Submission - Independent Pilots Association

117.25 Rest PeriodIPA Proposes:I. No Reduction in Minimum Rest PeriodII.III.Minimum Rest Period of 10 hours or 12 HoursUnacclimated in a New TheaterRecovery Rest Return to Home Base________________________________________________________________The IPA proposes the following changes:(c) (deleted) No certificate holder may reduce a rest period more than once in any168 consecutive hour period.(d)No certificate holder may schedule and no flightcrew member may accept anassignment for reserve or a flight duty period unless the flightcrew member is given arest period of at least 9 10 consecutive hours before beginning the reserve or flight dutyperiod measured from the time the flightcrew member reaches the hotel or othersuitable accommodation.According the FAA’s own Fitness for Duty Advisory Circular, AC120-FIT: “Managingrest is the means for managing the risk of being unfit for duty because of fatigue. This isthe joint responsibility of the air carrier and the crewmember. It’s unrealistic to assumethat a 9-hour rest period will yield nine or even eight hours of sleep by the crewmember.The reality is that a 9-hour rest period may yield seven hours of sleep when you takeinto consideration the time lost in checking in at a hotel, eating, and preparing to resumeduty at the conclusion of the sleep opportunity.” We believe that a 10-hour rest periodstarting at the rest facility is the minimum period of time that will allow the scientificallymandated eight hours of sleep. 2121 Battelle, supra note 16 at 18.27