A group of US pilots has formally expressed concern over some elements of FAA's highly anticipated proposed rule to change flight duty and rest regulations released on 10 September.
Rest and duty time issues emerged during the investigation of the February 2009 crash of a Colgan Air Bombardier Q400. At the conclusion of its investigation the National Transportation Safety Board (NTSB) highlighted the long commutes of both pilots prior to the flight. Chairwoman Deborah Hersman said the pilots fatigue, "chipped away at margins of safety the crew believed would insulate them".
The Coalition of Airline Pilots Associations (CAPA), whose members include American, Southwest and UPS and US Airways says it has "exhaustively analysed the NPRM [notice of proposed rulemaking] and feel the solutions proposed by the FAA often address industry economic concern issues to the exclusion of safety concerns".
CAPA raises four concerns about the rule, two of which focus on the increase in rest required prior to duty time by one hour to nine hours.
The association believes that the nine hour rest period does not allow enough time for a pilot to get a full eight hours of sleep. "This minimum rest would apply following extended international flights as well, a major reduction compared to today," says CAPA.
Another concern expressed by the association is that the nine hour rest period can be shortened once per week to eight hours, "further inducing fatigue".
CAPA's analysis of the rule also states it proposes a 25% increase in the amount of flying a pilot can be expected to accomplish on one day.
American pilots represented by the Allied Pilots Association cite no scientific basis for the 25% increase. "Common sense dictates that increasing flight time limits will increase pilot fatigue, in turn degrading the margin of safety," the union states.
CAPA also cites pitfalls in the proposed rule's lack of specification on limits on hours flown in a duty for three person crews. "Using only total duty as a limit, three pilots could fly as much as 15 hours, a 25% increase over today's limit of 12 hours," the group says.
The association highlights concerns expressed about the rule by Chesley Sullenberger to FAA Administrator Randy Babbitt: "The stated purpose of the rulemaking process was to enhance the safety of the travelling public by reducing pilot fatigue. This NPRM does neither." Captain Sullenberger and first officer Jeffery Skiles were the pilots of a US Airways Airbus A320 that ditched into the Hudson River in January 2009. Sullenberger retired from US Airways in March of this year, and Skiles serves as vice president of CAPA.