Submission - Independent Pilots Association

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(4) If all or a portion of a reserve flightcrew member’s reserve availabilityperiod falls between 0000 and 0600, the air carrier may increase themaximum reserve duty period in table E by one-half of the length of the timeduring the reserve availability period of 0000-0600 in which the air carrierdid not contact the flightcrew member, not to exceed 3 hours; however, themaximum reserve duty period may not exceed 16 hours. If the flightcrewmember is contacted for an assignment prior to 0000 hours the reserveduty period would not be extended.Note: For example, RAP starts at 2200 hours, pilot called at 0300 for flightassignment, the RAP may be extended by 1.5 hours. If the pilot was called prior to0000 hours there would be no extension.Rationale: The short call reserve section is complex and we are concerned that there willbe misunderstanding by flight crewmembers, schedulers and management officials with thesection as written. Consistent with other limitations in the proposal, we believe a chart is a betterway to set forth the short call reserve limits expressed in the proposal. We urge that the chartthat sets forth the short call reserve limits be adopted. In both the ARC and the NPRM preamble,the intent was expressed that RAP extension credit is to be made available for not contactingreserves between 0000 and 0600 whose RAP’s touch that time period. However, the proposedlanguage in 117.21(c)(4) (iv) and 117.21(c)(5)(iii) neglects this distinction, providing credit forany period of non-contact. This error in the language has been corrected in our revised languagein (4) above.(5) No certificate holder may schedule and no reserve flightcrew member onshort call reserve may accept an assignment of a flight duty period that beginsbefore the flightcrew member’s next reserve availability period unless theflightcrew member is given at least 14 hours rest. This provision may be usedonly once in a rolling 168 hour period.Rationale: The need for this provision is best illustrated by real world examples. A pilot isscheduled and adjusts his rest schedule for a series of RAPs beginning at 0400. If the operatorcontacts the pilot at 0600 (after the morning bank of departures) and releases the pilot for a 14hour rest period, the pilot could then begin a RAP at 2000 to cover the late evening bank of76
departures. The pilot could then be contacted at 2200 and released for another 14 hour restperiod. This cycle could continue for an indefinite period. Our proposal aligns this section withthe provision for shifting of a RAP in section (e). Without this provision there is essentially nodifference between a short-call and long-call reserve removing all circadian protection affordedby having a RAP system in the first place.117.25 RestThe following changes are proposed:(d)(1) (added) An unacclimated flight crewmember shall be given at least 12consecutive hours of rest beginning upon arrival at the rest facility before beginninga RAP or flight duty period.(f) (added) No certificate holder may schedule and no flightcrew member may acceptan assignment for reserve or a flight duty period after completion of any dutyperiod(s) (flight or reserve) in a new theater unless the flightcrew member is given arest period upon return to the flightcrew members home base location inaccordance with Table F.(f)(1)(added) The recovery rest in Table F satisfies the requirements for acclimationand the flight crewmember would then enter Table (B) without a penalty.Table F – Number of Local Nights for Recovery on Return to Home BaseElapsed Maximum Time Difference from Home Base (h)Time SinceLeavingHome base(h)4 5 6 7 8-9 10-12+60-84h 1* 2* 2* 2* 2* 384-108h 2* 2* 3 3 3 3108-132h 3 3 3 3 3 3132-156h 3 3 3 3 3 3156+h 3 3 3 3 3 3Note 1: The values in Table F refer to eastward transitions (eastward outbound/westward homebound) only. * denotes that for westward transitions (westwardoutbound/eastward homebound) one extra day is required to be added to the valuedepicted.77
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Submission of Comments on Flightcre
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BEFORE THEU.S. DEPARTMENT OF TRANSP
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their reporting for flight duty. Su
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The purpose of any FRMS is to ensur
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(1)(modified) The carrier’s entir
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II. We propose that Table A which s
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IPA Proposes:Flight Duty Period: Ex
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AcclimationIPA Proposes:I. Definiti
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II.Acclimated Local Time - means th
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Revised Table D—Flight Duty Perio
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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 and 72: Table A—Maximum Flight Time (Bloc
Page 73 and 74: 117.19(c)(3) deleted.117.19(d)(modi
Page 75: Table E—Short Call Reserve Duty P
Page 79: No certificate holder may schedule
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Submission - Independent Pilots Association

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