Submission - Independent Pilots Association

sleep according to a desired clock position. The crews’ circadian phase will be the keydeterminingfactor as to when and how long crews will subsequently sleep. In a 36 hour restsituation, crews could have only one full sleep cycle in their physiological nadir and if that fallsearly in the layover rest period, they would initially sleep, then be awake for an extended periodbefore reporting for duty. At that point, the pilots, through no fault of their own, would besignificantly fatigued after being awake for 12 to 15 hours prior to starting their duty period.We believe that the regulation should require 3 local nights rest. However, during thefirst 72 hours in theater, measured from the time of first arrival, a 36 hour rest within the 72hours may allow a flight crewmember to become acclimated. Merely being in theater for a 72hour period without at least 36 consecutive hours rest during that time would not allow a personto become acclimated. It is necessary to have both time in theater and adequate rest to becomeacclimated. The preamble to the proposed regulation states that the tables selected from the ARCwere in part based on being the most conservative approach. The wide range of availableresearch on the topic of acclimation, combined with operational experience, clearly supports amore conservative approach of 72 hours in theatre with 36 hours free of duty to consider thecrew acclimated.Acclimated Local Time - means the local time at the location where the pilot lasthad greater than 36 hours free from duty in the first 72 hours in theater.Rationale: This definition provides an unambiguous time for applying the definition ofNighttime Duty Period and for entering the FDP and Flight Time limit tables. The originalNPRM wording of “acclimated or home base” time left many questions of interpretation. Forexample, a USA based pilot who acclimates in Europe and then subsequently flies to Japanwould, under the current wording, enter the tables at Home Base time instead of Europe time.Similarly, the exact location of acclimation must be known to determine future loss of63