Submission - Independent Pilots Association

31) The FAA seeks input on the appropriate cumulative limits to place on duty, flightduty periods and flight time. Is there a need for all the proposed limits?Yes, the proposed cumulative duty and flight time limits need to beretained as proposed. Just as the certificate holder tracks flight time and flightduty periods, administrative duties should also be tracked. Administrative dutiesinclude any duty required by the certificate holder and counts towards daily andcumulative duty limits just as short call reserve does.32) The FAA also asks for comments on measuring limits on an hourly rather than dailyor monthly basis. Does this approach make sense for some time periods but not forothers?Hourly limits make sense for daily and weekly limits, but monthly limitsshould be based on 28 calendar days. Annual limits should also be based oncalendar days.33) If transportation is not considered part of the mandatory rest period, is there a needfor a longer rest period for international flights?Yes, we recommend 12-hours as a minimum. Crossing multiple times, anindividual’s readiness to sleep, circadian de-synchronization and wrong time ofthe day for sleep are all factors impacting fatigue when flying internationally. (SeeIPA Comments regarding 117.25 Rest Period)34) Whether some elements of an FRMS, such as an incident reporting system,would be better addressed through a voluntary disclosure program than through aregulatory mandate? (See IPA Comments regarding 117.7 FRMS)We strongly support the introduction of FRMS in the U.S. Aviation System. Wedo, however, believe that Section 117.7(b) needs to be amended to include thefollowing items:• The FRMS must be an equal partnership that includes the FAA, thecertificate holder and non-management pilot representative.• FRMS does not replace the regulatory scheme; its purpose is tosupplement adequate prescriptive rules.• Any FRMS must provide an equivalent or better level of safety and becentrally approved by the FAA. (One office at FAA headquarters should beresponsible for approving FRMS. This is the only way to provide a uniformFRMS approval scheme.)55