Says The FAA Should 'Reexamine The Rationale' For Some Changes

The Allied Pilots Association (APA) has characterized some of the FAA's proposed new flight and duty time regulations for pilots as "a big step backwards" and urged the agency to rework certain key provisions.

“We are pleased that the FAA has undertaken the long-overdue process of reviewing and revising flight and duty time rules for commercial airline pilots," said APA President Captain David Bates. "However, we urge the FAA to reexamine the rationale for some of the proposed changes. While some of the FAA's proposed new rules would enhance safety, others would represent a big step backwards."

"In APA's view, any change in the rules must be designed to enhance safety," he said. "For example, the FAA's proposal to reduce total time on duty during back-side-of-the-clock operations clearly meets that standard. Unfortunately, there are some important areas where the proposed new rules fall well short and instead appear to be catering to industry cost-cutting pressures."

The FAA has proposed increasing the maximum allowable time that pilots can spend at the controls to as many as 10 hours. The current limit is eight hours. "There is no scientific basis or validation for a 25 percent increase in maximum flight time for pilots," Bates said. "Common sense dictates that increasing flight time limits will increase pilot fatigue, in turn degrading the margin of safety."

In addition, Bates cited the proposed new rest requirements for pilots as "insufficient." Under the proposed new rule, all pilots—both domestic and international—would be allotted a minimum of nine hours. "Nine hours is insufficient—it's not enough to consistently provide pilots with the opportunity for eight hours of sleep, which is the minimum amount dictated by science," he said. "Under the proposed new rules, international pilots in particular would experience a dramatic reduction in the minimum amount of rest they would be eligible to receive."

The FAA announced the proposed new flight and duty time rules on September 12. A 60-day comment period that provides a formal process for interested parties to weigh in on the proposed new rules runs until November 13. The FAA's proposed new rules resulted from a lengthy rule-making process that involved a cross section of industry stakeholders, including APA.

"We will be participating in the comment period to make our concerns known to the FAA and other interested parties," Bates said. "While we very much welcome the prospect of updated flight and duty time limits, it's imperative that we use this long-awaited opportunity to enhance the margin of safety for the traveling public. In the unforgiving world of commercial aviation, we cannot permit bottom-line pressures to take precedence. Safety must remain the highest priority—first, last and always."

The APA represents the 11,500 pilots who fly for American Airlines.

FMI: www.alliedpilots.or, www.faa.gov