The Effects of Commuting on Pilot Fatigue (2011) / Chapter Skim
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Appendix D: Qualitative Analysis of Selected Public Comments to Proposed FAA Rules
Appendix D: Qualitative Analysis of Selected Public Comments to Proposed FAA Rules
Pages 147-164
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From page 147... ...
The NPRM specifies "limitations on the hours of flight and duty time allowed for pilots to address problems relating to pilot fatigue" (Federal Register, September 14, 2010) , aspects of which relate to the commuting practices of pilots.
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From page 148... ...
The qualitative data set was comprised of a purposeful sample of the public comments selected as relevant to the following topic areas: • d efinitions of commuting; • p revalence of commuting; • p erceptions of commuting as being problematic (e.g., when the unplanned occurs, such as weather disturbances or mechanical difficulties that delay flights) ; • c haracteristics and examples of responsible commuting; • p erceptions of commuting as less of a choice and more related to external factors (e.g., frequent domicile changes, low salaries, and other industry-related factors)
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From page 149... ...
. The continuous process of visiting and revisiting the narrative data, with an eye toward identifying similarities and differences in meaning and content, results in an interpretive description of the range of meanings associated with each of the topics under investigation.
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From page 150... ...
For example, the final code "frequent moving of domicile bases to new locations" was used to sort the following data: During the last decade, industryrelated factors have forced airlines to move the location of their domicile bases on a frequent basis. In response, a majority of pilots no longer live close to their domicile bases and most feel they are forced to commute to keep the loca tion of family residences stable and affordable.
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From page 151... ...
A large portion of flight crews commute via airlines to their crew base over hundreds of miles, and even over several times zones. Regional carriers are especially prone to opening and closing bases due to contracts with legacy carriers, and their pilots are less likely to be able to afford relocation.
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From page 152... ...
6 Perceptions of Commuting as Less of a Choice and More Related to External Factors Frequent changes in the location of domicile bases are perceived as the major reason for the increased numbers of pilots commuting by air. 42 One of the consequences of dramatically lower pilot salaries over the past 25 years is that some low-paid commuters cannot afford the cost of resting in a hotel or shared apartment as needed.
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From page 153... ...
11 5. To best ensure public safety, the FAA should mandate that air carriers are responsible for calculating the start of flight duty periods differently for pilots who commute by air.
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From page 154... ...
One respondent, representing the views of an organization, provided an overview of issues related to commuting in the context of the airline industry: Commuting is common in the airline industry, in part because of life-style choices available to pilots by virtue of their being able to fly at no cost to their duty station, but also because of economic reasons associated with protecting seniority on particular aircraft, frequent changes in the flight crew member's home base, and low pay and regular furloughs by some carriers that may require a pilot to live someplace with a relatively low cost of living. Three respondents agreed with an experienced cargo pilot who shared his rationale for having chosen to work for a long time for a cargo company: "[T]
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From page 155... ...
and do rest are responsible commuters. Thirty-four respondents wrote comments that agreed with one, that "commuters who report to duty too fatigued to safely fly are not responsible commuters." Fourteen respondents wrote comments that agreed with one, who said that pilots who commute overnight on "red eye" flights and do not have opportunities to rest are "not properly rested for late afternoon or evening flights." Eleven respondents wrote that pilots who are up early in the morning to commute to their domicile bases without opportunities to rest are often not fit for duty for flights later in the day.
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From page 156... ...
All of the respondents on this issue perceived the frequent changes in the location of domicile bases as the major reason for the increased numbers of long-distance commuters. One of the respondents stated that "regional carriers open and close bases more frequently due to contracts with legacy carriers and their pilots are less likely to be able to afford re-location." One respondent provided a brief overview of commuting and domicile relocation practices during the 20th century and the early 21st century: In decades past, commuting was not permitted, and crews lived within driving distance of base.
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From page 157... ...
One respondent argued that there would be an important consequence of instituting the proposed NPRM due to the low pay of some pilots who cannot afford to pay for a place to rest: "[I] f the new rules go through as written, those of us who don't have a more difficult commute will be flying with pilots who will regularly be up for 24 hours." A solution to the problem was proposed by six respondents who suggested that the FAA should require airlines to subsidize accommodations at low or no cost to the individual commuters.
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From page 158... ...
. One of the respondents noted that, "pilots are the experts in how fit for duty they are or are not -- regulations that dictate where a pilot must live or be before duty would be erroneous at best, would not enhance safety, and would place an unreasonable burden on pilots." Another respondent described how reporting fit for duty is a source of professional pride and adult status for pilots and then made the case that regulations to involve airlines in this assessment are an "onerous intrusion into lives of pilots." This respondent wrote: Pilots are scrutinized more than probably any other profession, includ ing and especially doctors.
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From page 159... ...
Another respondent expressed a special concern for rights to privacy, stating that, "as long as a pilot shows up fit for duty, the airline should not have any right to be concerned with whether a pilot commuted in or not." Yet a somewhat different comment came from a respondent who wrote that "it is best to ensure crewmembers are not exposed to fatiguing conditions rather than assess them after fatigue occurs." One respondent discussed the separate domains of responsibility between labor and management: The concept of the air carrier's ability to manage an individual employee's fitness to fly is erroneous. Airlines have direct control over the time of day of the operations, the number of takeoffs and landings scheduled, and con trolling the effects of crossing multiple time zones.
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From page 160... ...
(N = 27) Several respondents expressed the view that many pilots fear negative consequences if they report unfit to fly, due to fatigue, on the day of flight.
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From page 161... ...
Inadequate Data on Commuting Postpone regulations related to commuting until evidencebased fatigue mitigating practices are identified. Not enough is known about the cur rent number of pilots commuting by air, their commute flight patterns (distances covered and the time it takes)
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From page 162... ...
It is premature, wholly lacks any sci entific study or supporting data, and raises the same issues with regard to incorrectly involving certificate holders in the commuting practices of their flight crew members. One of the 15 respondents provided an explanation as to why individual variation in experiencing fatigue is a key factor in understanding predictors of fatigue among pilots: "[F]
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From page 163... ...
One of them wrote that the public "should be protected from pilots commuting to work from distant locations" and that it was "unacceptable to have a pilot reside in Florida and report for duty in Los Angeles after a long commuting flight." All eight respondents said that public safety would increase if the flight schedules factored in pilots' time zone acclimation. One of them reported that "the legacy carrier I worked for took the issue of fatigue very seriously -- schedules and assignments were made with consideration of circadian rhythms, time zone changes, and prior schedules." Five respondents argued in favor of commuter-specific rules about the start of duty periods.
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