Some of the public comments and suggestions addressed the issue of commuting and possible consequences of the proposed duty and rest rules on commuter pilots. It is those comments that we considered in our qualitative investigation.


Qualitative methods are used to investigate the why and how of decision making, rather than the what, where, when. For the purposes of this investigation, the public comments expressed the viewpoints of a group of volunteer respondents, both individuals and representatives of a variety of organizations, who submitted their thoughts and ideas about the NPRM to the FAA.

The qualitative data set was comprised of a purposeful sample of the public comments selected as relevant to the following topic areas:

  • definitions of commuting;
  • prevalence of commuting;
  • perceptions of commuting as being problematic (e.g., when the unplanned occurs, such as weather disturbances or mechanical difficulties that delay flights);
  • characteristics and examples of responsible commuting;
  • perceptions of commuting as less of a choice and more related to external factors (e.g., frequent domicile changes, low salaries, and other industry-related factors); and
  • suggestions and rationale for modifying the NPRM.


The FAA electronic database containing 2419 submitted comments was searched. Comments were sorted using three key words: “commut”; “commute”; and “commuting” (N = 176). A total of 85 comments were selected for inclusion: see Table D-1. In many cases, an individual comment contained multiple opinions of relevance (e.g., on both the definition of commuting and he prevalence of commuting practices, as well as some suggestions for the NPRM). As a result, over 400 statements relevant to the study were considered.

Data Analysis

The analysis of qualitative data is an iterative process of examining and reexamining the narrative data set throughout all phases of analytic inquiry (Wolcott, 1994; Morse and Richards 2002; Ulin et al., 2004; Crosby et al.,

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