Ryan Gibson

Document ID: FAA-2009-1093-0353
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: October 18 2010, at 12:00 AM Eastern Daylight Time
Date Posted: October 18 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: October 15 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: November 15 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b721eb
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This is comment on Rule

Flightcrew Member Duty and Rest Requirements

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1. The flight time requirements should not be increased from 8 to 10 hours. Recommendation: The rule does not address flightcrewmember "sits" in airport outstations/hubs throughout the day that are fatiguing and do not provide a place for the pilots to rest. I recommend that consideration be given to a flightcrew memeber that has to sit in an airport for 3-5 hours after completing a flight and before the next flight begins. Example: A pilot is scheduled to fly from DCA - BDL and sit for 4 hours before flying from BDL - DCA and then subsequently fly to MCI. Recommendation: The FRMS program should include oversight of flight pairings to ensure fatiguing schedules are not built that are potentially fatiguing. Currently, most airlines say that their computers build the pairings and take no responsibility in the fatiguing schedules. Recommendation: All flight duty times and flight hour limits should be "hard" times and the rule should not include any "reduced" or "legal to start, legal to finish" clauses.