US DOT - Landmark rule to manage pilot fatigue

[Machaca]

U.S. Dept. of Transportation


September 10, 2010

Landmark rule to manage pilot fatigue
will help protect 700 million air passengers each year (http://fastlane.dot.gov/2010/09/landmark-rule-to-manage-pilot-fatigue-will-help-protect-700-million-air-passengers-each-year.html)

Today, we're announcing a significant improvement in air travel safety: a proposal to fight fatigue (http://www.faa.gov/news/press_releases/news_story.cfm?newsId=11839) among commercial pilots. This will help protect the more than 700 million passengers and pilots who travel our nation's airways each year.
As you may recall, managing fatigue (http://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=11840) was a top priority in our Airline Safety Call to Action (http://fastlane.dot.gov/2009/06/acting-now-acting-together-on-regional-air-safety.html) following the tragic crash of Colgan Air flight 3407 in February 2009. We held a dozen safety forums (http://fastlane.dot.gov/2009/08/we-can-implement-aviation-safety-improvements-far-more-quickly-and-effectively-when-we-work-together.html) all across the US. We've talked with safety experts, aviation specialists, and fatigue scientists. And I'm pleased that we have addressed this issue.

The proposed rule also incorporates input from an Aviation Rulemaking Committee (http://www.faa.gov/about/committees/rulemaking/) with members from labor, industry, and the FAA. As Administrator Randy Babbitt said, "Fighting fatigue is the joint responsibility of the airline and the pilot, and after years of debate, the aviation community is moving forward to give pilots the tools they need to manage fatigue and fly safely."
Key new features of the proposed rule include:

One consistent rule for domestic, international, and unscheduled flights
A nine-hour opportunity for rest prior to duty (a one-hour increase over current rules)
New approach to measuring a rest period that guarantees the opportunity for eight hours of sleep
Different requirements based on time-of-day, number of scheduled segments, flight types, time zones, and likelihood that a pilot is able to sleep Features to manage cumulative risk include:

Weekly and monthly limits on duty time of any kind
Thirty consecutive hours free from duty every week (a 25% increase over current rules)The proposed rule also gives pilots the right to decline an assignment if they feel fatigued--without penalty. The FAA has also prepared guidance for air carriers who are required by Congress to develop a Fatigue Risk Management Plan (http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC%20120-103.pdf).
One important aspect of our proposed rulemaking (http://www.faa.gov/regulations_policies/rulemaking/recently_published/media/FAA_2010_22626.pdf) is that it will be open for public comment. So please weigh in at www.regulations.gov (http://www.regulations.gov/).
Like our roads, America's skies are the safest they've ever been. But they must be safer, and this rule is one more step toward that goal.

[Machaca]

FAA Proposes Sweeping New Rule to Fight Pilot Fatigue

For Immediate Release

September 10, 2010
Contact: Alison Duquette
Phone: (202) 267-3883

WASHINGTON — U.S. Transportation Secretary Ray LaHood and Federal Aviation Administration (FAA) Administrator Randy Babbitt today announced a landmark proposal to fight fatigue among commercial pilots by setting new flight time, duty and rest requirements based on fatigue science.

“This proposal is a significant enhancement for aviation safety,” said Secretary LaHood. “Both pilots and passengers will benefit from these proposed rules that will continue to ensure the safety of our nation’s air transportation system.”

Last year, Secretary LaHood and Administrator Babbitt identified the issue of pilot fatigue as a top priority during the Airline Safety Call to Action following the crash of Colgan Air 3407 in February 2009. Administrator Babbitt launched an aggressive effort to take advantage of the latest research on fatigue to create a new pilot flight, duty and rest proposal.

Today’s proposal is compatible with provisions in the Airline Safety and Federal Aviation Administration Extension Act of 2010, which directs the FAA to issue a regulation no later than August 1, 2011, to specify limitations on the hours of pilot flight and duty time to address problems relating to pilot fatigue.

“I know firsthand that fighting fatigue is a serious issue, and it is the joint responsibility of both the airline and the pilot,” said Administrator Babbitt. “After years of debate, the aviation community is moving forward to give pilots the tools they need to manage fatigue and fly safely.”

Currently, there are different rest requirements for domestic, international and unscheduled flights. The proposed rule would eliminate these distinctions. The proposal also sets different requirements for pilots based on the time of day and number of scheduled segments, as well as time zones, type of flights, and likelihood that a pilot is able to sleep under different circumstances.

The proposal defines “flight duty” as the period of time when a pilot reports for duty with the intention of flying an aircraft, operating a simulator or operating a flight training device. A pilot’s entire duty period can include both “flight duty” and other tasks that do not involve flight time, such as record keeping and ground training.

The FAA proposes to set a nine-hour minimum opportunity for rest prior to the duty period, a one-hour increase over the current rules. The proposed rule would establish a new method for measuring a pilot’s rest period, so that the pilot can have the chance to receive at least eight hours of sleep during that rest period. Cumulative fatigue would be addressed by placing weekly and 28-day limits on the amount of time a pilot may be assigned any type of duty. Additionally, 28-day and annual limits would be placed on flight time. Pilots would have to be given at least 30 consecutive hours free from duty on a weekly basis, a 25 percent increase over the current rules.

Congress recently mandated that all air carriers have a Fatigue Risk Management Plan (FRMP). Each carrier will be able to develop its own set of policies and procedures to reduce the risks of pilot fatigue and improve alertness. The FAA has prepared guidance material to help the airlines develop their FRMP.

The proposed rule incorporates the work of an Aviation Rulemaking Committee (ARC) comprised of labor, industry, and FAA experts that delivered its recommendations to Administrator Babbitt on September 9, 2009.

The Notice of Proposed Rulemaking is on display today at the Federal Registerat Public Inspection Documents (http://www.archives.gov/federal-register/public-inspection/). It is also available at Recently Published Rulemaking Documents (http://www.faa.gov/regulations_policies/rulemaking/recently_published/).

The 60-day public comment period closes on Nov. 13, 2010.

###

[hapzim]

Hope EASA are following this closely with there proposed changes to FTL's.

[411A]

...Federal Aviation Administration (FAA) Administrator Randy Babbitt
Hmmm, this turkey was normally out to lunch when he headed up ALPO, now, all of sudden, he's found religion?:ugh::ugh:

[atpcliff]

Hi!

What happened was the FAA kept stalling (and the White House wasn't helping, either!), so Congress finally had enough. They passed a bill that said new Flight/Duty/Rest rules would be in place by 1 Aug, 2011, latest.

cliff

[protectthehornet]

when I first started with my airline, no one was tired...they actually took good care of us. rarely less than 12 hours for an overnight. and even though we flew alot, we were well rested by the next day.

and when did things get bad?

when money was put before safety.

[Huck]

Hmmm, this turkey was normally out to lunch when he headed up ALPO, now, all of sudden, he's found religion?

I liked him then.

I like him now.

I wish he'd been running ALPA in 2007.....

[aterpster]

411A:

Hmmm, this turkey was normally out to lunch when he headed up ALPO, now, all of sudden, he's found religion?

Were you then, or are you now, a member of ALPA?

If you were not a member of ALPA when Randy was president, then on what basis do you grind your axe? You may have some great reasons, but "out to lunch when he headed up ALPO," is a whole lot of heat and very little light.

So, more information please about your negative views of the present FAA administrator, particularly since any info you can provide would be germaine to this thread.

[protectthehornet]

aterpster

I've been in alpa and am now out...as is every pilot in my airline.

we left alpa.

randy babbit as head of the FAA called for more experience in the cockpit

randy babbit as head of alpa enforced a merger policy which put people with 20 years at an airline junior to people with 3 years.


can you say , 'hypocrite'??

[bugg smasher]

As most of you know, the US airline industry relies heavily on the ability of its pilots to commute to work, often from opposite ends of the country. The constantly changing landscape of the industry, the ability to adapt swiftly to competitive pressures, and the resultant crew base assignments/closures/relocations have allowed most airline management teams in the US market great planning flexibility.

Well, it's all about to change.

With the proposed rules, it appears that a commute to work will be included in the aggregate duty/rest calculation for individual crew members; any legal exceedance generated by said commute, to be placed squarely on the shoulders of the pilot in question.

So, arrive at base in a legal and timely manner, check into an expensive hotel room, lose substantial time off on the front end of every trip, who is going to pay for this?

I have that sinking feeling...

[Huck]

With the proposed rules, it appears that a commute to work will be included in the aggregate duty/rest calculation for individual crew members; any legal exceedance generated by said commute, to be placed squarely on the shoulders of the pilot in question.


Just to play devil's advocate - the max duty times will be from 9 to 13 hours.

Maybe, if you can't commute and fly your trip within those limits, you are stretching yourself too thin....

[bugg smasher]

Flying boxes, Huck, is something that escapes public scrutiny. Mostly. You’ll have noticed by now that the UPS accident in DXB has generated nothing more than an occasional nod from an otherwise rabid press.

Yet a much smaller airplane crashes in Buffalo with the loss of fifty paying passengers or so, and now our profession has the benefit of the national spotlight? The inquisition is well under way.

Stretching too thin? Yes, I agree. We all know what the bean counters want, but what do you propose we, as pilots, do?

[MountainBear]

The industry is about to change, in a very big way...

But the critical question is this: will the skies be any safer. I won't dispute that there are some nice things in this rule for pilots. But I remain skeptical that anything in the rule is going to reduce accidents. To be more prcise, I can't help but wonder if the FAAs time might have been better spent elsewhere than coming up with a new rule for fatigue. :hmm:

[protectthehornet]

during babbit's time as head of alpa, or in upper tiers of alpa, ALPA let the camel's nose in the tent...can you say SCOPE CLAUSE?

The rise of regional airlines, like colgan ccame along at that time.

Ewr to Buf...that was a 737 run, or a DC9, or a 727...jets, remember those things? now a turboprop with cheap pilots.

tis deregulation that has harmed us...time to reregulate.

and to you nice folks who commute...time to move to the domicile. I moved from San Francisco To Boston for my airline...and then to washington,dc.


yup...be rested

[merlinxx]

Whoopee, someone in DOT has had a gander at UK CAP371:confused:

[Uncle Wiggily]

Spoke with a relative flying for an airline in the US and they said that their Chief Pilot already made plans to recall all the redundant pilots (over 120) by this October.

Plan on massive pilot movement in the US in the next few months. Oh yeah, and no more working more than a 12 hour duty day and there is a sliding scale so if you get up at 4AM you wont be allowed to work 12 hours. Amen!

[FIRESYSOK]

9-13 hours duty may work in the domestic freight world but pax pilots very often do 9-10 hours per day to get 3-4 legs in. Add a 3 hour commute and said pilot will not be legal for much afterward.

[PJ2]

Finally, at least one regulator is doing what pilot associations have had to accomplish through very tough negotiation and spending negotiating dollars on flight safety problems. The effects of fatigue are not counted solely in the accidents; it is counted in the risk to operations. After all, SMS is a preventative, anticipatory program to discern risk, assess and manage it.

Using science and collected, studied data is regularly dismissed due to an an historical anti-science public bias, however the science on fatigue has been well known and the effects of fatigue have been understood for decades.

It has taken since 1994 to accomplish this mild change not because the risk, the facts, the flight safety issues and the accidents aren't understood for what they are. It has taken this long for purely economic reasons.

In the meantime both truck and bus drivers have been for decades and today, are strictly regulated and monitored for their duty days and, if caught exceeding their day, are at risk of heavy fines, etc.

The commuting question has been around for a very long time but the question was highlighted when the NTSB learned that the Colgan First Officer was a "canary-in-the-mine" for all pilots who, because wages are so poor for airline pilots in their first years in this industry, were forced to commute from cheaper domiciles or even live with their parents. Such questions are certainly part of a larger economic picture, much of which neither the regulator nor individuals have control over but the fact remains and must be dealt with.

There is no doubt that the swirl of political, economic and safety issues makes it difficult to separate industrial issues from safety issues. Because no politician is also a safety person, they are easily swayed by populist arguments. But neither the regulator, the pilots associations nor the employer are entirely innocent in this chronic disagreement where safety and profit are the major forces. As the technical problems were, over the years, solved in doing fatigue research, the political and economic arguments began to fall away in the face of scientific work. Finally, after decades, that work is receiving intelligent comprehension rather than the arguments from ideology.

To those who offer the thought that the present initiative won't reduce the accident rate but may just increase costs, the evidence for safety-related initiatives based upon technical and scientific research since the mid-1950's is clear. This initiative is only part of a larger understanding of human factors, the primary origin of accidents now that weather, navigation and mechanical are largely under control. It takes deft politics and an economic case to implement safety initiatives but without the science, both are wasted. It is past time to do at least something even though such efforts will not serve all masters.

Perhaps Canada may take the US example and follow suit although history shows that recognition of these issues is dim. At present, the CARS still permits up to a 20-hour duty day which can legally be extended to a 23-hour duty day in "unforseen circumstances, for a crew of three, (Captain, F/O, Relief Pilot), providing an "SAE-conforming" bunk is provided. There is no provision at all for a fourth pilot on ULH flights and no recognition of circadian factors or off-duty periods after ULH flight. It is the individual pilot association contracts which today provide for more realistic duty days and 3rd/4th pilots where duty days exceeded two-pilot limits.

The efforts of Captain Babbitt must be applauded in the face of a regulator which has done nothing over the past fourty years to address this chronic problem. Sixteen years to get just to this point...

PJ2

[Neptunus Rex]

Hmmm, this turkey was normally out to lunch when he headed up ALPO, now, all of sudden, he's found religion?411A - Do you have any mates in this profession?

[Harry Shyters]

.......And of course the UK with one of the best (and scientifically-based) FTL schemes is going to throw that away for Sub-Part Q - a European political fudge. :ugh:

I hope you don't suffer too much from the laws of unintended consequence when the legislation is introduced. ;)

HS

[Idle Thrust]

PJ2 wrote:

Perhaps Canada may take the US example and follow suit although history shows that recognition of these issues is dim.

"DIM" is the classic understatement PJ2. We all know that Transport Canada has no interest in changing the current regulations - bureaucratic intransigence, pressure from the operators, or whatever, TC has consistently demonstrated little or no interest in this. Even when studies and committees have been established and laboured for years, the resultant recommendations lie on the shelf until they fall off into the dust.

So sad, and they walk among us.

[Huck]

what do you propose we, as pilots, do?

Me personally... I treat jumpseating as duty. If it's on company aircraft it is shown on my work calendar right beside my trip. Any manager can see it.

If I had something unfortunate happen, I sure wouldn't want to have to explain myself. Yeah, it's legal, but they pay me to hold myself to a little better standard than legal....

So... I'll jumpseat in to a one or two leg domestic trip. If I'm going overseas, I come in the night before.

[aterpster]

PJ2:

It has taken since 1994 to accomplish this mild change not because the risk, the facts, the flight safety issues and the accidents aren't understood for what they are. It has taken this long for purely economic reasons.

The FAA is (once again) changing course. In the mid-1980s they relaxed the U.S. airlines' rest rules and had the gall to state in the preamble to their final rule (paraphrased quote): "These rest standards we are adopting are minimum standards. Pilot unions can obtain better standards than these minimum standards through their collective bargaining processes."

Then, of course, many (if not most) managements soon tightened the screws down to the new minimum standards.

[bugg smasher]

Yeah, it's legal, but they pay me to hold myself to a little better standard than legal....

Excellent point. Legislation must be passed that requires all 121 carriers in the United States to provide their pilots with FedEx pay scales and work rules, or better.

[PJ2]

aterpster;
Pilot unions can obtain better standards than these minimum standards through their collective bargaining processes."
As in Canada, the regulator viewed such "better standards" (of fatigue risk management) solely as an industrial matter and not a flight safety matter. Airline managements gladly adopted the official view of the fatigue problem.

As evidenced by the chronic lack of willingness to seriously discuss the problem with a view to changing the regulations, that view still exists in Canada.

Back then, except in laboratories, understanding of fatigue as a biological/psychological matter, like CRM, was seen as so much new-age psychobabble and thereby "legitimately" dismissed as a problem. The sociological phenomenon of legitimacy is worth being familiar with; there was a time when smoking was cool...

As it is with flight data, understanding of crew fatigue, in domestic as well as long-haul operations, is no longer merely the domain of someone's opinion.

"Not-knowing", which used to foster plausible deniability in some quarters, is no longer an excuse to avoid addressing the problem and changing the regs and policy where the data indicates the need.

As with NASA before Challenger and continuing up to the Columbia accident, within the regulatory climate which is advancing SMS, (the privatization of flight safety*), and therefore within industry itself, the necessary tension between operations and flight safety has reduced, the lines blurred, based upon the illusion, and therefore the satisfaction, that the "safety problem" in all its iterations, has been solved.

The Air Ontario accident at Dryden, Ontario occurred over 21 years ago. Canada's aviation industry was ripe for an accident; such ripeness was surgically dissected and portrayed in the four-volume Moshansky Commission of Enquiry, released in 1992. Would that it were available today for others to read, because history is repeating itself, and there is no material to learn from.

As a result of Justice Moshansky's Report, significant changes took place, but at a cost of 24 lives. A new generation unfamiliar with such forces and phenomenon are permitting a form of institutional recidivism. Nobody is looking at the patterns that connect.

In my view, the Colgan accident should have triggered this kind of a response and subsequent enquiry as it was a canary-in-the-mine for our industry, albeit for different reasons, but swift but perhaps poorly-considered regulatory reaction was the choice.

While a bit of thread drift, in the view of many, the present circumstances in Canada have increased, not reduced, risk. Fatigue Risk Management is just one of the problems from which TC is largely now absent either out of fear of upsetting the introduction of SMS or through signficant lack of resources in terms of staffing, money and vision. It needn't be this way but apparently there is still only one way that can force change.

PJ2

* SMS is itself a better safety system. However, (and the Columbia Accident Investigation Board Report, Ch.7 is instructive for the entire industry and not just NASA), it must be structured so that it is effective. If "Operations" also staffs, finances, (and therefore "buys" the safety it wants), and has bureaucratic superiority over Safety, then the safety department is relegated to mere auditor-after-the-fact, or more pithily, a eunuch. The tension in priorities between the two is what keeps the industry safe. I am very unclear whether this kind of tension is structurally supported within SMS. It was not, within NASA. As soon as comfort and then contentment between the two groups occurs, one's safety system is ineffective.

[CD]

One of the problems with the structure of the Canadian regulatory process is the chokepoint at the Department of Justice. There are regulatory change proposals from 1999 and 2000 awaiting the attention of the DoJ so that they can be published in Gazette I for public comment. These proposals were consulted through the CARAC way back when but the DoJ still hasn't found the time to review them. I'm not sure if those changes would have made a difference or not, but now FRMS will likely overtake whatever had been proposed a decade ago.

It should also be noted that FRMS was proposed in Canada for both maintenance and cabin crew back in 2003/2004 but has also not yet been implemented... Neither of these employee groups have any duty time limits in Canada.

[surplus1]

This NPRM is a big step in the right direction but remember, it is not law yet. We can now anticipate an avalanche of negative commentary from the ATA, the RAA, the individual carriers and, etc. You may also anticipate they will calim that it is not economically feasible and will destroy the industry if implemented.

We shall see what the final rule will look like, if it is implemented at all.

I admire Babbit for at least having the fortitude to make the honest attempt. I hope he can hold the line.

PS: 411A - Babbitt was always light years ahead of the "Worthless" fellow that succeeded him.

[Carrier]

Those who framed the proposed changes and those above who hail them as a solution clearly do not understand the real problem.

Pilots will continue to arrive at work already fatigued from their second job and interstate/province commute because these are what they have to do in order to survive. Even if some of the commute is included in duty time the second job issue will not vanish. It's no good specifying so many hours off if much of that time has to be used working elsewhere to be able to pay the living expenses.

Until all pilots are paid a reasonable salary this situation will continue. From the posts above only Bugg Smasher seems to recognise the real issue.

[PJ2]

Carrier;
Those who framed the proposed changes and those above who hail them as a solution clearly do not understand the real problem.
It is not a sign of "not comprehending" if something is not mentioned. Rather, I would offer that those who have brought their views to the discussion already comprehend the issues as Bugg Smasher has stated, and have focussed on the NPRM itself. Wages and working conditions certainly play a role in the changing trends in accident rates we are seeing.

Let's begin with your comment, which I think is highly relevant.

Those with the intelligence, the ability, the discipline, the passion and the talent to make successful professional airline pilots are smart enough to know that working for $16,000/year after spending tens of thousands on education, (degree) and their licences and endorsements, is a waste of time and effort when first year nurses are earning upwards of $60k. It's one dynamic among many, which this industry, including our passengers, must consider.

The fact that young people are taking a look at this industry's wages and working conditions and saying, "I don't think so..." and selecting other professions, is one factor which is only dimly recognized but which was highlighted in Captain Sullenberger's presentation before Congress (http://transportation.house.gov/Media/file/Aviation/20090224/Sullenberger.pdf)in February, 2009.

The economics of our industry, especially the connector carrier industry which is notorious for high production demands while paying poorly and not supporting their crews in addressing fatigue and competency issues, is obliquely recognized here, (my comment on the Colgan accident, above), but more importantly, has been recognized and discussed in a number of other PPRuNe threads over an extended period of time. These threads typically extend the dialogue beyond the issues of wages and working conditions but certainly these are factors that require public discussion. Cheap air fares come at a cost and an air carrier's expenses must be paid for somehow.

Interestingly, this point was also made in the NTSB Report on the Colgan accident, specifically in the Chairman Hersman's Concurring remarks, (Notation 8090A):
Unfortunately, in the aviation industry, fatigue-related decisions – such as minimum crew hires, flight crew schedules and commuting – are decisions that too often reflect the economics of the industry, rather than the data and science of fatigue and human performance.
This report discusses fatigue issues in detail and as such is well worth reading in full, especially Chairman Hersman's remarks. Making such an observation in a formal accident report (about "the economics of the industry") is a huge statement and signal, with import far beyond the quiet words used. Every one of us who works and flies in this industry knows that the inclusion of that statement is important and is the truth.

I suggest that accident reports are rarely read by airline managements.

Further, I suggest that "the economics of the industry" will continue to place untoward pressures on crews, for well-known reasons.

With extremely rare exceptions, airline managements, especially in an SMS environment, (where, without sufficient and appropriate regulator oversight, is placing the responsibilities for flight safety in corporate, profit-driven, private hands), are literally incapable of perceiving and assessing, for example, the connection between wages/working conditions presently endured by our industry's crews and the serious flight safety issues which are only now acknowledged and highlighted by recent regulatory interventions such as requiring minimum flight time experience and now the NPRM on fatigue.

While we may debate the efficacy of such interventions, they are "there, vice not being there" and that, in a system which has known of these issues for thirty years but done nothing about them, is at least something.

PJ2

[MountainBear]

PJ2

But that gets at the heart of my first post in this thread. Let's ask the real question: is it safer to have a poorly trained and/or unskilled yet alert and refreshed pilot in the cockpit OR would you rather have a highly skilled well-trained pilot who is tired?

Now some will say that's a false choice and that the ideal is to have highly-trained well skilled pilots who are alert. Which are the same criteria that everyone wants from their neurosurgeon and heart doctor too!

Frankly, and I can only speak for myself here, but when I am passenger on a plane I'd rather have a tired Chuck Yeager at the controls than a pilot who is alert but can only mouth in disbelief, "are we crashing?":{ I think the great but tired pilot's fatigue degraded responses would be better than the alert buffoon.

So I'll reiterate the point in my first post. I don't doubt that fatigue is a real issue that effects safety. But is it truly the number one thing that the FAA can be doing to promote safety in the air?

I wonder.

[PJ2]

Mountainbear;

Hm...I take it that you believe that the choice isn't false, then, and that such a characterization of the choice between the two is the realistic question to ask when a passenger?

I view this more subtlely. Having done it for some time, I know that there are no "tired Yeagers" or "alert 'buffoons' " to use your term, in the cockpit and there is no "No.1 thing the FAA can do to promote safety in the air".

There are technical/weather/ATC/passenger/loading circumstances, airline policies, regulations, a political-economy and human factors at work in every cockpit, 99.9% of which crews successfully negotiate and provide unremarkable outcomes for their flights.

For the rare events, some tragic, which signal a failure in any, some or all of these arenas, how does one construct effective regulatory response which applies always and everywhere and qualifies as "No.1"? Having some experience with the regulatory process in Canada and the worthy goals outlined here and elsewhere which are continuously set aside or thwarted, I can speak to the difficulty of achieving even this.

PJ2

[bugg smasher]

There are technical/weather/ATC/passenger/loading circumstances, airline policies, regulations, a political-economy and human factors at work in every cockpit, 99.9% of which crews successfully negotiate and provide unremarkable outcomes for their flights.And given the sheer number of flights that operate successfully each and every hour of the day and night, in all weathers, a testament to the professionalism, training and dedication of the crews involved. An alarming percentage of them, no doubt, despite being in advanced states of fatigue.

The continuing refinements, through simulator training & technology, our evolving understanding of cross-cockpit dynamics and other human factors, improving aircraft systems, other perplexing issues far too many to list here, are making the skies safer each year, one small step at a time. Said refinements, though, all assume properly rested, alert, confident, and content pilots at the controls. A foregone conclusion in serious need of a careful re-think.

Forcing the pilot community at large into long term states of economic stress, decades of pension contributions thrown to the dogs at the stroke of an accountant’s pen, without redress of any kind, continuing shareholder-driven degradation of pay and terms, and now, the NPRM threatening to reduce quality of life even further by requiring pilots, making them legally liable, to position to the aircraft in a ‘non-fatiguing manner’, with all of the associated hotel costs and reduction in what little free time we have?

The all-encompassing issue here is, quite simply put, pay and working conditions. We will not see the incremental leap in safety now being demanded by the general public until this has been adequately, fairly, and intelligently addressed.

And this will cost money; who is going to pay for it?

[xsbank]

I think that there will be no significant changes in the fare-structure or basic rules of operating until the cost of the accidents, either monetary or SLF staying away, rises such that there is no alternative. I think that as the qualified, well-trained, competent people refuse to work for such crappy wages, dumber, less-qualified, less-well-trained people will take the jobs because it is more fun than McDonald's.

Finally, we will have aircraft that fly without crews because the computers will do a better job than the McDonald's crowd and we will all be done.

We will all be sitting in the pubs talking about the "good-old-days" like stage-coach drivers and soon, train drivers.

You heard it here first...