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In testimony before the U.S. House Aviation Subcommittee later today, ALPA will
present its initial analysis of the FAA’s Notice of Proposed Rulemaking on
airline pilots’ flight- and duty-time limits and minimum rest requirements.
As you know, our union has long pursued modern, science-based flight- and
duty-time and minimum rest regulations that would apply to all airline pilots,
regardless of the size of the equipment they fly or whether they carry cargo or
passengers.
In 2007, Capt. Prater created a Blue Ribbon Panel on Pilot Fatigue to review
the science and recommend an action plan for the union. In 2009, ALPA adopted a
landmark pilot fatigue policy. Last year we co-chaired and were represented by
seven pilots on the FAA’s Flight and Duty Time Limitations and Rest Requirements
Aviation Rulemaking Committee.
ALPA is very pleased that the FAA has released a
regulatory proposal. Guided by ALPA’s policy, our union’s
Flight Time/Duty
Time Committee is carefully reviewing the NPRM. The committee includes ALPA
pilot safety experts from the range of Part 121 flying, including regional,
domestic, international, and cargo operations.
While ALPA looks forward to submitting our full comments to the FAA, the
FT/DT Committee offers some initial observations about the proposal. We are very
encouraged by many aspects.
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First, the proposal appears to apply scientific
principles and recognizes human physiological limitations with increased
minimum rest periods and more reasonable duty days, and recognizes the
effects of circadian rhythms on fatigue.
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The proposal applies to all FAR Part 121 flying
and would eliminate “carve-outs” for supplemental operations.
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It incorporates FAR Part 91 “tag on” or ferry
flights within flight- and duty-time limitations.
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The proposed rule requires fatigue education and
training on a recurring basis at all airlines and provides for
implementation of a fatigue risk management program.
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The NPRM mandates that all flight crewmembers
report rested and fit for duty and establishes that fitness for duty is a
joint responsibility of the flight crewmember and airline.
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The proposal requires airlines to accurately
record and set scheduled flight and duty periods based on actual operations
and to make adjustments if unreliable scheduling is used.
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It makes the decision to extend the duty period a
joint responsibility of the pilot in command and the airline, and further
limits the number of times the duty period may be extended for a flight
crew.
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The proposal also requires positioning of
crewmembers or deadheading to be counted as duty.
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And, finally, the NPRM specifically recognizes
reserve duty.
All these factors mark important progress. Our union has, however, found
several areas in its preliminary analysis in which the NPRM does not adequately
reflect the ARC’s recommendations.
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The NPRM does not ensure that the length and
quality of rest after a long-range flight across multiple time zones is
sufficient before the next flight and duty period.
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We have concerns that the application of the
augmented flight and duty period table will not adequately address the
circadian disruption that the flight crewmember may experience during
certain types of long-range flying.
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The proposal does not assess the effects of
increasing the amount of block time in a duty period up to 10 hours.
After staunch advocacy by ALPA and others, the FAA has developed a proposed
rule that has the potential to make significant improvements in flight and duty
regulations.
The law now requires the FAA to publish new pilot flight- and duty-time rules
no later than July 31, 2011. ALPA’s FT/DT Committee will submit our
association’s comments to the FAA and share them with the membership. We will
also track the agency’s progress toward meeting the 2011 deadline for a final
rule.
If you have comments about the proposed rule, please email
fatigue@alpa.org, and your input will be
forwarded on to the FT/DT Committee as input to consider when analyzing the
proposal and developing ALPA’s position. |
