Submission - Independent Pilots Association

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117.9 Schedule ReliabilityThe IPA proposes the following changes:Schedule reliability – means the accuracy of the length of both a scheduled flightduty period and a scheduled flight segment as compared to the actual flightduty period and segment.This change in definition to include measurement of “flight segments” is necessary forconsistency with our proposed changes to 117.9.§ 117.9(a) Change 60 days to 30 days(a)(1)(modified) Its system-wide flight duty periods if the total actual flight dutyperiods exceed the scheduled flight duty periods by more than 15 minutesmore than 5 percent of the time, and(a)(2)(modified) Any scheduled flight segment that is shown to actually exceedthe schedule 20 percent of the time.(b)(modified) Each certificate holder must submit a report detailing thescheduling reliability adjustments required in paragraph (a) of this section to theFAA every 30 days detailing both overall schedule reliability and flight segmentreliability. <strong>Submission</strong>s must consist of:10
(1)(modified) The carrier’s entire FDP schedule for the previous 30 dayperiod and separately those FDP’s exceeding the scheduled FDP by 15minutes.(2)(modified) The carrier’s flight segments on a per segment basis and thelist of those segments exceeding the 20 percent requirement in (a)(2).These proposed amendments accomplish two changes to the proposed rule. First, thereporting period is 30 days rather than 60 days and second, a flight segment reliabilityrequirement is added.If a schedule exceeds the limits in this section the certificate holder should take promptaction to correct the schedule. A certificate holder should not be allowed to operate aschedule that violates the scheduling limitations for 60 days. With the sophisticatedcomputerized scheduling programs available and used by most, if not all certificateholders, a 30 day reporting period is neither unreasonable nor burdensome. Thecertificate holder should correct any schedule exceedance at the point the certificateholder becomes aware that the schedule does not meet the scheduling limitations.To achieve schedule reliability the individual flight segments must be considered. If agiven segment within a FDP causes the FDP to exceed the limits, the certificate holdercan merely leave the offending segment and change the pairing mix to hide the problemand/or bring it within limits. The problem segment would never be corrected. We believethat a scheduling metric must be included in 117.9. Certificate holders now provide ontimereports to the DOT on an individual flight segment so this should not be aburdensome requirement and we have incorporated the familiar 15 minute buffer metricfor the FDP reporting criteria.Finally, the reporting information should be available in a timely manner to allstakeholders and the public.11
Page 1: Submission of Comments on Flightcre
Page 4 and 5: BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 7 and 8: their reporting for flight duty. Su
Page 9: The purpose of any FRMS is to ensur
Page 13 and 14: II. We propose that Table A which s
Page 15 and 16: IPA Proposes:Flight Duty Period: Ex
Page 17 and 18: AcclimationIPA Proposes:I. Definiti
Page 19 and 20: II.Acclimated Local Time - means th
Page 21 and 22: Revised Table D—Flight Duty Perio
Page 23 and 24: mitigate fatigue. This is especiall
Page 25 and 26: Note: For example: If the RAP start
Page 27 and 28: 117.25 Rest PeriodIPA Proposes:I. N
Page 29 and 30: Table F - Number of Local Nights fo
Page 31 and 32: Consecutive Night Duty Period - mea
Page 33 and 34: 24-Hour LayoversWhile the IPA is su
Page 35 and 36: 117.7 Fatigue Risk Management Syste
Page 37 and 38: 117.19 Flight duty period: Augmente
Page 39 and 40: *As an administrative matter, we ha
Page 41 and 42: 117.25 Rest Period(c)(deleted) No c
Page 43 and 44: 117.27 Consecutive nighttime operat
Page 45 and 46: As currently proposed the regulatio
Page 47 and 48: 8) Is a 36-hour break from duty suf
Page 49 and 50: data available to certificate holde
Page 51 and 52: 17) Should some level of credit be
Page 53 and 54: is more difficult than nighttime sl
Page 55 and 56: 31) The FAA seeks input on the appr
Page 57 and 58: IPA’s Response to Questions Posed
Page 59 and 60: 9) The FAA seeks input on a circums
Page 61 and 62:
BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 63 and 64:
sleep according to a desired clock
Page 65 and 66:
Rationale: The term “nighttime fl
Page 67 and 68:
We would recommend a process set up
Page 69 and 70:
FRMS must be based on a partnership
Page 71 and 72:
Table A—Maximum Flight Time (Bloc
Page 73 and 74:
117.19(c)(3) deleted.117.19(d)(modi
Page 75 and 76:
Table E—Short Call Reserve Duty P
Page 77 and 78:
departures. The pilot could then be
Page 79:
No certificate holder may schedule
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Submission - Independent Pilots Association

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