Submission - Independent Pilots Association

aircraft.” In no case should augmented operations contain more than twosegments. The proposed chart in Table C to Part 117-Flight Duty Period:Augmented Operations is based on the TNO Report which only evaluated singleflight segment duty periods.Multi-leg augmentation should never be used solely for the purpose ofextending a flight duty period. A freshly rested flightcrew is always preferable to aflightcrew who has had a long duty period. Onboard rest is fragile and merely acountermeasure to mitigate fatigue and may not always be obtained due tofactors such as turbulence, time of day and readiness to sleep.Does it matter if each segment provides an opportunity for some rest?From the NPRM Preamble, “The proposed requirement for the 2-hour restopportunity on the last flight segment is designed to address a commonrecognition among the ARC members that, even on a flight with only twosegments, the last segment is often of such duration that there is no realistic restopportunity, even though this is when the crew is likely to be the most fatigued.”We agree and have recommended that the last flight provide an adequate sleepopportunity, two hours each for both pilots at the controls during approach andlanding, for a minimum segment length of six hours. In reality this mayoperationally allow a FDP containing a short flight, followed by a long flight. Insome cases this may preclude a rest opportunity on the first short flight. At notime should an operation consist of a long flight followed by a short flight.We recommend a 2-hour consecutive sleep opportunity for both requiredcrewmembers at landing. Both crewmembers manipulate the controls, i.e., thenon-flying pilot normally operates flaps, landing gear and radios and performsmonitoring duties so he must be equally alert. Much emphasis has been placedon the concept of crew resource management (CRM) and pilot monitoring duties.Also, there are circumstances such as Category III approaches where the pilotmonitoring might actually be the pilot landing. To deprive any of the operatingflightcrew members an in-flight rest opportunity would not help mitigate fatigueand violates the spirit and intent of augmented flight.16) Should flight time be limited to 16 hours maximum within an FDP, regardless of thenumber of flightcrew members aboard the aircraft, unless a carrier has an approvedFRMS?Yes, flight time should be limited to 16 hours maximum within an FDP.Anything beyond 16 hours should require FRMS50