Submission - Independent Pilots Association

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2. While three consecutive physiological nights may start approaching a reasonablecompromise for the purpose of entering the FDP tables, a 36-hour rest clearlywould not. In order for the rules to approach parity, the implication is that a nightof normal sleep would be approximately 8-9 hours of sleep. Three nights ofconsecutive sleep would be 24-27 hours of sleep. The 36-hour rule suggests thatcrews would remain asleep for nearly the entire layover period. This is notphysiologically plausible for healthy aircrews.3. Further, it is critical for any fatigue safety regulation to assess where a flightcrewmember is in their own circadian cycle – as that will determine when in thefollowing rest periods they will be able and likely to sleep from a physiologicalperspective. To be sure, being put into a rest cycle does not mean that the crewwill be able to sleep according to a desired clock position. The Crews’ circadianphase will be the key-determining factor as to when and how long crews willsubsequently sleep. In a 36 hour rest situation, crews could have only one fullsleep cycle in their physiological nadir and if that falls early in the layover restperiod, they would initially sleep, then be awake for an extended period beforereporting for duty. At that point, the pilot, through no fault of their own, would besignificantly fatigued after being awake for 12 or 15 hours prior to start their dutyperiod.While everyone expects crews to be professional and report fit and rested for their flyingduties, it would unfair if they rested when they were physiologically and predictably tiredand then awake when they physiologically were unable to easily sleep andsubsequently had to report to duty more fatigued then when they started.The IPA believes that the regulation should require 3 local nights rest. However, 72hours in theater in conjunction with a 36 hour rest within the 72 hours may allow a flightcrewmember to become acclimated. Merely being in theater for a 72-hour periodwithout at least a 36 consecutive hours rest during that time would not allow a person tobecome acclimated. It is necessary to have both time in theater and adequate rest tobecome acclimated.The preamble to the proposed regulation states that the tables selected from the ARCwere in part based on being the most conservative approach. Given the wide range ofavailable research on the topic of acclimation combined with the operationalconsequences of not taking a correct approach clearly points to selecting a moreconservative approach. We believe 72 hours in theater comprising 36 hours free of dutyas the compromise position in determining if a crew is acclimated for the purposed ofdetermining the length of the subsequent FDP.Lauber, Sleep/Wakefulness Management in Continuous/ Sustained Operations, 61 AviationSpace Envtl. Med. (1989) 733-743.18
II.Acclimated Local Time - means the local time at the location where theflightcrew member last had greater than 36 hours free from duty in the first72 hours in theater.This definition provides an unambiguous time for applying the definition of NighttimeDuty Period and for entering the FDP and Flight Time limit tables. The original NPRMwording of “acclimated or home base” time left many questions of interpretation.Similarly, the exact location of acclimation must be known to determine future loss ofacclimation. For example, a pilot flies to Paris and has 37 hours off, but at the end of his72 hours in theater happens to be 3 more hours east at Tel Aviv. He is now acclimated,but where? Would a further flight two more hours east to Dubai cause him to beunacclimated? It depends whether you define the point of acclimation as being tied tothe 36-hour rest or to the 72 hours in theater condition. The above-proposed definitionremoves such doubts about the location of acclimation and the use of regulation tables,allowing reliable computer programming of scheduling. Both the tables and thedefinition of Nighttime Duty Period should then use the new term, “Acclimated LocalTime”.III.Unacclimated – A flightcrew member becomes unacclimated if he hastraveled to a location more than 4 times zones or more than 60 degrees oflongitude from the location at which he was last acclimated.The NPRM references “unacclimated” in several sections of the proposed regulation butdoes not define the term. We believe it should be defined. Defining acclimation in termsof “time zones” is subject to whim of governmental policy, (e.g., all of China is in a singletime zone even though it spans 5 normal time zones in width) 60 degrees of longitude isequivalent to 4 normal time zones and should be included as an alternative to the timezone metric.IV.Theater (amended): means a geographical area where local time at thecrewmember’s flight duty period departure point and arrival point differ by nomore than 4 time zones, or 60 degrees of longitude.19
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 and 10: The purpose of any FRMS is to ensur
Page 11 and 12: (1)(modified) The carrier’s entir
Page 13 and 14: II. We propose that Table A which s
Page 15 and 16: IPA Proposes:Flight Duty Period: Ex
Page 17: AcclimationIPA Proposes:I. Definiti
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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