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BNET seems to be dead in terms of comments, so I’ll post here.
With regard to “commuter” pilots and fatigue, what do you expect/think might happen in terms of operating limits?
A long time ago, “commuter” airlines operated under Part 135, which isn’t as strict as the operating requirements under Part 121, which the major airlines use. A few years back, under a “one level of safety” marketing campaign, the commuter carriers transitioned over to Part 121 requirements.
Now, the historic commuter model (small-city hub feed for a major airline, where a pilot could fly 5-6 legs or more in and out of ORD in a single day) is significantly different than the historic major airline model where pilots could fly a single leg for their entire duty period. (Cruise flying is a LOT less demanding than take-off and landing). Granted, the commuters do a lot lot longer stage lengths these days, and some of their operations could mirror a lot of the domestic operations for their major airline partners, so the “historic” models have evolved a bit.
Let’s not forget that the “8 hours rest” that a pilot is legally required to have begins when the plane is blocked in and ends when the flight is blocked out. That’s right, the pilot is on his/her 8 hours of required rest while s/he is on the van to and from the hotel. Also, many commuters have a duty rig called a CDO (continuous duty overnight) where the pilot flies the last leg in to the outstation at night, stays on duty the entire night, and then flies the first leg out in the morning.
So, if you were to tighten the duty/flight day limitations, how would you do it? Would you advocate for rules that are stricter than the majors? What about for commuters who fly longer stage lengths?
Yes, BNET is a tough one to get comments on because it requires you to register. I think most people are turned away because of that.
I don’t know that rules should be more strict than the majors but rather I think they may tighten the rules across the board. With more of these Essential Air Service carriers flying 9 seaters under Part 135 regs, it wouldn’t surprise me to see them lower the limit once again to make them go Part 121 as well.
There’s no question in my mind that flying 6 hops through ORD is far more difficult than flying from Miami to Seattle. Would I support tighter rules? To some extent, I think I would. I think those stand up layovers (or CDOs as you call them) are just awful, especially if they go into a crowded hub where the layover becomes even shorter. I honestly don’t know what the right rules are for this, because I’m not an expert. There’s an important balance between rest and costs, and you don’t want to tip it too far either way.
I’ve heard talk that they might want to require commuters to fly in 12 hours before they’re scheduled to fly to make sure they’re adequately rested. What if you’re flying at 8p? You aren’t going to wake up really early to fly in before 8a? Instead you’ll have to fly in the day before and pay for a hotel out of pocket. If you do fly in early, you’re likely to be more tired by the time your flight comes around. So while I think there is room for more regulation, I’m not expert enough to know what it should be.
I think I misunderstood the context in which you used “commuter requirements” in your OP. Given that you were talking about two commuter (er, regional) airlines, I thought you were talking about a class of carriers, not the class of pilots who live away from their domicile and “commute” to work each trip ;)
At least to address the point of paying for a hotel, most pilots don’t. Generally speaking, pilots who live away from their domicile have what’s called a “crashpad” for exactly the purposes you describe. Generally, they pay $100/mo for access to a bunk bed in someone’s house. Sometimes they get a dedicated bed for their own personal use, and sometimes they have to take what’s available.
Perhaps the best “compromise” to the adequate rest issue is that a pilot who duties on prior to a specific time (say 10am) must be in base 12 hours prior. However, I don’t really see what this accomplishes — duty rigs at an airline can be up to 6 days in length. Shouldn’t the emphasis be on making sure that the pilot is adequately rested each night throughout his trip? Worrying about his personal choices on Day 1 seems to be shortsighted. Personally, I can function well with one short night of sleep once a week, but too many in a row is a recipe for disaster.