Submission - Independent Pilots Association

8) Is a 36-hour break from duty sufficient for an individual to acclimate to a new theater?As discussed in question #7, a minimum 36-hour break from duty issufficient for an individual to acclimate to a new theater only if that individual hasbeen in that theater for 72-hours. The IPA agrees with the FAA that the 36-hourbreak should be predicated on actual time and not scheduled time.9) Should flightcrew members be given a longer rest period when returning to homebase than would otherwise be provided based on moving to a new theater? (See IPAcomments regarding 117.25 Rest Period)Yes. We have proposed a modification to Section 117.25 to provide a tablefor recovery rest on return to home base. This concept is contained in numerousinternational regulations and current FAA regulations.10) Should the FAA have different requirements for flightcrew members who have beenaway from their home base for more than 168 hours? If so, why?Yes, these flightcrew members may have crossed multiple times zones andoperated with irregular duty hours over the course of the week resulting incircadian disruptions. Additionally, many of these types of pairings haveconsecutive or multiple 24-hour layovers resulting in cumulative sleep debt.Extended recovery sleep is necessary to fully restore the individuals sleepreservoir and recover from the effects of cumulative and transient fatigue.We also believe that there should be recovery rest for time away from homeoperating flights in a different theater that is less than 168 hours. The currentregulations provide for recovery rest in international operations for operationsless than a 168 consecutive hours period. See FAR 121.483, 121.485, 121.523,121.52511) Should the FAA require additional rest opportunities for multiple pairings betweentwo time zones that have approximately 24-hour layovers at each destination? What ifthe scheduled FDPs are well within the maxima in the applicable FDP table oraugmentation table? (See IPA comments regarding 24-hour Layovers)Yes, rest needs to be adjusted and multiple 24-hour layovers should belimited on consecutive days and on a weekly basis. The difficulty with 24-hourlayovers is the crewmember has to get two sleep opportunities in one off dutyperiod, which results in a circadian shift of the pilot’s “body clock” resulting in asleep debt. Further compounding this sleep debt are multiple 24-hour layovers on47