dividual pilot stated that, “the effects of commuting for the regional pilot are symptoms of a greater system failure.”


Not surprisingly, 12 stakeholders (2 airline associations, 2 pilot associations, 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 respondents 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 nonpunitive 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 provision of paid moves, cost-of-living adjustments (COLAs), and positive-space tickets rather than merely jumpseats for flights used for commuting. Supplementing 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.

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