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The
Commuter
Pilot's
Conundrum
Issue Number 5 15
Duty Time Requirements
Many of the rules and flight
duty requirements differ between
major air carriers (Part
121) and commuters (Part 135).
Table 1 summarizes differences
in the duty time requirements
of these respective carriers.
Fatigue
Dr. R. Curtis Graeber2 summarized his findings
on fatigue in air transport operations in the
Proceedings of the Flight Safety Foundation
38th International Air Safety Seminar in 1985
as follows:
“An initial analysis of NASA’s Aviation Safety
Reporting System (ASRS) in 1980 revealed that
3.8 percent (77) of the 2006 air transport crew
member error reports received since 1976 were
directly associated with fatigue (Lyman and
Orlady, 1980). This may seem like a rather
small proportion, but as the authors emphasize,
fatigue is frequently a personal experience. Thus,
while one crew member may attribute an error
to fatigue, another may attribute it to a more
directly perceived cause such as inattention or a
miscommunication. When all reports which
mentioned factors directly or indirectly related
to fatigue are included, the percentage increases
to 21.1 percent (426). These incidents tended to
occur more often between 00:00 and 06:00 [local
time] and during the descent, approach or landing
phases of flight. Furthermore, a large majority
of the reports could be classified as substantive,
potentially unsafe errors and not just minor
events.”
The Situation for Commuters
Why should there be any difference in the rules for major carriers
and commuters? When Part 135 regulations were drafted, the
equipment used in commuter operations was relatively slow and
unsophisticated. Some of the equipment used in commuter operations
is becoming more advanced, with commuters utilizing Electronic
Flight Instrument Systems (EFIS), Traffic Alert and Collision
Avoidance System (TCAS II) and autoflight equipment previously
installed on larger turbojets. However, much of the equipment
used by these commuter carriers is older-style technology, having
primary navigation and instrumentation as compared to more
advanced air carrier counterparts, and this often translates to a
higher workload. In addition, aircraft having 19 or fewer passenger
seats do not require flight attendants, further increasing the duties
and workload of the crews operating them.
Commuter flight crews, unlike their Part 121 counterparts, often
spend more of their flight time operating below 10,000 feet in busy
terminal environments where there can be many changes to speed,
altitude and heading assignments, such as New York, Los Angeles,
San Francisco, Atlanta, Chicago, and Washington/Baltimore. To
make matters more difficult, commuter aircraft may spend a
greater percentage of flight time in instrument meteorological
conditions (IMC) than turbojet equipment due to their lower cruising
altitudes. These factors certainly aggravate the effects of acute
and chronic fatigue. Consider the following pilot report:
✍ “…The entire day is scheduled for 7 hours and 20 minutes of
flight time, which is a very unrealistic estimate when flying in
and out of a New York hub, especially on an IFR day. Also, I
believe someone should look into revising the maximum duty
and flight time limits to include the amount of flight segments.
Doing 10 ILS approaches to minimums and flying 7 hours is not
the same as 1 round trip, New York to Denver, and doing 1,
maybe 2 approaches and flying seven hours…” (ACN 176041)
2 Dr. Graeber, now with the Boeing Company, is a former
research scientist with the NASA-Ames Research Center.
16 Issue Number 5
A Sample Schedule
Below is a de-identified copy of an actual daily series of scheduled
flights flown by a commuter carrier. To preserve anonymity,
flight numbers and destinations have been removed (see note 1).
This trip was constructed in accordance with FAR 135.265. In
this example, note that CITY B is one of the busy terminal
environments discussed above, and the crew flies into AND out
of this hub five times. (See note 2.)
The crew flying this trip was to report for duty one hour prior to
the first departure, and would remain on duty for fifteen minutes
after arrival at CITY D at the completion of the last leg. It is
important to note that delays during the day may become
cumulative, so that completion of the trip may be much later than
scheduled. The following graphic (Figure 1) summarizes the
day’s activities.
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