CAPA Urges FAA to Change NPRM on Flight and Duty Time

Contact: Captain Paul Onorato (202) 624-3540

Washington, D.C. (September 16th, 2010)—The Coalition of Airline Pilots Associations (CAPA) which represents over 28,000 commercial passenger and cargo pilots is concerned that portions of the Noticed of Proposed Rulemaking (NPRM) on Flight and Duty Time published on September 14th, 2010 may have a negative impact on flight safety.

While CAPA applauds the Federal Aviation Administration (FAA) for looking at a broad range of causal factors with regard to fatigue mitigation, CAPA’s Safety professionals have exhaustively analyzed the NPRM and feel the solutions proposed by the FAA often address industry economic issues to the exclusion of safety concerns.

Although the proposal places limits on how long pilots can be on duty based on time of day, it falls short of the mark to protect pilots against fatigue in many areas.
1) The rule proposes a 25% increase in the amount of flying a pilot can be expected to accomplish in a day.
2) For augmented (3 person) crews there is no specified limit on hours flown in a duty day. 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.
3) The rule calls for a 9 hour rest period which still does not allow enough rest time for a pilot to get 8 hours of sleep. This minimum rest would apply following extended international flights as well, a major reduction compared to today.
4) Even this 9 hour rest period can be shortened once a week to 8 hours, further inducing fatigue.

Pilot fatigue is an ever present threat to the safety of traveling public and has been identified on the National Transportation Safety Board’s “Most Wanted” list of regulatory changes for two decades. Logical regulatory reforms must take precedence with government regulators over the economic interests of the airline industry. Captain Paul Onorato, president of CAPA says, “You cannot make a pilot less fatigued by requiring them to fly more hours”.

The proposed rule has caught the attention of industry safety experts. In a recent letter to Administrator Babbitt, Captain Chesley “Sully” Sullenberger states, “The stated purpose of the rulemaking process was to enhance the safety of the traveling public by reducing pilot fatigue.This NPRM does neither”.

The Coalition of Airline Pilots Associations is a trade association which represents over 28,000 professional pilots at carriers including American Airlines, Southwest Airlines, UPS, US Airways, Southern Air, ABX Air, Atlas Air Cargo, Kalitta Air, Polar Air Cargo, Arrow Air, Horizon Air, Gulfstream Air, Cape Air, Miami Air, Omni Air and USA 3000.