Submission - Independent Pilots Association

is more difficult than nighttime sleep resulting in greater fatigue. Nighttimeoperations should be limited to 3 nights unless there is some sort of fatiguemitigation strategy.23) If the nighttime sleep opportunity is less than that contemplated under the split dutyprovisions of this notice, should a carrier be allowed to assign crew pairing sets inexcess of three consecutive nights? Why or why not?We agree with the FAA and science that consecutive nighttime dutyperiods contribute to sleep debt and increased fatigue. We also agree withscience that fatigue can be mitigated to some extent when a flightcrew member isgiven a sleep opportunity in a suitable accommodation. However, we do notbelieve this sleep opportunity mitigates the fatigue associated with an extendedflight duty period and should not be used to extend a flight duty period.24) If the nighttime sleep opportunity meets the split duty provisions of this notice,should the carrier be allowed to extend the flight duty period as well as the number ofconsecutive nighttime flight duty periods? Why or why not?No, the carrier should not be allowed to extend the flight duty period. TheFDP table was constructed based on acknowledging that duty during the WOCLcontributed to fatigue. The sleep opportunity afforded during split duty should beto mitigate fatigue not to extend a flight duty period.25) Should a fourth night of consecutive nighttime duty be permitted if the flightcrewmember is provided a 14-hour rest period between nights three and four?The FAA’s concept in the proposed rule to allow a fourth consecutivenighttime duty is better handled by requiring 12-hours of rest before eachnighttime duty period as recommended in the language proposed in thissubmission.26) Please comment on whether a 16 maximum hour FDP for long call reserve isappropriate when the maximum FDP for a lineholding flightcrew member is 13 hours.(See IPA comments regarding 117.21 Reserve Status)The FDP for a long call reserve should be 13-hours which is equivalent tothe maximum duty period as a lineholding flightcrew member. Since a long callreserve receives the same pre-duty rest as a line holder there is no rationale toassume he can work longer. The same physiological considerations should begiven to each flightcrew member regardless of his schedule status.53