AIN Blog: FAA Fatigue Rules Meet Resistance

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RAA's Scott Foose
In April 25 testimony before the House aviation subcommittee Scott Foose, RAA senior v-p for operations and safety, urged the FAA to count aeronautical experience toward flight time rather than require an arbitrary number of hours. (Photo: Paul Lowe)
May 4, 2012 - 1:28pm

Both of the FAA signature initiatives that arose out of the crash of a regional turboprop in Buffalo, N.Y., more than three years ago are still receiving some pushback from various quarters.  On the subject of fatigue, almost everyone favors more rest for flight crews, and who can argue?

Well, FedEx for one. The shipping giant has criticized an effort by Reps. Chip Cravaack (R-Minn.) and Tim Bishop (D-N.Y.) to extend the FAA’s proposed flight, duty and rest requirements to all-cargo air operations, which were not covered in the final rule.

The lawmakers argue that it is important have one set of rules for the entire Part 121 pilot community. But FedEx said in a statement to The Hill on April 23 that applying the same rules to cargo pilots is a bad idea.

“The proposed legislation attempts to implement a ‘one size fits all’ approach to fatigue mitigation, an approach that the Administration’s own analysis determined was not practical,” FedEx told the political newspaper in the statement. “The FAA recognized that fact when it wisely introduced the Fatigue Risk Management System, allowing carriers and pilots to develop customized plans together to achieve the best possible alertness results.”

Now, Airlines for America (A4A), the trade organization for the leading U.S. airlines, and the Regional Airline Association (RAA), which represents U.S. regional airlines, are urging the FAA to significantly revise its proposed requirements for Part 121 pilot certification and provide a system that recognizes the quality of a pilot’s training and experience, rather than relying solely on a specific number of flight hours.

“Hard-hour minimum requirements are not a substitute for the quality of a pilot’s training and experience,” A4A said in comments filed with the FAA on Tuesday. It noted that the change as proposed by the agency would have unintended consequences. “Failure to provide additional options for meeting the requirements, as recommended by safety experts, will result in an unnecessary pilot shortage and significant barriers to recruiting regional and mainline pilots.”

To avoid such unintended consequences, RAA urged the FAA to substitute the “aeronautical experience credit system” for the proposed academic training credit for flight experience and accept the 500 minimum actual number of flight hours from the proposed 1,000 flight hours.

Flight safety involves far more than accumulating an arbitrarily mandated number of actual flight hours, RAA said. Rather, airline flight safety is ensured only when Part 121 pilot candidates receive the right training in the right training environments.

RAA stressed that the notice of proposed rulemaking creates incentives for individuals to “buy hours in the cheapest way possible” to obtain 1,500 hours for an unrestricted airline transport pilot certificate.

Or, as RAA senior vice president of operations and safety Scott Foose told Congress recently, “Four hours of fair-weather sightseeing in a Skyhawk has minimal benefit as compared to four hours in a modern simulator with a highly trained, professional flight instructor.”

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