Submission - Independent Pilots Association

Table A—Maximum Flight Time (Block) LimitsTime of Report(Home Base orAcclimatedLocal Time)MaximumFlight Time(hours)0000-0459 70500-0659 80700-1259 91300-1959 82000-2359 7Rationale: The flight time limits must be “hard” and not scheduled for several reasons.Foremost, the most frequently abused provision of the current rules is the “scheduled flightlimitation provision.” Certificate holders consistently schedule to the limit, i.e., 7:59 or 7:55,even when they know in advance that the flight on a given day will not meet the scheduled timebecause of winds or ATC delays at busy airports. In practice, many of these schedules exceed 8hours by 45 minutes or more.The hard limits would be applied like “Whitlow” is with the 16 hours duty limit. As theFAA and others will recall, in 2001 the certificate holders resisted Whitlow on the grounds thatthe cost would put certificate holders out of business. We anticipate the same approach to thisNPRM. In their request to stay enforcement of Whitlow, the RAA stated that the Whitlowinterpretation would “bring about the demise of smaller carriers.” They would be required tohire numerous flight crewmembers and the cost would mean elimination of service to smallercities. Likewise, the ATA complained that enforcement of Whitlow would inconvenience thetraveling public as their members would have to delay and cancel flights. Additionally, the ATAcarriers would be subjected to having to hire many additional flight crewmembers incurringtremendous costs for salaries, benefits and training.71