By Stephen A. Alterman, President, Cargo Airline Association

With the debate over the most effective way to reduce crewmember fatigue still raging, it is vitally important to understand that the all-cargo air carrier industry continues to support changes to existing FAA regulations in this important safety area. This reassessment, however, must take into account the operational realities of the aviation marketplace and must be firmly rooted in fatigue science as that science applies to the airline industry. The Cargo Airline Association’s proposal for moving forward, a proposal that recognizes the impact of multiple flight segments and “time of day,” as well as affording pilots substantially greater rest opportunities and shorter duty days, takes these factors into account.

The all-cargo industry and other industry segments have always been outspoken leaders in support of the highest levels of safety. Our industry’s excellent safety record speaks for itself and reflects the total commitment of management, our pilots and support personnel. Public trust and confidence demand we adhere to and attain the highest standards of safety. Indeed, it is in our financial self-interest to do so.

In addition, as noted above, the all-cargo industry has been a leading proponent of modernizing the FAA’s pilot flight-time, duty-time rules. We participated fully in the FAA’s Aviation Rulemaking Committee (ARC), chartered by the FAA in 2009 to address the pilot fatigue issue, and the Cargo Airline Association (CAA) formally submitted a detailed proposal urging the FAA to adopt more stringent duty-time limits and rest rules that are based on science and operational experience and that recognize the operational differences among different segments of the industry.

The CAA’s proposed rules would (1) increase flight crew rest opportunities by 25-50%, depending on whether the operation is domestic or international; (2) decrease flight duty periods by 12.5-44%; (3) recognize the impact of “time of day” and “multiple operational segments” in the pilot fatigue equation and adjust the daily flight duty period accordingly.

The cargo industry strongly urged the FAA to recognize that various aviation industry segments have substantially different operational characteristics and that the only way to ensure the highest level of safety is to tailor the regulations to recognize these unique characteristics. Perhaps the best statement of this principle was made by FAA Administrator Randy Babbitt when he said, “In rulemaking, not only does one size not fit all, but it’s unsafe to think that it can.”

Regrettably, the FAA failed to acknowledge the safety records of the various segments and failed to consider carefully thought-out CAA safety proposals. It incorrectly assumed a mature body of scientific knowledge when, in fact, fatigue science as it applies to the airline industry is very much incomplete. And contrary to the FAA administrator’s admonition, the FAA proposed a “one-size-fits-all” rule that doesn’t work because aviation operations are simply not all the same.

By the FAA’s own admission, the proposed rule is designed to address the domestic passenger airline business model. But the rule must protect safety by taking into account the vast differences in domestic, international, scheduled, charter, passenger and cargo operations. While all pilots may have the same physiology, they do not all have the same duty schedules, cumulative flight hours and rest opportunities. The FAA’s proposed rule gave no consideration to whether a pilot is flying multiple daily short-haul commuter flights or a single daily long-haul international cargo flight on aircraft with private rest facilities and staffed with additional flight crews. CAA member carriers, by design, tend to fly more nighttime and long-haul routes. And our pilots already average substantially fewer flying hours each month than our passenger counterparts.

More importantly, FAA’s proposal fails the most basic test—it does not increase safety and will not prevent accidents. At the same time, it will burden U.S. airlines with the most restrictive and costly flight duty rules in the world. Any safety benefits of proposed regulations must be weighed against the projected costs of implementation. The FAA’s proposed rule utterly fails the required cost-benefit test. For the all-cargo industry, the safety benefits are virtually non-existent, while the resulting costs would be in the billions of dollars. For every dollar of benefit, the proposed rule would impose an overwhelming $3,800 in costs. Perhaps the best evidence of the lack of material safety benefits comes from NTSB data which reveal that, since 1982, there have been only two cargo accidents in which fatigue has been a cause or contributing factor. And, the proposed new rules would not have prevented either accident.

The FAA needs to revamp its rule to ensure that it is based on existing sound scientific principles as they relate to the aviation environment and reflects the vastly different operating sectors of the airline industry. CAA’s proposed rules would accomplish those objectives and should be adopted in lieu of the FAA’s “one-size-fits-all” proposal.

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