December 22, 2011
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.