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Airlines Sue FAA Over Crew Rest Requirements  
User currently offlineWorldTraveler From , joined Dec 1969, posts, RR:
Posted (5 years 7 months 3 weeks 6 days 15 hours ago) and read 5733 times:

AA, CO, and UA are among airlines that have sued the FAA over crew rest requirements on flights longer than 16 hrs.

"The airlines said in the complaint that they should have had a chance to comment on the rules, which would place yet another financial burden on them."

DL and NW were not part of the lawsuit and have separate agreements with the FAA governing ULH flights. DL is the only US carrier that operates either the A345 or 777LR, the two longest range commercial aircraft.

Here is the link to the Reuters summary. The WSJ carried the original article but it is available to subscribers only.

http://www.reuters.com/article/marke...sNews/idINN0537510320090105?rpc=44

32 replies: All unread, showing first 25:
 
User currently offlineKC135TopBoom From United States of America, joined Jan 2005, 12136 posts, RR: 51
Reply 1, posted (5 years 7 months 3 weeks 6 days 15 hours ago) and read 5599 times:

"FAA has neither demonstrated how the rule will advance safety, considered the potential that the rule may actually diminish safety, nor justified the significant costs of the rule against any purported benefit, the carriers said."

I fail to see how allowing a longer crew rest period after a 16 + hour flight duty may actually diminish safety.

Quoting WorldTraveler (Thread starter):
DL is the only US carrier that operates either the A345 or 777LR, the two longest range commercial aircraft.

In this case mentioning the A-340-500 does not apply here, as this rule would only effect US flag carriers. No US flag carriers are likely to ever order the A-340-500/IGW. But, this rule would also effect those flying the B-747-400/F/ERF, B-777-200ER/-LR/-LRF, B-777-300ER (if any US airline ever orders it, DL is a possibility), B-767-200ER/-300ER/ERF, A-340-300 (if US is still looking for them) or A-330-200/-300 as any one of these airplanes could have a tech problem before departure, and push the flight crew through that 16 hour window. So, the US airlines that would be effected by this new rule would be AA, CO, DL/NW, UA, US, FedEx, UPS, Atlas.


User currently offlineCubsrule From United States of America, joined May 2004, 22924 posts, RR: 20
Reply 2, posted (5 years 7 months 3 weeks 6 days 15 hours ago) and read 5587 times:



Quoting KC135TopBoom (Reply 1):
I fail to see how allowing a longer crew rest period after a 16 + hour flight duty may actually diminish safety.

Ultimately, though, it's irrelevant that the chances of the rule diminishing safety are low.

Like other federal agencies, when the FAA promulgates a rule, it must follow the proper notice and public comment procedures. According to the airlines, it did not do so. They have every right to sue.



I can't decide whether I miss the tulip or the bowling shoe more
User currently offlinePar13del From Bahamas, joined Dec 2005, 7145 posts, RR: 8
Reply 3, posted (5 years 7 months 3 weeks 6 days 14 hours ago) and read 5519 times:

Some what shocked by this, usually it is the NTSB pushing safety rules and regulations and the FAA siding with the airlines and knocking it down. Warrants more research, if the FAA is behind this something must be afoot.

As for the issue with the DL-777LR, I don't think they have been ordered with the extra fuel tanks, he fuss may be about delays etc. which will drive the time over 16Hours.


User currently offlineWorldTraveler From , joined Dec 1969, posts, RR:
Reply 4, posted (5 years 7 months 3 weeks 6 days 14 hours ago) and read 5475 times:



Quoting KC135TopBoom (Reply 1):
I fail to see how allowing a longer crew rest period after a 16 + hour flight duty may actually diminish safety.

there is some scientific evidence that extended time in another time zone after crossing multiple time zones might decrease mental performance if the time in the destination time zone is not long enough for the body to fully adjust. ie... mental performance might be best with one night of rest in the destination time zone but might decrease if the time exceeds one night but is less than the number of days necessary to fully adjust to the new time zone.

However, sleep research is not conclusive and there has been far more documented regarding being unable to perform mentally due to not having enough rest than from being forced to rest more than one desires. It is far easier for a person to burn excess energy if they feel fully rested than to do a job while not having sufficient rest. anyone with specifics is welcome to post them.

I do not know the specifics of either the new requirements by the FAA (which are the basis of this suit) or the agreements DL or NW have (and they are separate agreements since both still have their own op. certs) but I am quite sure that DL's India crew members have extended layovers and have specified off periods after they return from their trips.

Quoting KC135TopBoom (Reply 1):
In this case mentioning the A-340-500 does not apply here

The 345 and the 777LR are the only two commercial airplanes that can consistently operate flights greater than 16 hrs on a scheduled basis. Yes, any int'l flight can stretch beyond 16 hrs with delays. The FAA wants to deal with unscheduled flights that push beyond 16 hrs of duty time and scheduled flights that exceed 16 hrs. I believe there are only a couple US operated flights from/to the US that exceed 16 hrs on a scheduled basis and IIRC they involve India.


User currently offlineCubsrule From United States of America, joined May 2004, 22924 posts, RR: 20
Reply 5, posted (5 years 7 months 3 weeks 6 days 14 hours ago) and read 5403 times:



Quoting WorldTraveler (Reply 4):
I believe there are only a couple US operated flights from/to the US that exceed 16 hrs on a scheduled basis and IIRC they involve India.

You know DL better than I do and can likely fill us on on the length of their ULH flights, but I don't believe that AA, UA, or CO has a flight blocked at more than 16 hours.

ORD-DEL on AA is blocked at 14:40 ORD-DEL and 15:40 DEL-ORD.

ORD-HKG on UA is blocked at 15:38 ORD-HKG and 14:08 HKG-ORD.

EWR-HKG on CO is blocked at 15:55 both directions (convenient, isn't that?).



I can't decide whether I miss the tulip or the bowling shoe more
User currently offlineTranspac787 From United States of America, joined Jul 2007, 3205 posts, RR: 13
Reply 6, posted (5 years 7 months 3 weeks 6 days 14 hours ago) and read 5368 times:



Quoting WorldTraveler (Reply 4):
Yes, any int'l flight can stretch beyond 16 hrs with delays. The FAA wants to deal with unscheduled flights that push beyond 16 hrs of duty time and scheduled flights that exceed 16 hrs. I believe there are only a couple US operated flights from/to the US that exceed 16 hrs on a scheduled basis and IIRC they involve India.

Both per the FAR's and the NW/DL contract, any flight deck duty in excess of 8 hours requires no less than a 24 hour rest period after the flight is completed. That is, if a flight scheduled to be shorter than 16 hours breaches the 16 hour mark, 24 hour rest is required. In addition to this, for all flights scheduled longer than 16 hours (ATL-BOM, ATL-PVG) the layover must be at least 24 hours.

Incidentally, this same rule applies in various situations. For all flights scheduled shorter than 8 hours with a single crew (2 pilots), but exceed the 8 hour mark, the crew must have a 24 hour rest period.

For all flights with a 1.5 crew (3 pilots) scheduled shorter than 12 hours, but exceed the 12 hour mark, the crew must have a 24 hour rest period.

For all flights with a double crew (4 pilots) scheduled shorter than 16 hours, but exceed the 16 hour mark, the crew must have a 24 hour rest period.

And finally, for all flights in excess of 16 hours that do not have a triple crew (5 or 6 pilots), there is a minimum mandatory 24 hour rest period though I believe on the ATL-BOM flights, it's a 48 hour rest period.

Quoting WorldTraveler (Reply 4):
and IIRC they involve India.

HKG as well. Both ORD-HKG with UA and *especially* EWR-HKG with CO have a bad habit of going north of 16 hours duration during peak-jetstream season in the winter.

Even when UA ran LAX-HKG, it would come dangerously close to the 16 hour mark during the winter, around 15:30 to 15:40.


User currently offlineIkramerica From United States of America, joined May 2005, 21511 posts, RR: 60
Reply 7, posted (5 years 7 months 3 weeks 6 days 14 hours ago) and read 5334 times:



Quoting WorldTraveler (Reply 4):
ie... mental performance might be best with one night of rest in the destination time zone but might decrease if the time exceeds one night but is less than the number of days necessary to fully adjust to the new time zone

Jetlag usually kicks in during the second night of a multi-timezone trip. The first night your body is too disoriented to do anything but sleep when needed, but the subsequent nights, your body is trying to adjust it's rhythms to the new daylight cycle and can crash in the attempt.

Spending less than 24 hours may thus be beneficial to safety. Comment and study should have been allowed…



Of all the things to worry about... the Wookie has no pants.
User currently offlineDutchflyboi From Netherlands, joined Apr 2008, 333 posts, RR: 0
Reply 8, posted (5 years 7 months 3 weeks 6 days 13 hours ago) and read 5268 times:



Quoting Cubsrule (Reply 5):
but I don't believe that AA, UA, or CO has a flight blocked at more than 16 hours.

CO 49 BOM EWR is blocked for 16:15


User currently offlineNCB From , joined Dec 1969, posts, RR:
Reply 9, posted (5 years 7 months 3 weeks 6 days 13 hours ago) and read 5208 times:



Quoting WorldTraveler (Reply 4):
there is some scientific evidence that extended time in another time zone after crossing multiple time zones might decrease mental performance if the time in the destination time zone is not long enough for the body to fully adjust. ie... mental performance might be best with one night of rest in the destination time zone but might decrease if the time exceeds one night but is less than the number of days necessary to fully adjust to the new time zone.



Quoting Ikramerica (Reply 7):
Jetlag usually kicks in during the second night of a multi-timezone trip. The first night your body is too disoriented to do anything but sleep when needed, but the subsequent nights, your body is trying to adjust it's rhythms to the new daylight cycle and can crash in the attempt.

Spending less than 24 hours may thus be beneficial to safety. Comment and study should have been allowed…

Indeed these are rationals.
Sometimes shorter rests are more beneficial to longhaul ops because they would not disrupt circadian rythms as opposed to longer rests.


User currently offlineADXMatt From United States of America, joined Jul 2006, 950 posts, RR: 2
Reply 10, posted (5 years 7 months 3 weeks 6 days 10 hours ago) and read 5004 times:



Quoting Transpac787 (Reply 6):
*especially* EWR-HKG with CO have a bad habit of going north of 16 hours duration during peak-jetstream season in the winter.

This flight performs very well actually. We're not allowed to exceed the 16hrs on more then 10% of the frequecies. We actually come in significantly lower then that.

Quoting Dutchflyboi (Reply 8):
CO 49 BOM EWR is blocked for 16:15

This is when the crew is back at base so extended rest is not much of an issue. Having 2 sets of crews on layovers at the outstations is where the costs come in. Not only from hotels and per diem but more so from lack of productivity.

Most crews don't want to be away longer then they are anyhow. They're not getting paid (except per diem) and would rather be flying and making money or at home with their family.

The crew who brings in the flight today takes it out 24+ hours later. take away debriefing and check in the next day and travel to/from the hotel you still have a good 20 hours. (provided the flight was ontime.) you are going to be rested. That is if you actually rest and don't go bar hopping and shopping all day/night.  Smile


User currently offlineIkramerica From United States of America, joined May 2005, 21511 posts, RR: 60
Reply 11, posted (5 years 7 months 3 weeks 6 days 10 hours ago) and read 4971 times:



Quoting ADXMatt (Reply 10):
That is if you actually rest and don't go bar hopping and shopping all day/night.  

Which is what the FAA should REALLY be focusing on.  Wink



Of all the things to worry about... the Wookie has no pants.
User currently offlineWorldTraveler From , joined Dec 1969, posts, RR:
Reply 12, posted (5 years 7 months 3 weeks 6 days 8 hours ago) and read 4851 times:



Quoting Par13del (Reply 3):
As for the issue with the DL-777LR, I don't think they have been ordered with the extra fuel tanks, he fuss may be about delays etc. which will drive the time over 16Hours.

DL already operates over 16 hr flights.... BOMATL now. ATLJNB soon. BOMATL is 17.55 and 8500 miles which is the longest flight operated by a US airline.

Quoting Dutchflyboi (Reply 8):
CO 49 BOM EWR is blocked for 16:15

since DL blocked BOMJFK at least that long, it was a given CO would have to do the same.

Quoting Ikramerica (Reply 7):
Spending less than 24 hours may thus be beneficial to safety. Comment and study should have been allowed…

agree that circadian rhythms may be less affected by a short turnaround but the scientific research has to be there to justify it.

again, there is far more research to show the effects of insufficient sleep on brain performance than research about resetting circadian rhythms.

Quoting ADXMatt (Reply 10):
The crew who brings in the flight today takes it out 24+ hours later.

that may be the case for one particular crew but it won't work on a regular basis.... a crew that turns around that quickly more than couple times will time out long before the month is over.


User currently offlineMm320cap From United States of America, joined Jul 2004, 227 posts, RR: 3
Reply 13, posted (5 years 7 months 3 weeks 5 days 15 hours ago) and read 4006 times:



Quoting ADXMatt (Reply 10):
The crew who brings in the flight today takes it out 24+ hours later. take away debriefing and check in the next day and travel to/from the hotel you still have a good 20 hours. (provided the flight was ontime.) you are going to be rested. That is if you actually rest and don't go bar hopping and shopping all day/night.  

You obviously haven't flown long haul as a crewmember. 20 hours is most definitely NOT enough time to be rested for the return flight.


User currently offlineAirNZ From , joined Dec 1969, posts, RR:
Reply 14, posted (5 years 7 months 3 weeks 5 days 15 hours ago) and read 3921 times:



Quoting Mm320cap (Reply 13):
You obviously haven't flown long haul as a crewmember. 20 hours is most definitely NOT enough time to be rested for the return flight.

But I have, and I completely disagree. So can I ask why is it then that most people don't work alternative days......using your logic it follows that someone who, for example, worked a 9/10/11/12 hour day isn't then fit to work again until at least 24 hours later? Bit of a flaw there, is there not and what makes crew so different that such time is insufficient.......unless of course it is 'inwardly' wanted to persue leisure as opposed to the actual need for 'being rested'?


User currently offlineMm320cap From United States of America, joined Jul 2004, 227 posts, RR: 3
Reply 15, posted (5 years 7 months 3 weeks 5 days 11 hours ago) and read 3756 times:



Quoting AirNZ (Reply 14):
But I have, and I completely disagree. So can I ask why is it then that most people don't work alternative days......using your logic it follows that someone who, for example, worked a 9/10/11/12 hour day isn't then fit to work again until at least 24 hours later? Bit of a flaw there, is there not and what makes crew so different that such time is insufficient.......unless of course it is 'inwardly' wanted to persue leisure as opposed to the actual need for 'being rested'?

Well, what you are not considering is jet lag and time zones. Let's say you are a nurse. You work an 18 hour day, which is the duty period we are talking about with these 16 hour flights. It is not unreasonable to expect to have 20 hours off and then go back to work again for another 18 hour shift. But you are talking about being on the other side of the world here, and working the backside of the clock. If you've flown long haul, and you haven't had trouble with fatigue, then you are unique.

Any way you slice it, constant time zone change, jet lag, and having your duty periods constantly changing so that you are working early in the morning, late at night, and then all night long on any given trip is TOUGH on your body.

You seem to suggest that the only reason a crew would be fatigued is if they are out playing around on their layover. It is the rare crew that I've flown with that behaves in such a way. Most of us work very very hard to get enough rest on our layovers. I can't tell you how many times I've been laying awake staring at the ceiling at 4am, which is noon my body clock time.

If you are good to go consistently after 20 hours rest halfway across the world, you are a better person than I am. I'm thankful that the FAA finally recognizes that this is a SERIOUS problem.


User currently offlineMercure1 From French Polynesia, joined Jul 2008, 1390 posts, RR: 2
Reply 16, posted (5 years 7 months 3 weeks 5 days 9 hours ago) and read 3630 times:

Quoting WorldTraveler (Thread starter):
AA, CO, and UA are among airlines that have sued the FAA over crew rest requirements on flights longer than 16 hrs.

Would anyone from an EU, Mideast, or Asian carrier comment on the ULH duty rest requirements they have?
Perhaps the US airlines are also suing because they are being place in a competitive disadvantage vs these other global carriers?

[Edited 2009-01-06 18:09:53]

User currently offlineIkramerica From United States of America, joined May 2005, 21511 posts, RR: 60
Reply 17, posted (5 years 7 months 3 weeks 5 days 9 hours ago) and read 3576 times:



Quoting WorldTraveler (Reply 12):
again, there is far more research to show the effects of insufficient sleep on brain performance than research about resetting circadian rhythms.

16 hours off time is sufficient rest, considering it is combined with a rest period onboard the flight in both directions.

16 hour flight with 8 hours rest + 16 hours rest + 16 hour flight with 8 hours rest = 16 hours on duty and 32 hours off duty in a 48 hour period. Even though some of that middle rest involves getting to and from the airport, eating, etc., it's no different than any other job in that respect.

Can't really see how this is dangerous…



Of all the things to worry about... the Wookie has no pants.
User currently offlineATTart From United States of America, joined Dec 2008, 638 posts, RR: 0
Reply 18, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3558 times:



Quoting Ikramerica (Reply 17):


Quoting WorldTraveler (Reply 12):
again, there is far more research to show the effects of insufficient sleep on brain performance than research about resetting circadian rhythms.

16 hours off time is sufficient rest, considering it is combined with a rest period onboard the flight in both directions.

16 hour flight with 8 hours rest + 16 hours rest + 16 hour flight with 8 hours rest = 16 hours on duty and 32 hours off duty in a 48 hour period. Even though some of that middle rest involves getting to and from the airport, eating, etc., it's no different than any other job in that respect.

Can't really see how this is dangerous...

So, you know this from experience?



Remember: When someone talks behind your back, it only means you're two steps ahead of them!
User currently offlineIkramerica From United States of America, joined May 2005, 21511 posts, RR: 60
Reply 19, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3515 times:



Quoting ATTart (Reply 18):
So, you know this from experience?

Yes, I'm 36 years old and know from plenty of life experience that 36 hours of "rest" in a 48 hour period is a lot of time no matter where you are or what you do. You will naturally go to sleep for some period of time during that 16 hour break no matter what time zone you are in.

Considering that a pilot/FO always has another pilot/FO on duty at all times next to them, combined with the redundancy of the autopilot systems, and that adrenaline during an emergency negates any lethargy, I just can't see how working 16 hours during a 48 hour period with 16 hours break in the middle and time off before and after is unsafe.



Of all the things to worry about... the Wookie has no pants.
User currently offlineAviateur From United States of America, joined Apr 2004, 1352 posts, RR: 11
Reply 20, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3500 times:

I have NO trouble with a 16-hour flight with auxiliary crewmembers and decent on-board rest facilities.

You wanna know what's fatiguing: working for a regional airline, flying eight legs a day with reduced-rest overnights in between. THAT'S fatigue. It bothers me that the FAA and airlines are caught up in controversy over long-haul fatigue, when SHORT HAUL fatigue is the real problem.


PS



Patrick Smith is an airline pilot, air travel columnist and author
User currently offlineATTart From United States of America, joined Dec 2008, 638 posts, RR: 0
Reply 21, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3493 times:



Quoting Ikramerica (Reply 19):



Yes, I'm 36 years old and know from plenty of life experience that 36 hours of "rest" in a 48 hour period is a lot of time no matter where you are or what you do. You will naturally go to sleep for some period of time during that 16 hour break no matter what time zone you are in.

Considering that a pilot/FO always has another pilot/FO on duty at all times next to them, combined with the redundancy of the autopilot systems, and that adrenaline during an emergency negates any lethargy, I just can't see how working 16 hours during a 48 hour period with 16 hours break in the middle and time off before and after is unsafe.

So, your telling me that you have walked in the shoes of a Pilot?



Remember: When someone talks behind your back, it only means you're two steps ahead of them!
User currently offlineLAXintl From United States of America, joined May 2000, 25161 posts, RR: 46
Reply 22, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3472 times:



Quoting Mm320cap (Reply 13):
You obviously haven't flown long haul as a crewmember. 20 hours is most definitely NOT enough time to be rested for the return flight.

I very much beg to differ.

Several carriers, including a large US cargo operator for years has successfully run 12-hour turns to Asia from the US.

Crews have been happy as they not only maximize their flight hours with minimal time away from base, but specifically have commented such quick turns with going to hotel and sleeping and back to work have been less disruptive to them than previous 24+-hour lay overs where they had one foot in the US and the other in Asia timezone wise.



From the desert to the sea, to all of Southern California
User currently offlineAviateur From United States of America, joined Apr 2004, 1352 posts, RR: 11
Reply 23, posted (5 years 7 months 3 weeks 5 days 8 hours ago) and read 3473 times:



Quoting ATTart (Reply 22):
Considering that a pilot/FO always has another pilot/FO on duty at all times next to them, combined with the redundancy of the autopilot systems, and that adrenaline during an emergency negates any lethargy, I just can't see how working 16 hours during a 48 hour period with 16 hours break in the middle and time off before and after is unsafe.

I agree and disagree. It really depends on the arrival/departure times. On long-haul flights with arrivals and departures at funky times of day, timing your sleep is important, and often difficult.

For example: an 8-hour flight lands at sunrise after an overnight crossing. The next leg departs at 0400 the following morning. You can't sleep during the day, after landing, because that screws up your ability to get good rest prior to the 2 a.m. hotel pick-up. Stay up all day, on the other hand, and you feel miserable.

Sometimes a SHORTER layover is actually better.


PS



Patrick Smith is an airline pilot, air travel columnist and author
User currently offlineCubsrule From United States of America, joined May 2004, 22924 posts, RR: 20
Reply 24, posted (5 years 7 months 3 weeks 5 days 7 hours ago) and read 3437 times:



Quoting Ikramerica (Reply 19):
Considering that a pilot/FO always has another pilot/FO on duty at all times next to them, combined with the redundancy of the autopilot systems, and that adrenaline during an emergency negates any lethargy, I just can't see how working 16 hours during a 48 hour period with 16 hours break in the middle and time off before and after is unsafe.

Is the issue rest or the time zone change? I think the two issues might need to be separated, as both are at work here.

Even the longest north-south flights (FRA-JNB or YYZ-EZE) are shorter than 5000 nm, so they won't come close to 16 hours. That means that both the rest issue and the time zone issue come into play for all of the flights in question here.



I can't decide whether I miss the tulip or the bowling shoe more
25 ATTart : I know for me that 24hrs or so rest works for me. But, that is me. I can only speak for myself.[Edited 2009-01-06 19:44:21]
26 Mm320cap : Well, jetBlue pilots also petitioned the FAA to allow transcon turns a few years back because they wanted to maximize time off. Luckily, the FAA tank
27 Mm320cap : I've done that kind of flying too, and you are right, that is very fatiguing as well. Hopefully that will get on the radar as well. It's been interes
28 Mm320cap : You don't get it. 1) You are now halfway around the world. 2) You've crossed 20 timezones during that time 3) Your on-board "rest" is at 8000' in a d
29 WorldTraveler : and the poster is arguing that as a 36 year old, his body should be the barometer for what all int'l crewmembers do. Very, very few crewmembers on fli
30 VHXLR8 : That's what we do at QF, transcon returns, but with no DH, operating both ways LAX-JFK-LAX Now that is a BIG day at the office. How on earth do you t
31 WorldTraveler : with an augmented crew or just 2 pilots? do the FAs do the same thing? also, what is the usual LF on the US transcon segment?
32 XT6Wagon : I think is 95% about how the rule came about, since if you let them start making up rules like this without the proper procedures, it becomes very har
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