Important notice to all airline pilots employed in the UAE

[Dune]

As pointed out in a previous thread, a significant change to the UAE CAR-OPS 1 regulations has been proposed by the regulatory authorities. It was brought up under an EK thread but it equally is applicable to each of the other airlines based in the UAE.

Specifically the new proposed legislation will allow an airline in the UAE to fly its pilots to 1000 hours/year instead of the current maximum of 900 hours per year.

The GCAA has invited all persons who might be affected by this change in regulations to comment on whether they are in agreement or not.

I would suggest that those who do not submit some sort of response will be deemed by the authorities to be in agreement with the proposed changes. Therefore if you have ANY reservations about these changes it is imperative you submit a response to the GCAA prior to 01 May 2007.

The proposed amendment is titled NPA 03/07. Here is the link:

http://www.gcaa.ae/Admin/Content/File/NPA%2003-07-%20CAR%20OPS%201.doc

At the end of the notice you will find a "response sheet". Please take the time to fill it out and either email it or fax it to the GCAA.

Should you be interested in reading the CAR-OPS 1 with the proposed change, here is the link:

http://www.gcaa.ae/Admin/Content/File/CAR-OPS%201%2021-03-07.doc

Remember, no response WILL be interpreted by the GCAA as being in agreement. Here is a chance to have your say as to whether you agree with the proposed changes or not.

[Zick]

Hi Dune,

I'm a bit concerned that if we don't coordinate the responses, it will end being a big mess. I would suggest this.

1. We send the proposed draft text with the changes to IFALPA and ask them if their specialist could draft us a response letter with all the required medical and legal info that will help us.

2. We then post this letter on the thread, where everybody can have access, and then individualy send it to the GCAA.

I believe that if the receive a couple of hundred letters, even if all look alike will have a better impact.

Let me know what you think,

Kind regards,

Zick

[flareflyer]

Hi zick,

excellent idea.
Can you ask IFALPa to do that?

Flare

[mini cooper]

Mr Moderator, 4Holerpoler - Would it be possible to put a poll / survey out to gauge how many people have replied to the GCAA proposal of increased hours ie asking the question 'have you replied to the proposal' - I have done or I will do or I'm not going to. This way we would get some idea of how many people are taking note and doing something about it.
The trouble is many people out in the sand are worried about names being matched to posts on PPRUNE by over zealous managers putting two and two together, so they are unlikely to say they have done!!
PS this is also the reason there are a lack of posts on the Emirates site as you have to give your name to gain entry to the site!!!
Cheers

[ironbutt57]

Also post another thread about how many people give a cats ass about IFALPA:}

[Panama Jack]

Groups like IFALPA and other interest groups do have an interest in this matter, and I imagine will be submitting a response. NASA a few years ago did some studies on pilot fatigue.

Nevertheless, the important thing is to make your comments known if you have comments. Individual correspondence is normally the most meaningful to politicians and bureaucrats, signed "form-letters" lesser so, and petitions on the lowest scale of importance. Each form of the aforementioned three shows decreasing level of interest or priority from the originator. This was explained to me by a politician decades ago and when you think about it, it makes sense.

Nevertheless some guidance material on the issue would be helpful-- fatigue studies (or the lack thereof). What is the scientific justification (from fatigue studies) of bumping the 900 hours to 1000 hours (besides obviously the response of a request from airlines in the UAE)?

Are there any JAA, FAA, Transport Canada, or other regulators comparisons on this issue? Does anybody know a good link to a summary of studies done by NASA or other impartial groups on pilot fatigue?

[kingoftheslipstream]

Ladies and Gentlemen, Fellow UAE employed pilots:
This is a huge issue. Please make your voice heard, log on to the www.gcaa.ae website and make your contribution.
This is the most serious flight safety issue I've ever seen in my career.
Emirates pilots have the most to lose, simply because of the size of its operations and the large number of already tired pilots and the large number of daily flights. Fellow pilots at Etihad, Gulf, Air Arabia, RAK... you are important stakeholders in this.
Please send calm reasoned arguments to:
Chief Regulation and Investigation
Department of Aviation Safety and Security
GCAA
PO Box 6558
Abu Dhabi
UAE
via email to: [email protected]
With factoring of augmented ops, and this 11% increase in flight duty hours we are headed for disaster. It can't be permitted. The GCAA are our only line of defense since we can't collectively bargain. Hopefully some form of latent wisdom will prevail.
Spread the word, get all your fellow pilots to write. The new regs are to be effective 01 Jun 07, and the deadline for comments from concerned parties is 30 May 07!!!
Most sincerely
k-o-t-s

[Dune]

Excuse the excessive use of bandwidth but this issue is too important to let go in my opinion.

Here is the covering letter from the GCAA addressing the proposed amendment (bold my emphasis):

1. INTRODUCTION

1.1 The United Arab Emirate’s aviation safety requirements are currently contained in the Civil Aviation Regulations (CARs). For Approved Maintenance Training Organisations, the regulations are now based on the European model (JAR OPS 1 regulation amendment 12.

1.2 The purpose of this Notice of Proposed Amendment (NPA) is to:

(a) Continue the process of formal public consultation on proposed amendments of the Civil Aviation Regulations; and

(b) Ensure the adequacy of legislation governing operations of UAE registered in accordance with ICAO SARPS and international best regulatory practices; and

(c) Determine the effect on the aircraft operator of the proposed legislation.

1.3 The GCAA now seeks comments on this proposal from the aviation industry and the concerned parties before proceeding further.

1.4 Abbreviations

CAR Civil Aviation Regulation
GCAA General Civil Aviation Authority (UAE)
JAA Joint Aviation Authority
NPA Notice of Proposed Rule Making
SARPS ICAO Standards and Recommended Practices

2. OBJECTIVE

2.1 The objective of this NPA is to advise all concerned parties of the revision to the existing regulations.

2.2 A number of regulatory criteria have been identified to guide the development of the CARs. The criteria require that the new legislation should:

(a) be clear, concise and unambiguous;

(b) be consistent with the UAE’s international obligations;

(c) be harmonised with ICAO SARPS and international standards, unless unique UAE or EASA circumstances require otherwise;

(d) be outcome-based, to the greatest extent practicable;

(e) be cost effective; and

(f) be enforceable.

3. AFFECT OF CHANGES

3.1 The persons affected by this NPA are:

(a) Operators of UAE registered aircraft;

(b) Engineering personnel;

(c) Engineering and training organisations; and

(d) GCstaff.

3.2 The effect of the proposed new legislation is considered to be generally cost neutral, with greater operational flexibility and guidance.

3.3 There would be no additional change in GCAA inspections and compliance with the proposed legislation will be monitored and enforced through normal GCAA surveillance activity.

3.4 Amendment action is planned for the 01 June, 2007 edition of the CARs (2007-1). All pages would be valid from the date of issue.

4. PRESENTATION

The complete proposed amendment to CAR OPS 1 is issued in electronic format and can be downloaded from the GCAA website:
(www.gcaa.ae/Publications/ NPA)

The changes have been made in track change format in order to be easily reviewed.




5. HOW TO SUBMIT COMMENTS ON THIS NPA

The Notice of Proposed Amendment process is the GCAA’s method of notifying and seeking comment from industry and the public with respect to proposed changes to rules. All submissions are evaluated and assessed with a view to incorporating any necessary changes to the draft regulations prior to their formal promulgation as law.

In order to simplify collation and summarising of comments, it is requested that responses be made on the NPA Response Sheet provided (Refer page 6) or a copy of the sheet, with additional comments attached as necessary. Responses can be individual or from industry working groups. Written comments quoting NPA 03/07 should be forwarded by 01 May, 2007 to the following address:

Chief Regulation & Investigation
Department of Aviation Safety & Security
General Civil Aviation Authority

P. O. Box 6558
Abu Dhabi
United Arab Emirates

Telephone +971 (0)2 405 44 33
Facsimile +971 (0)2 405 44 65

Email [email protected]
Web site www.gcaa.ae


6. SUMMARY OF RESPONSES

Subsequent to the closing date for comments, a Summary of Responses (SOR) will be made publicly available in conjunction with the issue of the Final Rules for each Part. The GCAA may contact persons in respect to submissions in order to clarify issues but is not obliged to individually acknowledge or respond to comments or submissions.

[Dune]

As seen in my previous post, this proposed amendment is directed at all operators of UAE aircraft; in other words YOU!

If you hold a license in the UAE it is YOUR responsibility as a professional pilot to comment on the proposed changes in legislation. This has nothing to do with which airline you work for and any fear you might have about your airline finding out you submitted your opinion. This is above the airlines; this has nothing to do with your airline. This is the licensing authority asking you for your professional opinion on the proposed change. Period.

I have already sent both an email response as well as a fax copy. In addition I will be couriering a hard copy to them tomorrow so I have a paper record that they received my objection to this legislation (unlike an email and fax which can get conveniently "lost", a couriered hard copy will have to be signed for by someone in the GCAA).

Why would I go to this trouble? Because this proposed change has serious flight safety implications and is contrary to all forms of previous science on the affects of fatigue on aircrew (of which the most accepted form is the CAP 371 which the UAE GCAA adopted as their model but have now gone and disregarded with this proposal).

Rest assured the airlines had EVERYTHING to do with this proposal. It is not in the GCAA's interest to raise an internationally accepted limit on flight hours unless there was a proposal from the airlines to do so.

That is the reason why the GCAA is looking for YOUR response. They have the proposal from the airlines and as such they must consider it. Unless there are good reasons why these increased hours should not be introduced then the the governing authority has an obligation to consider doing so. That is why they are looking for your input. They need the thoughts of the professional pilot community (UAE ATPL license holders) to help them assess whether these proposed changes are safe or not. That is the reason why they have sought your input.

In my last word on this subject, I will be taking both my hard copy of my opposition to this amendment as well as the hard copy of the courier receipt and holding them in my safe. Why? Because should for any reason this amendment pass and god forbid something happens in the future where I am over 900 hours and ding an aircraft, copies of that will go to both my lawyer and the newspapers.

Cover your ass boys and girls.

[AI744]

It is beyond me as to how the GCAA can raise an internationally approved limit on flying hours and how this is applicable only to the UAE??? This is really pushing the limit .

[ernestkgann]

I'm as pissed off as the next fella and I have faxed in my objection to the GCAA but on the lighter side I've dug up the words to the EK theme song.

It's time to play the music
It's time to light the lights
It's time to meet the Muppets on the Muppet Show tonight.

Now when you meet one of the Mu...flight ops managers you'll have a tune to hum while you're waiting.

[kingoftheslipstream]

Fellow UAE pilots::)
Howdy folks
This issue is profoundly important, for all the reasons previously listed on this thread, and in many other threads on this website.
I won't reiterate what I've already posted, but this issue is on my mind obsessively an' so I'd like to give you all something else to think about related to the way that labour is exploited.
When families, such as us professional workin' types here in the UAE are under financial pressure, (due to currency imbalance and inflation and lack of real earnings increases an' we have few other places to go...), we have to consider our immediate and present needs. This means we have problems maintaining unity. That's why at my carrier for example, we have a bunch of useless tools who work on days off, 'cause they need the overtime.:=
This weakness is exploited by management. That's why we have pay by the hour introduced, minimal gains in salary, and the annual bonus...
We get slightly better terms in exchange for not challenging, or abandoning challenges to the system.
There is an undercurrent of 3rd World revenge in all a this... I reckon' I'd be amused if it wasn't killin' me...
Now is the time, one and only, to challenge the system. Speak now.
Good luck Compadres.:ok:
k-o-t-s

[Plank Cap]

Objection duly registered with the GCAA......

[B-777-3]

Hi guys


I had a talk to one of the GCAA guys about the 1000 hrs.
He said that EK manegement want them to do it but this will never happen.

It will remain 900 hrs:ok: :ok:

[kingoftheslipstream]

B-777-3

Ummm... have you not been paying attention?:confused: Have you logged on to the GCAA website and read the Notice of Proposed Amendment? This isn't some kinda' wind up pal, this is it. It's comin' to a Flt Ops Dept near you on 01 June 2007. Whoever you're talking to isn't talkin' straight.

k-o-t-s

[fractional]

Some of you may have seen this before, but problably did not. The sound quality isn't the best: http://www.youtube.com/watch?v=84-T7FtrFFw Please go all the way. Enjoy it!

[mini cooper]

I have just watched the video and found it interesting to see how others are dealing with the fatigue issue, it is a shame that EK didn't go along to listen. I would like to think that Ed, Squeely, AAR, TC and all would watch it, but they are unlikey to bother, more interested in having the LOSA guys wrinting something and nothing down so that they get the plaque on the wall in EGHQ.
Keep discovering................................................. ....

PS I sent in my thoughts n the changes to the flight time limitations to the GCAA, don't know if they got them though, or took any notice either!!!!!!!!!!!!!!!

[fractional]

I really hope all tours, blocks, flights, etc., end up like this did. Good night!
http://www.youtube.com/watch?v=PtzkGwh0zA8&mode=related&search=

[Smoozesailing]

Have a read of the latest amendment of the CARs (dated July 2007). 1000 hours is here to stay!:uhoh:

[ruserious]

Yes and it was always going to be, as many global regulators allow the same. But it is on a case by case basis, word on the street is we have to many variations, MFF, tightly scheduled trips and other nonsense to be allowed 1000 hrs. But then....

[411A]

It is beyond me as to how the GCAA can raise an internationally approved limit on flying hours and how this is applicable only to the UAE??? This is really pushing the limit .
Internationally recognised limit?
Really?
How very interesting.
For those who are not informed, the USFAA have had the limit at 1000 annual hours for as long as I have been a professional pilot...42 years.
One thousand hours seems entirely reasonable to me, and reminds me of the old saying by a former US President...Harry Truman, to wit:
If you can't stand the heat, stay out of the kitchen.
Next thing the folks in the UAE will want is more money...which, oddly enough, is fine by me.
After all, when you approached your present airlines HR department, you asked for work, did you not?:E

[stratocumulus]

Hi 411A,
just out of curiocity..does:nt the 1000 hour litmit apply only to Part 135 Ops?
I am a little(maybe more than little) rusty with the FARs :confused:
Thanx

[411A]

Ah...well actually, no, stratocumulus, it applies to 14CFR121 ops, and has for a very long time.

Now, I will admit that IF the sectors are short, and there is a lot of duty time consumed by other than actual flying time, the 1000 hours might just be a tad too much.

I'm mostly a long haul guy, so the hours add up quickly.

Having said all this, I have yet to find a pilot who, when offered a lot more dough for the hours flown, isn't up to the task, and smiles all the way to the bank.

Up the pay, and I suspect thre complaints will disappear.:}

You really do get what you pay for and it has been this way for a very long time.
Malcontent managements take heed...change, or else change will pass you by, much to your disappointment.

[Gillegan]

For those who are not informed, the USFAA have had the limit at 1000 annual hours for as long as I have been a professional pilot...42 years.

Though it may have changed since I left, the 1000 hour limit referred to Part 121 domestic operations. I believe that the limit for Flag operations (international) was/is actually 1200 hours per year. I also believe that Part 135 was 1200 hours.

I'm not defending the hours thing. In fact, I find EK's attitude towards flight duty time and fatigue reprehensible but I guess it's par for the course when you sign up for a job with no representation and very few employment rights.

[tbaylx]

Let's hope they don't slide all the way to Canada's limits of 1200 hours/year for airline ops.

[BIKKERDENNAH]

TBAYLX

SSSHHHH dont let em know other airlines fly 1200 hours per year!!

AHH probably too late anyway :ugh:

[mensaboy]

But in fairness to other countries with higher limits, they only use them as an upper limit, not as a TARGET!

In addition, they calculate hours differently, such as 'on chocks plus 30 minutes' for example. As well, block times for most airlines around the world are a more accurate reflection of true flight times, which is not the case at EK. And... although I'm not certain of this one... I believe simulator time counts towards total time, which is not the case at EK.

And the final two points is that MOST airlines enter into agreements with their unions on practical and enforced FTL's which are tailored to the particular operation and always less than the regulatory maximums. Also, there is very little consideration at EK when it comes to time zone crossings especially when doing east versus west flights as well as the mimimal effort and accomodation afforded pilots with respect to crew rest facilities or seating arrangements on long haul flights.

[Smoozesailing]

It is one thing to have a limit of 1000 hours a year and a pilot clocks all hours flown even during rest on ULR flights. It is a whole different ball game if the limit is 1000 hours and a pilot only logs 50% of the flight time because he is resting 50% of the time, again in the ULR case.

There are some un-named operators who count 50% of flight time and still want the newer 1000 limit! This will push the crew into uncharted territories.

[BIKKERDENNAH]

HEY Emirates does that!! :}