December 22, 2011
New Rest Rules for Pilots
Yesterday the FAA released new rules governing pilot duty time and flight time limitations. The aim is to reduce the effects of fatigue, which was mentioned in the NTSB’s report on the fatal crash of a Colgan Air flight near Buffalo, New York, in February 2009.
An article in USA Today highlights some of the changes, including an increase from eight to ten hours for the minimum rest period between duty periods. The intent is for pilots to get eight hours of actual sleep between flights.
Anything you read on this subject is likely to say it’s the pilots fighting for these rules, and that the airlines are resisting change because it will raise their costs. Speaking only for myself, I was happy with the rules we had, and I’m concerned about the the new rules.
First of all, the entire thing strikes me as a typical knee-jerk reaction to an accident: If only we had the right law, this bad thing wouldn’t have happened. The NTSB report on the Buffalo accident mentioned pilot fatigue, which was the main reason for the push for these new rules. Yet the Board voted against making fatigue a contributing factor in that accident, instead focusing on the lack of experience of the pilots and their response to the situation (see this Wikinews article).
There’s nothing in the new rules which would have mitigated any pilot fatigue in this particular accident. It wasn’t that the pilots didn’t have enough rest time. It was how they used the time they had, and the fact that they considered a hotel room beyond their budget.
Other aspects of the new rules also give me concern. I commute to work, flying from the D.C. area to New York (either La Guardia or JFK International airport). Like well over half of my company’s New York-based pilots, I have chosen not to live near those airports. Getting to work on time and ready for work (i.e. rested) is my responsibility, and I take it seriously.
If I have a trip that signs in at 5 p.m., I will usually take the 10:30 a.m. shuttle. This allows me several backup flights in case I don’t make the 10:30 (e.g. no room on the flight or it cancels for some reason). If I know ahead of time that travel is iffy, perhaps due to a winter storm watch, I will commute up a day ahead of time and get a hotel room. I’ve even taken the train when flights were canceling. On a normal commuting day, once I get to the airport I often take a brief nap before report time.
The new rules address the commuting issue and seem to imply that time spent commuting to work will be counted against duty time. [In several articles, this commuting time is incorrectly referred to as “deadheading,” but a deadhead is a scheduled, positive-space flight which is part of a pilot’s trip, and it’s already included in duty time.] Does this mean my duty day starts at 10:30 a.m.? If so, I won’t have adequate time left in my duty day to fly my trip, and so will be forced to commute in a day early for every single trip.
Will this ensure that I’m adequately rested? No. You can lead a pilot to a rest period, but you can’t make him sleep. The only effect I can see is that I will lose an extra day of my life for every trip, not to mention the extra expense of getting a hotel (or maintaining a crash pad).
And conspicuously absent from this consideration are the pilots who drive three hours or more to get to work. Not exactly a restful experience (compared to my nap on my flight from D.C.). But commuting by car is invisible in the new rules.
Being fit and ready for duty has always been the individual responsibility of each pilot, and this won’t change. But the new rules will, I fear, have a negative impact on my quality of life.
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Why don’t you live at your base and cut out all this ridiculous commuting?
Comment by Ted Williwams — December 23, 2011 @ 1:45 am
Common reaction from those not in the business. I don’t want to live in New York, just as I didn’t want to live in Atlanta when the company decided that was my base, or in Cincinnati when the company decided that was my base. Yes, I could continue to just uproot my family and move every time my domicile changes, but I choose not to. Among the reasons, not the least are the higher real estate costs and taxes on Long Island.
I know of one case at my previous airline where pilots had their domicile involuntarily changed as many as three times in a period of 18 months (Boston to New York to Cincinnati to Washington). In your worldview, they should just suck it up and relocate each time. Some of us prefer a little stability in our lives.
Comment by Steve Satre — December 23, 2011 @ 2:34 am
The FAA has fallen into the “regulatory well” trap. The Administration thinks if I make another “law” it will fix the issue of the day. The FAA is negligent in the writing of this new rule, in that all conditions to insure that “commuting” fatigue were not addressed.
In my opinion the old rule was “ok” and could have used a little increasing of the rest time. I prefer my flight crews to have a “chance” at 8 hours of sleep.
Laws like this impact all of us in terms of cost, both the consumer and the companies. The issue from the board was “experience”. To the FAA: How does this address experience? I agree with Steve’s statement that the new rule was a “knee-jerk” move by the FAA.
Any focus on commuting is just a move to detract the focus from the issue, pilot experience.
C-172 PIC and an exit row window “Captain” several weeks of every month.
Thanks to the professionals like Steve and the thousands of others in the industry.
Comment by Greg Dowd — December 23, 2011 @ 4:03 pm
Steve,
Somehow you are looking at it with the wrong perspective. Like you, many thousands of pilots worldwide comute everyday. You just cannot blame the law for losing one extra day so you get rested. YOU OPTED to live away from your base.You are providing your family with the roots you want, but there is a price to it, and this should not be paid by your passengers.
Comment by Paulo Prange — December 25, 2011 @ 4:24 am
(*sigh*) You’re ready for airline management.
Your opinion. You’re entitled to it. I’m not going to engage further on this one.
Comment by Steve Satre — December 25, 2011 @ 7:19 am
[...] who fly commercially are now subject to new rest rules. The View from 30,000 Feet blog covers some of the specifics, [...]
Pingback by New Rest Rules for Pilots | High Altitude Flying Club — December 28, 2011 @ 1:31 pm
Hi Steve,
Nice write up on the T&D changes.. I have always thought that the real question is “How long have you been up” That would be a tough call tho. BTW… Your thoughts on the cargo carve out for us freight dogs?
Thanks again,
Al Robinson
(near)
Memphis, Tn.
Comment by Robinson727 — January 23, 2012 @ 10:09 pm
Al,
Sorry to take so long to respond. (I’ve had some things distracting me from keeping up with this blog.) As for the carve out for freight, I wasn’t really that aware of the specifics but I don’t think there should be any difference. Safety of flight issues shouldn’t depend on having passengers on board.
Comment by Steve Satre — March 25, 2012 @ 2:31 am
Your essay clearly is making an error of deductive reasoning caused by misleading evidence and false paradigm. Two of the things any college educated person would easily know.
1. Before speaking of Colgan air crash, please read an official report of NTSB. Do you even know who writes on Wiki? Any professional field including the court of law knows not to quote from wiki because it’s a one-man-summary written by unknown souce therefore never has been publicly verified.
2. Before jumping into your own miscalculated time rules based on USA, read FAA guideline. If you happen to be a professional pilot who takes your job responsibility seriously, you will find within 315 page FAA initiatives your claim is false on your claim on duty time including the commute time.
3. You said “Being fit and ready for duty has always been the individual responsibility of each pilot, and this won’t change. But the new rules will, I fear, have a negative impact on my quality of life.” In other words, are you saying that being fit and ready for duty have a negative impact on your quality of life? By believing so, you know that you just invalidated your airmen medical certificate, right?
It is scary to believe a pilot like you is operating the sky of our country alongside of my wing.
Comment by Pilot here — August 15, 2012 @ 6:05 am