Dissecting the New Pilot Rest Rules

Ever since the Colgan Air crash in Buffalo, there has been a renewed effort to revamp the pilot rest Pilot Fatiguerules in the US, and now, we’ve finally seen a proposal from the FAA. To the layperson, this 39 page ruling (pdf) looks to be written in a foreign language, and about 5 pages in, you’re crying and rocking in the fetal position. So let’s see if I can break this down and explain exactly what’s being proposed here. Wish me luck. I fully expect a laundry list of comments with corrections from pilots here. (Please do.)

The FAA explains it this way:

Today’s proposal sets forth a matrix that addresses transient fatigue (i.e., the immediate, short-term fatigue that can be addressed by a recuperative rest opportunity) by establishing a 9-hour minimum rest opportunity prior to commencing duty directly associated with the operation of aircraft (flight duty period, or FDP), placing restrictions on
that type of duty, and further placing restrictions on flight time (that period of time when the aircraft is actually in motion—flight time is encompassed by FDP).

Get it? That’s what I thought. But fatigue really is the biggest issue here, and it’s good that it’s finally be addressed. The problem, however, is that no two sides will agree on how to address fatigue, so the FAA had to decide on something. The agency has put out its first proposal and now the comment period is open. There may very well be some changes before this becomes final.

Before we get started, there is one important distinction to be made. There is a difference between flight time and Flight Duty Period (FDP). Flight time is the time when you push back until you get back to the gate on the other side. FDP includes training, flight planning, and anything else involved in the operation of the flight. Transferring from the airport to the hotel doesn’t count, but that’s probably right where the line is drawn.

We’re going to have to make some generalizations here for simplicity’s sake. This proposal also hopes to simplify the rules across different types of operations, something that isn’t the case today. So let’s look at the rules that govern most travel for comparison purposes.

Duty Time Limits
Today, a pilot can fly 8 hours (flight time) in any 24 hour period. The new plan is going to vary based upon the number of flights scheduled during the day as well as the time that the pilot reports for duty. Why? Because it’s generally accepted that flight times that go against the body’s natural rhythm are more likely to cause fatigue, so pilots can’t fly as much while staying alert if they start their “day” in the middle of the night. Also, flying more flights in a day can add to fatigue. Here’s the new proposed chart.

Proposed Flight Duty Period Limits

As you can see, the big metric here is Flight Duty Period (FDP) instead of flight time, though flight time is still limited on the far right side. So now, if you start your day in the morning like most earthbound people would, you can be on duty for up to 13 hours and fly up to 10 hours. This means that some flights that couldn’t be done with two pilots in the past now might be possible if the flight time is between 8 and 10 hours. (This increase is going to be challenged by pilots for sure.) On the other hand, pilots could have been on duty for up to 16 hours in the past. But now, they’re limited to 13 at most.

Rest Requirements
The flip side of this is how much rest is required when not working. The previous rule required 8 hours of rest looking backwards in a 24 hour period. Now, the rule is 9 hours in the hotel. Also, pilots must get 30 consecutive hours off in each week, up from 24 hours today. Many still argue that 9 hours in the hotel isn’t enough, because everyone should get 8 hours of sleep per night and the body can’t be forced to just go to sleep on command.

Ways to Increase Duty Time
So now the idea is to limit flying to 10 hours at max, but that doesn’t really help us on long flights, right? How do you deal with a 15 hour flight from LA to Sydney? It’s called augmentation. If you add a third pilot, then you can fly longer. And if you add a fourth pilot, you can fly even longer. The idea is that the pilots work in shifts, so that when pilots aren’t working, they can get rest in the back. But to get rest, pilots need to have adequate facilities, and that’s been taken into account in the new system for extended duty times. Here’s what that looks like now.

Proposed Augmented Flight Duty Time Allowed

As you can see here, the rules come to a hard stop at 16 hours, but what about flights that are longer? There are special procedures that an airline can use through the FAA to get special exemptions created with specific plans for those rare ultra-long flights.

There is also another way to get more time from a pilot. It’s called split duty. That’s when a pilot is on duty, gets a break in the middle, and then flies more at the end. If there are adequate rest facilties (eg hotel room) and there’s enough time, then that can be used as a scheduling tool.

As if that wasn’t confusing enough, some fun-filled exceptions have been created to give some flexibility. For example, once a week, a crew can have a 2 hour extension of duty time (3 if there are 3 or more pilots) in order to deal with issues beyond the control of the airline. So they’re addressing summer thunderstorms and long delays, right? Nope.

Carriers should anticipate thunderstorms in many parts of the United States during the summer months. Likewise, heavy snow in the northern parts of the country should be anticipated during the winter, and the jet stream follows basic seasonal patterns. By the same token, carriers are not responsible for traffic delays; however, if they are operating out of chronically delayed airports, air traffic delays are clearly foreseeable.

Well that’s crap. I mean, yes, snow and storms happen during the summer, but they don’t happen every hour of every day. So why should airlines schedule so conservatively? They shouldn’t, but that doesn’t fly with the FAA proposal.

There is a lot more in here including a whole slew of discussion about pilots that are on reserve, or standing by to be used if necessary without having a flight scheduled in advance. There is also, finally, going to be 5 hours of initial and 2 hours of annual recurrent training on fatigue and how it effects pilots. There is none required today, so this is great.

In the end, this rule is probably not going to have a huge effect on the big guys because they already are closer to these new rules thanks to union contracts. Still, there will be pieces that the pilots or the airlines won’t like. It will probably have the biggest impact on some of the regional airlines out there with less strict rules. But that’s a good thing.

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