Submission - Independent Pilots Association

Consecutive Night Duty Period - means two or more nighttime flight dutyperiods that are not separated by at least a Part 117.25 rest between theduty periods that encompasses a physiological night’s sleep (0100 to 0700)at home base or acclimated local time.II. We agree with the FAA that there should be a limit placed on consecutivenighttime flight duty periods. Nighttime operations should be limited to three nightsunless some type of strategy to mitigate fatigue is prospectively available to theflightcrew member. Science supports the fact that flight operations that impinge on theWOCL contribute to circadian fatigue and transient fatigue. Also, because daytime sleepis less restorative than nighttime sleep an individual accrues cumulative sleepdeprivation, which has a profound impact on fatigue. We strongly disagree with anyclaim that a flightcrew member can simply “train” themselves to sleep during the day,thus negating all known science regarding the human body’s need to sleep during theWOCL.In the Preamble of the NPRM the FAA acknowledges there may be adverse safetyimpacts by limiting nighttime operations to three consecutive nights. Unintendedconsequences of limiting nighttime operations to three consecutive nights increases thenumber of first night operations, which many pilots agree is the most difficult becausethey aren’t accustomed to being awake all night on the first night. The IPA agrees withthis assessment.The solution proposed by the FAA to allow more than three consecutive nighttime flightduty periods does not accommodate current flight operations at UPS. The opportunity torest during the flight duty period in accordance with 117.7 is a minimum of 4 hours,measured from the time the flightcrew member reaches the rest facility. While the IPAcan support mitigating fatigue by providing a rest opportunity, in reality there are veryfew of our flight operations that would meet these requirements.Science acknowledges that adequate sleep is required to sustain performance.Additionally, if a sleep debt is accrued the only way to eliminate the sleep debt is withrecovery sleep. By providing pilots an opportunity to maximize the amount of sleepobtained through an extended sleep opportunity the accumulation of significant chronicsleep debt may be avoided. We believe this strategy can be employed to permit a fourthconsecutive nighttime flight duty period so long as the flightcrew member receives aminimum of 12 hours of rest following each flight duty period.31