ALPA has been trying to modernize the flight- and duty-time
regulations for nearly 25 years, working with Congress, the
Federal Aviation Administration, the International
Federation of Air Line Pilots’ Associations, and the
International Civil Aviation Organization to develop a model
FTDT rule. These efforts culminated in June when FAA
Administrator Randy Babbitt appointed members of labor,
industry, and government to the FAA Aviation Rulemaking
Committee. He charged the ARC with completing a
comprehensive review of the current flight-time and
duty-time regulations. During the past two months, seven ALPA pilots from cargo,
international, domestic, and regional airlines played a
critical role in the ARC, which completed its work on
September 1 with a group agreement to not release any
information concerning recommendations to the FAA so that
the agency could begin crafting a Notice for Proposed
Rulemaking (NPRM). ALPA honored the information blackout,
but other ARC participants chose to ignore it.
“While it remains our desire to not address any of the
information that has been recently leaked in
interviews to the press,” said Capt. Don Wykoff (Delta), who
co-chaired the ARC, “we do feel that it is now appropriate
for our members to review some of ALPA’s positions on these
issues as well.”
ALPA’s 6-point recommendation plan focused on securing
the following for our members: (1) one rule for all airline
pilots, not “carving out” the cargo and supplemental
operators; (2) a minimum 10-hour rest period; (3) a reserve
rest rule for all pilots; (4) having multiple segments and
circadian rhythm disruptions addressed; (5) establishing
limitations on duty periods, flight duty time, and block
time based on the fact that excessive working hours affect
flight safety; and (6) requiring the operator to prepare and
publish reliable schedules.
“We must have a single rule for all types of flying:
domestic, international, and supplemental,” said Capt. John
Prater, ALPA president. “There is no basis in science, nor
is there a true operational need, to have separate rules.”
ALPA’s recommendations, based on operational experience
and scientific study, incorporate ICAO and IFALPA guidelines
and represent a comprehensive framework, in concept and in
detail, of a flight- and duty-time and rest requirement
rule. The concepts within your union’s recommendation
demonstrate a scientific way of addressing both short-term
and cumulative (long-term) fatigue safeguards for all
operations.
Other concepts that ALPA addressed included a
non-punitive provision for pilots to be removed from flight
duties when they are fatigued, and a fatigue education
program. ALPA is also proposing the following block and
flight duty-time limits, as well as a 10-hour minimum rest.
Maximum Flight Time (Block) Limits:
Time of Report (Home Base)
|
Maximum Flight Time (hours) |
0000–0459 |
7 |
0500–0659 |
8 |
0700–1259 |
9 |
1300–1959 |
8 |
2000–2359 |
7 |
Flight Duty Period: Non-augmented Operations
Time of Report (Home Base or
Acclimated) |
Maximum Flight Duty Period
(hours) for Lineholders Based on
Number of Flight Segments
|
1 |
2 |
3 |
4 |
5 |
6 |
7+ |
0000–0359 |
9
|
9
|
9
|
9
|
9
|
9
|
9 |
0400–0459 |
10
|
10
|
9
|
9
|
9
|
9
|
9 |
0500–0559 |
11
|
11
|
11
|
11
|
10
|
9.5 |
9 |
0600–0659 |
12
|
12
|
12
|
12
|
11.5 |
11
|
10.5 |
0700–1259 |
13
|
13
|
13
|
13
|
12.5 |
12
|
11 |
1300–1659 |
12
|
12
|
12
|
12
|
11.5 |
11
|
10.5 |
1700–2159 |
11
|
11
|
10
|
10
|
9.5 |
9
|
9 |
2200–2259 |
10.5 |
10.5 |
9.5 |
9.5 |
9
|
9
|
9 |
2300–2359 |
9.5 |
9.5 |
9
|
9
|
9
|
9
|
9 |
While the ARC has submitted a report to the FAA
administrator as the next step in the process toward issuing
a Notice for Proposed Rule Making, several important steps
remain in the process to create new flight-time and
duty-time regulations, including putting the proposed rule
out for public comment. The NPRM is expected to be published
by the end of the year, according to statements made by
Babbitt. ALPA will remain fully engaged in the process, and
we will keep you updated on any further developments. |