In a Federal Aviation Administration analysis of its new airline pilot fatigue rules, the administration has seriously overestimated the cost, and undervalued the benefits, of applying the flight- and duty-time restrictions and minimum rest requirements to all-cargo pilots, according to the Air Line Pilots Association, Int’l.

“When realistic costing is applied and the benefits to pilots’ health are considered, an investment far less than what the FAA estimates would be required to bring all airline pilots under one set of fatigue regulations, regardless of whether they fly passengers or cargo in their aircraft,” said Capt. Lee Moak, ALPA’s president.

In comments to the Initial Supplemental Regulatory Analysis of the FAA’s final pilot fatigue rule, ALPA, the world’s largest independent aviation safety organization, makes clear that the FAA’s benefit costing is arbitrary and incomplete. For example:

• The FAA’s selection of the Boeing 727 aircraft is an invalid basis for the analysis. The B-727 is being phased out by U.S. cargo carriers, with less than 3 percent of the U.S. cargo fleet analyzed by ALPA currently consisting of B-727s. As a result, any future cargo accident would likely involve a larger, heavier aircraft that can carry much larger cargo loads and fly much greater distances, and the FAA’s analysis vastly undervalues the monetary effects of not covering all-cargo pilots.

• The FAA fails to take health benefits to pilots into account. The FAA’s own analysis concludes that the final rule would reduce fatigue-related flight crew payroll costs by 0.25 percent, resulting in $4.4 million in annual cost savings for cargo-only operations through reduced fatigue-related sick calls. In the longer view, a growing body of research across industries indicates that long hours of work and night work are linked to sleep loss, which in turn leads to a variety of negative health effects and has been found to be a predictor of both short- and long-term illness.

• A 10-year accident lookback is insufficient. The air cargo industry has a relatively safe record, but accidents have occurred. The FAA initially included a 20-year lookback in its analysis. Within those 20 years, four fatigue-related air cargo hull loss accidents occurred. By reducing the lookback to 10 years, the FAA reduced the overall fatigue-related cargo accidents to one, even though three had occurred in the previous 10-year span.

ALPA estimates that, given the FAA’s total cost of applying Part 117 to cargo air carriers, the net annual cost of applying the pilot fatigue regulations to all-cargo pilots would range from $1.1 million to $9.0 million, which for the industry as a whole is nominal. The cost of this safety investment will be more than made up by scheduling changes allowed by Part 117, and if two accidents are assumed, the benefit would outweigh the costs.

“Cargo pilots fly the same aircraft, over the same routes, operate in the same airspace and use the same airports,” said Moak. “When you consider the health benefits and do cost analysis using realistic aircraft, the cost of protecting all airline pilots from fatigue becomes nominal and is something the U.S. airline industry simply must do.”

“While ALPA’s all-cargo members are on the front lines of this issue, every member of the Air Line Pilots Association is dedicated to advancing one level of safety for all who depend on air transportation in this country,” Moak concluded. “We urge Congress in the strongest possible terms to pass the Safe Skies Act of 2013 and bring all airline pilots under the FAA’s fatigue rules.”