ATA Testimony by VP, Operations and Safety Basil Barimo before Senate Aviation Operations, Safety and Security Subcommittee on Pilot Duty Time and Fatigue Management

Commercial aviation helps drive more than 10M American jobs and 5 cents of every dollar of U.S. GDP
Commercial aviation drives more than $1 trillion per year in economic activity
In 2012, U.S. airlines moved more than 48,000 tons of cargo per day
In 2012, the value of a kilogram of U.S. merchandise exported by air averaged 121 times the value exported by sea
For every 100 airline jobs, some 360 are supported outside of the airline industry
Federal taxes constitute $61 – or 20% – of the price of a typical $300 domestic round-trip ticket
In 2011, U.S. airlines carried 16 percent more passengers and cargo using 10 percent less fuel than in 2000
Domestically, airlines drive 5% of economic activity but account for 2% of man-made GHG emissions
From 2000-2011, airlines reduced GHG emissions by 11% while transporting 16% more passengers and cargo
From 1975-2011, U.S. airlines and their partners reduced significant noise exposure by 99%
Commercial air travel is the safest form of intercity transportation in the United States
In the most recent decade, scheduled air service on U.S. airlines was seven times safer than in the 1970s
From 2000-2012, U.S. airlines improved the on-time arrival rate from 72.6% to 81.9%
From 2000-2012, U.S. airlines reduced the flight cancellation rate sharply from 3.30% to 1.29%
Airfares are a bargain: From 2000-2012, U.S. CPI rose 33% while average domestic fare rose just 13%
Adjusted for inflation, the average round-trip domestic airfare fell 15% from 2000
2007 domestic flight delays cost the United States approximately $31 billion
In 2012, the value of U.S. merchandise exported by air reached an all-time high of $427B
In 2012, U.S. exports of air-travel services reached an all-time high of $39.5B, driving a $5.1B trade surplus
In 2012, U.S. passenger and cargo airlines spent more than $50B on fuel, averaging 36% of operating expenses
In 2012, U.S. airlines posted the lowest annual rate of mishandled baggage ever recorded
FAA projects U.S. air travel demand to top 1 billion passengers in 2027
In 2012, US airlines flew 83.4 million passengers in scheduled international service - a record high
In 2012, the total value of merchandise exported from or imported to the United States by air exceeded $927 billion
In 2012, 7.15 teragrams of merchandise was exported from or imported to the United States by air

	ATA Testimony by VP, Operations and Safety Basil Barimo before Senate Aviation Operations, Safety and Security Subcommittee on Pilot Duty Time and Fatigue Management
	PubZone1 December 1, 2009 The Air Transport Association of America appreciates this opportunity to discuss pilot duty time and fatigue management issues with the Subcommittee. This important subject demands a collaborative, thorough and science-based response. ATA participated in the FAA Flight and Duty Time Limitations and Rest Requirements Aviation Rulemaking Committee (“the ARC”). That was a productive effort but we all must recognize that the ARC operated under significant time constraints. In any future rulemaking proceeding, consequently, we may expand upon the views that we expressed in the ARC and that are outlined below. We support a duty-day regulation designed to account for fatigue risks, including circadian cycles, time awake, time on task and acclimation to time zones. Our goal is to mitigate fatigue risk by: reducing the duty time of pilots, expanding scheduled rest opportunities to ensure adequate rest, and increasing pilots’ awareness of fatigue risk and their personal role in mitigating that risk. As in other aviation-safety undertakings, success here will depend on data-driven analyses and rigor in translating those analyses into regulatory action. The recommendations that we, in conjunction with the Cargo Airline Association and the Regional Airline Association, provided to the ARC were divided into substantive and procedural considerations. Substantive Issues With respect to substantive issues, we recommended that any new regulation establish a minimum of 10 hours of scheduled rest before the beginning of a flight-duty period at a domestic station and 12 hours of scheduled rest at an international station, with the possibility of a reduction of one hour in actual operations. We suggested additional, detailed rest requirements for certain international flights. Any new regulation should require each air carrier to adopt an FAA-approved fatigue mitigation program documenting its mitigation policies and training. Detailed means of compliance should be provided in an accompanying FAA-issued Advisory Circular. Use of an AC will provide the necessary flexibility to update airline fatigue mitigation programs as we build on future experience. Different air carrier operational environments must be recognized. These include domestic and international passenger operations, domestic and international cargo operations, and on-demand (nonscheduled) charter operations. We strongly urge that any new regulation account for the wide variety of operations, just as it does today. Nothing in fatigue and sleep research justifies a one-size-fits-all approach. Science-based principles, judiciously blended with many years of operational experience, will allow the various air carrier models to continue to operate safely. There also needs to be a focus on the individual in the regulations. Regulatory language should clearly prescribe the responsibility of the crew member to properly prepare himself for a flight. No fatigue policy without such an admonition can be regarded as comprehensive. Such language will also help address the pilot commuting issue. The FAA should also endorse controlled cockpit napping conducted in accordance with FAA-approved procedures to facilitate alertness during the critical phases of flight. Previous NASA research provides overwhelming evidence that controlled napping significantly mitigates fatigue risk. We must act on that evidence. Procedural Issues We are particularly concerned about the ultimate scope of any proposed regulation. Extraneous considerations should not burden our efforts to improve safety. In particular, a rulemaking proceeding is not the forum in which to resolve collective bargaining issues. We are also concerned about the effect of proposed duty and rest regulations on managers, who are also qualified as line pilots. If time spent in administrative duties counts as “duty” for cumulative purposes, or if a management pilot cannot have the discretion to check e-mail or use the telephone during a scheduled rest period, the possible result could be the end of line-qualified pilot managers, chief pilots or directors of operations. Since the beginning of commercial aviation, these pilot managers have played an essential role in safe airline operations, and the consequence of this rule on those management positions must be carefully considered. We recognize, of course, the need for appropriate rest prior to flight. This might be more appropriate for inclusion in a fatigue mitigation advisory circular. Finally, as in any major regulatory change, covered parties will need time implement new policies requiring programming and training. That is particularly so here where crew schedules will be affected. We, therefore, ask that the FAA provide a transition period of at least two years after the final regulation is published. Conclusion ATA members are committed to using the best science available combined with proven operational experience to improve pilot duty time and fatigue management. We look forward to working with the Committee, the FAA and other stakeholders in this important endeavor. PubZone2	A4A advocates measures to support aviation safety, security and well-being.