Submission - Independent Pilots Association

The proposed regulation (117.19 (c)(3)) provides for a two hour consecutive sleepopportunity for the flight crewmember manipulating the controls on landing. That sleepopportunity should be mandated for both required crewmembers at landing. Both crewmembersmanipulate the controls, i.e., the non-flying pilot normally operates flaps, landing gear and radiosand performs monitoring so he must be equally alert. This is especially important asaugmentation has the potential to significantly increase time on task. The final segment of anyaugmented flight must provide the required rest. During the most challenging approaches onshort final, both crewmembers are manipulating the controls and the manipulation of the flightcontrols transfers from one pilot to the other at about 300 feet. There are also other highworkload circumstances where both pilots are manipulating the controls such as when a landingmust be rejected or decision-making is required for diversion.117.21 Reserve StatusDue to overly complex language, we propose to rewrite section 117.21(c) as follows:(c)For short call reserve,(1) The maximum reserve duty period for un-augmented operations is defined as:74