Submission - Independent Pilots Association

may be required to overcome the affects of sleep inertia, the option ofwaking up a sleeping qualified flightcrew member during a time criticalemergency is ineffective. Integrity of augmented crew for the entire FDP isessential.6) Should short call reserve count as duty?Yes. The agency has consistently interpreted reserve duty to be a presentresponsibility for duty. In our view, that is tantamount to duty. The flightcrewmember is restricted in his/her activities and must be prepared toperform flight duty when called on short notice. We agree that flightcrewmembers in reserve status can acclimate just as any other flightcrewmember.7) Can a certificate holder assign additional duty time if there is no additional FDPcontemplated for the relevant time period?No. An extreme example would be the completion of a 18-hour augmentedflight duty period followed by an immediate scheduling of an 8-hourtraining period. The level of cumulative fatigue without an intervening restperiod is unacceptable. Any duty (FDP, reserve, training) performed onbehalf of the carrier should require the appropriate minimum rest periodbefore beginning the duty period. We believe that the cumulative dutyperiods should apply as written. The consecutive duty limits apply tocrewmembers that do fly and these limits are necessary to assure alertnessover a longer period of time. Also, the “implied 16 hour duty day” as statedin the Preamble should be part of the regulatory scheme. If a managementor other pilot wants to work excessive hours performing administrativeduties, he or she should relinquish flight duties.8) Does Union work count as administrative time?Yes, however the difficulty is that the work is not performed for thecertificate holder, not required to be reported to the certificate holder, isdifficult to track and even more difficult for the FAA to oversee. Anindividual performing administrative time for the carrier has a defined workschedule easily monitored by the carrier. As previously stated within thefindings it is incumbent upon all flight deck crewmembers to ensure theyare adequately rested prior to reporting for any flight deck duty period. Notonly would this apply to those who would be engaged in laborrepresentative activities but any other activity outside of that associatedwith the flight deck duty period. This concept is covered within therequirement to report fit for duty.58