Submission - Independent Pilots Association

Rationale: The term “nighttime flight duty” is not defined and to avoid confusion inapplying 117.27 we believe it should be defined. The Nighttime Flight Duty definition we haveused is the CAP 371 definition which we believe is scientifically correct.Rest Facility definition should include the following clarification:“A rest facility on an aircraft shall only be used for in-flight rest opportunities.”Rationale: This statement will eliminate any temptation to have crews obtaining theirPart 117.25 or Part 117.17 rest on the aircraft when it is on the ramp. A bunk or seat on anaircraft is simply not a suitable rest facility on the ground.Schedule Reliability – means the accuracy of the length of both a scheduled flightduty period and a scheduled flight segment as compared to the actual flight dutyperiod and segment.Rationale: This change in definition to include measurement of “flight segments” isnecessary for consistency with our proposed changes to 117.9 below.Suitable accommodation - means a single occupancy, facility with sound mitigationthat provides a crewmember with the ability to sleep in a bed and to control light.Rationale: Operational experience has demonstrated that a single occupancy room isrequired. Otherwise, disruptions such as the other person reading, watching TV, snoring, etc.,will disrupt the roommate’s rest.Theater - means a geographical area where local time at the crewmember’s flightduty period departure point and arrival point differ by no more than 4 time zonesor 60 degrees of longitude.Rationale: Theater is a term used in the proposed regulation and should be defined. 60degrees of longitude is necessary for those countries such as China which for political reasons isa single time zone.Unacclimated – A pilot becomes unacclimated if he has traveled to a location morethan 4 time zones or more than 60 degrees of longitude from the location at whichhe was last acclimated.65