Submission - Independent Pilots Association

(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