Submission - Independent Pilots Association

More documents

Recommendations

Info

For this reason they engaged in litigation to overturn Whitlow. When that effort failed,the certificate holders implemented the interpretation with little or no impact on their operation.They adjusted their scheduling practices with minimal or no cost. It can be anticipated that thecertificate holders will take the same position on hard limits as they did with Whitlow. The skyis falling approach should be rejected. With the sophisticated scheduling programs and historicaldata available to certificate holders, the implementation of this provision should be accomplishedat minimal cost. Another reason these limits must remain hard is that the current protection forexceeding schedule, which is compensatory rest, is not included in this proposal. If Table Awere to be scheduled rather than actual flight time there would be no protection for fatiguecaused by the exceedances. We do recommend that Table A be modified to reflect theunanimous view of the ARC that the limit be 7 hours for the early morning hours and themajority view that it be 7 hours for the late evening hours.Likewise, the majority view was that the maximum limit should be 9 hours for the 0700-1259 time period, which is a 12.5 percent increase when compared to the current rule. Even ifcertificate holders have to “buffer” schedules, they will be in no worse position than they aretoday because of the changed limits. In most instances, they will receive a distinct advantagewith the increased flight limits.117.19 Flight Duty Period: Augmented FlightcrewWe propose the following amendments and additions to 117.19.Amend (c)(1) to read:117.19(c)(1) The final segment provides a minimum of 2 consecutive hours availablefor in-flight rest for both flightcrew members occupying a control seat duringlanding. (This would require a minimum segment length of 6 hours for a 3 pilotcrew and 3:45 for a 4 pilot crew to achieve the required rest).72
117.19(c)(3) deleted.117.19(d)(modified) No certificate holder may assign and no flightcrew member mayaccept an assignment involving more than 2 flight segments under this section unless thecertificate holder has an approved fatigue risk management system under §117.7Rationale: As an administrative matter, we have pointed out in our clarifying questionson the docket that Table C as published in the NPRM has an incorrect heading. The Tableheading needs to match Table B and the “Time of Start” should include home base or acclimatedlocal time.The NPRM proposed chart in Table C is based on the TNO Report. Upon a furtherreview of the TNO Report, we believe the proposed Table C was oversimplified in two regards.The first was that many of the values were oversimplified following a rounding process thatdoesn’t adequately represent the actual calculations used in the ARC process. The secondoversimplification is the use of a standard 30-minute reduction for a nonacclimatedcrewmember. The end result is an improper application of a nonacclimated penalty for theoperation planned. Additionally, just as is the case with the acclimated discussion, a table thatreflects the true values is better suited to accurately reflect the appropriate reduction for thecrewmember not being acclimated.Additionally, the TNO Report is intended for single segment operation only and theaddition of more than one additional segment would stray too far from the science on which thecharts were developed. Multi-leg augmentation should only be allowed when no crew change ispossible. Multi-leg augmentation should never be used solely for the purpose of extending aflight duty period. Augmented flights must not be mixed with non-augmented flights in the sameflight duty period.73
Page 1:
Submission of Comments on Flightcre
Page 4 and 5:
BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 7 and 8:
their reporting for flight duty. Su
Page 9 and 10:
The purpose of any FRMS is to ensur
Page 11 and 12:
(1)(modified) The carrier’s entir
Page 13 and 14:
II. We propose that Table A which s
Page 15 and 16:
IPA Proposes:Flight Duty Period: Ex
Page 17 and 18:
AcclimationIPA Proposes:I. Definiti
Page 19 and 20:
II.Acclimated Local Time - means th
Page 21 and 22: Revised Table D—Flight Duty Perio
Page 23 and 24: mitigate fatigue. This is especiall
Page 25 and 26: Note: For example: If the RAP start
Page 27 and 28: 117.25 Rest PeriodIPA Proposes:I. N
Page 29 and 30: Table F - Number of Local Nights fo
Page 31 and 32: Consecutive Night Duty Period - mea
Page 33 and 34: 24-Hour LayoversWhile the IPA is su
Page 35 and 36: 117.7 Fatigue Risk Management Syste
Page 37 and 38: 117.19 Flight duty period: Augmente
Page 39 and 40: *As an administrative matter, we ha
Page 41 and 42: 117.25 Rest Period(c)(deleted) No c
Page 43 and 44: 117.27 Consecutive nighttime operat
Page 45 and 46: As currently proposed the regulatio
Page 47 and 48: 8) Is a 36-hour break from duty suf
Page 49 and 50: data available to certificate holde
Page 51 and 52: 17) Should some level of credit be
Page 53 and 54: is more difficult than nighttime sl
Page 55 and 56: 31) The FAA seeks input on the appr
Page 57 and 58: IPA’s Response to Questions Posed
Page 59 and 60: 9) The FAA seeks input on a circums
Page 61 and 62: BEFORE THEU.S. DEPARTMENT OF TRANSP
Page 63 and 64: sleep according to a desired clock
Page 65 and 66: Rationale: The term “nighttime fl
Page 67 and 68: We would recommend a process set up
Page 69 and 70: FRMS must be based on a partnership
Page 71: Table A—Maximum Flight Time (Bloc
Page 75 and 76: Table E—Short Call Reserve Duty P
Page 77 and 78: departures. The pilot could then be
Page 79: No certificate holder may schedule
show all

Submission - Independent Pilots Association

Create successful ePaper yourself

Delete template?

Save as template?