Submission - Independent Pilots Association

Rationale: The NPRM references “unacclimated” in several sections of the proposedregulation but does not define the term. We believe it should be defined. Defining acclimationin terms of “time zones” is subject to whim of governmental policy, (e.g., all of China is in asingle time zone even though it spans 5 normal time zones in width). 60 degrees of longitude isequivalent to 4 normal time zones and should be included as a supplement to the time zonemetric.117.5 Fitness for DutyWe support the concept that a flight crewmember must be fit for duty prior to operatingan aircraft. The fitness for duty is and must be a joint responsibility of the certificate holder andthe flight crewmember. While it is important that both the flight crewmember and the certificateholder be involved in fit for duty determinations, we cannot create an environment that requirestracking and reporting the activities of an individual flight crewmember prior to their reportingfor flight duty. Such tracking would be difficult, costly and impractical for the certificate holderto administer and would constitute an unwarranted invasion of the personal privacy of the flightcrewmember. The proposed provision provides a framework for educating and encouragingresponsible jointly-managed commuting policies. The proposed 117.5 should be adopted aswritten and the accompanying Advisory Circular (AC 120-FIT) should be removed from thedocket, as the topic itself was not exposed to the same peer review and recommendations thatother aspects of the proposed rule were during the ARC process. The FAA took a path in AC120-FIT significantly different from ARC recommendations. If it is the desire to continue downthis path, all of the applicable stakeholders should have a similar opportunity to provide input inthe process and a corresponding comment period should follow separate from this rulemaking.66