Easa Flight Time Limitations Changes

[thunderbird7]

Are people aware that EASA are planning changes to FTLs that will apply to all European JAA Licensed flight crew, that will make your eyes water more than they do now?

There is an oppurtunity to comment on the proposed changes on-line which BALPA is pursuing but the take up seems remarkably low, on the EASA website, given it will affect every pilot licensed in Europe.

Just curious if people even know this is happening?

Information here (http://wakeup.balpa.org/)

and comment here (https://hub.easa.europa.eu:443/security/?app=crt&act=login)

[Superpilot]

BALPA says the EASA approach has not used any scientific data to come up with their proposal. They must have something that shows their limits are fair? How the hell would it stand up when challenged?

[stuckgear]

Just curious if people even know this is happening?




yep was brought up on the 28th Feb, however, the post seems to have been removed.

[Saint]

That document runs to 244 pages. Fatigue set in well before I managed to extract any meaningful information.

[Sharky12t]

Folks, this is VERY important,

I hate to sound like a head-teacher but every once in a while a rant is completely necessary.

For all BALPA members, visit the dedicated website at wakeup.balpa.org where you certainly wont need to trawl through 244 pages of information. The key points are summarised along with extensive guidance on what we can do about it. Granted it's not an easy process to comment but the hard work has been done by the BALPA guys/girls with scope for extra emphasis from individuals should we be so inclined, if not it's a cut and paste exercise.

For non BALPA members this is as good a reason as any to join. There's nothing to stop a non-unionised individual from registering to comment with EASA but without the sort of guidance we've received from BALPA the process is very daunting.

I'm sure as this thread progresses we'll be able to add detailed information about the changes we could all see to our working lives if these proposals are implemented in their current form. For now I'll wrap up by saying that this affects all crews regardless of type/airline across the EU, so get off you're arses and do something about it. I believe apathy in the pilot community is one of the contributing factors that has allowed P2F, and our deteriorating T's and C's to continue to be eroded to this day.

Rant over, normal service is resumed.

[Denti]

The document is long, however the duty time regulation is only a few pages long, 7 in fact. The rest is justification why did come to that specific implementation. Read it, comment it, and make your peers aware of it. If you think EU-OPS subpart Q is bad, think again, EASA OPS will be much much worse. And CAP 371 won't help you anymore as it will be automatically replaced.

[judge11]

Given that the plethora of legislation that comes out of Brussels has leaned very much to, some would say, the overzealous protection of the individual in all matters from food hygene to health and safety, just who or what 'dark force' is driving this EASA move that seems to go against all scientific opinion?

Granted, this is taken from an on-line encyclopedia:

The daily (lorry) driving time shall not exceed 9 hours. The daily driving time may be extended to at most 10 hours not more than twice during the week. The weekly driving time may not exceed 56 hours. In addition to this, a driver cannot exceed 90 hours driving in a fortnight. Within each period of 24 hours after the end of the previous daily rest period or weekly rest period a driver must take a new daily rest period.

Are these eurocrat buffoons seriously trying to impose working hour legislation that European lorry drivers don't even come close to? Follow the money, or in our case, the 'driver' behind these farcical proposals.

[Abbey Road]

Follow the money, or in our case, the 'driver' behind these farcical proposals.What? You mean .... the airlines? Well, who would have guessed? :rolleyes:

Just about everybody would have guessed - everybody! ;)

[changeover]

I would push back at this really hard if I were you. The misery is real if you let the likes of pencil bushing board of directors/accountants get away with this. The U.S. pilots have looked to the scientific CAP371 for years trying to get new rules, and finally acheieved some head way. Some of those regualtions look photo copied out of the FAA regs.

[merlinxx]

Back in the early 70s we (UK charter operator) applied the CAP371 trial Doc/Regs before it became law.

Even took the application to the sandpit with me, FAA 121 ops, even the FSO Inspector commentated "we need something like this in the US" That was 1981,
anything:ugh:

CAP371 is the Gold standard:ok:

[411A]

Some of those regualtions look photo copied out of the FAA regs.
The FAA generally leads, others follow.:ok:

[DB6]

It not only needs to be fought, the organisation and individuals responsible should be identified, pursued and removed from authority. With extreme prejudice, to coin a phrase.

[757_Driver]

I will put my tuppenceworth into EASA, as should all of us, however I don't beleive it will make a blind bit of difference. All the EU agencies come up with these farcical consultations and then just implement the regulations they first though of, regardless of the opposition, input or comments from those involved in the process. and why not, after all these are unelected bodies that have to answer to nobody and can and do, do as they please.

[thunderbird7]

unelected bodies that have to answer to nobody and can and do, do as they please.

They do answer... to the electorate. MEPs are pushing this, elected almost by default by low turnouts from disinterested electorates.

This is an excellent example of how Europe affects our everyday lives, whether we like it or not and why we should pay attention to European elections with the same interest as we do national elections.

Perhaps we could have a Europe-wide expose of MEPs 'expense-gravy-train' in the same way as UK MPs have had in recent times!

Back to the subject - work your way through the EASA Comment Response Tool and have YOUR say about YOUR future before 20th March - you owe it to your career!

[joe two]

Reacting on this will take one or two hours,
however we need to act now , do it this week.

Two hours now will hopefully save us from hundreds of hours more per year.

We are becoming fatiqued and FTL's should become more restricted,
however for some reason EASA is coming up with this proposal.

BALPA is pulling us together via balpa.wakeup.org
React now as BALPA member or Trans National Member from other pilot unions
in Europe

Hopefully the other European Pilot unions are doing something like this as well? (French , Italian , Dutch , German ?)

Have a look at balpa.wakeup.org even if you are not (yet) a member.
Remember it is a proposal , we should act against it.

[Danny2]

The FAA generally leads, others follow.

411A, you can stop being an antagonist on this one. The FAA are now actually looking at adopting many of the scientifically proven limitations from CAP371 whilst EASA and the MEP's supporting these new regs, with the backing of the operators, are looking to adopt the outdated and unsafe FAA regs in many areas.

I'll leave it to to thers with more spare time than myself to provide links to the articles that point to the long awaited FAA turn around on FTL's.

[fireflybob]

Frankly I am amazed that anyone would think of increasing the amount of flight/duty hours which we can do.

It just beggars belief that the legislators would fly in the face of all the scientific data.

I also hope that BALPA get this well into the media so that passengers know what is proposed.

[CleanSpeed]

This is important, so if you haven't already done so I would join the unions in encouraging you to visit the EASA website (EASA CRT application (http://hub.easa.europa.eu/crt/)) and comment on their daft proposals.
You need to resister, log in, hit View Documents, right-click "OPS.055", then select "Add/Edit Comments".
It will take some time to trawl through and complete your comments (right-click on the right side of the screen and select "Add Comment", then click the Save button), but it's in everyone's best interests that we make ourselves heard on this one.
If you have access to the guidance from BALPA then their document tells you which paragraphs to click on and suggests suitable wording for the comments.

[411A]

Frankly I am amazed that anyone would think of increasing the amount of flight/duty hours which we can do.


Depends.
On another thread is mentioned the number of hours VS crews operate on some of their long haul sectors.
Here it is...

MCO 1 night, UVF 2 night, JNB 2 night BGI 1 night. 63hrs Block
LAS 2 night, BGi 2 night, LAS 2 night, MCO 1 night LAS 2night. 75hr block
HAV 4 night, JNB 2 night, MCO 2 night, SFO 2 night .68hr block

Passengers demand cheaper tickets, airline shareholders demand profits.
Couple this with rising costs (and not just oil, either, the carbon trading sceme, increased landing and parking fees, increased taxes on air tickets, etc) it is simply necessary to increase FD crew productivity.
Like it or not, the gravy train has left the FD crew plush bygone station.
Accept reality.
Either that, or find another job...one that might have bankers hours, for example.

[Ancient Observer]

Influencing in Europe/EASA

I hope that someone in the balpa world is experienced at influencing in Europe.
A few odd thoughts.
1. Influencing in Europe requires multiple attacks. EASA itself, the Commission, the MEPs and even the UK Govt all need to be influenced.

2. Get named individuals. Not office holders. Named individuals in the EU world do not like being identified. Identify them, and publish their role. Let them know that if accidents arise, they will be pursued through the French Courts. (They are so much nastier to individuals than the british ones)

3. All EU and EASA officials are looking for their next EU/EASA job. Bear this in mind when "influencing" them. In particular, the top few Directors in EASA are dependant on "Community goodwill" for their next job. Remember that. EASA Directors will not fart without Commission approval.

4. Be very clear about who writes the drafts, who the decision makers are, and who will actually take the decision. Attack all 3 layers.

Good luck

[stuckgear]

AO, some key points there which addresses the nub of the issue that flight safety takes second place to the justification of expending public money.

[Ancient Observer]

It might be worse than that. It is possible that some of the people involved in this decision care more about their next job than they do about Safety.
(Some being the operative word).

There needs to be a clear trail of personal accountability with this decision.

So.................get the names of the individuals involved, and publish them.

[411A]

Let them know that if accidents arise, they will be pursued through the French Courts.
Unlikely to make a difference with the concerned regulators.
Two reasons...

The French already give a pass to AirFrance, with all their many hull losses, and will likely do the same with other larger Euroland aircarriers.
And secondly, all the regulators have to do is point to an airline like EK, which works their pilots far more monthly hours (some lines if time have 99:20...read about it all in the middle-eastern forum) and yet, EK has a rather good safety record.

Therefore, are Euroland pilots somehow less 'safe' than the sandpit guys?:}
Quite likely not, therefore, longer hours will have no effect, on safety.

[Dormant Dog]

But the EK guys spend much of that time in the bunk. (Or did I hear somewhere they don't count that?)

The low cost jockies will be flying zombies.

The proposed EASA changes could have been written by Michael O'leary'. He has already boasted he can take two hull losses. Quite the businessman.

[411A]

The low cost jockies will be flying zombies.


Maybe.
Some changes may need to be made with their ops duty period however...the low cost pilots signed up (imagine that:}) for their planned ops (multi-sector) so...suck it up or, move over and let someone else have the job.
I'm quite sure the line is long, outside the HR door.

[stuckgear]

so 411A, you advocate that pilots should be fatigued and if they dont like it to foxtrot oscar ?

[joe two]

There is offcourse the odd guy/girl not taking this seriously.

For the rest : wakeup.balpa.org for some initial guidance.

[411A]

so 411A, you advocate that pilots should be fatigued and if they dont like it to foxtrot oscar ?

Yup, and here is one of the reasons why...

March 10, 2011
Airlines' entry into the European Union's carbon market next year will add at least EUR€1 billion to their costs, make some operators less competitive and ultimately lead to higher air fares.

From January 1 2012, around 4,000 aircraft operators will be included in the EU's Emissions Trading Scheme (ETS). Most flights that land and depart from EU airports will be covered, regardless of the operator's nationality.

The airlines will join around 11,000 factories and power plants whose emissions are currently capped under the ETS, forcing them to buy permits to cover emissions above the caps.

Aviation is responsible for around 3 percent of the EU's greenhouse gas emissions, and its levels are growing at a faster rate than those of any other sector.

The cost of joining the scheme will be between EUR€1 billion (USD$1.4 billion) and EUR€1.4 billion in 2012, analysts estimate, rising to EUR€7 billion in 2020.

Lufthansa, Europe's second-biggest airline, expects the ETS to cost it an extra EUR€350 million a year from 2012, rising each year after that.

"Airlines do have a big challenge," said Peter Sharratt, global director for energy and sustainability at consultancy WSP Environment & Energy.

"It is extremely likely that the cost of airlines' carbon allowances will be passed onto customers."

--Airwise



Airline shareholders won't pay for the added costs, passengers will.
Higher fares, airlines will demand more productivity from pilots.
Economics 101.

In short, IF you don't like it...find another job.
Airlines could care less...they will simply hire new pilots, under P2F contracts.
The writing is on the wall for those smart enough to read it.

[stuckgear]

Bokkenrijder,
I disagree, 411A isn't management at all far from it, he's a pilot on the back side of flying career thats found him flying charter ops on a type that, while a great aircraft, is in its operational twilight years, rather like 411A, as such, he likes to express his knowledge and present an aura of all knowing.

The fact is Carbon Trading has little to do with pilot fatigue, it's hyperbole to present the notion that someone knows what they are talking about. Airlines, will pass on the costs of carbon trading to the customer, that's if carbon trading remains in place, its been coming more prevalent as a pointless exercise, a scam, and recent situations as the integrity of the scheme have also been forthcoming.

There is no use in comparing what happens in another region as different regions have different influences and different factors.

By the EU commission's own data, the EU market involves:

• European Aviation market : a €140 billion business in 2006
• +/- 150 airlines
• 730 million passengers in 2006
• 1,000 airports
• 25,000 aircraft on average per day
• 1,000 air traffic control sectors
• 12 traffic bottlenecks account for 80% of delays

That is within the EU alone. The EU market cannot be compared with what happens in another geographical region, much as the US aviation industry is unique to itself, as is the Asian market, as is the African market, as is the pacific rim market. Each are individually unique. This is an issue that is within the EU and is subject to the operational factors and influences of the EU.

A key point here is that we need to move away from presentations and assertions from those who have an agenda, like the self job creationists in the EU, or are just full of 'pi$$ and vinegar' because the only ride they can get is an aircraft which one step away from Marana/Davis/Goodyear (heck its not even worth parting out an L-1011 anymore as the parts market is pointless).


The significant issue here is that raising flight times and increasing fatigue is nothing more than a fools errand.

Lets leave the safety issue aside as that is without doubt, and lets look at the economic aspect from an operational standpoint.

For an operator, fatigue increases pilot turn over and also increases sickness levels, both of those have an immediate impact on the operator and costs.

The hard cost of identification of forthcoming pilot recruitment demand, sourcing suitable applicants, recruiting those applicants, induction and company specific training (if already typed) before being released to service is well understood by each operator (or it should be) now with a fatigued pilot base,resulting in higher turnover of its pilot base, that cost has just increased substantially as has the lead time required which is leaving your fleet short of flight crews.

Now with pilots out on the line, as an operator, do you really want pilots calling in at short notice due to being unfit for flight with a diminished source of pilots to cover due to fatigue across the pilot base ? no of course not. delays, missed slots, cancelled flights has just increased your operational cost base.

So, raising flight times and pushing fatigued pilots is going to cost you, as an operator, significantly more money. The thinking that increasing duty times will increase productivity and generate more revenue is a false economy and completely myopic. completely false.

Aside from the fatigue effects on flight crews, if you care about this industry and its economic future, yourself and your future, you should challenge this incorrect presentation of an NPA.

[Landroger]

It not only needs to be fought, the organisation and individuals responsible should be identified, pursued and removed from authority. With extreme prejudice, to coin a phrase.

As SLF and friend of near outraged 737NG driver and uncle of a 767 driver, I am more than a bit concerned about this. While not entirely clear on what the implications are, at first glance I am not inclined to believe the EASA.

As to possible methods of resistance, there have been European 'Safety' pronouncements in my own industry - MRI scanning. The EU have been trying to reduce the amount of time radiographers spend in close proximity to the very strong magnetic field associated with MRI scanners, even though there is no direct or even circumstantial evidence that the field is in any way harmful. I have worked in very close proximity to such magnets for eighteen years and I'm KO(?):rolleyes: The hours the EU propose could mean either doubling the number of radiographers or seriously reducing the number of scans possible each day/session.

To this end, there was a serious plan on the part of many research organisations (within the NHS) to sue the EU collectively. The people I spoke to - some of them very senior and well respected - were confident that the EU bodies concerned were not immune to legal action, if neglect or recklessness could be shown.

It certainly seems from what I have read, that a good brief could hack an EU defending councel to ribbons, given the weight the public attach to safety issues.

I shall try to find out where this avenue of action has gone, as nothing has yet changed and there is little in the way of news or rumour.

[merlinxx]

Shag off 411 and your FAR91 nil regs. When I got our FSO (The Tiger's side of JFK) to look at CAP371 they were astounded with the background data that led to CAP371. So with your geriatric FAR 91 "we don't need regs" brigade, grow up:ugh::ugh::ugh::ugh::ugh:

And to you nay sayers re CAP371, suggest to take an indeph look at the science behind the doc. You maybe surprised at what you learn.:confused:

[thunderbird7]

411A is a Troll (http://en.wikipedia.org/wiki/Troll_(Internet)) on just about every post he 'contributes' to and, as such, is not welcome on a serious topic like this. I started the thread to point out to many who seem to be unaware, of the very real threat of EASA increasing flying hours and decreasing rest periods.

Most flight crew already work hard and have had increases in productivity forced on them to 'lean off' the fat in the system. Anyone who thinks an airline will benevolently add a 15% fudge factor to future local agreements is sadly mistaken!

[BitMoreRightRudder]

Forget 411a and his baiting, his opinion on this is completely irrelevant. The ramblings of someone who refuses to see the danger inherent in what is proposed and is in any case at the end of their career doesn't count for much on this particular subject - it is the actions and words from those of us with many more years still to go in this profession that will be crucial to the final outcome.

The safety implications arising from the NPA are obvious and anyone who has witnessed the extent to which the likes of EZY and FR abuse the FTL scheme currently in place will shudder at the thought of these new ridiculous and commercially driven limitations that have been dreamed up by bureaucrats and pen pushers with 0% experience of what our day to day job actually entails.

It takes about 45 minutes to comment on the EASA website if you follow the detailed guidelines set out by balpa.

[SPA83]

In the NPA, EASA refers to "crew productivity". What does that mean ? Could EASA give a definition of "crew productivity" ? Does EASA intend to add that requirement in the regulation and train pilots to be "productive" ?

[Bokkenrijder]

In the NPA, EASA refers to "crew productivity". What does that mean ? Could EASA give a definition of "crew productivity" ? Does EASA intend to add that requirement in the regulation and train pilots to be "productive" ?Excellent point! Shows again how much the "regulators" are bought and paid for by the big corporations. I guess these "regulators" will be the first ones to blame the airlines' greed if things go wrong, but will wash their hands in innocence when it comes to criticizing themselves for being asleep at the switch.

Viewing tip: watch The Inside Job (http://www.imdb.com/title/tt1645089/) (trailer here) (http://www.youtube.com/watch?v=X2DRm5ES-uA) to see how much faith we should have in our "regulators." :yuk:

[Mr Angry from Purley]

Bitmorerightrudder
Bit more info on how Easyjet abuse the FTL scheme please?. Your not mixing that with the ability to work hard when at work and have plenty of time off when not are you?......:\

[Quality Time]

Mr Angry

Although it was quite a few years ago when I worked for Easy I will give you an example of how it was/is quite possible to 'legally' take the proverbial.

Here is an extract from a past Easy summer roster.

Previously finished on deep nights. Two days plus rest day off.

Day1(after rest day) : Ltn- Nce -Ltn. 0510- 1010
Day2. :Ltn-Gla-Ltn-Pmi-Ltn. 0820- 1720
Day3. :Ltn-Cdg-Ltn-Pmi-Ltn. 1740- 0245
Day4. :rest
Day5. :Ltn-Pmi-Ltn. 0145- 0725
Day6. :Ltn- Agp-Ltn. 0230-0905


A few weeks of that and you need a month off just to recover believe me.
All legal apparently but ridiculous IMO.

As for Cap 371 being acceptable the following sentence is taken from a Crew Notice from the crewing manager two years before the roster above.

'Although we are operating within our approved 'flight time limitation scheme', I am seriously concerned that we are now at the verge of inducing fatigue in large numbers of our crew.'

I personally emailed Webster the Chief Executive, expressing my concerns and saying '....and are clearly a flight safety hazard in my opinion.'

The following month an article by Andrea Felsted quoting Webster,said that ' Mr Webster says pilots have raised concerns about the new Rostering system but they have not questioned safety standards.If they had, this would be taken very seriously.'

I heard lots of 'words of support' from the top during my time at Easy but very little happened in reality.

In my experience any flexibility given in FTL schemes or anything open to interpretation can and will be abused as required by some major airlines.

As for Ryanair I can no longer defend much of what they do but the rosters are one area that have been very positive in my time here so far.They much more accurately reflect the point I believe you were trying to make.

I strongly second FireflyBobs opinion on the EASA matter, unbelievable!

Get tough or get screwed....... and dont expect outside help or support!

[411A]

Day1(after rest day) : Ltn- Nce -Ltn. 0510- 1010
Day2. :Ltn-Gla-Ltn-Pmi-Ltn. 0820- 1720
Day3. :Ltn-Cdg-Ltn-Pmi-Ltn. 1740- 0245
Day4. :rest
Day5. :Ltn-Pmi-Ltn. 0145- 0725
Day6. :Ltn- Agp-Ltn. 0230-0905


A few weeks of that and you need a month off just to recover believe me.
All legal apparently but ridiculous IMO.


Legal, yes.
Especially tiring...no.

[Big Tudor]

Quality Time
Would say that sequence is not legal under CAP371. To do the two consecutive deep night duties on day 5 & 6 you would need a local night prior.
Should any duties be scheduled to be carried out within any part of the period 0200 and 0459 hours local time, for 2 consecutive nights, then crew members will finish the duty preceding this series of duties by 2359 hours local time such that the crew members can take a rest period during a local night

Sure Mr Angry will correct me if I'm wrong. :)

[Human Factor]

Legal, yes.
Especially tiring...no.

We're not in the colonies. Those times are local.

[Mir]

Day1(after rest day) : Ltn- Nce -Ltn. 0510- 1010
Day2. :Ltn-Gla-Ltn-Pmi-Ltn. 0820- 1720
Day3. :Ltn-Cdg-Ltn-Pmi-Ltn. 1740- 0245
Day4. :rest
Day5. :Ltn-Pmi-Ltn. 0145- 0725
Day6. :Ltn- Agp-Ltn. 0230-0905


While I honestly think that the above is a terrible schedule here is a schedule according to Subpart Q :

Day1(after days off) : Training 0540-1755
Day2(2 sectors) : 1530-0050
Day3(2 sectors) : 1720-2340 (almost rest day....)
Day4(2 sectors) : 1630-0230
Day5(Standby) : 1500-1600
Day6(2 sectors) : 0620-1920
2 days off afterwards...

The above is absolutely not an abnormal rostering in my company. Not talking about some small Eastern Europe, obscure, cargo operation (apologized to the Eastern Europe, obscure, cargo operations, that actually have a proper FTL), but a Western Europe medium sized operator just working according to Subpart Q.

All I can say is, I really hope that you guys (BALPA/IALPA/whatever) can cause enough commotion/uproar to change the proposed rules to something acceptable, otherwise I fear that the only way to change this blatent disregard of the hazards of fatigue, is a huge scorced hole in the ground......

[Mr Angry from Purley]

Quality
Agreed but does that schedule now still happen at Easyjet - ?
The roster you mention was in my humble view a by product of the UK CAA early / late rules - there's plenty of scientific evidence supporting consecutive earlys / nights and the EASA makes no mention of any proposed limits because in Europe apart from the UK there are few/none.
So bringing up what happened in the past is wrong because Easyjet went a long way to managing fatigue. I have more sypathy for MIR the only question i would ask is was that schedule possible before sub part Q was introduced:\

[Quality Time]

Mr Angry

I doubt that you would find such a roster at Easy now I agree.

Really I was trying to make the point that within relatively restrictive limits agreed by the authorities in a modern western airline it is quite possible to produce very fatiguing rosters. Everyone accepts crap rosters occasionally as part of the job but examples like these on a continual basis affected the health and wellbeing of lots of people.

Not willy waving here but the easy roster is significantly worse than the other example given imo. Six more sectors, four sector days, more deep night and no standby? Still tiring of course particularly if the standby was changed.

Within such a pattern it can vary a lot , nowadays trainers can find themselves with cadets every time they fly. Throw in some weather or other difficulties and they become really challenging.

Not being funny but do you fly yourself?

[AvMed.IN]

What is evident from the discussion thus far, is that almost all airlines continue to stretch their pilots' duty hours, thus compromising aviation safety with the tacit approval of the regulators (http://www.avmed.in/2010/12/unsafe-deceit-air-india-extends-pilots-duty-hours/).

But do they ever pause to consider as to how long can they stretch their vital human resource till it snaps - definitely such stressful working schedules (http://www.avmed.in/2011/02/stressed-out-or-stretched-beyond/) must be taking its toll on the pilots - personally and socially. There is a need to regulate the regulators.

Hence if the pilots or their associations have an opportunity to voice their concerns on the EASA's NPA on FDTL - they must act NOW.

[Bokkenrijder]

What is evident from the discussion thus far, is that almost all airlines continue to stretch their pilots' duty hours, thus compromising aviation safety with the tacit approval of the regulators. Absolutely!

Unfortunately it's the way things work;

1) corporations will try to push the envelop claiming it's all safe,
2) insiders will keep on warning,
3) regulators (greased by big corporation lobbyists) will continue to look away and,
4) in the end, when it all goes horribly wrong, the public will have to pay the price and some mid level employee (i.e. pilot!) will get the blame. :(

What a wonderful con job, it's basically the "financial crisis 2.0"

Don't let a good crisis and a massive oversupply of pilots go to waste! :yuk:

[Lucky Strike]

411A, you posted:

Day1(after rest day) : Ltn- Nce -Ltn. 0510- 1010
Day2. :Ltn-Gla-Ltn-Pmi-Ltn. 0820- 1720
Day3. :Ltn-Cdg-Ltn-Pmi-Ltn. 1740- 0245
Day4. :rest
Day5. :Ltn-Pmi-Ltn. 0145- 0725
Day6. :Ltn- Agp-Ltn. 0230-0905


A few weeks of that and you need a month off just to recover believe me.
All legal apparently but ridiculous IMO.
Legal, yes.
Especially tiring...no.

How would you know? You fly a heavy jet on, I assume, long haul sectors on an unspecified continent(s)

When did you last fly a B737-300 in Europe to the roster described?

[411A]

You fly a heavy jet on, I assume, long haul sectors on an unspecified continent(s)


Correct.

When did you last fly a B737-300 in Europe to the roster described?
I don't fly small jets on multiple sectors, in Euroland, or otherwise.
However, IF I desired to do so, I would expect a roster as above, accordingly.
To expect otherwise, is totally unrealistic...seems to me.
IE: join a short haul aircarrier, expect multiple sectors...and plenty of them.
Goes with the territory.
Get used to it...unlikely to change.

[Mr Angry from Purley]

Quality - sorry i could have put it differently. I have more sympathy for MIR's schedule because it's happening out there today. The EASY schedule you mentioned doesn't happen anymore because they reacted to a fatiguing situation that was becoming self evident.
As for me flying not me Chief, i'm a clone of 411A, er well maybe not. :\

[thunderbird7]

Only 4 days left to comment...

[silverhawk]

EASA's comment website is obstructive and time consuming on purpose to minimise negative feedback.

If these changes are implemented there will have to me a myriad of FATIGUE events MORd by crew to overturn the legislation

[AvMed.IN]

EASA's comment website is obstructive and time consuming on purpose to minimise negative feedback.

The said NPA on FDTL allows comments by e-mail as well, (with a restriction though) which may be of use to members not able to access EASA's Comment Response Tool (CRT):

For those with ease of access to CRT: Send your comments using the Comment-Response Tool (CRT) available at EASA CRT application (http://hub.easa.europa.eu/crt/)

However, in case the use of CRT is prevented by technical problems these should be reported to the CRT webmaster and you may still submit your comments by email to [email protected].

Hope it helps those who are inclined to safeguard their interests in the long run...

[groundfine]

The document is found at EASA CRT application
You think your days are already long?
Are you ever tired at work?
Is this the reason you sometimes make mistakes?
Are these proposed reduction of minimum rest periods and extension of working days the way to go in aviation?
You have until midnight tonight Sunday, 20 March to comment.
The BALPA organisation has made a big effort in putting together a "guide to responses" at wakeup.balpa.org
For your own sake and that of passengers everywhere don't pass this by.

[BitMoreRightRudder]

Only 1800 or so BALPA members have responded :hmm:

The implicatons of the NPA are frightening but it seems apathy abounds.

[joe two]

EASA should take these 1800 pilots very seriously !

[Doctor Cruces]

Quote "Day1(after rest day) : Ltn- Nce -Ltn. 0510- 1010
Day2. :Ltn-Gla-Ltn-Pmi-Ltn. 0820- 1720
Day3. :Ltn-Cdg-Ltn-Pmi-Ltn. 1740- 0245
Day4. :rest
Day5. :Ltn-Pmi-Ltn. 0145- 0725
Day6. :Ltn- Agp-Ltn. 0230-0905


A few weeks of that and you need a month off just to recover believe me.
All legal apparently but ridiculous IMO.


Legal, yes.
Especially tiring...no. "

End quote.




I have to say, up until this post I have disagreed with everything 411A has had to say on this subject, but this one got my interest.

If you want tiring, try working balls out, with a ten minute break every two hours, starting at 0600-1600 Mon-Fri and 0600-1300 Saturdays with two days a week overtime (compulsory) 'til 1900. Oh, and all for 300 quid a week after offtakes.

I know someone who does this and believe me, THAT'S tiring.

Now grow up lest the rest of us mere mortals start lumping you lot in with bankers.


:mad::ugh::=

[thunderbird7]

If you want tiring, try working balls out, with a ten minute break every two hours, starting at 0600-1600 Mon-Fri and 0600-1300 Saturdays with two days a week overtime (compulsory) 'til 1900. Oh, and all for 300 quid a week after offtakes.

I know someone who does this and believe me, THAT'S tiring.

Now grow up lest the rest of us mere mortals start lumping you lot in with bankers.

... if that person is flying 300 people every day, working in a fatigued state in a safety critical environment where mistakes = fatal accidents, and if you are happy to sit in an aeroplane flown by a pilot in that state, then your comment is relevant.

[lamina]

Doctor Cruces

Therein peeps lies the problem. The population at large cannot / will not ever understand the problem with crass rostering until they start working random work patterns. I know, I worked a "normal job" for 10 years leaving home at 05:45 returning about 19:30. What a doddle it was! But I had no real responsibility, if I made a mistake there was always tomorrow to sort it out.

[Quality Time]

The population at large cannot / will not ever understand the problem with crass rostering until they start working random work patterns.

Agreed. Support should not be expected from the public, if it affects them adversely in any way they will cry fowl.

Dr Cruces

I grew up a long time ago so don't be so insulting.

Once you or your pal 411A have operated such rosters for some time you might be qualified to comment.

I guess that's unlikely in your case as you aren't even a pilot!:ugh:

[changeover]

411A
The FAA does good work, but on the issue of flight time duty time they have had their heads stuck in the sand for years, due to bending to the will of the commercial operators lobby. In such a risk adverse society all professional pilots should be outraged at such disreguard for our safety, and the traveling publics. The FAA, and if passed EASA's lack of regulation for safe air travel with respect to fatigue on flight crews is WEAK. This is the kind of issues unions need to go on strike for in the year 2011.

[ltn and beyond]

This video clearly shows the negative impact on flight safety of the new EASA proposals.

DasErste Mediathek [ARD] - Plusminus - Flugverkehr: Piloten im Sekundenschlaf (Engl. Version) (http://mediathek.daserste.de/sendungen_a-z/432744_plusminus/6877250_flugverkehr--piloten-im-sekundenschlaf--engl--versi)

:uhoh::uhoh:

[hetfield]

http://www.dallasnews.com/incoming/article10458.ece/ALTERNATES/w620/12-24-2009.n1a_24JamaicaCrash.GH32O9CKQ.1.jpg

EASA WAKE UP!

[fourgolds]

Bloody hell , look at the einstein look alike french guy who represents EASA , involved in proposing the new rules!!!!! Clearly never set foot on an aircraft in his life. Just a Buraucrat , hippy .

What needs to be considered by the various organisations fighting this is the strategy of modern regulators. One must realise that their client is the Airline Industry and not the general public . I suspect there will be a slight reversal / compromise , however this is the exact tactic they set out to achieve. Let me put it this way , what is really needed to enhance safety is a reduction in the existing flight time limitations. This has fiancial ramifications. So here is the sollution as a regulator , propose new regulation that is far more dammaging , then compromise therebye gaining brownie points for appearing to be doing the correct thing. however the compromise is still worse than what is required. Airlines are happy as they get slightly more productivity , the press coverage talks about a reversal of policy ( so they get some positive press as government) , heck some of the organisations fighting it even get some credibility for taking them on. Whereas in reality the crews and the general public are far more at risk than before. To all those unions / organisations fighting this . You must make no comporomises , the goal is clear, an improvement to current FTL's is the only sollution. Fatigue is serious.

Sadly I know more accidents are in the pipeline , and they will always sideline fatigue as a factor. Good luck to all fighting this.

[hetfield]

Jean Claude Cluzeau (that Hippie Guy, spokesman of EASA):

"The proposal is balanced in terms of economics and social impact."

So the US Regualations are unbalanced!?

:ugh::ugh::ugh:

[4:th of july]

The Easa rep in this clip is a character out of a nightmare..
It gives an explanation of how Easa works and what kind of stuff we as pilots can expect in the future.
Truly scaring..:ooh:

[Piltdown Man]

Das Erste article was an excellent piece of work that ran a worthwhile comparison, among other things. Now if I was to play really dirty, I'd suggest that you could sell your FTL to passengers. For example, you could print your FTL in your inflight magazines - what you don't have any? Well maybe it could be printed on the receipt for your baggage loading charge.

If this gets through, it has got to be made totally clear to passengers which companies will allow their crews to go up to the new EASA limit and those who have will have more stringent limitations.

[DB6]

It seems to me that this is a golden opportunity for BALPA and other similar organisations to go in really hard - as opposed to the defensive postures currently being adopted - and target the individuals responsible for these proposals with a view to having them removed from their posts, and ultimately to get rid of EASA having showed it up for the utterly unsuitable and incompetent organisation it is.
Christ, even the EU said it was a shower of ****e, surely that's a good head start.

[jds_portugal]

This is against all the remains of safety! As a pilot I am shocked...

[foxcharliep2]

Bloody hell , look at the einstein look alike french guy who represents EASA , involved in proposing the new rules!!!!! Clearly never set foot on an aircraft in his life. Just a Buraucrat , hippy .



x2 - what a sick joke of a clown :mad:

Thanks for the link, very interesting and worth fighting against those stupid and dangerous rules.

Sheesh, am I happy to be retired .......

[S76Heavy]

Absolutely incredible.

Do these people ever get out in the real world?

How much room for manoeuvre is left for the individual member states CAAs to block this stupidity?

:ugh:

[hetfield]

It's

Jean-Marc Cluzeau, Head of Safety, Air France Industries

AVIATION WEEK'S MRO EUROPE 2008 (http://www.aviationweek.com/conferences/emailer/meu_mailer/meu_070308.htm)

[lomapaseo]

I really hope EASA has learned a valuable lesson here and next time offers up a buxom young lass to explain things.

Somewhere in all this I suspect that the pilot unions have there own cadre of long hairs to contest what they don't want to hear. :hmm:

[tubby linton]

With reference to Hetfield's photograph you have a senior policy making member of easa whose previous employer has had three hull losses in the last ten years one of which occurred during his tenure as head of safety

[6chimes]

Unfortunately public apathy/complacency and an industry acclimatised to declining standards will see this new scheme implemented. Much moaning and little action.

[glad rag]

With reference to Hetfield's photograph you have a senior policy making member of easa whose previous employer has had three hull losses in the last ten years one of which occurred during his tenure as head of safety

Nailed it tl.

[Sciolistes]

Fourgolds,
So here is the sollution as a regulator , propose new regulation that is far more dammaging , then compromise therebye gaining brownie points for appearing to be doing the correct thing. however the compromise is still worse than what is required
Absolutely right. Asking for something totally outrageous and then compromising on something that would not been accepted in the first place. This is a standard management technique and it even gets a mention n the JAA HPL syllabus!

[Knackered Nigel]

lomeopaseo,

Que? your point is...... Anyone who has read the NPA should be shocked. If this is approved and airlines go for it, then IMHO safety will be compromised. Ignoring scientific data on the human body and its peaks and troughs of fatigue is reckless.

[Lord Spandex Masher]

KN, bollocks to EASA, Crewing and my boss. If I'm not well rested I won't be going to work and I couldn't care less if the 'experts' say I can operate safely after 7.5 hours "rest".

Up yours EASA, you bunch of bureacratic nincompoops.

1. "Hello Crewing, I do not feel well rested, I am refusing to check in on the grounds of flight safety. Goodbye."

2. "Hello Crewing, I do not feel well rested, instead of a hire car I am requesting a taxi as is my right. This will cost you circa £200 instead of the £40 it would have cost if I felt rested enough to drive myself. Goodbye."

3. "Hello Crewing, none of my crew are going to operate in to discretion as they did not have enough rest. Please arrange appropriate accommodation for us and our 250 passengers. Goodbye."

Etc., etc..

[Cuban9]

This has been coming for years. I was at a BALPA conference years ago, when the then EU Raporteur was presdent to "discuss" the planned EU FTLs. His view, when asked why they coudn't be based on Science, was to effectively say, "You may as well accept you won't get plan A, but let's do a bit of haggling & you may get Plan B. No idea at all of the issues involved.

He was invited to join a crew for a long duty, to experience it first hand; he laughed.

Last week the BBC allocated 1 hour to a File on Four documenatary (repeated this Sunday) on the politicisation of accident reports in 3rd world countries. Later in the week, the UCL study on pilot fatigue produced by BALPA got a 2 minute mention in the morning news.

The esatablishment does not understand nor wish to understand the real issues that are invovled in this subject. Nor many of the other issues that surround large corporate influence & weak regulation.

[justanotherflyer]

The unkempt hippy character, who is dictating our working conditions, has no experience of professional aviation as a pilot.

Reassuring, huh?

Jean-Marc Cluzeau is a Graduate Engineer in Aeronautics with 23 years of working experience in design organisations, airlines and civil aviation administration. From 1994 to 2003, he worked with the Joint Aviation Authorities (JAA) and dealt with continuous airworthiness, mechanics licensing and maintenance Human Factors requirements. He had also been the SAFA program coordinator from the origin in 1996 till 2000. He then joined Air France Industries in 2003 where he held various senior management positions including lately that of Head of Flight Safety Department.

He has been appointed as Head of Flight Standards in the EASA Rulemaking Directorate in August 2008.

[lomapaseo]

knackered


lomeopaseo,

Que? your point is...... Anyone who has read the NPA should be shocked. If this is approved and airlines go for it, then IMHO safety will be compromised. Ignoring scientific data on the human body and its peaks and troughs of fatigue is reckless.


Just this ... I react to scientific data and not to individual opinions of how a person looks.

I have yet to form an opinion on this and reading PPrune isn't helping since it tends to be a one sided opinion using appearances as support.

[hetfield]

He has been disappointed as Head of Flight Standards in the EASA Rulemaking Directorate in August 2008. ...............

[stuckgear]

jeeze, superced there are some horrific accidents in that clip you linked to. Good to see that the issue is getting exposure elsewhere as unfortunately it's not likely to make the news in the UK if a.) it doesnt push the bbc's left wing agenda or b.) it doesnt involve wayne rooney.

This is an issue that should be under the media microscope.

[Loose rivets]

I think the link leads to a well produced report, not much we don't already know, but interesting to see just how many PhDs it takes to change a regulation - either way.


The problem is the quality of sleep 'we' get even if we get say, 12 hours off. Being moved to a lesser hotel to save money - with a longer drive and the road being drilled up outside - was something of a last straw with me in one airline.

The drinking thing is so interwoven with pilot fatigue. In the 'good' old days, there was enough time for the hard-bitten old skipper to down a few ales, and snore his head off for the next few hours. Now, it's doubtful he'd be legal in the morning. It was a fix for a career-long difficult situation, but now new findings show there's a significant cancer risk in drinking. Shut doors every way you turn these days.

[fireflybob]

The statement made by the EASA rep was further proof to me that this is being steamrollered through for "social and political integration" without ever considering the logical, scientific arguments. The bureaucrats want a level FTL playing field across the EU whatever the consequences.

It's beggars belief that EASA actually has the word "safety" in their title after these proposals - who side are they on?

[stuckgear]

superced's post with link lost in the merge:

re post of link here : DasErste Mediathek [ARD] - Plusminus - Flugverkehr: Piloten im Sekundenschlaf (Engl. Version) (http://mediathek.daserste.de/sendungen_a-z/432744_plusminus/6877250_flugverkehr--piloten-im-sekundenschlaf--engl--versi)

Note: From the report "EASA is claiming the proposal as a success" and the EASA representative is clear in presenting that economics are a driving factor in the decision making process, yet all those interviewed in the industry and outside the industry (bus drivers in respect of their legal time limits) think this a very, very poor.

And this proposal is from our regulator ?

[fireflybob]

And this proposal is from our regulator ?

agree stuckgear - are they "fit for purpose"?

[RatherBeFlying]

Engineers do the technical calculations; when they get to management they become glorified beancounters (common to many technical endeavors).

Injuries and lives lost among the labor force (non-engineers) are covered by Workers' Compensation. As long as the relevant safety regulations are observed, the casualty rate doesn't count for much. Yes, the safety regulations are a fig leaf.

Engineers do not do human factors.

[Mad (Flt) Scientist]

Engineers do not do human factors.

I'll be sure to tell my colleagues involved in cockpit interface design that they are not "real engineers", then. To pick an example.

[Mr Angry from Purley]

Don't forget guys that EASA FTL is only an updated version of Sub Part Q so a lot of airlines in Europe have already moved towards it already (and in some cases things have improved because limited FTL's were in place).

Long way to go yet in my humble view:\

[hetfield]

Take this Hippie Guy of EASA on an 4-5 days early morning shift or on a 12 hrs night flight, well a diversion can't be organized....

If only a few cells in his marihuana brain are left, maybe he changes his mind....but I doubt it.

[RVR800]

>Bloody hell , look at the einstein look alike french guy who represents >EASA , involved in proposing the new rules!!!!! Clearly never set foot on an >aircraft in his life. Just a Buraucrat , hippy .

He is focused on the "ECONOMIC AND SOCIAL" (its got nowt to do with safety!)

[d&b]

Have now left the industry because of the beurocracy plus a bit more and right now do not want to even think about going back to it. Not just about you guys that are flying but on the ground and maintenance as well. Sorry but I have 24 years experience and no longer want to carry on. Given up a lot but hey ho.

[Hannibalpower]

NPA 2010-14c, recommends the following changes, to Subpart Q

Are they mad ? Reduced rest 7 and half hours

• 7 days free of duty per calendar month.
• The Home base may be a multiple airport location. Recommends operators not
to change the home base more than 4 times in any given period of 12 calendar
months.
• Limitation to 11:45 when the extension starts in the period 22:00 to 4:59 was
removed.
• Extension of flight duty period due to in-flight rest: extensions beyond 18 hours
could be addressed by a specific Appendix to OR.OPS.100.FTL if the need
arises.
• 1000 flight hours in any 12 consecutive calendar months.
• Reduced rest to a minimum of 7h30.

[stuckgear]

d&b,

That's a very honest post.

The EASA proposals and the way in which they have been derived is worrying It is an absolute travesty of a proposal. In fact, submitting Alice in Wonderland would be more beneficial. At least there would have been some prose within it.

1. This proposal is short term and factually incorrect which will decrease the levels of safety and increase operational overheads to operators in the long term (excluding possible accident scenario) as fatigued crews will invariably have greater sickness rates, calling in fatigued will require more standby crews (who will also become fatigued) with a higher attrition rate of its pilot base. So that puts down the 'economic' argument.

2. In terms of the safety argument, there have been enough studies (See CAP & FAA) to put this down at the safety level.

3. In terms of the 'social' benefits argument, what exactly does that mean, can we define the social group. The aviation community as a social group? See point 1 above. The travelling public as a social group? See point 2 above. Or is the social benefits relating to the EASA regulatory social group which is generating work for itself and thereby securing it's own revenue ?

There are about 10 pages i could write on the failures of this and the implications, not the smoking hole in the ground scenario, but the tangible detriments not just within the macro environment.


The huge worry here is that this is demonstrable of the way in which EASA will regulate. Fit for purpose ? Not in the slightest.

Worried ? You bet I am.

[Quintilian]

This will align the pilots with how it is in the world of ATC. We are currently "allowed" to work 16h days, with up to 63h a week.

During the last week I worked:

Wedensday: Double shift (16h)
Thursday: Evening shift (8h)
Friday: Double shift (16h)
Saturday: Morning shift (8h) + Night shift to sunday (9h)
Sunday: Evening shift (7h)
Monday: Morning shift (8h)
Tuesday: Morning shift (8h)

80 hours in 6 days.

We can exceed the 63h limit because the the "weekly hour counter" is reset on mondays. Quite priceless.

[Young Paul]

IAMFI - does all this fit with social chapter regulations concerning limits to the number of hours worked per week?

[stuckgear]

That is lamentable. I know you guys on the ground are pushed hard and that we rely on you lot extensively to manage separation and effective flow of traffic. The ATC and the Pilot community can be considered unified in wanting a structure that enables both groups to do their critical work effectively and safely; It eases the burden on both parties in acheiving our objectives to moving large bits of metal through the sky quickly efficiently and safely.

What is it going to take for the regulatory base to get in the real world ? Do we as group have a representative body with the huevos to stand against this ?

I'm not one for industrial action, but if the representaive bodies of both Pilots and ATC were to state clearly, you bring this in, in part or in whole. then pilots and ATC within the EU will not be working until it is removed.

Faced with the potential *complete* standstill of all commercial traffic in the EU, they may well suddenly learn to listen. It would certainly open their eyes to the 'economic and social' influences and coupled with the global media attention a standstill would generate, caused by the failure of the safety regulator to act in the interests of safety whilst divergent from what the US is doing and what factual data supports, it may be the enema EASA needs.

[brownstar]

Dear Sirs
For any of you with yellow and blue tails, might I suggest that you read the FTL than are being proposed in the EU. They state that a limit of 1000 hours in any 12 months. (there is a paragraph about 900 in any Calendar year but this is superceded by the rolling 12 month rule, don't get stuck on this and miss the main point ) At the moment the 900 hours in 12 months limit translates to 900 in 11 months as pilots are forced to have a month off. So be sure that if this piece of legislation goes through you will be doing 1000 hours in 11 months. Now before you new pilots go kicking off that you don't work that much at the moment, they will never do it, I welcome the work etc, you will be missing the point. This legislation means that they CAN do this, and knowing the past history they WILL do it. The only question remains is are you going to sit there spineless and self serving with your heads turned, like fish in a net, unable to see the actual net tighten, drag you from the water and leave you flapping on the deck, by then its too late, or are you prepared to do something to not only protect your profession, but your lives and those of your passengers. For those of you who are young in the left seat, can you really see yourselves fit enough to retire at age 60/65 with possibly 42,000 hours of flying short haul 4/6 sector days. Did I mention the proposed reduction in rest also. What are YOU going to do about this, not someone else but YOU personally.

[despegue]

It is VERY SIMPLE.

We are ALL hired to provide a SAFE flight for the passengers.
When fatigued, do NOT hesitate or hang on, but CANCEL THE FLIGHT!
It is our duty to do so in order to maintain our safety and to DO OUR JOB. We'll see how long the idiots of EASA and management across Europe will last...

Of course striking is another very good method, but only when it will SHUT DOWN EUROPEAN AIR TRANSPORT. Management and EASA ONLY listen when it hurts their wallet.

Any pilot who agrees with the new proposal is a completely unsafe, unprofessional and incompetent fool. So I presume that if no one is willing to accept the new proposals, we MUST ALL TAKE ACTION.

[RAT 5]

Where are Bob Crowe, Arthur Scargill, Jack Jones & Scanlon when you need them. There is no way any of those union bosses would have allowed such an ultimatum to be imposed so quickly on their industries, and without membership discussion and input. It is driven by finance, nothing more, certainly not safety. This is not the same argument when they dumped the FE's. Pilots then cried saftey, took the extra cash and showed their colours. Same with 2 engines. This is very different; it's not an 'extra cash will generate acceptance' issue; it really is about safety and quality of life. The 2 are intertwined. If such an issue does not create a unity amongst the various national unions, including ATC, then nothing will. Surely the unions are there to protect the industry as a whole as well as individual companies. The industry is made up of their paying members and they owe it to them to protect it. Not a head in the sand coal miners' approach, even the steel workers', both were the victims of capitalism as were many other UK manufacturers, but this is much more fundamental to the safe operation that the pax assume and is taken for granted. National parliaments have a responsibility here. They need to be made aware and a PRO-active campaign started. I'm not suitable or as capable as others, before someone volunteers me, but there are paid officials who are. Let them earn their keep.

[Saint]

I am ashamed to say that I missed the opportunity to place comments on the EASA website. The FTL variation document is now closed. For anybody doubting whether companies will extend their working hours, here is a typical sequence of events which occurs under current rules:
Pilot fatigued so declines to fly.
Manager states that the legal limits only work if you manage your sleep properly.
Pilot offered sleep management course.
Pilot still tired because the one theory fits all is rubbish.
Management makes it clear that sleep management is an essential duty of the pilot and if he is unable to manage his/her sleep patterns then he/she is unfit/unsuitable to be a pilot.
Pilot continues to fly tired instead of losing job.
Disciplinary action because too tired to add two numbers together at the end of a sequence of duties
etc etc

[lomapaseo]

I am ashamed to say that I missed the opportunity to place comments on the EASA website. The FTL variation document is now closed. For anybody doubting whether companies will extend their working hours, here is a typical sequence of events which occurs under current rules:
Pilot fatigued so declines to fly.
Manager states that the legal limits only work if you manage your sleep properly.
Pilot offered sleep management course.
Pilot still tired because the one theory fits all is rubbish.
Management makes it clear that sleep management is an essential duty of the pilot and if he is unable to manage his/her sleep patterns then he/she is unfit/unsuitable to be a pilot.
Pilot continues to fly tired instead of losing job.
Disciplinary action because too tired to add two numbers together at the end of a sequence of duties
etc etc


A fair summary above of why a negative reaction to a decision you don't like doesn't change it.

two wrongs doesn't make a right

Regulatory decisons are typically based on expert input weighing the issues. This thread is mostly based on reaction to the decision rather than an expert balance of the issues that were considered.

I still have no opinion on the decision itself.

[Denti]

Regulatory decisons are typically based on expert input weighing the issues.

You have to rephrase that:

Regulatory decisions in europe are typically based on lobby group input weighing the issue. Expert input will only be included on external pressure.

Which is exactly what happened here. Until march 21st everybody could add their own comment or let himself be represented by an organization, for example ECA or his local trade union. Those comments will taken into consideration if they fit into the view of the relevant committee and their external experts (again, lobby groups) and a final version of the proposed legislation will be passed through the european commission and become binding european law.

[RAT 5]

As the law might be passed by people who are not effected by it directly, advised by many of the same, but imposed upon a very large group of people who will be effected, but were not consluted closely; and as the EU is a supposed democracy, and trumpets the ideals thereof, the democratic response of the very large group of those effected is to cry from the roof tops "which part of OFF didn't you understand". If the unelected EASA are hell bent on letting capitalism rip then the EU commission should let the priciples of democracy rip. May the better lot win, but sadly it is might be a foregone conclusion until the first smoking hole.

[stuckgear]

Regulatory decisons are typically based on expert input weighing the issues. This thread is mostly based on reaction to the decision rather than an expert balance of the issues that were considered.


lompaseo,

that's a negative. The EASA FTL revisions are deviod of expert input. They have been drafted ignoring the wealth of of information readily avaialble in numerous studies over the years, no decades. And is divergent from CAP371 and indeed divergent to what the FAA is doing in respect of fatigue.

Ergo, the the thread is not based on reaction, but the lack of peer reviewed and well published data and factual input into the FTL revisions.

[lomapaseo]

Ergo, the the thread is not based on reaction, but the lack of peer reviewed and well published data and factual input into the FTL revisions.

point taken:ok:

Then this is what should be tackled first before expressing individual non-expert damning of the descision.

Typically when I read comments in the USA Federal Register I at least have the opportunity to comment myself as an expert and/or to read the docket of how the coments of others were adjudged.

[stuckgear]

Lompasaeo,

I concur with you. Challenging the EASA FTL revisions based on the appearance (in that he looks like he sleeps on a park bench) of a key member of EASA in the drafting of the proposals detracts from the issue at hand. However, I can see the point in the comments on the issue, if someone has that little consideration toward appearance and presentation and consideration to detail, then that personality trait will likely reflect in thier professional undertakings.


For me, this whole issue is more than concerning.

We have a situation where decades of research and published data is available and has been brushed aside to draft these proposals. That is is neither logical, nor safe, nor responsible, nor progressive. It is regressive and divergent in terms of what more responsible agencies around are doing in order to combat fatigue and thus improve safety to those in the air and those on the ground.

Perhaps it took the issue of Colgan Air et al. for the issue to come to the forefront of public attention in the US. The question is does it take the deaths of our counterparts and deaths of passengers here in the EU for the regulator to heed what other agencies are doing/have done; what the flight crews are experiencing and expressing; what the published data and research supports; Indeed, what other EU agencies are doing in respect of fatigue in transportation; to heed the published FTL's already available in CAP371 ?

That is negligence. Out and out negligence and that reflects the way in which EASA is conducting itself, with arrogance, negligence and stupididty to the detriment of the safety of flight crews, passengers, aircraft, cargo and those on the ground.

[RAT 5]

If all the reaction (negative) to these proposals is correct, and if it is true they could lead to unsafe operations, is it not beholden on crews, indeed airlines as well, to be proactive and not to subject their a/c to enter areas of known possible reduced safety. Is that not what the paying public demand of us? Rather than wait for the moment of fatigue onset, and thus risk the inevitable bust up with Flt Ops, and possible victimisation when you refuse the flight, should a responsible crew not do their duty and avoid such areas in the first place? This leads to the question, why are there not more loud noises from the union leaders, even responsible Ops Directors, and even the chairman of passengers interest groups? For many many years this dribble of standards reduction has crept ever forwards to lull everyone into what is now the norm. The sharp end players in the industry have argued, but not campaigned successfully, that things were getting too bad. All failed; so here we are with this new proposal which smacks of being commercially driven. Surely this is a wake-up call; or is that the major unions have nice cosy agreements with their national carriers that they feel protected and do not feel the need to protect the industry as whole? If they are making noises in the background, excellent, why are we not informed; and if they are, there would be no need of such a long emotional thread on Prune. It would be all being looked after.

[RTO]

even responsible Ops Directors
Never heard about such a thing.

DFO is very much a political appointment where the yes man is chosen. What CEO would want a DFO spoiling the fun when he wants to squeeze a bit more profit out of the spunge.

And passengers do not give a rats ass about tired crew as long as they can pay 15 GBP for their AGP trip. To them we are just overpaid people that spend most of their work days on deck chairs in sunny places.

[RAT 5]

I agree about the DFO comment. It was somewhat tongue in cheek, but that behaviour is not what it is supposed to be. They are obliged to be responsible in and for their actions to all relevant parties, not just the share holders. As for the punters; the same was true for the long distance bus passengers to Greece and Turkey many years ago. They soon woke up when busses started getting airborne over road-side cliffs. Things changed, as much has on the railways and ships, after the smoking hole. Things change in our world too, after a smoking hole, but sadly it always has to be a proven technical, procedural, design fault for it to be rectified. Usually someone comes up with a quick fix and later a permanent one. They still claim 75% of prangs are human caused. The solution has been to design us out of the loop with double & triple back-ups. As reliability improves and airfields become more like mini major hubs with Cat 1 at the very least, mostly radar telling you what/ when and where to do this & that, the perceived role of the sharp end chaps has been diminished. We've allowed that and now the joke is wearing thin. These proposals show that; made all the more shocking by the apparent disregard of all the research, opinions & experience of the past 25 years. One thing is always certain, those who ignore history will really screw up the future. It is about to start.

[Ancient Observer]

In post 20 I described how to influence the political process that is he EU and EASA.
It is a political process. it is not a scientific process - unless the science is adopted by some one with power.

Writing complaints on here might make folk feel either better or worse. It matters not a jot.

The real world is not CAP 371 - it is the EASA/EU process.
get used to it, and either seek to influence it or lose all sense of power.

[RAT 5]

The question arises; why these drastic changes in the face of opposing evidence that they are not for the best? You say politics, I say commerce. Yes, the 2 are intertwined, and there must be some lobyists in the background, namely the airline management. There is no way any ignorant politician or even most gutless CAA's would have sat down and spent hours of discussion to come up with these changes. OK, there is a will to have an even playing field in the EU, true, but it would seem the discussions must have had input from only one side, the commercial one.
I've seen it before where rules were bent to accommodate the problems and make them go away. Dispensations were given by CAA's in the face of airlines crying poverty.
It's an interesting comparison: an airline is not making as much profit as it would like. Solution; introduce a baggage charge; later a credit card charge and a check-in charge. Still not enough, so add a wheel-chair levy: still not enough so increase any of the charges at random, but slowly and spaced out 1 euro = >50m extra dosh. Easy peasy. Little by little the pax get used to it and soak it up. Now there is a calamity insurance charge-mandatory = 140m euros extra. It's a money printing mint. Profits down, charges up just enough to not knock the pax figures. No real change in the product.
So now there is a shortage of pilots and airlines are strapped for cash. Lets allow an 11% increase in productivity for no extra pay. Wow, that will allieviate some of the pilot shortage and help the cash problem. 2 birds one stone. Where will this slipperey slope lead to?

[stuckgear]

RAT5,

Without doubt there has been likely lobbying from certain areas to see this put forward and agree with you. Also a contributing factor is the policy of the EU on aviation within Europe, I have the PDF documents here but obviously unable to post them (besides in their entirety, would take up too much space).

Quote from the EU policy document: The overall objective is "to improve the competitive nature, effectiveness, performance and stability of the aviation industry within Europe but also conversely also states the desire to protect citizen with the highest levels of safety standards."

The EASA FTL proposal document does not do this.

Also within the EU, the objective is set (quote from separate EU document from the above) "to make flying cheaper and more performing." In hard reality and practice. The EASA FTL proposal document does not do this.

Two separate EU departments both presenting cases on the aviation industry in the latter part of 2010, but are also contradictory to the proposals themselves. In the first case above the document sets forth the need to improve performance, competitiveness, effectiveness and stability but also states "the need to pursue a comprehensive approach toward aviation's impact on climate change through: Pursuing market-based measures through the inclusion of aviation in the EU’s Emissions Trading System from 2012 onwards".

So the essence there is to make the aviation industry more competitive internationally, by "introducing market based measures on Carbon Trading" for operators! Say Again?

In the second document which sets forth the proposal of "making flying cheaper and more performing", the presentation directs toward operators making cost efficiencies and to promote use of "greener" transportation particularly at congested times and locations. Uh! Run that by me again?

Both of these documents cite respectively: "The EU is committed to achieving the highest safety and security performance" and "a maintained or even enhanced level of safety."


Essentially, we can look at the proposals, the hot air and presentations and determine that the EU is aware that the industry is suffering in Europe with a saturated market that is regulated to the point that existing operators and new entrants are dissuaded from entering new and future market places; and with profit margins so small that the slightest market fluctuation could see the difference for operators going from profit to debt; so to adjust the regulatory failures of the EU they are passing the cost saving to be made (to be competative and more performing [sic]) on the professional flight crews who are already fatigued and low paid.

Yet they wave the flag of safety?

This is illustrative of the endemic failures of the EU to support the industry and have buck passed their failures around the EU and now to EASA, who with the EU aviation safety mandate [sic] have drafted a fantasy proposal which does everything the opposite of the data, studies, actions of the FAA to alleviate fatigue and prior regulations support.

All in the name of safety ? You got to be f:mad:king kidding me ?

EASA's own mission statement:


Our mission is to promote the highest common standards of safety and environmental protection in civil aviation in Europe and worldwide.


As one poster previously suggested: Not fit for purpose. Both EASA and the EU Euro-crats.

The worry is that it is blatantly obvious the dark hole commercial operations in Europe are headed toward and when it comes apart at the seams; We'll be left with a bunch of agencies and Eurocrats with their thumbs jambed tightly up their backsides not understanding what happened, what went wrong and why.

EASA and the EU need to listen to those with experience at the hard end; not draft fantasy, contradictory proposals from a beech 'effect' desk in Brussels/Bruges/Strasbourg/Koeln

:hmm:

[Mir]

The Danish newspaper Politiken had quite a cover story this Sunday :

Google Translate (http://translate.google.com/translate?js=n&prev=_t&hl=en&ie=UTF-8&layout=2&eotf=1&sl=auto&tl=en&u=http%3A%2F%2Fpolitiken.dk%2Ferhverv%2FECE1258511%2Fudmatte de-piloter-falder-i-soevn-og-begaar-fejl-i-cockpittet%2F&act=url)

Readable with Google Translate, but to summarize quickly, they conducted a study among approx. 1000 Danish pilots, which showed the same results, we have seen from other countries as well. That we are bloody tired, way passed the point, which can be considered safe, except in the minds of the bean-counters obviously.

These articles have actually caused a small bit of an uproar, with aviation doctors also being interviewed and stating, that they are shocked by what they are hearing, and it is pure luck, that we haven't had a serious accident yet.

This has got the attention of some of the politicians and the Danish transportation minister has actually gone so far, as to say, that he is disregarding the Danish CAA's data on this subject, and that he will address the EU on looking/changing the rules ASAP.

However I wouldn't personally hold my breath for these changes, but it is very nice to see, that this charade of FTLs are being looked at, at least, and personally hoping for the best possible outcome from this, so hopefully we will not have to have that big, black, burning hole in the ground happen, before the rules are changed...

[fireflybob]

Where will this slipperey slope lead to?

RAT 5, for me personally, early retirement!

[coolcaptain]

So I saw the graph on the BALPA site...

(am I allowed to insert? :O )

http://wakeup.balpa.org/images/single_sector.jpg

So what about required rest, and what has been proposed for constantly changing start times?

http://www.totalfootballforums.com/forums/public/style_emoticons/default/yawn.gif

[brownstar]

I would like to echo the sentiment from an earlier poster. Chatting on this item may make you feel better, it may even inform others who didn't know of the proposed changes, but unless you actually take a majority group action on this then it will go ahead.
At some point you are going to have to make a choice;
to do what is easy or to do what is right.

[flipster]

If you thought the Danish fatigue report was bad - see this about a UK airline with multiple EU bases - it doesn't say which airline but I think it is 'easy' to guess which it is.

Aviation News - Issue 5 - Shock Report on fatigued Pilots: 'Public should be alarmed' (http://newsletter.balpa.org/1pyjkio4d4b136unolilcs?email=true)

[AirbusPhp]

Nooo it can't be Easy. Our fatigue risk management system is Nasa tested, as management told us recently. We must be wrong. Must be someone else.:ugh:

[bean]

The article does not say that the survey was of one Airline. It says it was a survey of 482 pilots presumably from different airlines

[BitMoreRightRudder]

The 482 respondents are all ezy pilots. The survey was sent to us from a university research group. All ezy BALPA members had the opportunity to participate.