FAA's New Pilot Fatigue Regulations

The FAA's new flight and duty time regulations issued in December of 2011 encompass a number of new safety requirements that will help to combat pilot fatigue for Part 121 passenger operations. The new 10 hour minimum rest period will have the largest impact on safety, in my opinion. The existing regulations require only an 8 hour rest period for pilots before they have to report for duty again. This time period begins about 15-20 minutes after arrival once the crew is released from duty, depending on the airline. It does not include time to get out of the airport, transportation time to the hotel or your home,  winding down time, or time to eat. On a R.O.N. (Remain Over Night) trip, this can easily leave the pilots with 5 hours or less to sleep. This is a huge issue in the regional airline industry. Currently, regional airline management is often giving flight crews the bare minimum amount of rest time legally required in order to get the aircraft flying again as soon as possible and to avoid higher costs. A flight crew may pull into the gate at 8:45 pm and have a 6:00 flight the following morning. The airline would probably require them to report by 5:00 am or so, perfectly legal. This requires the flight crew to wake up at, say, 4:00 am.  They may have finally gotten to sleep at 11 o'clock or later the previous night. While many people may be able to function without a problem on 5 hours of sleep or less, I would hate to test out the sleep deprivation coping abilities of the crew while they are flying a highly sophisticated aircraft for up to 8 hours of flight time that day, and an even longer duty day.

To me, the new regulations for crew rest are a significant improvement over the current ones. The new regs will call for a 2 hour increase over the current amount of rest time required, bringing the total to 10 hours. The clock will still start after the crew is released from duty, but it also requires "an opportunity for 8 hours of uninterrupted sleep within the 10-hour rest period." This last statement will assure that pilots are better rested before taking the controls again. With a guaranteed 8 hour sleep period (ultimately optional to the pilot of course), the way I see it, there is a minimum gain of 2 hours of sleep per night which WILL make a huge difference. The full 10 hour period allows the pilot the opportunity to get to the hotel, eat, and relax for a little while and still get about 7 hours of sleep. The additional time will improve both mental and physical health. Although not ideal after one long stressful day and before another, this still meets the lower end of the average sleep requirements and is a major improvement over the current rules

While I have not been able to find any cost numbers specifically attributed to the increased rest period, the total cost to airlines is estimated to be $297 million. In the long run the benefits are estimated to be a median of $360 million. While the cost and benefit numbers seem arbitrarily created for those who only see dollar signs, I do believe that most of the cost will come from the increased rest period. Regional airlines will need to hire potentially 2-3,000 more pilots to fill the holes left in the schedule by the increasing rest demands and the hiring trend projected in the majors. Another effect that it may have on the airlines are less flights per day. With more required rest after a duty day is over, airlines will not be able to get airplanes in as late at night and out as early in the morning on a R.O.N. trip. Unless drastically increasing costs and wasting resources by coordinating additional flight crews and/or aircraft, this may lead to a small decrease in the number of flights operated per day, and would thus tighten the airline's profit margins. I do believe that these factors will have an impact on the traveler. The average airfare rose 8.5% in 2011, and further increases are expected this year. It is a reasonable guess that the hiring, training, and pay of these new pilots has been playing and will continue to play some role in these price increases.

I agree with the exemption of cargo carriers from these regulations. The regulations were created as a reaction to the fury of the general public after the Colgan crash in 2009, and was never intended to be aimed at cargo carriers as well. While pilots for on-demand cargo carriers work some of the hardest schedules on earth, the costs associated with implementing this new rule for such a carrier would be monumental. So many on-demand operations are struggling as it is and would not survive such a huge amount of hiring and training costs. It is the lack of a set schedule in on-demand operations that would make it near impossible to implement this rule. Each pilot would have such a narrow window to fly in with these regulations. Scheduled operators such as FedEx and UPS usually operate overnight during the body's circadian low points, but most of these pilots are used to that set schedule and theoretically it will not be a big fatigue problem.

By flying while fatigued, cargo pilots are putting a lot less at risk than if they were on a passenger airplane loaded with 150 passengers. A cargo plane that crashes due to pilot fatigue is only taking out the flight crew and the airplane (and hopefully no neighborhoods), and not putting so many passengers' lives at risk. The passenger airlines' monetary benefits from the increased crew rest are mostly attributed to the value of a human life, thus creating a large savings when not crashing. The same monetary benefits cannot be applied to a cargo airline carrying generally much less valuable cargo. This is a bit of a sick way to look at things, but it is the way the industry looks at it.

I have a solution to the fatigue problems in the cargo industry that would increase airline flight crew costs by less than one third, as opposed to twice the amount or more for the proposed regulation. In an on-demand operation when a flight crew is called to fly late in their on call time, or if a certain amount of flight time or legs are planned for, one additional pilot will be required for the flight. This allows each pilot to rest for about 1/3 of the flight time-a significant increase over no rest time. This regulation could include a table with such contributing factors as: hours into on call/duty time, total flight planned time, and number of legs planned for. I initially got this idea from trans-oceanic airline operations: Generally at least one extra flight crew member is required in order to reduce pilot fatigue.