I'm going in waves. First I was pissed, then I read the PDf a bit and I wasn't as much. Now I'm going back to thinking that this new proposal has some huge items in it that go backwards in safety.
Yes, transportation will not count as time on duty.
That is fine for going to the layover, but if the van ride to the airport the next day is an hour, shouldn't that county as duty time, or at least be considered for the purposes of how long the crew is allowed to be on duty or fly?
What about now (proposed) where you can start at 0700 domicile time, and be legal to block 10 hours! If the van time needs to be 0600, that's wakeup for most people at 0500-0530 and be legal to block 10 hours and be on duty for 13. I really just don't think waking up at 5:00AM and being able to block 10 hours is a great idea, at all.
Scenario 2:
Standup. 2155 report, the crew does not time out until the next morning at 0855. Many standup/high-speed overnight out-and-backs currently fit well within that timeframe. Even if the airline wants a buffer of 1.5-2 hours for possible MX issues or de-ice delays, the flight could still be scheduled to arrive at around 0700-0730 back at the hub, and we're back to having a crew doing a layover with five hours of sleep again. Right back to square one. Then we're also back to having van time included as rest again, too, although technically it's not even rest. WTF.
Scenario 3:
A couple oceanic flights that would no longer require a third pilot:
DL249
1440 AMS
1720 DTW
Block 8:40
~0700 report eastern time means the crew is legal for 13 hours of duty and 10 hours of block.
AA121
1750 CDG
2030 JFK
Block 8:40
~1030 report eastern time means the crew is legal for 13 hours of duty and 10 hours of block.
A friend of mine does Europe at lot with AA out of JFK. Like all the other airlines, they stay downtown in all cities there. The van ride for CDG and many others is 1 hour+. So this is an 8AM wakeup after flying all night the night before (so ZERO rest unless a relief pilot is in the contract), going into an airport that could easily turn 8:40 block into 9-10 if it's having a bad day. No breaks other than a few minutes at a time to use the lav. Again, I just think this is a very long workday with no sleep the night before do be doing with two pilots.
AA005
1335 DFW
1645 HNL
Block 8:10
~ Noon report central time means the crew is legal for 13 hours of duty and 10 hours of block.
Now, here's the return for those:
AA008
1650 HNL
0510 DFW
Block 7:20
~2030 report central time means the crew is legal for 11 hours of duty and 8 hours of block.
AA102
1930 HNL
0800 DFW
Block 7:30
~Same with this one.
So there's two complete trips that would go from 3 pilots, to 2, unless the pilot contract requires a third pilot due to the hours. That's going backwards in safety in my opinion.
I hope I just haven't read this thing enough yet. I think it will eliminate jobs while making some things safer, and other things not as safe as they already are. I'll be sure to comment in this 60 day window if I'm understanding this stuff correctly right now.