### Committee on the Effects of Commuting on Pilot Fatigue

Board on Human-Systems Integration

Division of Behavioral and Social Sciences and Education

Transportation Research BoardTHE NATIONAL ACADEMIES PRESS 500 Fifth Street, N.W. Washington, DC 20001



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Suggested citation: National Research Council. (2011). The Effects of Commuting on Pilot Fatigue. Committee on the Effects of Commuting on Pilot Fatigue, Board on Human-Systems Integration. Division of Behavioral and Social Sciences and Education. Washington, DC: The National Academies Press.

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### v COMMITTEE ON THE EFFECTS OF

COMMUTING ON PILOT FATIGUE

Clinton V. Oster, Jr. ( Chair ), School of Public and Environmental Affairs, Indiana University Benjamin A. Berman, Senior Research Associate, Ames Research Center, U.S. National Aeronautics and Space Administration J. Lynn Caldwell, Senior Research Psychologist, Wright-Patterson Air Force Base, OH David F. Dinges, Department of Psychiatry, Perelman School of Medicine, University of Pennsylvania R. Curtis Graeber, The Graeber Group, Kirkland, WA John K. Lauber, 1 

### Independent Consultant, Vaughn, WA David E. Meyer, Department of Psychology, University of Michigan Matthew Rizzo, Department of Neurology, Mechanical and Industrial Engineering, and the Public Policy Center, University of Iowa David J. Schroeder, Independent Consultant J. Frank Yates, Department of Psychology, University of Michigan

Toby Warden, Study Director Julie Schuck, Senior Program Associate Eric Chen, Senior Project Assistant Stephen Godwin, Liaison, Studies and Special Programs, Transportation
Research Board

1 Resigned from the committee in February 2011.

### vi BOARD ON HUMAN-SYSTEMS INTEGRATION

2010-2011

William S. Marras ( Chair ), Integrated Systems Engineering Department, Ohio State University Pascale Carayon, Department of Industrial and Systems Engineering, Center for Quality and Productivity Improvement, University of
Wisconsin–Madison Don Chaffin, Industrial and Operations Engineering and Biomedical Engineering, University of Michigan ( Emeritus ) Nancy J. Cooke, Cognitive Science and Engineering, Arizona State University Mary (Missy) Cummings, Aeronautics and Astronautics and Engineering Systems Division, Massachusetts Institute of Technology Sara J. Czaja, Department of Psychiatry and Behavioral Sciences, Center on Aging, University of Miami Miller School of Medicine Andrew S. Imada, A.S. Imada and Associates, Carmichael, CA Waldemar Karwowski, Department of Industrial Engineering and Management Systems, University of Central Florida David Rempel, Department of Medicine, University of California, San

Francisco Matthew Rizzo, Department of Neurology, Mechanical and Industrial Engineering, and the Public Policy Center, University of Iowa Thomas B. Sheridan, Departments of Mechanical Engineering and Aeronautics-Astronautics, Massachusetts Institute of Technology ( Emeritus ) David H. Wegman, Department of Work Environment, University of Massachusetts, Lowell ( Emeritus ) Howard M. Weiss, Department of Psychological Sciences, Purdue University

Barbara A. Wanchisen, Director Mary Ellen O’Connell, Deputy Director Christie R. Jones, Program Associate

### vii 

# Acknowledgments

This report is the work of the Committee on the Effects of Commut

ing on Pilot Fatigue, a project of the National Research Council’s (NRC’s) Division of Behavioral and Social Sciences and Education, overseen by the Board on Human-Systems Integration. The expertise and hard work of the committee were advanced by the support of our sponsor, the contributions of able consultants and staff, and the input of stakeholders. This study was congressionally mandated and sponsored by the Federal Aviation Admin

istration, and the support of their staff Jodi Baker, John Duncan, Dale E. Roberts, Kevin West, and Larry Youngblut were much appreciated. The committee also benefited from presentations by Lori Brown, faculty specialist, Western Michigan University College of Aviation; Bob Coffman, Coalition of Airline Pilots Association; Captain William McDonald, FedEx; Captain Bill Mims, retired; Jeff Moller, assistant vice president, Operations Systems and Practices, Association of American Railroads; Thomas Nesthus, Civil Aerospace Medical Institute, Federal Aviation Administration; Jessica Nowinski, National Aeronautics and Space Administration (NASA) Ames Research Center; pilot Charlotte O’Connell; George Paul, director, Techni

cal Services, National Air Carriers Association; Mark Rosekind, member, National Transportation Safety Board; Steven Sargent, Compass Airlines; Jeff Skiles, U.S. Airline Pilots Association; Captain Bill Soer; and Irving Statler, NASA Ames Research Center. Comments at committee meetings provided by other stakeholders and guests in attendance were also valuable. Additionally, the committee wishes to thank the 33 airlines who pro

vided information in response to the committee’s request for input (see Ap

pendix B) and the following aviation-related associations who also provided

### viii ACKNOWLEDGMENTS



### input: Cargo Airline Association, Coalition of Airline Pilots Associations, National Air Carriers Association, and U.S. Airline Pilots Association. This input was critical in allowing the committee to better understand pilot commuting. To the NRC staff, special thanks are due to Barbara Wanchisen and Mary Ellen O’Connell of the Board on Human-Systems Integration and Stephen Godwin of the Transportation Research Board who provided over

sight and support of the study. Thanks also to senior project assistant Eric Chen who provided administrative and logistical support over the course of the study as well as preliminary analysis for the zip code data. We also thank Daniel Cork, senior program officer with the Committee on Na

tional Statistics, for his additional statistical analyses; Julie Schuck, senior program associate, for her support with editing and writing; and Cherie Chauvin, program officer, for her help with editing and graphics. We also thank Jessica Scheer for her assistance with the committee’s analysis of the Notice of Proposed Rulemaking comments and Susan Van Hemel for her assistance with fact checking and editing. And finally we thank the executive office reports staff of the Division of Behavioral and Social Sciences and Education, especially Eugenia Grohman, who provided valuable help with the editing and production of the report, and Kirsten Sampson Snyder, who managed the report review process. We would also like to thank Tony Klausing of Indiana University for his assistance with the analysis of the aircraft departure data. John Lauber, who resigned from the committee in February 2011, pro

vided additional unpaid consultation on the report; we were fortunate to continue to benefit from his expertise after his resignation. This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with pro

cedures approved by the NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Evan Byrne, Human Performance and Survival Factors Division, National Transportation Safety Board; Paul Fischbeck, Department of Engi neer ing and Public Policy and Department of Social and Decision Sciences, Center for the Study and Improvement of Regulation, Carnegie Mellon University; R. John Hansman, T. Wilson Professor of Aeronau

tics & Astronautics, MIT International Center for Air Transportation, Massachusetts Institute of Technology; John Marshall, aviation consultant,ACKNOWLEDGMENTS 

### ix

Atlanta, GA; James C. Miller, human factors consultant, San Antonio, TX; John O’Brien, aviation consultant, VA; Joseph P. Ornato, Department of Emergency Medicine, Virginia Commonwealth University, Richmond, VA;
Barbara Phillips, Department of Internal Medicine, University of Kentucky;
Nicholas Sabatini, aviation consultant, Alexandria, VA; and Nita Lewis Shattuck, Human Systems Integration Program, Operations Research De

partment, Naval Postgraduate School, Monterey, CA. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations nor did they see the final draft of the report before its release. The review of this report was overseen by Richard W. Pew, principal scientist, Raytheon BBN Technologies, Cambridge, MA, as coordinator and and Floyd E. Bloom, Molecular and Integrative Neuroscience Department, The Scripps Research Institute, as review monitor. Appointed by the NRC, they were responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee
and the institution.

Clinton V. Oster, Jr., Chair Toby Warden, Study Director Committee on the Effects of Commuting on Pilot Fatigue

### xi 

# Contents

SUMMARY 1

1 INTRODUCTION 11 Study Background and Committee Charge, 12 Information Collection, 14 Operational Definitions, 16 Guide to the Report, 19

2 THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 21 Commuting: Background, 21 Commuting in Aviation, 22 Stakeholders’ Comments, 24 Aviation Industry Characteristics, 26 Changes in Industry Patterns, 33 Airline Policies and Practices, 39

3 AVIATION SAFETY AND PILOT COMMUTING 45 Aviation Safety, 45 Improvements in Aviation Safety, 49 Fatigue-Related Aviation Accidents, 51 Current Pilot Commuting Patterns, 64 Conclusion, 76

### xii CONTENTS



### 4 SLEEP, WAKEFULNESS, CIRCADIAN RHYTHMS, AND

FATIGUE 77 Fatigue, 77 Sleep and Circadian Rhythms, 79 Fatigue Management Technologies, 84

5 PILOT COMMUTING AND FATIGUE RISK 87 Inadequate Sleep Prior to Flight Duty, 87 Examples of “Favorable” and “Unfavorable” Commutes, 89 Recommendation, 96

6 REDUCING THE RISK OF FATIGUE FROM COMMUTING 99 Proposed FAA Rule Relevant to Fatigue, 99 Fatigue Risk Management Plans and Systems, 101 Conclusions and Recommendations, 111

BIBLIOGRAPHY AND REFERENCES 115

ACRONYMS 127

GLOSSARY 129

APPENDIXES

A Airlines, Associations, and Groups That Provided Written Input 135

B Public Meeting Agendas 137

C Summary of Stakeholder Response to Committee Request for Input 141

D Qualitative Analysis of Selected Public Comments to Proposed FAA Rules 147

E Mainline Airlines Departures by City 165

F Regional Airlines Departures by City 183

G Biographical Sketches of Committee Members and Staff 203

### xiii 

# Figures, Tables, and Boxes

FIGURES

1-1 Commuting in relation to duty, 18

2-1 Passengers carried by U.S. airlines, 30

2-2 Southwest total departures, 34

2-3 Southwest departures by city, 35

2-4 American Eagle departures by city, 35

2-5 Atlantic Southeast departures by city, 36

2-6 Air Wisconsin departures by city, 36

2-7 Delta total departures, 37

2-8 Delta departures by city, 38

2-9 U.S. carrier domestic load factors, 41

3-1 Safety of travel in the United States: 1989-2007, 46

3-2 U.S. and Canadian operators accident rates by year, 48

3-3 U.S. air carrier safety record: 1990-2010, 49

3-4 Distribution of home-to-domicile distances for mainline and regional pilots, 67

3-5 Share of pilots with home-to-domicile time zone differences, 71

5-1 Example 1a: Unfavorable commuting pattern, 90

5-2 Example 1b: Favorable commuting pattern, 91

5-3 Example 2a: Unfavorable commuting pattern, 92

5-4 Example 2b: Favorable commuting pattern, 92

### xiv FIGURES, TABLES, BOXES



### 5-5 Example 3a: Unfavorable commuting pattern, 94

5-6 Example 3b: Favorable commuting pattern, 94

5-7 Example 4a: Unfavorable commuting pattern—day 1 of 3 consecutive days. On second and third days, rest time reduced by 1 hour., 95

5-8 Example 4a: Unfavorable commuting pattern—overview of 3 consecutive days, 96

TABLES

3-1 Total Accidents and Fatigue Accidents by Injury Category, 1982- 2010, 55

3-2 Fatigue-Related Accidents, 1993-2009, 55

3-3 Distribution of Home-to-Domicile Distances by Industry Segment (in percentage), 66

3-4 Distribution of Home-to-Domicile Distances for Mainline Pilots by Airline (in percentage), 68

3-5 Distribution of Home-to-Domicile Distances for Regional Pilots by Airline (in percentage), 68

3-6 Distribution of Home-to-Domicile Distances for Cargo Pilots by Airline (in percentage), 69

3-7 Distribution of Home-to-Domicile Distances for Charter Pilots by Airline (in percentage), 69

3-8 Distance Between Residence and Domicile by Time Zone and Carrier (by percentage within time zone), 72

BOXES

1-1 Committee Statement of Task, 13

1-2 Organizations Contacted for Input, 15

1-3 Topics Posed in Call for Public Input, 16

2-1 Benefits of Commuting, 24

4-1 Risk Factors for Fatigue-Related Errors and Accidents, 86

6-1 FAA Proposed Regulations on Fatigue (Section 117.5), 101

### 1 

# Summary

The airline industry operates 24 hours a day, 7 days a week, deliver

ing passengers and cargo to locations worldwide. The pilots who fly the airplanes rely on their own expertise and judgment, that of their fellow crew members, the safety features of the airplane, and characteristics of the aviation system to ensure that the flights arrive safely. Fatigue is a widely ac

knowledged potential safety risk factor that can contribute to less effective pilot performance. Although the number and timing of hours worked and hours slept can contribute to fatigue, the federal regulations that govern pilot flight and duty time have not been revised in decades. In summer 2010 the U.S. Congress directed the Federal Aviation Ad

ministration (FAA) to update these regulations, taking into account recent research related to sleep and fatigue. A Notice of Proposed Rulemaking (NPRM) was released September 14, 2010. As part of their directive, Congress also instructed FAA to have the National Academy of Sciences conduct a study on the effects of commuting on pilot fatigue. The study was designed to review research and other information related to the prevalence and characteristics of commuting; to the science of sleep, fatigue, and circa

dian rhythms; to airline and regulatory oversight policies; and to pilot and airline practices. 1 

### It was intended to inform the commuting-specific compo

nent of the final regulations. This report describes the results of that study. Pilots live in diverse geographic regions. They commute between where they live and the airports where their duty assignment begins (i.e., their

1 This study was restricted to airlines operating under 14 CFR 121, which includes most passenger and cargo airlines that fly transport-category aircraft with 10 or more seats.

### 2 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### domicile). The committee considers pilot “commuting” to be the period of time and the activity required of pilots from leaving home to arriving at the domicile (airport—in the crew room, dispatch room, or designated location at the airport) and from leaving the domicile to returning back to home. Pilot commuting takes place during off-duty hours. Pilot commuting differs from the commuting of other workers in terms of frequency and variability, distance, transport modes, and time of day. Most pilots work for four main types of airlines: mainline airlines that predominately operate scheduled service in jet aircraft with more than 90 seats and often provide intercontinental service; regional airlines that pre

dominately operate scheduled service in aircraft, both jet and turboprop, with 90 or fewer seats; cargo airlines that deliver goods all over the world; and charter airlines that provide nonscheduled passenger flights. Flight scheduling, commuting provisions, seniority systems, and length of duty time vary across these segments of the industry. For most airline pilots, decisions about where to live and when and how to commute are their own to make. Generally, given the nature of flight scheduling, pilots do not commute on a daily basis; in fact, in some cases, they commute only two or three times a month. However, there are no comprehensive data on the frequency of pilot commuting, the lengths of commutes, or such trip characteristics as the transportation modes used in commuting. There are also no systematic data on the timing, duration, or quality of pilots’ sleep before or during their commutes. Furthermore, changes in airports to which the pilots’ report for the start of their duty (their domicile) may alter commuting patterns, but the committee was un

able to obtain any systematic information about how frequently individual pilots experience domicile changes or how such changes affect pilot com

muting behavior. The committee’s analysis of home-to-domicile distances, calculated from zip codes of 17,519 mainline pilots and 7,553 regional airline pilots,provided by 15 airlines, showed that roughly one-half have home-todomicile distances of less than 150 miles. Less than one-fourth have hometo-domicile distances of more than 750 miles. The distributions are similar for mainline and regional pilots even though these two segments of the industry differ. The proportion of pilots who have long coast-to-coast or international home-to-domicile distances is about 2 percent for mainline pilots and 1 percent for regional pilots. The committee also analyzed the home-to-domicile distances of 4,488 airline pilots from four cargo air

lines and 631 airline pilots from five charter airlines, but many of those airlines have different basing policies so the data from their pilots are not directly comparable to mainline and regional airlines. These home-to-domicile distances are only suggestive of commuting patterns for several reasons. First, the pilots’ residence zip codes were forSUMMARY 

### 3

their homes of record (i.e., those designated by the pilots on IRS forms and for the receipt of official notices from the airlines). Some pilots may have more than one home, and some may commute to work from temporary or seasonal residences that are not frequent origination points for their com

mutes. Second, pilots may arrange for rest facilities and obtain sleep at or near their domiciles (or at an en route location for a multistop commute) between leaving home and arriving at the domicile. Third, commutes may have varying degrees of circuity, particularly those involving multiple con

necting flights, so that the actual distances traveled are likely to be longer and may be much longer than the straight-line distances. Fourth, these data are for one point in time and provide no insight into how commut

ing patterns might change in response to a pilot’s career progression or from changes in the patterns of airline operations that result from mergers, bankruptcies, and changing economic or competitive conditions. Finally, the committee does not know the extent to which the sample of pilots in this analysis is representative of the larger pilot population. We caution the reader not to assume that the distance pilots live from the airport reflects their likely commute times. There is remarkably little data to evaluate this assumption.In all four segments of the industry, a breakdown of the home-todomicile distances by airline suggests that there is considerable variation across individual airlines. Similarly, an analysis of changes in aircraft de

partures from the principal cities served by each of 30 mainline, regional, and cargo airlines also found large differences in changes in flight patterns across airlines. Overall, the airline industry is heterogeneous, with great variability across the entire industry, in each segment of the industry, and for individual airlines, as well as among individual pilots. Commuting is one of many activities that usually take place during a pilot’s off-duty time. If decisions about how and when to commute result in a pilot’s not having adequate sleep, or if unanticipated circumstances prevent adequate sleep, there is the clear potential that the pilot will arrive to work fatigued and be forced to make the decision about being fit to fly. Similarly, if sleep is inadequate as a result of commuting time and the pilot does not decline the flight assignment on grounds of fatigue, the pilot may experience fatigue during the flight and duty period. A pilot’s decision about fitness for duty is likely made within the context of the flight schedule, the airline’s relevant policies and their implications for pay (i.e., whether or not the pilot will get paid if he or she calls in fatigued or sick), and knowledge about the specifics of the airplane and flight. Most jet airplanes are highly automated, with the periods of greatest pilot activity for most flights occurring during takeoff and landing. Most turboprop regional airplanes are less automated. There have been few aviation accidents in which fatigue was cited as a probable cause or contributing factor by the National Transportation Safety

### 4 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Board (NTSB), the agency responsible for investigating all U.S. airline (and other transportation) accidents. 2 

### Of the NTSB reports for the 863 relevant accidents that occurred between 1982 and 2010, only nine of the accidents for which the investigation was complete mentioned fatigue as a prob

able cause or contributing factor. 3 

### None mentioned commuting as either a probable cause or contributing factor. However, it can be difficult during an accident investigation to determine the extent to which fatigue might have played a role in the accident as well as the extent to which commuting might have contributed to fatigue. Based on the available information on (1) the commuting practices of pilots and commuting policies of airlines, (2) aviation accident reports, (3) the range of distances pilots live from their work domiciles, and (4) sci

entific information on fatigue that results from inadequate sleep, prolonged time awake and circadian timing, the committee concludes the following.

CONCLUSION: There is potential for pilots to become fatigued from commuting. However, there is insufficient evidence to determine the extent to which pilot commuting has been a safety risk in part because little is known about specific pilot commuting practices and in part because the safety checks, balances, and redundancies in the aviation system may mitigate the consequences of pilot fatigue.

Given that there is some potential for commuting to contribute to fa

tigue and clear evidence that fatigue can decrease performance, the commit

tee believes it is important to reduce the likelihood that commuting could contribute to pilot fatigue during duty. At the same time, the safety risk posed by commuting-induced fatigue is unknown. There is a need to un

derstand the extent to which the risk posed by fatigue resulting from some commutes may be mitigated by individual, airplane (e.g., flight deck sys

tems), or aviation system (e.g., crew resource management) characteristics. Furthermore, there is tremendous variability across individual pilot commuting practices and day-to-day experiences. Attempting to determine

2 An aircraft accident is defined in Title 49 Section 830.2 as “an occurrence associated with the operation of an aircraft which takes place between the time any person boards the aircraft with the intention of flight and all such persons have disembarked, and in which any person suffers death or serious injury, or in which the aircraft receives substantial damage” (Code of Federal Regulations, 2009).

3 “The NTSB determines the probable cause or causes of accidents. The objective of this determination is to discern the cause-and-effect relationships in the accident sequence. This could be described as why the accident happened. In determining probable cause, the NTSB considers all facts, conditions, and circumstances associated with the accident. Within each accident occurrence, any information that helps explain why that event happened is designated

as either a ‘cause’ or ‘factor.’ The term ‘factor’ is used to describe situations or circumstances that contribute to the accident cause” (National Transportation Safety Board, 2010a, p. 52).SUMMARY 

### 5

a one-size-fits-all delineation on what constitutes a fatiguing commute based on either time or distance is difficult because the length of the com

mute, measured either by distance or time spent commuting, does not necessarily determine whether or not the pilot reports fit for duty and well
rested. In addition, regulations specific to commuting could inadvertently lead to increased safety problems and additional loss of lives due to the unintended and unanticipated consequences. Consequently, although action is warranted to reduce the likelihood that commuting will present a safety risk, there is a lack of evidence to support the basis for issuance of regula

tions pertaining to commuting.

CONCLUSION: There are inadequate data to specify or determine the effectiveness of regulations regarding pilot commuting. Additional information is needed to determine if a regulatory approach ultimately would be appropriate.

At the same time, there is extensive scientific evidence on the nega

tive effects of fatigue on performance of many cognitive tasks, including those essential for safely operating a commercial aircraft. These include adverse effects of fatigue induced by sleep loss on maintaining wakefulness and alertness, vigilance and selective attention, psychomotor and cognitive speed, accuracy of performing a wide range of cognitive tasks, working and executive memory, and on higher cognitive functions such as decision making, detection of safety threats, and problem solving, as well as com

munication and mood. Fatigue is not, however, a binary condition in which one is either rested with no negative effects on performance or fatigued with severe negative effects on performance. There are degrees of fatigue and degrees of the negative effects of fatigue on performance. Moreover, the effects of fatigue on performance can vary substantially from one pilot to the next without any untoward effects on the safety of flight. The scientific literature shows fatigue as a risk to performance that can result from (1) being awake continuously for more than approximately 16 hours, or (2) sleeping too little (especially less than 6 hours on the day prior to work), or (3) when undertaking work at a time when the body is bio

logically programmed to be asleep (i.e., an individual’s habitual nocturnal sleep period), which for most people is between 10:00 p.m. and 7:00 a.m. Evidence that cognitive performance is adversely affected when sleep per 24 hours is cumulatively less than approximately 6 hours of sleep suggests that pilots should seek to obtain sufficient bed time to ensure they are fit for duty. The detrimental effects of fatigue on performance may be exacerbated by a tendency for individuals to have reduced awareness of the cognitive performance deficits that result. Pilots are currently required to report fit for duty. Judging whether a

### 6 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### pilot is fit for duty is an individual pilot decision that should take into ac

count the amount of sleep received prior to duty.

RECOMMENDATION 1: Pilots should avoid planning commutes or other preduty activities that result in being awake beyond approxi

mately 16 hours before the scheduled end of duty, endeavor to sleep
at least 6 hours 4 

### prior to reporting for duty, and obtain more than 6 hours sleep per day whenever possible to prevent cumulative fatigue from chronic sleep restriction. Pilots should also consider the amount of sleep and time awake in their decision making relative to when to inform their supervisors that they should not fly due to fatigue.

Although there are currently no agreed-on objective standards in the aviation industry to determine whether a pilot is reporting to duty fatigued, there are provisions in the proposed NPRM—Section 117.5—for assess

ment by others of whether a pilot is fatigued. The validity and reliability of such assessments are unknown, as is the likelihood that they can result in either false positives or false negatives. Consequently it is uncertain whether they can result in effective prevention of fatigue.

CONCLUSION: With regard to the proposed provisions in Section 117.5, there are no valid and reliable tools and techniques feasible to reach the goals of detecting fatigue and fitness for duty in pilots in an operational setting. To achieve these goals, further research would be needed to scientifically validate the tools and techniques, demonstrate that they are technically feasible in an operational environment, and evaluate their relationship to operational safety and the extent to which they can be integrated into an operational context.

Potential fatigue is an inherent component of a system that functions 24 hours a day, 7 days a week. Recognizing this, the international aviation industry has been developing an approach through fatigue risk management systems (FRMS) to better understand when fatigue is a concern and how to best mitigate that risk. Airlines develop FRMS specific to their operational environment. To date, commuting has not been a major consideration in these systems. Incorporating data on commuting in relation to pilots’ duty hours and sleep prior to duty would help inform these systems and allow airlines to consider mitigation strategies specific to their operations.

4 This refers to at least 6 hours of physiological sleep. Since physiological sleep is typically 85 to 95 percent of total bed time in healthy adults, time in bed for sleep will have to be 6.5 to 7 hours to ensure at least 6 hours of physiological sleep are acquired.SUMMARY 

### 7

RECOMMENDATION 2: The potential effects of commuting on pilot fatigue should be addressed as part of an airline’s strategies to man

age fatigue risk. If airlines develop fatigue risk management systems (FRMSs), they should gather information about preduty sleep and wake time relative to commuting practices and duty cycle. FRMSs should provide a mechanism for identifying problematic patterns and addressing them. FRMSs can offer both the airline and the Federal Aviation Administration an improved assessment of crew alertness dur

ing normal operations and thereby provide some information on the contribution of commuting to fatigue and whether fatigue is or is not within an acceptable level of risk.

Fatigue risk management plans (FRMPs) are the airline carriers’ man

agement plans outlining policies and procedures reducing the risk of flight crew member fatigue and improving flight crew member alertness. Public Law 111-216 requires each U.S. carrier operating under Part 121 (most passenger and cargo airlines that fly transport-category aircraft with 10 or more seats) to submit to the FAA their draft FRMPs for review and ac

ceptance. Provided in the FAA’s guidance on the development of an FRMP is a requirement for a fatigue education and awareness training program element, one of the subtasks of this element is the effects of commuting on fatigue. This requirement reflects the perspective that managing the effects of commuting on fatigue is a joint responsibility of airlines and pilots, a posi

tion with which the committee agrees. Although the FRMP approach is not as rigorous as the FRMS process, it is required of all Part 121 airlines and therefore presents an opportunity to reach a wider audience than FRMSs.

RECOMMENDATION 3: The committee supports fatigue education and awareness training as part of an airline’s fatigue risk manage

ment plan. Training relative to commuting should include guidelines regarding the effects of inadequate or disturbed sleep or prolonged wakefulness on fatigue and performance. Fatigue education and aware

ness training should be annually updated with particular attention to incorporating relevant new developments in sleep science.

As part of its data collection, the committee requested that airlines submit information on their pilot commuting, sick leave, and fatigue poli

cies, if available. Although only a small proportion of airlines responded (39 percent), it is clear from the information submitted and from comments provided in public that there is considerable diversity in these policies. In addition, not all airlines have commuting or fatigue policies, with pilots rely ing instead on sick leave availability to address potential fatigue. Air

-

### 8 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### lines should consider policies that would help pilots plan predictable com

mutes that do not promote fatigue on duty and policies that minimize the negative consequences when unanticipated events alter their commuting plans and lead to fatigue. The effects of these policies on pilot behavior are currently not well understood.

RECOMMENDATION 4: The Federal Aviation Administration should convene a joint industry, labor, and government working group, un

der the auspices of an independent organization (such as the Flight Safety Foundation), to assess industry policies on pilot commuting, sick leave, attendance/reliability, and fatigue and to develop industry best practices. The output of this joint working group should inform the development and updating of airline’s fatigue risk management plans and should be validated periodically.

Pilots make decisions about commuting in the context of other factors in their lives, the specifics of their flights, the policies in place at their air

lines, including sick leave and commuting policies, and other environmental factors. It is unclear to what extent pilots are aware of the findings from
current decision science or consider this information in their decision mak

ing. Decision-making strategies informed by this science could be incorpo

rated into FRMP training and considered in the development of industry best practices.

RECOMMENDATION 5: The Federal Aviation Administration should commission efforts to develop protocols and materials for training pi

lots to make decisions regarding commuting easily and effectively and to ensure that they are informed by current decision science.

As noted above, little is known about pilots’ commuting patterns and the extent to which their commuting patterns may affect the amount or quality of sleep or the amount of time awake prior to duty. A better un

derstanding of the relationship of commuting to primary risk factors for fatigue would represent a first step in increasing understanding of the relationship between commuting and fatigue. This information, combined with information that is recommended for inclusion in fatigue risk manage

ment plans, or in fatigue risk management systems when such systems are required, will provide input needed to inform further research and industry policies.

RECOMMENDATION 6: To inform the development of industry best practices and policies relative to commuting, the Federal Aviation Administration should fund a study to determine the relationshipsSUMMARY 

### 9

between distance from domicile and five primary fatigue risk factors: (1) sleep quantity in the 48 hours prior to the end of duty on each day of the trip; (2) sleep quality in the 48 hours prior to the end of duty on each day of the trip; (3) time awake in the 48 hours prior to the end of duty on each day of the trip; (4) cumulative sleep time in the 72 hours prior to the end of a duty period; and (5) circadian phase at which sleep is obtained and at which duty is undertaken. In order to be maximally useful, the study should include a large random sample of pilots from multiple companies representing the major industry segments. The study should provide objective data on fatigue risk antecedents by us

ing a well-validated technology that provides reliable information on sleep and wake periods, such as wrist actigraphy, as well as sleep-wake
diaries.

Collecting data on a 48- to 72-hour period is needed to fully under

stand pilots’ commuting experiences in the context of the many factors that affect their lives and work. The results of the study can help to identify situations that may warrant specific attention or additional research.

### 11 

# 1

Introduction

Nearly everyone experiences fatigue, but some professions, such as aviation, medicine, and the military, demand alert, precise, rapid, and well-informed decision making and communication with little margin for error. Recognizing this, the National Transportation Safety Board (NTSB) added “Reduce Accidents and Incidents Caused by Human Fatigue in the Aviation Industry” to its list of most wanted aviation safety improvements two decades ago. Specifically, the NTSB called for research, education, and revisions to regulations related to work and duty hours. Although regula

tory change has received attention in the form of at least two rounds of rule-making activity, there have been no actual changes to relevant regula

tions since 1985 despite a significantly expanded research base on sleep, fatigue, and circadian rhythms. 1 

### The potential for fatigue to negatively affect human performance is well established. Concern about this potential in the aviation context extends back decades, with both airlines and pilots agreeing that fatigue is a safety concern. A more recent consideration is whether and how pilot commuting, conducted in a pilot’s off-duty time, may affect fatigue during flight duty. It is important to note, however, that fatigue is not a binary condition in which one is either rested with no negative effects on performance or

1 A Notice of Proposed Rulemaking (NPRM) with revised regulations on this topic was promulgated in 1995, but it was withdrawn in 2009 with the acknowledgment that changes since 1995 in both the world of commercial aviation and the scientific understanding of fa

tigue had rendered it out of date. A new rule-making activity was started that resulted in a new NPRM issued in 2010. The committee discusses this FAA rule-making activity related to flight crew fatigue in Chapter 6.

### 12 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### fatigued with severe negative effects on performance. There are degrees of fatigue and degrees of the negative effects of fatigue on performance. Moreover, fatigue is highly variable and is influenced by a number of fac

tors, including amount of sleep, time awake, workload, time on task, and time of day.

STUDY BACKGROUND AND COMMITTEE CHARGE

Concern about the potential contribution to fatigue from time spent commuting to a duty station—known as a pilot’s domicile—increased fol

lowing a fatal Colgan Air crash in Buffalo, New York, on February 12, 2009. The crash, and the first officer’s cross-country commute, received substantial media attention. The NTSB determined that the probable cause of the accident was “the captain’s inappropriate response” to a low speed condition (National Transportation Safety Board, 2010b, p. 155). The NTSB report identified multiple contributing factors related to flight crew and corporate responsibilities. That report did not list fatigue or commuting as a probable cause or contributing factor in the accident report. Instead, the Board concluded that “the pilots’ performance was likely impaired because of fatigue, but the extent of their impairment and the degree to which it contributed to the performance deficiencies that occurred during the flight cannot be conclusively determined” (National Transportation Safety Board, 2010b, p. 108). Against this backdrop, in September 2010, Congress, through the Air

line Safety and Federal Aviation Administration Extension Act of 2010 (P.L. 111-216), directed the Federal Aviation Administration (FAA) to revise its regulations related to work and duty hours to reflect current research. The law also directed the FAA to contract with the National Academy of Sciences, through the National Research Council, to conduct a study of the effects of pilot commuting on fatigue. The Committee on the Effects of Commuting on Pilot Fatigue was constituted to carry out the mandatedstudy, which is intended to inform the development of the commutingrelated aspects of the FAA regulations also specified in the act. The committee was directed to review information in seven specified areas. These areas were (1) the prevalence of pilots commuting in the com

mercial air carrier industry, including the number and percentage of pilots who commute greater than 2 hours each way to work; (2) characteristics of commuting by pilots, including distances traveled, time zones crossed, time spent, and methods used; (3) the impact of commuting on pilot fatigue, sleep, and circadian rhythms; (4) commuting policies of commercial air car

riers (including passenger and all-cargo air carriers), including pilot checkin requirements and sick leave and fatigue policies; (5) post-conference materials from the FAA’s June 2008 symposium titled “Aviation FatigueINTRODUCTION 

### 13

Management Symposium: Partnerships for Solutions;” (6) FAA and inter

national policies and guidance regarding commuting; and (7) to the extent possible, airline and pilot commuting practices. On the basis of that review, the committee was charged to discuss relevant issues with the goal of identifying potential next steps, including possible recommendations related to regulatory or administrative actions or further research that can be taken by the FAA: see Box 1-1 for the com

mittee’s specific Statement of Task. The FAA issued a Notice of Proposed Rulemaking (NPRM) on Sep

tember 14, 2010—with a broad scope encompassing all aspects of pilot flight, duty, and rest requirements—inviting public comment that would be considered in issuing final regulations (Federal Aviation Administration, 2010c). 2 

### This study is intended to inform the component of those final regulations that are relevant to pilot commuting.

2 The full text of the NPRM is provided at the following link: http://www.gpo.gov/fdsys/pkg/ FR-2010-09-14/pdf/2010-22626.pdf [June 2011]. 

### BOX 1-1
Committee Statement of Task

Statement of Task:Under the oversight of the National Research Council’s Board on HumanSystems Integration (BOHSI), an ad hoc multidisciplinary committee has been appointed to review the effects of commuting on pilot fatigue. The committee will review available information related to the prevalence and characteristics of commuting, literature related to sleep, fatigue, and circadian rhythms, airline and regulatory oversight policies, and pilot and airline practices. Based on this review, the committee will

• define “commuting” in the context of pilot alertness and fatigue;

• discuss the relationship between the available science on alertness, fa

tigue, sleep and circadian rhythms, cognitive and physiological perfor

mance, and safety;

• discuss the policy, economic, and regulatory issues that affect pilot commuting;

• discuss the commuting policies of commercial air carriers and to the extent possible, identify practices that are supported by the available research;

and

• outline potential next steps, including to the extent possible, recommenda

tions for regulatory or administrative actions, or further research, by the Federal Aviation Administration (FAA).

### 14 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### This report describes pilot commuting and the relevant aspects of the aviation industry; reviews current and proposed regulations and nonregula

tory approaches to reducing the risk from fatigue; presents the committee’s analyses of input from stakeholders; reviews the scientific literature on fa

tigue in relation to time awake, time asleep, and time of day; and presents the committee’s findings, conclusions, and recommendations based on the information available during the course of the committee’s deliberations. The committee produced an interim report, Issues in Commuting and Pilot Fatigue: An Interim Report (National Research Council, 2011). That report described the committee’s work to that date, mapped out the ap

proach to information collection for the final report, and provided a review of the relevant scientific literature and regulatory documents. This report incorporates much of the interim report as background information. 3



### INFORMATION COLLECTION

There is extensive research—including research specific to the aviation industry—on alertness, fatigue, sleep, and circadian rhythms; cognitive and physiological performance; and safety. However, there is very little infor

mation specifically on pilot commuting, including commuting practices or airline policies and practices related to commuting. To help address this gap, the committee issued a call for input that was sent to pilot and airline associations and passenger groups and was posted on the project website: see Box 1-2. That call included an invitation to respond to a set of questions specific to the types of information the committee was asked to review: see

Box 1-3. The committee also requested information from 84 passenger and cargo airlines listed as Part 121 carriers by the FAA. 4 

### The airlines were invited to provide input to the study on the relevant topics. The airlines provided a variety of information, including general responses to questions the committee posed, as well as zip code data on pilots’ residences and domiciles (their place of work). In the interests of confidentiality, the com

panies that responded have been de-identified for data presentations in the report. The committee received written input from 37 airlines, associations, and groups: see Appendix A. In addition, the committee received input from organizations and indi

viduals interested in providing information, both in writing and in presenta

tions to the committee. All parties who wished to talk with us were included

3 A copy of the report is available for free download from the National Academies Press at http://www.nap.edu/catalog.php?record_id=13097 [June 2011].

4 Part 121 applies to most passenger and cargo airlines that fly transport-category aircraft

with 10 or more seats.INTRODUCTION 

### 15

**BOX 1-2** Organizations Contacted for Input

PILOT ASSOCIATIONS AND UNIONS

• Air Line Pilots Association

• Coalition of Airline Pilots Associations

• Allied Pilots Association (American Airlines pilots)

• Independent Pilots Association (UPS pilots)

• Southwest Airlines Pilots Association

• Teamsters Local 1224 (Horizon Air, Southern Air, ABX Air, Atlas Air World

wide [Atlas and Polar Air Cargo], Kalitta Air, Cape Air, Miami Air, Gulfstream Air, Omni Air and USA 3000 pilots)

• U.S. Airline Pilots Association (US Airways pilots)

• International Federation of Airline Pilots Association

AIRLINE-RELATED ASSOCIATIONS

• Air Transport Association

• Cargo Airline Association

• International Air Transport Association

• National Air Carrier Association

• National Air Transport Association

• National Business Aviation Association

• Regional Air Cargo Carriers Association

• Regional Airline Association

INDEPENDENT SAFETY-RELATED ORGANIZATIONS

• Air Travelers Association

• Flight Safety Foundation



### at open meetings held in November and December 2010 and February 2011: see Appendix B for the public meeting agendas. The committee also considered information from the following sources:

• a review of NTSB reports on aviation accidents to identify available information related to the contribution of commuting to flight crew fatigue;

• a review of confidential reports that mentioned commuting or fa

tigue that were submitted to the aviation safety reporting system (ASRS), a voluntary pilot reporting system; 5

5 ASRS is funded by the FAA and hosted by the U.S. National Aeronautics and Space

Administration.

### 16 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### • a review of the comments related to commuting or fitness for duty submitted in response to the NPRM;

• a review of available information on relevant airline policies and practices in the international arena;

• analysis of data requested from airlines on pilot residence (zip code) and duty location/domicile (zip code) to enable an approxi

mation of linear distance between home and domicile; and

• a review of the relevant scientific literature.

OPERATIONAL DEFINITIONS

For the purposes of this report, the committee used or adopted working operational definitions for three key issues: pilot fatigue, pilot domicile and home, and pilot commuting.

Pilot Fatigue

There is very strong evidence that fatigue can result in deteriorated performance (see Chapter 4). The Institute of Medicine defines fatigue as “an unsafe condition that can occur relative to the timing and duration **BOX 1-3** Topics Posed in Call for Public Input

Interested organizations or individuals were invited to provide comments on

their perspective in the following areas, as relevant to their work and experience:

A. the prevalence of pilots commuting in the commercial air carrier industry, including the number and percentage of pilots who commute greater than

2 hours each way to work;

B. the characteristics of commuting by pilots, including distances traveled,

time zones crossed, time spent, and methods used;

C. the impact of commuting on pilot fatigue;

D. whether and, if so, how the commuting policies and/or practices of commer

cial air carriers (including passenger and all-cargo air carriers), including pilot check-in requirements and sick leave and fatigue policies, ensure that pilots are fit to fly and maximize public safety;

E. whether and, if so, how pilot commuting practices ensure that they are fit

to fly and maximize public safety;

F. how “commuting” should be defined in the context of the commercial air

carrier industry; and

g. how FAA regulations related to commuting could or should be amended to

ensure that pilots arrive for duty fit to fly and to maximize public safety.INTRODUCTION 

### 17

of work and sleep opportunities” (Institute of Medicine, 2009, p. 218). Reported failings from fatigued pilots “have included procedural errors, unstable approaches, lining up with the wrong runway, and landing without clearances” (Federal Aviation Administration, 2010c, p. 55,855). Although it is recognized that fatigue can contribute to aircraft accidents, there is no agreed upon objective measure of fatigue post accident. Therefore, conclu

sions that fatigue likely contributed to accidents are most often inferred from evaluating sleep-wake history relative to scientific evidence on the causes and consequences of fatigue and, where possible, from review of the cockpit voice recorder. For this study, the committee focused on fatigue that would result from or be mitigated by off-duty activities, particularly those activities related to commuting (e.g., frequency and duration of com

mutes and opportunities for sleep).

Pilot Domicile and Home

The committee considers a pilot’s “domicile” to be the airport where a pilot begins and ends a duty assignment. This term is distinguished from a “hub,” which is a focus for the routing of aircraft and passengers. A pilot’s domicile may be at one of the airline’s hubs, but it may also be at an airport
that does not serve as a hub for that airline. The committee considers a pilot’s “home” to be the pilot’s residence: it is important to note that it is not necessarily the place where the pilot had the most recent opportunity for his or her customary sleep period prior to duty. The pilot may have access to a hotel room, apartment, or other sleep accommodation near his or her domicile for rest before starting an assignment.

Pilot Commuting

The committee considers pilot “commuting” to be the period of time and the activity required of pilots from leaving home to arriving at the do

micile (airport—in the crew room, dispatch room, or designated location at the airport) and from leaving the domicile to returning back to home. Pilot commuting takes place during off-duty hours. Pilot commuting differs from the commuting of other workers in terms of frequency and variability, distance, transport modes, and time of day. Figure 1-1 depicts pilot commuting in relation to a pilot’s off-duty and on-duty periods. The figure illustrates the complexity of factors that affect a pilot’s commuting choices including opportunities for rest and sleep. There is the potential for tremendous variability across individual pilot commut

ing practices and day-to-day experiences. This variability results from many influences, not only the duration or distance of the commute. In addition, commuting practices may be subject to further variation when pilots are

### 18 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### reassigned to different domiciles with seasonal or economic fluctuations in the industry. In planning a commute, a pilot must consider many things in order to arrive fit for duty such as time of day and time zone at start of duty, availability of seats on commuting flights, affordability and availabil

ity of sleep facilities, airline policies, and possible delays. These and other influences on pilots’ commuting decisions are discussed further throughout the report. The airline industry, the FAA, and other stakeholders have not adopted a uniform definition of pilot “commuting.” Airlines vary in their definitions and some airlines that provided commuting policies to the committee do not formally define it, although these policies are generally intended for pilots who live far enough away that they have to fly to their domicile to begin duty. The NPRM notes a reference from the British aviation safety agency FIGURE 1-1 Commuting in relation to duty. NOTE: The figure maps a pilot’s commuting and duty cycle along a timeline of variable start time and duration, noting the opportunities for rest and sleep and the many influences on commuting. Commuting can be active (driving oneself) or passive (allowing opportunities for rest or sleep). Deadheading (which involves passive traveling by air while on duty) counts toward work time and is not part of commuting. **Duty Includes duty flights,**  **time on ground, and**

**any deadheading Commute to Domicile** 

**Surface commute (e.g., car, bus, train),**  **passive air commute,**

**or combination**

**Influences on commuting choices**

**• Distance from domicile** 

**• Direction of travel (E-W, W-E)** 

**• Industry policies: commuting, scheduling,**  **fatigue/sick leave policies.**

**• Time since awake at start of duty** 

**• Time of day at start of duty** 

**• Number of time zones crossed** 

**• Opportunities and facilities for sleep** 

**• Availability of transport** 

**• Sleep prior to commute** 

**• Planning for unexpected delays**  ** Home**  **** **Prior to Duty Wait at airport**  **or time to sleep**

**at local**

**accommodations**

**Sleep/rest opportunities off duty and during commute** 

**• Home** 

**• Passive surface commute** 

**• Shared accommodations** 

**• Hotel** 

**• Airport accommodations** 

**Sleep/rest opportunities during passive flight** 

**• Jumpseat** 

**• Sleep compartment** 

**• Cabin seating (economy, other)**  

### On Duty **Commute (off duty) Off Duty** 

**... ...**  **Off Duty Commute Home** 
**Surface commute (e.g., car, bus, train),**  **passive air commute,**

**or combination**INTRODUCTION 

### 19

(the United Kingdom Civil Agency Authority) to commuting being more than 1.5 hours. In contrast, the FAA advisory circular, on Fitness for Duty, AC-120 FIT, sets a 2-hour threshold (Federal Aviation Administration, 2010c; U.S. Department of Transportation, 2010b). These dividing lines are arbitrary. Distinguishing or characterizing a commute solely on the basis of the duration or distance of commute, or modality of commuting, is overly simplistic. Such an approach may be desired for operational applications,but current thresholds for defining commuting based on time lack evidencebased underpinnings. Commuting matters insofar as it may interfere with fitness for duty. These determinations must be guided by scientific evidence on sleep and fatigue, in both laboratory and operational environments (see Chapter 4). All commutes, even commutes involving the same amount of time, may not have the same potential to influence fatigue. Some commutes may not be cognitively or physically demanding (e.g., seated as a passenger on a train, bus, or plane), even to the point of permitting sleep to be obtained, while other commutes may entail more physical (e.g., standing) or cognitive (e.g., driving) demands. Also, long distance air commutes that cross time zones have the potential to exacerbate fatigue for a commuting pilot by disrupting the sleep-wake cycle, depending on the time of day, direction of travel, and other characteristics of the flights operated after the commute. Yet, in some situations, the crossing of time zones potentially can mitigate the fatigue from a combined commute and flight duty period.

Pilot Fatigue Management Decision Making

Decision making is central to pilots’ efforts to avoid flying aircraft while they are fatigued. There are three major circumstances in which such decision making has special significance: (1) when the pilot is developing plans for commuting to his or her duty station; (2) when the pilot must make adjustments in plans necessitated by arising contingencies (e.g., bad weather); and (3) when the pilot has to decide whether and how to cancel a duty assignment because of (anticipated) fatigue. The decisions in all such situations are highly challenging. For instance, they typically involve multiple, often conflicting considerations, numerous stakeholders with com

peting interests (e.g., family members, colleagues, and supervisors), and the need to be informed by nonobvious and sometimes counterintuitive facts about the biology of fatigue and rest.

GUIDE TO THE REPORT

The structure of this report corresponds to aspects of the committee’s charge. Chapter 2 provides background information on commuting in gen

-

### 20 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### eral followed by an overview of the unique characteristics of pilot commut

ing. The chapter also includes a review of stakeholder comments that were either provided to the committee or obtained through an analysis of public comments submitted to the FAA on the NPRM. The chapter concludes with a discussion of aviation industry characteristics that are relevant to the ef

fects of commuting on pilot fatigue, including airline pilot hiring policies; airline crew schedules and pilot work patterns; airline route networks and crew basing; and competitive and external factors. Chapter 3 provides background information on aviation safety, includ

ing sources of safety improvement, followed by an analysis of information on fatigue-related aviation accidents from reports by the NTSB. The chap

ter concludes with a discussion and analysis of pilot commuting patterns that exist today. Chapter 4 provides an overview of the relevant science related to sleep, circadian rhythms, and fatigue. Chapter 5 includes a discussion, followed by illustrative examples, of aspects of pilot commuting that contribute to the risk of fatigue. The concluding Chapter 6 discusses ways to reduce the risk from fa

tigue caused by commuting. The chapter begins with background informa

tion on the current regulatory context followed by a discussion of fatigue risk management strategies for airlines. The committee’s recommendations are presented at the end of Chapters 5 and 6. Following the list of references, a glossary and an acronym list are pro

vided. Additional background information, data sources, and analyses are included in the seven appendices. Appendix A identifies the airlines, associa

tions, and groups that submitted documents for the committee’s review. Ap

pendix B provides the agendas for the committee’s open meetings, which list the organizations and individuals that presented before the committee and responded to its questions. The committee conducted a thorough review of all the documents submitted by airlines, associations, and groups as well as a few individual pilots; a summary of its review is included in Appendix C. In addition, the committee examined public comments in response to FAA’s NPRM that related to commuting. Appendix D presents a summary of the analysis of that purposeful sample of public comments. An analysis of scheduled aircraft departures for the third quarters of 2000, 2005, and 2010 is discussed in Chapter 2. The data for this analysis in number of aircraft departures by airline and by city are available in Appendix E for mainline airlines and in Appendix F for regional airlines. Also provided in Appendix E is a list of airport codes alongside the corresponding airports and cities. The final appendix (Appendix G) includes the biographical
sketches for the committee members and staff.

### 21 

# 2

The U.S. Airline Industry and Pilot Commuting

This chapter discusses characteristics of the U.S. airline industry and the policies and practices that are likely to have an effect on pilots’ com

muting choices. This discussion draws on the expertise of committee mem

bers, information from stakeholders who provided comments at committee meetings or through the study website (see Box 1-3 in Chapter 1), a review of the comments related to commuting that were submitted to the Federal Aviation Administration (FAA) in response to the Notice of Proposed Rule

making (NPRM), and a review of available airline policies.

COMMUTING: BACKGROUND

Commuting is usually defined as travel between home and a work lo

cation on a regular basis. A Gallup Poll found that the mean commute in the United States was 45.6 minutes and the median was 30 minutes; over

all, about 64 percent of commutes were less than 1 hour while 8 percent were 2 hours or more (Gallup, Inc., 2007). Characterizing a population’s commuting routines is complex at best because of the enormous variation between individuals, as well as the variation for individuals from 1 day or week to another (Lyons and Chatterjee, 2008). Most of the research on the effects of commuting and commuting habits has been conducted in the context of daily routines using ground transportation in large urban areas. Although there are some studies of remote or rural geographic areas and of employees in specific industries, such as shift workers, hospital staff, and miners, there is very little research that examines (or even mentions) the commute of pilots or the airplane as a mode of transport.

### 22 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### The nature of commuting has been changing. In one study of commut

ing over a 10-year period, half of the sample changed their main method of travel at least once, and one-fifth changed three or more times (Dargay and Hanly, 2003). Several studies have looked at the physiological effectsof relatively long car drives (Kluger, 1998); self-reported attitudes in highcongestion conditions (Hennessy and Wiesenthal, 1999); and rail com

muting (Walsleben et al., 1999; Evans et al., 2002). A common conclusion across many studies is that unpredictability leads to stress. Unpredictability can be due to unanticipated delays because of traffic volume or weather or the unreliability of services. However, the studies do not examine the extent to which fatigue from commuting would affect subsequent job per

formance. They also do not make comparisons across modes of transport.
There is insufficient research as to whether a 90-minute car drive is more fatiguing than a 90-minute train ride or a 90-minute plane ride. There is a body of literature looking at the positive effects of travel (Mokhtarian and Solomon, 2001; Bull, 2004; Lyons et al., 2007; Jain and Lyons, 2008). These include a physical and cognitive break between
activities at home and those at work and time to do other activities. Some activities—such as reading, writing, or rest—are only possible in passive modes of transportation, such as trains, busses, limousines, and airplanes. But even active modes of transportation, such as driving one’s own vehicle, can provide time to think, to listen to an audiobook or music, to admire the landscape, and to engage in conversation with companions. The value of these activities depends on individuals’ preferences and other demands
on their time.

COMMUTING IN AVIATION

Commuting is different in aviation than in most other industries. For many pilots, commuting is not a daily occurrence, as pilot duty assignments often extend over several days and keep pilots away from home for multiple days at a time. As a result, a pilot’s commute to work may be undertaken as infrequently as once or twice per month—or more frequently, depend

ing on the flying schedule and commuting arrangements. Pilots sometimes travel to arrive near their domicile (the location of the airport from which they fly) for a period before they are scheduled to fly for logistical reasons or to have a rest opportunity. This rest opportunity may be of a length and quality varying from a nap in a chair to a full night’s sleep in a hotel room

or apartment. It is not uncommon for pilots to travel by air to and from their flight assignment. Pilots commute by air to some extent because they can, and to some extent because they want to: like many Americans, pilots’ planned commutes depend on a host of personal and professional decisions involv

-THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 23

ing family, economics, and logistics. Commuting by air enables pilots to
live a considerable distance from their domicile and travel to work in a relatively short time. Pilots who provided input for this study told the committee that their commute is influenced by both economic and lifestyle considerations. In the comments the committee received from pilots, half or more of those who addressed the reasons for commuting by air, cited the high cost of living in the area of their domiciles, frequent domicile closings and the future unpredictability of domicile changes, and a desire to maintain fam

ily stability. A pilot may choose a community of residence outside of the domicile area because of cost of living near his or her assigned domicile. A home community may be selected based on such quality-of-life factors as a desired geographic region, proximity to a school system, or the existence of a support infrastructure for family while the pilot is on extended flight duty. Commuting by air also enables a pilot to maintain a stable residence if he or she is reassigned to another domicile. One of the respondents to the NPRM expressed similar sentiments:

Commuting is common in the airline industry, in part because of life-style choices available to pilots by virtue of their being able to fly at no cost to their duty station, but also because of economic reasons associated with protecting seniority on particular aircraft, frequent changes in the flight crew member’s home base, and low pay and regular furloughs by some carriers that may require a pilot to live someplace with a relatively low cost of living. ( quote pulled from public comments in response to FAA’s NPRM, see Appendix D )



### The key issue for safety is whether a pilot begins the subsequent duty rested and fit to fly regardless of how the pilot commutes to work. Although some pilots live at or close to their domiciles, other pilots live in a location that has never been a company domicile, maintaining a consistent residence as their assigned domicile changes from one airport to another. Some commutes may be a legacy of previous domicile closings or changes, in which pilots who once lived near their assigned domiciles must then commute in order to maintain roots in their original home com

munities. A point frequently made to the committee was that commuting choices, including the availability of travel by air, can provide pilots and their families an aspect of certainty and control when facing or considering the likelihood of mergers, domicile changes, furloughs, and the like, even when considering these as potential disruptions in the future. A pilot’s do

micile may also change as that pilot’s career progresses and the pilot flies progressively larger aircraft, first as a first officer and then as a captain. Flexibility in commuting choices provides benefits for pilots, but it also provides benefits for the airlines. As discussed below, the U.S. airline

### 24 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### industry has undergone changes in structure and in the pattern of flights during the last decade. Having pilots able to commute longer distances to their domiciles rather than requiring them to live nearby may allow the industry to change flight patterns more quickly to respond to changing market demands. Since, for most airlines, pilots are not required to live near their domiciles, the airlines typically do not pay for pilot relocation or for cost-of-living adjustments when pilots move from one domicile to another. Airline passengers may benefit since airline costs are lower and, in a competitive market, lower costs tend to lead to lower prices for consum

ers. Box 2-1 summarizes the benefits of commuting for pilots, airlines, and

consumers.

STAKEHOLDERS’ COMMENTS

As described in Chapter 1, requests for input data were sent to a variety of different stakeholders in the airline industry (see Box 1-2 in Chapter 1). Because of the extremely short turnaround (a few weeks) between the requests and the committee meeting, the response rates were relatively mod

est. As of March 23, 2011, the committee had received responses from 25 airlines (4 mainline passenger carriers, 8 regional passenger carriers, 9 cargo carriers, and 4 nonscheduled charter carriers), 2 of the airline associations, and 2 of the pilot associations. The committee’s review of the responses is **BOX 2-1** Benefits of Commuting

Benefits for Pilots Stable residence for family Family residence selected for quality-of-life factors

Low cost of living or low tax jurisdiction location No need to relocate to progress in career No need to relocate for domicile changes for industry competitive reasons

Benefits for Airlines Ability to adapt quickly to changes in flight patterns because of changes in

market No need to require pilots to live near domicile

No need to pay relocation expenses for pilots for domicile change

No need to pay cost-of-living adjustments for domicile change

Benefits for Passengers/Consumers Potential lower cost services and lower pricesTHE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 25

summarized below and detailed in Appendix C. (Some airlines responded with written input after this date, and their input was considered for this report, but it is not included in the summary of stakeholder response in Appendix C.) The committee also received written statements from three individual commercial pilots who volunteered their thoughts on issues being addressed by the committee. The committee also reviewed public comments related to commuting submitted in response to the NPRM. The public comments were purpose

fully sampled to select those that would be most relevant to definitions of pilot commuting and perceptions of commuting practices. Using the FAA’s electronic database (a total of 2,419 submissions), relevant comments were identified using key terms: “commut”; “commute”; and “commuting” (N = 176). From these, a total of 85 comments, representing remarks from 85 different individuals or organization representatives, were deemed relevant and selected for qualitative analysis. In many cases, an individual comment contained multiple viewpoints of relevance (e.g., the commenter’s own definition of commuting and an opinion on the prevalence of com

muting practices with some suggestions for the NPRM). As a result, more than 400 viewpoints of relevance to the study were considered. Appendix D presents a summary of the analysis of the purposeful sample of public comments submitted in response to the NPRM. Both of these reviews of stakeholder input have limitations that must be considered in interpreting the findings. Neither of these analyses is based on representative samples. In the case of the stakeholder input requested by the committee, individuals or organizations from targeted groups provided input based on an open-ended set of questions or, in a few cases, offered unsolicited input on the study topic. In the case of the review of public comments to the NPRM, respondents were invited to provide feedback on all aspects of the NPRM, and this analysis took into account a selection of comments that were relevant to commuting. The response sample, in both cases, is self-selected. The reader is urged to remember that the views reflected in these analyses represent those individuals and organizations that were motivated to provide input to the committee or feedback in response to the NPRM. Thus, it is difficult to know, or even estimate, the extent to which different results would have been obtained from a larger and more representative sample of the stakeholder population. For those that responded to the requests, it is difficult to know whether each respondent understood each question or request as intended. The reader should also note that not all respondents responded to every question, issue, or request. In addition to self-selecting whether to respond, respondents self-selected the questions or topics to which they responded. One important initial finding from both of these reviews is that there is no clear, consistent definition of pilot commuting in the airline industry.

### 26 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### There are reports of difficulties in estimating the number of pilots who commute by air or who commute relatively long distances or durations as well as any other types of commuting patterns. Respondents did offer a wide range of factors that influence pilots’ com

muting decisions. In order of reported frequency, from high to low, they included high cost of living near the domicile location; frequent domicile clos

ings and future unpredictability of the airline industry; cost and availability of adjunct sleep accommodations; desire to maintain family stability; low pay, especially for regional carriers; lifestyle preferences (e.g., for good weather and outdoor living); and absence of adequate coverage for costly moving expenses. In the aggregate, respondents acknowledged that com muting is a potentially fatiguing activity, but they also commented that commut ing conducted responsibly would not necessarily increase fatigue levels signifi

cantly. In regard to policies and regulations that might influence commut

ing practices, the responses were mixed and diverse, ranging from opinions that current policies and practices are appropriate to suggestions for airline

owner ship of and FAA regulation of factors relevant to commutes and fatigue (e.g., availability of jumpseats and rest accommodations).

AVIATION INDUSTRY CHARACTERISTICS

Characteristics of the aviation industry that influence pilot commuting include airline pilot hiring practices, crew scheduling practices (at many airlines a joint outcome of management decisions and collective bargaining negotiations); route network and crew basing practices; and competitive and passenger demand factors that can cause pilot staffing requirements to change over time. These characteristics also influence pilots’ preferences related to commuting and their decisions about where to maintain their homes. Also, some airline policies and practices can facilitate or impede a pilot’s ability to commute, with the potential for affecting not only the pilots’ choices of whether and how to commute; but also whether they experience fatigue related to the commute and whether they may operate flights in a fatigued condition.

Airline Pilot Hiring Policies

Pilots compete for positions at airlines in an international market for their services in which the supply of pilots in most years has exceeded the demand from a relatively small number of employers. The sources of trained and qualified pilot candidates (primarily, universities, flight schools, the military, and smaller operators) are geographically diverse. The commit

tee did not have information on the percentages of pilots from each source. In the United States, pilots taking entry-level positions at regional airlinesTHE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 27

have tended to earn lower wages than pilots at mainline carriers. In many cases, pilots who join a regional carrier hope to change employment to a mainline carrier after they have accumulated additional flight experience. Recent contractions and consolidations among several of the mainline airlines and changes in the mandatory pilot retirement age have arguably reduced the outlook for positions at mainline carriers. The tradition in the U.S. airline industry is for the company not to pay for a newly hired pilot’s moving expenses or to require that the pilot live at the domicile. As a result, many newly hired pilots may have both the capability and incentive to be

gin long-distance commuting. Once established, this pattern may continue through subsequent domicile changes as the pilots attempt to maintain a
consistent residence.

Airline Crew Schedules and Pilot Work Patterns

At most airlines, labor agreements between pilots and airlines estab

lish specific policies and practices regarding flight crew scheduling (within limitations for flight and duty time as established in the Code of Federal Regulations). Virtually all of these airlines rely on a bidding process to award monthly schedules (sometimes called lines or blocks) to pilots; selection advantages are given to pilots on the basis of seniority. Typically, a monthly schedule consists of multiple assignments of trips (sometimes called pairings), each of which may consist of several flights over a period lasting 1, 2, or up to more than 6 days. Each of these trips begins and ends at the pilot’s domicile (there also may be one or more overnights elsewhere) and thus comprises the basic duty assignment to and from which the pilot

commutes. By federal regulations, airline pilots are limited to fly no more than 1,000 hours per year, or an average of about 83 hours per month. On the basis of this monthly limit, the number of flight hours per trip will deter

mine the number of trips—and thus, potentially, the number of commutes— during the month. For example, if each of a pilot’s trips involves 20 hours of flying over 4 days, the pilot will do about four of these trips per month for 80 hours of flight time. There will be one or more days off between each trip during which a pilot may elect to commute home. Using the seniority-based bidding process, pilots select the desired trips and days worked given their individual preferences, including the nature of their commutes. For example, a pilot who commutes by air from home to the domicile may bid for the monthly line of four, 4-day trips; preferably, trips beginning at the domicile late on the first day (allowing for an inbound commute that morning) and ending back at the domicile relatively early on the fourth day (allowing for a homebound commute that evening). This pilot will make four commutes during the month. In contrast, a pilot who

### 28 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### lives near the domicile (e.g., a drive of 45 minutes to the airport) may bid for 10 1-day trips, each of which starts early in the morning and returns to the domicile later that day after 8 hours of flight time. This pilot will make 10 commutes during the month to accumulate 80 hours of flight time. Note that in this example the 1-day trips have more flying time per day, on aver

age, than the 4-day trips in the previous example. The pilot living near the domicile will likely work fewer days to accumulate the 80 flight hours for the month; the pilot with a long distance commute will have more work days and fewer days off to accumulate the same number of flight hours.

Airline Route Networks and Crew Basing

Decisions that airlines make about aircraft routings, crew schedules, and crew basing can affect pilots’ commuting incentives. The point from which a pilot begins duty (typically his or her domicile, with the exceptions noted below) is influenced by airline management practices that vary in the industry. For example, many scheduled airlines—those that operate on spe

cific routes at established times—operate a hub-and-spoke route network in which many flights converge on one airport (the hub) at about the same time so that passengers and cargo can connect conveniently to a flight that is going to the ultimate destination (a spoke). Either a hub or a spoke city could be a pilot’s domicile. Basing pilots at a hub can be attractive for airlines from the point of view of scheduling flexibility and for exchanging crews during connecting operations in the midst of an operating day. Even in a hub-and-spoke sys

tem, though, many airplanes are positioned at the spoke airports overnight, and basing pilots at a spoke airport can reduce the expenses of providing overnight accommodations (“overnighting”) for the pilots who work the originating and terminating flights of the day. In any case, the scheduling and routing of crews does not have to match that of the aircraft. For airlines using domicile basing, whether located at a hub, spoke, or elsewhere, the airlines typically leave the pilots responsible for performing the commute— by whatever modes and means necessary—so as to be at the domicile reli

ably on time and ready for duty. By requiring its pilots to be ready to fly at any domicile, operators are able to select domiciles that minimize the overall costs of staffing the airline, in addition to other factors. In contrast to the practices of most major scheduled airlines, other air

lines (most commonly those offering nonscheduled service 1 

### ) operate flight patterns in which their airplanes may be routed in a highly variable manner in accordance with customer demand, rarely returning to a specified base. Given this aircraft routing it may be most efficient to dispatch flight crews

1 Nonscheduled airlines operate on customer demand without a regular schedule.THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 29

directly from their homes to wherever the previous crew left the airplane. Many of these airlines, consequently, have no established pilot domiciles. In these cases there may be at least a shared responsibility between the company and pilots for the trip from home to the first flying assignment. In one variant of these practices, home basing, there is effectively no commute because the pilot’s on-duty work period begins and ends at his or her home. All of the travel to and from the pilot’s operational flying is scheduled by, and the responsibility of, the company. As on-duty travel (as distinct from commuting travel), depending on the timing of the flights and as required by regulations governing flight time, duty time, and rest, the company may be required to provide adequate facilities and time for rest between the positioning flight to the duty location and the pilot’s first operational flight. In another variant, gateway basing, the company establishes a number of gateway airport locations and assigns the pilot to the gateway nearest his or her home. Pilots are then responsible for commuting between their homes and the gateway, while the companies are responsible for on-duty travel between the gateway and wherever in the world the pilot’s first operational flights will begin and end.

Competitive and External Factors

The dynamic and evolving structure of the airline industry affects the environment in which pilots make commuting decisions. Some airlines’ re

sponses to a changing competitive environment have involved establishing new hubs and downsizing or closing existing hubs and starting service to cities they previously did not serve or ending service to some cities. Airline mergers and acquisitions have also led to downsizing or elimination of hubs believed to be redundant in the postmerger route structure. Seasonal scheduling can cause other complications and may result in changes in pilot domiciles to accommodate increased or decreased passenger demand for particular routes. These changes in flight patterns may lead to domicile expansions, contractions, closings, or openings, with concomitant changes to where a pilot is domiciled. Changes in domiciles are handled, typically, through seniority-based bidding: pilots with relatively less seniority may sometimes be involuntarily displaced to new domiciles in other parts of the United States (or even other parts of the world), or, in the extreme, furloughed from the company. Subsequently, recalls from furloughs in response to increases in travel demand may result in pilots being recalled to a domicile that is different from the one from which they were released. Other major disruptions to pilot employment have occurred as airlines have reorganized their fleets and route systems under bankruptcy protection or even ceased operations and liquidated; other employment opportunities for pilots have

### 30 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### developed, often at different domiciles, as new entrant airlines have begun operations.

Changing Service Patterns in the U.S. Airline Industry

Figure 2-1 shows the number of passengers carried by U.S. airlines in both domestic and international service in 2000, 2005, and 2010. In

ternational traffic increased throughout the period while domestic traffic increased between 2000 and 2005 then decreased in 2010, largely because of changes in the economy. Aggregate traffic statistics for the U.S. air

line industry do not show some of the important changes that have oc

curred over the last decade in both industry structure and service patterns. Throughout the past three decades following airline deregulation, new airlines have entered the market, some airlines have grown, others have gotten smaller sometimes as part of a bankruptcy restructuring, and still others have ceased operations. Two kinds of changes in the U.S. airline industry over the past decade are particularly notable in their potential to affect pilot commuting pat

terns: the rise of regional jet service, and mergers. An important industry change that could affect pilot commuting is the rise of the regional jet in

dustry and the extent to which regional jet service operated under contract to mainline carriers has replaced service in larger jets operated directly by mainline carriers. The rise of the regional jet industry is a relatively recent development (see Oster and Strong, 2006). In 1995, there was no regional



## Figure 2-1.eps - 100,000 200,000 300,000 400,000 500,000 600,000 700,000 800,000

2000 2005 2010Number of Passengers

Domestic

Inter national

Y

ear



### FIGURE 2-1 Passengers carried by U.S. airlines. SOURCE: Derived from data, used with permission, from Air Transport Association of America, Inc. (2011).THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 31

jet service operating from the hub airports of the mainline carriers. By 2000, such service accounted for 16 percent of aircraft departures, and in the next 3 years such service had grown to 38 percent of aircraft departures from hub airports. In that 3-year period, domestic departures from hub air

ports by mainline carriers declined 18 percent while departures from those hubs by regional airlines under contract to the mainline carriers increased 250 percent, so that combined departures by mainline carriers and regional jets increased by more than 11 percent. Although some of this regional jet service was on routes that had not previously been served by the mainline carriers, much of the service was a replacement of mainline jet service by regional jet service. The growth of regional airlines at the expense of mainline airlines may change the overall pilot commuting patterns in the airline industry if the commuting patterns of regional pilots are markedly different than those of mainline pilots. Without examining the commuting patterns of pilots in these two industry segments, however, it is not possible to determine even the direction, let alone the magnitude, of such changes. One possibility is that regional pilots might on average commute longer distances than main

line pilots because of the lower salaries regional pilots generally earn, which
could make them less able to live close to their domiciles if those domiciles were in areas with a high cost of living. Another possibility is that regional pilots might on average have shorter commutes because the service they provide is more likely to be shorter haul service providing feed to longer mainline flights at the mainline airline’s large hub. In a service pattern such as this, a regional pilot is more likely to begin and end the flight sequence each day at the same hub airport, unlike a mainline pilot, particularly a mainline pilot who may have multiday international flight sequences and therefore begin and end days while on assignment at multiple hubs. Airline mergers were not uncommon prior to airline deregulation in 1978, but the pace of mergers and resulting industry consolidation picked up considerably in the 1980s. Most of those mergers were among relatively small airlines or were the result of large airlines merging with (or acquir

ing) smaller airlines. However, several of the more recent mergers since 2000 have involved large established carriers. Notable among these was the merger of American and TWA in 2001; the merger of US Airways and America West in 2005; the merger of Delta and Northwest in 2009; and the merger of United and Continental in 2010. As is discussed below, such mergers have the potential to change pilot commuting patterns because they often involve reducing the flight activity at some of the premerger hubs. In addition to the effects of hub expansion and contraction, mergers can bring changes in domicile assignments as pilots from the premerger airlines bid for new opportunities (crew positions and aircraft types) across the changed array of domiciles of the new (merged) airline.

### 32 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Another recent trend has been mergers and industry consolidation among regional airlines. Notable among these mergers have been the merger of Republic Airways, Shuttle America, and Midwest Airlines in 2005 and 2009; the merger of Skywest, Atlantic Southeast, and ExpressJet Airlines in 2005 and 2009; and the merger of Pinnacle Airlines, Colgan Air, and Mesaba Airlines in 2007 and 2010. Since these regional airlines typi

cally operate under contract with mainline airlines, it remains to be seen how much effect, if any, these regional airline mergers will have on pilot commuting patterns. To the extent that mergers in the regional segment of the industry result in large regional airlines that operate under contract with multiple mainline carriers that operate hubs in different parts of the country, the mergers have the potential to change commuting patterns by regional pilots as pilots assigned to one mainline carrier’s hub are assigned
to a different mainline carrier’s hub.

Departure Changes

Changes in the number of aircraft departures have the potential to af

fect pilot commuting patterns, particularly when those changes are at the airports most frequently served by an airline and likely to serve as pilot domiciles. If an airline is experiencing growth in departures at an airport, then more pilots are likely to be domiciled there, and pilots who were pre

viously domiciled elsewhere might find their best duty cycle options at that airport. Conversely, if an airline is reducing its departures at an airport, then it is possible that pilots who have less seniority may be furloughed and those more senior pilots who remain might find their best duty cycle options at a different domicile. If pilots perceive that the industry structure and service patterns are likely to continue to evolve and the demand for airline travel likely to continue to be subject to fluctuating economic con

ditions, they might choose not to relocate their residences each time their domicile changes.

Pilots’ Careers

It is important to recognize that there can be pilot domicile changes even when airline service patterns are stable. In many airlines, a pilot’s career progression involves moving from smaller to progressively larger aircraft as a first officer and then becoming a captain and again moving from smaller to progressively larger aircraft. In many airlines, the mix of aircraft sizes will differ across their hubs. International service, for example, is typically conducted in large aircraft, so a hub that serves as a base for international service may have a higher proportion of large aircraft than another hub that serves predominately domestic routes. Thus, even in theTHE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 33

absence of changes in service patterns, a pilot may change domiciles as part of a normal career progression.

CHANGES IN INDUSTRY PATTERNS

The committee was unable to obtain any systematic information about how frequently pilots experienced domicile changes or how such changes altered pilot commuting behavior. To try to gain some insight into some of the industry changes that might alter commuting behavior, the committee conducted an analysis of changes in the number aircraft departures, by city, by airline, in the cities most frequently served by that airline and thus in the cities most likely to serve as domiciles for pilots. The data used for this analysis were scheduled aircraft departures taken from the Bureau of Transportation Statistics (n.d.-a). The data were from the third quarters of 2000, 2005, and 2010. All 30 carriers who reported more than 20,000 aircraft departures in the third quarter of 2010 were examined; there were 12 mainline airlines and 18 regional airlines. Two of the airlines were all-cargo airlines, FedEx and UPS, and the rest were pas

senger airlines. Summary statistics for each mainline airline are presented in Appendix E and for each regional airline in Appendix F. The statistics presented are the total number of aircraft departures in 2000, 2005, and 2010 and the number of aircraft departures for each year by city for each city that was one of the top 10 cities in terms of aircraft departures for that airline in any of the 3 years. For carriers involved in mergers, if the carrier reported data in 2010 as a single carrier, as was the case with Delta, US Airways, and American, the premerger data were combined as if the car

riers had been merged in all three time periods. If the carriers involved in the mergers reported data separately in 2010, as was the case with United and Continental, then the carriers were treated separately throughout all three periods.

Rise of Regional Jets

In examining the data, it quickly becomes apparent that the role of affiliated regional carriers has a large impact on mainline service patterns. Three of the mainline carriers, Southwest, Air Tran, and JetBlue, do not use affiliated regional carriers, and all showed growth in departures throughout the period. The remaining mainline airlines, which do use regional affiliated airlines, all showed declines in aircraft departures throughout the period. Both Air Tran and JetBlue are relatively new and small carriers that had comparatively few departures in 2000 and showed strong growth in 2005

### 34 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### and 2010. Both also showed strong growth in departures at their primary hubs, Atlanta for Air Tran and New York’s Kennedy Airport for JetBlue. 2 

### Southwest is a much more established airline than Air Tran and JetBlue and had the most domestic aircraft departures in 2010 of any U.S. airline. Southwest showed steady increases in departures over the period (see Fig

ure 2-2), and it did not experience sharp decreases in departures at any of its primary cities (see Figure 2-3). There were small drops in several cities and somewhat stronger increases in Las Vegas, Chicago Midway, and Bal

timore, as well as significant new service established in Denver. Although these changes in departures reflect changing service patterns, they are not the dramatic changes that have been seen at some of the carriers involved in mergers, as is discussed below. There is considerable variation in departure changes across the regional carriers. American Eagle, a regional carrier owned by American Airlines, has had a relatively stable pattern of service with its primary airports being the American hubs of Dallas and Chicago: see Figure 2-4. Similarly, Atlantic Southeast, which has been primarily a regional carrier affiliated with Delta, has focused much of its service on Atlanta: see Figure 2-5. When Delta stopped using Dallas and Cincinnati as hubs, Atlantic Southeast also saw

2 A partial exception to this pattern was Frontier Airlines, which used a regional affiliate, Great Lakes Airlines, to provide some service, and it showed increases in departures over the period. Frontier, however, is something of a hybrid between a mainline and a regional airline in that it operates both larger Airbus aircraft (with more than 90 seats) and smaller regional jets with fewer than 90 seats. 

## Figure 2-2.eps bitmap , labels replaced (no w editab le) 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000

2000 2005 2010Number of Departures

Y ear



### FIGURE 2-2 Southwest total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 35



## Figure 2-3.eps bitmap , labels redr aw n 0 5,000 10,000 15,000 20,000 25,000

2000

2005

2010Number of Departures

PH X MC O BWI OA

K MD

W LA

X DA

L HOU LA

S BN A SA N ST

L DE N



### FIGURE 2-4 American Eagle departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE 2-3 Southwest departures by city.* *In all figures for the airline departure analysis, cities are identified by the appro

priate airport code. Provided in Appendix E is a list of airport codes alongside the corresponding airports and cities. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).



## Figure 2-4.eps

redr aw n 0 5, 000 10, 000 15, 000 20, 000 25, 000 30, 000

DF W OR D JF K LA X M IA BO S NA S S AN LG A

CM

H RD U DC A SJ C 

### 200 0

200 5

201 0Number of Departures



### declines in flights in those cities. Beginning in 2010, Atlantic Southeast has also been providing services associated with United Airlines. In contrast, Air Wisconsin has experienced greater change in its ser

vice patterns: see Figure 2-6. The two principal cities Air Wisconsin served in 2000 were Denver and Chicago, which it served as a United Express carrier. However, in 2010 it became a US Airways Express carrier and switched its primary cities from Denver and Chicago to the US Airways hubs of Philadelphia and Charlotte, both cities it had not served in 2000.

### 36 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



## Figure 2-6.eps bitmap , labels redr aw n 2000

2005

2010

0 2,0 00 4,0 00 6,0 00 8,0 00 10, 000 12, 000Number of Departures 

### 14, 000DENORDMSNMKEATWRAPASEGJTMLISBNIADPHLJAXCHSJFKCLTDCALGAORFBUFRICGSOBOSGSP 

### 16, 000



### FIGURE 2-6 Air Wisconsin departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a)

. 

## Figure 2-5.eps bitmap , labels redr aw n 2000

2005

2010

0 5, 000 10, 000 15, 000 20, 000 25, 000 30, 000Number of Departures 

### 3 5, 000ATLDFWXNAVPSGTRMYRCHAPFNAVLGNVCVGTPACAESHVMGMHSVTYSBTRMEMIADDTWORD



### FIGURE 2-5 Atlantic Southeast departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).



### Indeed, only one of the cities found in Air Wisconsin’s top 10 in 2000, Milwaukee, continued to receive Air Wisconsin service in 2010, and none of the cities that were top 10 Air Wisconsin cities in 2010 had been served by Air Wisconsin in 2000. The Air Wisconsin experience illustrates how changes in contracts be

tween the regional airlines and the mainline airlines can result in large changes in regional operations at specific hub airports, with associated changes in re

-THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 37

gional pilot domicile assignment. Air Wisconsin effectively moved its entire operation to a different part of the country so that virtually all of its pilots experienced changes in their domiciles.

Mergers

In addition to the rise of affiliated regional airlines, mergers also played an important role in the changing service patterns of the mainline airlines. For example, Delta and Northwest merged at the end of 2009. The merged Delta’s total departures are presented in Figure 2-7. Delta experienced steady declines in departures throughout the period. Delta also experienced some sharp declines at some of their hubs, partly in the wake of the merger and partly for other reasons: see Figure 2-8. While the main Delta hub, Atlanta, experienced only small proportional declines in 2010, the former Northwest hubs of Detroit and Minneapolis/ St. Paul experienced sharper declines following the merger. However, not all the declines were necessarily related to the merger. Delta’s original Cin

cinnati hub experienced sharp declines before the merger and even sharper declines following the merger. The even sharper declines in aircraft depar

tures at Dallas/Fort Worth indicate a decision made prior to the merger to no longer operate a hub at that airport. These sorts of sharp declines at airports that had once been hubs may well have placed pressure on pilots to alter their commuting patterns.



## Figure 2-7.eps bitmap , labels redr aw n 0 50,000 100,000 150,000 200,000 250,000 300,000 350,000

2000 2005 2010Number of Departures

Y ear 400,000



### FIGURE 2-7 Delta total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 38 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### After the merger was completed and the Delta and Northwest pilots had integrated their seniority lists, subsequent seniority-based bidding for domiciles and positions may have also resulted in changes to commuting patterns. For example, it is possible that some former Delta pilots who had homes in or near Minneapolis and had been commuting from Minneapolis to Atlanta could now bid to be domiciled at Minneapolis, a former North

west hub, and have a shorter commute. Such opportunities, however, given the drop in departures in Minneapolis, may have been limited to pilots with relatively high seniority. Another possibility is that former Delta pilots whowere both domiciled and living in Atlanta may have found their best postmerger opportunities were in a former Northwest hub and thus may have chosen a longer commute. As can be seen both with the Delta/Northwest merger noted above and with the other merged carriers shown in Appendix E, mergers often result in decreases in departures at some of the premerger hubs as the merged airline consolidates its operations (as occurred for St. Louis following the Ameri

can/TWA merger). But airlines have also sharply decreased departures at hubs for reasons not associated with mergers, as was seen in Delta’s reduc

ing departures at Dallas/Fort Worth and in Appendix E with US Airways’ reducing departures at Pittsburgh. Regardless of the reason that hubs are sharply downsized or eliminated, such actions can put pressure on pilots either to relocate or to alter their commuting patterns. Flight departures are correlated with airline crew staffing requirements. Again, these hub airports are not synonymous with pilot domiciles, but the dynamic nature of hub departure volumes suggests that the staffing of pilots to operate the flights 

## Figure 2-8.eps bitmap , labels redr aw n 0 10,000 20,000 30,000 40,000 70,000

2000

2005

2010Number of Departures

AT L MC O ME

M DF

W SL

C CV

G MS

P DT

W LGA JFK BOS LAX 50,000 60,000



### FIGURE 2-8 Delta departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 39

passing through them has been subject to substantial change over at least the past decade. Lacking specific data about pilot commuting patterns, the committee was unable to measure the specific effects of mergers on pilot commuting. In the absence of opportunities to commute by air, these changes in the airlines’ operating pattern could lead to large-scale, sometimes short-term, relocations of pilots and families or inflexibility in the airlines’ ability to adjust to changes in flight patterns and thus to staffing needs. Consequently, the availability of commuting by air allows airlines to adjust crew staffing and domiciles quickly in accordance with market demands.

AIRLINE POLICIES AND PRACTICES

Various airline policies and practices may facilitate or hinder pilots’ abilities to commute, particularly by air and over long distances. Such policies include access to free or reduced-rate air travel, commuting poli

cies that spell out the consequences of failing to report to the domicile on time because of commuting, and policies related to sick leave (including attendance/reliability) and fatigue. For the most part, these policies are currently unregulated and subject to collective bargaining agreements. The committee requested information from airlines, airline associations, and pi

lot associations about these policies and practices. Responses were received from 33 airlines including mainline, regional, cargo, and charter carriers. It is important to note that these responses were a collection of heterogeneous submissions. Airlines provided a range of information: some airlines pro

vided basic descriptive statements about their policies while others provided copies of the actual policies. The committee did not request nor receive information as to how these policies were developed, on what scientific research they were based, or on how the policies were implemented.

Access to Air Travel and Rest Facilities

As is the case with many other airline employees, pilots are able to take advantage of free or reduced-rate (nonrevenue) travel, on a standby basis. Nonrevenue travel is available on the pilot’s own airline network and, in many cases, also on other airlines. Seating may be available using unsold seats in the passenger cabin or the jumpseat, which is an additional observer seat on the flight deck available to other pilots by courtesy of the captain. Although some airlines allow pilots to reserve the flight deck jumpseat in advance, other carriers require pilots to stand by for the jumpseat until it is awarded to the senior requestor 30 minutes before flight time. Under these procedures, only the most senior pilots would be able to rely on obtaining a jumpseat for their commutes.

### 40 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Some airlines have adopted additional corporate policies that facilitate pilot commuting by air or reduce the potential for stress and fatigue. For example, FedEx reported to the committee that it allowed pilots to reserve the jumpseat in advance; provided sleeping facilities at both its sorting hubs and outlying stations; and included the time spent in commuting from the pilot’s home airport to the domicile in the calculation of duty time with respect to the limits established by the labor contract. (Time spent commut

ing is not considered in duty time under current FAA regulations.) Similarly, Delta Airlines reported in a submission to the committee that it allows jumpseats to be reserved in advance. Some cargo and charter carriers that engage in home basing reported to the committee that they provided re

served seats for the trip to the pilot’s duty location and provided minimum rest periods of 4-9 hours, depending on the carrier, between the arrival of the commuting flight and commencement of preflight activities for a pilot’s operational flight. Although nonrevenue travel dramatically lowers the cost of commuting for pilots, it has the disadvantage of the uncertainty of standing by for open seats, especially given recently experienced record load factors. 3 

### Figure 2-9 shows the changes in system-wide domestic load factors from 2000 through 2010. By 2010, load factors had increased to over 82 percent. (Load factors on international flights by U.S. carriers were over 81 percent.) During the most popular travel times and on the most popular routes, load factors are even higher. The result is that there are fewer and fewer empty seats avail

able to pilots (or other airline employees) for nonrevenue travel than was
the case when load factors were lower. Adding to uncertainty over commuting arrangements are flight delays and cancellations due to bad weather, air traffic control delays at congested hub airports, and flights delayed or cancelled because of unscheduled main

tenance needs. Pilots told the committee in testimony that they experience stress from these uncertainties, with the risk of losing pay and being subject to disciplinary actions if their commute goes badly and they do not arrive at the domicile in a timely manner. Furthermore, they stated that the most common way to mitigate this uncertainty is to begin the commute on an earlier flight from the home airport to the domicile, which takes more time away from home and may reduce sleep opportunities prior to the start of duty. Although some airlines provide quiet, dark, temperature-controlled sleeping facilities in or near the domicile, most airlines do not. Many pilots arrange for their own sleeping facilities at or near their domiciles. These facilities range from private apartments owned or rented by the pilots to

3 The passenger load factor is a measure of how much of an airline’s passenger carrying ca

pacity is used and is calculated as the ratio of revenue passenger miles to available seat miles.THE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 41

hotel rooms rented by the night to temporary living arrangements shared among groups of pilots. The arrangements at shared accommodations (often referred to by pilots as “crash pads”) vary from a private bedroom regularly assigned and available to the pilot to a shared room with mul

tiple bunk beds in which the pilot takes a “hot bunk” that is open for the night. Thus, shared accommodations can achieve the ideal of a quiet, dark, temperature-controlled sleeping area, or they can fall well short of the ideal. The quality of sleep obtainable at these locations, whether at hotels, shared apartments, or company provided rest facilities, may vary considerably. The challenge of obtaining restful sleep in a less-than-ideal facility can further increase the stress of commuting and can contribute to pilots’ oper

ating flights in a fatigued state. This outcome is more likely if a pilot com

mutes to the domicile with the intent of obtaining rest there, is unable to sleep well, anticipates becoming fatigued by the end of the upcoming duty shift, yet declines to call off the trip (desiring not to cause a flight delay or concerned about losing pay from a trip dropped due to fatigue). 

# Figure 2-9.eps 0 10 20 30 40 50 60 70 80 90

200 0 2001 2002 2003 2004 2005 2006 2007 2008 200 9 2010Percentage of Seats Filled



### Y ear

FIGURE 2-9 U.S. carrier domestic load factors. SOURCE: Data from Bureau of Transportation Statistics (n.d.-b).

### 42 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Commuting Policies

A pilot who does not report to the domicile on time to prepare for the first operational flight of the trip (usually 1 hour prior to scheduled pushback) must be replaced by a reserve pilot. The flight’s departure may well be delayed if a late-arriving pilot does not alert the company about the situation ahead of time. Consequently, pilots who show up late for duty risk disciplinary actions up to and including termination. Airlines recognize that the uncertainties of commuting may be responsible for some late reports or no-shows for duty. It is in the interest of the airline to receive “prenotifica

tion” from pilots who are experiencing difficulty with their commute in or

der to facilitate the call-up of reserve pilots without the cost and disruption of a flight delay. However, it is also in the interest of the airline to maintain consequences for pilots who report late in order to motivate the pilots to arrive for duty reliably on time. Consistent with these goals, some of the airlines that provided infor

mation to the committee reported the establishment of commuting policies that require pilots, for example, to attempt standby travel on two flights that have open seat availability and would arrive at the domicile on time. Pilots who do not clear the standby list for the first flight must then notify a crew scheduler or chief pilot about their situation (providing the airline with the desired advance notification of a possible late report). If these pilots do not clear standby for the second flight, they may be provided a reserved seat on the same flight (possibly bumping a paying passenger) or may be allowed to drop the beginning of their scheduled trip with loss of pay for the missed flight segments, depending on the airline’s policy. Under some commuting policies, pilots who provide the specified prenotification may be assured that no disciplinary action will be taken for the late arrival. At other airlines, disciplinary action may be taken for overuse or abuse of the commuting policy, while overuse or abuse may not be well defined. One airline reported to the committee that repeated use of the allowances in the commuting policy might result in the pilot losing the privileges of that policy in the future.

Sick Leave and Attendance/Reliability Policies

Regulations require the individual pilot to assess his or her fitness to fly and require pilots to decline to fly whenever unable to meet medical certi

fication requirements (i.e., they are sick). Most airlines provide sick leave as an employee benefit, with an earned bank of sick or multipurpose leave hours for pilots to use to avoid loss of pay when missing a trip due to illness. Traditionally, 1 hour of the pilot’s earned sick leave bank wouldTHE U.S. AIRLINE INDUSTRY AND PILOT COMMUTING 

### 43

be used to substitute for each hour of flying time on the missed trip (most pilots are paid by the hour of flight time, or more specifically, block time including taxiing). 4 

### The potential relevance of sick leave to commuting, the committee was told informally, is that a pilot who is experiencing difficulty with a com

mute may choose to call in sick for the upcoming trip in order to maintain pay for the trip (which may be up to one-third of one’s monthly earnings, depending on the number of trips per month). Atlantic Southeast Airlines provided, in a submission to the committee, an excerpt from its Flight Op

erations Manual that “the use of sick leave when commute difficulties are encountered is a violation of Atlantic Southeast policy and could subject the pilot to discipline.” Regardless of stated policy, airlines recognize that this use or abuse of sick leave does occur. Perhaps in response (among other reasons), some airlines have established attendance and reliability policies that require pilots who frequently use sick leave to provide documentation of their illness and treatment, submit to interviews by flight managers, or be subject to disciplinary steps that may potentially lead to termination.

Fatigue Policies

Some airlines have established specific policies about flight crew fatigue. Uniformly, under the policies reported to the committee, airlines rely on the pilots to report fit for duty, including being properly rested, and also to notify the airline if they are too fatigued to operate safely at any time during a trip. In what appears to be a typical airline procedural response to a statement of fatigue by a pilot, Ameristar Air Cargo reported to the com

mittee in a submission: “There are no adverse consequences for a pilot to call in fatigued. If a pilot uses the word ‘fatigue,’ ‘tired,’ or similar wording that he or she is unfit for flight, that pilot is automatically removed from a flight assignment.” Beyond this initial response, there is variation as to whether, as a matter of policy or practice, managers interview or investigate pilots who make such fatigue calls. Reported policies varied as to whether the pilot receives pay for a trip not flown because of fatigue or forfeits the pay that would have been earned from the trip. Delta Airlines reported to the committee that in its experience “. . . our recent reviews have not shown us a significant amount of absences or missed flights due to commuting. To our knowledge, we only have a few

4 Under some labor agreements, though, the use of sick leave has been capped on a monthly basis, so a pilot calling in sick for a trip may lose some or all of the pay for that trip. This kind of agreement may provide a different incentive for a pilot who is sick to perhaps report for work and attempt to fly when not medically qualified.

### 44 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### fatigue situations per year that are associated with commuting.” However, no systemic, reliable information from any airline was available to the com

mittee about the effects, if any, of commuting on pilots’ reliably arriving at their domicile on time for duty or about the effects, if any, of commuting on either fatigue or fatigue calls.

### 45 

# 3

Aviation Safety and Pilot Commuting

The concern about the potential effects of pilot commuting on fatigue is rooted in concerns that increased pilot fatigue might increase the risk of an airline accident. As discussed in Chapter 4, there is extensive scientific evidence on the negative effects of fatigue on the performance of many cog

nitive tasks, including those essential for safely operating a commercial air

craft. This chapter provides the context in which to consider that evidence. This chapter begins with a review of the airline safety record in the United States and then turns to the sources of improvement in aviation safety. Of particular importance for the focus of this report is a discus

sion of those features of the aviation system that can mitigate the risk of individual pilot fatigue for flight safety. In the third section the chapter ex

amines investigations of the National Transportation Safety Board (NTSB)
for accidents that occurred from 1982 to 2010 in order to determine how often fatigue is found to be a probable cause or contributing factor for an accident and the extent to which there is evidence that commuting might have contributed to that fatigue. Finally, the chapter examines what is known about the current patterns of pilot commuting.

AVIATION SAFETY

Figure 3-1 confirms that airline travel is the safest form of passenger travel in the United States. Measured on the basis of fatalities per 100 mil

lion passenger miles, the fatality rate for both buses and trains was about 4 times higher than for airlines while the fatality rate for automobiles was about 75 times higher.

### 46 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Although measuring safety in terms of fatalities per passenger mile is a useful way of comparing safety across different modes of road travel, it is not the most useful way to measure airline safety. 1 

### For automobile travel, for example, the risk of an accident varies across the types of roads used. Travel on interstate highways is much safer than travel on arterial high

ways, which in turn are much safer than travel on local roads (National Research Council, 2010, Figure 3-10). Travel on rural roads is more dan

gerous than travel on urban roads for all highway types. But in all of these categories of highway travel, the risk is roughly proportional to the distance traveled, so that the risk of a fatal accident on a 200-mile trip is about twice the risk on a 100-mile trip. Thus, for highway travel, measuring safety on a passenger-mile basis is a reasonable portrayal of the risk a traveler faces.

1 Transportation safety is usually measured as the ratio of some adverse outcome, such as an accident or fatality, to a measure of exposure such as the number of trips taken or the

distance traveled. 

### FIGURE 3-1 Safety of travel in the United States: 1989-2007. SOURCE: Derived from data, used with permission, from Air Transport Associa

tion of America, Inc. (n.d.). See http://www.airlines.org/Economics/DataAnalysis/ Pages/SafetyRecordofUSAirCarriers.aspx [August 2011]. 1927-1937: AA Statistical Handbook (December 1945). 1938-1971: CAB Handbook of Airline Statistics (1973), Part VIII, Items 19c, d, pp. 595-596; NTSB Safety Studies Division. 1972- 1982: FAA Statistical Handbook (1972-1982), Table 9.3, p. 161, citing NTSB for totals; 1983-present: NTSB Aviation Accident Statistics, Table 6. Fatal Accident Rate excludes incidents resulting from illegal acts, consistent with NTSB practice. 

## Figure 3-1.eps 0 0.1 0.2 0.3 0.4 0.5 0.6 0.7 0.8

Auto s B uses Tr ains AirlinesFatalities per 100Million Passenger Miles



### Mod eAVIATION SAFETY AND PILOT COMMUTING 

### 47

The safety of airline travel is different. With airline flights, the risk of accident is largely confined to the landing and takeoff phases of flight, in

cluding the climb, descent, and approach phases. 2 

### Thus, for airline travel, the risk of an accident on a 1,000-mile flight is virtually the same as on a 500-mile flight since the only difference is the amount of time spent in cruise. When looking at airline travel, either across segments of the industry or over time, it is better to measure safety on a departure basis rather than on a mileage basis. A common way to do this is to measure fatal accidents per million aircraft departures. One shortcoming of this measure, however, is that a fatal accident is defined as one in which at least one passenger was killed. In this measure, an accident in which one passenger of 200 passengers on board was killed is treated the same as one in which all 200 passengers were killed. So fatal accidents per 1 million departures, although better than a distance-based measure, is still not a good measure of the risk a passenger faces when taking an airline flight. However, this measure is often used when looking at worldwide safety trends because there is often limited information available about enplanements in some countries, some ambiguity about the number of passengers killed in an accident, or the definition of what constitutes a fatality may differ slightly. In the United States and throughout much of the rest of the world a fatality is considered to be from the accident if the passenger dies within 30 days of the accident from injuries suffered in the accident. To reflect the risk to a passenger from taking an airline flight, a commonly used measure is passenger fatalities per million enplanements. Figure 3-2 shows the aviation safety record from 1959 through 2009 for U.S. and Canadian operators (combined) and for operators in the rest of the world. Canadian operators have generally had comparable safety to U.S. operators, and the two countries are often grouped together. 3 

### Two things are apparent in the figure. First, the safety record both in the United States and Canada and in the rest of the world has improved considerably since the 1960s and 1970s. Second, the safety record in the United States and Canada has been markedly better than the combined record for the rest of the world. It is important to note, however, that the safety record in the rest of the world varies considerably both by region and by individual airline: consequently, although the combined safety record is worse than for the United States and Canada, there are individual airlines in the rest of the world that have amassed excellent safety records.

2 For commercial jet service between 1999 and 2008, only 10 percent of fatal accidents occurred during the cruise phase of flight according to the Boeing Commercial Airplanes Statistical Summary of Commercial Jet Airplane Accidents (Boeing Commercial Airplanes, 2011).

3 For more discussion of U.S. and Canadian aviation safety, see Oster et al. (1992, Ch. 4).

### 48Figure 3-2.epslandscape010203040505960626466687072747678808284868890929496980002040608101991 Through 2010Rest of the worldU.S. & Canadian operators91929498000204060896Year2.01.51.00.50.0Rest of the worldU.S. & Canadian operatorsAnnualfatalaccidentrate(accidentsper milliondepartures)Year10

FIGURE 3-2 U.S. and Canadian operators accident rates by year. SOURCE: Boeing Commercial Airplanes (2011, p. 18). Reprinted with permission.AVIATION SAFETY AND PILOT COMMUTING 

### 49

Figure 3-3 shows the U.S. Air Carrier Safety record over the 1990 to 2010 period. As can be seen in the figure, the safety record for the second half of this period is notably better than for the first half. 4 

### However, look

ing at aviation safety records over time must be done with care. Airline accidents are rare events, but when an accident happens, large numbers of people can be killed, so the passenger fatality rates from year to year show considerable variation. Therefore, one needs to be cautious in drawing in

ferences about airline safety getting better or worse when looking at only a few years of data.

IMPROVEMENTS IN AVIATION SAFETY

Commercial aviation involves complex interactions and coordination among equipment, information, and people. As a result it is not surprising that the reasons aviation safety has improved over time involve a variety of factors. One source of improvement has been the improved performance and reliability of critical equipment such as aircraft, engines, and avionics. Equipment failures have decreased dramatically and system redundancy has typically enabled safe landings when these failures do occur. Similarly, more accurate air traffic control procedures have improved safety margins

4 Fatalities from accidents involving illegal acts (sabotage, suicide, and terrorism) have been excluded from this analysis. 

### 0. 000 0. 020 0. 040 0. 060 0. 080 0. 100 0. 120 0. 140 0. 160

1990- 2010 1 990 -2 00 0 2 001- 2010

Ti me Pe ri odPassengerFatalitiesperMillionEnplanements



### FIGURE 3-3 U.S. air carrier safety record: 1990-2010. SOURCE: Data on passenger fatalities and enplanements calculated from infor

mation from the National Transportation Safety Board (n.d.) and the Bureau of Transportation Statistics (n.d.-a).

### 50 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### both in the air and on the ground. Airline pilot training has benefited from the widespread use of improved training programs and advanced flightsimulators in which pilots can learn to manage both normal and nonnormal events safely (Helmreich et al., 1999). Many of these and other improvements have resulted from the combined efforts of many people and organizations—including the National Transportation Safety Board, the Federal Aviation Administration, airframe and aircraft component manu

facturers, airlines, pilots, and many others—to understand the causes of accidents and to take steps to reduce the risk of future accidents. A particularly important component of aviation safety improvement for the purpose of the committee’s work has been the joint application of procedural, social, and technological systems to identify crew errors on the flight deck and to facilitate their correction or mitigation. Such errors can stem from a variety of human factors including fatigue. One approach known to reduce risks from errors is crew resource management (CRM) (see Helmreich and Foushee, 2010). CRM training is mandated by the Fed

eral Aviation Administration (FAA) for the pilots of all Part 121 operators to facilitate effective crew communication, coordination, and the use of appropriate resources to prevent error. This systematic training is designed to enhance the ability of crews to perform as a team in order to reduce the potential for human error and improve safety on the flight deck. Such train

ing emphasizes the importance of communication and consultation with each other regarding potential safety threats (including crew members’ own fatigue state), managing such threats, confirming actions being taken, and cross-checking information from both instruments and external sources. The intention is to improve situational awareness, problem solving, and decision making. If an individual crew member is fatigued and thus more likely to make errors, CRM can help mitigate the effects of fatigue so that the errors are made less frequently or are caught quickly before they lead to an increased safety risk. Specifically, the practice of CRM requires a crew member to monitor other crew members, aircraft automation, and the overall flight situation and to identify any suspected errors with a verbal challenge that must be acknowledged. Such crew coordination practices have been shown in observational studies to be effective in identifying, trapping, and correct

ing pilot errors due to fatigue (Foushee et al., 1986; Thomas et al., 2006; Petrilli et al., 2007; Helmreich and Foushee, 2010; Thomas and Ferguson, 2010). Checklists are another highly reliable error-trapping mechanism ( Boorman, 2001; Pronovost et al., 2006) that can help pilots avoid miss

ing key actions for successfully completing important safety-related tasks. Similarly, the use of callouts can help maintain attention both for the person making the callout and the person receiving it. The use of standard operat

-AVIATION SAFETY AND PILOT COMMUTING 

### 51

ing procedures and the annual training that reinforces their use provides highly structured, routinized processes that can facilitate reliable and re

peatable cognitive performance. In addition, social interaction among the crew members can help maintain alertness on the flight deck and, through exchanging relevant information, can help reorient a pilot to focus on task performance. Taken together, these forms of crew interaction can help miti

gate fatigue risk in individual pilots as well as fatigued crews. A potential downside is that they may mask a pilot’s awareness of his or her actual level of fatigue. For very long flights of more than 8 hours, crew augmentation, adding one or two additional crew members, can help mitigate fatigue risk par

ticularly when inflight rest facilities such as bunks are provided for crew members to sleep when they are not on duty. Even on shorter flights, re

search has shown that short, controlled naps are a well-established fatiguemitigation strategy (Rosekind et al., 1994; Werfelman et al., 2009) that can enhance all cognitive and physiological processes. 5 

### However, in considering naps, one has to take account of sleep inertia so that recovery time is pro

vided before the crew member has to perform. Flight deck technologies can also help mitigate the effects of fatigue. Onboard map displays have greatly enhanced crews’ cognitive situation awareness regarding airplane navigation (Wiener and Nagel, 1988). A range of systems such as stall and wind shear warnings, Traffic Collision Avoidance Systems, and Ground Proximity Warning Systems (now part of the Terrain Awareness and Warning System) have been shown to be highly effective in helping crews manage safety risks even when tired at the end of a long flight or series of flights (see, e.g., Kuchar and Drumm, 2007). More generally, when designed properly, automation can support and supplement the cognitive capacity crews need to operate safely, while enabling a pilot to transition back to taking over the aircraft manually when necessary. Air traffic control flight monitoring can also trap and help correct errors both by monitoring by human controllers and with automated systems such as Minimum Safe Altitude Warning Systems. Each of these systems and processes can be effective in mitigating risks to safety from an individual’s fatigue but none is completely reliable and some introduce other cognitive loads. Taken together, however, they help mitigate potential safety risks of fatigue.

FATIGUE-RELATED AVIATION ACCIDENTS

A complication in understanding past accidents and in preventing future ones is that airline accidents rarely have a single cause. Rather, accidents are

5 Napping is discussed further in Chapter 4.

### 52 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### usually the culmination of a sequence of events that involve multiple causes and contributing factors. It is often difficult to determine what happened that led to an accident and what the contributing factors were, particularly when the flight deck crew is killed in the accident and cannot provide input to the investigation. Although there is usually information about what they were saying from the cockpit voice recorder and information about what was happening to the aircraft from the flight data recorder, there can often be some doubt about whether all of the things that may have contributed
to the accident were identified and understood. Assessing the role that pilot fatigue may have played in an accident is a challenge because of other potential contributing factors. In some cases, the cockpit voice recorder may reveal that pilots talked about being fatigued during the flight or there may have been other signs of fatigue from the cockpit voice recorder. In other cases, the record may be clear that a pilot received very little sleep prior to the flight. Beyond assessing the role of fatigue in an accident, assessing the role that pilot commuting may have played in pilot fatigue may be an even greater challenge. A pilot who lives close to the domicile and has a short commute may not necessarily arrive for duty well rested depending on the pilot’s activities prior to the commute. If the pilot did not sleep well the night before reporting for duty or if the pilot engaged in physically tiring activity prior to reporting for duty, then the pilot may be fatigued even if the commute was very short. Conversely, if the pilot commutes to the domicile by air from a distant point, that pilot will not necessarily report for duty fatigued. The pilot may fly to the domicile city the day before the duty cycle begins and get a good night’s sleep in a hotel before reporting for duty. It is important to realize that the length of the commute, measured either by distance or time spent commuting, does not necessarily determine whether or not the pilot reports for duty fit and well rested. As discussed in Chapter 4, fatigue can be exacerbated by cumulative sleep debt, the situation when sleep obtained over multiple days is too short in duration to maintain alertness. If a commute prior to the start of duty contributes to cumulative sleep debt from inadequate sleep throughout a multiday trip, then it is conceivable that commuting may have contributed to fatigue that built during the multiday trip and subsequently contrib

uted to an accident. In the analysis of NTSB accident reports discussed be

low, the committee was unable to assess whether this might have happened in any of the fatigue-related accidents. Although there is strong evidence that fatigue can result in deteriorated pilot performance (discussed below), even in such cases, the fact that a pilot is likely to have been fatigued does not necessarily mean that the pilot’s fa

tigue resulted in errors made during the accident sequence or contributed to the cause of the accident. Well-rested pilots have been involved in airplaneAVIATION SAFETY AND PILOT COMMUTING 

### 53

crashes and fatigued pilots have completed flights without accidents. How

ever, because the contribution of fatigue can be difficult to detect during an accident investigation, it is quite possible that fatigue may have contributed to accidents even when there is no clear evidence of pilot fatigue in the ac

cident record.

Committee’s Method of Analysis

Recognizing these challenges, the committee examined NTSB reports of
recent accidents 6 

### to try to assess the roles that pilot fatigue and commuting may have played as risks to aviation safety. Between 1982 and 2010, there were 863 accidents in the Part 121 portion of the industry where the NTSB had determined the probable cause and contributing factors 7 

### to the accident. One approach would have been to look at the accident reports for all 863 accidents to determine how often pilot fatigue or commuting might have played a role in the accident. Unfortunately, the committee did not have the time or the resources to conduct such an analysis. Instead, the
committee did an electronic search of the NTSB Aviation Accident and Incident Data System, which contains information collected during NTSB investigations of accidents and incidents involving civil aircraft within the United States, its territories and possessions, and in international waters. This system contains both the NTSB “probable cause reports,” which pro

vide the NTSB findings as to the probable cause and contributing factors of the accident, and the NTSB “factual reports,” which provide descriptions of the sequence of events that culminated in the accident. 8 

### One limitation of this analysis is that it provides no information about how often pilots were fatigued during their flights but were not involved in an accident. A second limitation of this approach is that accidents in which

6 An aircraft accident is defined in Title 49 Section 830.2 as “an occurrence associated with the operation of an aircraft which takes place between the time any person boards the aircraft with the intention of flight and all such persons have disembarked, and in which any person suffers death or serious injury, or in which the aircraft receives substantial damage.”

7 “The NTSB determines the probable cause or causes of accidents. The objective of this determination is to discern the cause-and-effect relationships in the accident sequence. This could be described as why the accident happened. In determining probable cause, the NTSB considers all facts, conditions, and circumstances associated with the accident. Within each accident occurrence, any information that helps explain why that event happened is designated

as either a ‘cause’ or ‘factor.’ The term ‘factor’ is used to describe situations or circumstances that contribute to the accident cause” (National Transportation Safety Board, 2010a, p. 52).

8 The database was accessed through the FAA’s Aviation Safety Information Analysis and Sharing System 

### ( ASIAS) (see http://www.asias.faa.gov/portal/page/portal/asias_pages/asias_ home/datainfo:databases:k-o) [June 2011] by using the NTSB Query Tool. The database can be accessed directly through the NTSB website, but the ASIAS website provides easier and quicker access to the same data.

### 54 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### fatigue may have played some role in the accident but in which the NTSB determined that the role was not sufficient for fatigue to be considered a probable cause or contributing factor will not be included. For example, considerable attention was paid to the first officer’s commute and possible fatigue following the 2009 Colgan Air crash in Buffalo, New York. How

ever, this accident was the culmination of a series of events and errors by the flight crew and the NTSB did not find that fatigue was either a probable cause or a contributing factor in that accident, so that accident was not included in our analysis as a fatigue-related accident. Both fatigue and commuting were discussed in the NTSB report on the Colgan accident. In the wake of that accident, the NTSB made 25 safety recommendations. One of those recommendations was related to fatigue
and recommended that the FAA:

Require all 14 Code of Federal Regulations Part 121, 135, and 91K opera

tors to address fatigue risks associated with commuting, including iden

tifying pilots who commute, establishing policy and guidance to mitigate fatigue risks for commuting pilots, using scheduling practices to minimize opportunities for fatigue in commuting pilots, and developing or identify

ing rest facilities for commuting pilots. (National Transportation Safety Board, 2010b, pp. 112-113)



### To carry out its analysis, the committee did an electronic search of the
NTSB’s online accident database for Part 121 accidents between 1982 and 2010 where the probable cause or contributing factor contained any of the words “fatigue” or “tired” or “sleep” or “commute” or “commuting.”
Each record found in the search was reviewed to see if the reference was to pilot fatigue. (Many of the references were to component failure due to metal fatigue.) Table 3-1 shows the number of accidents in each injury category and how many of those accidents had references to pilot fatigue, including the statements on probable cause and contributing factors. 9 

### Of the 863 Part 121 accidents that occurred during this period, nine of the accidents made some reference to pilot fatigue as a contributing factor. Table 3-2 lists each of the nine accidents with fatigue as a probable cause or contributing factor. Each accident report was examined individu

9 The NTSB injury categories are defined as follows: Fatal—Any injury that results in death within 30 days of the accident; Serious—Any injury that (1) requires the individual to be hospitalized for more than 48 hours, commencing within 7 days from the date the injury was received; (2) results in a fracture of any bone (except simple fractures of fingers, toes, or nose); (3) causes severe hemorrhages, nerve, muscle, or tendon damage; (4) involves any

internal organ; or (5) involves second- or third-degree burns, or any burns affecting more than 5 percent of the body surface; Minor—Any injury that is neither fatal nor serious; None—No injury (taken from CFR, Title 49, Transportation, Part 830).AVIATION SAFETY AND PILOT COMMUTING 

### 55

ally to determine if commuting by the pilots appears to have been a major contributor to that fatigue.

Connie Kalitta Services

The NTSB Aircraft Accident Report provides the following flight his

tory factual information for an uncontrolled collision with terrain on Au

gust 18, 1993: “A Douglas DC-8-61 freighter . . . registered to American International Airways (AIA) Inc., [doing business as] Connie Kalitta Ser

vices, Inc., and operat[ed] as AIA flight 808, collided with level terrain ap

TABLE 3-1 Total Accidents and Fatigue Accidents by Injury Category, 1982-2010

Injury Category Total Accidents Fatigue Accidents

Part 121 Fatal 95 2

Part 121 Serious 423 4

Part 121 Minor 78 0

Part 121 None 337 3

Total 863 9

SOURCE: National Transportation Safety Board Accident and Incident Data System, accessed through the Federal Aviation Administration’s Aviation Safety Information Analysis and Sharing System (ASIAS).



### TABLE 3-2 Fatigue-Related Accidents, 1993-2009

Event Date Operator Name Category of Operation Flight Phase Fatal/

Nonfatal

Aug 18-93 Connie Kalitta Services Nonscheduled Approach Serious
May 8-99 American Eagle Scheduled Landing-Roll Serious

June 1-99 American Airlines Scheduled Landing Fatal
July 26-02 Federal Express Corp Nonscheduled Approach Serious

Oct 19-04 Corporate Airlines Scheduled Approach Fatal

Feb 18-07 Shuttle America Corporation Scheduled Landing-Roll None

Apr 12-07 Pinnacle Airlines Scheduled Landing None

Jan 27-09 Empire Airlines Nonscheduled Landing Serious

May 6-09 World Airways Nonscheduled Landing-Flare Serious
SOURCE: National Transportation Safety Board Accident and Incident Data System, accessed through the Federal Aviation Administration’s Aviation Safety Information Analysis and Shar

ing System (ASIAS).

### 56 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### proximately 1⁄4 mile from the approach end of runway 10, after the captain lost control of the airplane while approaching the Leeward Point Airfield at the U.S. Naval Air Station (NAS), Guantanamo Bay, Cuba. The airplane was destroyed by impact forces and a post-accident fire, and the three flight crew members sustained serious injuries” (National Transportation Safety Board, 1994a, p. 1). Prior to the accident, on August 16 at 2300 (start of the duty day), the captain and first officer originated their 4-day flight sequence in Atlanta, Georgia (ATL). Their duty day ended at 1200 August 17 at the Dallas/Fort Worth airport, where they were allowed an 11-hour rest period (relieved of flight duty and provided with a hotel room) (National Transportation Safety Board, 1994a). It does not appear to the committee that commuting prior to the start of the flight sequence contributed to the fatigue on the day of the accident. The NTSB determined “that the probable causes of this accident were the impaired judgment, decision-making, and flying abilities of the captain and flight crew due to the effects of fatigue; the captain’s failure to prop

erly assess the conditions for landing and maintaining vigilant situational awareness of the airplane while maneuvering onto final approach; his fail

ure to prevent the loss of airspeed and avoid a stall while in the steep bank turn; and his failure to execute immediate action to recover from a stall. Additional factors contributing to the cause were the inadequacy of the flight and duty time regulations applied to 14 CFR, Part 121, Supplemental Air Carrier, international operations, and the circumstances that resulted in the extended flight/duty hours and fatigue of the flight crew members. Also contributing were the inadequate crew resource management training and the inadequate training and guidance by American International Airways, Inc., to the flight crew for operations at special airports, such as Guanta

namo Bay; and the Navy’s failure to provide a system that would assure that the local tower controller was aware of the inoperative strobe light so as to provide the flight crew with such information” (National Transporta

tion Safety Board, 1994a, p. 78).

American Eagle

The FAA’s Aviation Safety Information Analysis and Sharing (ASIAS) Brief Report, based on information from the NTSB Aviation Accident/ Incident Database, provides the following flight history on a runway over

run and collision on May 8, 1999: “A Saab 340B . . . sustained substantial damage during landing at John F. Kennedy International Airport (JFK), Ja

maica, New York. The airplane was owned by AMR Leasing Corporation, and operated by American Eagle Airlines Inc. as flight 4925. There were no injuries to 3 crew members [two pilots and the flight attendant] and 26AVIATION SAFETY AND PILOT COMMUTING 

### 57

passengers, while 1 passenger sustained a serious injury [while exiting the airplane]” (National Transportation Safety Board, 1999, p. 4). The report describes the flight crew’s sleep and duty time prior to the accident: “The flight crew was working a continuous duty overnight sched

ule. The previous day, they both awoke during the morning hours, did not sleep during the day, and reported for duty about 2200 for a flight sched

uled at 2246. The flight was delayed, and arrived at Baltimore/Washington International Airport (BWI) about 0100. They were asleep about 0130, and awoke about 0445 for the accident flight, which was scheduled to depart at 0610” (National Transportation Safety Board, 1999, p. 10). The accident report does not contain any information on pilot’s commutes prior the start of the flight sequence, but it does not appear to the committee that commuting was the primary contributor to fatigue on the accident flight. The NTSB determined that the probable cause of this accident was the “pilot-in-command’s failure to perform a missed approach as required by his company procedures. Factors [contributing to the accident] were the pilot-in-command’s improper in-flight decisions, the pilot-in-command’s failure to comply with FAA regulations and company procedures, inad

equate crew coordination, and fatigue” (National Transportation Safety Board, 1999, p. 10).

American Airlines

The NTSB describes the flight history of a June 1, 1999, aircraft ac

cident: “American Airlines flight 1420, a McDonnell Douglas DC-9-82 (MD-82), . . . crashed after it overran the end of runway 4R during landing at Little Rock National Airport in Little Rock, Arkansas. . . . The captain and 10 passengers were killed; the first officer, the flight attendants, and 105 passengers received serious or minor injuries” (National Transporta

tion Safety Board, 2001, p. 1). The report goes on to describe the flight crew’s commute and sleep pat

terns prior to the accident: “Flight 1420 was the third and final leg of the first day of a 3-day sequence for the flight crew. The flight sequence began at O’Hare International Airport, Chicago, Illinois [where the captain was domiciled]” (p. 1). “On May 30, 1999, the first officer traveled from his home outside Los Angeles, California, to Chicago. The first officer indicated that he had been commuting from his home to the Chicago-O’Hare base for about 3 months and that, as a result, he was adjusted to the central
time zone. The first officer indicated that he was involved in routine activi

ties while in the Chicago area” (p. 11). “The captain and the first officer reportedly received a normal amount of sleep the night before the accident; both went to sleep about 2200 and awoke about 0730. Also, there was no evidence that either pilot had experienced cumulative sleep loss in the days

### 58 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### before the accident” (pp. 143-144). Thus, it doesn’t appear to the com

mittee that commuting was a contributing factor to the fatigue the pilots experienced on the accident flight. The NTSB determined “that the probable causes of this accident were the flight crew’s failure to discontinue the approach when severe thunder

storms and their associated hazards to flight operations had moved into the airport area and the crew’s failure to ensure that the spoilers had extended
after touchdown. Contributing to the accident were the flight crew’s (1) impaired perfor

mance resulting from fatigue and the situational stress associated with the intent to land under the circumstances, (2) continuation of the approach to a landing when the company’s maximum crosswind component was ex

ceeded, and (3) use of reverse thrust greater than 1.3 engine pressure ratio after landing” (National Transportation Safety Board, 2001, pp. 169-170).

Federal Express

The NTSB describes the flight history of a July 26, 2002, aircraft ac

cident: “Federal Express (FedEx) flight 1478, a Boeing 727-232F (727), . . . struck trees on short final approach and crashed short of runway 9 at the Tallahassee Regional Airport (TLH), Tallahassee, Florida. . . . The captain, first officer, and flight engineer were seriously injured, and the airplane was destroyed by impact and resulting fire” (National Transportation Safety Board, 2004, p. 1). The captain lived in Memphis, Tennessee, and the first officer stayed in an apartment in Memphis on July 23 and 24 and a hotel in Winnipeg, Manitoba, Canada, on July 25. The flight engineer commuted from Albany, New York, to Memphis on July 24. He spent the night of July 25 in a hotel in Ottawa, Ontario, Canada, while on another flight se

quence. It does not appear to the committee that commuting played a role in the fatigue that contributed to the accident. The NTSB determined “that the probable cause of the accident was the captain’s and first officer’s failure to establish and maintain a proper glidepath during the night visual approach to landing. Contributing to the accident was a combination of the captain’s and first officer’s fatigue, the captain’s and first officer’s failure to adhere to company flight procedures, the captain’s and flight engineer’s failure to monitor the approach, and the first officer’s color vision deficiency” (National Transportation Safety Board, 2004, p. 68).

Corporate Airlines

The NTSB describes the flight history of an October 19, 2004, aircraft accident: “Corporate Airlines (doing business as American Connection)AVIATION SAFETY AND PILOT COMMUTING 

### 59

flight 5966, a BAE Systems BAE-J3201, . . . struck trees on final approach and crashed short of runway 36 at Kirksville Regional Airport (IRK), Kirks

ville, Missouri. . . . The captain, first officer, and 11 of the 13 passengers were fatally injured, and 2 passengers received serious injuries” (National Transportation Safety Board, 2006, p. 1). “The flight crew was on a regularly scheduled 4-day sequence that began on Sunday, October 17, 2004. The accident occurred on the last flight of the third day, which departed from STL [St. Louis, Missouri] about 1842” (National Transportation Safety Board, 2006, p. 1). Because the ac

cident occurred on the third day of the trip sequence, it does not appear to the committee that the commutes the pilots experienced prior to the start of the trip sequence contributed to their fatigue on the accident flight. The NTSB determined “that the probable cause of the accident was the pilots’ failure to follow established procedures and properly conduct a non

precision instrument approach at night in instrument meteorological condi

tions, including their descent below the minimum descent altitude (MDA) before required visual cues were available (which continued unmoderated until the airplane struck the trees) and their failure to adhere to the estab

lished division of duties between the flying and nonflying (monitoring) pilot. Contributing to the accident were the pilots’ failure to make standard callouts and the current Federal Aviation Regulations that allow pilots to descend below the MDA into a region in which safe obstacle clearance is not assured based upon seeing only the airport approach lights. The pilots’ failure to establish and maintain a professional demeanor during the flight and their fatigue likely contributed to their degraded performance” (Na

tional Transportation Safety Board, 2006, p. 58).

Shuttle America

The NTSB describes the flight history of a February 18, 2007, run

way overrun and subsequent collision: “Delta Connection flight 6448, an Embraer ERJ-170, . . . operated by Shuttle America, Inc., was landing on runway 28 at Cleveland Hopkins International Airport (CLE), Cleveland, Ohio, during snow conditions when it overran the end of the runway, con

tacted an instrument landing system (ILS) antenna, and struck an airport perimeter fence. The airplane’s nose gear collapsed during the overrun. Of the 2 flight crew members, 2 flight attendants, and 71 passengers on board, 3 passengers received minor injuries” (National Transportation Safety Board, 2008b, p. 1). During the first two flights of the accident trip sequence, the cap

tain flew with a different first officer than the accident first officer. The captain had been on vacation for 7 days prior to the accident and “was not originally scheduled to work on the day of the accident (he was scheduled

### 60 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### to continue his vacation through the following days), but he had called crew scheduling on the night of February 17, 2007, to request a trip. He was offered and then accepted a 2-day trip assignment” (p. 9). The NTSB report goes on to describe the commuting and flight sched

ule of the captain: “On the day of the accident, the captain traveled as anonrevenue passenger on a flight from Louisville International AirportStandiford Field (SDF) Louisville, Kentucky, to ATL [Atlanta International Airport, Atlanta, Georgia] to report for a scheduled 2-day trip. The cap

tain was scheduled to report to SDF at 0525, and the flight to ATL had ascheduled arrival time of 0733. The first flight leg, from ATL to SarasotaBradenton International Airport (SRQ), Sarasota, Florida, was delayed because of weather. The flight departed ATL at 0914 and arrived at SRQ at 1042. The second flight leg departed SQR at 1108 and arrived at ATL at 1242. The third flight leg, the accident flight, departed on time (with a dif

ferent first officer) from ATL at 1305 and had an expected arrival time at CLE of 1451” (p. 1). In the accident investigation, “the captain reported that he was unable to sleep later that night [February 17], stating that he received 45 minutes to 1 hour of sleep. He went to bed at 2000 but did not fall asleep until 0000 on February 18 and then awoke at 0100. He tossed in bed until about 0200, at which time he decided to get up and prepare for the 0525 report time in SDF [to travel to ATL]” (p. 9). The report documents additional concerning facts regarding the cap

tain: “At the time of the accident, the captain had been on duty for 9 hours 40 minutes with a total flight time of 5 hours 2 minutes. Also, the captain had been awake for all but about 1 hour of the previous 32 hours; he stated that his lack of sleep affected his ability to concentrate and process information to make decisions” (pp. 9-10). “The captain also reported that he had insomnia, which began 9 months to 1 year before the accident and lasted for several days at a time, and a 10-year chronic cough” (p. 10). “In addition, the captain reported that, for breakfast on the day of the ac

cident, he ate graham crackers and drank orange juice while traveling as a nonrevenue passenger and then drank coffee and ate peanuts and chips later on. The captain stated that he was planning to eat lunch in ATL before the accident flight leg but was unable to do so because of the delays from the earlier flight legs and the change in first officers” (p. 10). The captain’s prior attendance record fear of corrective action may have also contributed to accident: “On January 16, 2007 (about 1 month before the accident), the Shuttle America assistant chief pilot notified the captain, in writing, that his attendance had reached an unacceptable level—nine absence occurrences (seven sick and two unavailable attendance marks) totaling 18 days within the previous 12 months—and that future occur

rences would result in corrective action, which could include terminationAVIATION SAFETY AND PILOT COMMUTING 

### 61

from the company. (According to the company’s policy, eight absence occur

rences would result in termination.) The captain had not received previous notification from Shuttle America about his attendance. The captain stated that, even though he was tired on the day of the accident, he did not cancel his trip because he thought that could result in his termination” (p. 11). For this accident, it appears to the committee that fatigue likely resulted from a combination of the captain’s inability to sleep the night before the accident flight, the commute from Louisville to Atlanta, and the flight de

lays that reduced the captain’s time between flights and extended his time awake. While the commute appears to have contributed to the fatigue, the committee notes that even without the time spent commuting, the pilot would have still had a period of more than 24 hours in which he only had about an hour’s sleep. The NTSB determined “that the probable cause of this accident was the failure of the flight crew to execute a missed approach when visual cues for the runway were not distinct and identifiable. Contributing to the accident were (1) the crew’s decision to descend to the instrument landing system decision height instead of the localizer (glideslope out) minimum descent altitude; (2) the first officer’s long landing on a short contaminated runway and the crew’s failure to use reverse thrust and braking to their maximum effectiveness; (3) the captain’s fatigue, which affected his ability to ef

fectively plan for and monitor the approach and landing; and (4) Shuttle America’s failure to administer an attendance policy that permitted flight crew members to call in as fatigued without fear of reprisals” (National Transportation Safety Board, 2008b, p. 67).

Pinnacle Airlines

The NTSB describes the flight history of an April 12, 2007, aircraft ac

cident: “A Bombardier/Canadair Regional Jet (CRJ) CL600-2B19, . . . oper

ated as Pinnacle Airlines flight 4712, ran off the departure end of runway 28 after landing at Cherry Capital Airport (TVC), Traverse City, Michigan. There were no injuries among the 49 passengers (including 3 lap-held in

fants) and 3 crew members, and the aircraft was substantially damaged” (National Transportation Safety Board, 2008a, p. 1). The NTSB reports that the accident occurred on the flight crew’s first day of a 4-day scheduled trip; the accident flight was the fifth and final flight segment for the day. The captain’s home was near Pensacola, Florida, and he commuted to his base at Memphis International Airport (MEM, Memphis, Tennessee). The pilot commuted to Memphis on April 10 andconducted training on a flight to Minneapolis-St. Paul International (WoldChamberlain) Airport (MSP). The captain spent the night before the acci

dent at a hotel in Minneapolis-St. Paul, arriving at the hotel at 2200. The

### 62 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### captain stated that he had slept soundly the night before the day of the accident flight. Thus, it does not appear to the committee that the commute was a major contributor to the captain’s fatigue during the accident flight. The NTSB determined “that the probable cause of this accident was the pilots’ decision to land at Cherry Capital Airport (TVC), Traverse City, Michigan without performing a landing distance assessment, which was required by company policy because of runway contamination initially reported by TVC ground operations personnel and continuing reports of deteriorating weather and runway conditions during the approach. This poor decision making likely reflected the effects of fatigue produced by a long, demanding duty day and, for the captain, the duties associated with check airman functions. Contributing to the accident were (1) the Federal Aviation Administration pilot flight and duty-time regulations that per

mitted the pilots’ long, demanding duty day and (2) the TVC operations supervisor’s use of ambiguous and unspecific radio phraseology in provid

ing runway braking information” (National Transportation Safety Board, 2008a, p. 55).

Empire Airlines

The NTSB describes the flight history of an January 27, 2009, aircraft accident: “An Avions de Transport Régional (ATR) Aerospatiale Alenia ATR 42-320 (ATR 42), . . . operating as Empire Airlines flight 8284, was on an instrument approach when it crashed short of the runway at Lubbock Preston Smith International Airport (LBB), Lubbock, Texas. The captain sustained serious injuries, and the first officer sustained minor injuries. The airplane was substantially damaged. The airplane was registered to FedEx Corporation (FedEx) and operated by Empire Airlines, Inc., as a 14 Code of Federal Regulations (CFR) Part 121 supplemental cargo flight. The flight departed from Fort Worth Alliance Airport (AFW), Fort Worth, Texas, about 0313” (National Transportation Safety Board, 2011, p. 1). The captain commuted from his home in Portland, Oregon, to Midland International Airport (MAF), in Midland, Texas, on January 24, 2 days before the start of the trip sequence that culminated in the accident. The first officer commuted from her home in Salt Lake City, Utah, to MAF on January 18, 8 days before the start of the trip sequence that culminated in the accident. The first officer flew a trip sequence ending January 23, and she spent the weekend in Midland, Texas (off duty for over 72 hours prior to beginning the accident flight). Thus, it does not appear to the committee that either pilot’s commute from their home to their domicile contributed to their fatigue at the time of the accident. The NTSB determined “that the probable cause of this accident was the flight crew’s failure to monitor and maintain a minimum safe airspeedAVIATION SAFETY AND PILOT COMMUTING 

### 63

while executing an instrument approach in icing conditions, which resulted in an aerodynamic stall at low altitude. Contributing to the accident were (1) the flight crew’s failure to follow published standard operating proce

dures in response to a flap anomaly, (2) the captain’s decision to continue with the unstabilized approach, (3) the flight crew’s poor crew resource management, and (4) fatigue due to the time of day in which the accident occurred and a cumulative sleep debt, which likely impaired the captain’s performance” (National Transportation Safety Board, 2011, p. 83).

World Airways

The FAA’s ASIAS Brief Report, based on information from the NTSB Aviation Accident/Incident Database, provides the following flight history on a May 6, 2009, abnormal runway contact that resulted in significant damage to the aircraft: “A Boeing DC-10-30, operated by World Airways as flight 8535, experienced a hard landing on runway 10 at Baltimore/ Washington-Thurgood Marshall International Airport, Baltimore, [Mary

land] (BWI). . . . The captain, flight engineer and 9 flight attendants re

ported minor injuries” (National Transportation Safety Board, 2009, p. 5). The report indicates that the captain had been on a multiday trip sequence prior to the accident flight that included flights as captain and as a passenger. On May 3 (3 days prior to the accident), while piloting a flight from the Philippines, the captain reported feeling ill, probably from food poisoning. During the accident flight, the captain reported digestive system discomfort. The report does not contain any information on pilot’s commute prior the start of his flight sequence on April 27, but because the captain was at the end of a multiday trip sequence, it does not appear to the committee that commuting prior to the beginning of the trip sequence contributed to the pilot’s fatigue. The NTSB determined that the probable cause of this accident was “the captain’s inappropriate control inputs following a firm landing, resulting in two hard nose-gear impacts before executing a go-around. Contributing to the inappropriate control inputs was the captain’s fatigue and physical discomfort; and a possible lack of practical consolidation of skills and experience due to a protracted and fragmented training period” (National Transportation Safety Board, 2009, p. 7).

Conclusion

Of the nine accidents examined by the committee during the 1982 through 2010 period and for which NTSB concluded that fatigue was ei

ther a probable cause or contributing factor, there was only one in which it appeared that commuting might have contributed to the fatigue on the

### 64 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### accident flight. In that accident, the February 18, 2007, Shuttle America runway overrun, it appeared to the committee that fatigue likely resulted from a combination of the captain’s inability to sleep the night before the accident flight, followed by the commute as a nonrevenue passenger from Louisville to Atlanta, in turn followed by the flight delays during the duty cycle that extended the captain’s time awake.

CURRENT PILOT COMMUTING PATTERNS

The committee was charged to “review the available information re

lated to the prevalence and characteristics of commuting.” Unfortunately, the committee was not able to find any systematic or comprehensive data on the frequency of pilot commuting, the lengths of pilot commutes, or the characteristics of their commutes, such as the modes used of commuting by pilots. 10 

### In the absence of such information, one approach would have been to conduct a survey to acquire systematic reliable data about the prevalence and characteristics of pilots and their commutes. However, developing, test

ing, implementing, and analyzing a pilot survey to acquire such data would have required time and resources that were not available to the committee. In the absence of systematic data about actual pilot commutes and in order to gain some insight into likely commuting patterns, the committee requested information about the locations of pilot homes (residences) and domiciles from all Part 121 airlines, using a list of airlines provided by the FAA. Specifically, airlines were asked to provide the zip code of each pi

lot’s home of record (i.e., those designated by the pilots on IRS forms and for the receipt of official notices from the airlines) and the domicile from which that pilot begins his or her duty cycle. The committee received thisinformation for 30,171 pilots. The committee then calculated the straightline distance from the center of the home zip code to the center of the domicile zip code for each pilot. The straight line distances between zip codes are referred to as “home-to-domicile distances” for convenience, but
these calculated home-to-domicile distances have several limitations and are only suggestive of pilot commuting patterns for several reasons. First, the pilots’ home zip codes were for their homes of record. Some pilots may have multiple homes, including seasonal residences, and may not always start their commutes from their homes of record. Second, some pilots may arrange for temporary accommodations at or near their domiciles (or at an intermediate location for a multistop commute) and sleep there the night

10 The only published information appears to be data included in the NTSB report that followed the Colgan Air crash, which reported that 68 percent of the Colgan pilots based at Newark were commuting, with the commutes being various distances (National Transporta

tion Safety Board, 2010, pp. 47-48).AVIATION SAFETY AND PILOT COMMUTING 

### 65

prior to the start of their duty cycles. Third, commutes may be circuitous, particularly those involving multiple connecting flights, so that the actual distances traveled are likely to be longer and may be much longer than the calculated home-to-domicile distances. Fourth, these data are for a single point in time and provide no insight into how commuting patterns might change in response to a pilot’s career progression or changes in the patterns of airline operations resulting from mergers, bankruptcies, or changing economic or competitive conditions (see Chapter 2). Finally, the committee does not know the extent to which this sample of pilots is representative of the larger pilot population. Notwithstanding these limitations and recognizing that the data werenot provided by all airlines, the committee believes that the home-todomicile distance patterns described below provide some insight into pilot commuting patterns found in each of four segments of the industry: Main

line airlines were defined as those that predominately operate scheduled passenger operations in jet aircraft with more than 90 seats (under Part 121 rules). Zip code data were provided by four airlines for 17,519 pilots in this segment. Regional airlines were defined as those that predominately oper

ate scheduled service in aircraft, both jet and turboprop, with 90 or fewer seats (under Part 121 rules). Zip code data were provided by 11 airlines for 7,533 pilots in this segment. Cargo airlines defined as those that conduct scheduled or nonscheduled cargo operations (under Part 121 supplemental rules). Zip code data were provided by four airlines for 4,488 pilots in this segment. Charter airlines were defined as those that conduct nonscheduled passenger operations (under Part 121 supplemental rules). Zip code data were provided by five airlines for 631 pilots in this segment. To preserve the confidentiality of the pilots, the individual airlines that provided the data were not identified. Not identifying the airlines prevented the committee from examining any relationships between the characteristics and policies of an individual airline and the patterns of home-to-domicile distances for that airline’s pilots and thus may limit the lessons that can be drawn from these data. However, the airlines were categorized by the four industry segments—mainline, regional, cargo, and charter. Table 3-3 summarizes the home-to-domicile patterns by industry seg

ment. When viewing Table 3-3 and the following figure and tables in this section, it’s important to keep in mind that a pilot making a short commute may or may not arrive rested and fit for duty depending on what that pilot’s activities were prior or during the commute. For example, if the pilot did not sleep well the night prior to reporting for duty or was involved in tiring physical activity earlier in the day, or even was awake since early morning before leaving home to commute to the domicile, the pilot might be fatigued even if the commute was very short. Similarly, a long commute does not necessarily mean that the pilot reported for duty fatigued. The pilot may

### 66 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### have made the commute the day prior to reporting for duty and may have had a full night’s sleep in a hotel following the commute, prior to report

ing for duty. The first column of Table 3-3 shows the percentage of pilots in each of the four industry segments whose home-to-domicile distance is less than 30 miles. This distance is admittedly arbitrary but is intended to represent a relative short commute similar to that experienced by much of the nonpilot workforce. The second column shows the percentage of pilots in each industry segment whose home-to-domicile distance is between 31and 90 miles while the third column shows the percentage whose home-todomicile distance is between 91 and 150 miles. These columns represent longer home-to-domicile distances but still ones where a commute is likely to be made by surface transport. By adding the numbers in the first three columns, one can see the percentage of pilots whose home-to-domicile dis

tance is less than or equal to 150 miles. For mainline pilots, this sum is 49 percent; for regional pilots, this sum is 50 percent; for cargo pilots, this sum is 42 percent; and for charter pilots, this sum is also 42 percent. The fourth, fifth, and sixth columns in Table 3-3 show the percentages of pilots whose home-to-domicile distances are, respectively, between 750 and 1,500 miles, 1,501 and 2,250 miles, and greater than 2,250 miles. These columns represent home-to-domicile distances where one might ex

pect pilots to commute by air transport. To provide some perspective of these distances, the straight-line distance between Dallas and Indianapolis is about 768 miles, the straight-line distance between Salt Lake City and Detroit is 1,487 miles, and the straight-line distance between San Diego and Miami is 2,265 miles. Again, by adding these three columns, one can see that 22 percent of both mainline pilots and regional pilots have home-to-domicile distances of greater than 750 miles while 26 percent ofcargo pilots and 30 percent of charter pilots have these longer home-todomicile distances. TABLE 3-3 Distribution of Home-to-Domicile Distances by Industry Segment (in percentage)

Operation Less Than

30 Miles 31-90
Miles 91-150
Miles 750-1,500
Miles 1,501-2,250
Miles Greater
Than
2,250
Miles

Mainline 31 14 4 16 4 2 Regional 37 9 4 16 5 1 Cargo 37 4 1 17 7 2
Charter 29 9 4 27 2 1

SOURCE: Data from stakeholders’ input to committee.AVIATION SAFETY AND PILOT COMMUTING 

### 67

Looking more broadly at the data in Table 3-3, several things stand out. First, the distributions appear to be very similar for mainline and regional pilots even though these two segments of the industry differ in many respects. Second, the distributions for the cargo and charter segments of the industry are different from both each other and from the scheduled passenger segments. Given their differences in operating and basing poli

cies (see Chapter 2), this is not surprising. Finally, looking at the right-most column, it appears that the proportion of pilots who have extremely long
home-to-domicile commutes—coast to coast or international—is in about 1-2 percent across these four industry segments. Figure 3-4 shows the distributions of home-to-domicile distances for mainline and regional pilots. The similarity of these distributions seen in Table 3-3 is even more apparent when the entire distributions are examined. So in spite of differences in average age, pay, average flight length, and in

dustry structure, it appears that the home-to-domicile commuting patterns of mainline and regional pilots are very similar.
Table 3-4 shows the distribution of home-to-domicile distances for mainline pilots by airline. (The total sample line is the same as the line for the mainline airlines in Table 3-3.) The four mainline airlines that provided data included both large, well-established airlines and smaller, more re

cently established airlines. As can be seen in the table, the top two airlines, both large established carriers, have similar distributions, while the bottom



## Figure 3-4.eps bitmapPercentage

Mile s



### FIGURE 3-4 Distribution of home-to-domicile distances for mainline and regional pilots.

SOURCE: Data from stakeholders’ input to committee.

### 68 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### two, both smaller, more recently established airlines, are different both from the two larger airlines and from each other.
Table 3-5 shows the distribution of home-to-domicile distances for re

gional pilots by airline. The 11 regional airlines that provided data included airlines of varying size and operating in different regions of the country. The data show that there is variation in home-to-domicile patterns across the air

lines. One might infer that differences in various characteristics of the airlines are associated with different home-to-domicile patterns. TABLE 3-4 Distribution of Home-to-Domicile Distances for Mainline Pilots by Airline (in percentage)

Mainline

Airlines Less Than

30 Miles 31-90
Miles 91-150
Miles 750-1,500
Miles 1,501-2,250
Miles Greater Than 2,250

Miles

A 33 12 5 15 3 1 J 34 18 3 18 4 3

N 18 17 4 20 6 3

W 8 6 3 13 23 19 Total Sample 17,519 Pilots 31 14 4 16 4 2

NOTE: For all home-to domicile distance tables the de-identified airlines have coded alphabeti

cally based on the order in which the input was received. SOURCE: Data from stakeholders’ input to committee.



### TABLE 3-5 Distribution of Home-to-Domicile Distances for Regional Pilots by Airline (in percentage)

Regional

Airlines Less Than

30 Miles 31-90
Miles 91-150
Miles 750-1,500
Miles 1,501-2,250
Miles Greater Than 2,250

Miles

C 24 6 4 25 7 2

D 27 4 1 27 3 0

E 47 12 3 6 3 1

F 34 6 13 15 2 2

H 42 12 4 6 3 1

K 22 12 3 18 10 0

O 34 9 4 22 6 1

R 40 6 5 12 4 1

T 100 0 0 0 0 0

U 80 11 0 3 0 2

X 11 16 10 25 5 7 Total Sample 7,533 Pilots 37 9 4 16 5 1

SOURCE: Data from stakeholders’ input to committee.AVIATION SAFETY AND PILOT COMMUTING 

### 69

Table 3-6 shows the distribution of home-to-domicile distances for cargo pilots by airline. The four cargo airlines that provided data included airlines of varying size and operating patterns. The data show that there is variation in home-to-domicile patterns across the airlines. One might infer
that differences in various characteristics of the airline are to be associated with different home-to-domicile patterns.
Table 3-7 shows the distribution of home-to-domicile distances for charter pilots by airline. The five charter airlines that provided data in

cluded airlines of varying size and operating patterns. The data show that there is variation in home-to-domicile patterns across the airlines. One might infer from the table that differences in various characteristics of the airline are to be associated with different home-to-domicile patterns. Although the data the committee received are neither a complete ac

counting nor a randomly drawn sample, the committee believes that they TABLE 3-6 Distribution of Home-to-Domicile Distances for Cargo Pilots by Airline (in percentage)

Cargo
Airlines Less Than

30 Miles 31-90
Miles 91-150
Miles 750-1,500
Miles 1,501-2,250
Miles Greater Than 2,250

Miles

B 36 3 1 17 8 3

M 87 13 0 0 0 0

P 81 7 2 3 0 0

S 90 0 3 0 0 3 Total Sample 4,488 Pilots 37 4 1 17 7 2

SOURCE: Data from stakeholders’ input to committee.



### TABLE 3-7 Distribution of Home-to-Domicile Distances for Charter Pilots by Airline (in percentage)

Charter

Airlines Less Than

30 Miles 31-90
Miles 91-150
Miles 750-1,500
Miles 1,501-2,250
Miles Greater Than 2,250

Miles

G 59 24 6 6 0 0

I 4 0 4 46 3 2

L 20 8 10 32 0 0 Q 67 25 3 2 0 0

V 57 7 1 8 3 0 Total Sample

631 Pilots 29 9 4 27 2 1

SOURCE: Data from stakeholders’ input to committee.

### 70 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### provide useful information and some insight into the home-to-domicile patterns of pilots in the Part 121 portion of the industry. The home-to-domicile patterns of the mainline and regional airlines appear, in aggregate, to be very similar even though these segments of the industry have markedly different operations and industry structure. Inall four segments of the industry, however, a breakdown of the home-todomicile distances by airline suggests that there is considerable variation across individual airlines. Policies directed at addressing concerns about the potential impact of commuting on pilot fatigue should recognize this heterogeneity in the industry.

Time Zone Considerations

The implications of crossing one or more time zones for potential fa

tigue during duty are complex as such crossings involve the time of day of flight, the direction of travel (whether traveling east to west where time is “gained” or west to east where it is “lost”) as well as the standard consid

erations related to characteristics of the commute. For example, the impli

cations of crossing multiple time zones would be lessened if the pilot was able to plan and implement a commute that enabled him or her to obtain adequate sleep prior to duty (e.g., by arriving the night before). In addition, crossing time zones in and of itself, particularly a single time zone, is not an indicator of potential fatigue as the distance traveled can be quite short or very far. Recognizing these caveats, the committee analyzed the available zip code data to obtain additional descriptive information related to pilot residences and domiciles specific to time zones. The majority of pilots (73.5 percent) reported a residence in the same time zone as their domicile. A significant additional percentage (18.8 per

cent) reported a residence one time zone away from their domicile, with much smaller percentages travelling two time zones (5 percent), three time zones (2.3 percent), or four or more time zones (.4 percent) time zones. A similar pattern emerges by type of carrier, particularly when comparing mainline and regional airlines: see Figure 3-5. However, proportionally fewer pilots who work for cargo and charter airlines report residences and domiciles in the same time zone and more report distances that cross one

or two time zones. When looking at time zones in combination with distance, the scenario is more complex. The distance between home and domicile for pilots in the same time zone ranged from less than a mile to 1,288 miles; for pilots who cross a single time zone, the distance ranged from 14 to 2,439 miles. In other words, there are long commutes that stay in a single time zone and short commutes that cross into a different time zone. Similarly, a relatively small percentage of pilots (11.1 percent) who travel across a time zoneAVIATION SAFETY AND PILOT COMMUTING 

### 71

travel a greater distance than the pilots who have a residence and domicile in the same time zone and some pilots who crossed three time zones re

ported a shorter distance between domicile and residence than pilots who crossed only one or two time zones. The greatest distances travelled obvi

ously involve travel across multiple time zones. The shortest distance for pilots travelling across two, three, or four or more time zones, respectively, are 1,004, 1,656, and 2,890 miles. Table 3-8 shows detailed data for all pilots as well as by carrier type.
There is little conclusive that can be said about the number of time zones crossed given wide variation in distances travelled and lack of infor

mation about how the commute is actually conducted. It is possible that pilots who commute across multiple time zones are fatigued when they arrive for work. It is also possible that these pilots fly to their domicile the night before they are expected to report for duty and obtain adequate sleep prior to duty. Without information about actual commuting practices, these data serve merely a descriptive purpose and should not be used to make any conclusions about the likelihood of fatigue as a result of the corresponding

commute.

Additional Considerations

The committee also reviewed data from NASA’s Aviation Safety Re

porting System (ASRS). ASRS collects, processes, and analyzes voluntarily submitted aviation safety incident reports of unsafe occurrences and haz

ardous situations from pilots, air traffic controllers, dispatchers, flight 

## Figure 3-5.eps 0 20 40 60 80 100

MainlinePercentage



## Regional Cargo Char ter 0

1

2

3

4+

FIGURE 3-5 Share of pilots with home-to-domicile time zone differences.

SOURCE: Data from stakeholders’ input to committee.

### 72TABLE 3-8Distance Between Residence and Domicile by Time Zone and Carrier (by percentage within time zone)MILESNo Time ZonesOne Time ZoneALLMLReg’lCargoChart.ALLMLReg’lCargoChart.0-6055.852.158.867.858.90.10.10.160-1207.38.66.12.89.40.71.10.9120-1803.84.04.31.83.11.61.73.20.1180-2405.86.54.94.34.22.12.14.40.10.5240-3003.43.63.12.14.54.35.95.30.53.0300-3602.21.82.63.23.44.42.84.18.3360-4203.43.43.14.00.83.02.60.96.00.5420-4803.02.63.44.71.32.93.82.22.6480-5402.62.62.82.23.14.04.43.24.03.0540-6002.12.12.01.84.75.43.55.28.48.1600-6601.81.81.42.12.95.74.34.29.47.6660-7200.90.70.81.81.08.58.210.07.58.6720-7801.11.30.80.30.310.412.610.07.26.1780-8400.60.60.90.30.55.44.55.76.95.1840-9000.91.10.80.20.38.57.56.812.44.0900-9601.82.12.00.15.34.27.04.116.7960-1,0201.41.80.80.30.55.77.06.52.09.61,020-1,0801.41.90.9a0.83.32.93.92.49.61,080-1,1400.60.80.43.13.13.02.66.61,140-1,2000.10.2a2.01.61.92.27.11,200-1,2600.10.1a0.32.71.33.44.71.51,260-1,320a2.01.82.22.21.01,320-1,3801.32.00.90.31.51,380-1,4404.57.43.41.21,440-1,5001.01.10.81.41,500-1,5600.81.00.21.11,560-1,6200.71.00.20.51,620-1,6800.10.20.10.11,680-1,7400.10.11,740-1,800a1,800-1,8601,860-1,9200.11,920-1,9800.1a0.31,980-2,0400.20.72,040-2,1002,100-2,1600.12,160-2,2200.12,220-2,2802,280-2,3400.10.22,340-8,400b0.10.10.3

### 73TABLE 3-8Distance Between Residence and Domicile by Time Zone and Carrier (by percentage within time zone)MILESNo Time ZonesOne Time ZoneALLMLReg’lCargoChart.ALLMLReg’lCargoChart.0-6055.852.158.867.858.90.10.10.160-1207.38.66.12.89.40.71.10.9120-1803.84.04.31.83.11.61.73.20.1180-2405.86.54.94.34.22.12.14.40.10.5240-3003.43.63.12.14.54.35.95.30.53.0300-3602.21.82.63.23.44.42.84.18.3360-4203.43.43.14.00.83.02.60.96.00.5420-4803.02.63.44.71.32.93.82.22.6480-5402.62.62.82.23.14.04.43.24.03.0540-6002.12.12.01.84.75.43.55.28.48.1600-6601.81.81.42.12.95.74.34.29.47.6660-7200.90.70.81.81.08.58.210.07.58.6720-7801.11.30.80.30.310.412.610.07.26.1780-8400.60.60.90.30.55.44.55.76.95.1840-9000.91.10.80.20.38.57.56.812.44.0900-9601.82.12.00.15.34.27.04.116.7960-1,0201.41.80.80.30.55.77.06.52.09.61,020-1,0801.41.90.9a0.83.32.93.92.49.61,080-1,1400.60.80.43.13.13.02.66.61,140-1,2000.10.2a2.01.61.92.27.11,200-1,2600.10.1a0.32.71.33.44.71.51,260-1,320a2.01.82.22.21.01,320-1,3801.32.00.90.31.51,380-1,4404.57.43.41.21,440-1,5001.01.10.81.41,500-1,5600.81.00.21.11,560-1,6200.71.00.20.51,620-1,6800.10.20.10.11,680-1,7400.10.11,740-1,800a1,800-1,8601,860-1,9200.11,920-1,9800.1a0.31,980-2,0400.20.72,040-2,1002,100-2,1600.12,160-2,2200.12,220-2,2802,280-2,3400.10.22,340-8,400b0.10.10.3continued

### 74TABLE 3-8ContinuedMILESTwo Time ZonesThree Time ZonesALLMLReg’lCargoChart.ALLMLReg’lCargoChart.0-6060-120120-180180-240240-300300-360360-420420-480480-540540-600600-660660-720720-780780-840840-900900-960960-1,0200.20.32.31,020-1,0800.516.31,080-1,1401.21.12.22.31,140-1,2003.14.62.20.71,200-1,2604.76.73.00.316.31,260-1,3203.84.15.511.61,320-1,3804.64.67.20.39.31,380-1,4407.27.58.54.311.61,440-1,5004.45.55.00.39.31,500-1,5606.45.16.58.314.01,560-1,62012.413.111.712.37.01,620-1,68013.615.17.719.60.40.40.71,680-1,7406.21.216.76.01.01.20.71,740-1,8005.64.95.28.62.73.91,800-1,8606.95.86.711.01,860-1,9206.62.14.521.66.75.912.21,920-1,9802.13.50.70.78.69.87.516.71,980-2,0401.52.11.75.35.36.816.72,040-2,1000.70.42.06.06.37.52,100-2,1604.36.73.00.73.43.16.12,160-2,2200.50.95.15.17.52,220-2,2800.30.50.34.94.38.82,280-2,3400.30.73.93.56.82,340-8,400b2.83.55.052.051.335.4100.066.7aLess than .05 percent.bThe distance between domicile and residence for all pilots who travelled across four time zones were all in this range.

### 75TABLE 3-8ContinuedMILESTwo Time ZonesThree Time ZonesALLMLReg’lCargoChart.ALLMLReg’lCargoChart.0-6060-120120-180180-240240-300300-360360-420420-480480-540540-600600-660660-720720-780780-840840-900900-960960-1,0200.20.32.31,020-1,0800.516.31,080-1,1401.21.12.22.31,140-1,2003.14.62.20.71,200-1,2604.76.73.00.316.31,260-1,3203.84.15.511.61,320-1,3804.64.67.20.39.31,380-1,4407.27.58.54.311.61,440-1,5004.45.55.00.39.31,500-1,5606.45.16.58.314.01,560-1,62012.413.111.712.37.01,620-1,68013.615.17.719.60.40.40.71,680-1,7406.21.216.76.01.01.20.71,740-1,8005.64.95.28.62.73.91,800-1,8606.95.86.711.01,860-1,9206.62.14.521.66.75.912.21,920-1,9802.13.50.70.78.69.87.516.71,980-2,0401.52.11.75.35.36.816.72,040-2,1000.70.42.06.06.37.52,100-2,1604.36.73.00.73.43.16.12,160-2,2200.50.95.15.17.52,220-2,2800.30.50.34.94.38.82,280-2,3400.30.73.93.56.82,340-8,400b2.83.55.052.051.335.4100.066.7aLess than .05 percent.bThe distance between domicile and residence for all pilots who travelled across four time zones were all in this range.

### 76 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### attendants, maintenance technicians, and others. 11 

### There was limited in

formation available in the reports to determine the degree to which com

muting was a factor in the reported incidents. Also, since these reports are voluntarily submitted, in some cases to gain immunity from punishment, it is not clear the extent to which these reports are representative of the experiences of the entire Part 121 pilot population. The committee did not find that these data were useful in the context of the committee’s charge, and these data are not discussed in the report.

CONCLUSION

CONCLUSION: There is potential for pilots to become fatigued from commuting. However, there is insufficient evidence to determine the extent to which pilot commuting has been a safety risk in part because little is known about specific pilot commuting practices and in part because the safety checks, balances, and redundancies in the aviation system may mitigate the consequences of pilot fatigue.

11 For details, see http://asrs.arc.nasa.gov/overview/summary.html [May 2011].

### 77 

# 4

Sleep, Wakefulness, Circadian Rhythms, and Fatigue

FATIGUE

Prevention of fatigue as a safety risk in commercial aviation operations has focused on effective management of duty and rest scheduling (Dinges et al., 1996). When considered in the context of work safety, fatigue has been broadly defined as a biological drive for recuperative rest (Williamson et al., 2011). Over the past several decades, the scientific knowledge base about the causes of fatigue and its effects on performance has grown significantly.
The Aviation Fatigue Management Symposium: Partnerships for Solutions

, supported by the Federal Aviation Administration (FAA) (2008), included several presentations summarizing the state of the science relevant to fa

tigue in aviation (and other transportation modes). 1 

### Additional work was presented a year later in International Conference on Fatigue Management in Transportation Operations: A Framework for Progress (U.S. Department of Transportation, 2009). It is well established that fatigue has multiple interactive sources. The primary ones that may be relevant to pilots’ commutes include duration of time awake prior to work, duration of time slept prior to work, restfulness of sleep (i.e., sleep continuity) prior to work, and the biological time (i.e., circadian phase) at which sleep and/or commuting occur relative to the start of work. The duration of time at work (i.e., time on task) is a regulated factor for fatigue mitigation.

1 For more information on the Aviation Fatigue Management Symposium: Partnerships for Solutions, see http://www.faa.gov/news/conferences_events/2008_aviation_fatigue/ [June 2011].

### 78 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### In the aviation industry, commutes that involve travel across multiple time zones have the potential to exacerbate the fatigue associated with commuting, as can chronic restriction of sleep for multiple days prior to commuting. It is important to recognize that these fatigue effects can be mitigated to some extent by following good sleep hygiene practices 2 

### in the period between the end of the commute and the time of reporting for duty. Due to a lack of relevant data, it is unknown to what extent good sleep hygiene practices are followed by commuting pilots to ensure they are alert during their postcommute flight and duty periods. 3 

### Extensive scientific evidence exists on the negative effects of fatigue on the performance of many cognitive tasks, including those essential for safely operating a commercial aircraft. The adverse effects of fatigue induced by sleep loss include maintaining wakefulness and alertness; vigilance and se

lective attention; psychomotor and cognitive speed; accuracy of performing a wide range of cognitive tasks; working and executive memory; and higher cognitive functions, such as decision making, detection of safety threats, and problem solving; and communication and mood (Harrison and Horne, 2000; Thomas et al., 2000; Durmer and Dinges, 2005; Philibert, 2005; Banks and Dinges, 2007, 2011; Goel et al., 2009b; Lim and Dinges, 2010). The Institute of Medicine (IOM) defines fatigue as “an unsafe condi

tion that can occur relative to the timing and duration of work and sleep opportunities” (Institute of Medicine, 2009, p. 218). It further states:

In healthy individuals, fatigue is a general term used to describe feelings of tiredness, reduced energy, and the increased effort needed to perform tasks effectively and avoid errors. It occurs as performance demands increase because of work intensity and work duration, but it is also a product of the quantity and quality of sleep and the time of day work occurs.



### Pilot commuting practices and individual day-to-day experiences can be quite variable, depending on many factors. The extent to which pilot com

muting is contributing to fatigue at work—by reducing sleep time, extend

ing wake time prior to duty, or interrupting a habitual nocturnal sleep period—is not known.

2 Good sleep hygiene practices generally refer to those behaviors that effectively control all behavioral and environmental factors that precede sleep and may interfere with sleep, to ensure the sleep is as restful as possible, in order to promote daytime alertness or help treat or avoid certain sleep disorders (see Thorpy, 2011).

3 The committee did not consider the use of sleeping medications by pilots during commutesprior to duty because the FAA has restrictions on pilots’ use of Federal Drug Administrationapproved prescription sleep medications, over-the-counter drugs, and supplements for sleep.SLEEP, WAKEFULNESS, CIRCADIAN RHYTHMS, AND FATIGUE 

### 79

SLEEP AND CIRCADIAN RHYTHMS

A full understanding of the relationship between commuting and pilot fatigue is complicated by the fact that there are inadequate data on the timing, duration, and quality of pilots’ sleep before and during commutes. Quality of sleep encompasses factors that can affect the recuperative value of sleep, immediately prior to and during a commute period, such as noise, light, body posture, sleep surface, and ambient temperature.

Time Awake, Sleep Time, and Circadian Time

Scientific understanding of the interaction of circadian biology and homeostatic sleep need is fundamental to identifying how fatigue can oc

cur relative to commuting. Circadian rhythms are daily (24-hour) rhythms, reflected in microbiology, physiology and behavior, that control the timing of the sleep/wake cycle and influence physical and cognitive performance, activity, food consumption, body temperature, cardiovascular rhythms, muscle tone, and aspects of hormone secretion and immune responses, as well as many other physiological functions. When an individual is acutely sleep-deprived by remaining awake into his or her habitual nocturnal sleep period, elevated homeostatic pressure for sleep due to time awake extend

ing beyond 16 hours develops as the internal circadian clock in the brain is withdrawing the drive for wakefulness (Van Dongen and Dinges, 2005; Institute of Medicine, 2009). Performance deficits not apparent up to 16 hours awake can suddenly become evident as a result of these two interac

tive processes (i.e., increasing sleep pressure and decreasing wake drive). These deficits can be similar to those observed when people are under the
influence of alcohol. 4 

### The quantifications of fatigue-related performance noted above suggest that pilots should not be awake beyond approximately 16 hours at the time a duty period ends, unless there are unexpected reasons for this to occur or adequate system mitigation (discussed in Chapter 3). To the extent that commute time may lengthen a duty day beyond this threshold, such com

mutes should be avoided. The sleep homeostatic drive can produce fatigue during waking per

4 For example, performance on an unpredictable tracking task after being awake more than 17 hours (after 3:00 a.m.) was equivalent to the effects of a 0.05 percent blood alcohol con

centration (Dawson and Reid, 1997). Williamson and Feyer (2000) also reported that after 17-19 hours without sleep (corresponding to 10:30 p.m. and 1:00 a.m.), speed or accuracy on some cognitive tests was equivalent or worse than those found at a 0.05 percent blood alcohol concentration. Depending on the cognitive task measured, 20-25 hours of wakefulness produced performance decrements equivalent to those observed at a blood alcohol concentra

tion of 0.10 percent (Lamond and Dawson, 1999).

### 80 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### formance at work as a result of inadequate sleep duration or poor quality sleep in the day prior to work (e.g., due to environmental disturbances or physical problems within the individual such as illness or a sleep disorder). Whether due to being awake too long prior to work or to sleeping too little prior to work, the elevated pressure for sleep in the human brain results in subjective fatigue and sleepiness, and degradation of attention, work

ing memory, mental speed, and other cognitive performance functions, including higher-order functions involved in decision making (Harrison and Horne, 2000; Killgore et al., 2006; McKenna et al., 2007; Venkatramen et al., 2007). These cognitive changes can result in turn in adverse effects on work performance (Mitler et al., 1988; Dinges, 1995). Fatigue as a risk to individual pilot performance can result from (1) being awake continuously for more than approximately 16 hours, or (2) sleeping too little (especially less than 6 hours on the sleep opportunity prior to work), or (3) when undertaking work at a time when the body is biologically programmed to be asleep (i.e., an individual’s habitual nocturnal sleep period), which for most people is between 10:00 p.m. and 7:00 a.m. (Van Dongen and Dinges, 2005; Basner and Dinges, 2009; Institute of Medicine, 2009). 5 

### Fatigue-related performance deficits from inadequate sleep can vary markedly across a day and night (without sleep). This variation in perfor

mance is due to the fact that sleep and circadian drives in the brain interact nonlinearly in the control of performance and alertness (Dijk et al., 1992; Goel et al., 2011). For example, performance deficits after being awake at night peak between 6:00 and 10:00 a.m. but are less severe by 6:00-10:00 p.m. (12 hours later) (Goel et al., 2011). The detrimental effects of fatigue on performance may be exacerbated by a tendency for individuals to have reduced awareness of their cognitive performance deficits that result, even as these deficits increase in frequency with consecutive days of inadequate sleep (Van Dongen et al., 2003a; Banks et al., 2010). Although the effects of acute sleep deprivation on performance may be transiently influenced by such factors as social and physical activity (Goel et al., 2011), a recent meta-analysis of 70 articles that covered 147 cogni

tive tests of several moderators identified time awake as the most significant predictor of behavior during a period of acute sleep deprivation (Lim and Dinges, 2010). This finding could be especially relevant to those instances in which pilots may obtain little to no sleep within the 24 hours before a flight

5 The period of habitual sleep time at night has also been identified as encompassing the “window of circadian low,” defined as the hours between 2:00 a.m. and 6:00 a.m. for in

dividuals adapted to a usual day-wake/night-sleep schedule. This estimate of the window of circadian low is calculated from extensive scientific data on the circadian low in performance, alertness, subjective fatigue, and body temperature (see Dinges et al., 1996).SLEEP, WAKEFULNESS, CIRCADIAN RHYTHMS, AND FATIGUE 

### 81

and then undertake a lengthy duty day. In such an instance, sleep time is reduced and time awake is increased, and both factors contribute to fatigue. Much is known about the cognitive and functional deficits that result when healthy adult volunteers remain awake for 24-40 hours (Harrison and Horne, 2000; Philibert, 2005; Institute of Medicine, 2006, 2009; Goel et al., 2009b). Scientific understanding of the effects of sleep deprivation on cognitive functions has accumulated for more than a century (for re

views of this extensive literature, see Kleitman, 1963; Dinges and Kribbs, 1991; Harrison and Horne, 2000; Durmer and Dinges, 2005; Institute of Medicine, 2009). The cognitive effects of sleep deprivation are due to changes in the brain. Recent advances in neuroimaging technologies have provided further insights into physiological changes in the brain and underlying performance functions that manifest themselves when fatigue results from reduced sleep (Portas et al., 1998b; Drummond et al., 1999, 2005; Drummond and Brown, 2000; Thomas et al., 2000; Bell-McGinty et al., 2004; Chee and Chieh, 2004; Habeck et al., 2004; Chee et al., 2006, 2008; Chuah et al., 2006; Wu et al., 2006; Lim et al., 2007, 2010; Venkatramen et al., 2007; Institute of Medicine, 2009). It is now recognized that although most adults exposed to a night without sleep experience fatigue-related declines in performance, the timing and severity of the declines vary across individuals, including pilots (Doran et al., 2001; Leproult et al., 2003; Van Dongen et al., 2004; Bliese et al., 2006; Institute of Medicine, 2009). These differences in individual cogni

tive vulnerability to sleep loss may have a basis in biological factors (e.g., normal genetic variation) regulating sleep and circadian rhythms (Goel et al., 2009a, 2010; Institute of Medicine, 2009). People with untreated sleep disorders are also subject to individual vulnerability and may experience negative effects on their performance and safety beyond those experienced by healthy individuals.

Chronic Partial Sleep Deprivation

In addition to acute sleep deprivation, fatigue can be exacerbated by chronic partial sleep loss, also known as cumulative sleep debt, which oc

curs when the sleep obtained over multiple days is too short in duration to maintain behavioral alertness during the daytime (Van Dongen et al., 2003b). There is scientific evidence that chronic sleep restriction results in cumulative performance deficits across days and that the rate of the perfor

mance decline is inversely proportional to the sleep obtained (Dinges et al., 1997; Belenky et al., 2003; Van Dongen et al., 2003a). These conclusions are also supported by data from an experiment in which daily sleep was chronically obtained by supplementing various shortened nocturnal sleep

### 82 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### periods with varying-duration daytime naps (Mollicone et al., 2007). In all of these controlled laboratory studies, measures of behavioral alertness decreased and cognitive performance deficits increased cumulatively across consecutive days, at a rate inversely proportional to the amount of sleep provided each day (for reviews, see Banks and Dinges, 2007, 2011). Performance deficits from chronic sleep restriction can accumulate across days to levels equivalent to those found after even one or two nights without any sleep (Van Dongen et al., 2003a). They are also influenced by the duration of habitual sleep prior to the sleep restriction period (Rupp et al., 2009). Moreover, chronic sleep restriction that is followed by a night of little to no sleep results in severe deficits in cognitive performance (Banks et al., 2010). Recovery of behavioral alertness following chronic sleep loss often requires extended periods of sleep that are 1-3 hours longer than habitual sleep for one or more nights (Belenky et al., 2003; Lamond et al., 2007; Banks et al., 2010). The threshold at which chronic sleep restriction adversely affects behav

ioral alertness and cognitive performance in the majority of healthy adults is when time in bed for sleep is 7 hours or less per 24 hours for a number of consecutive days (Belenky et al., 2003; Van Dongen et al., 2003a; Banks and Dinges, 2007, 2011; Mollicone et al., 2007). Since physiological sleep at night in healthy adults aged 25-65 years averages 90 percent (± 5 percent) of time in bed (Ohayon et al., 2004)—this percentage is often less with in

creasing age and when sleep is taken in the daytime—the duration of actual physiological sleep time during a 7-hour time in bed in a healthy adult can range from 6.0 hours to 6.7 hours of physiological sleep. What people report as their usual sleep duration is almost always anoverestimate. For example, a population-based sample of N = 669 middleaged adults found that subjective reports of habitual sleep were only moder

ately correlated (r = 0.47) with an objective measure of sleep time (i.e., wrist actigraphy), and that there was a systematic over-reporting bias—those who actually slept 5 hours overreported their sleep durations by 1.2 hours (i.e., 6.7 hours), and those sleeping 7 hours overreported by their sleep durations by 0.4 hours (Lauderdale et al., 2008). Although scientific experiments indicate a minimum threshold of 7 hours’ time in bed for sleep is appropriate for at least 80 percent of adults (many of whom will require more than 7 hours in bed to achieve the physi

ological sleep duration necessary to prevent reductions in alertness and cognitive functions), it is unknown whether this threshold should be ap

plied to the estimated 20 percent of adults who report sleeping 6 hours or less per night (Kripke et al., 2002). There is currently no consensus among scientists and public health experts on (1) what proportion of adults are naturally short sleepers (i.e., they require 6 or fewer hours of sleep a night to be alert) and what proportion are simply chronically sleep deprivedSLEEP, WAKEFULNESS, CIRCADIAN RHYTHMS, AND FATIGUE 

### 83

at this level of daily sleep; and (2) the extent to which caffeine and other stimulant foods and supplements—none of which are chemical substitutes for sleep—can prevent deficits in behavioral alertness and cognitive perfor

mance under chronic sleep restriction. Although there are extensive studies on the alertness-promoting effects of caffeine under acute sleep loss condi

tions, there are few studies on its effects under conditions of chronic sleep restriction, when tolerance can develop within a few days (Bonnet et al., 2005). In addition, many people do not consume caffeine, and the many who do so are not aware of the dose they are ingesting or whether tolerance has developed from chronic use. Therefore it is difficult to estimate whether caffeine is being used effectively to prevent the adverse effects of chronic restriction of sleep (below 7 hours of time in bed) on behavioral alertness and cognitive performance. Evidence that cognitive performance is adversely affected when sleep per 24 hours is cumulatively less than 7 hours (time in bed) suggests that pilots should seek to obtain sufficient bed time to ensure they are fit for duty. To the extent that time taken for sleep may be reduced by commuting,
such commutes should be avoided.

Napping

Naps are most easily defined as periods of sleep less than half the duration of a typical nocturnal sleep period (Dinges, 1989; Dinges and Broughton, 1989). They are also most often identified with sleep obtained in locations other than a bed, and sleep when clothing is not removed. Naps are one of the frequently used fatigue countermeasures (caffeine be

ing the other), and there is substantial scientific evidence that nap sleep can help reduce the severity of fatigue during prolonged duty periods of work (Dinges et al., 1987; Institute of Medicine, 2009). Naps have been found to be beneficial for fatigue mitigation in commercial pilots (Rosekind et al., 1994), although some pilots report that some sleep obtained in sleeping berths on long-haul aircraft—which is most often less than 3.5 hours in duration—often affords less restoration than equivalent-duration sleep in a bed (Rosekind et al., 2000; Roach et al., 2010). Although nap sleep obtained while sitting has some benefit for reduc

ing fatigue, studies have found that sleeping while sitting upright (with the requirement of at least partial antigravity posture) results in less sleep time and poorer sleep quality than sleeping in a semirecumbent position (Nicholson and Stone, 1987). Sleeping in a semirecumbent position with ambient noise results in more light sleep and less deep sleep than sleep

ing supine without noise (Dinges et al., 1981). Since pilot commuting can involve sleep opportunities while seated or semirecumbent (e.g., in a car, bus, or plane during a commute), the recovery potential of such sleep may

### 84 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### be of less value than an equivalent period of sleep in a bed. These findings make it difficult to estimate the value of naps and longer sleeps obtained by pilots during commutes to work. Body posture and ambient noise level, as well as physical comfort, are not the only factors that can influence the benefits of nap sleep. Although napping has been shown to be an effective technique for restoring alertness and performance during periods of continued wakefulness, it is the timing and length of a nap, along with the timing of the nap in the 24-hour pe

riod (i.e., when it occurs relative to circadian phase), that also moderates the benefits of napping for performance (Dinges et al., 1987; Webb, 1987; Rogers et al., 1989; Bonnet, 1991; Rosa, 1993; Matsumoto and Harada, 1994; Vgontzas et al., 2007; Caldwell et al., 2009). Naps taken following a prolonged period of wakefulness or during the habitual sleep period (and in the window of circadian low) can be associated with more severe and prolonged sleep inertia, which is a period of grogginess and performance deficits immediately after awakening (Jewett et al., 1999b; Tassi and Muzet, 2000). After the sleep inertia dissipates—in 20 minutes to 2 hours, depend

ing on the degree of prenap sleep deprivation and the timing of the nap— the fatigue-reducing benefits of the nap occur, but they will dissipate faster than the benefits of a full nocturnal sleep period.

FATIGUE MANAGEMENT TECHNOLOGIES

Recognition of the complex nature of the multiple interacting factors that influence the buildup and reduction of fatigue as a state that can affect performance has been at the core of the development and application of various fatigue management technologies. The science of fatigue manage

ment has developed rapidly over the past decade in civilian transporta

tion sectors, with much of the applied research sponsored originally by the military, where sustained and continuous operations pose acute and chronic fatigue-related challenges. There are now several well-documented candidate technologies for managing fatigue and its negative effects on performance. These fall into two broad categories: fatigue-detection tech

nologies and mathematical models of fatigue risk. Substantial progress has
been made in each of these areas. Development of technologies in the first category—fatigue-detection technologies for management of the fatigue risk—has been of interest to transportation modalities in particular for the past 10-15 years, especially in motor vehicle operations (Balkin et al., 2011). These technologies include development of relatively unobtrusive ways to determine an operator’s level of alertness or performance during duty, as well as devices that predict fa

tigue in advance of a work cycle or trip (Balkin et al., 2004, 2011; Basner and Dinges, 2011). A recent review of fatigue-detection technologies orga

-SLEEP, WAKEFULNESS, CIRCADIAN RHYTHMS, AND FATIGUE 

### 85

nized them into four categories (Balkin et al., 2011): (1) Fitness-for-duty tests that are designed to assess whether operators have sufficient alert

ness/performance capacity prior to a work cycle or duty period; (2) online operator monitoring technologies that are designed to provide real-time monitoring of an operator’s physiological or behavioral state during work; (3) performance-based monitoring systems that are designed to continuously track operational performance to detect operator conditions/behaviors that can lead to reduced safety; and (4) embedded or secondary-task technologies that are designed to monitor and/or enhance operator performance/alertness by modulating the amount of stimulation provided through a secondary task. Although some of the fatigue-detection technologies have been studied in operational environments and shown promise—especially in combination (e.g., Dinges et al., 2005), there remain important unresolved questions and limitations regarding the validity and reliability of their use relative to actual work performance, and their acceptance by operators and industries (Dinges and Mallis, 1998; Balkin et al., 2011). There is also a need to determine how such technologies could be used most effectively in fatigue management in commercial aviation, especially as it relates to commuting. The second major category of fatigue management technologies con

sists of mathematical models of fatigue or the risk fatigue poses to safety. The models make predictions about the likelihood of fatigue as a risk to performances using information on duty time and scheduling, sleep quan

tity and quality, circadian and time-zone information, and other variables (for reviews see Mallis et al., 2004; Dawson et al., 2011). Over the past decade, a number of federal agencies have supported the continued devel

opment and evaluation of mathematical models of fatigue risk (Jewett et al., 1999a; Neri, 2002). A workshop sponsored by the U.S. Department of Defense, the U.S. Department of Transportation, and the National Aero

nautics and Space Administration provided an opportunity to conduct an initial evaluation and comparison of seven of these mathematical models from the United States, Europe, and Australia (Mallis et al., 2004). Al

though predictions of performance were promising, the evaluation showed that further research was needed to demonstrate the models’ validity and reliability using real-world data, and that the models could not make reli

able predictions of group performance risks from fatigue over multiday schedules (Dinges, 2004; Van Dongen, 2004). In recent years, some of the models have undergone further improvements in the accuracy of their pre

dictions of both the basic dynamics of chronic sleep restriction in relation to fatigue (e.g., McCauley et al., 2009), and in relation to prediction of accidents (e.g., Hursh et al., 2008). The potential for practical application of the mathematical models in the commercial aviation context—and particularly in relation to pilot commuting—has not yet been determined. A recent review of eight of the

### 86 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### mathematical models of fatigue in work settings concluded that although the models are intended to provide quantitative information on the likely average level of fatigue risk associated with a given pattern of work and sleep, there is considerable individual variability attributable to personal biology and task variables not included in current models (Dawson et al., 2011; see also Van Dongen et al., 2004). The review also concluded that given the current limitations of the fatigue models, they may be most useful as one element in a fatigue risk management system (Dawson et al., 2011). Considerable research is needed to address how to use these models, andother knowledge in the design and implementation of staffing and workscheduling programs in order to minimize fatigue (see National Research Council, 2007; Horrey et al., 2011). The issue of fatigue in safety-sensitive work operations cuts across many industries and has been addressed broadly in the scientific literature. The combination of work demands, sleep restriction, and circadian factors can negatively affect alertness, performance, speed, accuracy, and central nervous system functioning (Cabon et al., 1993; Goel et al., 2009b): see Box 4-1. The next chapter looks more closely at the potential for pilots’ commuting patterns to affect their risk of fatigue. **BOX 4-1** Risk Factors for Fatigue-Related Errors and Accidents

Risks of fatigue-related errors and accidents stem from multiple interrelated and interacting aspects of work, rest, and sleep. These include but are not limited

to:

1.	 duration of work periods within a single day and over time,

2.	 time of day at which work occurs,
3. variation in the timing of work within and between weeks,

4.	 duration of sleep obtained on work days and on nonwork days,

5. frequency and duration of days off from work,

6. different vulnerabilities of workers to fatigue from these factors, and

7. volume and intensity of work.

SOURCE: Institute of Medicine (2009, pp. 218-219) citing the works of Dinges (1995), Rosa (2001), Drake et al. (2004), Folkard et al. (2005), and Van Dongen (2006).

### 87 

# 5

Pilot Commuting and Fatigue Risk

In this chapter we relate the scientific evidence presented in Chapter 4 to the manner in which pilot commuting could contribute to these factors and therefore to fatigue as an operational risk. 1 

### We repeat the caution to readers not to assume that the distance pilots live from the airport reflects their likely commute times. As discussed above, there are very little data to evaluate that assumption.

INADEQUATE SLEEP PRIOR TO FLIGHT DUTY

Consistent with the scientific literature from laboratory experiments (reviewed in Chapter 4), field studies of pilots have found that sleep dura

tion in the 24 hours prior to a flight duty period can contribute to pilot fatigue in flight. In a recent report by Thomas and Ferguson (2010), sleep and performance data from captains and first officers were collected by trained expert observers during 302 normal flight operations of a commer

cial airline flying short-haul jet operations that primarily occurred between 6:00 a.m. and 10:00 p.m. Crew members provided estimates of their total sleep in the prior 24 hours, their total sleep in the prior 48 hours, and the total time they were awake since their last sleep period at the commence

1 We did not consider transportation while crews are laying over during long-haul opera

tions, as these typically involve arranged times, hotels for sleep, and conveyances to and from the airport, and they fall within the flight and duty time regulations. We are also not consider

ing in-flight sleep during long-haul operations with augmented crews, as these also fall within the flight and duty time regulations.

### 88 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### ment of cruise (i.e., early in flight). Observers assessed the crew during normal flight operations using the “threat and error management model” (Helmreich, 2000; International Civil Aviation Organization, 2002; Klinect, 2002). In this model, safety was defined as the active process of crews’ effec

tive management of operational threats, which included aspects of normal flight operations that have the potential to negatively affect safety, such as adverse weather or an aircraft system malfunction, and management of the inevitable errors that occur as part of normal human performance. The study found that restricted sleep in both the 24-hour and 48-hour periods prior to each sector was associated with changes in crews’ threat and error management performance. Restriction to less than 6 hours of sleep in the prior 24 hours was associated with degraded operational performance and increased error rates (Thomas and Ferguson, 2010). The authors concluded that their findings support prior sleep as a critical fatigue-related variable. A study of 19 long-haul pilots also found that sleep in the prior 24 hours was a significant predictor of self-rated fatigue and the measured mean response speed of the psychomotor vigilance task after international flight sectors (Petrilli et al., 2006). These investigators concluded that in order to minimize the risk of fatigue, the sleep obtained by pilots should be taken into account in the development of flight and duty time regulations. This provocative suggestion may or may not be considered relative to flight and duty time regulations, but the scientific evidence on how commut

ing may contribute to fatigue because of inadequate sleep and prolonged wakefulness may suggest that there is a shared responsibility for mitigating fatigue between pilots and carriers. Sleep is a physiological phenomenon that is defined by measuring brain waves, eye movements, muscle activity, and other physiological processes. As noted in Chapter 4, in order to acquire 6 hours physiological sleep time, an average healthy adult must spend approximately 7 hours in bed, as physiological sleep occurs for 85-95 percent of time in bed for healthy sleepers. Thus, when it is necessary to obtain at least 6 hours of physi

ological sleep, the time in bed would have to be approximately 7 hours. Moreover, although some people can function at normal levels for a night or two with 6 hours of physiological sleep, repeated days of 6 hours of sleep can result in cumulative fatigue and its attendant cognitive performance deficits in a significant portion of the population (Van Dongen et al., 2003a; Mollicone et al., 2007). Therefore, a requirement of 6 hours of physiologi

cal sleep (i.e., 7 hours of time in bed) prior to duty should be considered a bare minimum for alert functioning, and its adequacy for pilot alertness should be periodically evaluated.PILOT COMMUTING AND FATIGUE RISK 

### 89

EXAMPLES OF “FAVORABLE” AND

“UNFAVORABLE” COMMUTES

In order to illustrate how the various dimensions of a pilot’s commute may be affected by sources of fatigue, the committee presents illustrations of commute patterns for four different combinations of home-to-domicile distances, timing, and circadian shifts. These commute patterns are drawn from the committee’s direct conversations with various stakeholders (in

cluding pilots, airlines, unions, and the FAA), in the course of hearings and testimony, during this study. These examples reflect the norms of the indus

try based on conversations with industry officials, the committee’s experi

ence, and the committee’s analysis of home-to-domicile distances calculated from zip code data (see Chapter 3). These selections may not reflect the true distribution of commutes but were rather chosen to highlight different patterns. These illustrations are accompanied by examples of “favorable” and “unfavorable” commuting patterns based on the findings from sleep science. Four primary sources of fatigue—time awake, sleep time, sleep quality, and circadian phase—are the dependent variables for determining whether a commute is favorable or unfavorable. These examples begin with place of residence for the pilot and end with the completion of the pilot’s first day’s duty assignment. 2 

### The committee had no way to determine how much more risk an unfavorable commute would present as compared to a
favorable one.

Example 1: Home, Portland, Oregon; Domicile, San Francisco International Airport (SFO)

Description: Early morning awakening following short sleep

Factors: Time since awakening, with 13 hours duty

Unfavorable: Example 1a

The pilot, on the evening preceding the assignment, goes to bed ear

lier than usual at 9:00 p.m., but, unaccustomed to the early bedtime, falls asleep at 10:00 p.m. The pilot wakes at 3:00 a.m. at home in Portland after 5 hours of sleep. The pilot departs his home at 3:30 a.m. and arrives at the Portland International Airport (PDX) at 4:00 a.m. The pilot departs PDX at 5:00 a.m. on a 1-hour commuting flight as a passenger to SFO. The pilot reports for duty at 8:00 a.m. for the first assigned flight, which departs at 9:00 a.m. The pilot flies three legs, with the last one landing at

2 All time references refer to the time associated with the pilot’s place of residence (residence time), not time at location of flight legs or aircraft landing.

### 90 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Bradley International Airport (BDL) in Hartford, Connecticut, at 9:00 p.m. (Oregon time). At this time, the pilot has been awake for 18 hours, includ

ing 13 hours of duty, following a short sleep (5 hours). For the graphical representation of this example, see Figure 5-1.

Favorable: Example 1b

The pilot commutes from home to SFO the day before the duty assign

ment begins. The pilot arrives in San Francisco by 9:30 p.m., sleeps at a hotel near the airport, going to sleep by 11:00 p.m. and awakens at 6:30 a.m. (with 7.5 hours of sleep). Following the same pattern above, ending the duty at BDL, the pilot’s time since awakening is 14.5 hours, following a night of 7.5 hours of sleep. For a graphical representation of this example, see Figure 5-2.

Example 2: Home, Alexandria, Virginia; Domicile: John F. Kennedy International Airport (JFK), New York City

Description: Emergent, unplanned circumstance in commute

Factors: Long total awake time without nap, operations during circa

dian low 

## Figure 5-1.eps9:0010:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:00

PM AM PM Rest (6 in bed, 5 sleep)

Commute (2.5)

On Duty (13) Flight Segments (7) T otal Time Aw ak e (18)Activity (hours)



### Time of Da y at Residenc e

FIGURE 5-1 Example 1a: Unfavorable commuting pattern. SOURCE: Based on a submission by a pilot to the Aviation System Reporting Sys

tems (ASRS) database. ASRS collects, processes, and analyzes voluntarily submitted aviation safety incident reports of unsafe occurrences and hazardous situations from pilots, air traffic controllers, dispatchers, flight attendants, maintenance technicians,
and others. For details, see http://asrs.arc.nasa.gov/overview/summary.html [May 2011].PILOT COMMUTING AND FATIGUE RISK 

### 91

Unfavorable: Example 2a

The pilot obtains a full night’s sleep (7 hours) in the evening prior to duty and awakens at his normal time of 6:00 a.m. After spending the morning and early afternoon at home engaged in normal activities, the pilot leaves at 2:00 p.m., arriving at Ronald Reagan Washington National Air

port (DCA) at 2:30 p.m. for a 3:30 p.m. departure to JFK. The flight is late and departs at 4:30 p.m., arriving at JFK at 6:00 p.m. The pilot reports for duty at 7:00 p.m. The pilot begins the single-leg assignment at 8:00 p.m. to Phoenix, Arizona, arriving at 1:00 a.m. (Virginia time). Although the pilot had adequate sleep the night before, the pilot’s time awake by the end of the duty day is 19 hours. Even if the pilot attempted to sleep or nap prior to leaving home for the commute to JFK, the pilot is unlikely to have obtained restful sleep so soon after awakening and during the circadian peak. Moreover, the pilot is waiting for a delayed flight and then taking a short commuting flight during the afternoon circadian low, when a nap attempt may be more suc

cessful. Thus, with the commute occupying the best portion of the preduty period for sleep, although several hours are potentially available for sleep prior to duty, it is quite possible that this pilot will be landing the aircraft in Phoenix fatigued, with the length of time since awakening likely to affect individual performance adversely. For the graphical representation of this example, see Figure 5-3. 

## Figure 5-2.eps7:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:00

PM AM PM Rest (8 in bed, 7.5 sleep) Commute (3.0)

On Duty (13) Flight Segments (7) To tal Time Aw ak e (14.5)Activity (hours)



### Time of Da y at Residence



### FIGURE 5-2 Example 1b: Favorable commuting pattern.

### 92 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Favorable: Example 2b

The pilot leaves home earlier, finds a rest facility, and naps in an envi

ronment conducive to quality rest during this circadian phase for napping, 2:00 p.m. to 5:00 p.m. For the graphical representation of this example, see Figure 5-4. 

## Figure 5-3.eps10:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:00

PM AM PM Rest (8 in bed, 7 sleep) Commute (4 ) On Duty (6 ) Flight Segments (5 ) T otal Time Aw ak e (19)Activity (hours)



### Time of Da y at Residenc e AM



### FIGURE 5-3 Example 2a: Unfavorable commuting pattern. SOURCE: Based on personal testimony from stakeholders at open session meetings.



## Figure 5-4.eps10:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:0010:0011:0012:001:00

PM AM PM Rest (8 in bed, 7 sleep

, 3 nap) Commute (3) On Duty (6) Flight Segments (5) T otal Time Aw ak e (16)Activity (hours)



### Time of Da y at Residenc e AM



### FIGURE 5-4 Example 2b: Favorable commuting pattern.PILOT COMMUTING AND FATIGUE RISK 

### 93

Example 3: Home, Concord, California; Domicile, Charlotte/ Douglas International Airport (CLT), Charlotte, North Carolina

Description: Transcontinental commute, cargo airline

Factors: Nocturnal sleep loss and work during circadian low; unrestful sleep environment; early morning awakening; inadequate sleep in 24 hours prior to end of duty; difficulty of sleeping during circadian high; question

able sleep quantity/quality during night-time commuting flight.

Unfavorable: Example 3a

The pilot leaves home in Concord, California, at 9:00 p.m., arriving at SFO at 10:00 p.m. The pilot departs SFO at 11:00 p.m. to commute to CLT, arriving Charlotte at 4:00 a.m. (California time). The pilot checks in for duty at 5:00 a.m. and begins the duty assignment at 6:00 a.m. for a 3-hour flight to Dallas/Fort Worth International Airport (DFW), arriving at 9:00 a.m. (California time). If the pilot had slept from noon to 8:00 p.m. at home, before depart

ing at 9:00 p.m., the pilot would have obtained adequate sleep. However, by sleeping on the normal pattern, from 11:00 p.m. to 7:00 a.m., and then napping during the afternoon circadian low from 2:00 p.m. to 5:00 p.m. (with actual sleep time 2.5 hours), the amount of time slept within the past 24 hours preceding the projected time of landing in Dallas would be inadequate. The pilot could then consider the sleep that she might obtain during the 5-hour commuting flight from the West Coast to the East Coast. In fa

vor of obtaining restful sleep during this commute, the all-night timing of the flight spans not only the window of circadian low, but also the pilot’s entire habituated sleep period. The duration and quality of sleep actually obtained, though, will depend on factors beyond the immediate control ofthe pilot, such as whether the available accommodation is in a first-class lieflat sleeper seat or in an upright coach seat next to a crying baby. On arrival at CLT, the pilot may well be faced with a decision of whether to advise the airline that of being unfit to operate the assigned flight to DFW due to fatigue. For the graphical representation of this example, see Figure 5-5.

Favorable: Example 3b

The pilot commutes in to Charlotte on the day before the assigned flight, and sleeps near the domicile in a hotel or local accommodation, with plenty of time for a complete sleep period before awakening at 3:30 a.m. (in time to report to the domicile, CLT, for duty at 5:00 a.m., including local travel). Although the possibility of obtaining high-quality sleep is likely bet

-

### 94 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



## Figure 5-5.eps11:0012:001:002:003:004:005:006:007:00...2:003:004:005:006:007:008:009:0010:0011:0012:001:002:003:004:005:006:007:008:009:00

PM AM PM Rest (8 in bed, 7 sleep , 2.5 nap) Commute (7) On Duty (4) Flight Segments (3) T otal Time Aw ak e (23.5)Activity (hours)



### Time of Day at Residence AM



### FIGURE 5-5 Example 3a: Unfavorable commuting pattern. SOURCE: Based on personal testimony from stakeholders at open session meetings.

1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:0010:00 11 :00 12:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00 9:00

PM AM

| | | | | | | | | | | | | | | | | | | | | Rest (7.5 in bed, 6.5 sleep) Commute (7.5)

On Duty (4) Flight Segments (3) T

otal T ime A wake (13.5)Activity (hours)



### T ime of Day at Residence AM



### FIGURE 5-6 Example 3b: Favorable commuting pattern.



### ter in a bed than on the airplane, it is important to note that the very early wake-up call for the West Coast habituated pilot may make it difficult to obtain a full night’s rest due to the interruption of the habitual sleep period. For the graphical representation of this example, see Figure 5-6.

Example 4: Home, Baltimore, Maryland; Domicile: Washington Dulles International Airport (IAD), Chantilly, Virginia

Description: Same 1-day schedule for 3 consecutive days

Factors: Time awake, sleep loss (cumulative), and sleep qualityPILOT COMMUTING AND FATIGUE RISK 

### 95

Unfavorable: Example 4a

A pilot has the same 1-day schedule for 3 consecutive days. On the first night preceding the assignment, the pilot goes to bed at 10:00 p.m. and wakes at 4:00 a.m. for 5 hours of sleep (6 hours in bed). The pilot departs home (her residence in Baltimore) at 5:00 a.m. for the 2-hour commute to her domicile, IAD. The pilot checks in for duty at 7:00 a.m. and begins the first of four flight legs for the day at 8:00 a.m. The pilot concludes the duty day and leaves for the commute home at 8:00 p.m. The pilot repeats this pattern for the next 2 days. However, on the evenings of the first and second days, due to the commute home, the amount of sleep each night decreases by 1 hour to 4 hours (5 hours of time in bed). For the graphical representations of these 1-day and 3-day patterns, see Figures 5-7 and 5-8.

Favorable

Given current scheduling practices, there is no obvious favorable alter

native to the commuting pattern for this flight schedule, and it is therefore reflective of shared responsibility between the pilot and the airline. One possible mitigation of fatigue might be for the pilot to take a nap between the hours of 3:00 p.m. and 4:00 p.m. on each afternoon. The value of the nap would be contingent on sleep quality. However, airlines also might be able to effectively limit the negative effects of fatigue on pilots’ performance by using both their bidding procedures and their trip pairings (including computerized preference bidding systems) to refrain from assigning mul

PM AM | Re st * (6 in bed, 5 sleep ) Commute (2 ) On Duty (13) Flight Segments (4 ) To tal Time Aw ak e (16)Activity (hours)



### Time of Da y at R esidenc e PM10:0012:0011:001:009:008:007:006:005:004:003:002:00 | | | | | | | | | | | | | | | | | | | | |10:0012:0011:001:008:007:006:005:004:003:002:00



### FIGURE 5-7 Example 4a: Unfavorable commuting pattern—day 1 of 3 consecutive days. On second and third days, rest time reduced by 1 hour.
SOURCE: Based on communication with FAA officials.

### 96 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### tiday trip assignments like this one to pilots who are commuting to their domicile, even if the commute is a driving commute of less than 2 hours.

Discussion

Commute time cannot be viewed singularly without considering such factors as the time of the start of the duty day, the length of the duty day, and what the pilot was doing that would add to the overall time awake at the end of the duty day. The end result is a product of the interaction of those factors. Pilots need to consider these several factors when thinking about commuting in a way to minimize fatigue. What is noteworthy about all of these examples is that the favorable commutes all cut into the pilot’s time at home; it appears there is often a tradeoff between time at home and beginning the duty cycle adequately rested.

RECOMMENDATION

Extensive scientific evidence exists on the negative effects of fatigue on performance of many cognitive tasks (see Chapter 4), including those essential for safely operating a commercial aircraft. The adverse effects of fatigue induced by sleep loss include maintaining wakefulness and alertness, vigilance and selective attention, psychomotor and cognitive speed, accu

racy of performing a wide range of cognitive tasks, working and executive memory, and on higher cognitive functions such as decision making, detec

tion of safety threats, and problem solving, as well as communication and mood. Fatigue is not, however, a binary condition where one is either rested with no negative effects on performance or fatigued with severe negative 

## Figure 5-8.eps 12:00 AM 12:00 PM 12:00 AM 12:00 PM 12:00 AM 12:00 PM 12:00 AM

Da y 1

| | | | | | | Rest Commute

On Duty Flight Segments

Time Aw ak eActivity



### Time of Da y at Residence Da y 2 D ay 3



### FIGURE 5-8 Example 4a: Unfavorable commuting pattern—overview of 3 con

secutive days.
SOURCE: Based on communication with FAA officials.PILOT COMMUTING AND FATIGUE RISK 

### 97

effects on performance. There are degrees of fatigue and degrees of the negative effects of fatigue on performance. Similarly, the effects of fatigue on performance can vary substantially from one pilot to the next without any untoward effects on the safety of flight. The scientific literature shows fatigue as a risk to performance can result from three factors: (1) being awake continuously for more than approximately 16 hours, or (2) sleeping too little (especially less than 6 hours on the day prior to work), or (3) when undertaking work at a time when the body is biologically programmed to be asleep (i.e., an individual’s habitual nocturnal sleep period), which for most people is between 10:00 p.m. and 7:00 a.m. The evidence that cognitive performance is adversely affected when the amount of sleep in 24 hours is cumulatively less than approximately 6 hours suggests that pilots should seek to obtain sufficient bed time to ensure they are fit for duty. The detrimental effects of fatigue on performance may be exacerbated by a tendency for individuals to have reduced awareness of the cognitive performance deficits that result from fatigue. Pilots are currently required to report fit for duty. Judging whether a pilot is fit for duty is an individual pilot decision that should take into ac

count the amount of sleep received prior to duty.

RECOMMENDATION 1: Pilots should avoid planning commutes or other preduty activities that result in being awake beyond approxi

mately 16 hours before the scheduled end of duty, endeavor to sleep at
least 6 hours 3 

### prior to reporting for duty, and obtain more than 6 hours of sleep per day whenever possible to prevent cumulative fatigue from chronic sleep restriction Pilots should also consider the amount of sleep and time awake in their decision making relative to when to inform their supervisors that they should not fly due to fatigue.

Although there are currently no agreed-on objective standards in the aviation industry to determine whether a pilot is reporting to duty fatigued, there are provisions in the proposed Notice of Proposed Rulemaking for as

sessment by others of whether a pilot is fatigued. The validity and reliability of such assessments are unknown, as is the likelihood that they can result in either false positives or false negatives. Consequently it is uncertain whether they can result in effective prevention of fatigue. The proposed regulation is discussed in the next chapter.

3 This refers to at least 6 hours of physiological sleep. Since physiological sleep is typically 85 to 95 percent of total bed time in healthy adults, time in bed for sleep will have to be 6.5 to 7 hours to ensure at least 6 hours of physiological sleep are acquired.

### 99 

# 6

Reducing the Risk of Fatigue from Commuting

Current federal flight duty time regulations (14 CFR 91 and 14 CFR 121) do not address pilot commuting. There is only a general requirement (in Part 91.13) that “No person may operate an aircraft in a careless or reckless manner so as to endanger the life or property of another.” This provision is interpreted by the Federal Aviation Administration (FAA) and the airline industry as requiring that pilots report fit for duty.

PROPOSED FAA RULE RELEVANT TO FATIGUE

In response to P.L. 111-216 (the Airline Safety and Federal Aviation Administration Extension Act of 2010), the FAA on September 14, 2010, is

sued a Notice of Proposed Rulemaking (NPRM) ( Federal Register , Vol. 75, No. 177) related to flight and duty time that attempts to take advantage of the available research on fatigue, sleep, and circadian rhythms and, among other things, to consider the effects of commuting, means of commuting, and the length of the commute on fitness for duty. In referring to the flight duty period (FDP) the NPRM states that “An FDP begins when a crew

member is required to report for duty that includes a flight, series of flights, or positioning flights (including part 91 ferry flights) and ends when the aircraft is parked after the last flight and there is no plan for further aircraft movement by the same crewmember” (p. 55,859). Thus, in the proposed regulations, time spent commuting is not considered duty time. Time spent commuting is also not considered rest by the FAA. As the NPRM states,
“The FAA does believe that it is unreasonable to assume that an individual

### 100 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### is resting while commuting. Accordingly, time spent commuting, either lo

cally or long-distance, is not considered rest” (p. 55,875).

Background

As part of its efforts to update the regulations, the FAA chartered an Aviation Rulemaking Committee (ARC) in June 2009. The ARC was comprised of representatives from labor, industry, and the FAA, and it was tasked with using fatigue science and a review of international approaches to develop recommendations for revisions of current regulations. The ARC was unable to reach consensus on all issues, however they did reach con

sensus on the role of commuting in any proposed regulations. With respect to commuting they “unanimously recommended that pilots be reminded of their existing obligations under part 91 to report to work fit for duty, but that the FAA impose no new requirements” (p. 55,874).

Issues Related to the Proposed Rule

The proposed regulations present commuting as fundamentally an issue of fitness for duty, defining a responsible commuter as a pilot who “plans his or her commute to minimize its impact on his or her ability to get mean

ingful rest shortly before flying, thus fulfilling the proposed requirement that he or she reports for an FDP rested and prepared to perform his or her assigned duty” (p. 55,874). The NPRM places considerable emphasis on education because, as the NPRM states, “The FAA believes a primary reason that pilots may engage in irresponsible commuting practices is a lack of education on what activities are fatiguing and how to mitigate develop

ing fatigue” (p. 55,875). Pilot education is one of the specified objectives of the draft advisory circular on fitness-for-duty mentioned above. The effect of commuting on fatigue is also one element of a recommended training curriculum specified in the NPRM. In the NPRM (p. 55,875), the FAA further states that “it is inappro

priate to simply rely on the existing requirements in Part 91 to report to work fit for duty.” FAA proposes a new Part 117 to address fitness for duty. The proposed rule states, “Fit for duty means physiologically and mentally prepared and capable of performing assigned duties in flight with the highest degree of safety” (p. 55,885). The proposed section 117.5 goes on to place specific responsibility on both the flight crew member and the
airline: see Box 6-1. As a complement to issuance of the NPRM, the FAA issued a draft ad

visory circular (AC 120-FIT) on fitness for duty “to demonstrate acceptable methods of compliance with Title 14 of the Code of Federal Regulations (14 CFR) proposed part 117, § 117.5.” The draft circular clearly statesREDUCING THE RISK OF FATIGUE FROM COMMUTING 

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that fitness for duty is considered a joint responsibility of the air carrier and the crew member and goes on to say, “Part 117 recognizes the need to hold both air carriers and pilots responsible for making sure crewmembers are working a reasonable number of hours, getting sufficient sleep, and not reporting for flight duty in an unsafe condition. Many of the ways that air carriers and crewmembers negotiate this joint responsibility are handled in the context of labor management relations and agreements.”

FATIGUE RISK MANAGEMENT PLANS AND SYSTEMS

There are currently two different regulatory initiatives that are relevant to the discussion of commuting and its effect on fatigue: fatigue risk man

agement plans (FRMPs) and fatigue risk management systems (FRMSs). It is important not to confuse the two. **BOX 6-1**
FAA Proposed Regulations on Fatigue (Section 117.5)

a. Each flight crew member must report for any flight duty period rested and prepared to perform his or her assigned duties.

b. No certificate holder may assign and no flight crew member may accept as

signment to a flight duty period if the flight crew member has reported for a flight duty period too fatigued to safely perform his or her assigned duties or if the certificate holder believes that the flight crew member is too fatigued to safely perform his or her assigned duties.

c. No certificate holder may permit a flight crew member to continue a flight duty period if the flight crew member has reported himself too fatigued to continue

the assigned flight duty period.

d. Any person who suspects a flight crew member of being too fatigued to per

form his or her duties during flight must immediately report that information to

the certificate holder.

e. Once notified of possible flight crew member fatigue, the certificate holder

must evaluate the flight crew member for fitness for duty. The evaluation must

be conducted by a person trained in accordance with § 117.11 and must be completed before the flight crew member begins or continues an FDP.

f. As part of the dispatch or flight release, as applicable, each flight crew member

must affirmatively state he or she is fit for duty prior to commencing flight.

g. Each certificate holder must develop and implement an internal evaluation and

audit program approved by the Administrator that will monitor whether flight

crew members are reporting for FDPs fit for duty and correct any deficiencies.

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### Fatigue Risk Management Plans

Fatigue risk management plans are an airline’s policies and procedures to reduce the risk of flight crew member fatigue and to improve flight crew member alertness (see Federal Aviation Administration, 2010a). P.L. 111- 216 required U.S. airlines to submit drafts of their plans to the FAA. On August 19, 2010, the FAA issued an InFO (Information for Operators; see Federal Aviation Administration, 2010a) that provided the necessary in

formation for air carriers regarding the structure and elements involved in the development of a fatigue risk management plan. 1 

### The FRMP structure
should consist of:

• senior-level management commitment to reducing fatigue and im

proving flight crew member alertness;

• FRMP scope and fatigue management policies and procedures;

• current flight time and duty period limitations;

• rest scheme consistent with limitations;

• fatigue reporting policy;

• education and awareness training program;

• fatigue incident reporting process;

• system for monitoring flight crew fatigue; and

• an FRMP evaluation program (Federal Aviation Administration, 2010a).

The guidance instructs that FRMPs should be updated every 24 calendar-months. In support of the development of FRMPs, the FAA issued another InFO that provides an FRMP checklist for operators to ensure that
all of the relevant elements of an FRMP were included in their submission (Federal Aviation Administration, 2010b). According to the FAA (Federal Aviation Administration, 2010a, p. 1):

A FRMP is an air carrier’s management plan outlining policies and proce

dures for reducing the risks of flightcrew member fatigue and improving flightcrew member alertness. The FRMP policies and procedures should focus on the air carrier’s specific kind of operations (e.g., domestic, flag, and supplemental) and the type operations (e.g., continuous duty over

nights, night vs. day operations, cargo vs. passenger operations, short-haul vs. long-haul, etc.).

1 The checklist can be found at http://www.faa.gov/other_visit/aviation_industry/airline_ operators/airline_safety/info/all_infos/media/2010/InFO10017.pdf [June 2011], and the supplemental document can be found at http://www.faa.gov/other_visit/aviation_industry/ airline_operators/airline_safety/info/all_infos/media/2010/info10017SUP.pdf [June 2011], respectively.REDUCING THE RISK OF FATIGUE FROM COMMUTING 

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The FAA issued guidance as to the structure of the plan as well as the submittal, review, and acceptance processes. Of relevance to commuting, the FAA checklist identifies “The effects of fatigue as a result of commut

ing” as one of 15 elements and tasks for the fatigue education and aware

ness training program to be referenced in the FMRP (see Federal Aviation Administration, 2010b). The following question regarding FRMPs was posed to airlines from whom the committee requested input for this study, “Does your Fatigue Risk Management Plan include any reference or consideration of commut

ing? If so, please provide a copy of the plan.” Out of the 33 airlines that provided input to the committee, 17 re

sponded with comments relevant to the FRMP. Eleven provided a statement on the status of their FRMP, if indeed they had one. For the most part, these responses included statements that the plan was submitted and pending approval. In one instance, the airline mentioned that commuting was not referenced as commuting is not allowed. Another airline pointed out that commuting was not relevant because the airline practiced home basing. In yet another case, a very small airline wrote that it was not relevant because of the few fatigue calls they had had in the past 5 years, none was related to commuting. Among the six airlines that provided copies of plans, five included the wording, noted above, from the FAA guidance document regarding com

muting as a factor to be addressed in a fatigue education and awareness training program. Two of these five included an additional statement that commuting information was to be collected when fatigue was reported by a pilot. One of these five airlines had a statement in its FRMP that fatigue
was a factor under review for event evaluation. In one other case an airline includes the following statement in its FRMP (personal communication):

Crewmembers commuting greater than two hours from the company facility are required to overnight in their domicile, if their bid assignment includes an early morning departure between the hours of 0000-0600, thus elevating the potential of fatigue. The STBY crew understands the time zone they are on STBY for and are expected to be rested and prepared to report to duty as needed.



### Fatigue Risk Management Systems

New developments both in the science of fatigue and performance and in management and regulatory philosophies have led to the other regula

tory approach in the transportation domain, usually termed fatigue risk

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### management systems (FRMSs). 2 

### These systems are focused on integrating scientific knowledge about fatigue and its management with the realities of airline operations. In essence, these systems recognize that responsibility for managing fatigue-related safety risks is a shared responsibility of regulatory authorities, operators, and individual pilots. In an effort to collect additional data, the committee approached many international regulatory and safety oversight organizations, operators, and pilot associations—including the International Civil Aviation Organization (ICAO), the International Air Transport Association, the Flight Safety Foun

dation, and the International Federation of Airline Pilots’ Association

— to obtain information regarding existing regulations, policies, and best prac

tices regarding commuting outside the United States. It is interesting to note that little information was received as to relevant aspects to commuting and fatigue with the exception of FRMSs. The ICAO established a FRMS task force to review scientific and opera

tional knowledge and to develop detailed regulatory standards and guidance for member countries on implementation of such systems (see International Civil Aviation Organization, 2009). The proposed Standard and Recom

mended Practice (SARP) was approved for adoption by the ICAO Council on June 13, 2011. It will become effective for member states on October 15 and applicable on December 15, 2011. FRMS, according to the new ICAO standard, promotes addressing flight crew fatigue in a comprehensive and proactive manner by gather

ing objective data regarding sleep, fatigue, and operational parameters to manage the risk which fatigue can pose to flight safety (International Civil Aviation Organization, 2011a, 2011b). This approach is in stark contrast to managing the risk through prescriptive limits of flight time or duty periods based on the assumption that a pilot is safe to fly as long as he or she is operating within prescribed hourly limits. It is important to note that hours spent commuting are not included in such limits. When an airline chooses to implement FRMS within an approved regulatory framework it commits to specifying both predictive and proac

tive processes that it will use to identify potential fatigue hazards and the resulting safety risks. The predictive processes are applied when developing monthly crew rostering schedules and can include the use of scientifically derived biomathematical computer models as well as operational experi

ence to take into account factors known to affect sleep and fatigue and their effects on performance (International Civil Aviation Organization, 2011a, 2011b).

2 An FRMS is a data-driven and scientifically based process to continuously manage and monitor fatigue-related risks to ensure that personnel are performing at adequate levels of alertness in flight operations.REDUCING THE RISK OF FATIGUE FROM COMMUTING 

### 105

After the rostering schedules are implemented then the proactive pro

cesses are used to identify hazards during current operations on an ongoing basis. These processes can include crew self-reports of fatigue as well as more objective measures of sleep, using actigraphs (a wristwatch-like device that is worn continuously), and crew performance, using simple tests devel

oped in the laboratory, such as the widely accepted Flight Data Monitoring (also known as Flight Operations Quality Assurance or FOQA) to identify
deviations from planned flight parameters in airplane handling performance during approach and landing. The operator must also ensure that remedial actions, necessary to effectively mitigate the risks associated with the haz

ards, are implemented promptly, and it must specify the methods it will use to actively monitor the effectiveness of those actions taken to mitigate fatigue risks (International Civil Aviation Organization, 2011a, 2011b). According to the FAA, “An FRMS can be part of an organization’s SMS [safety management system] or a stand-alone system” (U.S. Department of Transportation, 2010a, p. 4). If an airline has a safety management system, then the data collection and analysis would preferably be carried out in
a manner consistent with that SMS. 3 

### Sample crews are selected with no regard to whether or not they have commuted long distances by car, bus, train, or air before starting duty. Given the prevalence of commuting, de

scribed elsewhere in this report, it can be assumed that a substantial number of the sampled crews will include commuters who travel long distances by all forms of transportation. Thus, FRMSs provide a rigorous method to assure that crews are oper

ating at a suitable level of alertness without regard to the characteristics of their commutes. FRMSs can offer both the operator and regulators a valid “snapshot” of crew alertness during normal operations and thereby provide at least a partial assessment that the contribution of commuting to fatigue is or is not within an acceptable level. Such limited assurance offers a signifi

cant benefit beyond simply requiring the crew and the operator to adhere to prescriptive limits when no data are routinely gathered to assess the specific risk that fatigue may pose to a particular set of flights. Furthermore, if an operator wishes to assess whether some types of commuting produce more fatigue for a specific trip pairing, an FRMS provides a ready method to do so. FRMSs are currently under development by several foreign carriers. Industry and professional groups, as well as U.S. state regulatory agencies, are also involved in development and implementation efforts. An FRMP includes some elements of an FRMS (e.g., management policy, event reporting and evaluation, and fatigue education and aware

ness training), but it is still based on flight time and duty period limita

3 For explanation of an SMS, see http://www.icao.int/anb/safetymanagement/DOC_9859_ FULL_EN.pdf [June 2011].

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### tions and a focus on reported events. It does not include the key proactive FRMS element of routinely assessing fatigue risk on specific trip pairings. Consequently, its ability to address commuting is limited to education and training and reactive analyses of reported unsafe events. When FRMS becomes applicable as an ICAO worldwide standard in December 2011, member states will each have to decide how to implement the new standard within their aviation regulations. The proposed SARPs combine all standards for fatigue management under a general heading of “Fatigue Management” rather than being dispersed as they are now throughout Annex 6, Part I. This consolidation will enable states to allow operators the option of utilizing FRMS as the basis for some or all of their operations in place of prescriptive regulations. In anticipation, ICAO has worked with industry (International Air Transport Association, IATA) and labor (International Federation of Airline Pilots’ Association, IFALPA) to draft complementary FRMS Manuals for Operators and Regulators, which are scheduled to be released in July 2011. Although an FRMS is not mandatory for U.S. carriers, the FAA did issue an Advisory Circular (AC 120-103) on FRMSs on August 3, 2010 (U.S. Department of Transportation, 2010a). The circular identifies the basic components of an FRMS and how it may be implemented in avia

tion operations as a means of improving safety and performance. In the circular, an FRMS is described as “a data-driven and scientifically based process that allows for continuous monitoring and management of safety risks associated with fatigue-related error. It is part of a repeating perfor

mance improvement process. This process leads to continuous safety en

hancements by identifying and addressing fatigue factors across time and changing physiological and operational circumstances.” The circular notes that it may be implemented as part of the organization’s safety management system or as a stand-alone system. The components for an FRMS include (a) a fatigue risk management policy, (b) an education and awareness training program, (c) a fatigue anal

ysis and reporting system, (d) monitoring fatigue in flight and cabin crew, (e) an incident reporting process, and (f) performance evaluation. Roles and responsibilities in the FRMS process include the operator, the employees/ crew, and the regulator. The regulator’s responsibility is to audit the pro

cess and ensure that the FRMS is responsive to feedback and provides a level of safety that is equivalent to those established by existing regula

tions. The data-driven approach of an FRMS is derived from the guidance developed by the Flight Safety Foundation for regulatory authorities to use for approving flights greater than 16 hours ( Flight Safety Foundation Editorial Staff, 2005) . The process was used first for Singapore Airlines, and it has since been by several other airlines, including the current effort by the FAA to assess fatigue on ultra-long-range flights by Delta, American,REDUCING THE RISK OF FATIGUE FROM COMMUTING 

### 107

and Continental Airlines. In the NPRM, related to fatigue, the FAA has proposed that carriers use a similar FRMS approach for flights not covered by the new regulations. In order to be consistent with other states, the FAA will need to adjust the circular to be consistent with the ICAO FRMS SARPs recently approved by the ICAO Council. The FAA approach is compatible with ICAO’s initiative on fatigue risk management systems and the trend over the past two decades of many U.S. federal regulatory agencies to shift more responsibility to the organizations they regulate and to encourage cooperative rather than adversarial rela

tionships. Generally, these initiatives rely on management systems that use continuous monitoring to identify and mitigate potential risks before they have safety consequences. 4



### Pilot Decision Making

Decision making is central to pilots’ efforts to avoid flying their aircraft while they are fatigued. Once a pilot has made a strategic decision of where to live in relation to his or her domicile, there are three major circumstances in which such tactical decision making has special significance: (1) when the pilot is developing plans for commuting to the domicile; (2) when the pilot must make adjustments in plans necessitated by arising contingencies (e.g., bad weather); and (3) when the pilot has to decide whether and how to can

cel a duty assignment because of (anticipated) fatigue. The decisions in all such situations are highly challenging. For instance, they typically involve multiple, often conflicting considerations, numerous stakeholders with com

peting interests (e.g., family members, colleagues, and supervisors), and the need to be informed by nonobvious and sometimes counterintuitive facts about the biology of fatigue and rest.

Regulatory Considerations: General Issues

A major concern in establishing any regulation is designing it so that it achieves its intended effect. Negative unintended consequences often emerge when a seemingly simple regulation is implemented in a complex system. Regulators may not have enough knowledge about the detailed operation of the systems and so may adopt seemingly simple regulations that fail to anticipate how the system will respond to those regulations. An early analysis of the general problem of unintended consequences found that one of its sources is “imperious immediacy of interest,” which is where

4 Such voluntary FAA programs include the Aviation Safety Action Program and the Flight Operational Quality Assurance Program.

### 108 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### the intended consequence of an action is desired so strongly that potential unintended effects are purposely ignored (Merton, 1936). The committee is concerned that a rush to establish regulation regard

ing pilot commuting and fatigue without an adequate understanding of how pilot commuting and fatigue interact with the aviation system might trigger unanticipated and unintended consequences that have not yet been carefully anticipated. Such unanticipated and unintended consequences can reduce the effec

tiveness of the regulation in achieving its goal, and in some cases may even result in a regulation having the opposite effect of what had been intended. A noteworthy example occurred with the 55 mph speed limit, established in March 1974 in response to the 1973 oil embargo (see National Research Council, 1984). Following this adoption, highway fatalities dropped. Al

though multiple factors contributed to the decline in fatalities, the general consensus was that the reduced speed limits had resulted in fewer highway fatalities. As the fuel shortage eased, the speed limit was retained largely on the grounds of the increased safety it apparently provided. However, in response to other pressures and interests, in 1987, 40 states raised the speed limit to 65: many anticipated that highway fatalities would again increase due to the higher speeds. Although highway fatalities did increase, so did vehicle miles traveled. A study that examined statewide fatality rates, con

sidering not only the roads on which the speed limits were changed but also the non-interstate roads on which they were not, found that the higher 65 mph speed limit reduced the statewide fatality rates by 3.4-5.1 percent in comparison with other states (Lave and Elias, 1994). It appears that this un

expected and initially counterintuitive result was because enforcement and highways are integrated systems. The federal government had threatened to impose financial penalties if the 55 mph speed limit was not enforced, so states devoted considerable patrol resources to rural interstates and reduced both enforcement on other highways and other safety activities. In addition, it appears that the higher level of enforcement on rural interstates may have caused some drivers to switch to parallel noninterstate highways, which are more dangerous in terms of fatalities but which had the same speed limit and less speed enforcement. Where the 55 mph speed limit was raised and the threat of federal financial sanctions removed, highway patrols reallo

cated their activities to a better balance from a safety perspective and with the higher interstate speed limits, some drivers switched from parallel rural roads to the safer interstate highways. This experience offers two cautionary lessons for safety regulation. One is that complex systems may react to regulation in ways that were unan

ticipated and, in this case, counter to the goal of improved highway safety. The second is that patterns of enforcement can have important and often unanticipated effects on how a system reacts to regulation.REDUCING THE RISK OF FATIGUE FROM COMMUTING 

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In aviation safety regulation, another possible unintended consequence of regulation can come from modal shift effects. A regulation that increases costs to the airline industry will likely result in some portion of those costs being passed on to travelers in the form of higher airline ticket prices. Higher airline ticket prices would cause some travelers to switch their mode of travel from airplanes to automobiles. Since travel by private automobile is more dangerous than travel by commercial airline, the result of such a shift would be an increase in highway fatalities. Thus, however many airline passenger and crew lives are saved by the airline safety regulation, the net savings of life from the regulation would be less because of the increase in highway fatalities. In some cases, the net effect may actually be a net loss of lives from a regulation intended to save lives. This potential for an outcome other than that intended was forecast for a proposed regulation to mandate the use of child safety seats on commercial airlines. One study of the proposed regulation (Windle and Dresner, 1991) concluded that more lives would be lost from the switch to highway travel from the higher travel costs for families with children than would be saved from the added safety benefit of child safety seats.

Regulatory Considerations: Pilot Commuting

Developing a regulation to address pilot commuting would face several challenges. The first would be to determine how many lives the elimination of commuting-related fatigue would be expected to save. Although there is no doubt that, in principle, commuting can contribute to pilot fatigue, that pilot fatigue can contribute to reduced pilot performance and that reduced pilot performance can contribute to aviation accidents that can result in fatalities, the magnitudes of any of these effects are not well understood. In particular, there is very little knowledge about the extent to which pilot commuting contributes to pilot fatigue in practice, in part because there are almost no systematic data on current pilot commuting patterns. Determining the extent to which fatigue may have contributed to an ac

cident is difficult in an accident investigation, the committee’s examination of 863 accidents found only 9 in which fatigue was judged to be a prob

able cause or contributing factor (see Chapter 3). In none of the accidents was commuting-related fatigue judged by the National Transportation Safety Board to be a probable cause or contributing factor, and, of the nine fatigue-related accidents, there was only one in which a commute may have been one of the contributors to that fatigue. Although the limitations of the accident investigation process means that the role of fatigue may be difficult to detect so that these figures may well understate the role of fatigue, it is still difficult to conclude that commuting-related fatigue is a major source
of aviation accidents.

### 110 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### The second challenge would be to determine what proportion of commuting-related fatigue accidents a proposed regulation would prevent. Commuting occurs during a pilot’s off-duty time and, collectively, from a diverse array of home locations to a large number of domiciles using a wide variety of transportation options. Enforcement of a regulation designed to alter pilots’ behavior during their off-duty hours would be difficult. In such situations, as suggested by the enforcement of the 55 mph speed limit, dif

ferent patterns of enforcement could have different impacts on the actualeffect of the regulation. Enforcement might well prevent some fatigueinducing commutes, depending on how a regulation was implemented, but the form of enforcement could also induce some counterproductive
behavior. The third challenge would be to determine what the regulation would cost to both pilots and airlines and the subsequent effects of those added costs would be on airline ticket prices. Higher ticket prices would cause some travelers to switch from airline travel to auto travel, with the result of some increase in highway deaths. At first glance, it might appear that only the direct costs to the airlines would influence ticket prices, but costs the regulation might impose on pilots might also have an effect. If the regulation imposed costs on pilots, it could make being an airline pilot a less attractive career than it had been prior to the regulation. If that caused some pilots to choose a different profession, then the airlines might have to pay higher wages to attract a sufficient number of pilots to the industry. Those higher wages, should they be necessary, would result in higher costs to the airlines and eventually higher ticket prices. With these considerations in mind, it is important to note that assessing the impact of cost on airline ticket prices and, in turn, on increased highway fatalities is beyond the scope of the current requirements for cost-benefit analysis of proposed regu

lations. There are other possible adverse consequences from regulations: see Viscusi (1994) and Viscusi and Zeckhauser (1994). Given that there is some potential for commuting to contribute to fa

tigue and clear evidence that fatigue can decrease performance, the commit

tee believes it is important to reduce the likelihood that commuting could contribute to pilot fatigue during duty. At the same time, the safety risk posed by commuting-induced fatigue is unknown. There is a need to un

derstand the extent to which the risk posed by fatigue resulting from some commutes may be mitigated by individual, airplane (e.g., flight deck sys

tems), or aviation system (e.g., crew resource management) characteristics. There is also tremendous variability across individual pilot commutingpractices and day-to-day experiences. Attempting to determine a one-sizefits-all delineation on what constitutes a fatiguing commute on the basis of either time or distance is difficult because the length of the commute, measured either by distance or time spent commuting, does not necessarilyREDUCING THE RISK OF FATIGUE FROM COMMUTING 

### 111

determine whether or not the pilot reports fit for duty and well rested. And as discussed above, regulations specific to commuting could inadvertently lead to increased safety problems and additional loss of lives due to unin

tended and unanticipated consequences. Consequently, although action is warranted to reduce the likelihood that commuting will present a safety risk, there is a lack of evidence to support the basis for issuance of regula

tions pertaining to commuting.

CONCLUSIONS AND RECOMMENDATIONS

CONCLUSION: With regard to the proposed provisions in Section 117.5, there are no valid and reliable tools and techniques feasible to achieve the goals of detecting fatigue and fitness for duty in pilots in an operational setting. To achieve these goals, further research would be needed to scientifically validate the tools and techniques, demonstrate that they are technically feasible in an operational environment, and evaluate their relationship to operational safety and the extent to which they can be integrated into an operational context.

CONCLUSION: There are inadequate data to specify or determine the effectiveness of regulations regarding pilot commuting. Additional information is needed to determine if a regulatory approach would be appropriate.

Potential fatigue is an inherent component of a system that functions 24 hours a day, 7 days a week. Recognizing this, the aviation industry has been developing an approach through FRMSs to better understand when fatigue is a concern and how to best mitigate that risk. Airlines develop FRMSs specific to their operational environment. To date, commuting has not been a major consideration in these systems. Incorporating data on commuting in relation to pilots’ duty hours and sleep prior to duty would help inform these systems and allow airlines to consider mitigation strategies specific to their operations.

RECOMMENDATION 2: The potential of commuting on pilot fa

tigue should be addressed as part of an airline’s strategies to man

age fatigue risk. If airlines develop fatigue risk management systems (FRMSs), they should gather information about preduty sleep and wake time relative to commuting practices and duty cycle. FRMSs should provide a mechanism for identifying problematic patterns and addressing them. FRMSs can offer both the airline and the Federal Aviation Administration an improved assessment of crew alertness

### 112 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### during normal operations and thereby provide some information on the contribution of commuting to fatigue and whether fatigue is or is not within an acceptable level of risk.

FRMPs are the airline carriers’ management plans outlining policies and procedures reducing the risk of flight crew member fatigue and improv

ing flight crew member alertness. P.L. 111-216 requires each U.S. carrier operating under Part 121 to submit to the FAA their draft FRMP for review and acceptance. Provided in the FAA’s guidance on the development of an FRMP is a requirement for a fatigue education and awareness training program element, one of the subtasks of this element is the effects of com

muting on fatigue. This requirement reflects the perspective that managing the effects of commuting on fatigue is a joint responsibility of airlines and pilots, a posi

tion with which the committee agrees. Although the FRMP approach is not as rigorous as the FRMS process, it is required of all Part 121 airlines and therefore presents an opportunity to reach a wider audience than FRMS.

RECOMMENDATION 3: The committee supports fatigue education and awareness training as part of an airline’s fatigue risk manage

ment plan. Training relative to commuting should include guidelines regarding the effects of inadequate or disturbed sleep or prolonged wakefulness on fatigue and performance. Fatigue education and aware

ness training should be annually updated with particular attention to incorporating relevant new developments in sleep science.

As part of its data collection, the committee requested that airlines submit information on their policies on pilot commuting, sick leave, and fatigue, if available. Although only a relatively small proportion of airlines responded (39 percent), it is clear from the information submitted and from comments provided in public comments that there is considerable diversity in these policies. In addition, not all airlines have commuting or fatigue policies, with pilots relying instead on sick leave availability to address potential fatigue. Airlines should consider policies that would help pilots plan predictable commutes that do not promote fatigue on duty and policies that minimize negative consequences when unanticipated events alter their commuting plans and lead to fatigue. The effects of these policies on pilot behavior are currently not well understood.

RECOMMENDATION 4: The Federal Aviation Administration should convene a joint industry, labor, and government working group, un

der the auspices of an independent organization (such as the Flight Safety Foundation), to assess industry policies on pilot commuting, sickREDUCING THE RISK OF FATIGUE FROM COMMUTING 

### 113

leave, attendance/reliability, and fatigue and to develop industry best practices. The output of this joint working group should inform the development and updating of airlines’ fatigue risk management plans and should be validated periodically.

Pilots make decisions about commuting in the context of other factors in their lives, the specifics of their flights, the policies in place at their air

lines, including sick leave and commuting policies, and other environmental factors. It is unclear to what extent pilots are aware of the findings from
current decision science or consider this information in their decision mak

ing. Decision-making strategies informed by this science could be incorpo

rated into FRMP training and considered in the development of industry best practices.

RECOMMENDATION 5: The Federal Aviation Administration should commission efforts to develop protocols and materials for training pi

lots to make decisions regarding commuting easily and effectively and to ensure that they are informed by current decision science.

As described above, little is known about pilots’ commuting patterns and the extent to which their commuting patterns may affect the amount or quality of sleep or the amount of time awake prior to duty. A better understanding of the relationship of commuting to primary risk factors for fatigue would represent a first step in increasing understanding of the relationship between commuting and fatigue. This information, combined with information that is recommended for inclusion in the required FRMPs or in FRMSs, when such systems are required, will provide input needed to inform further research and industry policies.

RECOMMENDATION 6: To inform the development of industry best practices and policies relative to commuting, the Federal Aviation Administration should fund a study to determine the relationships be

tween distance from domicile and five primary fatigue risk factors: (1) sleep quantity 48 hours prior to the end of duty on each day of the trip; (2) sleep quality 48 hours prior to the end of duty on each day of the trip; (3) time awake in the 48 hours prior to the end of duty on each day of the trip; (4) cumulative sleep time in the 72 hours prior to the end of a duty period; and (5) circadian phase at which sleep is obtained and at which duty is undertaken. In order to be maximally useful, the study should include a large random sample of pilots from multiple companies representing the major industry segments. The study should provide objective data on fatigue risk antecedents by using a well-

### 114 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### validated technology that provides reliable information on sleep and wake periods, such as wrist actigraphy, as well as sleep-wake diaries.

Collecting data on a 48- to 72-hour period is needed to fully under

stand pilots’ commuting experiences within the context of multiple factors. The results of the study can help identify situations that may warrant spe

cific attention or additional research.

### 115 

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### 127 

# Acronyms

ARC Aviation Rulemaking Committee

ASIAS Aviation Safety Information Analysis and Sharing

ASRS Aviation Safety Reporting System

BOHSI Board on Human-System Integration

BTS Bureau of Transportation Statistics

CASS Cockpit Access Security System

CFR Code of Federal Regulations

CRM Crew Resource Management

DBASSE Division of Behavioral and Social Sciences and Education

FAA Federal Aviation Administration

FAR Federal Aviation Regulation

FDP flight duty period

FRMP fatigue risk management plan

FRMS fatigue risk management system

GPWS Ground Proximity Warning System

ICAO International Civil Aviation Organization

IOM Institute of Medicine

NAS National Academy of Sciences

### 128 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### NASA National Aeronautics and Space Administration

NPRM Notice of Proposed Rulemaking

NTSB National Transportation Safety Board

SARP Standards and Recommended Practice

TCAS Traffic Collision Avoidance Systems

### 129 

# Glossary

14 CFR Part 121: federal flight duty time regulations.

AC-120 FIT: As a complement to issuance of the NPRM, the FAA issued a draft advisory circular (AC 120-FIT) on fitness for duty.

Air carriers: a commercial carrier utilizing aircraft as its means of transport; an airline, as for passengers or freight.

Airport/standby reserve: a defined duty period during which a crew mem

ber is required by a certificate holder to be at, or in close proximity to, an airport for a possible assignment. 1



### Cargo airlines: air carriers with flights for the purpose of delivering goods
to locations.

Charter airlines: air carriers that provide nonscheduled passenger flights.

Circadian rhythms: daily (24-hour) rhythms instantiated in microbiology, physiology and behavior that control the timing of the sleep-wake cycle and influence physical and cognitive performance, activity, food consump

tion, body temperature, cardiovascular rhythms, muscle tone, and aspects

1 Federal Register, “Notice of Proposed Rule Making: Flight Crew Member Duty and Rest,” September 14, 2010, Volume 75, Number 177.

### 130 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### of hormone secretion and immune responses, as well as many other physi

ological functions.

Commuting: the period of time and the activity required of pilots from leav

ing home to arriving at the domicile (airport—in the crew room, dispatch room, or designated location at the airport) and from leaving the domicile
back to home.

Crash pads: temporary living arrangements shared among groups of pilots.

Crew pairing: a flight duty period or series of flight duty periods assigned to a flight crew member which originate or terminate at the flight crew
member’s home base. 2



### Crew Resource Management (CRM): the application of procedure and training through a team management system designed to address the chal

lenge of optimizing the human/machine and human/human interfaces. In

cludes all groups routinely working with the flight crew who are involved in decisions required to operate a flight safely.

Deadhead transportation: transportation of a crew member as a passenger, by air or surface transportation, as required by a certificate holder, exclud

ing transportation to or from a suitable accommodation. 3



### Deadheading: term used when travel is provided to members of a flight crew in order to position them appropriately for duty. According to FAA regulations, deadheading is considered to be part of their work, or duty

time.

Domicile: the airport where a pilot begins and ends a duty period.

Duty: any task, other than long-call reserve, that a crew member performs on behalf of the certificate holder, including but not limited to airport/ standby reserve, short-call reserve, flight duty, preflight and postflight duties, administrative work, training, deadhead transportation, aircraft positioning on the ground, aircraft loading, and aircraft servicing. 4



### Duty period: a period that begins when a certificate holder requires a crew

2 Ibid.

3 Ibid.

4 Ibid.GLOSSARY 

### 131

member to report for duty and ends when that crew member is free from
all duties. 5



### Fatigue: a physiological state of reduced mental or physical performance capability resulting from lack of sleep or increased physical activity that can reduce a crew member’s alertness and ability to safely operate an aircraft or perform safety-related duties. 6



### Fatigue risk management plans (FRMPs): the airline carriers’ management plans outlining policies and procedures reducing the risk of flight crew member fatigue and improving flight crew member alertness.

Fatigue risk management systems (FRMSs): a data-driven and scientifically based process that allows for continuous monitoring and management of safety risks associated with fatigue-related error. It is part of a repeating performance improvement process. This process leads to continuous safety enhancements by identifying and addressing fatigue factors across time and changing physiological and operational circumstances. 7



### First officer: the member of a flight crew who is second in command to the captain.

Fit for duty: physiologically and mentally prepared and capable of perform

ing assigned duties in flight with the highest degree of safety. 8



### Flight crew: the people involved in operating an aircraft in flight, includes pilots, flight engineers, flight navigators, and cabin attendants assigned to duty in an aircraft during flight time.

Flight duty period (FDP): a period that begins when a flight crew member is required to report for duty with the intention of conducting a flight, a series of flights, or positioning or ferrying flights, and ends when the aircraft is parked after the last flight and there is no intention for further aircraft movement by the same flight crew member. A flight duty period includes deadhead transportation before a flight segment without an intervening required rest period, training conducted in an aircraft, flight simulator or flight training device, and airport/standby reserve. 9

5 Ibid.

6 Ibid.

7 Ibid.

8 Ibid.

9 Ibid.

### 132 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Gateway basing: the airline arranges a flight (when necessary) from a speci

fied gateway city to the departure city of the pilot’s first flight, and the pilot is responsible for the commute from home to the gateway city.

Home: the pilot’s residence.

Home basing: the airline arranges a reserved seat on a flight from the pilot’s home location to the city from which the pilot’s flight departs.

Hub: a focal airport for the routing of aircraft and passengers.

Hub-and-spoke: a system where many flights converge on one airport (the hub) at about the same time so that passengers and cargo can connect conveniently to a flight that is going to the ultimate destination (a spoke).

Jumpseat: an additional observer seat on the flight deck available to other pilots by courtesy of the captain.

Long-call reserve: a reserve period in which a crew member receives a re

quired rest period following notification by the certificate holder to report for duty. 10



### Long-haul: flights are that involve long distances, typically beyond 6 hours in length, and often are nonstop flights.

Mainline airlines: air carriers that predominately operate scheduled service in jet aircraft with more than 90 seats and often provide intercontinental

service.

Nonrevenue travel: free or reduced-rate (nonrevenue) travel.

Overnighting: assignment by an airline for a flight crew member to spend a required rest period at a location that is not the pilot’s domicile, normally including prearranged accommodations and local transportation; see also layover.

Part 91 ferry: a flight with no paid passengers or cargo aboard, performed to position an aircraft to a desired location such as to perform its next

10 Ibid.GLOSSARY 

### 133

revenue flight; alternatively, a flight of an aircraft that is not airworthy, performed under provisions of a “ferry permit.” 11



### Part 121: This phrase refers to most passenger and cargo airlines that fly transport-category aircraft with 10 or more seats.

Regional airlines: air carriers that predominately operate scheduled service in aircraft, both jet and turboprop, with 90 or fewer seats

.

11 Federal Aviation Administration. (n.d.). Special Flight Permits

. Available: http://www. faa.gov/about/office_org/field_offices/fsdo/phl/local_more/media/ferry_permit.pdf [June 2011].

### 135 

# Appendix A

Airlines, Associations, and Groups That Provided Written Input

The committee received a wide range of written input from airlines, as

sociations, and groups. This input was comprised of either one or more of the following: general responses to the questions posed by written requests (see Box 1-3, in Chapter 1), home-to-domicile zip code information for airline pilots (for 24 airlines); and information specific to relevant airline policies and fatigue risk management plans.

AIRLINES

ADI Air Wisconsin Airlines Corporation Aloha Air Cargo Ameristar Air Cargo, Inc. Atlantic Southeast Airlines, Inc. Atlas Air Worldwide (Atlas and Polar Air Cargo) Capital Cargo Colgan CommutAir Champlain Enterprises Compass Airlines
Delta Air Lines Empire

Era Aviation Everts Air Cargo Federal Express Florida West International Airways, Inc.

### 136 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### GoJet_Trans States Holdings JetBlue Miami Air International, Inc.
North American Airlines Omni Air International, Inc.
Pinnacle PSA Airlines, Inc
Seaborne Airlines
Trans States Airlines
United Continental

UPS US Airways USA Jet Airlines USA 3000 Brendan Airways Virgin America World Airways
Unidentified Airline*

ASSOCIATIONS AND GROUPS

Cargo Airline Association
Coalition of Airline Pilots Associations
National Air Carriers Association
U.S. Airline Pilots Association

*This airline requested not to be identified.

### 137 

# Appendix B

Public Meeting Agendas

Meeting 1: Monday, November 22, 2010

9:45 am Public Welcome and Study

• Connie Citro , interim deputy director, Division of Behavioral and Social Sciences and Education (DBASSE)

• Clint Oster , chair, Committee on the Effects of Commuting on Pilot Fatigue
Committee Member and Staff Introductions Participant Introductions

10:00 am Sponsor Perspective Charge and Expectations of the Study

• Dale E. Roberts , aviation safety inspector, Air Transportation Division, Federal Aviation Administration (FAA)

Questions and Discussion

11:00 am NTSB Comments

• Mark Rosekind , member, National Transportation Safety
Board

Questions and Discussion

### 138 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### 12:00 pm Working Lunch Topics: Informal Discussion with Presenters

12:45 pm Relevant Research Flight Attendant Fatigue Study

• Thomas Nesthus , Civil Aerospace Medical Institute, FAA

Human Factors Monitoring Program: Fatigue Risk Management Scientific Study

• Jessica Nowinski , National Aeronautics and Space
Administration Ames Research Center (with Irving Statler participating by phone)

Questions and Discussion

2:15 pm Stakeholder Comments

• Charlotte O’Connell , pilot

• Jeff Skiles , U.S. Airline Pilots Association

Questions and Discussion

3:00 pm Adjourn Open Session

Meeting 2: Monday, December 20, 2010

10:00 am Welcome and Introductions

• Robert M. Hauser , interim executive director, DBASSE

• Clint Oster , committee chair

10:15 am Stakeholder and Public Comments: Part I

• Captain (retired) Bill Mims , A Pilot’s Perspective

• Steven Sargent , Compass Airlines

11:15 am An Ongoing Study on Commuting and Pilot Fatigue

• Lori Brown , faculty specialist, Western Michigan University College of Aviation (via teleconference)

12:15 pm Working Lunch Lunch will be served in the meeting room. Topics: Discussion with PresentersAPPENDIX B 

### 139

1:00 pm Stakeholder and Public Comments: Part II

• Airline Pilots Association, Intl., Captain Bill Soer, flight and duty time committee member

• National Air Carriers Association, George Paul , director,
Technical Services

• Coalition of Airline Pilots Associations, Captain Bob Coffman

2:30 pm General Discussion with Guests

3:00 pm Break

3:15 pm Learning Lessons for the Railroad Industry

• Jeff Moller , assistant vp, Operations Systems and Practices, Association of American Railroads, Washington, DC

4:15 pm Final Questions and Discussion

4:30 pm Adjourn Open Session

Meeting 3: Monday, February 21, 2011

10:00 am Welcome and Introductions

• Clint Oster , committee chair

10:15 am Stakeholder and Public Comments Presentations and

Discussion

• Captain William McDonald , managing director, Flight Operations Contract Administration, FedEx

Meeting 3: Tuesday, February 22, 2011

9:45 am Welcome and Introductions

• Clint Oster , committee chair

10:00 am FAA Presentation on NPRM

• Dale E. Roberts , aviation safety inspector, Air Transportation Division, FAA

• Greg Kirkland, assistant division manager, Flight Standards Service Air Transportation Division, FAA

### 141 

# Appendix C

Summary of Stakeholder Response

to Committee Request for Input

To help inform the committee’s deliberations, requests for data were sent to a variety of different stakeholders in the airline industry, including 84 individual airlines, 8 airline associations, and 7 commercial pilot asso

ciations. Because of the extremely short turnaround (a few weeks) between our sending these requests and the meetings of the committee, the response rates from the stakeholders considered here were relatively modest, a total of 29. The committee conducted a qualitative review of written input re

ceived by March 23, 2011, which included responses from 25 individual airlines (4 mainline passenger carriers, 8 regional passenger carriers, 9 cargo carriers, and 4 nonscheduled charter carriers), 2 of the airline associations, and 2 of the pilot associations. (Some airlines responded with written input after this date but their input could not be included in this review.)
The committee received written statements from three individual com

mercial pilots who volunteered their thoughts on issues being addressed by the committee which was considered in the review of stakeholder response. During the committee’s meetings, several of these individuals as well as some officials from particular airlines and professional associations met with the committee to present their views orally. Overall, the obtained data bear on the set of issues and questions outlined in Box 1-3 (in Chapter 1), as well as other related policies and practices of the particular air carriers and the Federal Aviation Administration (FAA). This appendix summarizes what the committee learned from that input

### 142 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### on the specific issues of interest to its work regarding commuting 1 

### : defini

tion, prevalence, reasons, effects, and suggestions for improvement.

DEFINITIONS OF COMMUTING

In response to requests for definitions of what “commuting” means to pilots and crew members of commercial air carriers, the committee received a heterogeneous mix of replies from 17 of the queried stakeholders (1 air

line association, 2 pilot associations, 3 individual pilots, and 11 individual airlines). Two of the respondents did not offer definitions, stating that “any definition of ‘commuting’ would be purely subjective” and “commuting cannot be defined.” Four respondents emphasized that a “one-size-fits-all” definition of commuting would be inappropriate because pilot and crew

member commutes may involve multiple different modes of travel, as well as widely variable travel distances and times, with a variety of en route

activities. For 11 respondents, however, there was some consistency of views about the airlines industry’s interpretations of “commuting.” In particu

lar, they explicitly defined “commuting” as referring specifically to travel arranged by pilots and other crew members acting as independent agents for going to and from home and work. Seven respondents specifically con

strained the commuting activity to involve travel by air. For example, one senior pilot for a major passenger carrier said: “I would say a ‘commuting’ pilot is one who takes a flight instead of driving. ‘Commuting’ should be defined as a flight. This is a starting point of how to define the corporate responsibility in numbers of commuting pilots.” Consistent with this view, three other respondents even said that “commuting” refers specifically to traveling by air from home to base using available jumpseats. However, seven other respondents at least implicitly said that “commuting” might entail not only air travel but also other modes (e.g., driving) if that travel
takes 2 hours or more.

PREVALENCE OF COMMUTING

Several factors make it challenging to precisely characterize the preva

lence of commuting by pilots and other crew members across the airline industry. Some stakeholders who responded explicitly on this issue were reluctant to offer numerical estimates due to the ambiguity of defining “commuting.” For example, an official of a pilot association said: “preva

lence can’t be quantified, because ‘commuting’ can’t be defined.”

1 There may be some subjective biases in the coding and quantification of the data, due to a need for treating similar statements by various stakeholders as paraphrases of each other.APPENDIX C 

### 143

Even if one accepts a nominal definition of “pilot commuting” as air travel from home to domicile, there would still be challenging aspects to quantifying the prevalence of commuting because of its variability. At one extreme, for some airlines (e.g., some unscheduled charter passenger carri

ers) none of the pilots travel to work by air, because they all live within a 90-minute drive time of their domicile. At the opposite extreme, for other airlines nearly 90 percent of their pilots and other crew members travel to work by air, with 10-20 percent of them taking more than 2 hours for doing so, and 10 percent or more of them traveling at least 1,000 miles. For ex

ample, one major cargo carrier reported that for one of its principal domi

ciles, 73 percent of the pilots commute at least 6 hours by air. Commuting to a domicile may change because of airlines restructuring. For example, according to a pilot from one mainline carrier, commuting to one specific domicile increased by a factor of 2—from 30 to 60 percent—when flights operated from another domicile of that carrier were substantially reduced. Summarizing the responses from two airline associations, two pilot associations, two individual pilots, and nine individual airlines, the percent

ages of pilots who commute by air range from less than 5 percent to nearly 90 percent depending on a wide range of factors, including type of airline, particular domicile, and phase of airline restructuring. Some examples from respondents include a major cargo carrier that reported 47 percent of its pilots commute by air, and another major cargo carrier that reported commuting by air varies from 37 percent for one domicile to 88 percent for another domicile. In terms of distance, the number of long-distance air commutes (more than 1,000 miles) will likely continue to change over time given the economic dynamism of the industry.

REASONS FOR COMMUTING

The 10 stakeholders (2 airline associations, 2 pilot associations, 3 indi

vidual pilots, and 3 individual airlines) who explicitly addressed this issue noted several interrelated factors that explain why considerable numbers of pilots choose to commute from home locations that are several hours
and hundreds to thousands of miles from their domiciles. Those factors included the high cost of living at the domiciles (mentioned by six respon

dents); frequent domicile closings and future unpredictability of the airline industry (mentioned by five respondents); the desire to maintain family stability (mentioned by five respondents); low pay, especially for regional carriers (mentioned by four respondents); lifestyle preferences, e.g., for good weather and outdoor living (mentioned by three respondents); and absence of adequate coverage for costly moving expenses (mentioned by one respondent).

### 144 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### EFFECTS OF COMMUTING ON PILOT FATIGUE

Especially relevant to the committee’s central concerns were replies received from 12 stakeholders (2 airline associations, 2 pilot associations, 2 individual pilots, and 6 airlines) who explicitly commented on the effects of commuting on pilot fatigue. Although some degree of subjectivity and economic or personal self-interest undoubtedly colors these views, they nevertheless provide some useful perspectives. For example, six respondents acknowledged that commuting is a potentially fatiguing activity. Extending this line of commentary, five responded and explicitly noted or strongly hinted that fatigue can have negative effects on pilots’ performance of flight deck duties and ought to be addressed. At the same time, however, four respondents emphasized how chal

lenging it is to measure the effects of commuting on pilot readiness and fitness for duty, given the difficulties with defining “commuting,” quanti

fying its prevalence, and accounting for the heterogeneous ways in which pilots commute. In particular, six respondents noted that the fatiguing ef

fects of various types of commutes may be quite different. For example, a

90- minute commute through chaotic rush-hour traffic to reach a domicile airport might elevate stress and fatigue levels substantially more than would a relaxed 3-hour commute by air. One respondent also pointed out that there are individual differences among pilots in terms of how their com

mutes may affect them. With these sorts of caveats in mind, five respondents stated that com

muting done responsibly by flight crew members would not necessarily increase their fatigue levels significantly. Also, six respondents said that commuting pilots—especially those who travel relatively long distances— should plan their commutes for proper rest at their domiciles before report

ing for operational duty. In this vein, six respondents said that commuting directly into a work period from a remote location without proper rest along the way is a bad practice. Four respondents mentioned the unpre

dictability and stress-inducing aspects of direct, long, no-break commutes before duty assignments as exacerbating factors. Indeed, three respondents who discussed the fatigue issue in detail emphasized how stress itself is a primary contributor to the effects of commuting on pilot fatigue. Several stakeholders provided concrete examples in which pilot fatigue could result from problematic commuting. The following scenario from one respondent, redacted to provide confidentiality, is illustrative of input
to the committee:

A crewmember lives [on the East Coast], is based in [the Mid-West], and has an 11-day trip commencing [from the domicile] with a flight to [central Europe]. The initial flight is scheduled to depart in the morning at 0630 local time and arrive approximately 8 hours later. To arrive at domicile, the crewmember must leave home at 1900 local time in the evening [be

-APPENDIX C 

### 145

fore duty begins] and drive 2 hours to a major [East Coast] metropolitan airport. The crewmember then commutes via cockpit jump seat on a flight [to the domicile] that arrives there at 0015 local time [early in the next morning]. The crewmember now has almost five hours until report time for the first scheduled segment to [Europe]. Because of this imprudent, unregulated commuting practice, this crewmember [might] be awake, and for all practical purposes on duty, for over 21 hours upon landing [later that day] in Europe.



### Different points of view were provided to the committee by 12 respon

dents (2 airline associations, 2 pilot associations, 3 individual pilots, and 5 individual airlines) regarding the prevalence of problematic commuting. At one extreme, three respondents claimed that commuting almost never sig

nificantly increases pilot fatigue or affects pilots’ fitness for duty. Typifying these comments is the response from one pilot association, such as: “For commuting pilots, the impact of commuting on pilot fatigue is minimal. . . . Pilots, as professionals, carefully restrict their own activity and commute responsibly, because they are in the same airplane at the end of the day as their passengers.” The respondent added, “Pilots are professionals and as a group we ensure we show for work ‘fit to fly’.” One explanation offered for this optimistic view was that “the present method of pilots self-policing their own physiological needs has been, and still remains, an effective de

terrent of fatigue. . . . Pilots have ably borne this responsibility since man first took to the skies. . . . A pilot who has a difficult or lengthy commute to work recognizes the effect this will have on him . . . and will commute the day before to give himself time for adequate rest [before reporting for operational duty].” At the opposite extreme, three other respondents claimed that pilots’ commutes can sometimes be problematic. Illustrating this opposing view

point are the following quotes from input to the committee: “[T]he impact of commuting on pilot fatigue is not minimal.” “[T]he reality is that . . . pilots [sometimes] commute directly into a trip, allowing for more time at home and saving a few dollars. But this practice sacrifices rest and com

promises professionalism.” The official of one major cargo carrier wrote: “Many crew members commute directly into their [very early morning] duty assignments, which increases the level of fatigue and, in some cases, would increase their effective duty days beyond proposed FAR [Federal Aviation Regulation] maximums.” Such strong negative opinions were ex

pressed not only by some air carriers but also by individual pilots. Three respondents also noted that having to pay for hotel rooms and “crash pads” is a disincentive for responsible commuting. One respondent also mentioned that inadequate base facilities contribute to the effects of commuting on pilot fatigue and that the adverse effects of commuting are especially problematic for crew members of regional air carriers. One in

-

### 146 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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

SUGGESTIONS FOR HOW TO IMPROVE THE SYSTEM

Not surprisingly, 12 stakeholders (2 airline associations, 2 pilot as

sociations, 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 respon

dents 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 nonpuni

tive 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 provi

sion of paid moves, cost-of-living adjustments (COLAs), and positive-space tickets rather than merely jumpseats for flights used for commuting. Supple

menting 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.

### 147 

# Appendix D

Qualitative Analysis of Selected Public Comments to Proposed FAA Rules

The Department of Transportation and Federal Aviation Administra

tion (FAA) issued a Notice of Proposed Rulemaking (NPRM), “Flight Crew Member Duty and Rest,” on September 14, 2010. The FAA’s proposed rules were developed in response to requests made by President Obama and Congress to issue final regulations by August 1, 2011. The NPRM specifies “limitations on the hours of flight and duty time allowed for pilots to ad

dress problems relating to pilot fatigue” ( Federal Register , September 14, 2010), aspects of which relate to the commuting practices of pilots. The FAA invited the public to submit questions and comments about “any matters they consider relevant” and indicated that “we may incorpo

rate any such recommendation in a Final Rule” ( Federal Register , Septem

ber 14, 2010). The NPRM suggested that individuals provide comments and suggestions on specified topics:

• same or better protection against the problems of fatigue at a lower

cost;

• factors to consider in calculating the maximum of flight duty periods (FDPs);

• when to permit flight crew members or carriers to operate beyond a scheduled FDP;

• reliability of proposed reporting requirements;

• parameters of proposed reporting requirements;

• intervals between reporting requirements; and

• length of time for air carriers to report a problematic crew pairing.

### 148 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Some of the public comments and suggestions addressed the issue of com

muting and possible consequences of the proposed duty and rest rules on commuter pilots. It is those comments that we considered in our qualitative investigation.

ANALYTIC METHOD

Qualitative methods are used to investigate the why and how of deci

sion 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.

Sample

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 com

ment 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.,APPENDIX D 

### 149

2006; Fetterman, 2010). The continuous process of visiting and revisiting the narrative data, with an eye toward identifying similarities and differ

ences in meaning and content, results in an interpretive description of the range of meanings associated with each of the topics under investigation. Several procedures were systematically followed to analyze the data set and are presented below as Phases 1-4.

Phase 1 After an analyst completed four readings of the data set, each response was tagged by a one-sentence description. Especially vivid and “to-the-point” responses were highlighted for later consideration as illus

trative quotes. The responses were then sorted by relevance to each of thetopic areas under investigation (see above). Below is an example of a onesentence description (in italics) and of a quote for consideration.

As long as a pilot is fit for duty, the air carrier should not have the right to know whether or not a pilot commuted by air.

“I also disagree with the FAA’s views that discourage commuting. Pilots should have a right to live where they want to, and can af

ford it, rather than trying to exist in an expensive city, with poor family life situations. Pilots should not be open to discipline of any type as long as they show up fit for duty. As long as a pilot shows up fit for duty, the airline should not have any right to be concerned with whether a pilot commuted in or not.”

Phase 2 Preliminary codes were developed to experiment with sorting the content of the responses in each of the topic areas. “Coding” is the pro

cess of assigning descriptive labels, or codes, to “chunks” of the narrative data set (see Wolcott, 1994; Morse and Richards, 2002; Ulin et al., 2004; Crosby et al., 2006). For example, the following chunks of the narrative data (one-sentence descriptions [in italics] and quotes) have been assigned to the code “most pilots commute responsibly:” TABLE D-1 Number of Comments Reviewed and Selected for Inclusion in Analysis, by Key Words

Key Words Used Number of

Comments
Reviewed Number of

Comments
Selected

“commut”

“commute” 53 27

“commuting” 123 58
Total 176 85 

# }

### 150 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### It is rare for pilots to commute irresponsibly.

“I highly disagree with the FAA’s proposal. The FAA is attempting to control a vast minority of pilots that commute irresponsibly. The majority of pilots that I know, work with and offer jumpseats to, are commuting responsibly. I rarely have a pilot that cuts com

muting down to the wire with no back-ups or rest prior to report

time.”

The majority of pilots commute responsibly by using hotels or crash pads to rest.

“The high majority of pilots that I know, work with and have had in the jumpseat from other carriers demonstrate responsibility with reporting to duty fit. Most commute the evening before a trip the next day, others commute in the morning for an evening sign in and head to a hotel or crash pad to rest.”

Let the record speak for itself—thousands of pilots commute every day without incident.

“Any language that includes restrictions on where a pilot shall live compared to his base is not going to increase safety one bit. Let these professionals decide what is best for themselves about how to get adequate rest while still commuting. Their record speaks for it

self and thousands of pilots commute every day without incident.”

Phase 3 After six rounds of sorting with a variety of codes, final codes were selected to sort the content and meaning of the responses in each topic area. For example, the final code “frequent moving of domicile bases to new locations” was used to sort the following data:

During the last decade, industry

- related factors have forced airlines to move the location of their domicile bases on a frequent basis. In response, a majority of pilots no longer live close to their domicile bases and most feel they are forced to commute to keep the loca

tion of family residences stable and affordable. Estimates of one

half or more pilots commute to work by air. Long commutes are never desirable and the “commuter adaptation” to the industry

wide change is viewed by many pilots as being “part of the job” (N = 42)

. All of these respondents perceived the frequent changes in the location of domicile bases as the major reason for the increased numbers of commuters by air. One of the 42 respondents wrote: “[R]egional carriers open and close bases more frequently due to contracts with legacy carriers and their pilots are less likely to be
able to afford re-location.”APPENDIX D 

### 151

One respondent provided a brief overview of commuting and do

micile relocation practices during the 20th century and the early 21st century:

“In decades past, commuting was not permitted, and crews lived within driving distance of base. In that era, flight crews were paid about fifty to four hundred percent more in current dollars, allow

ing them to afford high cost of living areas. During this period, it was also less common for air carrier to change bases. When it did occur, it was rare and the economic impact wasn’t as great given the wages afforded to the crews. In the last decade, it has been more common for air carriers to open and close crew bases due to economic conditions and outsourcing agreements. Crews that had moved into bases were now required to commute, with relocation being both financially and emotionally difficult, if not impossible. A large portion of flight crews commute via airlines to their crew base over hundreds of miles, and even over several times zones. Regional carriers are especially prone to opening and closing bases due to contracts with legacy carriers, and their pilots are less likely to be able to afford relocation. The regional carrier I worked for
had numerous crew bases on the east coast to the mid-continent. Some of these crew bases had opened and closed several times. Also, Junior First Officers earning $20,000 to $30,000 annually were more prone to being assigned and reassigned to these bases.”

Phase 4 The last step of the qualitative analysis was the writing. During the writing process, the interpretive analysis is fine-tuned and streamlined to provide readers with an increasingly crisp presentation of the results.

RESULTS

This section presents the results of the analysis described above. See Table D-2 for a summary of results by number of respondents.

Definitions of Commuting

Thirty-nine respondents perceived the topic of commuting to be “an area of extreme ambiguity.” One of the respondents described a definitional ambiguity related to defining lengthy commutes by air or car:

Trying to mandate rest “in area” prior to duty is noble but burdensome. With the sprawl of today’s large metroplex population centers many lo

cal pilots have at least a 1-2 hr commute, when including the drive to the airport, parking, movement from parking area to crew sign-in areas, etc.

### 152 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### TABLE D-2 Summary of Results by Number of Respondents

Topic Number *

Definitions of CommutingCommuting is an area of extreme ambiguity, involving short- and longdistance commuters who travel by car and/or airplanes to arrive at

their domicile bases. 39

Prevalence of Commuting The majority of pilots commute to work via air. 7

* Between 50-60 percent of pilots commute to work via air. 6 The majority of part 135 pilots often choose to work at cargo carriers because they can avoid commuting long distances to their domicile

bases. 4 A minority of pilots commute to work over long distances. 2

Perceptions of Commuting as Problematic The majority of pilots have adapted to the energy demands of commuting and successfully manage their need for rest; their safety record speaks for itself. Commuting is now perceived as “part of the job.” 22 Commuting does not impact pilots’ fatigue level. 2

Characteristics and Examples of Responsible Commuting Commuters who report to duty too fatigued to safely fly are not responsibly commuting. 34 Commuters who can afford to schedule opportunities for resting in a bed, as needed, are responsible commuters. 24 Pilots who commute overnight on “red-eye” flights, and do not have opportunities to rest, most appropriately in a bed, are not properly rested for late afternoon or evening flights. 14 Pilots who are up early in the morning to commute to their domicile bases, and do not have opportunities to rest as needed, are often not fit for flight duty for a late afternoon or evening and are not adequately

rested. 11 The majority of pilots commute responsibly. 6 Very few pilots commute irresponsibly and those that do are employed by small regional carriers. 6

Perceptions of Commuting as Less of a Choice and More Related to

External Factors Frequent changes in the location of domicile bases are perceived as the major reason for the increased numbers of pilots commuting by air. 42 One of the consequences of dramatically lower pilot salaries over the past 25 years is that some low-paid commuters cannot afford the cost of resting in a hotel or shared apartment as needed. 24 Pilots who reflect on their years of experience residing close to their domicile bases and commuting short and/or long distances contend that postcommute rest in a bed, in a quiet, dark, and secluded area is necessary to combat the fatiguing effects of commuting, and as stated above, some low-paid commuters cannot afford to rest appropriately. 14APPENDIX D 

### 153

Topic Number *

The FAA should develop regulations mandating that air carriers subsidize the cost of rest accommodations to lower-paid pilots who want to rest following their commutes. 6 As a result of the above, if the proposed rules are authorized, pilots without difficult commutes will regularly fly with pilots who have been

awake for 24 hours. 2 Regional carriers open and close bases more frequently due to contracts with legacy carriers and their pilots are less likely to be able to afford

relocation. 1

Suggestions to the FAA by Respondents 1. The FAA should continue to mandate that pilots are held accountable for reporting to work fit for duty and not give airlines the authority to measure pilots’ fitness for duty, e.g., fatigue level, or to ask employees to report on the preflight activities of peers. 52 2. In addition to the proposed mandate for airlines to develop fatigue management plans and strategies, the FAA should also require airlines to implement no-fault fatigue policies. 27

3. Postpone regulations related to commuting until evidence-based, fatigue-mitigating practices are identified. Not enough is known about the current number of pilots commuting by air, their commute flight patterns (distances covered and the time it takes), and their rest patterns prior to reporting for duty. There is also little research evidence about the relationships between commuting practices and job performances. 15 4. The FAA should mandate that airline companies provide positive space to pilots commuting by air, if requested, because ‘space-available’ travel can be highly stressful. 11 5. To best ensure public safety, the FAA should mandate that air carriers are responsible for calculating the start of flight duty periods differently for pilots who commute by air. 8

*The total number of respondents was 85. In many cases, individually submitted comments contained multiple opinions of relevance. As a result, over 400 statements relevant to the study were considered. 

### TABLE D-2 Continued

For instance, I’m relatively “close” to the airport in DFW, but usually give myself 1 hr for the drive in and bus ride from the employee lot. Those in slightly more distant suburbs or exurbs might be unrealistically burdened by a 1.5 hr commuting limit.



### Prevalence of Commuting

Perceptions about the prevalence of commuting were discussed primar

ily in the context of respondents’ opinions about the proposed on-base rest

### 154 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### requirement for commuters. There were 16 respondents on this topic: 6 said that between 50-60 percent of pilots commute by air to work; 7 said that “a majority” commute by air; 1 wrote that the vast majority of pilots com

mute by air; and 2 said that a “minority of pilots commute to work over long distances.” One of the respondents in the last group made a distinction between short- and long-distance commuters, estimating that “many pilots commute 11⁄2 to 3 hrs via airplane, while only a small percentage of pilots commute long distances to their home domicile.” A pilot with more than 30 years of industry experience provided a historical perspective on the recent increase in the number of crew members who commute by air to their domiciles:

In the last decade, it has been more common for air carriers to open and close crew bases due to economic conditions and outsourcing agreements. Crews that had moved into bases were now required to commute, with relocation being both financially and emotionally difficult, if not impos

sible. A large portion of flight crews commute via airlines to their crew base over hundreds of miles, and even over several times zones.



### One respondent, representing the views of an organization, provided an overview of issues related to commuting in the context of the airline industry:

Commuting is common in the airline industry, in part because of life-style choices available to pilots by virtue of their being able to fly at no cost to their duty station, but also because of economic reasons associated with protecting seniority on particular aircraft, frequent changes in the flight crew member’s home base, and low pay and regular furloughs by some carriers that may require a pilot to live someplace with a relatively low cost of living.



### Three respondents agreed with an experienced cargo pilot who shared his rationale for having chosen to work for a long time for a cargo com

pany: “[T]he overwhelming majority of part 135 pilots live in close prox

imity to their assigned bases or points of departure. Most commonly, this is specifically why pilots choose to fly part 135, as it allows them to spend their off duty hours at their own residences.” Respondents made several distinctions in the types of commuting: long-distance commuting by air; shorter distance commuting by air (1.5-3 hours); and varying number of hours/car commute (2-4 hours), which are not covered by the proposed regulation.APPENDIX D 

### 155

Perceptions of Commuting as Problematic

Twenty-two respondents did not perceive commuting to be problematic and did not see the need for additional regulations about mandated oppor

tunities for rest. Their responses included statements that commuters had “adapted to the fatigue challenges of commuting,” that “commuting is part of the job,” and that “commuting is a way of life and many of us have no other way to get to work. We can continue to manage our rest as we have learned to do for decades.” Eighteen of the respondents argued that, as one respondent wrote, “the safety record of commuters speaks for itself.” Two respondents did not consider same-day commuting to be a prob

lem, with one contending that this type of commuting “does not impact crew members’ fatigue levels.” However, another respondent wrote that “a crew member who is up all day before an evening departure is not properly rested.” One representative of an airline carrier wrote that commuting is a “significant issue in fatigue and its mitigation” and also that “as carriers de

velop training programs for FRMP and for this regulation, commuting must be addressed. This will place significant pressure on labor-management relations. However, we see no regulatory solution at this time.”

Characteristics and Examples of Responsible Commuting

Six respondents agreed that the majority of pilots commute responsibly. Twenty-four respondents agreed that those who commute long distances and can afford to pay hotels or portions of the rent for apartments (“crash pads”) and do rest are responsible commuters. Thirty-four respondents wrote comments that agreed with one, that “commuters who report to duty too fatigued to safely fly are not respon

sible commuters.” Fourteen respondents wrote comments that agreed with one, who said that pilots who commute overnight on “red eye” flights and do not have opportunities to rest are “not properly rested for late afternoon or evening flights.” Eleven respondents wrote that pilots who are up early in the morning to commute to their domicile bases without opportunities to rest are often not fit for duty for flights later in the day. Six respondents commented in the vein of one who wrote that, “very few pilots commute irresponsibly, and those that do, are employed by small regional carriers.” One respondent suggested that the desire to maximize the number of days off can lead some commuters to report to duty not fully fit, noting
that:

there are a very small percentage of pilots (mostly employed at small re

gional carriers) who choose to commute at irresponsible times, largely due to income restraints (unable to afford to pay for lodging) and not wanting to have fewer days off within the month (lowering personal quality of life).

### 156 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Commuting Related to External Factors

Many respondents to the NPRM said that commuting decisions are related less to pilots’ choices than to two external factors: frequent mov

ing of domicile bases to new locations and a significant decrease in salary levels, for both veteran and new pilots, in recent decades. The rest of this section presents our summary of the issues, in italics, and quotes on the subject from respondents.

Frequent Moving of Domicile Bases to New Locations

During the last decade, industry

- related factors have forced airlines to move the location of their domicile bases on a frequent basis. In response, a majority of pilots no longer live close to their domicile bases and most feel they are forced to commute longer distances to keep the location of family residences stable and affordable. Estimates of one

- half or more pi

lots commute to work by air. Long commutes are never desirable and the “commuter adaptation” to the industry

- wide change is viewed by many pilots as being “part of the job.” (N = 42)



### All of the respondents on this issue perceived the frequent changes in the location of domicile bases as the major reason for the increased numbers of long-distance commuters. One of the respondents stated that “regional carriers open and close bases more frequently due to contracts with legacy carriers and their pilots are less likely to be able to afford re-location.” One respondent provided a brief overview of commuting and domicile relocation practices during the 20th century and the early 21st century:

In decades past, commuting was not permitted, and crews lived within driving distance of base. In that era, flight crews were paid about fifty to four hundred percent more in current dollars, allowing them to afford high cost of living areas. During this period, it was also less common for air carrier to change bases. When it did occur, it was rare and the economic impact wasn’t as great given the wages afforded to the crews.

In the last decade, it has been more common for air carriers to open and close crew bases due to economic conditions and outsourcing agreements. Crews that had moved into bases were now required to commute, with re

location being both financially and emotionally difficult, if not impossible. A large portion of flight crews commute via airlines to their crew base over hundreds of miles, and even over several times zones. Regional carriers are especially prone to opening and closing bases due to contracts with legacy carriers, and their pilots are less likely to be able to afford relocation. The regional carrier I worked for had numerous crew bases on the east coast to the mid-continent. Some of these crew bases had opened and closedAPPENDIX D 

### 157

several times. Also, Junior First Officers earning $20,000 to $30,000 an

nually were more prone to being assigned and reassigned to these bases.



### Deceases in Salary Levels

Pilot salaries have significantly decreased over the past decades. As a result, some low

- paid pilots are not able to afford the cost of resting in a hotel or a shared apartment (“crash pad”) prior to starting work on a

same

- day flight. (N = 24)



### Fourteen respondents agreed that proper rest for pilots meant sleeping or resting in a bed in a quiet location. One respondent—with “over 30 years of continuous experience as a line pilot . . . the first 15 of those years spent residing in domicile and the more recent 15 years living on the West Coast and commuting” to several domicile locations on the East Coast and the Midwest—represented the viewpoints of the respondents on this issue:

[E]xperience has shown me that the most important antidote to combat

ing fatigue is the opportunity for sleep when needed. It does not take an expensive study to tell us what is already intuitively known—that adequate rest requires an adequate bed—in a quiet, dark, and secluded area that is isolated in such a manner as to not be subject to disturbance.



### One respondent argued that there would be an important consequence of instituting the proposed NPRM due to the low pay of some pilots who cannot afford to pay for a place to rest: “[I]f the new rules go through as written, those of us who don’t have a more difficult commute will be fly

ing with pilots who will regularly be up for 24 hours.” A solution to the problem was proposed by six respondents who suggested that the FAA should require airlines to subsidize accommodations at low or no cost to the individual commuters. As stated by one of the six: “[T]here just needs to be a provision for commuter pilots to have adequate accommodations to rest. I suggest that air carriers pay for hotels for the low paid pilots who are forced to commute.” One respondent contended: “[I]f the air carrier was responsible for the rest of commuters by providing them with lodging for a period prior to the start of duty, the rule [to rest] would be easily
enforceable.” Nine respondents referred to their perceptions of the role of low-paid, fatigued pilots in the Colgan crash. One of them said that, “the event that caused this [proposed] rule change was the Colgan accident . . . its cause was inexperienced pilots and a crew that could not afford to sleep in a bed. Their commute to work was not the problem, low pay was.”

### 158 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Suggestions to the FAA

Pilots’ Responsibility to Report Fit for Duty

To date, the FAA and airline companies have held pilots responsible for assessing their own fitness for duty status. If unfit for any reason, regula

tions require a pilot to step aside and report for duty as a sick person, temporarily unfit for duty. The FAA should continue to mandate that pilots are held accountable for reporting to work fit for duty and not give airlines the authority to measure pilots’ fitness for duty, e.g., fatigue level, or to ask employees to report on the pre

- flight activities of peers. (N = 52)



### The strong support for this idea appears to be related to three major factors: (1) pilots’ professional pride in being responsible for assessing their own level of fitness for duty (N = 45); (2) the view that individuals alone are responsible for their life circumstances and have the right to privacy in all possible matters (N = 30); (3) the contrary view (to 2) that airlines are responsible for ensuring safe working conditions of their employees (N = 11). One of the respondents noted that, “pilots are the experts in how fit for duty they are or are not—regulations that dictate where a pilot must live or be before duty would be erroneous at best, would not enhance safety, and would place an unreasonable burden on pilots.” Another respondent described how reporting fit for duty is a source of professional pride and adult status for pilots and then made the case that regulations to involve airlines in this assessment are an “onerous intrusion into lives of pilots.” This respondent wrote:

Pilots are scrutinized more than probably any other profession, includ

ing and especially doctors. We are trusted with the lives of hundreds of people at a time, yet I fear the FAA is about to enact a set of regulations that would treat us like children by not allowing us the responsibility of determining for our own self whether or not we are fit for duty. Any such regulations would be a one-size-fits-all, onerous intrusion into the lives of pilots that would do nothing to increase fitness for duty. We are already held accountable for our actions while on duty; I think we can handle the responsibility of knowing how to show up in a condition of fitness for that duty.



### Another respondent wrote:

The new regulation, as written, may put pilots in a position of changing their life in a way that will NOT enhance safety, and may actually decrease it. Commuting to work in a coach seat where rest is possible, is no more dangerous than a pilot that works in his yard for 5 hours before he reports for duty. Yet, the first pilot is under scrutiny because he commuted and the second pilot is not under scrutiny. Pilots are the experts in how fit forAPPENDIX D 

### 159

duty they are or are not. Please ensure that all liability for pilots ensuring fitness for duty is removed from this NPRM. Further, please remove all regulation that might dictate where a pilot must live or be before duty. These regulations would be erroneous at best, would not enhance safety, and would place an unreasonable burden on pilots.



### Another respondent expressed a special concern for rights to privacy, stating that, “as long as a pilot shows up fit for duty, the airline should not have any right to be concerned with whether a pilot commuted in or not.” Yet a somewhat different comment came from a respondent who wrote that “it is best to ensure crewmembers are not exposed to fatiguing conditions rather than assess them after fatigue occurs.” One respondent discussed the separate domains of responsibility be

tween labor and management:

The concept of the air carrier’s ability to manage an individual employee’s fitness to fly is erroneous. Airlines have direct control over the time of day of the operations, the number of takeoffs and landings scheduled, and con

trolling the effects of crossing multiple time zones. The flight crew member is the only one who can control the effects of commuting.



### Forty-nine individual respondents and five respondents who repre

sented the views of their organizations emphasized the importance of not tracking pilots’ arrival and departure times at their domiciles because it is an unwarranted invasion of privacy. As one organizational respondent

wrote:

We support the concept that a flight crewmember must be fit for duty prior to operating an aircraft. The fitness for duty is and must be a joint responsibility of the certificate holder and the flight crew member. While it is important that both the flight crew member and the certificate holder be involved in fit for duty determinations, we cannot create an environ

ment that requires tracking and reporting the activities of an individual flight crew member prior to their reporting for flight duty. Such tracking would be difficult and costly for the certificate holder and constitute an unwarranted invasion of the personal privacy of the flight crew member.



### Two of the individual respondents pointed out that tracking is not the only option for ensuring responsible commuting; one wrote:

While it is important for all stakeholders to be involved in the fitness-forduty equation, we simply cannot operate in an environment that places a priority on the tracking and reporting of commuting over educating and encouraging responsible, jointly managed commuting policies.

### 160 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### Another respondent further questioned the FAA on the issue of individual rights and responsibilities:

[T]o start with, whatever happened to personnel responsibility? Existing rules and regulations require a crew member to show up fully rested and ready for work. That is a crew member responsibility, not a company responsibility. Commuting needs to be a crew members’ responsibility.



### Six respondents discussed the role of personal choice and responsibility in commuting and other off-the-clock behaviors. One wrote:

[C]ommuting should not be touched. Pilots are required to show up for work rested and fit to fly. That is the law. If they choose to commute all night or stay up and watch television all night at home before work, then they should call in sick. That is already the mandate. Making more rules does not help anything.



### Fatigue Policies

In addition to the proposed mandate for airlines to develop fatigue man

agement plans and strategies, the FAA should also require airlines to implement no

- fault fatigue policies. (N = 27)



### Several respondents expressed the view that many pilots fear negative consequences if they report unfit to fly, due to fatigue, on the day of flight.One respondent described the advantages of instituting a “no-questionsasked” fatigue policy:

Getting hired at Southwest Airlines (SWA) represents reaching my goal
destination. One of the most amazing and effective policies for combating fatigue that the pilots at SWA have is a no-questions-asked fatigue policy. What this means is that if a pilot calls in fatigued, s/he is done. Scheduling will pull the pilot from the trip and the pilot’s job is not in jeopardy!!! The pilot is not going to be disciplined or penalized for calling in fatigued.

Pilots have a great deal of responsibility, and what an outstanding policy like this does is to allow the pilot to focus on the most important prior

ity, that of public safety, while recognizing and accommodating to his/her personal limitations. In my five years at SWA, I have not once called in fatigued. I have called in sick a few times, and I have only praise for the courteous, professional treatment I have received in those circumstances. No pressure to get back to work until ready to do so. Based on those ex

periences, I have full confidence that the no-questions-asked fatigue policyAPPENDIX D 

### 161

works as promoted. A pilot who thinks his/her job is in jeopardy is not going to call in fatigued!



### Another respondent expressed disappointment that the proposed NPRM did not address a basic need of pilots:

I am disappointed with the FAA’s view on pilot commuting. I’ve read that 60% of pilots commute by air to work. If the FAA believes that fatigue mitigation is a joint responsibility between crewmembers and the airline, then the airlines need to be required to have some type of a non-punitive fatigue policy.



### A third respondent advocated for crew members’ right to “cry Uncle” when fatigued:

The creation of a no-fault fatigue program where a crewmember may, without fear of discipline or any financial considerations, declare himself unfit to fly (due to fatigue) and be provided a rest period accordingly, would mitigate day-of-flight fatigue issues. Consider the long day with bad weather, deicing, holding, diverting, etc. Giving crew the opportunity to cry, “Uncle” would be invaluable.

It is a crewmember’s responsibility to arrive rested and ready prior to flight and properly modifying the Rest and Duty Time regulations will give them more tools to proactively manage their fatigue. However, if a crew becomes fatigued they should not feel pressured to complete a flight segment nor penalized for any reason. It is a crewmember’s responsibility to arrive rested and ready prior to flight and properly modifying the Rest and Duty Time regulations will give them more tools to proactively man

age their fatigue.



### Inadequate Data on Commuting

Postpone regulations related to commuting until evidence

- based fatigue

mitigating practices are identified. Not enough is known about the cur

rent number of pilots commuting by air, their commute flight patterns (distances covered and the time it takes), and their rest patterns prior to reporting for duty. There is also little research evidence about the relation

ships between commuting practices and job performances. (N = 15)



### The lack of information about commuting practices and their relation

ships with job performance was the reason behind the advise to delay any regulations. Two of the 15 respondents identified another topic missing from the knowledge base, which one characterized as “the lack of reliable estimates of how fatigued pilot commuters become as their flight duty

### 162 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### periods progress, especially for long distance commuters.” Five of the 15 respondents, representing the views of organizations, commented on lack of supporting data in the Advisory Circular, AC 120-FIT; one wrote:

The practice of personal commuting must remain each flight crew mem

ber’s responsibility to be fit for duty for every flight duty period to which they are assigned. The FAA’s accompanying Advisory Circular, AC 120- FIT, should clearly be withdrawn. It is premature, wholly lacks any sci

entific study or supporting data, and raises the same issues with regard to incorrectly involving certificate holders in the commuting practices of their flight crew members.



### One of the 15 respondents provided an explanation as to why indi

vidual variation in experiencing fatigue is a key factor in understanding predictors of fatigue among pilots: “[F]atigue is definitely a threat in our environment, but it is so individual and so unique. I have had 20 hour layovers with a good 8 hour sleep and find myself fatigued sometimes.” Given the knowledge gaps, another respondent discussed an alternative to regulatory mandates. “[A]n advisory approach may be more effective than a regulatory approach at this time.”

Required Space for Commuting

The FAA should mandate that airline companies provide positive space to pilots commuting by air, if requested, because ‘space available’ travel can be highly stressful. (N = 11)



### One of the 11 respondents noted that “a number of cargo airlines already provide positive space for all pilots to whatever domicile that the airline requires them to be based at.” Three respondents said that the FAA should provide pilots with positive space; as one wrote, “so they can plan their commutes with more accuracy thus giving them the chance to get the required rest before their flight.” Another respondent elaborated this point of view, concluding:

For pilots who choose to commute, give them the option to add deadhead legs both before and after their scheduled trips. These deadhead trips would get the pilots from their homes to their domicile bases with much less stress and without the uncertainty of space available travel. This in

crease in quality of life would take away much of the risk in irresponsible commuting. The decreased stress would also decrease one of the factors leading to fatigue.APPENDIX D 

### 163

Duty Period Calculations

To best ensure public safety, the FAA should mandate that air carriers are responsible for calculating the start of flight duty periods differently for pilots who commute by air. (N = 8)



### Two respondents expressed the need for FAA action; one wrote that “airline management will not voluntarily safely schedule crews unless they are under threat from the FAA.” Two pilots commented on the fact that some pilots commute over one or two time zones to their domiciles. One of them wrote that the public “should be protected from pilots commuting to work from distant locations” and that it was “unacceptable to have a pilot reside in Florida and report for duty in Los Angeles after a long com

muting flight.” All eight respondents said that public safety would increase if the flight schedules factored in pilots’ time zone acclimation. One of them reported that “the legacy carrier I worked for took the issue of fatigue very seri

ously—schedules and assignments were made with consideration of circa

dian rhythms, time zone changes, and prior schedules.” Five respondents argued in favor of commuter-specific rules about the start of duty periods. One wrote that rules “should be implemented when commuting exceeds a defined number of miles and/or hours spent commut

ing.” One suggested that “the only clear solution is a regulation requiring pilots to commute ‘on-duty’ in terms of calculating rest prior to flight.” Also in this vein, one of them thought that the duty period “should begin one hour prior to their intended commuting flight and should not go over 12 hours, including commuting and working segments, and up to 14 hours with crew consent.” Another of the five respondents concluded that “it is then only fair, in order to protect the public, to enforce the regulation by subjecting a commuter pilot to random checks.”

### 165 

# Appendix E

Mainline Airlines Departures by City

This appendix presents the committee’s analysis of changes in the number of aircraft departures discussed in Chapter 2 for mainline airlines. Figures E-1 through E-24, ordered alphabetically by airline, show total departures by airport code (refer to Table E-1 for corresponding cities) and by airline, in the cities most frequently served by that airline and thus in the cities most likely to serve as domiciles for pilots. The data used for this analysis were scheduled aircraft departures taken from Air Carrier Summary: T3: U.S. Air Carrier Airport Activity Statistics provided by the Bureau of Transportation Statistics (n.d.-a) of the U.S. Department of Transportation. The data were from the third quarter of 2000, 2005, and 2010. All carriers that reported more than 20,000 aircraft departures in the third quarter of 2010 were examined. This group consisted of 12 mainline airlines. Two of the airlines were all-cargo airlines, FedEx and UPS, and the rest were passenger airlines.

### 166 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



# Figure E-1.eps bitmap , labels redr aw n 25,000

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### FIGURE E-2 Air Tran total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE E-1 Air Tran departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 167



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### FIGURE E-3 Alaska departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-4 Alaska total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 168 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE E-5 American departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-6 American total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 169



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### FIGURE E-7 Continental departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-8 Continental total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 170 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE E-9 Delta departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-10 Delta total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 171



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### FIGURE E-11 FedEx departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-12 FedEx total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 172 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE E-13 Frontier departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-14 Frontier total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 173



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### FIGURE E-15 JetBlue departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-16 JetBlue total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 174 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE E-17 Southwest departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-18 Southwest total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 175



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### FIGURE E-19 United departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-20 United total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 176 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE E-21 UPS departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-22 UPS total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX E 

### 177



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### FIGURE E-23 US Airways departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE E-24 US Airways total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 178 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



### TABLE E-1 Airport Codes for Airline Departure Analysis

Codes Airport City State

ABE Lehigh Valley International Allentown PA

ABQ Albuquerque International Albuquerque NM

ABR Municipal Aberdeen SD

ACK Nantucket Memorial Nantucket MA

AFW Fort Worth Alliance Fort Worth TX

ALS Municipal Alamosa CO

ANC Ted Stevens Anchorage International Anchorage AK

ASE Aspen Aspen CO

ATL Hartsfield-Jackson Atlanta International Atlanta GA

ATW Outagamie County Appleton WI

AUS Austin-Bergstrom International Austin TX

AVL Asheville Regional Fletcher NC

AZO Kalamazoo/Battle Creek International Kalamazoo MI

BDL Bradley International Windsor Locks CT

BFI Boeing Field/King County International Seattle WA

BHM Birmingham Birmingham AL

BIL Billings Billings MT

BJI Bemidji Bemidji MN

BNA Nashville International Nashville TN

BOI Boise Air Terminal/Gowen Field Boise ID

BOS Logan International Boston MA

BRD Brainerd Lakes Regional Brainerd MN

BTR Ryan Baton Rouge LA

BTV Burlington International Burlington VT

BUF Buffalo Niagara International Buffalo NY

BWI Baltimore/Washington International Thurgood Marshall Baltimore MD

CAE Metropolitan Columbia SC

CAK Akron/Canton Regional Akron/Canton OH

CHA Lovell Field Chattanooga TN

CHO Albemarle Charlottesville VA

CHS Charleston International Charleston SC

CLE Hopkins International Cleveland OH

CLT Charlotte Douglas Charlotte NC

CMH Port Columbus International Columbus OH

COS Colorado Springs Colorado Springs CO

CRP Corpus Christi International Corpus Christi TX

CRW Yeager Charleston WVAPPENDIX E 

### 179

Codes Airport City State

CVG Cincinnati/Northern Kentucky Covington KY

CWA Central Wisconsin Wausau WI

DAL Love Field Dallas TX

DAY James Cox Dayton International Dayton OH

DCA Ronald Reagan Washington National Washington DC

DDC Dodge City Municipal Dodge City KS

DEN Denver International Denver CO

DFW Dallas/Fort Worth International Dallas TX

DIK Dickinson Dickinson ND

DSM Des Moines International Des Moines IA

DTW Detroit Metropolitan Wayne County Detroit MI

EFD Ellington Field Houston TX

EUG Eugene Eugene OR

EWB New Bedford New Bedford CT

EWR Newark Liberty International Newark NJ

FAI Fairbanks International Fairbanks AK

FAT Fresno Air Terminal Fresno CA

FLL Fort Lauderdale/Hollywood International Fort Lauderdale FL

FMN Municipal Farmington NM

FSD Joe Foss Field Sioux Falls SD

GCC Campbell County Gillette WY

GEG Spokane International Spokane WA

GJT Walker Field Grand Junction CO

GNV Gainesville Regional Gainesville FL

GPT Gulfport-Biloxi International Gulfport MS

GRR Gerald R. Ford International Grand Rapids MI

GSO Piedmont Triad International Greensboro NC

GSP Greenville-Spartanburg International Greenville-Spartanburg SC

GTR Golden Triangle Regional Columbus OH

HHH Hilton Head Hilton Head SC

HOU William P. Hobby Houston TX

HPN Westchester County White Plains NY

HSV Huntsville International-Carl T. Jones

Field Huntsville AL

HYA Barnstable Hyannis MA

IAD Washington Dulles International Washington DC

IAH George Bush Intercontinental Houston TX 

### TABLE E-1 Continued

continued

### 180 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Codes Airport City State

IND Indianapolis International Indianapolis IN

ITH Tompkins County Ithaca NY

JAX Jacksonville Jacksonville FL

JFK John F Kennedy International New York NY

JNU Boundary Bay Juneau AK

LAR General Brees Field Laramie WY

LAS McCarran International Las Vegas NV

LAX Los Angeles International Los Angeles CA

LBL Municipal Liberal KS

LGA LaGuardia New York NY

LGB Long Beach Municipal Long Beach CA

LIH Lihue Kauai Island HI

LNK Lincoln Lincoln NE

LWS Nez Perce County Regional Lewiston ID

MBS MBS International Saginaw MI

MCI Kansas City International Kansas City KS

MCO Orlando International Orlando FL

MDT Harrisburg International Harrisburg PA

MDW Midway Chicago IL

MEM Memphis International Memphis TN

MFR Rogue Valley International-Medford Medford OR

MGM Dannelly Field Montgomery AL

MHT Manchester-Boston Regional Manchester NH

MIA Miami International Miami FL

MKE General Mitchell International Milwaukee WI

MLI Quad-City Moline IL

MSN Dane County Regional Madison WI

MSP Minneapolis-St. Paul International Minneapolis MN

MVY Martha’s Vineyard Vineyard Haven MA

MYR Myrtle Beach International Myrtle Beach SC

OAK Oakland International Oakland CA

OGG Kahului Maui HI

OKC Will Rogers World Oklahoma City OK

OMA Eppley Airfield Omaha NE

ONT Ontario International Ontario CA

ORD Chicago O’Hare International Chicago IL 

### TABLE E-1 ContinuedAPPENDIX E 

### 181

Codes Airport City State

ORF Norfolk International Norfolk VA

PBI Palm Beach International West Palm Beach FL

PDX Portland International Portland OR

PFN Bay County Panama City FL

PHL Philadelphia International Philadelphia PA

PHX Sky Harbor International Phoenix AZ

PIT Pittsburgh International Pittsburgh PA

PLN Emmet County Pellston MI

PRC Prescott Prescott AZ

PSC Tri-Cities Pasco WA

PVC Provincetown Provincetown MA

PVD T.F. Green Providence RI

PWM International Jetport Portland ME

RAP Regional Rapid City SD

RDM Roberts Field Redmond OR

RDU Raleigh-Durham International Raleigh-Durham NC

RFD Greater Rockford Rockford IL

RIC Richmond International Richmond VA

RKD Knox County Regional Rockland ME

RKS Sweetwater County Rock Springs WY

RNO Reno-Tahoe International Reno NV

ROA Roanoke Regional Roanoke VA

ROC Greater Rochester International Rochester NY

RSW Southwest Florida International Fort Myers FL

SAN San Diego International San Diego CA

SAT San Antonio International San Antonio TX

SBA Municipal Santa Barbara CA

SBN South Bend Regional South Bend IN

SBY Wicomico Regional Salisbury-Ocean City MD

SCE University Park State College PA

SDF Louisville International (Standiford Field) Louisville KY

SEA Seattle-Tacoma International Seattle WA

SFO San Francisco International San Francisco CA

SHR Sheridan Sheridan WY

SHV Regional Shreveport LA

SJC Mineta San Jose International San Jose CA 

### TABLE E-1 Continued

continued

### 182 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Codes Airport City State

SJU Luis Munoz Marin International San Juan PR

SLC Salt Lake City International Salt Lake City UT

SMF Sacramento International Sacramento CA

SNA John Wayne Santa Ana CA

STL Lambert-St. Louis International St Louis MO

STT Cyril E. King Charlotte Amalie, St.

Thomas VI

STX Henry E. Rohlsen Christiansted, St Croix VI

SYR Syracuse Hancock International Syracuse NY

TEX Telluride Regional Telluride CO

TLH Tallahassee Regional Tallahassee FL

TPA Tampa International Tampa FL

TUL Tulsa International Tulsa OK

TUS Tucson International Tucson AZ

TYS McGhee Tyson Knoxville TN

VPS Eglin AFB Valparaiso FL

XNA Northwest Arkansas Regional Fayetteville AR

YKM Yakima Air Terminal Yakima WA 

### TABLE E-1 Continued

### 183 

# Appendix F

Regional Airlines Departures by City

This appendix presents the committee’s analysis of changes in the number of aircraft departures discussed in Chapter 2 for regional airlines. Figures F-1 through F-36, ordered alphabetically by airline, show total de

partures by airport code (refer to Table E-1 in Appendix E for correspond

ing cities) and by airline, in the cities most frequently served by that airline and thus in the cities most likely to serve as domiciles for pilots. The data used for this analysis were scheduled aircraft departures taken from Air Carrier Summary: T3: U.S. Air Carrier Airport Activity Statistics provided by the Bureau of Transportation Statistics (n.d.-a) of the U.S. Department of Transportation. The data were from the third quarter of 2000, 2005, and 2010. All carriers that reported more than 20,000 aircraft departures in the third quarter of 2010 were examined. This group consisted of 18 regional airlines.

### 184 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE F-2 Air Wisconsin total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE F-1 Air Wisconsin departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

### 185



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### FIGURE F-4 American Eagle total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE F-3 American Eagle departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 186 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE F-5 Atlantic SE departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-6 Atlantic SE total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

### 187



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### FIGURE F-8 Cape Air total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE F-7 Cape Air departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 188 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE F-9 Chautauqua departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-10 Chautauqua total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

### 189



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### FIGURE F-11 Colgan departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-12 Colgan total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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### FIGURE F-13 Comair departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-14 Comair total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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### FIGURE F-15 Expressjet departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-16 Expressjet total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 192 THE EFFECTS OF COMMUTING ON PILOT FATIGUE



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### FIGURE F-17 Great Lakes departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-18 Great Lakes total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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### FIGURE F-20 Horizon total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a). FIGURE F-19 Horizon departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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### FIGURE F-21 Mesa departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-22 Mesa total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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### FIGURE F-23 Mesaba departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-24 Mesaba total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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### FIGURE F-25 Piedmont departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-26 Piedmont total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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### FIGURE F-27 Pinnacle departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-28 Pinnacle total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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### FIGURE F-29 PSA departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-30 PSA total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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FIGURE F-32 Republic total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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### FIGURE F-33 Shuttle America departures by city. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-34 Shuttle America total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).APPENDIX F 

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FIGURE F-36 SkyWest total departures. SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

### 203 

# Appendix G

Biographical Sketches of Committee Members and Staff

Clinton V. Oster, Jr. ( Chair ) is a professor at the School of Public and En

vironmental Affairs at Indiana University. Previously, he served as director of the Transportation Research Center and as associate dean at the School of Public and Environmental Affairs at Indiana University. His research focuses on air traffic management and aviation infrastructure, with an em

phasis on aviation safety. His research also includes airline economics, air

line competition policy, and energy policy. He has been a consultant to the U.S. Department of Transportation, the Federal Aviation Administration, the National Aeronautics and Space Administration (NASA), the European Bank for Reconstruction and Development, state and local governments, and private-sector companies in the United States, Canada, the United Kingdom, Russia, and Australia. He is a member of the National Aviation Advisory Group of the U.S. Government Accountability Office, and he has been an expert witness for the Environment and Natural Resource Division and the Antitrust Division of the U.S. Department of Justice. He received a B.S.E. in chemical engineering from Princeton University, an M.S. in urban and public affairs from Carnegie Mellon University, and a Ph.D. in econom

ics from Harvard University.

Benjamin A. Berman is a senior research associate in the Human Systems Integration Division at the NASA Ames Research Center (affiliated through San Jose State University), and he is a pilot for a major U.S. air carrier with 9,000 hours of flight experience. Before returning to professional flying in 2001, he was on the staff of the National Transportation Safety Board (NTSB), where he served as the chief of the Major Investigations Division

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### and led the Operational Factors Division (responsible for flight opera

tions, air traffic control, and meteorology investigations). At NTSB, he also served as the flight operations investigator for major cases, including the USAir B-737 accident in Pittsburgh and the ValuJet DC-9 accident in the Everglades, and he managed flight crew human factors research projects. He holds an airline transport pilot certificate with type ratings for the Boe

ing 777, Boeing 737, Embraer 120, and Dornier 228. He received an A.B. summa cum laude in economics from Harvard College.

J. Lynn Caldwell is a senior research psychologist for the U.S. Air Force Re

search Laboratory, currently stationed at Wright-Patterson Air Force Base in Ohio. Previously, she was with the U.S. Army’s Aero medical Research Laboratory, where she conducted numerous simulator and in-flight in

vestigations on fatigue countermeasures and circadian rhythms in rated military pilots. She has also been a member of the Warfighter Fatigue

Counter measures Program and a distinguished visiting scholar at the U.S. Air Force Academy. She has served as a fatigue consultant for vari

ous U.S. Air Force commands and other military and civilian groups. She frequently provides fatigue management workshops, safety brief

ings, and training courses to aviation personnel, flight surgeons, com

manders, and safety officers. She is certified as a sleep specialist by the American Board of Sleep Medicine. She received a Ph.D. in experimental psychology from the University of Southern Mississippi.

David F. Dinges is a professor and chief of the Division of Sleep and Chro

nobiology and director of the Unit for Experimental Psychiatry in the De

partment of Psychiatry and associate director of the Center for Sleep and Circadian Neurobiology at the Perelman School of Medicine, University of Pennsylvania. He also leads the neurobehavioral and psychosocial factors team for the National Space Biomedical Research Institute. His research focuses on the physiological, neurobehavioral, and cognitive effects of sleep loss, disturbances of circadian biology, and stress, and the implications of these unmitigated effects on health and safety. He has been president of the U.S. Sleep Research Society and of the World Federation of Sleep Research and Sleep Medicine Societies, and he has served on the board of directors of the American Academy of Sleep Medicine and the National Sleep Founda

tion. He is currently editor-in-chief of Sleep . His awards include the 2004 Decade of Behavior Research Award from the American Psychological Association and the 2007 NASA Distinguished Public Service Medal. He has an A.B. in psychology from Saint Benedict’s College, an M.S. in physi

ological psychology from Saint Louis University, an honorary M.A. from the University of Pennsylvania, and a Ph.D. in physiological psychology from Saint Louis University.APPENDIX G 

### 205

R. Curtis Graeber is the president of The Graeber Group, Ltd. Previously, he served as the chief engineer for human factors and director of regional safety programs at Boeing Commercial Airplanes and in other several management positions in research, airplane design, and safety. He also led Boeing’s efforts to improve regional safety, including industry development and implementation of the global aviation safety roadmap. Before joining Boeing, he led the flight crew fatigue research program at NASA’s Ames Re

search Center and served as chief of flight human factors. He also served as the human factors specialist for the Presidential Commission on the Space Shuttle Challenger Accident. He is a fellow of the Royal Aeronautical Soci

ety and the Aerospace Medical Association. He has chaired working groups for the Federal Aviation Administration, the Flight Safety Foundation, and the International Civil Aviation Organization. His safety-related awards in

clude the Guild of Air Pilots and Air Navigators’ Cumberbatch Trophy and the Aerospace Medical Association’s Boothby-Edwards Award. He serves as chair of Air New Zealand’s Independent Alertness Advisory Panel, and he is a member of the board of directors of the National Sleep Foundation. He received a Ph.D. in neuropsychology from the University of Virginia.

David E. Meyer is a faculty member of the Cognition and Cognitive Neu

roscience Program in the Department of Psychology at the University of Michigan. Previously, he worked in the Human Information Processing Research Department at Bell Telephone Laboratories. His teaching and his research have dealt with fundamental aspects of human perception, attention, learning, memory, language, movement production, reaction time, multitasking, executive mental control, human-computer interaction, personality and cognitive style, cognitive aging, cognitive neuroscience, mathematical models, and computational models. He is a fellow in the Society of Experimental Psychologists, the American Psychological Society, the American Psychological Association, and the American Association for the Advancement of Science. The American Psychological Association has honored him with its Distinguished Scientific Contribution Award. He is a member of the National Academy of Sciences. He received a Ph.D. from the University of Michigan.

Mary Ellen O’Connell ( Senior Staff Officer ) is deputy director for the Board on Human-Systems Integration and the Board on Behavioral, Cognitive, and Sensory Sciences at the National Research Council (NRC). At the NRC, she has served as study director for five major consensus studies: on prevention of mental disorders and substance abuse, international educa

tion and foreign languages, ethical considerations for research on housingrelated health hazards involving children, reducing underage drinking, and assessing and improving children’s health. She also organized workshops

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### on welfare reform and children and gun violence. Previously, she held various positions at the U.S. Department of Health and Human Services (HHS), including serving as director of state and local initiatives in the Of

fice of the Assistant Secretary for Planning and Evaluation. Her previous positions also include work on homeless policy and program design at the U.S. Department of Housing and Urban Development and as director of
field services for the Commonwealth of Massachusetts. She has a B.A. with distinction from Cornell University and an M.A. in the management of hu

man services from the Heller School for Social Policy and Management at Brandeis University.

Matthew Rizzo is professor of neurology, engineering, and public policy at the University of Iowa. At the university, he is also vice chair for clinical/ translational research and director of the division of neuroergonomics, its visual function laboratory, and its instrumented vehicles in the Department of Neurology, as well as director of the University Aging Mind and Brain Initiative. His clinical interests and activities include behavioral neurology, cognitive neuroscience, and memory disorders. His research interests in

clude behavioral disturbances resulting from central nervous system injury, neural substrates of human vision (including attention and visuomotor control), aging and dementia, driving performance, and driving simula

tion. He has conducted research on fatigue and truckers for the National Institutes of Health and the Iowa Department of Transportation. He is a member of the American Academy of Neurology, the American Neurologi

cal Association, the Human Factors and Ergonomics Society, the Society for Neuroscience, and the Vision Sciences Society. He has an M.D. from Johns Hopkins University School of Medicine.

David J. Schroeder is a private consultant. Previously, he was a manager of the Aerospace Human Factors Research Division at the Civil Aero Medi

cal Institute of the Federal Aviation Administration (FAA), where he also served as supervisor of clinical psychology research and as the long-time administrator of the FAA’s Employee Attitude Survey. His research is docu

mented in over 40 Office of Aviation Medicine (OAM) technical reports and in more than 125 presentations in a range of areas, including disori

entation, job attitudes, stress, age, shiftwork and fatigue, and color vision. He assisted with the psychological screening of federal air marshals during their post-9/11 hiring increase. He was the Office of Aviation Medicine Manager of the Year in 2005 and led his division to become the OAM Of

fice of the Year in 1999 and 2005. He is past president of the Oklahoma Psychological Association, the Division of Applied Experimental and En

gineering Psychology of the American Psychological Association, and theAPPENDIX G 

### 207

Aerospace Medical Association. He has a Ph.D. in psychology from the University of Oklahoma.

Toby Warden ( Study Director ) is a program officer with the Board on Human-Systems Integration of the National Research Council (NRC). Pre

viously, she worked as a program officer with the NRC’s Board on At

mospheric Sciences and Climate, serving as study director for the projects that published Climate Stabilization Targets: Emissions, Concentrations, and Impacts Over Decades to Millennia and When Weather Matters: Sci

ence and Service to Meet Critical Societal Needs . Prior to joining the NRC staff, she had extensive experience as a program manager and community organizer in the fields of public health and youth advocacy in Boston, Massachusetts. Her doctoral research applied quantitative and qualitative methodologies to examine the rise of the U.S. Mayors Climate Protection Agreement. She has a B.A. in history, magna cum laude, and a Ph.D. in so

cial ecology with an emphasis on environmental analysis and design, both from the University of California, Irvine.

J. Frank Yates is an Arthur F. Thurnau professor, a professor of psychology, a professor of marketing and business administration, and a principal in the Judgment and Decision Laboratory of the Department of Psychology, all at the University of Michigan. He is also the coordinator of the Decision Consortium, which is a University of Michigan-wide association of faculty and students whose scholarship includes significant decision-making ele

ments. The main focus of his research is on decision making at both the theoretical and practical levels. That work has emphasized understanding how people decide in the challenging conditions of real life and developing means of assisting them to decide better in those circumstances. He is a past president of the Society for Judgment and Decision Making and is active in a variety of other efforts to advance decision scholarship, including ef

forts involving scholarly journals. He has been an active member of many government and other organizations, including the advisory panel of the Decision, Risk, and Management Science Program at the National Science Foundation. He holds a Ph.D. from the University of Michigan.