Submission - Independent Pilots Association

27) Please comment on whether the proposed maximum extended FDP of 22 hours foran augmented flightcrew member is appropriate. If not, please provide an alternativemaximum FDP.The proposed maximum extended FDP of 22 hours is not appropriate. Themaximum proposed FDP should be the maximum FDP 18 hours.28) Please comment on whether a certificate holder should receive credit for not callinga flightcrew member during the WOCL while on reserve.Yes. If all or a portion of a reserve flightcrew member’s reserve availabilityperiod falls between 0000 and 0600, the air carrier may increase the maximumreserve duty period by one-half of the length of the time during the reserveavailability period in which the air carrier has not contacted the flightcrewmember, not to exceed 3 hours. However, the maximum reserve duty period maynot exceed 16 hours. This credit will only be calculated for the time during 0000-0600 before the flightcrew member was contacted. In both the ARC and the NPRMpreamble, the intent was expressed that RAP extension credit is to be madeavailable for not contacting reserves between 0000 and 0600 whose RAP’s touchthat time period. However, the proposed language in 117.21(c)(4) (iv) and117.21(c)(5)(iii) neglects this distinction, providing credit for any period of noncontact.29) Should minimum required rest while on reserve status be greater than the amountof rest required for a lineholding flightcrew member? If so, please provide supportingdata, if not, please provide rationale.No, minimum rest for reserve and a line holder should be the same toprovide an equivalent level of safety.30) Please comment on the level of complexity on the proposed reserve system.The short call reserve section is complex and we are concerned that theremay be misunderstanding by flightcrew members, scheduler and managementofficials as currently written. Consistent with other limitations in the proposal, webelieve a chart is a better way to set forth the short call reserve limits expressedin the proposal. We urge that the chart contained in our comments that sets forththe short call reserve limits be adopted. (See IPA Comments regarding 117.21Reserve Status)54