Should Cargo Carriers Be Exempt From Flight/Duty Changes?
- According to the FAA’s press release (2013), the new rules require a first officer to have an ATP certificate, requiring 1,500 hours of total time. Prior to the rules being enacted, only 250 hours were required, with no ATP certificate requirement. In addition, first officers must now have a type rating for the aircraft they with to fly, whether a passenger or cargo operation. A requirement for 1,000 hours total time as first officer was put in place for those pilots wanting to upgrade to Captain; there was no such requirement prior. The ATP certificate now requires enhanced training, with a new training program and at least 50 hours of multi-engine time. What now allows one to partially bypass the 1,500-hour rule is the new restricted ATP (rATP). This rATP allows for one to fly for a passenger or cargo operation with less than 1,500 hours, depending on qualifications such as type of college degree in the field and prior military flight experience. There is also an age requirement of 21 for the rATP, rather than the prior 23 years old.
- The current limitations for cargo carriers require pilots have a minimum rest period of 10 hours prior to their flight period and an allowance for 8 hours of uninterrupted sleep time within those 10 hours. However, the flight and duty requirements do vary based on what time the pilot starts on any particular day (Rest Requirements for, 2013).
- I believe that cargo operations have been voided from the requirement due to the public perception of flying cargo. These pilots are not flying passengers so why should they have to have the same amount of rest time as pilots responsible for the lives of all those onboard (at least what the public may think)? In addition, cargo operations work around the clock and are continuously in operation. Restricted duty and rest times would be a detriment to the cargo operations, with a great loss in funds, unless they hire more pilots. And with the pilot shortage we have currently, that may not be possible. Especially due to the higher preference for air transport operation in comparison to flying cargo I’ve experienced.
- I do not believe the cargo carriers should be included in the new rules. First of all, I believe the current rules are too strict, so I do not even believe the rules should apply to air transport operations. What I do believe is that 500 hours is sufficient for first officer of either operation type (a small increase for cargo requirements and a nice decrease in air transport’s requirements). I was informed by a friend who flies for Piedmont Airlines that knowing what he knows now, he believed he would not have been ready to handle the Dash-8 and following that, the ERJ-145, at the 250-hour minimum. Some people may be very sufficient to operate in transport aircraft at 250 hours, but not everyone has the skill set at that point for it to be continuously safe so 500 hours seems reasonable. Lastly, if the pilot shortage is not addressed, I would tend to agree with the cargo operations having even less duty and rest requirements in comparison to air transport. They are responsible for fewer lives (just the captain and co-pilot, unless you count the potential victims on the ground, which would likely be less than potential fatalities in air transport anyways) and lesser requirements seems reasonable.
- If cargo carriers were included in these new rules, my career at an airline wouldn’t largely be affected. There would be slightly more pilots going to the airline as a result, but nothing substantial. If the requirements are the same at both cargo and airline operations, there is a lost incentive of flying for the cargo operations when the flight and rest requirements are equalized.
References
Press Release – FAA Issues Final Rule on Pilot Training. (2013,
July 10). Retrieved January 29, 2018, from
https://www.faa.gov/news/press_releases/news_story.cfm?newsId=15314
Rest Requirements for Air Cargo Pilots. (2013, January 29).
Retrieved January 29, 2018, from
http://pnglc.com/rest-requirements-for-air-cargo-pilots/
I have to disagree with you on the first question. The question was asking about the new flight/duty times required according to the FAA press release in 2011. (See Link)
ReplyDeletehttps://www.faa.gov/news/press_releases/news_story.cfm?newsId=13272
You talked about the 1500 hour rule which was apart of the first blog post.
Also for question #2 it states that cargo companies are exempt from FAR part 117. Your answer is exactly the rest requirement for FAR part 117 which is not what cargo companies use. Cargo companies use pre-2011 rules meaning depending on if the leg is domestic, international or unscheduled determines flight and duty time.
I misread the cargo pilot article. Those regulations I stated were proposed regulations and not current regulations. And the 1500 hour rule is the main point of question 1. Yeah, the question mentions duty times and such, but that 1500 hour rule is the center of attention in getting pilots to the industry so I did not focus on the other specifics.
DeleteGreat Reflection on the issue, Austin. Although, I do want to state that the airline industry will suffer if part 135 carriers will be included in the new rule (I think). We will see a huge amount of Cargo Pilots switching to the airlines so for us, it will be much harder to acquire a job within those companies.
ReplyDeleteAs I stated in my post, the potential cargo pilots may instead choose airlines due to both options having the same restrictions so I agree with you there. In my opinion, having less restrictions on duty and rest times at the cargo operators is an incentive for some.
DeleteYou mentioned that more cargo pilots would be inclined to go to the airlines if part 117 were to become applicable to cargo carriers. You credit a loss of incentive when the flight and duty requirements are the same for all 121 operators. I could not disagree more with this. The current rules applicable to non-passenger operators are not an incentive for pilots to fly cargo. Cargo pilots fly on short nortice, for long hours, and at all hours of the day and/or night. Many pilots would not even think about going into cargo. The part 117 rules on flight, duty and rest are an improvement to the previous rules for pilots. Part 117 mandates more rest for pilots; therefore, quality of life is better for airline pilots now than it is for cargo pilots under the previous rules. If part 117 standardized the rest requirements across the board, there would be more cargo pilots. First, there would have to be more cargo pilots hired to fill demand, since current cargo pilots would be required to take more rest. And second, more pilots would be inclined to fly cargo because it would not be as demanding. Other than that, your post was fine.
ReplyDeleteI see it from a different perspective. I don't like the duty and required rest times. Maybe because I'm someone who likes working and will be flying the maximum I can when I get to the airlines and the rest times impede that ability. I don't want anyone telling me how much I can fly and the breaks I have to take so if these new duty and rest requirements applied to cargo, the people who are like myself who like to work a lot would be less inclined to fly cargo and it'd be more of a toss up between the two. I see the current cargo requirements as an incentive for those who want more hours.
Delete...and thus more pay.
DeleteThe comparative differences between the all-cargo and the passenger carriage aviation industries are very similar yet quite different. Similar in forms of equipment operated, beyond configuration differences of course, yet different in fashion of how the respective equipment is utilized. Aircraft mostly full of bodies vs. aircraft full of inanimate objects and a few bodies. With regard to the FAA “Flightcrew Member Duty and Rest Requirements” final rule, a science based research methodology determined that universal flightcrew fatigue factors were shared across disparate segments of industry. Through such validation, ruling eliminated duty and rest requirement differences between the multiple segments of industry and unified them into the single body of 14 C.F.R. 117 regulations. Yet, interestingly enough, the sole exception to the ruling was made for the all-cargo segment. Exception was not due to science based determinations that the all-cargo industry posed less pilot fatigue safety risks compared to other like-kind industry segments but rather because it served to be most negatively financially impacted based on cost-benefit analyses and supporting testimony from the all-cargo industry itself. Clearly indicative of industry lobby mechanics devised to promote and protect fiscal interest above that of overall safety. Would all-cargo inclusion within 14 C.F.R. 117 affect an industry crippling consequence? Doubtful, as all-cargo has generally remained an extremely profitable segment of the aviation industry. Yet, some reports state that the all-cargo segment has been affected by more accidents than the passenger carriage counterparts in recent years. An excerpt from NPR: All Things Considered audio transcript, host Audie Cornish talks with Bloomberg News reporter Alan Levin, for “Why Do Cargo Planes Have Spottier Safety Records?” radio segment (2013):
ReplyDeleteCORNISH: And we talked about that number, eight times as many fatal accidents with cargo planes as with passenger planes. Give us more context there. What kind of trips? What kind of flights? What kind of accidents are these?
LEVIN: There's a number of ways to slice the data, but any way you look at it, cargo is having more accidents, at least as far as the rate of accidents per flight. In the past five years, there have been four U.S. registered large aircraft cargo fatal accidents compared to one fatal accident on passenger flights. And when you consider that there's roughly 10 times as many passenger flights, it's quite a large difference.
CORNISH: Now, is it known what factors essentially put the cargo flights at higher risk?
LEVIN: There's no black and white reason for this, but there are several factors that experts and accident reports point to. One, cargo flights are going to operate into more dangerous regions, airports that aren't as modernized as, say, a Chicago O'Hare or something like that. The other issue is that the regulations for cargo are different than for passenger.
For example, just a year and a half ago, after decades of struggle, the U.S. put in place new rules to prevent fatigue in pilots, but they exempted the cargo pilots. The reason for this is, basically, every time the federal government creates a new rule, they have to justify it on a cost-benefit analysis. And the way you figure out the costs of an accident is by the number of deaths that are projected, and because a cargo airline carries very few people, usually just the two pilots, the deaths expected from an accident are much lower. And therefore, it's been very difficult for the government to justify new safety rules like this (NPR, 2013).
Admittedly, it is an older report on the topic but nonetheless one which still bears contemporary relevance. What is your perspective on the balance of financial and safety surety?
– Aviator in Progress
Reference
NPR. (2013). Why Do Cargo Planes Have Spottier Safety Records? NPR: All Things Considered. [Audio transcript]. Retrieved from: https://www.npr.org/templates/story/story.php?storyId=212692335
My perspective is that I agree with how the government justifies new rules by doing a cost analysis. You cannot solve every little problem with airline and cargo operations or it'd be too cost prohibitive. Unfortunately, there is an acceptable death toll because we need air transportation. We cannot prevent every accident and to make new regulations, requirements, and money expenditures to throw at a problem is not a good idea.
DeleteAustin,
DeleteI agree and disagree with you. I do agree that the public perception of cargo pilots is definitely not as good as the major carriers. They work crazy amount of hours and are called in at a moments notice with not a lot of rest periods but with what I disagree with is with the new rules. Yes the rules for cargo pilots are so much more stricter than the airlines but they are people as well. They should be getting the same treatment if not more than their passenger counterpart and it should help with the steady flow of rotations from duty and off duty days.
I thought the rules for airline pilots were stricter and that part 117 didn't apply to the cargo operations, which would've given cargo pilots some more rest time? Am I wrong?
DeleteI completely agree on answer 5. If cargo carriers were to be included, there wouldn't be much of a change, but I could see pilots going to airliners due to relaxed schedules and not having to be out for days at a time on various different legs, well, depending how that certain carrier operates. The current cargo company I work for now has out pilots out for 16 days of duty time. This means you aren't at home and are staying majority of the time overseas. If rules were changed, I could see the pilots wanting to do airline jobs due to not having that issue.
ReplyDeleteMost definitely.
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