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Economic Counsel to the Transportation Industry

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# Summary of CrewPairings, Inc. Economic Analysis of Flightcrew Member Duty and Rest Requirements Rulemaking

September 2012Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 1 

## Table of Contents

INTRODUCTION

................................ ................................ ................................ ................................ ..................... 3

B ACKGROUND

................................ ................................ ................................ ................................ ............................... 3 O BJECTIVES

................................ ................................ ................................ ................................ ................................ .. 4 C REW P AIRINGS B ACKGROUND

................................ ................................ ................................ ................................ ......... 5 C REW P AIRINGS M ETHODOLOGY

................................ ................................ ................................ ................................ ....... 5 C ASES

................................ ................................ ................................ ................................ ................................ .......... 7 O VERVIEW OF R ESULTS

................................ ................................ ................................ ................................ ................... 8 U NCERTAINTIES

................................ ................................ ................................ ................................ ............................. 8

CASE A: MAINLINE PAS SENGER NARROW

- BODY

................................ ................................ ................................ .... 9

S UMMARY

................................ ................................ ................................ ................................ ................................ .... 9 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ......................... 9 Buffers

................................ ................................ ................................ ................................ ................................ .. 9 Pairings

................................ ................................ ................................ ................................ ............................... 10 Bid Lines

................................ ................................ ................................ ................................ ............................. 11 Results

................................ ................................ ................................ ................................ ................................ 11

CASE B: MAINLINE PAS SENGER NARROW

- BODY

................................ ................................ ................................ .. 14

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 14 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 14 Buffers

................................ ................................ ................................ ................................ ................................ 14 Pairings

................................ ................................ ................................ ................................ ............................... 15 Bid Lines

................................ ................................ ................................ ................................ ............................. 16 Results

................................ ................................ ................................ ................................ ................................ 17

CASE C: MAINLINE PAS SENGER WIDE

- BODY

................................ ................................ ................................ ........ 19

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 19 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 19 Buffers

................................ ................................ ................................ ................................ ................................ 19 Pairings

................................ ................................ ................................ ................................ ............................... 20 Bid Lines

................................ ................................ ................................ ................................ ............................. 21 Results

................................ ................................ ................................ ................................ ................................ 22

CASE D: MAINLINE PAS SENGER WIDE

- BODY

................................ ................................ ................................ ........ 25

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 25 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 25 Buffers

................................ ................................ ................................ ................................ ................................ 25 Pairings

................................ ................................ ................................ ................................ ............................... 26 Bid Lines

................................ ................................ ................................ ................................ ............................. 27 Results

................................ ................................ ................................ ................................ ................................ 28

CASE E: REGIONAL PAS SENGER

................................ ................................ ................................ ............................ 30

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 30 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 30 Buffers

................................ ................................ ................................ ................................ ................................ 30 Pairings

................................ ................................ ................................ ................................ ............................... 31 Bid Lines

................................ ................................ ................................ ................................ ............................. 32Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 2 Results

................................ ................................ ................................ ................................ ................................ 32

CASE F: REGIONAL PAS SENGER

................................ ................................ ................................ ............................ 35

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 35 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 35 Buffers

................................ ................................ ................................ ................................ ................................ 35 Pairings

................................ ................................ ................................ ................................ ............................... 36 Bid Lines

................................ ................................ ................................ ................................ ............................. 37 Results

................................ ................................ ................................ ................................ ................................ 37

CASE G: ALL

- CARGO NARROW

- BODY

................................ ................................ ................................ ................... 40

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 40 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 40 Buffers

................................ ................................ ................................ ................................ ................................ 41 Pairings

................................ ................................ ................................ ................................ ............................... 41 Bid Lines

................................ ................................ ................................ ................................ ............................. 42 Results

................................ ................................ ................................ ................................ ................................ 43

CASE H: ALL

- CARGO WIDE

- BODY

................................ ................................ ................................ ......................... 45

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 45 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 45 Buffers

................................ ................................ ................................ ................................ ................................ 46 Pairings

................................ ................................ ................................ ................................ ............................... 47 Bid Lines

................................ ................................ ................................ ................................ ............................. 49 Results

................................ ................................ ................................ ................................ ................................ 50

CASE I: SUPPLEMENTAL WIDE

- BODY

................................ ................................ ................................ .................... 52

S UMMARY

................................ ................................ ................................ ................................ ................................ .. 52 D ETAILED R ESULTS

................................ ................................ ................................ ................................ ....................... 52 Buffers

................................ ................................ ................................ ................................ ................................ 53 Pairings

................................ ................................ ................................ ................................ ............................... 54 Bid Lines

................................ ................................ ................................ ................................ ............................. 55 Results

................................ ................................ ................................ ................................ ................................ 56

APPENDIX 1: PAY VARI ABLES

................................ ................................ ................................ ............................... 58Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 3 

## Introduction

**BACKGROUND**

The Flightcrew Member Duty and Rest Requirements Notice of Proposed Rulemaking (NPRM) published by the FAA on September 14, 2010 (the NPRM) proposed new regulatio ns applicable to certificate holders and their flightcrew members operating under 14 CFR Part 121. The purpose of the proposed regulations was to reduce the risk to aviation safety of flightcrew member fatigue. The proposed rules and regulations would repl ace the existing flight time limitations and rest requirements contained in 14 CFR Part 121 Subparts Q, R and S (the FAR).

After reviewing the comments received from the aviation community and the results of detailed analyses of the differences in air carr ier flightcrew member scheduling cost and predicted flightcrew member fatigue resulting from the adoption of the NPRM, the FAA produced an internal pre

- decision draft of the regulations (the Final Rule ) in April 2011. The Final Rule was significantly diffe rent from the NPRM. As a whole, the changes resulted in the Final Rule being less costly in terms of air carrier flightcrew member scheduling than the NPRM.

The FAA published the final Flightcrew Member Duty and Rest Requirements in December 2011. The rule elements of the published Final Rule were nearly identical to the internal pre

decision Final Rule . However, the set of carriers required to comply with the published Final Rule was different fr om the set of carriers required to comply with either the NPRM or internal
pre

- decision Final Rule . Only air carriers that conducted passenger operations under 14 CFR Part 121 were required to comply with the published Final Rule. Air carriers that conduct ed all

- cargo operations under 14 CFR Part 121 were not required to comply with the published Final Rule, as they were under the NPRM.

GRA

, Incorporated, in support of the FAA, subcontracted with CrewPairings, Inc. to analyze the air carrier flightcrew memb er scheduling impact of the NPRM and Final Rule . CrewPairings selected a representative set of air carrier flight and flightcrew member schedules for in

- depth analysis. The air carriers selected included passenger short

- haul, long

- haul, regional and supple mental operators and all

- cargo operators.
This report is a summary of CrewPairings’ Final Rule analysis prepared by GRA, Incorporated and reviewed by CrewPairings

. T he CrewPairings Final Rule results are considered to be
accurat e representations of the im pact of the Final Rule on flightcrew member scheduling

.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 4 

### OBJECTIVES

The FAA estimated the costs of the NPRM in a Regulatory Impact Analysis (RIA) published in September 2010 with the NRPM. Costs were categorized in four main components: flight operations, schedule reliability, fatigue training and rest facilities. Flight operations accounted for approximately 60 percent ($760 million) of the total nominal cost of the NPRM ($1,254 million). The flight operations component was composed of several sub

- compone nts, with flightcrew member scheduling cost accounting for the majority of flight operations costs

. Numerous commenters objected to the NPRM RIA cost estimate . For example , the Air Transport Association of America, Inc. (ATA) 1 estimated that the nominal flight operations cost of the NPRM would be $8,759.0 million, or more than 11 times the cost estimated by the FAA, even though ATA’s cost estimate included only mainline, low cost and large cargo carriers while the NPRM RIA cost estimate included all carriers subject to the rule. 2 American Airlines, Inc. estimated that its nominal flight operations cost to comply with the NPRM would be $4,970 million, or more than six times the cost estimated by the FAA for the entire Part 121 in dustry. 3

Commenters asserted that the NPRM RIA cost estimate was based on faulty assumptions and cost inputs. For instance, ATA stated that, “Unsupportable assumptions include, but are not limited to... Collective bargaining agreement adjustments to comply w ith Proposal assumed to have no cost; and

, Ability of carriers to optimize their results to reduce cost assumed without factual bases or modeling.” 4 In particular, commenters objected to the FAA’s assumption that optimization would reduce carriers’ flightc rew scheduling compliance cost by 25 percent in the short

- term. As stated in the NPRM RIA, “This discount off of raw costs approximates the savings expected from the computer models used to build schedules; flight schedules will be rearranged into new trip s that meet the new constraints of the rule.” 5

The objective of contracting with CrewPairings was to respond to commenters by developing better flightcrew member scheduling cost estimates. The CrewPairings results eliminate d the need for FAA to make assump tions regarding flightcrew member scheduling actions that carriers may take by using a commercial flightcrew member scheduling model used by ca rriers in real

world operations. The CrewPairings results reflect ed the outcome of the process by which carriers create the most efficient flightcrew member schedule possible, in compliance with numerous constraints, including federal regulations, labor agreements, market demands and operational requirements.

1 The ATA changed its name to Airlines for America (A4A) in 2012.
2 Comments of the Air Transport Association of America, Inc. in the matter of Notice of Proposed Rulemaking for Flightcrew Member Duty and Rest Requirem ents, November 15, 2010.
3 Comments of American Airlines, Inc. in the matter of Notice of Proposed Rulemaking for Flightcrew Member Duty and Rest Requirements, November 15, 2010.
4 Comments of the Air Transport Association of America, Inc. in the matter of Notice of Proposed Rulemaking for Flightcrew Member Duty and Rest Requirements, November 15, 2010.
5 Federal Aviation Administration, Regulatory Impact Analysis of Flightcrew Member Duty and Rest Requirements Notice of Proposed Rulemaking, September 3, 20 10, p.85.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 5 The FAA used the CrewPairings results to develop the Regul atory Impact Analysis for the Final Rule. 6 The FAA calculated the change in crew scheduling cost per flightcrew member attributable to the Final Rule by multiplying FAA

- estimated unit costs by CrewPairings

calculated changes in various crew scheduling metr ics . Every Part 121 carrier was matched to the most similar CrewPairings case or combination of cases based on characteristics such as fleet, operation type and labor agreement. The change in cost per flightcrew member from the CrewPairings analysis was then extrapolated to the number of flightcrew members employed by each Part 121 carrier.



### CREW **PAIRINGS B ACKGROUND** 

CrewPairings, Inc. provides crew pairing and schedule optimization services to airlines and is owned by Dr. Robert Gerbracht and Candler Brooks. The firm has more than 70 years of combined experience providing crew pairing optimization services to the airline industry. CrewPairings uses the Cygnus system, which consists of a pairing and bid line optimizer, to create production

- calib er solutions for its clients.

Dr. Gerbracht developed the Cygnus system over a period of 40 years. The system has been implemented at more than 30 major airlines worldwide. Cygnus has been used at all types of airlines, including global, national, regional and freight airlines.



### CREW **P AIRINGS**  **M ETHODOLOGY** 

Isolating the impact of the flightcrew member duty and rest regulations from the various other scheduling practices and constraints is essential for an accurate assess ment of the impact of the Final Rule. CrewPairings achieved this objective by including all of the regulatory, contractual and discretionary scheduling practices used by each carrier during the flightcrew member scheduling process. Cygnus settings were validated by independently creating a Bas eline Solution and comparing it with the Production Solution provided by each carrier. Cygnus settings were considered validated once the Baseline Solution was equivalent to the Production Solution in terms of cost and productivity. After validation of the Baseline Solution, the Final Rule Solution was created by substituting the Final Rule for the FARs. Any observed change in crew scheduling metrics between the Baseline Solution and Final Rule Solution was solely attributable to the Final Rule

. Figure 1 provides an overview of CrewPairings’ methodology.

6 Federal Aviation Administration, Regulatory Impact Analysis of Flightcrew Member Duty and Rest Requirements Final Rule, November 18, 2011.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 6 **Figure 1**  **: CrewPairings Methodology Overview**

CrewPairings obtained a set of data files from each of the carriers selected for analysis and imported the files into Cygnus. The carrier

- provided data files included flight schedules, aircraft flow information, a set of production pairings (the Production Solution) a nd the carrier’s rule set (contractual, management and discretionary rules). Typical carrier rule sets included crew base locations and aircraft types , minimum and maximum block hours within each crew base, minimum ground time for an aircraft swap

, and sch eduling buffers for maximum and/or minimum flight time, rest time and duty time. Existing FARs were already included in Cygnus.

After importing the data files into Cygnus, CrewPairings executed the Cygnus optimization models to produce the Baseline Solutio n. The Baseline Solution was compared with the Production Solution to verify that CrewPairings accurately inputted all of the carrier

- provided data files. Metrics such as the amount s of credit hours, duty periods, hotel room nights, distribution of time am ong bases and number of aircraft swaps were compared between the solutions. In all cases, the Baseline Solution was virtually identical to the Production Solution in terms of cost and productivity. Essentially, this meant that the CrewPairings

- generated Ba seline Solution could be flown by the carrier in full compliance with all contractual, management, discretionary and existing reg ulatory constraints with no significant differences from the Production Solution.

The Final Rule Solution was created after val idation of the Baseline Solution by replacing the FARs with the Final Rule . Several elements of the Final Rule were buffered to reflect the fact that the Final Rule applie d to actual, rather than planned, flight, duty and rest times. The specificSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 7 buffers w ere chosen based on conversations with crew schedulers at the carriers. No substantial changes were made to flight schedules, aircraft flow or carrier rule sets. 7

The Final Rule was responsible for change s in crew scheduling metrics between the Baseline So lution and Final Rule Solution because the only change was replacement of the FARs with the Final Rule . The Final Rule Solution consist ed of production

- ready pairings and bid lines. The carrier could load the Final Rule Solution into its crew management sy stem and operate the exact same schedule as in the Production Solution, while being in full compliance with all contractual, management, discretionary and Final Rule regulatory constraints.

The number of flight segments and aircraft block hours differed sl ightly between the Baseline Solution and Final Rule Solution for most cases because of the issue of carry

- in and carry

- out flight segments. As previously described, Cygnus output consisted of production

- ready pairings and bid lines. Due to the replacement of the FAR with the Final Rule, the flight segments placed in the carry

- in and/or carry

- out sets were not necessarily identical in the Baseline Solution and Final Rule Solution. Carry

- in flight segments were those flight segments that started in the calend ar month of the scheduling period of analysis, but were included in pairings from the preceding scheduling period. Carry

- out flight segments were those flight segments that started in the calendar month of the scheduling period of analysis, but were includ ed in the subsequent scheduling period. For all cases, the differences in carry

- in and carry

- out flight segments for each case were small and did not significantly impact the outcome of the CrewPairings analysis.

This report presents crew scheduling metric s for each solution that relate to how flightcrew members are compensated. Flightcrew members are compensated based on the number of credit hours worked, which include flight time, credit for other types of work and credit subject to minimum guarantees, depending on labor agreements. Per diem is paid based on time away from base ( TAFB ) , depending on labor agreements. Carriers incur costs for hotel rooms provided for flightcrew members during trips. More details on flightcre w member pay practices are available in Appendix 1.



### C **ASES**

CrewPairing s selected eight “cases”, each consisting of a carrier fleet type, designed to be representative of the Part 121 industry. In addition, a “synthetic” supplemental carrier case was created based on one of the eight cases. The procedures described in the CrewPairings Methodology section were carried out for each of the nine cases and Final Rule results were calculated.

The cases consisted of two mainline passenger narrow

- body fleets operating mainly domestic short

- haul service, two mainline passenger wide

- body fleets operating mainly international long

haul service, two regional passenger fleets, one all

- cargo narrow

- body fleet operating mainly

7 In an extremely limited number of situations, flight schedules were changed by a small amount to reflect the fact that carriers are likely to make slight adjustments to flight schedules rather than incur large increases in flightcrew member scheduling cos ts.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 8 domestic short

- haul service, one all

- cargo wide

- body fleet operating mainly international long

haul service and one supplemental wide

- body fleet operating mainly international long

- haul service.

For a few cases, un ique or temporary carrier scheduling constraints were eliminated to make the results more applicable to the industry. In these cases, the constraints were eliminated for both the Baseline and Final Rule Solution s , so that the impact of the Final Rule could be isolated.



### OVERVIEW OF RESULTS

Since the objective of this analysis was to determine the impact of the Final Rule on carrier flightcrew member scheduling cost, this report presents results in terms of their impact on carrier flightcrew member scheduling cost. Terms such as “more constraining”, “less efficient” and “negative impact” mean that the Final Rule will result in carriers expending more resources (i.e. credit hours, TAFB and/or hotel rooms) to operate the same flight schedule as under the FAR

. Te rms such as “less constraining”, “more efficient” and “positive impact” mean that the Final Rule will result in carriers expending fewer resources (i.e. credit hours, TAFB and/or hotel rooms) to operate the same flight schedule as under the FAR.

The impact of the Final Rule depend ed greatly on the operation type. The Final Rule slightly improved crew scheduling results for one passenger wide

- body case and one passenger narrow

body case, while it made results slightly worse for the other passenger wide

- body case and other
passenger narrow

- body case . The Final Rule worsened crew scheduling results for the regional passenger cases because of their use of short rest periods which were not possible under the Final Rule . The impact on crew sche duling was more double layovers and/or crew staging for regional carriers

. The Final Rule worsened crew scheduling results for the all

- cargo operator cases because of reduced maximum flight time limits for international operations, reduced maximum flight d uty period limits and consecutive nighttime operations limitations. The Final Rule reduced crew scheduling results for the supplemental case because the Final Rule was considerably more constraining than the supplemental FARs and typical supplemental carri er labor agreement.



### UNCERTAINTIES

Flight duty period time, flight time and rest time buffers will become essential flightcrew member scheduling considerations because the Final Rule limits are based on actual, rather than scheduled, times. Carrier flightc rew schedulers will need to apply buffers during the scheduling process to ensure that operational delays do not cause crewmember schedules to become illegal at sub

- optimal rates. CrewPairings explored different amounts of buffering; the results can vary

s ignificantly depending on the buffers.

CrewPairings’ results were based on buffers chosen during consultation with the flightcrew schedulers at the carriers that provided data. However, it is reasonable to expect that flightcrew schedulers will experiment with and refine buffer s as they gain experience with the Final Rule and its impacts on flightcrew member scheduling.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 9 

## Case A: Mainline Passenger Narrow

**- Body** 

**SUMMARY**

Case A consisted of the short

- haul operations of a mainline passenger carrier using narrow

- body aircraft. The Final Rule Solution was less efficient in terms of credit hours than the Baseline Solution mainly because of the increased minimum rest period. This result ed in longer layovers for flightcrew members, which increase d the number of credit hour s , TAFB and hotel rooms required . The changes in maximum flight time and maximum FDP time limits had little impact on Case A.



### DETAILED RESULTS

Case A consiste d of a subset of the short

- haul operations of a mainline passenger carrier using

narrow

- body aircraft during the January 2010 scheduling period. There were more than 16,000 flight segments during the scheduling period, most of which were domestic. However, there were also some flight segments to Mexico and the Caribbean. Since the carr ier mixed domestic and international flying in its crew pairings, all of these flight segments were included in the study.

The augmentation and acclimation elements of the Fin al Rule d id not affect Case A , as all of the flight segments operated with an unaugmented crew and all of the flightcrew members remain ed acclimated at all times. Case A did not have any split duty periods.



### Buffers

The three main Final Rule rule elements t hat affected Case A were the maximum unaugmented flight time, maximum unaugmented FDP time and minimum rest period limits. CrewPairings applied buffers to both the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rat her than planned, operations. In Figure 2 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the

“ Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Eff ective Final Rule ” limit, the contractual rule was shown in the “Effective Final Rule ” column.

Figure 2 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current C BA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 10 **Figure 2**  **: Case A Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Production Solution) were cons tructed with the constraints of the “Effective Current Rule” column in Figure 2 , in addition to all other FAR, contractual, management and discretionary constraints no t shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 2

, in addition to all other Final Rule

, contractual, management and discretionary constraints not shown.

The maximum flight time limit applicable to the Baseline Solution was 7:50 hours, which was the FAR limit less the ten minute buffer used by the carrier in practice. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum flight time limit of the Final Rule was therefore expected to have a mixed impact on the Fi nal Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum FDP limit applicable to the Baseline Solution was 8:00

- 12:30 hours, which was the CBA limit less a 30 minute debrief period. The maximum FDP limit applicable to the Final Rule Solution was the same as the maximum FDP limit applicable to the Baseline Solution, because the CBA less a 30 minute buffer appli ed by CP was more constraining than the Final Rule . The maximum FDP limit of the Final Rule was therefore expected to have no impact on the Final Rule Solution pairings.

The minimum rest period applicable to the Baseline Solution was 9:00

- 12:00 hours, depe nding on the amount of flight time in the previous 24 hour period. The CBA minimum rest period was 9:00 hours, but the FAR require d additional rest time if the amount of flight time in the Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final
Rule 2

Maximum Unaugmented

Flight Time 8:00

- - 0:10 7:50 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Unaugmented

FDP Time 6 16:00 8:30 - 13:00 0:30

- 8:00 - 12:30 9:00 - 14:00 3 0:30 5 8:00 - 12:30 3

Minimum Unaugmented

Rest Time 8:00 - 12:00 4 9:00

- - 9:00 - 12:00 10:00

- 10:00

6 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time Rule Element Time in Hours:Minutes

1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP

4 Depending on the amount of flight time in the past 24-hour period

5 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 11 preceding 24 hour period exceed ed eight hours. The minimum rest per iod applicable to the Final Rule Solution was 10 :00 hours , which was expected to have a negative impact on the Final Rule Solution pairings because the Final Rule require d an additional hour of rest in most situations

. 

### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraint s. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, contractual, management and discretionary constraints.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were ap plicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 14 days off

,

• No single days off

,

• No single working days, except at the beginning/ending of the month

,

• A target of 80 credit hours, with a maximum of 92

,

• Minimize the amount of open time

,

• No reserve days on any flying line , and

• All lines were valid for one captain and one first officer.

In addition to these rules, some common rules intended to improve flightc rew members’ quality of life were imposed, including:

• At least one block of three consecutive days off

,

• Blocks of two consecutive working days were allowed, but penalized, with no more than two in any line

,

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized, in any line , and

• No more than five blocks of consecutive working days during the month, to reduce the need for commuters to commute to/from their base.



### Results

The Final Rule significantly impacted the practice of scheduling flightcrew members to the contract minimum 9:00 rest period to efficiently crew overnight aircraft due to the one hour increase in the mi nimum rest period. Many stations had two or more aircraft overnights and it was common practice to arrange the overnight ground times such that the earliest arriving aircraft could take the latest departing morning flight with the minimum 9:00 hour rest period. The other aircraft ’s crew did not have enough time for a minim um overnight rest period and typically required midday staged crews. Often there were just enough midday flights to provideSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 12 staging for the aircraft that required it. Most of the Baseline Solution short layovers were no longer feasible for the Final Rule S olution.

To maximize efficiency , Cygnus attempted to stage the crews on a midday flight, turning one layover into two. However, there frequently were no midday flights available for staging, necessitating either daily deadhead flights or double layovers o f around 33 hours. The average layover time increased from 15:00 in the Baseline Solution to 16:46 in the Final Rule Solution, which was a significant increase of nearly two hours

. The result was a sizeable increase in the number of required hotel rooms, d eadhead time and overall synthetic time. 8

None of the Final Rule cumulative flight or flight duty time constraints adversely affected the bid lines for the Final Rule Solution.

The Final Rule Solution was approximately three percent less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 3

. The average number of duty hours and block hours per duty period decreased, which meant that the average flightcrew member had to work slightly more days per month. The Final Rule Solution required 4.5 percent more flightcrew member working days to comple te the same flight schedule as in the Baseline Solution.

**Figure 3**  **: Case A Monthly Results** 

Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case A flightcrew members were paid full credit for all block hours and deadhead hours. They also receive d a 1

- for

- 3.5 trip rig and a duty rig of 1

- for

- 2 during the day or 1

- for

- 1.75 at night. The average duty period minimum was 5:15.

8 Synthetic time is the difference between block hours and credit hours and is primarily generated by deadhead credit, duty rigs, minimum guarantee, and/or trip rig. Metric Crew Position Baseline Final Rule

Lines CA or FO 462 477 15 3.2% Credit Hours All 74,274 76,461 2,187 2.9% Block Hours All 71,303 71,288 -15 0.0% Aircraft Block Hours N/A 35,652 35,644 -8 0.0% Domestic TAFB All 251,500 270,160 18,660 7.4% International TAFB All 0 0 0 N/A Hotel Rooms All 8,772 9,432 660 7.5% Average Duty Hours per Duty Period CA or FO 9.2 8.8 -0.4 -4.3%
Average Block Hours per Duty Period CA or FO 5.5 5.4 -0.1 -1.8%
Average Days Off per Month CA or FO 15.3 15.1 -0.2 -1.1% ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 13 Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. All TAFB was domestic and increased by more than seven percent

.
Hotel rooms were the numb er of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. The Final Rule Solution resulted in the use of more than seven percent more hotel rooms.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 14 

## Case **B : Mainline Passenger Narrow** 

**- Body** 

**SUMMARY**

Case B consisted of the short

- haul operations of a mainline passenger carrier using narrow

- body aircraft. Although the effective Final Rule maximum FDP time and minimum rest period limits

were more restrictive than current practice, the Final Rule Solution was actually slightly more efficient in terms of credit hours than the Baseline Solution. Cygnus was able to re

- optimize flightcrew member schedules to take advantage of less restrictive maxi mum flight time limits in a significant number of situations

.


### DETAILED RESULTS

Case B consisted of a subset of the short

- haul operations of a mainline passenger carrier using

narrow

- body aircraft during the July 2010 scheduling period. There were more tha n 20,000 flight segments during the scheduling period, most of which were domestic. However, there were also some flight segments in Canada, Mexico, the Caribbean, Central America and South America. Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight

s egments were included in the study.

The augmentation and acclimation elements of the Final Rule did not affect Case B , as all of the flight segments operated with an unaugmented crew and all of the flightcrew me mbers remain ed acclimated at all times. The Baseline Solution did contain a significant number of split duties because a number of redeye flights operated nightly.



### Buffers

The three main Final Rule rule elements that affected Case B were the m aximum u naug mented f light time, m aximum u naugmented FDP time and minimum r est period limits. CrewPairings applied buffers to both the maximum flight time and FDP time limits to reflect the fact that they applied to actual, rather than planned, operations. In Figure 4 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the co ntractual rule is shown in the “Effective Final Rule ” column.

Figure 4 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column . The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column

.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 15 **Figure 4**  **: Case B Buf fers** 



### Pairings

The Baseline Solution pairings (equivalent to the Production Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 4 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 4

, in addition to all other Final Rule , contractual, management and discretionary constraints not shown.

The maximum flight time limit applicable to the Baseline Solution was 8:00 hours, which was the FAR limit. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum flight time limit of the Final Rule was therefor e expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum FDP limit applicable to the Baseline Solution was 10:15

- 13:15 hours, which was the CBA limit , less a 15 minute debrief . The maximum FDP limit applicable to the Final Rule Solution was 8:30

- 13:15 hours, depending on FDP start time, after application of a 30 minute buffer. The low end was the buffered Final Rule and the high end was the CBA limit. The maximum FDP limit of the Final Rule was therefore expected to have a negative impact on the Final Rule Solution pairings; the Effective Final Rule limit was more constraining than the Effective Current Rule in most situations.

The minimum rest period applicable to the Baseline Solution was 8:15

- 12:00 hours, depending on the amount of flight time in the previous 24 hour period, which was the buffered FAR requirement. The minimum rest per iod applicable to the Final Rule Solution was 10 hours. The Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final
Rule 2

Maximum Unaugmented

Flight Time 8:00

- - - 8:00 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Unaugmented 6
FDP Time 16:00 10:30 - 13:30 0:15

- 10:15 - 13:15 9:00 - 14:00 3 0:30 5 8:30 - 13:15 3

Minimum Unaugmented

Rest Time 8:00 - 12:00 4 8:00

- 0:15 8:15 - 12:00 4 10:00

- 10:00

4 Depending on the amount of flight time in the past 24-hour period

5 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00

6 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time 1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP Rule Element Time in Hours:MinutesSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 16 minimum rest period of the Final Rule w as therefore expected to have a negative impact on the Final Rule Solution pairings because t he Effective Final Rule required minimum rest period was nearly two hours greater than the Effective Current Rule in most situations

. 

### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the solutions for Case B

. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule , contractual, management and discretion ary constraints.

The only Final Rule constraint that would potentially have had a significant impact on the Final Rule Solution bid lines was the consecutive nighttime operations limit . This constraint limit ed flightcrew members to three consecutive flight duty periods that impinge on the window of circadian low unless the carrier provide d the flightcrew member with a minimum two hour rest opportunity in a suitable accommodation during each FDP, in which case five consecutive flight duty periods were permit ted.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were applicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were :

• Minimum of 12 days off

,

• No single days off

,

• No single working days, except at the beginning/ending of the month

,

• A target of 83 credit hours, with a maximum of 92

,

• Minimize the amount of open time

,

• No reserve days on any flying line , and

• All lines are va lid for one captain and one first officer.

In addition to these rules, some common rules intended to improve flightcrew members’ quality of life were imposed, including:

• At least one block of three consecutive days off

,

• Blocks of two consecutive working da ys were allowed, but penalized, with no more than two in any line

,

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized, in any line , and

• No more than five blocks of consecutive w orking days during the month, to reduce the need for commuters to commute to/from their base.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 17 

### Results

The Final Rule Solution was slightly more efficient in terms of credit hours than the Baseline Solution, as shown in Figure 5 . Re

- optimization of flightcrew member schedules under the Final Rule resulted in almost three percent less TAFB (net of domestic and international TAFB ) a nd nearly six percent f ewer hotel roo m nights required.

The increased minimum rest requirement (from 8:15 to 10:00) had the largest negative impact on the Final Rule Solution. The average l ayover time increased from 17:26 to 18:11, which reflected the increased usage of double layovers in the Final Rule Solution. The number of duty periods in the Final Rule Solution decreased relative to the Baseline Solution but the number of calendar days increased. This translated to 1.2 percent fewer days off per month per bid line.

Despite the negative impacts of the minimum rest requirement, the Final Rule had a positive impact as a whole because Cygnus was able to take advantage of the increased maximum flight time limit (maximum buffered flight time limit of 8:30 for duty periods beginning between 05: 00 and 19:59 base time) to create more efficient pairings. In the Final Rule Solution, 13 percent of duty periods exceeded eight hours of block time. The average block time per duty period increased by 3.4 percent from the Baseline Solution to the Final Ru le Solution.

The Final Rule split duty constraint did not impact the Final Rule because each split duty had at least six hours of time between flight segments, which was much more than the three hours minimum rest opportunity required by the Final Rule, ev en after accounting for the 1:45 of debrief, transfer to rest facility and brief time.

The consecutive nighttime operations constraint did not ultimately have a negative impact on the Final Rule Solution, as Cygnus was able to create bid lines with no loss of productivity resulting from that constraint relative to the Baseline Solution.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 18 **Figure 5**  **: Case B Monthly**  **Results**

Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case B flightcre w members were paid full credit for all block hours and deadhead hours. They also receive d a 1

- for

- 4 trip rig for trips with a duty break of more than 29 hours

. Time away from base was all time spent away from a flightcrew member’s base while on a trip, fr om the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. Domestic TAFB decreased by more than four percent and international TAFB increased by almost one percent

.
Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. Metric Crew Position Baseline Final Rule

Lines CA or FO 849 843 -6 -0.7% Credit Hours All 140,975 140,547 -429 -0.3% Block Hours All 138,313 138,386 73 0.1% Aircraft Block Hours N/A 69,157 69,193 37 0.1% Domestic TAFB All 355,923 340,888 -15,035 -4.2% International TAFB All 156,387 157,417 1,030 0.7% Hotel Rooms All 15,900 14,956 -944 -5.9% Average Duty Hours per Duty Period CA or FO 8.1 8.5 0.4 4.9%
Average Block Hours per Duty Period CA or FO 5.8 6.0 0.2 3.4%
Average Days Off per Month CA or FO 14.7 14.6 -0.2 -1.2% ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 19 

## Case C: Mainline Passenger Wide

**- Body** 

**SUMMARY**

Case C consisted of the long

- haul operat ions of a mainline passenger carrier using wide

- body aircraft. The Final Rule Solution was slightly more efficient in terms of credit hours than the Baseline Solution

. T he increased minimum rest period result ed in longer layovers for flightcrew members, wh ich increase d credit hour s , TAFB and hotel rooms

. However, these impacts were mostly offset by the decreased credit hours, TAFB and hotel rooms th at resulted from the ability to reduce the number of flightcrew members on some augmented operations because o f increased maximum flight time limits and increased maximum flight time limits for unaugmented operations

. 

### DETAILED RESULTS

Case C consisted of a subset of the long

- haul operations of a mainline passenger carrier using wide

- body aircraft during the Januar y 2010 scheduling period. There were more than 6,000 flight segments during the scheduling period, most of which were domestic. However, there were also flight segments to Mexico, the Caribbean South America, Europe, Africa, the Middle East and Asia. Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight segments were included in the study.

Nearly all of the Final Rule constraints affect ed Case C, as many flight segments were operated with augmented crews. Case C ha d only a few split duty periods.



### Buffers

The six main Final Rule rule elements that affected Case C were the maximum unaugmented and augmented flight time, maximum unaugmented and augmented FDP time and minimum unaugmented and augmented rest period limits. CrewPairings applied buffers to the maximum flight time and FDP time limits to reflect the fact that they applied to actual, rather than planned, operations. In Figure 6 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. Howev er, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the contractual rule is shown in the “Effective Final Rule ” column.

Figure 6 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 20 **Figure 6**  **: Case C Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Production Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 6 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 6
, in addition to all other Final Rule , contractual, management and discretionary constraints not shown.

The maximum unaugmented flight time limit applicable to the Baseline Solution was the FAR limit of 8:0 0 hours. The maximum unaugmented flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum unaugmented flight time limit of the Final Rul e was therefore expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum augmented flight time limit applicable to the Baseline Solution was the FAR limit of 12 :00 hours for crews with one additional pilot or the FAR limit of 16 :00 hours for crews with two additional pilots, less a ten minute buffer. The maximum aug mented flight time limit applicable to the Final Rule Solution was the Final Rule limit of 13 :00 hours for crews with one Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final Rule 2

Maximum Unaugmented

Flight Time 8:00

- - - 8:00 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Augmented Flight Time (3 crew) 12:00 (4 crew) 16:00 - - 0:10 (3 crew) 11:50 (4 crew) 15:50 (3 crew) 13:00 (4 crew) 17:00 0:30 (3 crew) 12:30 (4 crew) 16:30

Maximum Unaugmented 8

FDP Time 16:00 8:30 - 13:00 0:30

- 8:00 - 12:30 9:00 - 14:00 3 0:30 4 8:00 - 12:30 3

Maximum Augmented FDP Time 8 (3 crew) 16:00 (4 crew) no limit (3 crew) 16:00 (4 crew) 18:00 - - (3 crew) 16:00 (4 crew) 18:00 (3 crew) 15:00 - 17:00 5 (4 crew) 17:00 - 19:00 5 0:30 4 (3 crew) 14:30 - 16:00 5 (4 crew) 16:30 - 18:00 5

Minimum Unaugmented

Rest Time 8:00 - 12:00 6 9:00

- - 9:00 - 12:00 6 10:00

- 10:00

Minimum Augmented Rest Time 8:00 - 18:00 7 9:00

- - 9:00 - 18:00 7 10:00

- 10:00

8 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time 1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

Rule Element Time in Hours:Minutes

5 Depending on FDP start time; Maximum show n is for aircraft equipped w ith Class 1 rest facility, reduced if aircraft is equipped w ith low er class rest facility 2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP

6 Depending on the amount of flight time in the past 24-hour period

7 Flag rules, including double out if crew exceeds 8-in-24, 18:00 after breaking 8-in-24, 20-in-48 or 24-in-72 4 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 21 additional pilot or the Final Rule limit of 17 :00 hours for crews with two additional pilots, less a 30 minute buffer. The maximum aug mented flight time limit of the Final Rule was therefore expected to have a positive impact on the Final Rule Solution pairings because the Effective Final Rule maximum augmented flight time was 40 minutes greater than the Effective Current Rule

.
The maxim um unaugmented FDP limit applicable to the Baseline Solution was 8:00

- 12:30 hours, which was the CBA limit less a 30 minute debrief period. The maximum unaugmented FDP limit applicable to the Final Rule Solution was the same as the maximum unaugmented FDP limit applicable to the Baseline Solution, because the CBA less a 30 minute debrief period

was more constraining than the Final Rule . The maximum unaugmented FDP limit of the Final Rule was therefore expected to have no impact on the Final Rule Solutio n pairings.

The maximum augmented FDP limit applicable to the Baseline Solution was 16 :00 hours for crews with one additional pilot and 18 :00 hours for crews with two additional pilots, which were the CBA limits. The maximum augmented FDP limit applicable to the Final Rule Solution was the Final Rule less the 30 minute buffer applied by CrewPairings. The maximum augmented FDP limit of the Final Rule was therefore expected to have a negative impact on the Final Rule Solution pairings because the Effective Fi nal Rule was more restrictive than the Effective Current Rule in most situations

. The minimum rest period applicable to the Baseline Solution was 9:00

- 1 8 :00 hours, depending on the amount of flight time in the previous 24 hour period. The CBA minimum rest period was 9:00 hours, but the FAR require d additional rest time if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The minimum rest period applicable to the Final Rule Solution was 10 :00 hours, which was expected to have a negative impact on the Final Rule Solution pairings because the Final Rule require d an additional one hour of rest in most situations.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Soluti ons using the pairings from the solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, contractual, management and discretionary constraints.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were applicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 14 days off

,

• No single days off

,

• No single working days, except at the beginning/ending of the month

,

• A target of 76 credit hours, with a maximum of 84

,

• Minimize the amount of open time

,Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 22 • N o reserve days on any flying line

,

• Two

- day blocks of both work and days off prohibited in most cases , and

• Blocks of work normally limited to a maximum of six days, although individual trips longer than six days are allowed to exceed the limit.

Lines were b uilt separately for each base and crew type.



### Results

The Final Rule Solution was slightly more efficient in terms of credit hours than the Baseline Solution, as shown in Figure 7 . Re

- optimization of flightcrew member schedules under the Final Rule resulted in almost four percent more TAFB and almost ten percent more hotel room nights

. **Figure 7**  **: Case C Monthly Results**

The increased minimum rest period and increased augmented flight time limits had the greatest impact during creation of the Final Rule Solution pairings. The increased minimum rest period negatively impacted the pairings while the increased augmented fligh t time limits positively impacted the pairings ; the net impact was a slight decrease in credit hours

. The increased minimum rest period negatively impacted domestic operations pairings for the most part because the carrier created flight schedules that wer e designed to optimize flightcrew member scheduling given the minimum 9:00 hour rest period prescribed by the labor agreement. Metric Crew Position Baseline Final Rule

CA or FO 451 457 6 1.3% IO 205 202 -3 -1.5% RC 14 8 -6 -42.9% Credit Hours All 85,806 85,736 -70 -0.1% Block Hours All 80,754 77,264 -3,490 -4.3% Aircraft Block Hours N/A 32,412 32,424 13 0.0% Domestic TAFB All 126,747 130,610 3,863 3.0% International TAFB All 205,626 213,974 8,348 4.1% Hotel Rooms All 8,241 9,032 791 9.6% CA or FO 9.3 9.5 0.2 2.2% IO 10.8 11.0 0.2 1.9% RC 13.6 14.0 0.4 2.9% CA or FO 6.9 6.9 0.0 0.0% IO 9.1 7.4 -1.7 -18.7% RC 12.1 6.5 -5.6 -46.3% CA or FO 16.5 16.8 0.3 1.6% IO 16.7 17.0 0.3 1.8% RC 15.1 18.1 3.1 20.3% Lines

Average Duty Hours per Duty Period

Average Block Hours per Duty Period

Average Days Off per Month ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 23 Many stations had two or more aircraft overnights and it was common practice to arrange the overnight ground times such that the earliest arriving aircraft could take the latest departing morning flight with a minimum nine hour rest period. The other aircraft ’s crew did not have enough time for a minimum overnight and typically required midday staged crews. Often there were just eno ugh midday flights to provide staging for the aircraft that required it.

The Final Rule significantly impact ed this practice due to the one hour increase in the minimum rest period. Most of the planned short layovers were no longer feasible in the Final Ru le Solution. To maximize efficiency , Cygnus attempted to stage the crews on a midday flight, turning one layover into two. However, there frequently were no midday flights available for staging, necessitating either daily deadhead flights or double layover s of around 33 hours. The number of layovers of 30 hours or more increased from 59 to 147. This was reflected in the increased average number of days per trip, which increased from 3.75 in the Baseline Solution to 4.23 in the Final Rule Solution. The resul t was a sizeable increase in the number of required hotel rooms, deadhead time and overall synthetic time.

This negative impact was offset by the positive impacts associated with the increased maximum augmented flight time limits of the Final Rule . Even after application of a 30 minute buffer, the Effective Final Rule allow ed 40 additional minutes of flight time for crews with both one and two additional flightcrew members. This allow ed the carrier to reduce the number of flightcrew members on some trips to Europe from the East Coast from three to two. Similarly, the number of flightcrew members on some trips to Asia from the West Coast was reduced from four to three.

The average block hours per duty pe riod decreased dramatically for the additional flightcrew member positions. This was because Cygnus scheduled additional flightcrew members on deadhead flights if they were not required to operate the flight in the Final Rule Solution, which was in contrast to the practice in the Baseline Solution of scheduling additional flightcrew members to operate the flight even if it was not required. Since flightcrew members received full credit for deadhead time, the impact on the average credit hours per duty period was much less dramatic. Average credit hours per duty period decreased by 2.1 percent for IOs and 0.8 percent for RCs.

None of the Final Rule cumulative flight or flight duty constraints adversely affect ed the bid lines for the Final Rule Solution.

Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case C flightcrew members were paid full credit for all block hours and deadhead hours. They also receive d a 1

- for

- 3.5 trip rig and a duty rig of 1

- for

- 2 during the day or 1

- for

- 1.75 at night. The average duty period minimum was 5:15.

Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. Domestic TAFB increased by three percent and international TAFB increased by four percent

.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 24 Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between f lights. The number of required hotel rooms increased by nearly ten percent

.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 25 

## Case D: Mainline Passenger Wide

**- Body** 

**SUMMARY**

Case D consisted of the long

- haul operations of a mainline passenger carrier using wide

- body aircraft. Althoug h the effective Final Rule maximum augmented FDP time and minimum rest period limits were more restrictive than current practice, the Final Rule Solution was more efficient in terms of credit hours than the Baseline Solution. Cygnus was able to re

- optimize flightcrew member schedules to take advantage of less restrictive maximum flight time limits in some situations, resulting in fewer credit hours, TAFB and hotel rooms for the Case D Final Rule Solution

.


### DETAILED RESULTS

Case D consist ed of a subset of the long

- haul operations of a mainline passenger carrier using wide

- body aircraft during the July 2010 scheduling period. There were nearly 1,000 flight segments during the scheduling period, all of which were international

. Each trip con sisted of a single flight segment between a domestic location and an international location in Europe, the Middle East or Asia. Almost every trip used an augmented flightcrew.



### Buffers

The six main Final Rule rule elements that affected Case D were the max imum unaugmented and augmented flight time, maximum unaugmented and augmented FDP time and minimum unaugmented and augmented rest period limits. CrewPairings applied buffers to the maximum flight time and FDP time limits to reflect the fact that they appl i ed to actual, rather than planned, operations. In Figure 8 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, resulted in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restric tive than the “Effective Final Rule ” limit, the contractual rule was shown in the “Effective Final Rule ” column.

Figure 8 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” col umn and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 26 **Figure 8**  **: Case D**  **Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Production Solution) were constructed with the constraints of the “Effective Current Rule” col umn in Figure 8 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 8

, in addition to all other Final Rule , contractual, management and discretionary constraints not shown

.
The maximum unaugmented flight time limit applicable to the Baseline Solution was 7:50 hours, which was the FAR limit less a ten minute buffer . The maximum unaugmented flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:3 0 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum flight time limit of the Final Rule was therefore expected to have a possible positive impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit could allow flights currently operating with one additional flightcrew member to operate with no additional flightcrew members

. The maximum augmented flight time limits applicable to the Baseline Solution were 11:50 hours, which was the FA R limit less a ten minute buffer, for flights with one additional flightcrew member and 16 hours, which was the FAR limit, for flights with two additional flightcrew members. The maximum augmented flight time limit s applicable to the Final Rule Solution we re 12:30 hours for flights with one additional flightcrew member and 16:30 hours for Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final Rule 2

Maximum Unaugmented

Flight Time 8:00

- - 0:10 7:50 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Augmented Flight Time (3 crew) 12:00 (4 crew) 16:00 - - (3 crew) 0:10 (4 crew) 0:00 (3 crew) 11:50 (4 crew) 16:00 (3 crew) 13:00 (4 crew) 17:00 0:30 (3 crew) 12:30 (4 crew) 16:30

Maximum Unaugmented 8

FDP Time 16:00 10:30 - 13:30 0:30

- 10:00 - 13:00 9:00 - 14:00 3 0:30 4 8:30 - 13:30 3

Maximum Augmented FDP Time 8 (3 crew) 16:00 (4 crew) no limit (3 crew) 16:00 (4 crew) 18:00 - - (3 crew) 16:00 (4 crew) 18:00 (3 crew) 15:00 - 17:00 5 (4 crew) 17:00 - 19:00 5 0:30 4 (3 crew) 14:30 - 16:00 5 (4 crew) 16:30 - 18:00 5

Minimum Unaugmented

Rest Time 8:00 - 12:00 6 8:00

- 0:15 8:15 - 12:00 6 10:00

- 10:00

Minimum Augmented Rest Time 8:00 - 18:00 7 8:00

- 1:00 9:00 - 18:00 7 10:00

- 10:00

8 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time 1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer) Rule Element Time in Hours:Minutes

5 Depending on FDP start time; Maximum show n is for aircraft equipped w ith Class 1 rest facility, reduced if aircraft is equipped w ith low er class rest facility 2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP

6 Depending on the amount of flight time in the past 24-hour period

7 Flag rules, including double out if crew exceeds 8-in-24, 18:00 after breaking 8-in-24, 20-in-48 or 24-in-72 4 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 27 flights with two additional flightcrew members, which were the Final Rule limits, after application of a 30 minute buffer. The maximum augmented flight time limits of the Final Rule

were therefore expected to have a positive impact on the Final Rule Solution pairings, as they allow ed between 30 and 40 additional minutes of flight time.

The maximum unaugmented FDP limit applicable to the Baseline Solution was 10 :00

- 13 :00 hou rs, which was the CBA limit , less a 30 minute international debrief . The maximum unaugmented FDP limit applicable to the Final Rule Solution was 8:30

- 13: 00 hours, depending on FDP start time, after application of a 30 minute buffer. The low end was the buf fered Final Rule and the high end was the CBA limit. The maximum unaugmented FDP limit of the Final Rule was therefore expected to have a negative impact on the Final Rule Solution pairings; the Effective Final Rule limit was more constraining than the Eff ective Current Rule in most situations.

The maximum augmented FDP limit applicable to the Baseline Solution was 16:00 hours for flights with one additional flightcrew member and 18:00 hours for flights with two additional flightcrew members , which were the CBA limit s . The maximum augmented FDP limit s applicable to the Final Rule Solution were 14 :30

- 1 6 : 00 hours for flights with one additional flightcrew members and 16:30

- 18:00 hours for flights with two additional flightcrew members

, depending on FDP start time, after application of a 30 minute buffer. The maximum augmented FDP limit s of the Final Rule were therefore expected to have a negative impact on the Final Rule Solution pairings; the Effective Final Rule limit s were more constraining than the E ffective Current Rule in most situations.

The minimum rest period s applicable to the Baseline Solution were 8:15

- 12:00 hours for unaugmented operations and 9:00

- 18:00 hours for augmented operations , depending on the amount of flight time in the previous 24 hour period, which were the buffered FAR requirement s . The minimum rest period applicable to the Final Rule Solution was 10 :00 hours. The minimum rest period of the Final Rule was therefore expected to have a negative impact on the Final Rule Solution pai rings; the Effective Final Rule period was between one and two hours greater than the Effective Current Rule in most situations.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions us ing the pairings from the solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, c ontractual, management and discretionary constraints.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were applicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 12 days off

,

• No single days off

,Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 28 • No single working days, except at the beginning/ending of the month

,

• A target of 83 credit hours, with a maximum of 92

,

• Minimize the amount of open time , and

• No r eserve days on any flying line

. 

### Results

The Final Rule Solution was able to reduce the use of TAFB and hotel rooms by a full 30 days for the scheduling period for a particular pairing between the East Coast and the Middle East, because of the change in minimum duty break regulations. The FAR required a longer duty break f

or flightcrew members that flew more than eight hours in a 24 hour period. The Final Rule replaced that provision with a uniform minimum duty break of 10 hours. This change allowed the optimizer to create 13

- 18 hour layovers in the Final Rule Solution, rat her than the 25

- 30 hour layovers in the Baseline Solution.

There was an increase in credit hours, TAFB and hotel rooms associated with the need for a third flightcrew member for a particular pairing between the East Coast and Western Europe in the Final R ule Solution. The block time for this pairing was less than the eight hour maximum flight time limit permitted by the FAR and Final Rule , but was more than the buffered Effective Final Rule maximum flight time limit of 7:30.

The increase in credit hours, T AFB and hotel rooms associated with the third pilot was more than outweighed by the decrease associated with the fourth pilot. The effective maximum flight time limit for an augmented flight with three flightcrew members increased from 11:50 to 12:30. This change meant that the previously referenced pairing between the East Coast and the Middle East could be completed with an augmented flightcrew of three flightcrew members rather than four.

Cygnus was able to re

- optimize pairings to eliminate nearly all co nflicts with maximum flight time, maximum FDP time and minimum rest period limits while reducing credit hours, TAFB and hotel rooms relative to the Baseline Solution. The Final Rule Solution was almost three percent more efficient in terms of credit hours than the Baseline Solution, as shown in Figure 9

.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 29 **Figure 9**  **: Case D**  **Monthly Results** 

Credit hours consist ed of the total number of hours for which fli ghtcrew members were paid. Case D flightcrew members were paid full credit for all block hours and deadhead hours. They also receive d a 1

- for

- 4 trip rig for trips with a duty break of more than 29 hours

. The diffe rence in block hours was greater than the difference in credit hours because flightcrew members were paid at the same credit hour rate for deadhead flights.

Time away from base was all time spent away from a flightcrew member’s base while on a trip, from t he time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. All TAFB in Case D was international.

Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. The number of required hotel rooms decreased by about nine percent. Metric Crew Position Baseline Final Rule

CA or FO 117 116 -1 -0.9% IO 111 116 5 4.5% RC 85 70 -15 -17.6% Credit Hours All 35,863 34,898 -965 -2.7% Block Hours All 35,863 33,753 -2,111 -5.9% Aircraft Block Hours N/A 9,725 9,699 -26 -0.3% Domestic TAFB All 0 0 0 N/A International TAFB All 114,962 112,221 -2,741 -2.4% Hotel Rooms All 1,620 1,586 -34 -2.1% CA or FO 13.2 13.2 0.0 0.0% IO 13.6 13.2 -0.4 -2.9% RC 14.9 15.5 0.6 4.0% CA or FO 12.0 12.0 0.0 0.0% IO 12.3 11.4 -0.9 -7.3% RC 13.6 12.6 -1.0 -7.4% CA or FO 18.9 18.8 -0.1 -0.4% IO 19.1 19.1 0.0 0.0% RC 19.9 20.2 0.3 1.6% Change

Lines

Average Duty Hours per Duty Period

Average Block Hours per Duty Period

Average Days Off per MonthSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 30 

## Case E: Regional Passenger

**SUMMARY**

Case E consisted of the operations of a regional passenger carrier using regional jet aircraft. The Final Rule Solution was slightly less efficient in terms of credit hours and significantly less efficient in terms of TAFB and hotel rooms than the Baseline Solution mainly because of the increased minimum rest period. This result ed in longer layovers for flightcrew members, which increase d TAFB and hotel rooms . The changes in maximum flight time and maximum FDP time limits ha d little impact on Case E

. 

### DETAIL **ED RESULTS**

Case E consisted of a subset of the operations of a regional passenger carrier using regional jet aircraft during the July 2010 scheduling period. The Case consisted of all flight segments operated for one mainline passenger carrier client. The Case E carrier maintain ed complete separation between sub

- fleets operated for mainline passenger carrier clients when scheduling flightcrew members. There were nearly 6,000 flight segments during the scheduling period, all of which were domestic . Flights t o C anada were considered domestic for flightcrew member scheduling purposes by the carrier.

The augmentation and acclimation elements of the Final Rule did not affect Case E , as all of the flight segments were operated with an unaugmented crew and all of t he flightcrew members remain ed acclimated at all times. Case E did not have any split duty periods.



### Buffers

The three main Final Rule rule elements that affected Case E were the maximum unaugmented flight time, maximum unaugmented FDP time and minimum rest period limits. CrewPairings applied buffers to both the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rather than planned, operations. In Figure 10 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the contractual rule is shown in the “Effective Final Rule ” column.

Figure 10 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 31 **Figure 10**  **: Case E**  **Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Pro duction Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 10 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 10

, in addit ion to all other Final Rule , contractual, management and discretionary constraints not shown.

The maximum flight time limit applicable to the Baseline Solution was 8 : 0 0 hours, which was the FAR limit. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum flight time limit of the Final Rule was therefore expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum FDP limit applicable to the Baseline Solution was 13:45 hours, which was the CBA limit less a 15 minute debrief period. The maximum FDP limit applicable to the Final Rule Solution was between 8:30 and 13:30, which was the Final Rule less a 30 minute buffer. The maximum FDP limit of the Final Rule was expected to have a negative impact on the Final Rul e Solution pairings because the Effective Final Rule limit was more constraining than the Effective Current Rule in all situations

. The minimum rest period applicable to the Baseline Solution was 8 : 3 0

- 12:00 hours, depending on the amount of flight time in the previous 24 hour period. The CBA minimum rest period was 8:00 hours, but the FAR require d additional rest time if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The carrier applie d a 30 minute buffer. The Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final
Rule 2

Maximum Unaugmented

Flight Time 8:00

- - - 8:00 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Unaugmented

FDP Time 6 16:00 14:00 0:15

- 13:45 9:00 - 14:00 3 0:30 5 8:30 - 13:30 3

Minimum Unaugmented

Rest Time 8:00 - 12:00 4 8:00

- 0:30 8:30 - 12:00 10:00

- 10:00

6 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time

Rule Element Time in Hours:Minutes

1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP

4 Depending on the amount of flight time in the past 24-hour period

5 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 32 minimum rest p eriod applicable to the Final Rule Solution was 10 :00 hours, which was expected to have a negative impact on the Final Rule Solution pairings because the Final Rule require d an additional ninety minutes of rest in most situations.



### Bid Lines

The Cygnus syst em was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionar y constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, contractual, management and discretionary constraints.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were applicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 1 2 days off

,

• At least one block of three consecu tive days off

,

• No single days off

,

• No single working days, except at the beginning/ending of the month

,

• A target of 8 5 credit hours, with a maximum of 92

,

• Minimize the amount of open time

,

• No reserve days on any flying line , and

• All lines are valid for one captain and one first officer.

In addition to these rules, some common rules intended to improve flightcrew members’ quality of life were imposed, including:

• Blocks of two consecutive working days were allowed, but penalized, with no more than two in any line

,

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized, in any line , and

• No more than five blocks of consecutive working days during the month, to reduce the need for commuter s to commute to/from their base.



### Results

The Final Rule Solution was slightly less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 3 . Re

- optimization of flightcrew member schedules under the Final Rule resulted in more than eight percent more hotel room nights required and six percent more TAFB

. The increased minimum rest period had the greatest impact on the Case E pairings because the carrier created flight schedules that were designed to optimize flightcrew member scheduling given the minimum 8:0 0 hour rest period required by the FAR plus a 30 minute buffer applied bySummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 33 the carrier. At many stations, the aircraft overnight time was less than the 10:00 hours required by the Final Rule . CrewPairings increased the standard maximum allowed duty break from 27:00 to 33:00 hours to address this problem. Increasing the maximum allowed duty break added the alternative of double layovers 9 to the options of staging crews using midday flights or using deadhead flights.

The number of layovers of 30 hours or more increased from 0 in the Baseline Solution to 239 in the Final Rule Solution. The average layover increased from 16:15 to 19:39, which was a significant increase of more than three hours. The result was a sizeable increase in the number of required hotel rooms, deadhead time and TAFB

. Although the Baseli ne Solution contained a number of split duties, the Final Rule did not adversely affect them, because there was enough time between flight segments to satisfy the Final Rule split duty constraint.

The Final Rule maximum flight time limit of nine hours (8:3 0 buffered limit) had a positive impact on the pairings. Nearly eight percent of Final Rule Solution duty periods had flight time in excess of eight hours.

The net impact of the longer average layovers and increased maximum flight time limit was that fligh tcrew members had to work about six percent more duty and block hours per duty period, but had nearly five percent fewer average days off per month.

None of the Final Rule cumulative flight or flight duty time constraints adversely affected the bid lines f or the Final Rule Solution.

**Figure 11**  **: Case E**  **Monthly Results** 

9 Double layovers are duty breaks of 27:00 to 33:00 hours. Metric Crew Position Baseline Final Rule

Lines CA or FO 150 152 2 1.3% Credit Hours All 25,763 25,820 57 0.2% Block Hours All 24,998 24,987 -11 0.0% Aircraft Block Hours N/A 12,499 12,494 -6 0.0% Domestic TAFB All 96,243 102,054 5,812 6.0% International TAFB All 0 0 0 N/A Hotel Rooms All 3,344 3,624 280 8.4% Average Duty Hours per Duty Period CA or FO 8.2 8.7 0.5 6.1%
Average Block Hours per Duty CA or FO 5.3 5.6 0.3 5.7%
Average Days Off per Month CA or FO 14.9 14.2 -0.7 -4.7% ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 34 Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case E flightcrew members were paid full credit for all block hours and 75 percent credit for deadhead hours.

Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip.

Hot el rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 35 

## Case F: Regional Passenger

**SUMMARY**

Case F consisted of the operations of a regional passenger carrier using regional jet aircraft. The Final Rule Solution was slightly less efficient in terms of credit hours than the Baseline Solution mainly because of the increased minimum rest period. Thi s result ed in longer layovers for flightcrew members, which increase d credit hour s , TAFB and hotel rooms . The changes in maximum flight time and maximum FDP time limits ha d little impact on Case F

. 

### DETAILED RESULTS

Case F consisted of a subset of the opera tions of a regional passenger carrier using regional jet aircraft during the November 2010 scheduling period. The Case consisted of all flight segments operated for one mainline passenger carrier client. The Case F carrier maintain ed complete separation be tween sub

- fleets operated for mainline passenger carrier clients when scheduling flightcrew members. There were more than 6,000 flight segments during the scheduling period, most of which were domestic. However, there were also some flight segments to Mexi co . Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight segments were included in the analysis

. The augmentation and acclimation elements of the Final Rule did not affect Case F , as all of the flight segments were operated with an unaugmented crew and all of the flightcrew members remain ed acclimated at all times. Case F did not have any split duty periods.



### Buffers

The three main Final Rule rule elements that affected Case F were the maximum unaugmented flight time, maximum unaugmented FDP time and minimum rest period limits. CrewPairings applied buffers to both the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rather than planned, operations. In Figure 12 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the “Effective Final Rule ” limit that was actually used when creating p airings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the contractual rule is shown in the “Ef fective Final Rule ” column.

Figure 12 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 36 **Figure 12**  **: Case F**  **Buffers**



### Pairings

The Baseline Solu tion pairings (equivalent to the Production Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 12 , in addition to all oth er FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 12

, in addition to all other Final Rule , contractual, management and discretionary constraints not shown.

The maximum flight time limit applicable to the Baseline Solution was 8:00 hours, which was the FAR limit. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum flight time limit of the Final Rule was therefore e xpected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum FDP limit applicable to the Baseline Solution was 1 3:1 5

- 13:40 hours, which was the CBA limit less a 15 minute debrief period and five to thirty minute buffer . The maximum FDP limit applicable to the Final Rule Solution was between 8:30 and 13:30, which was the Final Rule less a 30 m inute buffer. The maximum FDP limit of the Final Rule was expected to have a negative impact on the Final Rule Solution pairings because the Effective Final Rule limit

was more constraining than the Effective Current Rule in all situations.

The minimum res t period applicable to the Baseline Solution was 8: 5 0

- 12:00 hours, depending on the amount of flight time in the previous 24 hour period. The CBA minimum rest period was 8:00 hours, but the FAR require d additional rest time if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The carrier applie d a 50 minute buffer to the minimum rest period. The minimum rest period applicable to the Final Rule Solution was 10 :00 Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final
Rule 2

Maximum Unaugmented

Flight Time 8:00

- - - 8:00 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Unaugmented

FDP Time 6 16:00 14:00 0:15 0:05 - 0:30 13:15 - 13:40 9:00 - 14:00 3 0:30 5 8:30 - 13:30 3

Minimum Unaugmented

Rest Time 8:00 - 12:00 4 8:00

- 0:50 8:50 - 12:00 4 10:00

- 10:00

6 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time

Rule Element Time in Hours:Minutes

5 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00 1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Maximum for 1 segment during FDP, reduced if 3 or more segments during FDP

4 Depending on the amount of flight time in the past 24-hour periodSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 37 hours, which was expected to have a negative impact on the Final R ule Solution pairings because the Final Rule require d an additional 70 minutes of rest in most situations.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the se solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule , contractual, manageme nt and discretionary constraints.

Although the carrier use d a preferential bidding system instead of bid lines, the basic line constraints were applicable to bid line construction as well. The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 1 1 days off

,

• At least one block of three consecutive days off

,

• No single days off

,

• No single working days, except at the beginning/ending of the month

,

• A target of 8 3 credit hours, with a maxi mum of 98

,

• Minimize the amount of open time

,

• No reserve days on any flying line , and

• All lines are valid for one captain and one first officer.

In addition to these rules, some common rules intended to improve flightcrew members’ quality of life were imposed, including:

• Blocks o f only two consecutive working days were allowed, but penalized, with no more than two in any line , and

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized, in any line

. 

### Results

The Final Rule Solution was slightly less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 13 . Re

- optimization of flightcrew member s chedules under the Final Rule resulted in a slight increase in credit hours, nearly five percent more hotel room nights required and more than five percent more TAFB

. The increased minimum rest period had the greatest impact on the Case F pairings because the carrier created flight schedules that were designed to optimize flightcrew member scheduling given the minimum 8: 0 0 hour rest period required by the FAR with a 50 minute buffer applied by the carrier. At many stations, the aircraft overnight time was less than the 10:00 hours required by the Final Rule . CrewPairings increased the standard maximum allowed duty break from 22:00 to 33:00 hours to address this problem. Increasing the maximum allowed duty breakSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 38 added the alternative of double layovers 10 to the options of staging crews using midday flights or using deadhead flights.

The number of layovers of 24 hours or more increased from 27 in the Baseline Solution to 62 in the Final Rule Solution. The average layover increased from 14:43 to 15:20. The result was a sizeable increase in the number of required hotel rooms, deadhead time and overall synthetic time.

Average duty hours per duty period decreased more than three percent and average block hours per duty period decreased two percent. Since the n umber of lines did not change, the average number of days off per month in the Final Rule Solution decreased nearly five percent so that the same amount of flying could be completed as in the Baseline Solution.

None of the Final Rule cumulative flight time or flight duty time constraints adversely affect ed the bid lines for the Final Rule Solution.

**Figure 13**  **: Case F**  **Monthly Results** 

Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case F f lightcrew members were paid full credit for all block hours and 50 percent credit for deadhead hours.

Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. Domestic TAFB increased by more than five percent and international TAFB decreased by nearly three percent

.

10 Double layovers are duty breaks of 27:00 to 33:00 hours. Metric Crew Position Baseline Final Rule

Lines CA or FO 120 120 0 0.0% Credit Hours All 20,272 20,309 37 0.2% Block Hours All 20,062 20,062 0 0.0% Aircraft Block Hours N/A 10,031 10,031 0 0.0% Domestic TAFB All 77,596 81,744 4,148 5.3% International TAFB All 575 560 -16 -2.7% Hotel Rooms All 2,948 3,092 144 4.9% Average Duty Hours per Duty Period CA or FO 8.7 8.4 -0.3 -3.4%
Average Block Hours per Duty Period CA or FO 5.1 5.0 -0.1 -2.0%
Average Days Off per Month CA or FO 13.5 12.8 -0.6 -4.8% ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 39 Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. The use of hotel rooms increased by nearly five percent.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 40 

## Case G: All

**- Cargo Narrow** 

**- Bo**  **dy**

**SUMMARY**

Case G consisted of the operations of a short

- haul all

- cargo carrier using narrow

- body aircraft. The Final Rule Solution was less efficient in terms of credit hours than the Baseline Solution mainly because of the reduced maximum flight time limit for international operations, maximum FDP limits and consecutive nighttime operations constraint . This result ed in increased credit hour s , TAFB and hotel rooms

. 

### DETAILED RESULTS

Case G consisted of a subset of the operations of a short

- haul all

- carg o carrier using narrow

- body aircraft during the August 2010 scheduling period. There were more than 2,000 flight segments during the scheduling period, most of which were domestic, with a few international destinations. Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight segments were included in the study.

Case G was a representative example of the short

- haul operations of all

- cargo carriers. The nature of operations differ ed greatly from the typical passenge r carrier. The levels of aircraft and flightcrew member utilization were much lower than the levels at passenger carriers. This was because the majority of duty periods consist ed of a flight segment from an outstation to a sort facility

, a n approximately f our hour period during which the aircraft was unloaded and reloaded and a flight segment back to the same outstation from which it arrived.

Nearly all duty periods occurred during nighttime hours and most duty periods infringe d on the window of circadian low (WOCL)

. 11 For this reason, the Case G carrier’s collective bargaining agreement and flightcrew member scheduling rules contain ed many measures designed to mitigate fatigue

- inducing conditions characteristic of nighttime fligh t operations.

Case G include d a number of scheduling rules that were designed to enhance the quality of life for its flightcrew members. The first major scheduling rule was the requirement that the majority of flight legs must be contained in “city pure pa irings.” City pure pairings consist ed of four or five consecutive duty periods that consist ed of a flight from an outstation to a sort facility and a flight back to the same outstation. Thus, flightcrew members had layovers at the same outstation
every res t period of a trip.

The second major scheduling rule was the prohibition on trips transiting the major sort facility

, excluding those pairings created through the city pure pairings rule . Thus, the trip consist ed of a flight segment from the main sort fac ility to an outstation and a flight segment back to the main sort facility. The legal duty break occurred during the layover at the outstation. The intent was that several of these trips would be placed consecutively during bid line construction with only a few hours between trips , which ha d the same ultimate effect as the city pure pairing rule.

11 The WOCL is the period of maximum sleepiness that occurs between 0200 and 0559 during a physiological night.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 41 

### Buffers

The three main Final Rule rule elements that affected Case G were the maximum unaugmented flight tim e, maximum unaugmented FDP time and minimum rest period limits. CrewPairings applied buffers to both the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rather than planned, operations. In Figure 14 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, results in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the contractual rule is shown in the “Effective Final Rule ” column.

Figure 14 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.

**Figure 14**  **: Case G**  **Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Pro duction Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 14 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 14

, Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final
Rule 2

Maximum Unaugmented

Flight Time 8:00/12:00 3

- - 0:25/0:00 3 7:35/12:00 3 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Unaugmented 10
FDP Time 16:00 5:00 - 13:00 4 0:30

- 4:30 - 12:30 4 9:00 - 14:00 5 0:30 8 4:30 - 12:30 4,5

Minimum Unaugmented

Rest Time 8:00 - 12:00 6 10:15 7

- - 10:15-12:00 7 10:00

- 10:15 9

10 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time 8 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00 1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

4 Domestic limits depending on report time. International limits vary betw een 11 and 13 hours depending on previous rest period

5 Maximum for 1 segment during FDP, reduced if 3 or more segments during FDP

7 9:00 minimum rest before all deadhead duty, except only 8:00 before all deadhead duty to base at the end of a trip 2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Domestic/international

9 10:00 minimum rest if rest period is before all deadhead duty

Rule Element Time in Hours:Minutes

6 Depending on the amount of flight time in the past 24-hour periodSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 42 in addit ion to all other Final Rule , contractual, management and discretionary constraints not shown.

The maximum unaugmented flight time limit s applicable to the Baseline Solution were 7 : 35 hours for domestic operations and 12:00 hours for international operations , which were the buffered FAR limit s . The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after app lica tion of a 30 minute buffer.

The maximum FDP limit applicable to the Baseline Solution was 4:30

- 12 : 3 0 hours, which was the CBA limit less a 30

- minute debrief period. The maximum FDP limit applicable to the Final Rule Solution was also between 4 :30 and 1 2 :30 , which was the lower of the Final Rule less a 30 minute buffer and the CBA limit less a 30 minute debrief period

. The minimum rest period applicable to the Baseline Solution was 10:15

- 12:00 hours. The lower end was t he CBA minimum rest period and the high er end was the FAR if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The minimum rest period applicable to the Final Rule Solution was 10 :15 hours, which was the CBA minimum rest period. The Final Rule minimum rest period w as expected to have a slightly positive impact on the Final Rule Solution pairings because the Final Rule remove d the requirement for additional rest if flight time exceed ed eight hours in the preceding 24 hour period

.
The Final Rule limit ed flightcrew members to three consecutive flight duty periods that impinge d on the window of circadian low unless the carrier provide d the flightcrew member with a minimum two hour rest opportunity in a suitable accommodation during each FDP, in which case five consec utive flight duty periods were permitted. The consecutive nighttime operations constraint was very important for Case G because the vast majority of duty periods impinge d on the WOCL.

Since the Final Rule require d a minimum two hour rest opportunity during each FDP to qualify for five consecutive FDPs, transfer time to and from the suitable accommodation had to be accounted for, in addition to debrief/brief times. The Case G carrier informed CrewPairings that a total of 30 minutes for transfer to and from t he suitable accommodation would be appropriate assumptions to use in the analysis. In addition, CrewPairings estimated the total debrief/brief times to be 45 minutes. This mean t that each FDP had to have a total of 3:15 hours between flight segments to qua lify for five consecutive FDPs.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the solutions. The Baseline Solution bid lines were constructed in complia nce with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, contractual, management and discretionary constraints.

The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 43 • Minimum of 1 3 days off

• No single days off

• No single working days

• No double working days, except at the beginning/ending of the month

• A target of 74 credit hours, with a maximum of 84

• Minimize the amount of open time

• No reserve days on any flying line

• All lines are valid for one captain, one first officer and one flight engineer

. In addition to these rules, some common rules intended to improve flightcrew members’ quality of life were imposed, inclu ding:

• At least one block of three consecutive days off

• At most six consecutive working days, except for the trips that themselves range up to 12 days in duration

• A penalty for base layovers near 24 hours in duration, because it is better to run trips back

- to

- back with shorter layovers

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized , in any line

• No more than five blocks of consecutive working days during the month, to reduce th e need for commuters to commute to/from their base.



### Results

The Final Rule Solution was more than two percent less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 15 . Re

- optimization of flightcrew member schedules und er the Final Rule resulted in more than one percent more hotel room nights required and more than three percent more TAFB

. The maximum fligh t time limit of the Final Rule only impacted one international route because of the replacement of the effective current rule maximum limit for international operations of 12:00 hours with the uniform effective Final Rule limit of 8:30 hours for all operat ions. However, this led to a significant negative impact as two sets of flightcrew members were needed to do the same amount of flying previously accomplished by one set of flightcrew members. The Final Rule maximum flight time limit did not impact any oth er Final Rule Solution pairings because the nature of all

- cargo operations resulted in few flight hours per duty period.

Although the buffered maximum FDP limit of the Final Rule was similar to the current CBA, there were certain times of the day during wh ich the buffered Final Rule limit was less than the current CBA, leading to negative impacts on pairings.

There were five city pure pairings that did not have the required ground time, leading to negative impacts on pairings. These pairings had ground time of 2:44 to 3:10, which was less than the required minimum buffered 3:15 ground time.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 44 The augmentation and acclimation elements of the Final Rule did not affect Case G, as all of the flight segments were operated with an unaugmented crew and all of the fli ghtcrew members remained acclimated at all times. The split duty rule was not particularly important because the specific instances that would allow split duties already complied with the maximum unaugmented FDP limits.

**Figure 15**  **: Case**  **G Monthly**  **Results**

Credit hours consist ed of the total number of hours for which flightcrew members are paid. Case G flightcrew members were paid full credit for all block and deadhead hours. Duty rig was paid at the rate of 1

- for

- 2 during the day and 1

- for

- 1.92 during the night. Trip rig was paid at the rate of 1

- for

- 3.75. Minimum duty period guarantees range d from 3:00 to 6:00 hours per duty period.

Time away from base was all time spent away from a flig htcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the trip. Domestic TAFB increased by one percent and international TAFB increased by more than forty pe rcent

.
Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. Metric Crew Position Baseline Final Rule

Lines CA, FE or FO 110 113 3 2.7% Credit Hours All 24,551 25,110 560 2.3% Block Hours All 10,844 10,829 -15 -0.1% Aircraft Block Hours N/A 3,615 3,610 -5 -0.1% Domestic TAFB All 89,276 90,166 890 1.0% International TAFB All 5,846 8,237 2,390 40.9% Hotel Rooms All 3,837 3,891 54 1.4% Average Duty Hours per Duty Period CA, FE or FO 4.8 4.8 0.0 0.0%
Average Block Hours per Duty Period CA, FE or FO 2.0 1.9 -0.1 -5.0%
Average Days Off per Month CA, FE or FO 14.5 14.4 -0.1 -0.5% ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 45 

## Case H: All

**- Cargo Wide** 

**- Body** 

**SUMMARY**

Case H consisted of the op erations of an all

- cargo carrier using wide

- body aircraft. The Final Rule Solution was less efficient in terms of credit hours than the Baseline Solution mainly because of the maximum FDP limits and consecutive nighttime operations constraint. This result e d in more TAFB and hotel rooms

. 

### DETAILED RESULTS

Case H consisted of a subset of the operations of an all

- cargo carrier using wide

- body aircraft during the August 2010 scheduling period. There were more than 6,000 flight segments during the scheduling per iod. Approximately 70 percent of the flight segments were short

- haul domestic operations and 30 percent were long

- haul international operations. Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight segments we re included in the study.

Case H was a representative example of the wide

- body aircraft operations of all

- cargo carriers. The domestic short

- haul operations generally occurred from Monday afternoon to Saturday afternoon while the international short

- haul o perations occurred throughout the week.

The nature of short

- haul domestic operations differ ed greatly from the typical passenger carrier. The levels of aircraft and flightcrew member utilization were much lower than the levels at passenger carriers. This was because the majority of duty periods consist ed of a flight segment from an outstation to a sort facility, an approximately four hour period during which the aircraft

was unloaded and reloaded and a flight segment back to the same outstation from which it arrived.

The nature of long

- haul international operations also differ ed greatly from the typical passenger carrier. The routes were long and thin international routes throughout the entire North ern Hemisphere that circled the globe in both directions fr om bases in the United States. The flights operate d infrequently and in many cases with at least one additional flightcrew member. The majority of duty periods consist ed of a single flight segment. Deadheading was common because flights on these routes wer e infrequent. The international flights also operate d to military fields, which obviously did not offer the possibility of deadheading on scheduled passenger flights.

Many duty periods occurred during nighttime hours and most duty periods infringe d on the window of circadian low

. 12 For this reason, the Case H carrier’s collective bargaining agreement and flightcrew member scheduling rules contain ed many measures designed to mitigate fatigue

inducing conditions characteristic of nighttime flight operations.

12 The WOCL is the period of maximum sleepiness that occurs between 0200 and 0559 during a physiological night.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 46 Case H include d a number of scheduling rules that were designed to enhance the quality of life for its flightcrew members. The first major scheduling rule was the requirement that the majority of flight legs had to be contained in “city pure pairings.” Cit y pure pairings consist ed of four or five consecutive duty periods that consist ed of a flight from an outstation to a sort facility and a flight back to the same outstation. Thus, flightcrew members had layovers at the same outstation during every rest per iod of a trip.

The second major scheduling rule was the prohibition on trips that transit ed the major sort facility, excluding those pairings created through the city pure pairings rule. Thus, the trip would consist of a flight segment from the main sort facility to an outstation and a flight segment back to the main sort facility. The legal duty break occurred during the layover at the outstation. The intent was that several of these trips would be placed consecutively during bid line construction with on ly a few hours between trips, which ha d the same ultimate effect as the city pure pairing rule.



### Buffers

The three main Final Rule rule elements that affected Case H were the unaugmented and augmented maximum flight time, maximum FDP time and minimum res t period limits

. CrewPairings applied buffers to the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rather than planned, operations. In Figure 16 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, result ed in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restrictive than the “Effective Final Rule ” limit, the contractual rule is shown in the “Effective Final Rule ” column.

Figure 16 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” colu mn or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” column.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 47 **Figure 16**  **: Case H**  **Buffers**



### Pairings

The Baseline Solution pairings (equivalent to the Production Solution) were constructed with the constraints of the “Effective Current Rule” column in Figure 16 , in addition to all other FAR, contractual, management and discreti onary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 16

, in addition to a ll other Final Rule , contractual, management and discretionary constraints not shown.

The maximum unaugmented flight time limits applicable to the Baseline Solution were 7:35 hours for domestic operations and 12:00 hours for international operations, which were the buffered FAR limits. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The maximum unaugmented flight time limit of the Final Rule was therefore expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining. Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final Rule 2

Maximum Unaugmented

Flight Time 8:00/12:00 9

- - 0:25/0:00 9 7:35/12:00 9 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Augmented Flight Time (3 crew) 12:00 (4 crew) 18:00 - - - (3 crew) 12:00 (4 crew) 18:00 (3 crew) 13:00 (4 crew) 17:00 0:30 (3 crew) 12:30 (4 crew) 16:30

Maximum Unaugmented 12
FDP Time 16:00 5:00 - 13:00 6 0:30

- 4:30 - 12:30 6 9:00 - 14:00 3 0:30 4 4:30 - 12:30 3,6

Maximum Augmented FDP Time 12 (3 crew) 18:00 (4 crew) 20:00 (3 crew) 18:00 (4 crew) 20:00 0:30

- (3 crew) 17:30 (4 crew) 19:30 (3 crew) 15:00 - 17:00 5 (4 crew) 17:00 - 19:00 5 0:30 4 (3 crew) 14:30 - 16:30 5 (4 crew) 16:30 - 18:30 5

Minimum Unaugmented

Rest Time 8:00 - 12:00 10 10:15 7

- - 10:15 - 12:00 7,10 10:00

- 10:15

Minimum Augmented Rest Time 8:00 - 18:00 11 12:00

- - 12:00 - 18:00 11 10:00

- 12:00

8 10:00 minimum rest if rest period is before all deadhead duty

Rule Element Time in Hours:Minutes

1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

4 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00

5 Depending on FDP start time; Maximum show n is for aircraft equipped w ith Class 1 rest facility, reduced if aircraft is equipped w ith low er class rest facility 2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDP

10 Depending on the amount of flight time in the past 24-hour period

11 Flag rules, including double out if crew exceeds 8-in-24, 18:00 after breaking 8-in-24, 20-in-48 or 24-in-72 6 Domestic limits depending on report time. International limits vary betw een 11 and 13 hours depending on previous rest period

7 9:00 minimum rest before all deadhead duty, except only 8:00 before all deadhead duty to base at the end of a trip

9 Domestic/international

12 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty timeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 48 The maximum augmented flight time limits applicable to the Baseline Solution were 12:00 hours for flights with one additional flightcrew member and 18:00 hours for flights with two additional flightcrew members, which were the FAR limits. The maximum fligh t time limits applicable to the Final Rule Solution were 12:30 hours for flights with one additional flightcrew member and 16:30 hours for flights with two additional flightcrew members, which were the Final Rule limits after application of a 30 minute buf fer. The maximum augmented flight time limits of the Final Rule were therefore expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other cases it was less constraining.

The maximum unaugmented FDP limit applicable to the Baseline Solution was 4:30

- 12:30 hours, which was the CBA limit less a 30 minute debrief period. The maximum FDP limit applicable to the Final Rule Solution was also between 4:30 and 12:30, which was the smaller of the Final Rule less a 30 minute buffer and the CBA limit less a 30 minute debrief period. Although the buffered maximum FDP limit of the Final Rule was similar to the current CBA, there were certain ti mes of the day during which the buffered Final Rule limit was less than the current CBA

. The maximum augmented FDP limits applicable to the Baseline Solution were 17:30 hours for flights with one additional flightcrew member and 19:30 for flights with two additional flightcrew members, which were the CBA limits less a 30 minute debrief period. The maximum FDP limits applicable to the Final Rule Solution were between 14:30 and 16:30 for flights with one additional flightcrew member and between 16:30 and 18:3 0 hours for flights with two additional flightcrew members, which were the Final Rule limits less a 30 minute buffer . The Effective Final Rule s limits were significantly less than the Effective Current Rule in all situations.

The minimum unaugmented rest p eriod applicable to the Baseline Solution was 10:15

- 12:00 hours. The lower end was the CBA minimum rest period and the higher end was the FAR if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The minimum rest period applica ble to the Final Rule Solution was 10:15 hours, which was the CBA minimum rest period. The Final Rule minimum augmented rest period was expected to have a slightly positive impact on the Final Rule Solution pairings because the Final Rule remove d the requi rement for additional rest if flight time exceed ed eight hours in the preceding 24 hour period.

The minimum augmented rest period applicable to the Baseline Solution was 12:00

- 18:00 hours. The lower end was the CBA minimum rest period and the higher end wa s the FAR if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The minimum rest period applicable to the Final Rule Solution was 12:00 hours, which was the CBA minimum rest period. The Final Rule minimum augmented rest period was expected to have a slightly positive impact on the Final Rule Solution pairings because the Final Rule remove d the requirement for additional rest if flight time exceed ed eight hours in the preceding 24 hour period.

The Final Rule limit ed flightcrew me mbers to three consecutive flight duty periods that impinge d on the window of circadian low unless the carrier provide d the flightcrew member with a minimum two hour rest opportunity in a suitable accommodation during each FDP, in whichSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 49 case five consecuti ve flight duty periods were permitted. The consecutive nighttime operations
constra int was very important for Case H because the vast majority of domestic duty periods impinge d on the WOCL.

Since the Final Rule require d a minimum two hour rest opportunity during each FDP to qualify for five consecutive FDPs, transfer time to and from the suitable accommodation had to be accounted for, in addition to debrief/brief times. The Case H carrier informed CrewPairings that a total of 30 minutes for transfer to and from the suitable accommodation would be appropriate assumptions to use in the analysis. In addition, CrewPairings estimated the total debrief/brief times to be 45 minutes. This meant that each FDP had to have a total of 3:15 hours between flight segments to qualify for five consecutive FDPs.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for both the Baseline and Final Rule Solutions using the pairings from the solutions. The Baseline Solution bid lines were constructed in co mpliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constructed in compliance with all Final Rule

, contractual, management and discretionary constraints.

The primary rules used for constructi on of both Baseline and Final Rule Solution bid lines were:

• Minimum of 13 days off

,

• No single days off

,

• No single working days

,

• No double working days, except at the beginning/ending of the month

,

• A target of 74 credit hours, with a maximum of 84

,

• Minimize the amount of open time

,

• No reserve days on any flying line , and

• All lines are valid for one captain and one first officer

, one relief first officer or one relief captain

. In addition to these rules, some common rules intended to improve flightcrew member s’ quality of life were imposed, including:

• At least one block of three consecutive days off

,

• At most six consecutive working days, except for the trips that themselves range up to 12 days in duration , and

• A penalty for base layovers near 24 hours in duration, because it is better to run trips back

- to

- back with shorter layovers

• T rips were put into morning (report 05:00

- 12:30) and afternoon families, with mixing of different families allowed, but penalized, in any line

• No more than five blocks of consec utive working days during the month, to reduce the need for commuters to commute to/from their base.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 50 

### Results

The Final Rule Solution was slightly more than one percent less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 17 . Re

- optimization of flightcrew member schedules under the Final Rule resulted in a two percent increase in TAFB and more than two percent more hotel room nig hts required.

There were a number of city pure pairings that did not have enough ground time between flight segments to meet the rest requirements of the consecutive nighttime operations rule. There were a number of pairings that exceeded the buffered 8:3 0 maximum flight duty period limit for flight duty periods that began during the early morning. These two constraints caused a significant number of pairings of five to six days in the Baseline Solution t o be broken up into multiple pairings of fewer days in the Final Rule Solution. In the Baseline Solution, 77 percent of trips were one to four day trips. In the Final Rule Solution, 81 percent of trips were one to four day trips.

The cumulative flight duty period and flight time limits did not affect Case H because flightcrew members had low levels of flight duty period and flight time in the Baseline Solution.

**Figure 17**  **: Case H**  **Monthly Results** 

Credit hours consist ed of the total number of hours for which flightcrew members were pa id. Case H flightcrew members were paid full credit for all block and deadhead hours. Duty rig was Metric Crew Position Baseline Final Rule

CA or FO 473 480 7 1.5% IO 99 102 3 3.0% RC 8 7 -1 -12.5% Credit Hours All 79,164 80,148 984 1.2% Block Hours All 51,348 51,509 161 0.3% Aircraft Block Hours N/A 22,910 22,902 -9 0.0% Domestic TAFB All 128,231 134,428 6,197 4.8% International TAFB All 217,279 218,140 862 0.4% Hotel Rooms All 9,696 9,936 240 2.5% CA or FO 7.1 6.8 -0.3 -4.2% IO 10.2 10.2 0.0 0.0% RC 12.2 13.2 1.0 8.2% CA or FO 4.1 3.9 -0.2 -4.9% IO 6.4 6.4 0.0 0.0% RC 3.9 4.9 1.0 25.6% CA or FO 14.4 14.1 -0.3 -2.0% IO 15.3 15.4 0.0 0.3% RC 17.0 17.1 0.1 0.8% Change

Lines

Average Duty Hours per Duty Period
Average Block Hours per Duty Period
Average Days Off per MonthSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 51 paid at the rate of 1

- for

- 2 during the day and 1

- for

- 1.92 during the night. Trip rig was paid at the rate of 1

- for

- 3.75. Minimum duty period guarantees range d from 3:00 to 6:00 hours per duty period.

Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed for his first duty period until the end of his debrief period at his last duty period of the t rip. Domestic TAFB increased by nearly five percent and international TAFB increased slightly

.
Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long si t times between flights.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 52 

## Case I: Supplemental Wide

**- Body** 

**SUMMARY**

Case I consisted of the operations of a representative supplemental carrier using wide

- body aircraft. The Final Rule Solution was less efficient in terms of credit hours than the Baseline So lution because of nearly all of the Final Rule elements. The Final Rule was significantly more constraining than current FAA Part 121 Subpart S supplemental rules and supplemental carrier labor agreements. This resulted in more credit hour s , TAFB and hotel rooms

. 

### DETAILED RESULTS

Since CrewPairings was not provided with data from an actual supplemental carrier, a representative supplemental carrier was created using the flight schedule and crew bases from Case H, along with a representative supplemental carrier CBA and FAR Part 121 Subpart S supplemental flight, duty and rest rules

. The flight schedule consisted of more than 6,000 flight segments during the scheduling period. Approximately 70 percent of the flight segments were short

- haul domestic operat ions and 30 percent were long

- haul international operations. Since the carrier mixe d domestic and international flying in its crew pairings, all of these flight segm ents were included in the study. The domestic short

- haul operations occurred from Monday af ternoon to Saturday afternoon while the international short

- haul operations occurred throughout the week.

The nature of short

- haul domestic operations differ ed greatly from the typical passenger carrier. The levels of aircraft and flightcrew member utiliz ation were much lower than the levels at passenger carriers. This was because the majority of duty periods consist ed of a flight segment from an outstation to a sort facility, an approximately four hour period during which the aircraft

was unloaded and rel oaded and a flight segment back to the same outstation from which it arrived.

The nature of long

- haul international operations also differ ed greatly from the typical passenger carrier. The routes were long and thin international routes throughout the entir e Northern Hemisphere that circled the globe in both directions from bases in the United States. The flights operate d infrequently, frequently with at least one additional flightcrew member. The majority of duty periods consist ed of a single flight segment . Deadheading was common because flights on these routes were infrequent. The international flights also operate d to military fields, which obviously did not offer the possibility of deadheading on scheduled passenger flights.

The representative supplemen tal carrier CBA permit ted much more flight and duty time than the typical passenger or all

- cargo carrier CBA. Similarly, the supplemental flight, duty and rest rules permit ted much more flight and duty time than the flag flight, duty and rest rules that sc heduled passenger carriers and many all

- cargo carriers operate d under.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 53 

### Buffers

All of the Final Rule elements significantly impact ed Case I. Three of the main rule elements that affected Case I were the maximum flight time, maximum FDP time and minimum rest period limits shown in Figure 18 . CrewPairings applied buffers to the maximum flight time and FDP time limits to reflect the fact that they appl ied to actual, rather than planned, operations. In Figure 18 , the CrewPairings buffer is shown in the “CP Buffer” column, which, when applied to the “ Final Rule ” limit, r esult ed in the “Effective Final Rule ” limit that was actually used when creating pairings for the Final Rule Solution. However, if the contractual rule shown in the “Current CBA” column less the debrief time shown in the “Debrief” column was more restricti ve than the “Effective Final Rule ” limit, the contractual rule is shown in the “Effective Final Rule ” column.

Figure 18 includes an “Effective Current Rule” column for comparison to the “Effective Final Rule ” column. The “Effective Current Rule” is the more restrictive of the “Current FAR” column or “Current CBA” column, after applying the buffer in the “Current Buffer” column and the debrief time in the “Debrief” colum n.
**Figure 18**  **: Case I**  **Buffers**

Current FAR Current CBA Debrief Carrier Buffer Effective Current Rule 1 Final Rule CP Buffer Effective Final Rule 2

Maximum Unaugmented

Flight Time 8:00

- - - 8:00 8:00 - 9:00 0:30 7:30 - 8:30

Maximum Augmented Flight Time (3 crew) 18:00 (4 crew) 22:00 - - - (3 crew) 12:00 (4 crew) 16:00 (3 crew) 13:00 (4 crew) 17:00 0:30 (3 crew) 12:30 (4 crew) 16:30

Maximum Unaugmented 8

FDP Time 16:00 16:00 0:15

- 15:45 9:00 - 14:00 3 0:30 4 8:30 - 13:30 3

Maximum Augmented FDP Time 8 (3 crew) 18:00 (4 crew) 22:00 (3 crew) 18:00 (4 crew) 22:00 0:15

- (3 crew) 17:45 (4 crew) 21:45 (3 crew) 15:00 - 17:00 5 (4 crew) 17:00 - 19:00 5 0:30 4 (3 crew) 14:30 - 16:30 5 (4 crew) 16:30 - 18:30 5

Minimum Unaugmented

Rest Time 8:00 9:00/12:00 7

- - 9:00/12:00 7 10:00

- 10:00/12:00 7

Minimum Augmented Rest Time 8:00 - 18:00 6 12:00

- - 12:00 - 18:00 6 10:00

- 12:00

8 The FDP concept does not exist in current FARs; therefore the Current columns in this row refer to duty time 5 Depending on FDP start time; Maximum show n is for aircraft equipped w ith Class 1 rest facility, reduced if aircraft is equipped w ith low er class rest facility

6 Supplemental rules, including double out if crew exceeds 8-in-24, 18:00 after breaking 8-in-24, 20-in-48 or 24-in-72

7 Domestic/international Rule Element

4 Plus the 0:30 de facto buffer resulting from §117.19 for a total of 1:00 Time in Hours:Minutes

1 The more restrictive of the current CBA, less debrief, or the FAR (adjusted for carrier buffer)

2 The more restrictive of the current CBA, less debrief, or the Final Rule (adjusted for CP buffer)

3 Depending on FDP start time; Maximum show n is for 1 segment during FDP, reduced if 3 or more segments during FDPSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 54 

### Pairings

The Baseline Solution pairings were constructed with the constraints of the “Effective Current Rule” column in Figure 18 , in addition to all other FAR, contractual, management and discretionary constraints not shown. The Final Rule Solution pairings were constructed with the constraints of the “Effective Final Rule ” column in Figure 18 , in addition to all other Final Rule

, contractual, management and discretionary constraints not shown.

The maximum unaugmented flight time li mit applicable to the Baseline Solution was the FAR limit of 8:00 hours. The maximum flight time limit applicable to the Final Rule Solution was between 7:30 hours and 8:30 hours, depending on FDP start time, after application of a 30 minute buffer. The ma ximum unaugmented flight time limit of the Final Rule was therefore expected to have a mixed impact on the Final Rule Solution pairings; in some situations the Effective Final Rule limit was more constraining than the Effective Current Rule and in other

ca ses it was less constraining.

The maximum augmented flight time limits applicable to the Baseline Solution were 1 8 :00 hours for flights with one additional flightcrew member and 22 :00 hours for flights with two additional flightcrew members, which were the FAR limits. The maximum flight time limits applicable to the Final Rule Solution were 12:30 hours for flights with one additional flightcrew member and 16:30 hours for flights with two additional flightcrew members, which were the Final Rule limits after application of a 30 minute buffer. The maximum augmented flight time limits of the Final Rule were therefore expected to have a negative impact on the Final Rule Solution pairings; the Effective Final Rule limit s were much more constraining than the Effect ive Current Rule.

The maximum unaugmented FDP limit applicable to the Baseline Solution was 15:45 hours, which was the FAR and CBA limit less a 15 minute debrief period. The maximum FDP limit applicable to the Final Rule Solution was between 8 :30 and 1 3 :30, which was the Final Rule less a 30 minute buffer. The maximum unaugmented FDP limit of the Final Rule was therefore expected to have a significant negative impact on the Final Rule Solution pairings because the Effective Final Rule was much more const raining than the Effective Current Rule

. The maximum augmented FDP limits applicable to the Baseline Solution were 17: 45 hours for flights with one add itional flightcrew member and 21 : 45 for flights with two additional flightcrew members, which were the FA R and CBA limits less a 15 minute debrief period. The maximum FDP limits applicable to the Final Rule Solution were between 14:30 and 16:30 for flights with one additional flightcrew member and between 16:30 and 18:30 hours for flights with two additional flightcrew members, which were the Final Rule limits less a 30 minute buffer. The Effective Final Rule s limits were significantly less than the Effective Current Rule in all situations.

The minimum unaugmented rest period s applicable to the Baseline Soluti on were 9: 00 hours for rest periods preceding a domestic duty period and 12:00 hours for rest periods preceding an international duty period, which were the CBA minimums . The minimum rest period s applicable to the Final Rule Solution were 10: 00 hours for r est periods preceding domestic duty periods

, which was the Final Rule minimum, and 12:00 hours for rest periods preceding internationalSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 55 duty periods, which was the CBA minimum . The Final Rule minimum augmented rest period

was expected to have a slightly ne gative impact on the Final Rule Solution pairings because the Final Rule minimum for rest periods preceding domestic duty periods was one hour greater than the Effective Current Rule

. The minimum augmented rest period applicable to the Baseline Solution was 12:00

- 18:00 hours. The lower end was the CBA minimum rest period and the higher end was the FAR if the amount of flight time in the preceding 24 hour period exceed ed eight hours. The minimum rest period applicable to the Final Rule Solution was 12:00 h ours, which was the CBA minimum rest period. The Final Rule minimum augmented rest period was expected to have a slightly positive impact on the Final Rule Solution pairings because the Final Rule remove d the requirement for additional rest if flight time exceed ed eight hours in the preceding 24 hour period.

The Final Rule limit ed flightcrew members to three consecutive flight duty periods that impinge d on the window of circadian low unless the carrier provide d the flightcrew member with a minimum two hour rest opportunity in a suitable accommodation during each FDP, in which case five consecutive flight duty periods were permitted. The consecutive nighttime operations constraint was very important for Case I because the vast majority of domestic duty period s impinge d on the WOCL.

Since the Final Rule require d a minimum two hour rest opportunity during each FDP to qualify for five consecutive FDPs, transfer time to and from the suitable accommodation had to be accounted for, in addition to debrief/brief times . The Case H carrier informed CrewPairings that a total of 30 minutes for transfer to and from the suitable accommodation would be appropriate assumptions to use in their analysis. These values were also used for Case I. In addition, CrewPairings estimated the total debrief/brief times to be 45 minutes. This meant that each FDP had to have a total of 3:15 hours between flight segments to qualify for five consecutive FDPs.



### Bid Lines

The Cygnus system was used to construct a complete set of bid lines for bot h the Baseline and Final Rule Solutions using the pairings from the solutions. The Baseline Solution bid lines were constructed in compliance with all FAR, contractual, management and discretionary constraints. The Final Rule Solution bid lines were constr ucted in compliance with all Final Rule

, contractual, management and discretionary constraints.

The primary rules used for construction of both Baseline and Final Rule Solution bid lines were:

• Minimum of 1 1 days off

• S ingle and double days off were allowed, but penalized

• S ingle and double working days were allowed, but penalized

• A target of 80 credit hours, with a maximum of 100.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 56 

### Results

The Final Rule Solution was seven percent less efficient in terms of credit hours than the Baseline Solution, as shown in Figure 19 . Re

- optimization of flightcrew member schedules under the Final Rule resulted in nearly four percent more TAFB and eight percent more hotel room nights req uired. The Final Rule constraints were more restrictive in almost every situation. The Final Rule solution used less crew augmentation than the Baseline Solution, primarily because the Baseline Solution took advantage of the supplemental rules to create a significant number of mult i

- segment augmented duties. The share of single

- segment duty periods increased from 52 percent to 65 percent. These duties were not possible in the Final Rule Solution because of maximum FDP time constrains.

Overall, 774 of the 1, 044 Baseline Solution CA/FO trips violated at least one of the Final Rule constraints and had to be re

- optimized for the Final Rule Solution. Exceeding the Final Rule maximum FDP time limit was the most common reason that Baseline Solution trips were not
p ossible in the Final Rule Solution. The average duty hours and block hours per duty period decreased dramatically in the Final Rule Solution for all crew positions.

The Final Rule limited cumulative FDP time to 60 hours during any consecutive 168 hour peri od. A number of trips in the Baseline Solution violated this constraint and had to be re

optimized for the Final Rule Solution. A number of trips also violated the consecutive nighttime operations constraint and the 30 hours of rest in 168 consecutive hour s constraint of the Final Rule. The net impact of all of these constraints was that the average number of days off per month for flightcrew members decreased, because they needed to work more days per month to complete the same flight schedule as in the Ba seline Solution.Summary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 57 **Figure 19**  **: Case I**  **Monthly Results** 

Credit hours consist ed of the total number of hours for which flightcrew members were paid. Case I flightcrew members were paid full credit for all block and deadhead hours. Duty rig was paid at the rate of 1

- for

- 2. Trip rig was paid at the rate of 1

- for

- 4

. Time away from base was all time spent away from a flightcrew member’s base while on a trip, from the time he report ed f or his first duty period until the end of his debrief period at his last duty period of the trip. Domestic TAFB increased by almost three percent and international TAFB increased by five percent

.
Hotel rooms were the number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. Metric Crew Position Baseline Final Rule

CA or FO 341 386 45 13.2% IO 119 78 -41 -34.5% RC 5 8 3 60.0% Credit Hours All 64,235 68,876 4,642 7.2% Block Hours All 52,793 50,864 -1,929 -3.7% Aircraft Block Hours N/A 22,933 22,928 -5 0.0% Domestic TAFB All 114,951 118,109 3,159 2.7% International TAFB All 196,677 206,436 9,759 5.0% Hotel Rooms All 9,582 10,338 756 7.9% CA or FO 10.2 8.1 -2.1 -20.6% IO 11.4 10.2 -1.2 -10.5% RC 14.2 12.3 -1.9 -13.4% CA or FO 5.9 4.7 -1.2 -20.3% IO 6.9 6.8 -0.1 -1.4% RC 6.5 2.8 -3.7 -56.9% CA or FO 12.5 12.0 -0.5 -3.8% IO 14.0 13.8 -0.2 -1.2% RC 17.4 15.4 -2.0 -11.6% Lines

Average Duty Hours per Duty Period

Average Block Hours per Duty Period

Average Days Off per Month ChangeSummary of CrewPairings

, Inc. Economic Analysis of Flightcre w Member Duty and Rest Requirements Rulemaking

September 2012 Page 58 

## Appendix 1: Pay Variables

Block Hours Hours during which a flightcrew member operates an aircraft. Also commonly called flight h ours although taxi times are included.

Credit Hours Hours for which a flightcrew member is paid. Credit hours can include block hours, deadhead credit, duty rig, trip rig, and minimum guarantees.

Deadhead Credit Credit based on some fraction of the time spent deadheading. Carriers typically credit flightcrew members with 50

– 100 percent of the flight time of a deadhead flight, sometimes subject to a minimum guarantee per deadheading occasion. Ground transportation via limousine, train, or water transpor t to move a flightcrew member from one airport to another is also subject to deadhead credit.

Duty Rig Credit for hours spent on duty. Duty rig was created to prevent carriers from scheduling a flightcrew member with long duty periods but only a small amount of block time.

Hotel Room Nights The number of hotel room nights associated with the layovers (duty breaks) in the solution plus any day rooms contractually required for long sit times between flights. In the absence of specific carrier

- supplied data for early check

- in and late check

- out rules at each hotel, all cases used a simple rule specifying one room per flightcrew member for every X hours of duty break time or fraction thereof (for example, a new ro om cost for every 24 hours of layover). X typically ranges from 24

– 30 hours.

Minimum Guarantee Minimum pay guarantee for each duty period or working day.

Per Diem A fixed amount of compensation paid to flightcrew members per unit of time (typically pe r hour or per day). In this report, per diem is calculated based on TAFB. The per diem rate typically differs based on whether a trip is domestic or international.

Synthetic Time Synthetic time is the difference between block hours and credit hours and is primarily generated by deadhead credit, duty rigs, minimum guarantee, and/or trip rig.

Trip Rig Credit for hours away from base spent on a trip. Trip rig was created to prevent carriers from scheduling a flightcrew member to fly to a destination and spend days there before returning home with little compensation.

TAFB (Time Away From Base) All time spent away from a flight crew member’s base while on a trip, from the time he reports for his first duty period until the end of his debrief period at his las t duty period of the trip.

Ticket Costs The actual ticket costs paid to other carriers for deadheading on that carrier’s flights. Such ‘offline’ deadhead flights are mostly avoided, each carrier preferring to deadhead on their own flights or at least on f lights flown by their regional partners. Some all

- cargo operators are an exception to this rule and will deadhead solely on offline flights.