After the FAA released the new revised flight and duty rules
on December 21st many pilots took a big sigh of relief. It is clear
to the public and aviation community the amendment will fabricate a shortage of pilots in all 121 operations. There are
a few key points the new rules change such as higher minimum rest periods,
cumulative flight and duty time limits, new training requirements, and fit for
duty releases. In my personal opinion, the greatest impact will lie within the
flight time limits of previously 8 hours to the increased 10-hour rest
requirement. As a training
dispatcher and commercial pilot I may have a skewed analytical view,
but clearly anyone is capable of seeing how these small changes will shift the
industry.
The recommended amount of sleep required for a healthy body
is 8 hours according to The National Sleep Foundation. The previous rest requirements in place
gave airline pilots a minimum of 8-hour rest period. All that means is that
they are off the clock for 8 hours. Therefore, as soon as their tasks are
complete on their last flight for the day that 8 hours starts. Let say a pilot
arrives at the gate around 11:30 p.m. at our local Detroit Metro Airport. It
takes an hour to empty and close down normal procedures. They are off the clock
at 12:30 a.m., but are required to be back at the airport by 8:30 a.m. for there next
flight. Said pilot arrives at their hotel around 1:00 a.m. to have a meal and hit the sack
around 2:00 a.m. The Pilot would have to be awake by 7:00 a.m. to shower, eat breakfast, and
commute back to the airport. At most, after factoring the normal everyday
functioning activities with this scenario said pilot is obtaining 5 hours of
sleep. Now that is not healthy! In fact, as most individuals know, running on
five hours of sleep consistently will not only cause a massive amount of sleep
debt, but also have a noticeable decrease in the normal functions of an everyday
human being. To learn more about
functions of sleep and contributing factors visit The National Institute of Health website.
The FAA release states “a pilot must have an opportunity for
8 hours of uninterrupted sleep within the 10 hour rest period.” The new rules
will allow each pilot the opportunity to obtain those 8 hours. Previously, there
was no language referencing “uninterrupted” therefore the new rule guarantees
the option for a full 8 hours.
Financially speaking, the new 10 hours minimum will require
a change in previous procedures of the airlines. Generally, the same crew who
flew a plane in and landed at 11pm will have the flight out of the destination
at 6am. To keep those same flight times
available the airlines will have to schedule another crew to pick up those
shifts. As you can see this will require an influx in crews if they wish to
keep the same amount of business creating new training and wages. There may be
a change in the schedule of flights as well as an increase in fares due to the
incurred costs the airlines will be responsible for. The FAA states the new
benefits will cost the industry around $300 million but the benefits of more
safety and less accidents due to fatigue will is estimated between $247–$470
million.
Cargo Companies (Part 135 Operations) were excluded from the
amendment of rest requirements due to insufficient cost benefits. After
analyzing the situation I would have to agree with the FAA’s decision of
exemption. The Cargo portion of the industry is an entirely different animal.
There is not a set schedule for operations like the airliners and they work
with inconsistent variables. To have the same set of rules is not logical for
their operations.
I however do agree
with cargo pilots in the argument of changing the rest requirements to work
with their specific operations. By not having a schedule the general vibe of
the industry in comparison to the airlines is more relaxed. Cargo companies do
not have the same business values as the airlines have with customer relations.
Of course there is customer base, which have a more personal relation with the
company than airlines with the general public. By working with the public the
airlines undergo certain pressures such as frustrated customers due to
increased fares, small seats, baggage fares, lost items, delays, cancellations,
turbulence, and reputation. Cargo corporations are omitted from most of these
pressures. Furthermore, as we discussed
in class the change would cause most of the cargo companies to go bankrupt, as
they would have to double their crews to make up for the duty rules. This would
cause undue stress on the already struggling economy causing a monopoly within
the large cargo providers therefore defying our economic principles.
These factors alone bring me to the conclusion Airlines and Cargo Companies should
not have the same regulation structure. It’s like running a zoo. You can have
the overall structure of centralizing many species of animals in one place, but
there is no way you would keep the cats (lions, tigers, panthers) in the same building as the reptiles. To reiterate my solution to the
financial impact on cargo airlines and fatigue rules involves forming a
different set of key points that is catered to the needs of the cargo
companies. Such as with our example in class to expect a pilot to be fit for
duty after being awake for 30 hours already is utterly vacuous and an accident
waiting to happen. Something needs to change and it will take time before it is
concluded.
One of the nicest aspects of the new rules/regulations is the fact that airlines will need to hire more pilots. From a pilot perspective, this is awesome news. From an airline perspective, not so much, since the ensuing costs would roughly be at least $300 million according to the FAA. You had mentioned that there may be a change for passengers in the sense of an increase in fares. I'd be willing to bet that's virtually a guarantee. But, the change won't be much, probably about +$5 a ticket. American Airlines flies approximately 80-90 million passengers each year, while in 2010 Delta carried roughly 110 million. So, a mere $3-$6 surcharge or so per passenger ticket fares for vastly improved working conditions for the pilots and significantly improved safety sounds like a bargain. Most passengers probably wouldn’t even recognize the slightly higher fares, or, would simply attribute it to economic inflation, so they likely wouldn't gripe much about it.
ReplyDeleteNice and pretty thorough discussion. I would have like to have seen a little more original thought, however, as many of your points were from examples directly given in class.
DeleteI believe it is true that the costs associated with implimenting this regulation to cargo companies would shut down most of the smaller companies and leave us with just a few of the giants in the industry. Also, nice analogy using the zoo. Keep in mind however that this regulation applies only to Part 121 carriers, so the cargo companies exempt from this regulation are largely 121 Supplemental carriers.
ReplyDeleteI really like how you explained your rationale. I particularly liked the zoo analogy for describing cargo carriers. I would however be interested in hearing any ideas you have for a legislation for the cargo carriers.
ReplyDeleteVery good examples and facts! The National Sleep Foundation requires 8 hours sleep, cant agree more! Very good examples with the cargo carriers, never worked or been to a cargo carrier but everything I hear, does sound like a zoo. Enjoyed the blog!
ReplyDeleteThis is very good on examples I think, since I touch on sleep depravation, you outline the time limit and usage of an individuals personal time. I also like the zoo comparison, because it actually does make alot of sense. Good blog.
ReplyDelete