Table C.1: Categorization of Air Carriers

ABX AIR INC Freight Integrated 313 0% 100% FEDERAL EXPRESS CORP Freight Integrated 4,227 0% 100% UNITED PARCEL SERVICE CO Freight Integrated 2,690 0% 100% AEKO KULA INC (Aloha Air Cargo) Freight Narrow-body 22 0% 100% AERO MICRONESIA INC (Asia Pacific Airlines) Freight Narrow-body 17 0% 100%

AIR TRANSPORT INTERNATIONAL LIMITED LIABILITY CO Freight Narrow-body 208 17% 83%

AMERIJET INTERNATIONAL INC Freight Narrow-body 72 0% 100% AMERISTAR AIR CARGO INC Freight Narrow-body 17 17% 83% ASTAR USA INC Freight Narrow-body 120 0% 100% CAPITAL CARGO INTERNATIONAL AIRLINES INC Freight Narrow-body 140 0% 100%

CARIBBEAN SUN AIRLINES INC Freight Narrow-body 8 100% 0% fleet type is similar to freight narrow-body case and aircraft utilization is assumed to be more like freight narrow-body case than passenger narrow-body or regional case DYNAMIC AIRWAYS LLC Freight Narrow-body 8 100% 0% aircraft utilization is assumed to be more like freight narrow-body case than passenger narrow-body or regional case FALCON AIR EXPRESS INC Freight Narrow-body 25 100% 0% aircraft utilization is assumed to be more like freight narrow-body case than passenger narrow-body or regional case KALITTA CHARTERS II LLC Freight Narrow-body 35 0% 100% LYNDEN AIR CARGO L L C Freight Narrow-body 77 0% 100% NATIONAL AIR CARGO GROUP INC Freight Narrow-body 31 5% 95% NORTHERN AIR CARGO INC Freight Narrow-body 24 0% 100% SIERRA PACIFIC AIRLINES INC Freight Narrow-body 10 100% 0% aircraft utilization is assumed to be more like freight narrow-body case than passenger narrow-body or regional case SKY KING INC Freight Narrow-body 32 100% 0% aircraft utilization is assumed to be more like freight narrow-body case than passenger narrow-body or regional case ATLAS AIR INC Freight Wide-body 531 2% 98% CBA is assumed to be more like freight wide-body case than supplemental case and operation kind listed on airline certificate is domestic and flag NORTH AMERICAN AIRLINES Freight Wide-body 185 100% 0% CBA is assumed to be more like freight wide-body case than supplemental case, operation kind listed on airline certificate is domestic and flag, and aircraftutilization is assumed to be more like freight widebody case than passenger wide-body case

POLAR AIR CARGO WORLDWIDE INC Freight Wide-body 198 0% 100% CBA is assumed to be more like freight wide-body case than supplemental case and operation kind listed on airline certificate is domestic and flag ALASKA AIRLINES INC Passenger Integrated 1,420 99% 1% AMERICAN AIRLINES INC Passenger Integrated 9,463 100% 0% CONTINENTAL AIRLINES INC Passenger Integrated 4,103 100% 0% DELTA AIR LINES INC Passenger Integrated 10,791 100% 0% HAWAIIAN AIRLINES INC Passenger Integrated 403 100% 0% UNITED AIR LINES INC Passenger Integrated 5,456 100% 0% US AIRWAYS INC Passenger Integrated 4,377 100% 0% AIRTRAN AIRWAYS INC Passenger Narrow-body 1,683 100% 0% ALLEGIANT AIR LLC Passenger Narrow-body 326 100% 0% BRENDAN AIRWAYS LLC (USA 3000) Passenger Narrow-body 54 100% 0%

CONTINENTAL MICRONESIA INC Passenger Narrow-body 123 100% 0% FRONTIER AIRLINES INC Passenger Narrow-body 681 100% 0% JETBLUE AIRWAYS CORPORATION Passenger Narrow-body 1,979 100% 0% MIAMI AIR INTERNATIONAL INC Passenger Narrow-body 80 100% 0% MN AIRLINES LLC (Sun Country) Passenger Narrow-body 143 100% 0% SOUTHWEST AIRLINES CO Passenger Narrow-body 5,885 100% 0% SPIRIT AIRLINES INC Passenger Narrow-body 453 100% 0% SWIFT AIR L L C Passenger Narrow-body 27 100% 0% CBA is assumed to be more like passenger narrowbody case than freight narrow-body case TEM ENTERPRISES INC (Casino Express) Passenger Narrow-body 40 100% 0%

VIRGIN AMERICA INC Passenger Narrow-body 330 100% 0% VISION AIRLINES INC Passenger Narrow-body 95 100% 0% RYAN INTERNATIONAL AIRLINES INC Passenger Wide-body 150 100% 0%

AERODYNAMICS INC Regional 5 100% 0% AIR WISCONSIN AIRLINES CORPORATION Regional 753 100% 0%

AMERICAN EAGLE AIRLINES INC Regional 2,525 100% 0% ATLANTIC SOUTHEAST AIRLINES INC Regional 1,668 100% 0%

AVIATION SERVICES LTD (Freedom Air) Regional 7 97% 3% Explanation 3

Operator 1 Flightcrew Members 1 Industry Group Percent of Revenue Departures: Passenger 2 Percent of

Revenue Departures: Cargo-only 2Table C.1: Categorization of Air Carriers

Explanation 3 Operator 1 Flightcrew Members 1 Industry Group Percent of Revenue Departures: Passenger 2 Percent of

Revenue Departures: Cargo-only 2

CHAMPLAIN ENTERPRISES INC (CommutAir) Regional 163 100% 0%

CHAUTAUQUA AIRLINES INC Regional 638 100% 0% COLGAN AIR INC Regional 440 100% 0% COMAIR INC Regional 1,037 100% 0% COMPASS AIRLINES LLC Regional 408 100% 0% EMPIRE AIRLINES INC Regional 45 0% 100% CBA is assumed to be more like regional case than freight narrow-body case ERA AVIATION INC Regional 54 100% 0% EXECUTIVE AIRLINES INC Regional 286 100% 0% EXPRESSJET AIRLINES INC Regional 2,100 100% 0% GOJET AIRLINES LLC Regional 246 100% 0% GREAT LAKES AVIATION LTD Regional 292 100% 0% GULF AND CARIBBEAN CARGO INC Regional 48 0% 100% CBA is assumed to be more like regional case than freight narrow-body case GULFSTREAM INTERNATIONAL AIRLINES INC Regional 158 100% 0%

HAWAII ISLAND AIR INC (Island Air Hawaii) Regional 38 100% 0%

HORIZON AIR INDUSTRIES INC Regional 621 100% 0% HYANNIS AIR SERVICE INC (Cape Air) Regional 13 98% 2%

LYNX AVIATION INC (Frontier) Regional 29 100% 0% MESA AIRLINES INC Regional 1,257 100% 0% MESABA AVIATION INC Regional 935 100% 0% MOUNTAIN AIR CARGO INC Regional 54 0% 100% PENINSULA AIRWAYS INC Regional 80 93% 7% PIEDMONT AIRLINES INC Regional 505 100% 0% PINNACLE AIRLINES INC Regional 1,255 100% 0% PRESCOTT SUPPORT CO Regional 10 0% 100% CBA is assumed to be more like regional case than freight narrow-body case PSA AIRLINES INC Regional 517 100% 0% REPUBLIC AIRLINES INC Regional 681 100% 0% RHOADES AVIATION INC Regional 2 0% 100% SEABORNE VIRGIN ISLAND INC Regional 25 100% 0% SHUTTLE AMERICA CORPORATION Regional 525 100% 0% SKYWEST AIRLINES INC Regional 2,746 100% 0% TATONDUK OUTFITTERS LTD Regional 56 11% 89% CBA is assumed to be more like regional case than freight narrow-body case TRANS STATES AIRLINES LLC Regional 237 100% 0% USA JET AIRLINES INC Regional 52 26% 74% CBA is assumed to be more like regional case than freight narrow-body case CENTURION AIR CARGO INC Supplemental 47 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental EVERGREEN INTERNATIONAL AIRLINES INC Supplemental 185 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental FLORIDA WEST INTERNATIONAL AIRWAYS INC Supplemental 32 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental KALITTA AIR LLC Supplemental 334 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental OMNI AIR INTERNATIONAL INC Supplemental 315 100% 0% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental SKY LEASE I INC (Tradewinds Airlines) Supplemental 59 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental SOUTHERN AIR INC Supplemental 281 0% 100% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental WORLD AIRWAYS INC Supplemental 421 43% 57% Fleet type is similar to supplemental case and operation kind listed on airline certificate is supplemental Notes:
1 Source: FAA Vital Information Subsystem (VIS) December 2010
2 Source: BTS, Database T1: U.S. Air Carrier Traffic and Capacity Summary by Service Class (2010) 3 Airline Certificate Source: http://av-info.faa.gov/OperatorsName.asp

## Table C.2: Block Hours per Pilot from Carrier Supplied Data

Industry Group Pilots 1 

## Flight Minutes Block Hrs

per Pilot Passenger Integrated 12,292 42,834,514 58.1 Passenger Narrow-body 6,144 21,905,688 59.4 Passenger Wide-body 6,149 20,928,826 56.7 Regional 1,195 3,323,147 46.3 Supplemental 682 1,627,920 39.8 Freight Integrated 3,669 10,606,019 48.2 Freight Narrow-body 833 2,090,926 41.8 Freight Wide-body 2,906 8,515,093 48.8

Industry Group Pilots 1 

## Flight Minutes Block Hrs

per Pilot Passenger Integrated 12,267 44,687,045 60.7 Passenger Narrow-body 6,075 22,139,229 60.7 Passenger Wide-body 6,195 22,547,816 60.7 Regional 1,395 4,165,528 49.8 Supplemental 563 1,598,946 47.3 Freight Integrated 3,059 7,322,455 39.9 Freight Narrow-body 636 1,004,179 26.3 Freight Wide-body 2,586 6,318,276 40.7

Industry Group Block Hrs per Pilot Passenger Integrated 59.4 Passenger Narrow-body 60.1 Passenger Wide-body 58.7 Regional 48.1 Supplemental 43.6 Freight Integrated 44.0 Freight Narrow-body 34.1 Freight Wide-body 44.8

First Month of Data

Second Month of Data

Average of Two Months of Data

1 

## Pilots that flew at least one segment during monthTable C.3: Adjusting Form 41 Pilot and CoPilot Cost Data

Industry Group Pilot and CoPilot Costs Q1-Q3 2010 1 (thousands) Pilot and

CoPilot Costs Q1-Q4 2010 2 (thousands) Total

Pilots 3 Pilots at

Carriers that Report Form 41 Adjustment

Factor Adjusted Total

Pilot and CoPilot Costs (thousands) Fully Burdened

Pilot and CoPilot Costs (thousands) 4
Passenger Integrated $3,498,191 $4,710,694 36,013 36,013 100% $4,710,694 $5,506,802 Passenger Narrow-body $1,281,923 $1,726,249 11,899 11,737 101% $1,750,075 $2,045,838 Passenger Wide-body $10,104 $13,606 150 150 100% $13,606 $15,906 Regional $757,814 $1,020,479 20,511 18,000 114% $1,162,836 $1,359,355 Supplemental $108,319 $145,863 1,674 1,583 106% $154,248 $180,316 Freight Integrated $1,094,050 $1,473,257 7,230 7,230 100% $1,473,257 $1,722,238 Freight Narrow-body $23,811 $32,064 846 400 212% $67,816 $79,276 Freight Wide-body $86,037 $115,858 914 914 100% $115,858 $135,438 Total $6,860,249 $9,238,071 79,237 76,027 105% $9,448,391 $11,045,169 * items may not sum to totals due to rounding 1 Source: Bureau of Transportation Statistics Form 41 data (Item 51230, Pilots and Copilots, from Schedule P-5.2)
2 Source: Q1-Q3 costs multiplied by approx 1.347 (the ratio of full year costs to Q1-Q3 costs)
3 Source: FAA Vital Information Subsystem (VIS) December 2010
4 Pilot and CoPilot Costs * 1.169. See Appendix C.12

### Table C.4: Cargo Operations Benefits Analysis

row Item Base Case (2011 $M) High Case

(2011 $M) Sensitivity

(2011 $M) Source

1 Onboard Fatalities 3.2 3.2 Average of 5 fatal cargo accidents involving US carriers during 2001-2010 2 Ground Fatalities 0.4 0.4 Average of 5 fatal cargo accidents involving US carriers during 2001-2010 3 VSL $6.2 $9.5 High: DOT guidance circa 2011, Sens: DOT guidance circa 2012 is $9.1 million in 2012 in 2012 dollars. This value is $8,945,300 expressed in 2011 dollars (adjusted using GDP deflator). This value grown at prescribed rate of 1.07 percent annually for 6 years until 2018 (the mid-point of the benefits period) is $9.5 million in 2011 dollars. 4 Total Fatalities Valuation $22.3 $34.20 =(row 1 + row 2) * row 3 5 Injuries 3 Actual Number of Injuries from FedEx July 26, 2002 Accident 6 Value of Injury $0.65 OST guidance 7 Medical Costs $0.07 Medical costs for AIS3 ("Serious") injury, from NHTSA (2000), Table 2, converted from 2000$ in original source to 2011$ using change in CPI for medical care services (series SUUR0000SAM2) between 2000 and 2011 (57.0%). 8 Total Injuries Valuation $2.16 =row 5 * (row 6 + row 7) 9 Fatalities and Injuries Valuation $2.16 $22.30 $34.20 =row 4 + row 8 10 Estimates for the replacement value of an aircraft $15.2 $23.5 $42.5 Base: B757, High: MD-11, Sensitivity: B747

11 Cargo Value $3.7 $8.80 $10.80 Based on aircraft model's capacity 12 Accident investigation cost $0.60 $10.50 $10.50 “Economic Values for FAA Investment and Regulatory Decisions, A Guide,” Oct. 3, 2007, pp. 8-4 and 8-5 and inflated using the GDP deflator. 13 Environmental cleanup cost $1.00 IPA comment that the cleanup for Shanksville was $1M 14 Total $21.70 $65.1 $99.0 = sum of row 9 through row13 15 Effectiveness Rating 15% 15% 15% FAA AVP 16 Benefit of Rule over 10 year period $3.255 $9.77 $14.85 =row 14 * row 15

17 Annual Benefit of Rule $0.326 $0.977 $1.485 =row 16 / 10

## Table C.5: Cargo Operations Benefits Analysis, Analysis Period

Base Case High Case Sensitivity

Analysis Year Calendar

Year Annual

Benefit (2011 $M) PV at 7%

(2011 $M) PV at 3%

(2011 $M) Annual

Benefit (2011 $M) PV at 7%

(2011 $M) PV at 3%

(2011 $M) Annual

Benefit (2011 $M) PV at 7%

(2011 $M) PV at 3%

(2011 $M)

1 2012 2 2013 3 2014 $0.33 $0.27 $0.30 $0.98 $0.80 $0.89 $1.49 $1.21 $1.36
4 2015 $0.33 $0.25 $0.29 $0.98 $0.74 $0.87 $1.49 $1.13 $1.32
5 2016 $0.33 $0.23 $0.28 $0.98 $0.70 $0.84 $1.49 $1.06 $1.28 6 2017 $0.33 $0.22 $0.27 $0.98 $0.65 $0.82 $1.49 $0.99 $1.24
7 2018 $0.33 $0.20 $0.26 $0.98 $0.61 $0.79 $1.49 $0.92 $1.21 8 2019 $0.33 $0.19 $0.26 $0.98 $0.57 $0.77 $1.49 $0.86 $1.17 9 2020 $0.33 $0.18 $0.25 $0.98 $0.53 $0.75 $1.49 $0.81 $1.14 10 2021 $0.33 $0.17 $0.24 $0.98 $0.50 $0.73 $1.49 $0.75 $1.10
11 2022 $0.33 $0.15 $0.24 $0.98 $0.46 $0.71 $1.49 $0.71 $1.07
12 2023 $0.33 $0.14 $0.23 $0.98 $0.43 $0.68 $1.49 $0.66 $1.04 Total $3.26 $2.00 $2.62 $9.77 $5.99 $7.85 $14.85 $9.11 $11.94

### Table C.6: IPA contractual minimums analysis

Source

Line # Freight Integrated Credit Hours 1 Baseline 103,715 

### GRA, Incorporated, “Summary of CrewPairings, Inc. Economic Analysis of Flightcrew Member Duty and Rest Requirements Rulemaking,” September 2012 2 Change due to rule 1,544 Table 17 3 % Change 1.488% line 2 / line 1

UPS contractual minimums analysis 4 Total Regular Line Credit 221,221 IPA Comments 5 Total Regular Line Pay 224,989 ibid. 6 Total Regular Line Pay if each line plussed up 1.488 in credit hour 227,344 ibid. 7 % increase in regular pay 1.047% ibid.

8 ratio 0.70 line 7 / line 3

Credit Hour cost per line, Freight Integrated 9 monthly $466 Table 19 10 annual $5,592 line 9 * 12

11 Overestimate per lineholder per year $1,678 (1 - line 8) * line 10

12 UPS pilots 2,690 Table C.1 13 percent lineholder 0.52 Table 20 14 Total overestimate 2,347,186 line 11 * line 12 * line 13

## Table C.7: Cargo Operations Rest Facilities Cost Sensitivity Analysis

Year Engineering Installation Downtime Fuel Total Nominal Cost 2012 $0 2013 $1,000,000 $2,250,000 $0 $3,250,000 2014 $2,250,000 $21,825 $2,271,825 2015 $21,825 $21,825 2016 $21,825 $21,825 2017 $21,825 $21,825 2018 $21,825 $21,825 2019 $21,825 $21,825 2020 $21,825 $21,825 2021 $21,825 $21,825 2022 $21,825 $21,825 2023 $21,825 $21,825 Total $1,000,000 $4,500,000 $0 $218,250 $5,718,250Table C.8: Part 121 Cargo Accident History

NTSB_RPRT_NBR EVENT_ LCL_DA TE ACFT_MAKE_NAME ACFT_MODEL_CO DE NAME INJURY_ LEVEL_ DESC Onboard On

ground fatalities

DCA91MA021 17-Feb-91 MCDONNELL DOUGLAS DC-9-15 RYAN INTERNATIONAL AIRLINES FATAL 2 0 DCA92MA022 15-Feb-92 DOUGLAS DC-8-63 FATAL 4 0 MIA95RA121 28-Apr-95 DOUGLAS DC-8F-54 FATAL 3 6 MIA95RA162 27-Jun-95 CONVAIR CV-440 FATAL 2 0 ANC96FA102 20-Jul-96 DOUGLAS DC-6A NORTHERN AIR CARGO FATAL 4 0 MIA97RA011 22-Oct-96 BOEING 707-323 MILLON AIR FATAL 4 30 DCA97MA059 07-Aug-97 DOUGLAS DC-8-61 FINE AIRLINES, INC. FATAL 4 1 DCA00MA026 16-Feb-00 DOUGLAS DC-8-71F EMERY WORLDWIDE AIRLINES INC FATAL 3 0 DCA04MA068 13-Aug-04 CONVAIR DIV. OF GEN. DYNAMICS CV-340 (580) AIR TAHOMA INC FATAL 2 0 DCA08RA077 06-Jul-08 MCDONNELL DOUGLAS DC-9-15 USA JET AIRLINES, INC FATAL 2 0 DCA08RA078 07-Jul-08 BOEING 747-200 CENTURION AIRLINES FATAL 8 2 DCA09RA041 23-Mar-09 MCDONNELL DOUGLAS MD11 FEDEX CORPORATION FATAL 2 0 DCA10RA092 03-Sep-10 BOEING 747-44AF UNITED PARCEL SERVICE CO FATAL 2 0 DCA13RA081 29-Apr-13 BOEING 747-428 WELLS FARGO BANK NORTHWEST NA TRUSTEE FATAL 7 0 DCA13MA133 14-Aug-13 AIRBUS A300 F4-622R UNITED PARCEL SERVICE CO FATAL 2 0

Average (2001-2010) 3.2 0.4

Source: NTSB Aviation Accident Database

## Table C.9: Summary of Crew Pairings Cargo Operations Analysis

Baseline Final Rule Difference Baseline Final Rule Difference Baseline Final Rule Difference Case G All-Cargo Narrow-body 4.8 4.8 0.0 14.5 14.4 0.1 17.4 17.5 -0.1 Case H All-Cargo Wide-body

CA or FO 7.1 6.8 0.3 14.4 14.1 0.3 25.8 25.2 0.6 IO 10.2 10.2 0.0 15.3 15.4 -0.1 35.0 34.7 0.2 RC 12.2 13.2 -1.0 17 17.1 -0.1 37.0 39.7 -2.7 Case I Supplemental Wide-body

CA or FO 10.2 8.1 2.1 12.5 12 0.5 41.7 34.0 7.6 IO 11.4 10.2 1.2 14 13.8 0.2 42.6 38.6 4.0 RC 14.2 12.3 1.9 17.4 15.4 2 41.7 41.9 -0.154

*Hours on Duty per Week=(30-Days Off per Month)*(7/30)*Duty Hours per Duty Period Duty Hours per Duty Period Days off per Month Hours on Duty per Week*

## Table C.10: Effectiveness Ratings of Accidents used in Recent Rulemakings



## Carrier Flt # Date Flightcrew Member Duty and Rest Requirements (FDR) Pilot Certification and

Qualification Requirements for Air Carrier Operations Rule (FOQ) Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers (N&O) Total

Colgan 3407 2/12/2009 0.5 0.2 0.2 0.9 COMAIR 5191 8/27/2006 0.35 0.15 0.5 Corporate 5966 10/19/2004 0.75 0.15 0.05 0.95

## Table C.11: Average Flightcrew Member Cost per Credit Hour

Industry Group Pilot and

Copilot Costs (thousands) Block Hours Average Flightcrew Cost per Block Hr Fully Burdened Average Incremental Flightcrew Cost per Block Hr [A] [B] [C] [D] Passenger Integrated 3,498,191 7,008,613 $499 $583 Passenger Integrated: Narrow-body 1,639,481 4,054,243 $404 $473

Passenger Integrated: Wide-body 1,858,710 2,954,370 $629 $735

Passenger Narrow-body 1,281,923 2,943,256 $436 $509 Passenger Wide-body 10,104 15,146 $667 $780 Regional 757,814 4,236,987 $179 $209 Supplemental 108,319 152,194 $712 $832 Freight Integrated 1,094,050 738,541 $1,481 $1,732Freight Narrowbody 23,811 32,419 $734 $859Freight Widebody 86,037 101,601 $847 $990

Notes: [A]

[B]

[C] [D] Bureau of Transportation Statistics Form 41 data (Item 51230, Pilots and

Copilots, from Schedule P-5.2) Block hours for each carrier were taken from the AirHoursRamp item in the Air Carrier Summary Data, T2: U.S. Air Carrier Traffic and Capacity Statistics by Aircraft Type =1000*[a] / [b] =[c] * 1.169. See Table C.12.

## Table C.12: Analysis of Employer Provided Benefits

Does benefit category vary with additional hours worked for individuals? % of Total Compensation 1



## Wages and salaries 70.3 Total benefits 29.7 No 6.9

No 2.8

No 8.2

Yes 3.7

Yes 8.2

Totals Yes 11.9 No 17.9 Total 29.8

Wage multiplier for employer provided benefits 1.169

Source:

1 

## BLS, Employer costs for Employee compensation - June 2013 Table 5, Private Industry http://www.bls.gov/news.release/pdf/ecec.pdf Paid leave (Vacation, Holiday, Sick, Personal)

Insurance (Life, Health, Short-term disability, Long-term disability) Retirement and savings

Legally required benefits (Social Security and Medicare, Federal UI, State UI, Workers Compensation) Supplemental pay (Overtime and premium, Shift differentials, Nonproduction bonuses)