Submission - Independent Pilots Association

weather events such as a blizzard in Newark that cripples the entire northeast or anunforecast March ice storm in Memphis. As further discussed in the Preamble, “Thus,while the FAA contemplates that adverse weather could fit within the criteria because itis beyond the control of the certificate holder, it would not always be consideredunforeseeable. Carriers should anticipate thunderstorms in many parts of the UnitedStates during the summer months. Likewise, heavy snow in the northern parts of thecountry should be anticipated during the winter, and the jet stream follows basicseasonal patterns.” 14 We do not believe circumstances based strictly on economicbusiness consideration, inadequate staffing or poor schedule planning qualify as beingbeyond the control of the certificate holder.We are concerned that some submitters may propose allowing an extension of a FDPbeyond the maximum limits in Table B. Any extension to a scheduled FDP must takeinto account the amount of sleep a flightcrew member has had during the last restperiod, as well as any accumulated sleep debt. For example, a flightcrew member couldshow at 1200 for a scheduled 8:00 hour FDP ending at 2000 expecting the followingFDP to start the next day at 0700. Extending the FDP to the charted maximum of 13:00(ending at 0100) is over a 60% increase from scheduled duty. Extending the FDP to themaximum plus two hours (15:00 hours ending at 0300) is almost a 90% increase fromscheduled duty. If the flightcrew member awoke at 0600 prior to the start of the FDP(expecting to get off duty at 2000 the same evening), when getting off duty at 0300 hewould have been awake for 21 hours. Science has drawn the correlation between timeawake and blood alcohol content (BAC). Twenty-one hours awake closely mimics themental acuity of a BAC of .08. 15 While some operations could be scheduled with alonger FDP, prospective rest opportunities must be taken into account, not future makeuprest opportunities. 16 Additionally consideration must be given to other factors suchas number of legs, time of day, previous flight duty periods and environmental factors asthe interactions between multiple fatigue-related factors contribute to fatigue buildup.We also apply the same rationale to FDP extensions to 117.19 Flight Duty Period:Augmented flightcrew. As currently proposed the rule does not provide greater restopportunities for augmented operations, as well as the consensus opinion that restduring flight cannot be guaranteed. Therefore, the 2-hour extension should remain thesame for augmented operations.We propose the following amendment to 117.19:117.19(f)(1)(modified) The pilot in command and certificate holder may extend a flightduty period beyond the scheduled flight duty period up to 3 2 hours.14 Id.15 Drew Dawson and Kathryn Reid. Fatigue, Alcohol and Performance Impairment, 388Nature 235 (1997).16 An Overview of the Scientific Literature Concerning Fatigue, Sleep, and the CircadianCycle (Battelle Memorial Institute, Frederick Md.) January 1998 at 1316