Submission - Independent Pilots Association

their reporting for flight duty. Such tracking would be difficult and costly for the certificateholder and constitute an unwarranted invasion of the personal privacy of the flight crewmember.The proposed provision, Section 117.5, provides a framework for educating and encouragingresponsible jointly managed commuting policies. The proposed 117.5 should be adopted aswritten. However, the accompanying Advisory Circular (AC 120-FIT) should be removed fromthe docket since the topic itself did not receive the same peer review and recommendations thatother aspects of the proposed rule received during the ARC process. The IPA notes the FAA haschosen to take a path that is significantly different from ARC recommendations, as this was onearea where all ARC members were in agreement. If it is the desire to continue down this path, allof the applicable stakeholders should have a similar opportunity to provide input in the processand a corresponding comment period following. We would recommend a process be set upwhere this occurs and would recommend an ARAC approach so that the problem is properlyidentified and jointly addressed.The IPA also agrees with the FAA’s decision to require that air carriers includeadministrative duties when calculating maximum cumulative duty limits. We suggest that forsubordinate officials who engage in administrative duties as well as flying, the FAA place a dutyperiod limitation of 65 hours a week, which cannot be increased. The rationale for thissuggestion is that allowing stakeholders to increase the limit past 65 hours within a 5 ¾ day 9period would have an adverse safety impact. Subordinate officials who have worked in an officeall day and report to fly a nighttime duty period will be more likely to be fatigued. They shouldbe held to the same limits of duty and rest as other flightcrew members. Failure to provide thesame limitations for these individuals will burden other flightcrew members with the additionaltask of monitoring the fatigue level of these individuals. Finally, the IPA maintains that carriersmust be responsible for tracking the time subordinate officials spend on administrative dutiesdutieswhich include answering e-mails at home and remaining on call at home for check airmanassignments from the certificate holder.The IPA supports the proposed rules. We do however note some areas of concern. Wehave included in our comments modifications to the rules, which we believe, if accepted, willprovide a framework to ensure the safety of our airways.9 Proposed Rule 117.25 (b) “Before beginning any reserve or flight duty period, a flightcrewmember must be given at least 30 consecutive hours free from all duty in any 168consecutive hour period…”7