Submission - Independent Pilots Association

(d)(1) (added) An unacclimated flightcrew member shall be given at least 12consecutive hours of rest beginning upon arrival at the rest facility beforebeginning a RAP or flight duty period.(e)(deleted) In the event of unforeseen circumstances, the pilot in command andcertificate holder may reduce the 9 consecutive hour rest period in paragraph (d) of thissection to 8 consecutive hours.Reduced rest should never be permitted. The science supporting reduced rest assumesa full sleep bank. 22 It strikes us that assuming a full sleep bank at any point in any FDPis a risky proposition. As a reduced rest period would in all likelihood follow an extendedFDP, it makes even less sense to consider reducing rest. We feel that the best policy isto consistently take the conservative route, especially when one considers the variationsin report time, daytime sleep, and the whole host of other factors that flightcrewmembers must deal with. Should the FAA persist in allowing reduced rest it is criticalthat this is not permitted in conjunction with an extension of a flight duty period beyondthe maximums in Table B.(f) (added) No certificate holder may schedule and no flightcrew member mayaccept an assignment for reserve or a flight duty period after completion of anyduty period(s) (flight or reserve) in a new theater unless the flightcrew member isgiven a rest period upon return to the flightcrew member’s home base location inaccordance Table F.(f)(1) (added) The recovery rest in Table F satisfies the requirements foracclimation and the flightcrew member would then enter Table B without apenalty.22 Id. at 18.28