Easa Flight Time Limitations Changes
 

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

and comment here

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?

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

Fatigue
 

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

EASA Sub Part Q
 

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.

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.

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.

What? You mean .... the airlines? Well, who would have guessed? :rolleyes:

Just about everybody would have guessed - everybody! ;)

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.

Danny CAP371
 

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:

The FAA generally leads, others follow.:ok:

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.

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.

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!

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.

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.

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.

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) 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.

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

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

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.

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.

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.

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.

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.

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

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

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

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

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.

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.

DB6
 

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.

FTLs
 

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:

411A is a Troll 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!

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.

one of my comments
 

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 (trailer here) to see how much faith we should have in our "regulators." :yuk:

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?......:\

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!

Legal, yes.
Especially tiring...no.

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

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