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Old 1st Mar 2019, 06:47
  #2187 (permalink)  
Rated De
 
Join Date: Sep 2017
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A frame of reference.

I understand you not getting it, you don't have a frame of reference.
As Qantas is heavily recruiting, some new hire pilots might consider commuting cross continent. It is important to understand the difference between opinion, personal experience and regulatory issues.

Irrespective of the cheapness of the seat in which one sits the 'frame of reference' is provided by two key insights:
  1. The UK CAA and the British Airways response to fatigue mitigation
  2. AIPA's documented concerns with respect to new TOD limits and their implications.

With respect to point 1, the UK is also a signatory to ICAO Annex 6. That the provisions relate to a dual responsibility to mitigate fatigue, may perhaps explain, why British Airways have acted. It doesn't look a cookie cutter response, it seems a risk averse and logical position to adopt.

. For this particular sector, which departs early evening, it works best, for me, to spend a night in my own bed. Get up when I wake up, catch the early afternoon flight to Perth, have a couple of hours to iron a shirt and grab a bite to eat, then go to work. I don’t care if I have the first break, or second. It doesn’t matter as I either have first break and doze, or second break and have a solid four hour sleep. I actually find that I’m arriving in London ready to start the day. I don’t even feel like I need to sleep immediately after getting to the hotel.
Unfortunately, referring to point 2 above, neither science nor indeed your own association (AIPA) considers your strategy is optimal.
Thank you to your colleagues for providing a frame of reference. This below is reproduced from AIPA submission regarding changes to CAO 48.1

Sleep Pressure"There is ample scientific evidence going back to the 1990s that recognises that, in the absence of drugs, people do not sleep when there is no biological readiness for sleep. While the SPC suggests that FCMs can plan their sleep pre-flight, that approach is problematic. It is not clear which FCMs CASA suggests should sign-on sufficiently fatigued to be able to sleep immediately after top of climb, even if that compromises their usefulness in the event of an earlier emergency or the Captain’s discretion to operationally determine the allocation of in-flight rest.In any event, the original 2013 Instrument tables reflected that start time was an important factor for all FCMs that could not be offset by the presence of an in-flight rest option. No valid scientific argument has been proposed by either the operators or CASA to abandon CASA’s earlier approach to this issue. "
A 2240 Sydney time departure, having woken on the East Coast in the morning, even with in-flight rest will not mitigate fatigue.
Further, your association considers the degradation of crew rest 'due commercial imperative' to be a further reason why fatigue cannot be mitigated in-flight, stating;

Quality of in-flight rest
CASA needs to get serious about setting and maintaining standards for crew rest facilities, rather than allowing operators to self-regulate according to their “business needs”. There are plenty of real world examples of sub-standard facilities, some of which are due to inadequate design and many due to inadequate control of the surrounding cabin environment. Importantly, the external environment effects such as airflow noise and turbulence can also prevent the FCM from gaining all of the benefits of in-flight rest.

As a superior driver, perhaps the sharp bend can be handled at 120km/h. The legislation considers that the best way is to write rules so everybody gets around the bend safely, and thus prescribe a lower speed limit.
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