"Meeting Expectations"
Peggy Gilligan, Washington, D.C.,
August 6, 2013

ALPA Flight, Duty and Rest Symposium Opening


Remarks as Prepared for Delivery

Good afternoon, and thank you, Captain [Lee Moak]. This is an important topic, and I’m glad we’re here to discuss it. Shedding light on this – having an open discussion about where we are and where we need to go – that’s a good thing. More importantly, it’s the right thing. The bottom line is not in doubt. Everyone has to have a common understanding and a common path for implementation of the new regulations by January 4 – that’s 151 days from today.

Here in America, there are a couple things we expect, things that we really depend on. Coffee. Starbucks has to be right, and when it’s not, we’re going to do something about it. Another is front end alignments. Close enough is not good enough.

Our industry has an expectation of our very own, a must that’s on everyone’s list. Something that the passenger expects each and every time, something that the passenger demands each and every time. There is the formal expectation that the crew is rested and fit for duty. There is no exception, no wiggle room, no close-is-close-enough about it.

America expects everyone in the cockpit is ready to fly. We’re here over the next couple days to talk about the whys and the wherefores, but the bottom line is that the rule expects you to be rested, to be sharp, to have your “A” game from takeoff to touchdown.

While this has been a long time coming, I think it’s also an opportunity for us as an industry to celebrate the true success we’re dealing with here. This is the first successful change in flight duty rules in 30 years. This is how long ago that was: 30 years ago this week, an airline by the name of America West started flying out of Sky Harbor.

We’re celebrating success because we were able to replace a convoluted rule that today has 200 legal interpretations that support it. I think that we’re making a huge step forward, replacing what had become a Rube Goldberg solution with actual science. Instead of “this looks good,” we’re able to use the study of Circadian rhythms to make sure we’re able to provide a higher level of alertness for pilots.

Before I get too much further along, I’ve got to give credit where credit’s due. The Colgan crash was a dark day for all of us. As we all know, the Call to Action that resulted put emphasis on flight duty and rest and a 45-day deadline to get this done. For those of us who’ve participated in calls to action, especially on contentious issues like this one, 45 days is an incredibly tight schedule. But as they say, the rest is history. And we are here to celebrate a job well done.

ARC co-chairs ALPA’s own Don Wykoff and Delta’s Jim Mangie who’re joining us today guided 18 members from the airlines and labor to make this happen. This group recognized early on that they would not be able to reach consensus on every issue. But they were generally successful in agreeing on broad regulatory approaches. I don’t think anyone actually counted the number of hours the ARC put in, but it was very clearly thousands, and this from people who all had full time jobs. But it didn’t stop them. To make sure we understand what the ARC intended, Don and Jim stayed available to help us while we were writing the rule and throughout the entire rulemaking process.

Without the leadership of Don and Jim, supported by the FAA’s Dale Roberts and John Duncan who also are joining us here, and without a couple dozen people really pulling hard to get this done,  today would’ve been just one more discussion about how we really need to get something done about flight and duty.

They were given this task by then-Administrator Randy Babbitt, someone who had a strong personal commitment to this project. His charge: a recommendation for a single approach to addressing fatigue. The ARC delivered on its promise on September 9, 2009. That’s one of those dates that will get lost when historians write the history of aviation, but what the group achieved on that day set a standard that’s literally going to change how we fly.

So what have we done with the ARC’s fine work? We established that the flight duty period begins when a flight crew member is required to report for duty with the intention of conducting a flight. It ends when the aircraft is parked after the last flight. It includes the period of time before a flight or between flights that a pilot is working without an intervening rest period. We limited flight time depending on whether you’re flying at night or flying overnight or flying a half-dozen segments in the middle of the day without ever getting above 5,000 feet. And to define rest, we set a 10-hour minimum rest period prior to the flight duty period. That’s a two hour increase over the old rules. The pilot must have an opportunity for 8 hours of uninterrupted sleep within the 10-hour rest period.

We do allow some flexibility. Using a fatigue risk management system, an operator can customize its schedules to its own business model. A carrier can submit a plan, have it evaluated by fatigue experts and validated by the FAA. And then the operator has to collect data to make sure it works.

This entire approach is built around one thing: fitness for duty. Some have raised concern with pilot commuting. There are many variables that go into the average pilot’s day, and commuting does take its toll. Living in Seattle and flying out of Dallas is not the same thing as living in Fairfax and flying out of Dulles, although given the traffic here, it might actually be easier to live in Seattle and fly out of Dallas. But whether you spend your time playing an easy round of golf or sinking the posts for a new deck on the back of the house, your responsibility is to be rested.

You’re expected to show up ready, fit for duty. The rules only work if you follow them.

We depend on you to play by the rules. Without your integrity, the rules won’t work. That’s why we added the requirement for crew members to confirm their fitness before each flight. That’s the only way it can work. The FAA expects pilots and airlines to take joint responsibility when considering if a pilot is fit for duty, including fatigue resulting from pre-duty activities.

So, where are we? This industry has an expectation of its own that must be met, each time, every time. Let me underscore you’re takeaway here: In this country, there are a handful of people that we expect to be on target every day, no exceptions. People like surgeons and fire fighters and parachute-packers. Put pilots right at the top of that list. Our safety record – and every passenger – depends on the integrity and the fitness for duty of our flight crew.

So I invite all of you to take advantage of the next two days. For the pilots here, learn all you can about the new rules and your responsibilities.

For the airline reps who are here, listen to the pilots concerns and be ready to work with your labor or employee group to implement these rules safety and effectively.

And you all should learn as much as you can about the software and the other tools that will help all of us manage the risk of fatigue more effectively and maintain our outstanding safety record. Thank you.

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