David Michael Shinn

Document ID: FAA-2009-1093-0372
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: October 25 2010, at 12:00 AM Eastern Daylight Time
Date Posted: October 25 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: 80b75c0c
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This is comment on Rule

Flightcrew Member Duty and Rest Requirements

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I think this is a step backwards with regards to flight time and will result in increased fatigue on long-haul international flights. There's no apparent accounting for circadian swaps and multiple time-zone crossings. There's no INTENT comment with the regulations, which will result in companies putting their own 'spin' on the regulation, and causing the FAA attorneys to defend and/or support, or deny what the Company's interpretation is. I've fought this with the multi-leg augmented flights under Supplemental Ops. Just add more crew members and puddle jump them around the Pacific, rather than use the extra crew member as they were intended to accomplish that single long range flight. The FAA attorneys won't oppose airline management, and this slide in rules in their favor will hurt aviation safety.