DE727UPS
Well-Known Member
http://www.ipapilot.org/letters/ChiefPilotsLetter.pdf
"As the Chief Pilots of America’s largest all-cargo airlines, we are writing to explain why
changing the flight and duty time rules that apply to all-cargo carriers is a bad idea and that doing
so could actually make our operations less safe and put our pilots at risk.
The Federal AviationAdministration (FAA) has carefully analyzed changing the rest rules and found virtually zero
benefit in applying the passenger fatigue rules to all-cargo carriers. Additionally, on March 24,
2016, the US Court of Appeals denied the Independent Pilots Association's Petition to change the
rules and found that the FAA acted reasonably in its decision to exempt all-cargo pilots from Part
117 passenger pilot rest rules. However despite this, we understand Senator Boxer has offered
amendment #3489 that would apply the passenger carrier rules to our very safe all-cargo
industry. We have been working in all-cargo operations around the globe for a combined 121 years of
experience between us, and during that time we have come to understand the effects of fatigue as
well as the ways to prevent or mitigate that fatigue. Put simply, measures used to prevent fatigue
must be different for passenger carriers than they are for cargo carriers because our work
schedules are different. We fly fewer legs, have longer layovers. and have better rest
opportunities on our trips, including while technically “on duty” waiting for our nightly sorts to
occur. Resting during the loading of aircraft has a dramatic impact on our alertness. This rest,
our longer layover times, and the ability to call in fatigued, makes our operation and how we deal
with fatigue at night a proven success. We typically start fewer trips per month, thus affording us
better opportunities to be fully rested before we fly and better opportunities to recover thereafter.
Perhaps most significantly, we fly an average of 34 hours per month (express segment) and 45.5
hours per month (heavy freight segment) – while passenger carrier pilots fly approximately 60
hours each month. Over the years, we have capitalized on the unique opportunities for fatigue risk management
systems that offer scientifically sound protections on top of existing FAA regulations. These
systems are tailored to the flying we do, and they help keep us rested and safe. Imposing rules
that are clearly designed for passenger airline operations on all-cargo carriers would be illadvised
and unwarranted. We are proud to work for airlines that have gone above and beyond the requirements of existing
cargo regulations and that are at the forefront of fatigue risk management research. Rest assured
that, as pilots, we do not take any aircraft safety issue lightly. We simply ask that, if faced with
misguided attempts to apply passenger-centric Part 117 rules to cargo airlines, you consider our
strong belief that such efforts would be counterproductive and vote no on Senator Boxer’s
amendment #3489. Thank you for your time and consideration of this important safety issue."
I like this part "and have better rest opportunities on our trips, including while technically “on duty” waiting for our nightly sorts to occur. Resting during the loading of aircraft has a dramatic impact on our alertness."
You can't make this stuff up. I did some night sort stuff through SDF a couple weeks ago and had two hours of this new "cargo cutout rest". Didn't get any sleep, sadly to say. Something must be wrong with me.
"As the Chief Pilots of America’s largest all-cargo airlines, we are writing to explain why
changing the flight and duty time rules that apply to all-cargo carriers is a bad idea and that doing
so could actually make our operations less safe and put our pilots at risk.
The Federal AviationAdministration (FAA) has carefully analyzed changing the rest rules and found virtually zero
benefit in applying the passenger fatigue rules to all-cargo carriers. Additionally, on March 24,
2016, the US Court of Appeals denied the Independent Pilots Association's Petition to change the
rules and found that the FAA acted reasonably in its decision to exempt all-cargo pilots from Part
117 passenger pilot rest rules. However despite this, we understand Senator Boxer has offered
amendment #3489 that would apply the passenger carrier rules to our very safe all-cargo
industry. We have been working in all-cargo operations around the globe for a combined 121 years of
experience between us, and during that time we have come to understand the effects of fatigue as
well as the ways to prevent or mitigate that fatigue. Put simply, measures used to prevent fatigue
must be different for passenger carriers than they are for cargo carriers because our work
schedules are different. We fly fewer legs, have longer layovers. and have better rest
opportunities on our trips, including while technically “on duty” waiting for our nightly sorts to
occur. Resting during the loading of aircraft has a dramatic impact on our alertness. This rest,
our longer layover times, and the ability to call in fatigued, makes our operation and how we deal
with fatigue at night a proven success. We typically start fewer trips per month, thus affording us
better opportunities to be fully rested before we fly and better opportunities to recover thereafter.
Perhaps most significantly, we fly an average of 34 hours per month (express segment) and 45.5
hours per month (heavy freight segment) – while passenger carrier pilots fly approximately 60
hours each month. Over the years, we have capitalized on the unique opportunities for fatigue risk management
systems that offer scientifically sound protections on top of existing FAA regulations. These
systems are tailored to the flying we do, and they help keep us rested and safe. Imposing rules
that are clearly designed for passenger airline operations on all-cargo carriers would be illadvised
and unwarranted. We are proud to work for airlines that have gone above and beyond the requirements of existing
cargo regulations and that are at the forefront of fatigue risk management research. Rest assured
that, as pilots, we do not take any aircraft safety issue lightly. We simply ask that, if faced with
misguided attempts to apply passenger-centric Part 117 rules to cargo airlines, you consider our
strong belief that such efforts would be counterproductive and vote no on Senator Boxer’s
amendment #3489. Thank you for your time and consideration of this important safety issue."
I like this part "and have better rest opportunities on our trips, including while technically “on duty” waiting for our nightly sorts to occur. Resting during the loading of aircraft has a dramatic impact on our alertness."
You can't make this stuff up. I did some night sort stuff through SDF a couple weeks ago and had two hours of this new "cargo cutout rest". Didn't get any sleep, sadly to say. Something must be wrong with me.
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