NPRM Action needed.

[Furloughed Brown]

Take a minute to have your voice heard, no excuses!


EMAIL A LETTER TO THE WHITE HOUSE!

To participate in sending a letter to the White House, follow these few simple steps:

1) Go to Home | Coalition of Airline Pilots Associations click on the "Contact Your Legislators" button in the lower right side of the CAPA Home Page.

2) Under "Current Action Alerts" header, click on:
“Letter to the WHITE HOUSE: Now is the time to release Flight Time/Duty Time Regulations”

3) Enter your zip code in the "Action Alert" box, write your name in the "Your Name" box, enter your sender information below and click “send” and email your letter to the President.

2) CALL THE WHITE HOUSE!
(202) 456-1111 (Comments)
(202) 456-1414 (Switchboard)

[westhawk]

Any particular rule you'd like to see enacted?

If you want people to rally around your cause, it might be helpful if you told them what that cause is!

[mustangsally]

It is all about crew rest limitations. We are currently located on the third rock from the sun. Sorry about the last sentence, but if you are a 121/135 operator you should be in the know. If not, then.........

[Caboclo]

What is it about being a pilot that turns people into such lazy whiners? I used to drive semi-trucks; the duty time rules in that industry are 70 hours in any consecutive 8 days, and I was constantly up against that limit. If we further limit our duty times, then we'll only be able to work 1 or 2 days a week, which means we'll never make any money. Of course we get tired; that's why it's called work. If you're not willing to get tired, then you shouldn't be paid. :ugh:

[stepwilk]

You were transporting frozen haddock, or king crabs, or maybe crates of condoms. As a freightdog, perhaps you still are.

[westhawk]

The merits of flight/duty/rest time regulation for both part 121 and 135 have been debated ad nauseum for long enough for me to be sure they won't be resolved to anyone's satisfaction any time soon. That said, commenting on a NPRM is allowed, and one could even say encouraged by the administrative rulemaking process in place within the USA.

As to the matter of whose comments will be given any notice or affect the outcome, that's another issue. Every American citizen should realize that our form of representative government relies upon blocs of influence to decide policy. As a consequence of this truth, those blocs of influence with the greatest resources usually affect the process outcome to a greater degree than those with fewer resources. A more cynical way of stating this dictum is that those with the gold make the rules.

In the 121 airline world, the airline corporate entities win most of the battles. Their only organized opponent in any governmental matter is the various airline unions, whose effectiveness at swaying the outcome of rulemaking over the last few decades is a matter best left to be debated on another forum.

In the 135 on demand charter world, charter and airplane management companies are represented in government affairs by a number of industry organizations. They do so virtually absent any organized opposition.

The well constructed reasoning of individual industry professionals commenting on NPRMs is a good thing, don't get me wrong. But providing facts and research supporting one's views is far more compelling and the only way for individuals to have any hope of influencing the outcomes sought by the better funded and better organized industry representation. In short, any comments made regarding the NPRM should connect the dots between the proposed rules and their effect upon aviation safety if enacted or are not enacted. Expect industry to present cost/benefit analysis which support a set of conclusions which are contrary to the typically expected viewpoints of flightcrew members.

This particular battle will be fought and won or lost, but the larger fight for sensible and balanced regulation will be a long one. There are many battles yet to be fought and incremental evolution rather than revolution is the realistic expectation. In other words, don't expect any big change at all. Expect industry to get most of what it wants, with a few concessions that appear to recognize the known facts and maybe make things that little bit safer.

In conclusion, let me add that the part 135 flight and duty time Aviation Rulemaking Committee submitted it's conclusions and adjourned back in about 2004 or so. The rules were successfully blocked by industry and have not been revisited since. The NPRM in question is limited to part 121 operations and has no regulatory effect upon part 135 ops. As far as part 135 on demand charter goes, things stay just the way that they are!

[Kittty125]

Dear Caboclo,

Yours is just about the most ill thought out post I have ever seen on PPRuNe - and I have seen a few.

[No RYR for me]

What is it about being a pilot that turns people into such lazy whiners? I used to drive semi-trucks; the duty time rules in that industry are 70 hours in any consecutive 8 days, and I was constantly up against that limit. If we further limit our duty times, then we'll only be able to work 1 or 2 days a week, which means we'll never make any money. Of course we get tired; that's why it's called work. If you're not willing to get tired, then you shouldn't be paid.

This is exactly the knowledge level of the average congresman and woman and an extra reason why you should lobby.

[GlueBall]

"...If we further limit our duty times, then we'll only be able to work 1 or 2 days a week, which means we'll never make any money. Of course we get tired; that's why it's called work. If you're not willing to get tired, then you shouldn't be paid."

Caboclo...Come and step out of your Alaskan bush flying wilderness and work a 14hr LAX-HKG sector; and upon arrival, tell us what day and time it is. . .and how many hours you need in your crib before you'll be ready for the next flight. :ooh:

[SeniorDispatcher]

While I'm sure there at least some similarities that you see, it's the ones that you don't consider that torpedo your argument below the proverbial waterline..

1. You're not operating across multiple time zones, all the more exacerbated if you're going west to east, against the clock. The adverse effects on your circadian rythm are proportionally smaller given your slower than jet speeds and crossing fewer time zones within a given timeframe.

2. You're not carrying passengers, but inaminate freight, and transporting the former involves a higher legal standard of care. Of course, if you're driving hazmat loads, or ones that could make a very loud "boom", you could kill as many on the ground as might be seen with a passenger aircraft accident.

3. You're operating in a 2 dimensional world, and not a 3 dimensional world. If you nod off and run off the road and come to a safe stop somewhere (assuming you don't run into something/someone in the process), you're still alive to drive another day--not so if you're flying a planeload of pax.

The common-sense bottomline here, irrespective of flying any aircraft, or driving any type of vehicle, is not to operate one when you're tired, or impaired. Period.

[TSR2]

Yes, and if you have a major problem in your truck you pull off the road and stop, WE CAN'T!

But you could land at the nearest airport and have a snooze if tiredness is that bad.

[SeniorDispatcher]

Assuming, of course, the so-called "nearest airport" wasn't an hour (or more) away, and further assuming one didn't prang the aircraft before it was able to make it to the gate...:rolleyes:

Besides, should you make it to the gate, you won't be getting much rest since the 150+ pax in the back will be banging on the cockpit door, wanting to know when the flight will leave..

[stepwilk]

But you could land at the nearest airport and have a snooze if tiredness is that bad.

You're talking about somebody in a 172, right? (That's an airplane.)

[aterpster]

Dan Buster,

Yes, and if you have a major problem in your truck you pull off the road and stop, WE CAN'T!

Plus, most of them violate the rules under which they operate, because it is the way this very unskilled (and usually uneducated) work force makes money. They also far too often kill innocents in the process.

It's amazing how many dodo non-pilots, much less professional pilots, frequent this forum.

[stepwilk]

Doesn't anybody bother to read posters' public profiles before slagging them? Assuming he isn't lying--which would be a stretch considering how few active DC-6 pilots there are--Cabocio is an ATP DC-6 pilot flying freight

[LadyGrey]

Of course we get tired; that's why it's called work. If you're not willing to get tired, then you shouldn't be paid

Tell me, is your brain frozen:confused:

So you would not have any problem with putting you and your family on a flight with a "tired pilot":confused:

.Come and step out of your Alaskan bush flying wilderness and work a 14hr LAX-HKG sector; and upon arrival, tell us what day and time it is. . .and how many hours you need in your crib before you'll be ready for the next flight


Exactly! And from frequent GA flying as PAX, I can tell you , that even a well rested FC and well rested PAX at departure of a long-haul-flight ( 10+ hrs ) everybody will be tired at arrival.....Crew and PAX!


Incredible post:mad:

LG.

[Kittty125]

Stepwilk,

Respectfully, I think you are rather missing the point. Somewhat like Cabocio...

[captjns]

It is an issue that has been long needed to be dealt with for domestic, international flying and the old West Coast Hawaii turn. Lets not forget the number of time zones crossed. North/South operations need to be addressed as well.

A maximum number of takeoffs and landings to be accomplished during day and night operations need to be addressed too.

The subject of duty and rest are important matters that need to be dealt with grown ups, of which alas:{, after the battle of the US budget, it has been proven that we have none in Congress:*.

After all, they have more important matters to deal with:hmm:... vacations???:{

[sam376329]

aterpster (http://www.pprune.org/members/297138-aterpster)

what makes you think that truck drivers are unskilled and uneducated?
we have a different skill set than a pilot true. but unskilled? nah.
i don't claim to know what it's like being a pilot and read these forums because i find it interesting.
i'm glad that you guys and gals are identifying the problem of fatigue and are trying to adress it in a responsible manner. because lord knows i wouldn't want an overworked pilot flying myself or my loved ones.
just my thoughts is all. cheers