Submission - Independent Pilots Association

Note 2: When the elapsed time away from home base is less than 60 hours onelocal night’s recovery rest should be provided on return to base, except when thereturning flight duty period encroaches the WOCL, then an additional local nightsrest will be added.Rationale: A flight from the U.S. to Europe or Asia disrupts the circadian cycle and a restof 9 hours is not sufficient to achieve an appropriate level of alertness. However, when flightcrewmembers fly to a new theater they should be given at least 12 hours at a suitableaccommodation between all duty periods until they become acclimated to the new theater inaccordance with 117.25 or return to home base.Where crew members are not acclimated, upon return to home base, a recovery periodshould be provided that ensures a crew member’s body clock has recovered to home base localtime before the start of the next duty. The time necessary to ensure complete recovery of thecircadian rhythm varies as a function of the elapsed time away from home base and themaximum time difference from home base. Table F can be used to determine the number oflocal nights required to readapt within an hour of home base.We also believe that there should be recovery rest for time away from home whenoperating flights in a different theater that is less than 168 hours away from home base. Thecurrent regulations provide for recovery rest in international operations for operations less than a168 consecutive hours period. See 121.483, 485; 121.523, 525We believe that this recovery rest is necessary to address cumulative fatigue, to providecircadian restabilization and to repay accumulated sleep debt. We therefore propose the recoveryrest chart (Table F) be incorporated into the final rule.117.27 Consecutive Nighttime OperationsWe propose the following amendment:78