Easa Flight Time Limitations Changes
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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
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
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
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
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.
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Regulatory decisons are typically based on expert input weighing the issues.
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.
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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.
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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.
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.
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.
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.
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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.
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.
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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.
even responsible Ops Directors
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.
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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.
It's politics, stupid!!
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.
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.
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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?
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?
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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
king kidding me ?
EASA's own mission statement:
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
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
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.
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
Last edited by stuckgear; 19th Apr 2011 at 13:45.
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A glimmer of hope?
The Danish newspaper Politiken had quite a cover story this Sunday :
Google Translate
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...
Google Translate
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...
)
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as has been said before, wake up to the real world !
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.
At some point you are going to have to make a choice;
to do what is easy or to do what is right.
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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'
Aviation News - Issue 5 - Shock Report on fatigued Pilots: 'Public should be alarmed'
