Submission - Independent Pilots Association

FRMS must be based on a partnership approach for which there is agreement between theoperator, regulator and pilot body. As FRMS is a new emerging concept, a Memorandum ofUnderstanding between principle stakeholders should form the basis of initial agreement and bethe subject to on-going periodic review based on assessment of the effectiveness of the programin achieving its stated goals. The Memorandum of Understanding must include a mechanism forthe representatives of the stakeholding pilots to unilaterally suspend or terminate participation inthe operator’s FRMS in the event that the representatives of the stakeholding pilots determine intheir discretion that the FRMS program’s safety purpose is not being met.Pilot representatives, either from, where such a body exists, an established organizationindependent of the company, or where such a body does not exist, independently elected directlyby the pilots, must be included as members of the operator’s Fatigue Management SteeringGroup. This committee will be fully involved in the initial development of the FRMS program,and shall be fully and directly involved in the on-going oversight of the operator’s FRMSprogram including the development of modifications of the FRMS to meet the program’s safetypurpose.117.9 Schedule ReliabilityWe propose the following additions and changes to the Schedule Reliability section:117.9(a) Change 60 days to 30 days(a)(2)(modified) Any scheduled flight segment that is shown to actually exceedschedule 20 percent of the time.(b)(modified) Each certificate holder must submit a report detailing the schedulingreliability adjustments required in paragraphs (a) of this section to the FAA every69