Committee on the Effects of Commuting on Pilot Fatigue

Board on Human-Systems Integration

Division of Behavioral and Social Sciences and Education

Transportation Research Board
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on Pilot Fatigue. Committee on the Effects of Commuting on Pilot Fatigue, Board 

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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 

1Resigned 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 Commuting 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 Administration, 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, Technical 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 provided information in response to the committee’s request for input (see Appendix 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 oversight 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 National 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, provided 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 procedures 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 

Engineering 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 Aeronautics & 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 Department, 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, delivering 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 acknowledged 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 Administration (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 circadian rhythms; to airline and regulatory oversight policies; and to pilot and 

airline practices.1 It was intended to inform the commuting-specific component 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 

1This 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 predominately 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 unable to obtain any systematic information about how frequently individual 

pilots experience domicile changes or how such changes affect pilot commuting 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 airlines 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 for 
SUMMARY 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 commutes. 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 connecting 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 commuting 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 departures 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 probable 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) scientific 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 fatigue and clear evidence that fatigue can decrease performance, the committee 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 understand the extent to which the risk posed by fatigue resulting from some 

commutes may be mitigated by individual, airplane (e.g., flight deck systems), 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 

2An 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 commute, 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 regulations 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 negative 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 communication 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 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. 

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 account 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 approximately 16 hours before the scheduled end of duty, endeavor to sleep 

at least 6 hours4 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 assessment 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. 

4This 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 manage 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 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. 

Fatigue risk management plans (FRMPs) are the airline carriers’ management 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 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 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 position 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 management 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 awareness 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 policies, 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 

relying 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 commutes 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, under 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 airlines, 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 making. Decision-making strategies informed by this science could be incorporated 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 pilots 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 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 fatigue risk management 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 relationships 
SUMMARY 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 using 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 understand 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 regulatory change has received attention in the form of at least two rounds of 

rule-making activity, there have been no actual changes to relevant regulations 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 

1A 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 fatigue 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 factors, 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 following 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 Airline 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 mandated 

study, 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 commercial 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 carriers (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 Fatigue 
INTRODUCTION 13

Management Symposium: Partnerships for Solutions;” (6) FAA and international 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 committee’s specific Statement of Task. 

The FAA issued a Notice of Proposed Rulemaking (NPRM) on September 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. 

2The 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, fatigue, sleep and circadian rhythms, cognitive and physiological performance, 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, recommendations 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 nonregulatory approaches to reducing the risk from fatigue; presents the committee’s 

analyses of input from stakeholders; reviews the scientific literature on fatigue 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 approach 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 information 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 companies 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 individuals interested in providing information, both in writing and in presentations to the committee. All parties who wished to talk with us were included 

3A 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]. 

4Part 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 Worldwide [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 fatigue that were submitted to the aviation safety reporting system 

(ASRS), a voluntary pilot reporting system;5

5ASRS 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 approximation 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 commercial 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, conclusions 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 commutes 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 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.

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 commuting 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 availability 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) 

...Off Duty Commute (off duty) On 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 competing 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 commuting. 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 effects 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, including sources of safety improvement, followed by an analysis of information 

on fatigue-related aviation accidents from reports by the NTSB. The chapter 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 fatigue caused by commuting. The chapter begins with background information 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 provided. Additional background information, data sources, and analyses are 

included in the seven appendices. Appendix A identifies the airlines, associations, and groups that submitted documents for the committee’s review. Appendix 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’ commuting choices. This discussion draws on the expertise of committee members, 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 Rulemaking (NPRM), and a review of available airline policies. 

COMMUTING: BACKGROUND

Commuting is usually defined as travel between home and a work location 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; overall, 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 commuting 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 effects 

of relatively long car drives (Kluger, 1998); self-reported attitudes in highcongestion conditions (Hennessy and Wiesenthal, 1999); and rail commuting (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 performance. 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, depending 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 family 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 communities. 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 domicile 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 consumers. 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 modest. 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 prices
THE 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 purposefully 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 commuting 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’ commuting decisions. In order of reported frequency, from high to low, they 

included high cost of living near the domicile location; frequent domicile closings 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 commuting is 

a potentially fatiguing activity, but they also commented that commuting 

conducted responsibly would not necessarily increase fatigue levels significantly. In regard to policies and regulations that might influence commuting practices, the responses were mixed and diverse, ranging from opinions 

that current policies and practices are appropriate to suggestions for airline 

ownership 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 committee did not have information on the percentages of pilots from each source. 

In the United States, pilots taking entry-level positions at regional airlines 
THE 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 begin 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 establish 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 determine 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 average, 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 specific 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 system, 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 reliably 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 airlines (most commonly those offering nonscheduled service1) 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 

1Nonscheduled 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’ responses 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. International 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. airline industry do not show some of the important changes that have occurred 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 patterns: the rise of regional jet service, and mergers. An important industry 

change that could affect pilot commuting is the rise of the regional jet industry 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 2010

Number of Passengers

Domestic

International

Year

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 airports 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 mainline 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 acquiring) 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 typically 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 affect 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 previously 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 conditions, 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 the 
THE 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 passenger 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 carriers 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 Figure 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 Baltimore, 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 

2A 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 (now editable)

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2000 2005 2010

Number of Departures

Year

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 redrawn

0

5,000

10,000

15,000

20,000

25,000

2000

2005

2010

Number of Departures

PHX

MCO

OA

BWI

K

MDW

LAX

DAL

LA

HOU

S

BNASAN

STL

DEN

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 appropriate 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

redrawn

0

5,000

10,000

15,000

20,000

25,000

30,000

DFW

ORD

JFK

LAX

MIA

BOS

NAS

SAN

LGA

CMH

RDU

DCA

SJC

2000

2005

2010

Number 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 service 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 redrawn

2000

2005

2010

0

2,000

4,000

6,000

8,000

10,000

12,000

Number of Departures

14,000

DEN

OR

D

MSN

MKE

AT

W

RAP

ASE

GJT

MLI

SB

N

IAD

PHL

JAX

CH

S

JFK

CLT

DC

A

LGA

ORF

BUF

RIC

GSO

BOSGSP

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 redrawn

2000

2005

2010

0

5,000

10,000

15,000

20,000

25,000

30,000

Number of Departures 35,000

ATL

DFW

XNA

VPS

GT

R

MY

R

CHA

PFN

AVL

GN

V

CVG

TPA

CAESHV

MG

M

HSV

TYS

BTR

ME

M

IAD

DTW

OR

D

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 between 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 Cincinnati hub experienced sharp declines before the merger and even sharper 

declines following the merger. The even sharper declines in aircraft departures 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 redrawn

0

50,000

100,000

150,000

200,000

250,000

300,000

350,000

2000 2005 2010

Number of Departures

Year

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 Northwest 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 who 

were 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 American/TWA merger). But airlines have also sharply decreased departures at 

hubs for reasons not associated with mergers, as was seen in Delta’s reducing 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 redrawn

0

10,000

20,000

30,000

40,000

70,000

2000

2005

2010

Number of Departures

ATL

MCO

MEM

DFW

SLC

CVG

MSP

DTW

LGA

BOS

JFK

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 policies 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 pilot 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 provided 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 commuting 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 reserved 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 available 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 maintenance 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 

3The passenger load factor is a measure of how much of an airline’s passenger carrying capacity 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 multiple 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’ operating flights in a fatigued state. This outcome is more likely if a pilot commutes 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

2000

2001

200220032004

200520062007200820092010

Percentage of Seats Filled

Year

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 “prenotification” from pilots who are experiencing difficulty with their commute in order 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 information 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 certification 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 would 
THE 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 commute 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 Operations 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 committee 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 

4Under 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 committee 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 cognitive tasks, including those essential for safely operating a commercial aircraft. 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 discussion 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 examines 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 million 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 highways, which in turn are much safer than travel on local roads (National 

Research Council, 2010, Figure 3-10). Travel on rural roads is more dangerous 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.

1Transportation 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 Association 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

Autos Buses Trains Airlines

Fatalities per 10

0

Million Passenger Miles

Mode
AVIATION 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, including 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.

2For 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). 3For more discussion of U.S. and Canadian aviation safety, see Oster et al. (1992, Ch. 4).
48

Figure 3-2.eps

landscape

0

50

40302010

59 60 62 64 66 68 70 72 74 76 78 80 82 84 86 88 90 92 94 96 98 00 02 04 06 08 10

1991 Through 2010

Rest of the worldU.S. & Canadian operators

91 92 94 98 00 02 04 06 08 96

Year

2.01.51.00.50.0

Rest of the worldU.S. & Canadian operators

Annual 

fatal

accident

rate 

(accidents 

per million

departures)

Year

10

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, looking 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 inferences 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 

4Fatalities 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 1990-2000 2001-2010

Time Period

Passenger Fatalities per 

Million Enplanements

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

SOURCE: Data on passenger fatalities and enplanements calculated from information 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 flight 

simulators 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 manufacturers, 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 Federal 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 training 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 correcting 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 missing 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 repeatable 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 mitigate 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 particularly when inflight rest facilities such as bunks are provided for crew 

members to sleep when they are not on duty. Even on shorter flights, research 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 provided 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 

5Napping 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 contributed to an accident. In the analysis of NTSB accident reports discussed below, 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 fatigue resulted in errors made during the accident sequence or contributed to 

the cause of the accident. Well-rested pilots have been involved in airplane 
AVIATION SAFETY AND PILOT COMMUTING 53

crashes and fatigued pilots have completed flights without accidents. However, 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 accident record. 

Committee’s Method of Analysis

Recognizing these challenges, the committee examined NTSB reports of 

recent accidents6 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 factors7 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 provide 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 

6An 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).

8The 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. However, 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 operators to address fatigue risks associated with commuting, including identifying 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 identifying 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 individu9The 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 history factual information for an uncontrolled collision with terrain on August 18, 1993: “A Douglas DC-8-61 freighter . . . registered to American 

International Airways (AIA) Inc., [doing business as] Connie Kalitta Services, Inc., and operat[ed] as AIA flight 808, collided with level terrain apTABLE 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 Sharing 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 properly assess the conditions for landing and maintaining vigilant situational 

awareness of the airplane while maneuvering onto final approach; his failure 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 Guantanamo 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 Transportation 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 overrun and collision on May 8, 1999: “A Saab 340B . . . sustained substantial 

damage during landing at John F. Kennedy International Airport (JFK), Jamaica, 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 26 
AVIATION 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 schedule. 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 scheduled 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, inadequate 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 accident: “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 Transportation Safety Board, 2001, p. 1). 

The report goes on to describe the flight crew’s commute and sleep patterns 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 activities 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 committee 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 thunderstorms 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 performance 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 exceeded, 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 accident: “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 sequence. 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), Kirksville, 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 accident 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 nonprecision instrument approach at night in instrument meteorological conditions, 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 established 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” (National Transportation Safety Board, 2006, p. 58).

Shuttle America

The NTSB describes the flight history of a February 18, 2007, runway 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, contacted 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 captain 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 schedule of the captain: “On the day of the accident, the captain traveled as a 

nonrevenue 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 captain was scheduled to report to SDF at 0525, and the flight to ATL had a 

scheduled 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 different 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 captain: “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 accident, 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 occurrences would result in corrective action, which could include termination 
AVIATION SAFETY AND PILOT COMMUTING 61

from the company. (According to the company’s policy, eight absence occurrences 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 delays 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 effectively 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 accident: “A Bombardier/Canadair Regional Jet (CRJ) CL600-2B19, . . . operated 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 infants) 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 and 

conducted training on a flight to Minneapolis-St. Paul International (WoldChamberlain) Airport (MSP). The captain spent the night before the accident 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 permitted the pilots’ long, demanding duty day and (2) the TVC operations 

supervisor’s use of ambiguous and unspecific radio phraseology in providing 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 airspeed 
AVIATION 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 procedures 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, [Maryland] (BWI). . . . The captain, flight engineer and 9 flight attendants reported 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 either 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 related 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, testing, 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 pilot’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 this 

information 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 

10The 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 Transportation 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 were 

not 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: Mainline 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 operate 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 segment. 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 reporting 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 31 

and 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 distance 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 expect 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 of 

cargo 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 policies (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 industry 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 recently 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

bitmap

Percentage

Miles

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 regional 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 airlines. 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 alphabetically 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 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 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 accounting 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. In 

all 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 fatigue 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 considerations related to characteristics of the commute. For example, the implications 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 percent) 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 zone 
AVIATION 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 reported a shorter distance between domicile and residence than pilots who 

crossed only one or two time zones. The greatest distances travelled obviously 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 information 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 Reporting System (ASRS). ASRS collects, processes, and analyzes voluntarily 

submitted aviation safety incident reports of unsafe occurrences and hazardous situations from pilots, air traffic controllers, dispatchers, flight 

Figure 3-5.eps

0

20

40

60

80

100

Mainline

Percentage

Regional Cargo Charter

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

MILES 

No Time Zones One Time ZoneALL ML Reg’l Cargo Chart. ALL ML Reg’l Cargo Chart.

0-60 55.8 52.1 58.8 67.8 58.9 0.1 0.1 0.160-120 7.3 8.6 6.1 2.8 9.4 0.7 1.1 0.9120-180 3.8 4.0 4.3 1.8 3.1 1.6 1.7 3.2 0.1180-240 5.8 6.5 4.9 4.3 4.2 2.1 2.1 4.4 0.1 0.5240-300 3.4 3.6 3.1 2.1 4.5 4.3 5.9 5.3 0.5 3.0300-360 2.2 1.8 2.6 3.2 3.4 4.4 2.8 4.1 8.3360-420 3.4 3.4 3.1 4.0 0.8 3.0 2.6 0.9 6.0 0.5420-480 3.0 2.6 3.4 4.7 1.3 2.9 3.8 2.2 2.6480-540 2.6 2.6 2.8 2.2 3.1 4.0 4.4 3.2 4.0 3.0540-600 2.1 2.1 2.0 1.8 4.7 5.4 3.5 5.2 8.4 8.1600-660 1.8 1.8 1.4 2.1 2.9 5.7 4.3 4.2 9.4 7.6660-720 0.9 0.7 0.8 1.8 1.0 8.5 8.2 10.0 7.5 8.6720-780 1.1 1.3 0.8 0.3 0.3 10.4 12.6 10.0 7.2 6.1780-840 0.6 0.6 0.9 0.3 0.5 5.4 4.5 5.7 6.9 5.1840-900 0.9 1.1 0.8 0.2 0.3 8.5 7.5 6.8 12.4 4.0900-960 1.8 2.1 2.0 0.1 5.3 4.2 7.0 4.1 16.7960-1,020 1.4 1.8 0.8 0.3 0.5 5.7 7.0 6.5 2.0 9.61,020-1,080 1.4 1.9 0.9 a 0.8 3.3 2.9 3.9 2.4 9.61,080-1,140 0.6 0.8 0.4 3.1 3.1 3.0 2.6 6.61,140-1,200 0.1 0.2 a 2.0 1.6 1.9 2.2 7.11,200-1,260 0.1 0.1 a 0.3 2.7 1.3 3.4 4.7 1.5
73

1,260-1,320 a 2.0 1.8 2.2 2.2 1.01,320-1,380 1.3 2.0 0.9 0.3 1.51,380-1,440 4.5 7.4 3.4 1.21,440-1,500 1.0 1.1 0.8 1.41,500-1,560 0.8 1.0 0.2 1.11,560-1,620 0.7 1.0 0.2 0.51,620-1,680 0.1 0.2 0.1 0.11,680-1,740 0.1 0.11,740-1,800 a1,800-1,8601,860-1,920 0.11,920-1,980 0.1 a 0.31,980-2,040 0.2 0.72,040-2,1002,100-2,160 0.12,160-2,220 0.12,220-2,2802,280-2,340 0.1 0.22,340-8,400b 0.1 0.1 0.3

continued
74TABLE 3-8 Continued

MILES 

Two Time Zones Three Time ZonesALL ML Reg’l Cargo Chart. ALL ML Reg’l Cargo Chart.

0-6060-120120-180180-240240-300300-360360-420420-480480-540540-600600-660660-720720-780780-840840-900900-960960-1,020 0.2 0.3 2.31,020-1,080 0.5 16.31,080-1,140 1.2 1.1 2.2 2.31,140-1,200 3.1 4.6 2.2 0.71,200-1,260 4.7 6.7 3.0 0.3 16.31,260-1,320 3.8 4.1 5.5 11.6
75

1,320-1,380 4.6 4.6 7.2 0.3 9.31,380-1,440 7.2 7.5 8.5 4.3 11.61,440-1,500 4.4 5.5 5.0 0.3 9.31,500-1,560 6.4 5.1 6.5 8.3 14.01,560-1,620 12.4 13.1 11.7 12.3 7.01,620-1,680 13.6 15.1 7.7 19.6 0.4 0.4 0.71,680-1,740 6.2 1.2 16.7 6.0 1.0 1.2 0.71,740-1,800 5.6 4.9 5.2 8.6 2.7 3.91,800-1,860 6.9 5.8 6.7 11.01,860-1,920 6.6 2.1 4.5 21.6 6.7 5.9 12.21,920-1,980 2.1 3.5 0.7 0.7 8.6 9.8 7.5 16.71,980-2,040 1.5 2.1 1.7 5.3 5.3 6.8 16.72,040-2,100 0.7 0.4 2.0 6.0 6.3 7.52,100-2,160 4.3 6.7 3.0 0.7 3.4 3.1 6.12,160-2,220 0.5 0.9 5.1 5.1 7.52,220-2,280 0.3 0.5 0.3 4.9 4.3 8.82,280-2,340 0.3 0.7 3.9 3.5 6.82,340-8,400b 2.8 3.5 5.0 52.0 51.3 35.4 100.0 66.7aLess 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 information available in the reports to determine the degree to which commuting 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.

11For 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 fatigue 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. 

1For 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 practices2 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 selective 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 condition 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 commuting is contributing to fatigue at work—by reducing sleep time, extending wake time prior to duty, or interrupting a habitual nocturnal sleep 

period—is not known. 

2Good 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). 

3The committee did not consider the use of sleeping medications by pilots during commutes 

prior 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 occur 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 extending 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 interactive 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 commutes should be avoided.

The sleep homeostatic drive can produce fatigue during waking per4For 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 concentration (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 concentration 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, working 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 performance 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 cognitive 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 

5The 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 individuals 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 reviews 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 cognitive 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 occurs 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 performance 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 behavioral 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 increasing 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 an 

overestimate. For example, a population-based sample of N = 669 middleaged adults found that subjective reports of habitual sleep were only moderately 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 physiological sleep duration necessary to prevent reductions in alertness and 

cognitive functions), it is unknown whether this threshold should be applied 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 deprived 
SLEEP, 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 performance under chronic sleep restriction. Although there are extensive studies 

on the alertness-promoting effects of caffeine under acute sleep loss conditions, 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 being 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 reducing 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 sleeping 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 period (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, depending 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 management has developed rapidly over the past decade in civilian transportation 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 technologies 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 fatigue 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 alertness/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 consists 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 quantity 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 development 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 Aeronautics 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). Although 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 reliable 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 predictions 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, and 

other 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 duration 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 commercial 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 commence1We did not consider transportation while crews are laying over during long-haul operations, 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 considering 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’ effective 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 commuting 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 physiological 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 physiological 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 (including pilots, airlines, unions, and the FAA), in the course of hearings and 

testimony, during this study. These examples reflect the norms of the industry based on conversations with industry officials, the committee’s experience, 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 earlier 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 

2All 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, including 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 assignment 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 circadian low 

Figure 5-1.eps

9:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

PM AM PM

Rest 

(6 in bed, 5 sleep)

Commute (2.5)

On Duty (13)

Flight Segments (7)

Total Time Awake (18)

Activity (hours)

Time of Day at Residence

FIGURE 5-1 Example 1a: Unfavorable commuting pattern. 

SOURCE: Based on a submission by a pilot to the Aviation System Reporting Systems (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 Airport (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 successful. 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.eps

7:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

PM AM PM

Rest 

(8 in bed, 7.5 sleep)

Commute (3.0)

On Duty (13)

Flight Segments (7)

Total Time Awake (14.5)

Activity (hours)

Time of Day 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 environment 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.eps

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:00

PM AM PM

Rest 

(8 in bed, 7 sleep)

Commute (4)

On Duty (6)

Flight Segments (5)

Total Time Awake (19)

Activity (hours)

Time of Day at Residence

AM

FIGURE 5-3 Example 2a: Unfavorable commuting pattern. 

SOURCE: Based on personal testimony from stakeholders at open session meetings.

Figure 5-4.eps

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:00

PM AM PM

Rest 

(8 in bed, 7 sleep, 

3 nap)

Commute (3)

On Duty (6)

Flight Segments (5)

Total Time Awake (16)

Activity (hours)

Time of Day at Residence

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; questionable 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 departing 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 favor 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 of 

the 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.eps

11:00

12:00

1:002:003:004:005:006:007:00 ...2:003:004:005:006:007:008:009:00

10:00

11:00

12:00

1:002:003:004:005:006:007:008:009:00

PM AM PM

Rest

(8 in bed, 7 sleep, 2.5 nap)

Commute (7)

On Duty (4)

Flight Segments (3)

Total Time Awake (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 9:0010:0011:00 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) 

 Total Time Awake (13.5) 

Activity (hours)

Time 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 quality
PILOT 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 alternative 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 mulPM AM

| 

Rest* 

(6 in bed, 5 sleep)

Commute (2)

On Duty (13)

Flight Segments (4)

Total Time Awake (16)

Activity (hours)

Time of Day at Residence

PM

10:0011:0012:00

1:002:003:004:005:006:007:008:009:00

| | | | | | | | | | | | | | | | | | | | | 10:00 11:00 12:00 1:00 2:00 3:00 4:00 5:00 6:00 7:00 8:00

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, 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 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

Day 1

| | | | | | | 

Rest 

Commute

On Duty

Flight Segments

Time Awake

Activity

Time of Day at Residence

Day 2 Day 3

FIGURE 5-8 Example 4a: Unfavorable commuting pattern—overview of 3 consecutive 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 account 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 approximately 16 hours before the scheduled end of duty, endeavor to sleep at 

least 6 hours3 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 assessment 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.

3This 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, issued 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 crewmember 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 locally 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 consensus 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 meaningful 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 developing 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 inappropriate 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 advisory 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 states 
REDUCING THE RISK OF FATIGUE FROM COMMUTING 101

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 management 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 assignment 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 perform 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.
102 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

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 information 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 improving 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 procedures 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 overnights, night vs. day operations, cargo vs. passenger operations, short-haul 

vs. long-haul, etc.).

1The 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 103

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 commuting” as one of 15 elements and tasks for the fatigue education and awareness 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 commuting? If so, please provide a copy of the plan.”

Out of the 33 airlines that provided input to the committee, 17 responded 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 commuting 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 regulatory approach in the transportation domain, usually termed fatigue risk 
104 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

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 Foundation, and the International Federation of Airline Pilots’ Association—to 

obtain information regarding existing regulations, policies, and best practices 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 operational 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 Recommended 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 gathering 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 proactive 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 experience to take into account factors known to affect sleep and fatigue and 

their effects on performance (International Civil Aviation Organization, 

2011a, 2011b).

2An 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 processes 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 developed 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 hazards, 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, described 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 operating 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 significant 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 awareness training), but it is still based on flight time and duty period limita3For explanation of an SMS, see http://www.icao.int/anb/safetymanagement/DOC_9859_

FULL_EN.pdf [June 2011]. 
106 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

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 aviation 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 performance improvement process. This process leads to continuous safety enhancements 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 analysis 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 process and ensure that the FRMS is responsive to feedback and provides a 

level of safety that is equivalent to those established by existing regulations. 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 relationships. 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 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 competing 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 

4Such 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 regarding 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 effectiveness 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. Although 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, considering 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 unexpected 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 reallocated 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 unanticipated 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 109

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 accident is difficult in an accident investigation, the committee’s examination 

of 863 accidents found only 9 in which fatigue was judged to be a probable 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, different patterns of enforcement could have different impacts on the actual 

effect 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 regulations. 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 fatigue and clear evidence that fatigue can decrease performance, the committee 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 understand the extent to which the risk posed by fatigue resulting from some 

commutes may be mitigated by individual, airplane (e.g., flight deck systems), or aviation system (e.g., crew resource management) characteristics.

There is also tremendous variability across individual pilot commuting 

practices 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 necessarily 
REDUCING 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 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 regulations 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 fatigue should be addressed as part of an airline’s strategies to manage 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 improving 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 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 position 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 management 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 awareness 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, under the auspices of an independent organization (such as the Flight 

Safety Foundation), to assess industry policies on pilot commuting, sick 
REDUCING 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 airlines, 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 making. Decision-making strategies informed by this science could be incorporated 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 pilots 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 between 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 understand pilots’ commuting experiences within the context of multiple factors. 

The results of the study can help identify situations that may warrant specific 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 member 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 consumption, body temperature, cardiovascular rhythms, muscle tone, and aspects 

1Federal 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 physiological functions.

Commuting: 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 

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 challenge of optimizing the human/machine and human/human interfaces. Includes 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, excluding 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 

2Ibid.

3Ibid.

4Ibid.
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 performing 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

5Ibid.

6Ibid.

7Ibid.

8Ibid.

9Ibid.
132 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Gateway basing: the airline arranges a flight (when necessary) from a specified 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 required 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 

10Ibid.
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.

11Federal 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, associations, 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 Presenters
APPENDIX 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 associations. 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 received 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 commercial 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 commuting1: definition, 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 airline 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 crewmember 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 particular, 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 constrained 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 prevalence 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: “prevalence can’t be quantified, because ‘commuting’ can’t be defined.” 

1There 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 carriers) 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 example, one major cargo carrier reported that for one of its principal domiciles, 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 percentages 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 individual 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 respondents); 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 challenging it is to measure the effects of commuting on pilot readiness and 

fitness for duty, given the difficulties with defining “commuting,” quantifying its prevalence, and accounting for the heterogeneous ways in which 

pilots commute. In particular, six respondents noted that the fatiguing effects 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 commutes may affect them.

With these sorts of caveats in mind, five respondents stated that commuting 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 reporting 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 unpredictability 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 respondents (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 significantly 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 deterrent 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 viewpoint 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 compromises 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 expressed 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 associations, 3 individual pilots, and 5 individual airlines) offered a range of 

suggestions for how to improve the commercial airlines system with respect 

to commuting. 

The viewpoint of the airline carriers is embodied in a set of related 

replies from three respondents. They stated explicitly that current airline 

commuting policies and practices—to the extent any exist—are already 

adequate, that no major new changes need be made, and that the burden 

of ensuring that flight crew members are fit for duty should not be shifted 

to the air carriers. Rather, in their opinion, fatigue management in the 

context of commuting should remain solely the responsibility of flight crew 

members. Their comments also suggested that the FAA should more tightly 

regulate the commuting practices of pilots, but not by imposing additional 

burdens on air carriers to monitor pilot behavior. For example, two urged 

that commuting overnight on “red-eye” flights directly prior to subsequent 

duty periods should be strongly discouraged or banned outright.

Contrasting with these views were the responses from individual airline 

pilots and their professional associations. Specifically, three such respondents said that no new rules and regulations should be imposed on pilots 

who commute by air to work nor should their commuting practices be 

scrutinized by their employers. Instead, they suggested that the FAA should 

more tightly regulate the policies of air carriers that influence the ease or 

difficulty of commuting. They urged that a new regulation be put in place 

whereby all commercial air carriers would institute standardized nonpunitive sick leave, fatigue, and commuting policies, unlike the wide variety 

of punitive, nonpunitive, and nonexistent policies that currently prevail. 

Furthermore, one respondent suggested that airlines’ commuting policies 

should be coordinated with the scheduling of back-up commuter flights 

through CASS (the Cockpit Access Security System). 

Three respondents also suggested that specific rules regarding regional 

air carriers need to be strengthened. Along these same lines, three responses 

expressed considerable enthusiasm for requiring airlines to improve their 

support of pilots whose domiciles are changed, including additional provision of paid moves, cost-of-living adjustments (COLAs), and positive-space 

tickets rather than merely jumpseats for flights used for commuting. Supplementing these suggestions, one respondent noted as well that rest facilities 

at airlines’ bases (domiciles, hubs, and spokes) should be upgraded with 

more comfortable and quiet sleeping quarters.
147

Appendix D

Qualitative Analysis of Selected Public 

Comments to Proposed FAA Rules 

The Department of Transportation and Federal Aviation Administration (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 address 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 incorporate any such recommendation in a Final Rule” (Federal Register, September 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 commuting and possible consequences of the proposed duty and rest rules on 

commuter pilots. It is those comments that we considered in our qualitative 

investigation. 

ANALYTIC METHOD

Qualitative methods are used to investigate the why and how of decision making, rather than the what, where, when. For the purposes of this 

investigation, the public comments expressed the viewpoints of a group of 

volunteer respondents, both individuals and representatives of a variety of 

organizations, who submitted their thoughts and ideas about the NPRM 

to the FAA. 

The qualitative data set was comprised of a purposeful sample of the 

public comments selected as relevant to the following topic areas:

•	 definitions of commuting;

•	 prevalence of commuting;

•	 perceptions of commuting as being problematic (e.g., when the

unplanned occurs, such as weather disturbances or mechanical 

difficulties that delay flights);

•	 characteristics and examples of responsible commuting;

•	 perceptions of commuting as less of a choice and more related to

external factors (e.g., frequent domicile changes, low salaries, and 

other industry-related factors); and

•	 suggestions and rationale for modifying the NPRM.

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 comment contained multiple opinions of relevance (e.g., on both the definition 

of commuting and he prevalence of commuting practices, as well as some 

suggestions for the NPRM). As a result, over 400 statements relevant to 

the study were considered.

Data Analysis

The analysis of qualitative data is an iterative process of examining and 

reexamining the narrative data set throughout all phases of analytic inquiry 

(Wolcott, 1994; Morse and Richards 2002; Ulin et al., 2004; Crosby et al., 
APPENDIX D 149

2006; Fetterman, 2010). The continuous process of visiting and revisiting 

the narrative data, with an eye toward identifying similarities and differences 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 illustrative quotes. The responses were then sorted by relevance to each of the 

topic 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 afford 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 process 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 commuting 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 itself 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 location of family residences stable and affordable. Estimates of onehalf or more pilots commute to work by air. Long commutes are 

never desirable and the “commuter adaptation” to the industrywide 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 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 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 local 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 Commuting

Commuting 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. 14
APPENDIX 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 primarily 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 commute 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 impossible. 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 company: “[T]he overwhelming majority of part 135 pilots live in close proximity 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 opportunities 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 problem, 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 develop 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 responsible 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 regional 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 moving 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 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 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 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 
APPENDIX D 157

several times. Also, Junior First Officers earning $20,000 to $30,000 annually 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 combating 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 flying 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, regulations 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, including 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 for 
APPENDIX 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 between 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 controlling 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 represented 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 environment 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 management 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 priority, 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 experiences, I have full confidence that the no-questions-asked fatigue policy 
APPENDIX 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 manage their fatigue.

Inadequate Data on Commuting

Postpone regulations related to commuting until evidence-based fatiguemitigating 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. (N = 15)

The lack of information about commuting practices and their relationships 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 member’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 scientific 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 individual 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 increase 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 commuting 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 seriously—schedules and assignments were made with consideration of circadian 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 commuting.” 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 redrawn

25,000

20,000

15,000

10,000

5,000

0

2000

2005

2010

ATL

MC

O

MD

W

TPAPHL

FLL

IAD

GP

T

DFW

HO

U

BWI

BO

S

LG

A

CAK

MK

E

IND

RSW

Figure E-2.eps

bitmap, labels redrawn

2000 2005 2010

Year

0

10,000

20,000

40,000

50,000

60,000

70,000

80,000

30,000

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

Figure E-3.eps

bitmap, labels redrawn

2000

2005

2010

14,000

12,000

10,000

8,000

4,000

0

6,000

2,000

SEA ANC PDX LAX SFO JNU OAK FAI SJC SNA SAN LAS

Figure E-4.eps

bitmap, labels redrawn

2000 2005 2010

Year

44,000

42,000

38,000

36,000

34,000

32,000

40,000

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

Figure E-5.eps

bitmap, labels redrawn

2000

2005

2010

60,000

50,000

20,000

10,000

0

40,000

30,000

DFW STL ORD MIA LAX JFK LGA SJC SJU BOS SFO DCA

Figure E-6.eps

bitmap, labels redrawn

300,000

250,000

100,000

50,000

0

200,000

150,000

2000 2005 2010

Year

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

Figure E-7.eps

bitmap, labels redrawn

2000

2005

2010

35,000

20,000

15,000

10,000

5,000

0

30,000

25,000

IAH

EWR

LA

DCA

ORD

X

BOS

CLE

SFO

SEA

LAS

MCO

DFW

ATL

DEN

Figure E-8.eps

bitmap, labels redrawn

2000 2005 2010

Year

120,000

100,000

40,000

20,000

0

80,000

60,000

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

Figure E-9.eps

bitmap, labels redrawn

2000

2005

2010

70,000

40,000

30,000

20,000

10,000

0

60,000

50,000

ATL

DTW

LAX

MEMMCO

LGA

BOS

JFK

SLC

DFW

CVG

MSP

Figure E-10.eps

bitmap, labels redrawn

2000 2005 2010

Year

400,000

350,000

200,000

100,000

0

300,000

250,000

150,000

50,000

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

Figure E-11.eps

bitmap, labels redrawn

2000

2005

2010

18,000

10,000

8,000

6,000

4,000

0

14,000

12,000

2,000

16,000

MEM IND EWR OAK LAX AFW ONT PDX ANC ORD SLC

Figure E-12.eps

bitmap, labels redrawn

2000 2005 2010

Year

76,000

74,000

68,000

64,000

72,000

70,000

66,000

62,000

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

Figure E-13.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

12,000

2,000

LAX

DF

LAS

W

ABQ

OMA

SFOPHX

PDX

MDW

SAN

MCI

SE

SLC

A

DEN

MKE

Figure E-14.eps

bitmap, labels redrawn

2000 2005 2010

Year

25,000

20,000

5,000

0

15,000

10,000

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

Figure E-15.eps

bitmap, labels redrawn

2000

2005

2010

JF

K

BUF

FLL

MC

O

TPA

RO

C

ON

T

OA

K

BTV

LG

B

BO

S

IAD

LAS

LG

A

SJU

HPN

PBI

10,000

8,000

6,000

4,000

0

14,000

12,000

2,000

16,000

Figure E-16.eps

bitmap, labels redrawn

2000 2005 2010

Year

60,000

50,000

10,000

0

40,000

30,000

20,000

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

Figure E-17.eps

bitmap, labels redrawn

2000

2005

2010

20,000

15,000

10,000

0

25,000

5,000

PHX

LAS

HOU

OAK

MDW

BWI

MCO

DEN

SAN

DA

BNA

L

LAX

STL

Figure E-18.eps

bitmap, labels redrawn

2000 2005 2010

Year

350,000

200,000

100,000

0

300,000

250,000

150,000

50,000

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

Figure E-21.eps, now used as E-19

bitmap, labels redrawn

25,000

20,000

15,000

10,000

0

35,000

30,000

5,000

45,000

40,000

ORD DEN SFO LAX IAD SEA BOS LAS PHX SAN PDX LGA

2000

2005

2010

Figure E-22.eps, now used as E-20

bitmap, labels redrawn

2000 2005 2010

Year

200,000

100,000

0

250,000

150,000

50,000

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

Figure E-19.eps (now used at E-21)

bitmap, labels redrawn

2000

2005

2010

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

9,000

8,000

MI

A

ANC

PHL

SDF

SAT

EFD

AUS

LAX

BFI

FSD

ON

T

RFD

DFW

CAE

EWR

DSM

BDL

Figure E-20.eps, now used at E-22

bitmap, labels redrawn

2000 2005 2010

Year

20,000

10,000

0

30,000

25,000

15,000

5,000

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

Figure E-23.eps

bitmap, labels redrawn

2000

2005

2010

25,000

20,000

15,000

10,000

0

35,000

30,000

5,000

PHX

MCO

LG

BWI

A

BOS

DCA

LAXLAS

CL

PIT

PHL

T

FLL

DFW

ORD

Figure E-24.eps

bitmap, labels redrawn

2000 2005 2010

Year

200,000

100,000

0

300,000

250,000

150,000

50,000

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 WV
APPENDIX 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 Continued
APPENDIX 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 departures by airport code (refer to Table E-1 in Appendix E 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 18 

regional airlines. 
184 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-1.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

14,000

12,000

2,000

16,000

DEN

OR

D

MS

N

MK

E

ATW

RAP

ASE

GJ

T

MLI

SBN

IAD

PHL

JAX

CHS

JF

K

CLT

DCA

LG

A

ORF

BUF

RIC

GS

O

BO

S

GS

P

Figure F-2.eps

bitmap, labels redrawn

2000 2005 2010

Year

50,000

40,000

10,000

5,000

0

20,000

15,000

45,000

25,000

30,000

35,000

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

Figure F-3.eps

bitmap, labels redrawn

2000

2005

2010

25,000

20,000

15,000

10,000

0

30,000

5,000

DFW

SAN

BOS

MIAJF

LAX

K

ORD

CMH

LGA

DCA

RD

SJC

U

XNA

Figure F-4.eps

bitmap, labels redrawn

2000 2005 2010

Year

160,000

40,000

20,000

0

80,000

60,000

100,000

120,000

140,000

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

Figure F-5.eps

bitmap, labels redrawn

25,000

20,000

15,000

10,000

0

30,000

5,000

35,000

2000

2005

2010

ATL

DFW

XNA

VPS

GT

R

MY

R

CHA

PFN

AVL

GN

V

CVG

TPA

CAESHV

MG

M

HSV

TYS

BTR

ME

M

IAD

DTW

OR

D

Figure F-6.eps

bitmap, labels redrawn

2000 2005 2010

Year

100,000

80,000

20,000

10,000

0

40,000

30,000

90,000

50,000

60,000

70,000

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

Figure F-7.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

12,000

2,000

0

ACK BOS HYA MVY SJU PVD EWB STT PVC STX STL

Figure F-8.eps

bitmap, labels redrawn

2000 2005 2010

Year

20,000

10,000

0

40,000

30,000

50,000

60,000

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

Figure F-9.eps

bitmap, labels redrawn

2000

2005

2010

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

MCO

LGA

FL

ORD

L

CMH

STL

IAD

CLE

CVG

SDF

DCA

MKE

IND

GSO

PHL

Figure F-10.eps

bitmap, labels redrawn

2000 2005 2010

Year

20,000

10,000

0

40,000

30,000

50,000

60,000

70,000

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

Figure F-11.eps

bitmap, labels redrawn

2000

2005

2010

2,500

2,000

1,500

1,000

0

4,500

3,500

500

IAH

4,000

3,000

LGA

BOS

PIT

IAD

ACK

CRW

SYR

BDL

RKD

EWR

BUF

CLL

DCA

Figure F-12.eps

bitmap, labels redrawn

10,000

5,000

0

20,000

15,000

25,000

30,000

2000 2005 2010

Year

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).
190 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-13.eps

bitmap, labels redrawn

25,000

20,000

15,000

10,000

0

30,000

5,000

35,000

2000

2005

2010

MC

O

LG

A

CVG

MI

A

MH

T

TLH

DAY

DTW

GR

R

TYS

JF

K

BO

S

RDU

DCA

GS

O

JAX

CHS

MS

P

ME

M

DCA

ATL

Figure F-14.eps

bitmap, labels redrawn

100,000

80,000

20,000

10,000

0

40,000

30,000

90,000

50,000

60,000

70,000

2000 2005 2010

Year

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 191

Figure F-16.eps

bitmap, labels redrawn

2000 2005 2010

Year

120,000

80,000

20,000

0

40,000

100,000

60,000

Figure F-15.eps

bitmap, labels redrawn

2000

2005

2010

25,000

20,000

15,000

10,000

0

30,000

5,000

35,000

CLE

IAH

EWR

DAL

CVG

IAD

RO

C

CRP

ME

M

DAY

STL

MCI

BNA

CLT

IND

RDU

OR

D

ATL

MS

P

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

Figure F-17.eps

bitmap, labels redrawn

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

2000

2005

2010

DEN

PHXCYS

PRC

FM

N

LAR

LBL

RKS

TEX

ALS

BIL

MCI

GC

C

GC

K

DDC

DIK

SHR

Figure F-18.eps

bitmap, labels redrawn

25,000

15,000

10,000

5,000

0

20,000

2000 2005 2010

Year

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 193

Figure F-19.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

18,000

14,000

2,000

16,000

12,000

RNO

YK

LAX

SMF

SJC

M

DEN

RDM

PSC

BO

GEG

EUG

I

SE

PDX

A

MFR

LWS

Figure F-20.eps

bitmap, labels redrawn

2000 2005 2010

Year

50,000

40,000

10,000

5,000

0

20,000

15,000

45,000

25,000

30,000

35,000

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).
194 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-21.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

2,000

12,000

PHX

CAE

CLT

LA

ORD

S

DEN

TUS

IAD

PHL

OGG

AUS

LIH

HNL

ATL

Figure F-22.eps

bitmap, labels redrawn

2000 2005 2010

Year

80,000

20,000

10,000

0

40,000

30,000

90,000

50,000

60,000

70,000

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 195

Figure F-23.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

14,000

2,000

16,000

12,000

DTW

MS

P

ME

M

CWA

ATWDSM

CVG

BRD

PLN

AZOABR

OK

C

BJI

DAYCAKSBN

SLC

ATL

DFW

AUS

Figure F-24.eps

bitmap, labels redrawn

80,000

20,000

10,000

0

40,000

30,000

50,000

60,000

70,000

2000 2005 2010

Year

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).
196 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-25.eps

bitmap, labels redrawn

2000

2005

2010

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

10,000

8,000

9,000

PHL CLT LGA PIT MDT BWI ROA SYR SBY CHO HHH ITH

Figure F-28.eps

bitmap, labels redrawn

2000 2005 2010

Year

40,000

10,000

5,000

0

20,000

15,000

45,000

25,000

30,000

35,000

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 197

Figure F-27.eps

bitmap, labels redrawn

18,000

10,000

8,000

6,000

4,000

0

14,000

12,000

2,000

16,000

2000

2005

2010

DTW

MS

P

ME

M

IND

MK

E

TYSLNK

MLI

TUL

BO

S

ATL

CVG

JF

K

LG

A

CLE

MB

S

Figure F-28.eps

bitmap, labels redrawn

2000 2005 2010

Year

80,000

20,000

10,000

0

40,000

30,000

50,000

60,000

70,000

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).
198 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-29.eps

bitmap, labels redrawn

2000

2005

2010

10,000

8,000

6,000

4,000

0

14,000

12,000

2,000

DA

PIT

Y

DCA

CL

PHL

T

CAK

DTW

PWM

BHM

CRW

HSV

LGA

TYS

Figure F-30.eps

bitmap, labels redrawn

2000 2005 2010

Year

10,000

5,000

0

20,000

15,000

25,000

30,000

35,000

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 199

Figure F-31.eps

bitmap, labels redrawn

2000

2005

2010

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

PHL DCA CLT DEN MKE MCI PIT CMH IND BDL

Figure F-32.eps

bitmap, labels redrawn

2000 2005 2010

Year

50,000

40,000

10,000

5,000

0

20,000

15,000

45,000

25,000

30,000

35,000

FIGURE F-31 Republic departures by city.

SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

FIGURE F-32 Republic total departures.

SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).
200 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

Figure F-33.eps

bitmap, labels redrawn

5,000

4,000

3,000

2,000

0

7,000

6,000

1,000

2000

2005

2010

IAD

OR

D

HPNORF

IND

ABE

CHO

IAH

SCE

CRW

LG

A

DEN

ATL

DCA

MS

P

CMHDFW

Figure F-34.eps

bitmap, labels redrawn

10,000

5,000

0

20,000

15,000

25,000

30,000

2000 2005 2010

Year

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 201

Figure F-35.eps

bitmap, labels redrawn

2000

2005

2010

25,000

20,000

15,000

10,000

0

5,000

SLC LAX DEN SFO ORD FAT SBA SAN PDX COS MSP MKE

Figure F-36.eps

bitmap, labels redrawn

2000 2005 2010

Year

180,000

160,000

40,000

20,000

0

80,000

60,000

100,000

120,000

140,000

FIGURE F-35 SkyWest departures by city.

SOURCE: Data from Bureau of Transportation Statistics (n.d.-a).

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 Environmental 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 emphasis on aviation safety. His research also includes airline economics, airline 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 economics 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 
204 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

and led the Operational Factors Division (responsible for flight operations, 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 Boeing 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 Research Laboratory, currently stationed at Wright-Patterson Air Force Base 

in Ohio. Previously, she was with the U.S. Army’s Aeromedical Research 

Laboratory, where she conducted numerous simulator and in-flight investigations on fatigue countermeasures and circadian rhythms in rated 

military pilots. She has also been a member of the Warfighter Fatigue 

Countermeasures Program and a distinguished visiting scholar at the 

U.S. Air Force Academy. She has served as a fatigue consultant for various U.S. Air Force commands and other military and civilian groups. 

She frequently provides fatigue management workshops, safety briefings, and training courses to aviation personnel, flight surgeons, commanders, 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 Chronobiology and director of the Unit for Experimental Psychiatry in the Department 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 Foundation. 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 physiological 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 Research 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 Society 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 include 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 Neuroscience 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 education 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 
206 THE EFFECTS OF COMMUTING ON PILOT FATIGUE

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 Office 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 human 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 include 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 simulation. 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 Neurological 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 Medical 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 documented in over 40 Office of Aviation Medicine (OAM) technical reports 

and in more than 125 presentations in a range of areas, including disorientation, 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 Office of the Year in 1999 and 2005. He is past president of the Oklahoma 

Psychological Association, the Division of Applied Experimental and Engineering Psychology of the American Psychological Association, and the 
APPENDIX 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). Previously, she worked as a program officer with the NRC’s Board on Atmospheric 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: Science 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 social 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 elements. 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 efforts 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.