Submission - Independent Pilots Association

24-Hour LayoversWhile the IPA is supportive of the vast improvements in the current proposal we remainconcerned that 24-hour layovers and their disruption on sleep and circadian rhythmswas not addressed at all in the NPRM. This issue was discussed at length during theARC process and several different concepts to limit or restrict 24-hour layovers werepresented.Professional pilots overwhelmingly agree that a 24-hour layover presents manychallenges for a flightcrew member. The difficulty with 24-hour layovers is that thecrewmember has to get two sleep opportunities in one off duty period. Many pilots willconfirm that it is almost impossible to get one full sleep cycle, let alone two in a 24-hourperiod. The result is a circadian shift of the pilot’s “body clock” resulting in a sleepdeficit. This is especially true when flying internationally and an individual may not bepredisposed to sleep based on his circadian rhythms. The result of a lost sleepopportunity is that through no fault of his own the pilot would be significantly fatiguedprior to starting his duty period.Further compounding this sleep debt are multiple 24-hour layovers on consecutivedays. This results in a cumulative sleep debt and increased fatigue. The length of theduty period is irrelevant because the issue with 24-hour layovers is specific to theamount of rest an individual can obtain in the 24-hour off duty period. It is physicallyimpossible to obtain two full sleep cycles in a 24-hour period. The IPA suggests limitingflightcrew members to no more than two scheduled layovers between 18-30 hours in arolling 168 hours to prevent accumulated sleep debt. The IPA urges the FAA to revisitthe issue of 24-hour layovers when drafting the final rule.33