Appendix C

Summary of Stakeholder Response to Committee Request for Input

To help inform the committee’s deliberations, requests for data were sent to a variety of different stakeholders in the airline industry, including 84 individual airlines, 8 airline associations, and 7 commercial pilot associations. Because of the extremely short turnaround (a few weeks) 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), 2 of the airline associations, and 2 of the pilot associations. (Some airlines responded with written input after this date but their input could not be included in this review.)

The committee received written statements from three individual commercial pilots who volunteered their thoughts on issues being addressed by the committee which was considered in the review of stakeholder response. During the committee’s meetings, several of these individuals as well as some officials from particular airlines and professional associations met with the committee to present their views orally. Overall, the obtained data bear on the set of issues and questions outlined in Box 1-3 (in Chapter 1), as well as other related policies and practices of the particular air carriers and the Federal Aviation Administration (FAA).

This appendix summarizes what the committee learned from that input



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Appendix C Summary of Stakeholder Response to Committee Request for Input To help inform the committee’s deliberations, requests for data were sent to a variety of different stakeholders in the airline industry, including 84 individual airlines, 8 airline associations, and 7 commercial pilot asso- ciations. Because of the extremely short turnaround (a few weeks) 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 re- ceived 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), 2 of the airline associations, and 2 of the pilot associations. (Some airlines responded with written input after this date but their input could not be included in this review.) The committee received written statements from three individual com- mercial pilots who volunteered their thoughts on issues being addressed by the committee which was considered in the review of stakeholder response. During the committee’s meetings, several of these individuals as well as some officials from particular airlines and professional associations met with the committee to present their views orally. Overall, the obtained data bear on the set of issues and questions outlined in Box 1-3 (in Chapter 1), as well as other related policies and practices of the particular air carriers and the Federal Aviation Administration (FAA). This appendix summarizes what the committee learned from that input 141

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142 THE EFFECTS OF COMMUTING ON PILOT FATIGUE on the specific issues of interest to its work regarding commuting1: defini- tion, prevalence, reasons, effects, and suggestions for improvement. DEFINITIONS OF COMMUTING In response to requests for definitions of what “commuting” means to pilots and crew members of commercial air carriers, the committee received a heterogeneous mix of replies from 17 of the queried stakeholders (1 air- line association, 2 pilot associations, 3 individual pilots, and 11 individual airlines). 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 crew- member commutes may involve multiple different modes of travel, as well as widely variable travel distances and times, with a variety of en route activities. For 11 respondents, however, there was some consistency of views about the airlines industry’s interpretations of “commuting.” In particu- lar, they explicitly defined “commuting” as referring specifically to travel arranged by pilots and other crew members acting as independent agents for going to and from home and work. Seven respondents specifically con- strained the commuting activity to involve travel by air. For example, one senior pilot for a major passenger carrier said: “I would say a ‘commuting’ pilot is one who takes a flight instead of driving. ‘Commuting’ should be defined as a flight. This is a starting point of how to define the corporate responsibility in numbers of commuting pilots.” Consistent with this view, three other respondents even said that “commuting” refers specifically to traveling by air from home to base using available jumpseats. However, seven other respondents at least implicitly said that “commuting” might entail not only air travel but also other modes (e.g., driving) if that travel takes 2 hours or more. PREVALENCE OF COMMUTING Several factors make it challenging to precisely characterize the preva- lence of commuting by pilots and other crew members across the airline industry. Some stakeholders who responded explicitly on this issue were reluctant to offer numerical estimates due to the ambiguity of defining “commuting.” For example, an official of a pilot association said: “preva- lence can’t be quantified, because ‘commuting’ can’t be defined.” 1 Theremay be some subjective biases in the coding and quantification of the data, due to a need for treating similar statements by various stakeholders as paraphrases of each other.

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143 APPENDIX C Even if one accepts a nominal definition of “pilot commuting” as air travel from home to domicile, there would still be challenging aspects to quantifying the prevalence of commuting because of its variability. At one extreme, for some airlines (e.g., some unscheduled charter passenger carri- ers) none of the pilots travel to work by air, because they all live within a 90-minute drive time of their domicile. At the opposite extreme, for other airlines nearly 90 percent of their pilots and other crew members travel to work by air, with 10-20 percent of them taking more than 2 hours for doing so, and 10 percent or more of them traveling at least 1,000 miles. For ex- ample, one major cargo carrier reported that for one of its principal domi- ciles, 73 percent of the pilots commute at least 6 hours by air. Commuting to a domicile may change because of airlines restructuring. 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 percent- ages 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. Some examples from respondents include a major cargo carrier that reported 47 percent of its pilots commute by air, and another major cargo carrier that reported commuting by air varies from 37 percent for one domicile to 88 percent for another domicile. In terms of distance, the number of long-distance air commutes (more than 1,000 miles) will likely continue to change over time given the economic dynamism of the industry. REASONS FOR COMMUTING The 10 stakeholders (2 airline associations, 2 pilot associations, 3 indi- vidual pilots, and 3 individual airlines) who explicitly addressed this issue noted several interrelated factors that explain why considerable numbers of pilots choose to commute from home locations that are several hours and hundreds to thousands of miles from their domiciles. Those factors included the high cost of living at the domiciles (mentioned by six respon- dents); frequent domicile closings and future unpredictability of the airline industry (mentioned by five respondents); the desire to maintain family stability (mentioned by five respondents); low pay, especially for regional carriers (mentioned by four respondents); lifestyle preferences, e.g., for good weather and outdoor living (mentioned by three respondents); and absence of adequate coverage for costly moving expenses (mentioned by one respondent).

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144 THE EFFECTS OF COMMUTING ON PILOT FATIGUE EFFECTS OF COMMUTING ON PILOT FATIGUE Especially relevant to the committee’s central concerns were replies received from 12 stakeholders (2 airline associations, 2 pilot associations, 2 individual pilots, and 6 airlines) who explicitly commented on the effects of commuting on pilot fatigue. Although some degree of subjectivity and economic or personal self-interest undoubtedly colors these views, they nevertheless provide some useful perspectives. For example, six respondents acknowledged that commuting is a potentially fatiguing activity. Extending this line of commentary, five responded and explicitly noted or strongly hinted that fatigue can have negative effects on pilots’ performance of flight deck duties and ought to be addressed. At the same time, however, four respondents emphasized how chal- lenging it is to measure the effects of commuting on pilot readiness and fitness for duty, given the difficulties with defining “commuting,” quanti- fying its prevalence, and accounting for the heterogeneous ways in which pilots commute. In particular, six respondents noted that the fatiguing ef- fects of various types of commutes may be quite different. For example, a 90-minute commute through chaotic rush-hour traffic to reach a domicile airport might elevate stress and fatigue levels substantially more than would a relaxed 3-hour commute by air. One respondent also pointed out that there are individual differences among pilots in terms of how their com- mutes may affect them. With these sorts of caveats in mind, five respondents stated that com- muting done responsibly by flight crew members would not necessarily increase their fatigue levels significantly. 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 report- ing 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. Four respondents mentioned the unpre- dictability and stress-inducing aspects of direct, long, no-break commutes before duty assignments as exacerbating factors. Indeed, three respondents who discussed the fatigue issue in detail emphasized how stress itself is a primary contributor to the effects of commuting on pilot fatigue. Several stakeholders provided concrete examples in which pilot fatigue could result from problematic commuting. The following scenario from one respondent, redacted to provide confidentiality, is illustrative of input to the committee: A crewmember lives [on the East Coast], is based in [the Mid-West], and has an 11-day trip commencing [from the domicile] with a flight to [central Europe]. The initial flight is scheduled to depart in the morning at 0630 local time and arrive approximately 8 hours later. To arrive at domicile, the crewmember must leave home at 1900 local time in the evening [be-

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145 APPENDIX C fore duty begins] and drive 2 hours to a major [East Coast] metropolitan airport. The crewmember then commutes via cockpit jump seat on a flight [to the domicile] that arrives there at 0015 local time [early in the next morning]. The crewmember now has almost five hours until report time for the first scheduled segment to [Europe]. Because of this imprudent, unregulated commuting practice, this crewmember [might] be awake, and for all practical purposes on duty, for over 21 hours upon landing [later that day] in Europe. Different points of view were provided to the committee by 12 respon- dents (2 airline associations, 2 pilot associations, 3 individual pilots, and 5 individual airlines) regarding the prevalence of problematic commuting. At one extreme, three respondents claimed that commuting almost never sig- nificantly increases pilot fatigue or affects pilots’ fitness for duty. Typifying these comments is the response from one pilot association, such as: “For commuting pilots, the impact of commuting on pilot fatigue is minimal. . . . Pilots, as professionals, carefully restrict their own activity and commute responsibly, because they are in the same airplane at the end of the day as their passengers.” The respondent added, “Pilots are professionals and as a group we ensure we show for work ‘fit to fly’.” One explanation offered for this optimistic view was that “the present method of pilots self-policing their own physiological needs has been, and still remains, an effective de- terrent of fatigue. . . . Pilots have ably borne this responsibility since man first took to the skies. . . . A pilot who has a difficult or lengthy commute to work recognizes the effect this will have on him . . . and will commute the day before to give himself time for adequate rest [before reporting for operational duty].” At the opposite extreme, three other respondents claimed that pilots’ commutes can sometimes be problematic. Illustrating this opposing view- point are the following quotes from input to the committee: “[T]he impact of commuting on pilot fatigue is not minimal.” “[T]he reality is that . . . pilots [sometimes] commute directly into a trip, allowing for more time at home and saving a few dollars. But this practice sacrifices rest and com- promises professionalism.” The official of one major cargo carrier wrote: “Many crew members commute directly into their [very early morning] 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 ex- pressed not only by some air carriers but also by individual pilots. Three respondents also noted that having to pay for hotel rooms and “crash pads” is a disincentive for responsible commuting. One respondent also mentioned that inadequate base facilities contribute to the effects of commuting on pilot fatigue and that the adverse effects of commuting are especially problematic for crew members of regional air carriers. One in-

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146 THE EFFECTS OF COMMUTING ON PILOT FATIGUE dividual pilot stated that, “the effects of commuting for the regional pilot are symptoms of a greater system failure.” SUGGESTIONS FOR HOW TO IMPROVE THE SYSTEM Not surprisingly, 12 stakeholders (2 airline associations, 2 pilot as- sociations, 3 individual pilots, and 5 individual airlines) offered a range of suggestions for how to improve the commercial airlines system with respect to commuting. The viewpoint of the airline carriers is embodied in a set of related replies from three respondents. They stated explicitly that current airline commuting policies and practices—to the extent any exist—are already adequate, that no major new changes need be made, and that the burden of ensuring that flight crew members are fit for duty should not be shifted to the air carriers. Rather, in their opinion, fatigue management in the context of commuting should remain solely the responsibility of flight crew members. Their comments also suggested that the FAA should more tightly regulate the commuting practices of pilots, but not by imposing additional burdens on air carriers to monitor pilot behavior. For example, two urged that commuting overnight on “red-eye” flights directly prior to subsequent duty periods should be strongly discouraged or banned outright. Contrasting with these views were the responses from individual airline pilots and their professional associations. Specifically, three such respon- dents said that no new rules and regulations should be imposed on pilots who commute by air to work nor should their commuting practices be scrutinized by their employers. Instead, they suggested that the FAA should more tightly regulate the policies of air carriers that influence the ease or difficulty of commuting. They urged that a new regulation be put in place whereby all commercial air carriers would institute standardized nonpuni- tive 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). Three respondents also suggested that specific rules regarding regional air carriers need to be strengthened. Along these same lines, three responses expressed considerable enthusiasm for requiring airlines to improve their support of pilots whose domiciles are changed, including additional provi- sion of paid moves, cost-of-living adjustments (COLAs), and positive-space tickets rather than merely jumpseats for flights used for commuting. Supple- menting these suggestions, one respondent noted as well that rest facilities at airlines’ bases (domiciles, hubs, and spokes) should be upgraded with more comfortable and quiet sleeping quarters.