A Regional Airline Pilot's Work (and Rest?)

The FAA says the duty-time regulations discussed below are safe. Are they? This pilot, whose e-mail to me this afternoon describes the grinding routine, says "Hell no!" I've withheld his name till I hear from him again that it's ok to use it.

His e-mail:

"ALPA has been beating this drum for years and finally making some minor
headway. I hate that 50 people had to die, but maybe this will be the kick in
the pants it takes for the FAA (or Congress) to pass some duty time regulations
that have a basis in medical science (as opposed to being pulled out of some
administrator's ass 50 years ago, which is pretty much how we got where we are
today).

The compensatory rest regulation, for instance, was originally designed so that
pilots would be able to catch up the day after weather/mechanicals/etc. caused
them to dip under the nine-hour required rest period. Unfortunately, airline
pressure on the FAA managed to convince the FAA to issue an interpretation of
this rule that brought about our current scheduling nightmare -- that pilots
could be SCHEDULED for less than required rest as long as compensatory rest was
built into the next day's schedule. That's in total contradiction to the
original intent of the rule and it's dangerous, but every regional airline
(including mine, which I will not name) does it and there's not a damn thing
any of us can do about it because the FAA says it's OK.

I don't know what things were like 50 years ago when all these regulations were
conceived, but the reality of modern airline life is something like this:

You get into the airport at, say, 2200. Your "off-duty" period officially
starts 15 minutes after the flight blocks in, so that's 2215. In reality,
you're lucky if you have all your stuff packed up, the postflight completed,
and are on your way to the hotel van at this point. By the time you actually
get to the hotel, it's 2240, assuming the van was on time. I don't know anyone
who can fall asleep the minute they walk into their hotel room, so let's say
that at best, you're asleep by 2315. You've already lost an hour of your "rest"
right there, and that's a best-case scenario.

Now, your block-out time the next morning is 0800. The FAA says this meets the
requirement of nine hours off-duty ("rest") time, since you go back on duty 45
minutes prior to departure time. Of course, the airline requires you to be AT
THE AIRPLANE at this point, so in order to be there on time, you had to leave
the hotel at 0630 (it's a 20-minute drive and the hotel van only runs on the
hour and half-hour, so an 0700 van is too late). Most people I know take at
least half an hour to wake up and get ready in the mornings, which means you
couldn't set your alarm for any later than 0600, which means you got less than
seven hours of sleep on a "nine-hour" overnight in this best-case scenario.

The really fun schedules are the ones where the airline gives you a
reduced-rest overnight (less than nine hours) on day 3 of a four-day trip and
then schedules you for eight hours of flying in five (or even seven!) legs on
day 4. Those schedules are also perfectly legal according to the FAA, but are
they safe? Hell. No.

The way to fix this is nothing short of a complete overhaul of duty time
regulations. I don't have a problem with the scheduled flight time limitations
(eight hours of scheduled flying is tiring, yes, but it's doable on plenty of
rest), but I definitely have a problem with the rest requirements. The
realities of hotels and transportation to and from the airplane are such that
any scheduled off-duty period of less than 10 hours is entirely too short
(you'd be lucky to get eight hours of good rest even then), and the 15-minute
"debrief time" after a flight is utterly preposterous. (To be fair to the FAA,
I believe that's actually a contractual thing rather than part of the FARs; it
could be longer if our contract specified it to be.) Here's what I would
propose as a starting point for new language in FAR 121.471(b) (which,
incidentally, also greatly simplifies figuring out rest requirements, which are
currently a NIGHTMARE to determine):

* Flight crews cannot be *scheduled* for less than 10 hours of off-duty time
during consecutive days of duty under any circumstances at all.
* Off-duty time, for the purposes of rest requirements, is defined as that time
the flight crew is at the rest location (hotel). It does not include time spent
en route to or from the rest location.

The first provision still allows the somewhat controversial continuous-duty
overnights (also called "stand-ups", "high-speeds", and "illegals" by various
pilot groups), while preventing airlines from scheduling back-to-back two-day
trips with very short rest in domicile between trips. It also eliminates the
concept of "reduced-rest" overnights entirely. Put simply, if a crew arrives
two hours late to their overnight, the crew gets 10 hours off duty, period. If
that means the flight the next morning goes out two hours late and people miss
their connections, tough cookies for the airline and the passengers. I'd rather
they miss a connection than end up a smoking hole in the ground, and I'm sure
they would, too, if you put it to them that way.

If we can't have the second provision, the minimum off-duty time in the first
provision needs to be 11 hours to make up for it."

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