Duty Limitations and Cargo Carries

1.  After the Colgan Air accident, the FAA issued new regulations for pilots in order to ensure safer flights for passengers in the United States and abroad. The major new regulation for part 121 operations was the 1500 hour rule. Previously, the requirement to become a co-pilot (first officer) was a commercial pilot license with 250 hours of flight time. After the Colgan Air 3407 crash of 2009, co-pilots were required to have an Air Transport Pilot (ATP) certificate. This requires 1500 total time as a pilot. The new regulations were enacted by the  Federal Aviation Administration Extension Act of 2010. There are some exceptions to obtain an ATP certificate. For example, military pilots are required to have 750 hours of pilot time. Pilots with a Bachelor's degree in aviation are required to have 1000 hours ("Press Release-FAA Boosts Aviation Safety with New Pilot Qualification Standards", 2013).

Duty limitations were modified after the Colgan Air crash. Flight time is now limited to eight or nine hours, depending on the pilot's start time of duty. The time that counts as flight time is any time the aircraft is moving under its own power before, during, and after flight. There is now a requirement of at least 10 hours of rest period between flight duty periods. There must also be an opportunity for 8 hours of uninterrupted sleep for pilots. Additionally, pilots must be free from duty for a period of at least 30 consecutive hours each week. Pilots and airlines are jointly expected to be responsible for considering fatigue. Pilots must state before duty that they feel they are fit to fly ("Press Release-FAA Issues Final Rule on Pilot Fatigue ", 2011).
2. Currently, pilots under Part 135 operations may not exceed 1200 hours in one calendar year. Additionally, there is a maximum of 120 hours of flight time each month. They may not fly more than 34 hours per week either. Pilots are required to have 9 consecutive hours of rest after schooled flight time that is less than 8 hours. For scheduled  flight time more than 8 hours but less than 9 hours, there is a requirement of 10 consecutive hours of flight. For 9 hours or more of scheduled flight time, pilots are required to have 11 consecutive hours of rest ("14 CFR 135.265-Flight Time Limitations" n.d)

3. The main reason that cargo carriers are  not enforced by the FAA by these regulations is that they are too costly compared with the benefit they could generate in this industry ("Press Release-FAA Issues Final Rule on Pilot Fatigue ", 2011). Personally, I believe that this is the main reason that cargo carriers are not enforced by the new rule. However, I do think that public perception plays a big role in this situation. The FAA Extension Act of 2010 was enacted as a response to the public backlash that resulted from the Colgan Air 3407 crash. In order to show that the FAA takes responsibility in ensuring safe transportation for the public, the Extension Act of 2010 was issued. I do not think that value of life played a big reason in the actions of FAA. After all, fatigued and inexperienced pilots not only put their passengers' lives in danger, they also put the lives of everyone else they fly over in danger as well. If value of life was one of the reasons behind the actions of the FAA, then cargo carriers would be required to follow the same rules passenger carriers are required to follow.

4. I do believe that cargo carriers should be required to follow these rules. Fatigue must not be taken lightly. For the value of life of pilots and the general public, I think that the FAA should require cargo carriers to follow the fatigue mitigation rules. Pilots on a UPS flight that crashed in Alabama could be heard saying that they are fatigued. According to transcripts, the deceased pilots complained how cargo carriers are not required to follow the same fatigue rules as airline carriers (Carroll, 2014). If this requirement puts an undue burden on cargo carriers because of costs, then maybe the FAA could make a provision in which cargo carriers are required to implement fatigue rules slowly over a certain period of time. This may mitigate the cost factor that cargo carriers face.

5. If cargo carriers were required to follow the same fatigue rules, then the workplace environment of management operations in cargo operations would significantly change. Schedules will have to be adjusted to follow the same rules. From a management perspective, the workload would most likely increase because there are more requirements to follow in order to make sure pilots are well rested and not fatigued. There are several areas within the management side that need to be addressed. For example, pilot accommodations may need to be adjusted in order to account for pilot rest time. A hotel that is closer to the airport may need to be reserved so that crew members can get adequate rest. More pilots need to be hired in order to create more slack in the schedule since pilots will no longer be allowed to work the same amount of hours. Training facilities may need to be expanded in order to accommodate the increase in pilots being hired. Contracts for cargo deliveries may need to also be adjusted because cargo deliveries might not reach their destinations as quickly as before. Basically, the workload for pilots will decrease while the workload for management will increase.

References

Press Release-FAA Boosts Aviation Safety with New Pilot Qualification Standards (2013). Federal Aviation Administration. Retrieved From: //www.faa.gov/news/press_releases/news_story.cfm?newsId=14838

Press Release-FAA issues Final Rule on Pilot Fatigue (2011). Federal Aviation Administration. Retrieved From:
https://www.faa.gov/news/press_releases/news_story.cfm?newsId=13272

14 CFR 135.265-Flight Time Limitations and Rest Requirements: Scheduled Operations. (n.d). Cornell University Law School Retrieved From:
https://www.law.cornell.edu/cfr/text/14/135.265

Carroll, J (2014). UPS Pilots Urge More Rest for Cargo Crews. USA Today. Retrieved From:  http://www.usatoday.com/story/news/nation/2014/03/13/ups-pilots-urge-more-rest-for-cargo-                    crews/6402615/