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Appendix C: Summary of Stakeholder Response to Committee Request for Input
Pages 141-146

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From page 141...
... between our sending these requests and the meetings of the committee, the response rates from the stakeholders considered here were relatively modest, a total of 29. The committee conducted a qualitative review of written input received by March 23, 2011, which included responses from 25 individual airlines (4 mainline passenger carriers, 8 regional passenger carriers, 9 cargo carriers, and 4 nonscheduled charter carriers)
From page 142...
... . Two of the respondents did not offer definitions, stating that "any definition of ‘commuting' would be purely subjective" and "commuting cannot be defined." Four respondents emphasized that a "one-size-fits-all" definition of commuting would be inappropriate because pilot and crewmember commutes may involve multiple different modes of travel, as well as widely variable travel distances and times, with a variety of en route activities.
From page 143...
... For example, according to a pilot from one mainline carrier, commuting to one specific domicile increased by a factor of 2 -- from 30 to 60 percent -- when flights operated from another domicile of that carrier were substantially reduced. Summarizing the responses from two airline associations, two pilot associations, two individual pilots, and nine individual airlines, the percentages of pilots who commute by air range from less than 5 percent to nearly 90 percent depending on a wide range of factors, including type of airline, particular domicile, and phase of airline restructuring.
From page 144...
... Also, six respondents said that commuting pilots -- especially those who travel relatively long distances -- should plan their commutes for proper rest at their domiciles before reporting for operational duty. In this vein, six respondents said that commuting directly into a work period from a remote location without proper rest along the way is a bad practice.
From page 145...
... duty assignments, which increases the level of fatigue and, in some cases, would increase their effective duty days beyond proposed FAR [Federal Aviation Regulation] maximums." Such strong negative opinions were expressed not only by some air carriers but also by individual pilots.
From page 146...
... They urged that a new regulation be put in place whereby all commercial air carriers would institute standardized nonpunitive sick leave, fatigue, and commuting policies, unlike the wide variety of punitive, nonpunitive, and nonexistent policies that currently prevail. Furthermore, one respondent suggested that airlines' commuting policies should be coordinated with the scheduling of back-up commuter flights through CASS (the Cockpit Access Security System)


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