U.S. Department of Transportation

FEDERAL AVIATION ADMINISTRATION

Office of Aviation Policy and Plans

Washington, D.C. 20591

INITIAL SUPPLEMENTAL REGULATORY IMPACT ANALYSIS

Flightcrew Member Duty and Rest Requirements

PART 117

Final Rule

OFFICE OF AVIATION POLICY AND PLANS

October 4, 2012
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Table of Contents

Purpose of this Supplemental Regulatory Impact Analysis (RIA)..................................... 1

Disposition of Issues Raised by Comments........................................................................ 3

Benefit/Cost Summary...................................................................................................... 16

Benefit Analysis................................................................................................................ 18

The Nature of Fatigue ................................................................................................... 19

Causes of Fatigue.......................................................................................................... 20

Fatigue and Transportation ........................................................................................... 20

Recent Findings on Fatigue and Occupational Performance........................................ 22

Aviation Safety Reporting System (ASRS).................................................................. 24

Effectiveness of Final Rule........................................................................................... 26

Quantified Benefits....................................................................................................... 35

Passenger Operations Base Case Estimate ............................................................... 36

Passenger Operations High Case Estimate ............................................................... 38

Cargo-only Operations Base Case Estimate ............................................................. 40

High Case Estimate................................................................................................... 42

Benefit Summary .......................................................................................................... 43

Cost Analysis.................................................................................................................... 45

Flight Operations Cost .................................................................................................. 47

Crew Scheduling....................................................................................................... 48

Computer Programming............................................................................................ 69

Payroll Cost Savings from Reducing Flightcrew Members Fatigue ........................ 71
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Flight Operations Cost Summary.............................................................................. 74

Rest Facilities................................................................................................................ 75

Engineering............................................................................................................... 78

Installation................................................................................................................. 79

Downtime.................................................................................................................. 80

Fuel Consumption Costs........................................................................................... 81

Fatigue Training............................................................................................................ 84

Cost Analysis Summary................................................................................................ 88

Benefit Cost Summary...................................................................................................... 90

Appendix A: Relevant Accident History .......................................................................... 91

Appendix B: Sensitivity Analysis................................................................................... 125

Sensitivity #1: Adjusting for Block Hour Discrepancy .............................................. 126

Sensitivity #2: Alternative Weighting of Case Results............................................... 129

Sensitivity #3: Alternative Assumptions Regarding Percent of Flightcrew Members 

Who Are Reserves .................................................................................................................. 132

Sensitivity #4: Alternative Assumption Regarding Percent of Sick Time that would be 

Saved Due to the Final Rule ................................................................................................... 135

Appendix C: Detailed Data Tables................................................................................. 138
1

Purpose of this Supplemental Regulatory Impact Analysis (RIA)

On December 21, 2011, the Federal Aviation Administration (FAA) issued a final rule 

that was published in the Federal Register as Flight Crew Member Duty and Rest Requirements

on January 4, 2011 (77 Fed. Reg. 330-01). The regulations, which are limited to passenger 

operations conducted under 14 CFR 121 (Part 121), become effective on January 4, 2014. On 

December 21, 2011, the FAA also issued a Regulatory Impact Analysis (original RIA) dated 

November 18, 2011 (FAA-2009-1093-2477). The original RIA provides the basis for the FAA’s 

decision to (1) promulgate the final rule establishing new flight, duty and rest requirements for 

flight crews in passenger operations; and (2) exclude flight crews in cargo-only operations from 

the new mandatory requirements. While cargo-only operations are not required to meet the new 

regulations, the rule permits these operators to opt in to the rule if they so choose.

On December 22, 2011 the Independent Pilots Association (IPA) filed a timely petition 

for review. During the course of reviewing the administrative record for the purpose of preparing 

the government’s brief, the FAA discovered errors in the original RIA that supports the final 

rule. The errors were associated with the scope of costs related to the implementation of the 

regulations for cargo-only operations. These errors appeared to be of a sufficient amount that the 

FAA concluded it was prudent to review the portion of the cost-benefit analysis related to cargoonly operations and allow interested parties an opportunity to comment on the corrected analysis.

On May 17, 2012, the FAA asked the United States Court of Appeals for the District of 

Columbia Circuit to suspend the litigation of the final rule while the agency corrected the 

inadvertent errors it had discovered. The court granted the FAA’s motion on June 8, 2012. While 

the passenger operations rule is not at issue in the court proceedings, the FAA, in an abundance 

of caution, decided to have that portion of the original RIA reevaluated as well.
2

The FAA contracted with the John A. Volpe National Transportation Systems Center to 

review the original RIA for accuracy, correct any errors identified, and prepare a supplemental 

regulatory evaluation laying out the revised analysis. This Initial Supplemental RIA is the 

product of that review.

While this Initial Supplemental RIA largely mirrors the original RIA in both content and 

organizational structure, it provides more detail on the potential impacts the final rule would 

have on both passenger and cargo-only operations. In addition, this Initial Supplemental RIA 

provides expanded discussion of the methodology and information sources used in the analysis, 

corrects some reporting of results and minor calculation errors present in the original RIA, and 

presents sensitivity analysis on key assumptions used in the analysis.

1 A new Appendix B 

contains the results of those sensitivity analyses while Appendix C contains detailed data tables, 

which are summarized in the body of this Initial Supplemental RIA.

In the original RIA, the portion of scheduling costs related to cargo-only operations of air 

carriers that conduct both passenger and cargo-only operations (mixed operations carriers) were 

inadvertently excluded from the reported costs of extending the final rule to cargo-only 

operations. This Initial Supplemental RIA fixes that omission and that revision has significantly 

increased the estimates of the stated costs of extending the final rule to cargo-only operations. 

Due to inclusion of impacts on cargo-only operations, a few air carriers were reclassified for ease 

of explication. 

This Initial Supplemental RIA does not serve to reevaluate the policy decisions behind 

the FAA’s decision to issue a final rule implementing new flight, duty and rest requirements for 

 

1 Wherever possible, this Initial Supplemental RIA relies on the same data used for the original RIA. In some cases, 

new estimates were developed and more recent data sources were used.
3

Part 121 carriers engaged in carrying passengers. Table 1 and Table 2 summarize the differences 

between the original RIA and the Initial Supplemental RIA.

Table 1: Passenger Operations Nominal Costs and Benefits Over 12 Year Analysis Period

Original RIA

(millions)

Supplemental RIA

(millions) Difference (millions)

Total Benefits - Base Case $376 $401 $25

Total Benefits - High Case $716 $757 $41

Total Costs $390 $457 $67

Table 2: Cargo Operations Nominal Costs and Benefits Over 12 Year Analysis Period

Original RIA

(millions)

Supplemental RIA

(millions)

Difference

(millions)

Total Benefits - Base Case $20.35* $5

Total Benefits - High Case $32.55* $31

Total Costs $306 $550 $244

* FAA did not detail potential benefits to cargo-only operations in the original RIA. Rather, the 

FAA assumed that benefits associated with averting a single catastrophic accident involving a 

cargo plane would range between $20.35 million and $32.55 million.

Disposition of Issues Raised by Comments

The following summarizes the FAA’s responses to the comments on the economic 

analysis. These responses address the most substantive comments made in response to the Notice 

of Proposed Rulemaking (NPRM). They are largely unchanged from the discussion in the 

original RIA. The comments addressed here include those made by Air Transportation 

Association (ATA), American Airlines, United Airlines, Cargo Airline Association (CAA), 

Federal Express, United Parcel Service (UPS), National Air Carriers Association (NACA), Atlas 

Air Worldwide Holdings, Lynden Air Cargo, Omni Air International, Inc., and Southern Air, Inc. 

Commenters questioned the base year dollar and analysis period. The final rule uses 2012 

(the year the final rule was published) as the base year with some preparatory costs incurred 

during the period 2012 through 2013. Recurring costs and the benefits of the final rule are 
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presented for the 10-year period 2014 through 2023. We have provided sensitivity analysis based 

upon a discount rate of both seven percent and three percent. This 12-year analysis period is 

sufficient for the costs and benefits to be in a steady state.

The FAA also received comments questioning the validity of the accident set. To address 

the criticism of using the historical twenty-year analysis period, the FAA narrowed the accident 

set to the most recent ten years. However, while this approach addressed the issues raised by the 

commenters, narrowing of the analysis time period reduces the number of accidents/observations 

available for the benefit analysis. Consequently, while there is a sufficient accident basis to 

demonstrate a broad benefit basis justifying the cost of this rule, the data does not permit 

accident analysis for every industry segment.2 The “high” benefit forecast incorporates 

expectations for larger airplanes and higher load factors in the future. Even though the rate of 

accidents may have declined in the last ten years, the future consequences of an individual crash

may well be more catastrophic.

Commenters questioned that the historical accident rate is significantly higher than the 

probable accident rate for the period of analysis because accidents have declined in recent years. 

The requirements contained in this final rule only address the rates of pilot fatigue. As 

Table 7 shows, the preventable accident rate related to fatigue has not significantly decreased in 

the last 10 years. 

The original RIA also includes a list of appropriate accidents along with the final 

Commercial Aviation Safety Team (CAST) scoring. Appendix A: Relevant Accident History

includes detailed fatigue information and the reasoning behind the final CAST scoring. 

 

2 In this Initial Supplemental RIA, FAA has provided separate benefits estimates of the final rule for passenger 

operations and cargo-only operations.
5

After considering the comments on the original RIA for the NPRM, the FAA took a 

different approach to evaluate the final rule. In the analysis for the NPRM, the FAA attempted to 

show through statistical analysis and simulation that a broader fatigue problem existed than what 

could be shown through National Transportation Safety Board (NTSB) accident findings. In 

response to industry comments objecting to this approach, the FAA Office of Aviation Safety 

began by narrowing the set of accidents to those with a strong correlation to fatigue and hence 

narrowed the benefit analysis from a broader fatigue problem to the specific regulatory changes. 

As a result, the FAA re-examined every accident used in the NPRM and applied the CAST 

methodology only to the accidents whose likelihood would have been reduced if the 

requirements in the final rule had been effective prior to the accident. Using this methodology, 

the FAA re-analyzed the effectiveness of the provisions in the final rule in mitigating accidents 

where fatigue was identified as a factor in the accident, and removed accident cases that were not 

closely correlated with fatigue factors from the NPRM. From this exercise, a smaller set of 

accidents was determined appropriate for further economic analysis of the final rule. With a 

smaller number of accidents, a simulation methodology was no longer appropriate. Instead, the 

FAA used a commonly-used benefit methodology. This methodology is grounded in NTSB 

findings, uses the CAST methodology, and is also transparent and easily reproducible. The 

methodology is discussed in both the original RIA and this Initial Supplemental RIA. 

Industry questioned the use of $12.6 million for a statistical life value. The use of $12.6 

was for a sensitivity test. For the final rule, the FAA uses the $6.2 million as the value of an 

averted fatality as used commonly by the Department of Transportation (DOT). 

Commenters also objected to the FAA’s assumptions regarding the 25 percent costsavings resulting from long-term scheduling optimization in the draft RIA evaluating the NPRM. 
6

For the original RIA, the assumed long-term schedule optimization factor is dropped. Instead,

operations and scheduling costs were analyzed using a crew scheduling optimizer. This different 

approach estimates operations and scheduling costs of the final rule by applying the duty and rest 

time restrictions of the final rule to industry scheduling data using Cygnus, CrewPairing’s (CP) 

crew scheduling optimization model. 3 Cygnus has been used by more than 30 major airlines 

worldwide over the past 40 years and is currently used by a number of carriers.

Commenters also contended that the FAA underestimated the NPRM costs related to 

flight operations in that carriers would be forced to hire new crewmembers and increase flight 

duty periods (FDP).

In this Initial Supplemental RIA, the FAA has re-estimated the costs reflecting final rule 

modifications and used the above-referenced crew scheduling model to better estimate whether 

the rule would force carriers to hire new crewmembers. The use of a crew pairing optimizer

enabled FAA to more accurately model the impacts of the rule on industry crew scheduling costs 

than was possible during NPRM cost analysis. The data in the original RIA included full bid line 

and pairing information for each flightcrew member. Because the crew pairing optimization 

results showed that the final rule resulted in relatively small increases in the number of credit 

hours needed to complete existing flight schedules, FAA determined that certificate holders 

could conduct existing operations under the final rule without hiring additional flightcrew 

 

3 A technical report detailing the Cygnus optimization can be found in the docket. See Summary of Crew Pairings, 

Inc. Economic Analysis of Flightcrew Member Duty and Rest Requirements Rulemaking, GRA Inc., September 2012.
7

members. The optimization also shows that where pilots worked more days in total under the 

final rule, they worked shorter days, thus obviating the need for additional pilots.

4

Commenters did not support the costs related to schedule reliability and argued that they 

were underestimated. One commenter stated the costs would be as high as $9.6 billion. They 

argued that by excluding the cost of schedule buffering required by multiple provisions of the 

NPRM, the FAA omitted the major source of cost to the industry. 

As stated in the preamble to the final rule, the FAA has largely removed schedule 

reliability from this rule. The FAA has instead adopted provisions that limit extensions of the 

FDP and requires reporting of FDP extensions and activities that were not otherwise permitted 

by the provisions of §117.11, §117.19 and §117.29 in the final rule. Under this amendment, costs 

to airline carriers are limited to reporting exceptional activities. As such, these costs are expected 

to be relatively minor. 

Some commenters stated the appropriate average wage rate should be $297 per hour. The 

FAA notes this wage rate significantly contributed to the industry cost estimates. The $297 per 

hour wage rate as an average is almost two times the wage rate from Form 41 narrow-body pilots

and four times the wage rate from the 2010 Census Bureau on the airline industry. 

Commenters also argued that the FAA underestimates fatigue training cost described in

the NPRM.

All carriers already are required to comply with Public Law 111-216 Section 

212(b)(2)(B) with respect to the fatigue risk management plan and training (FRMP). In this final 

rule, the FAA removed the proposed requirement that pilots receive additional fatigue training 

 

4 See Summary of Crew Pairings, Inc. Economic Analysis of Flightcrew Member Duty and Rest Requirements 

Rulemaking, GRA Inc., September 2012.
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that is not required by the FRMP. As such, the FAA expects the cost of fatigue education and 

training to be largely reduced. The final rule does expand the fatigue education and training 

requirements to dispatchers and certain members of management. The FAA made this change 

because air carriers operating under Part 121 will be in compliance with the statutory pilot 

training requirement as part of their FRMPs. Since the final rule extends fatigue training to 

management and dispatchers, it is expected to be added to existing fatigue risk management 

education and training program. 

Numerous commenters stated that the FAA underestimated the cost of rest facilities due 

to the loss of first class seating and out-of-service time required for infrastructure installation.

The FAA re-analyzed the facility cost based upon the actual numbers and types of 

facilities that will need to be put in by querying the inspectors for the fleet of airplanes. The FAA 

assumed the worst case scenario (all Class 1 facilities). The FAA recalculated the number of 

airplanes needing additional upgraded rest facilities. Based on the existing fleet, the FAA 

estimates 225 airplanes used in passenger operations will need Class 1 facilities. In addition, the 

FAA re-estimated compliance costs of optimizing existing equipment and installing first class 

facilities. We have also estimated downtime and additional fuel burn costs. The final rule rest 

facility costs include purchase, design and engineering, physical installation of the facilities on 

the affected aircraft, downtime impact on revenue, and fuel burn cost. Therefore, the cost of rest 

facilities was estimated to the full extent in the final rule.

The commenters stated that the FAA’s cost analysis does not factor in the costs of the 

cumulative limits. The FAA notes that all known constraints including the final rule monthly and 

annual constraints were imbedded in CP optimization. 
9

The commenters submitted that the FAA assumed for the NPRM that the industry’s 

collective bargaining agreements (CBAs) will be renegotiated to permit carriers to adapt to the 

new rules without any additional costs to the carriers and also assumes that any short term costs 

that result from conflicts between the new rule and existing CBAs should not be “counted” as 

part of the NPRM. 

The final rule does not require renegotiation of current CBAs. In the final rule the FAA 

did not calculate potential gains based on the renegotiation of CBAs. The final rule will give a 

two-year buffer for carriers to implement all provisions. The FAA still believes that CBA 

negotiations could result in a change of economic interests between carriers and crewmembers. 

Any such change is a transfer of benefits and costs between carriers and bargaining units. Such 

transfers would be negotiated between parties and transfers do not change the total cost and 

benefits to society.

Many entities conducting supplemental operations stated that the rule would cause the

nature of their operations to significantly change, which would result in lost revenue 

opportunities or much higher cost, or both.

The FAA adopted significant modifications in the final rule to mitigate the impact on 

supplemental operations. For example, in the final rule, the FAA made compliance with Part 117 

voluntary for cargo-only operations. With regard to supplemental passenger operations, the FAA 

increased both the augmented and unaugmented FDP limits from the NPRM. The FAA also 

increased the split-duty credit and made that credit easier to obtain. In addition, the FAA notes 

that section 119.55 provides the mechanism to obtain deviation from existing regulations for 

military missions. Taken together the FAA has provided substantial flexibility for supplemental 
10

operations, and as a result, permits most existing revenue opportunities relative to flight safety 

risks based on the past ten years of NTSB accident findings.

The commenters contend that the FAA assumes, without any evidence, that there will be

a reduction in absenteeism due to “improved fatigue management,” and that reduced absenteeism 

costs will offset part of the cost of the NPRM.

The FAA believes that the final rule will improve productivity and reduce absenteeism by 

the enhanced fatigue management system. Center for Disease Control (CDC) research shows that 

chronic fatigue can cause illness and even death.5 Comments and data received from Air Line 

Pilots Association (ALPA), the largest independent pilots’ union in the world, devoting more 

than 20 percent of its dues income to support aviation safety, validated the FAA’s estimation of 

cost saving from reducing flightcrew members fatigue and absenteeism. 

Commenters questioned that there is no justification provided that sick leave use will be 

reduced by five percent.

The FAA notes that a study in the railroad industry found that fatigue counter measures 

reduced absenteeism from 4.79 percent to 1.94 percent, a decrease of 40 percent.6 In addition, 

this Initial Supplemental RIA provides a sensitivity analysis on this assumption which can be 

found in Appendix B.

Commenters contended that accidents involving two pilots and a flight engineer should 

be analyzed separately because in the modern era almost all flights are operated without a flight 

engineer. 

 

5 CDC’ s MMWR, Weekly, February 29, 2008 / 57(08);200-203 6 Sherry, “Fatigue Countermeasures in the Railroad Industry: Past and Current Developments,” Association of 

American Railroads, 2000.
11

This rule does not distinguish between accidents involving a flight engineer and accidents 

without a flight engineer because it is difficult to attribute specific amounts of fatigue and 

accident causality to a flight engineer. More specifically, it is difficult to predict in a fatiguerelated accident, how the two pilots would have handled the aircraft in question if a flight 

engineer had not been present. As such, because it is unclear how much flight-engineer fatigue 

contributed to past accidents and that this rule does not prohibit flight engineers from working on 

the flight deck, the original RIA used for this rule does not distinguish between accidents 

involving two pilots and those involving a flight engineer.

Some commenters stated that the FAA simply ignores flight cancellation costs despite the 

fact that of the NPRM will result in substantial increases in flight cancellations.

As discussed above, the FAA calculated the scheduling costs of this rule by running the 

pertinent data through the Cygnus crew scheduling optimization model. The Cygnus model did 

not indicate that there would be an increase in cancellations as a result of the changes imposed 

by this rule. This is because certificate holders will be able to use their existing staff members to 

cover the scheduled flights.

It was argued by commenters that by excluding the cost of schedule buffering required by 

multiple provisions of the NPRM, the FAA has omitted the major source of cost to the industry.

There are a few major changes related to crew scheduling made in the final rule from the

NPRM, which significantly reduced the cost to the industry. The pertinent changes from the 

NPRM are: (1) a flight extension for unexpected circumstances that arise after takeoff, and (2) 

the removal of the requirement that “circumstances beyond the control of the certificate holder” 

have to be present in order to utilize the 2-hour FDP extension for certain unforeseen operational 

circumstances. Using the crew pairing optimizer to simulate operation schedule, costs that are
12

attributable to the final rule were estimated to the full extent, including the cost of schedule 

buffering. The schedule optimization included buffers on flight and FDP limits to account for 

operational delays.

The commenters further stated that the FAA has omitted the cost estimation attributable 

to the provision of “three consecutive nights” (section 117.27, NPRM), which is more likely to 

impact cargo carriers partly because they have a substantial concentration of operations during 

the night time period and flight crew that are accustomed to night time operations. 

As an initial matter, the FAA notes that, based on the cost-benefit analysis, cargo-only

operations are not covered by the final rule. However, based on industry comments the FAA has 

mitigated the burden to cargo operators who may choose to operate under Part 117 by reducing 

(to two hours) the length of “mid-duty rest” that is necessary to schedule five consecutive 

nighttime FDPs. Moreover, UPS and FedEx stated in their comments that they currently provide 

their flightcrew members with a mid-duty breaks that are, on average, two hours long. Because 

the final rule permits five consecutive nights with two-hour breaks, the impact of the 

consecutive-night provision on cargo-only operators such as UPS and FedEx will be minimal

should they choose to operate under Part 117. The consecutive nights rule is included in CP 

optimization.

The commenters also argued that, under the FAA’s cost-benefit methodology, there is no 

benefit to limiting duty time below 15 hours.

The FAA agrees the risk of accident prevalence in the 15th hour block and beyond is 

much greater than that associated with duty times short of the 15th hour block. To evaluate this 

proposition, the FAA computed ratios of accidents to exposure duty hours (dividing accidents in 

a sequence of flight hour blocks by pilot exposure duty hours), which substantiated the 
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conclusion that accident risk steeply increases in the 15th hour block and beyond. However, the 

FAA has also determined that FDPs of less than 15 hours can lead to unacceptably high accident 

risk. For example, the statistical evidence indicates that the ratio of accidents to block hours rises 

at a fast rate in the 13th to 14th hour block range. Therefore, the regulation of flight duty time 

being limited under the 15th hour block is necessary and beneficial.

Allied Pilots Association (APA) generally supported the NPRM but stated that the FAA 

overestimated computer programming cost, fatigue training costs due to overstated training, pay 

and rest facility installation costs. In addition, APA commented that the FAA underestimated the 

schedule optimization factor and the agility of air carriers when motivated to achieve efficiency.

The computer programing cost is a very small component of airline operation cost. 

Overall, the operation cost in the final rule was revised and turned out to be lower than that of 

NPRM. The fatigue training cost was revised to be lower than that of NPRM because of the 

changes made to the proposed fatigue training requirements by the final rule. The revised rest 

facility installation cost was also lower than that of the NPRM. APA’s comment on the 

overestimation of the NPRM cost was based on the assumption that long-term optimization will 

occur at a much faster rate than implicit in the cost analysis, which would result in more savings 

in the long run than in the short run. The FAA agrees that long-term optimization of air carriers 

could be greater than expected. The FAA believes that the crew scheduling optimizer program 

provides a better estimate to the final rule. Therefore, the FAA believes that the final rule cost 

estimates incorporating crew scheduling optimization model accurately reflect the compliance 

costs. 

ATA's Oliver Wyman analysis on September 14, 2011, “Estimated Job Loss Resulting 

from Flightcrew Member Duty and Rest Requirements” attached to the ATA petition on Flight, 
14

Duty and Rest asserted that the proposed rule would cause the loss of nearly 17,000 U.S. airline 

jobs, which would result in total job losses to the economy of 398,000 jobs.

The FAA believes that ATA’s analysis of the jobs impact from the proposed Flightcrew 

Member Duty and Rest Rule is inaccurate. ATA’s jobs impact analysis is based on its estimate, 

derived from its analysis of the NPRM, that this rule will cost $19.6 billion over a 12-year 

period. However, many of the major provisions of the final rule have been significantly altered 

from the NPRM, and, as discussed elsewhere, the FAA estimates that the final rule will cost 

approximately $457 million in nominal terms over 12 years. This $457 million cost is 

significantly smaller than the $19.6 billion cost on which ATA based its job impact analysis. 

CrewPairing’s analysis of the final rule results in no change in pilot employment. Therefore, the 

FAA does not agree with ATA’s job impact findings.

With regard to the accidents that were used to calculate the benefits for this rule, some 

commenters stated that the ATI 2/16/95 flight (RT2) was a Part 91 ferry flight, and that the 

issues leading to that flight’s accident have been addressed by other rulemakings. Consequently, 

the commenters assert, this flight would not be permitted under current rules.

This comment refers to an accident involving ATI in Kansas City during a nighttime Part 

91 engine-out ferry flight in a 4-engine DC-8. Prior to takeoff, the flight engineer had improperly 

determined the minimum control speed on the ground (VMCG), which produced a value that 

was 9 knots too low. On the first takeoff attempt, the pilot applied power too soon to the 

“asymmetrical engine” (the serviceable engine on the side with the failed engine) and was unable 

to maintain directional control during the takeoff roll. He rejected the takeoff and, in preparation 

for a second takeoff, the pilot agreed to have the flight engineer advance the throttle on the next 

takeoff attempt. This conflicted with the prescribed procedure. 
15

At 3,215 feet into the takeoff roll, the DC-8 started to veer to the left. At 3,806 feet, the 

aircraft rotated with a tail strike but the tail remained in contact with the runway for another 820 

feet. At 5,250 feet, the aircraft became airborne and climbed to 100 feet, then sank and crashed. 

All three crew members were killed.

NTSB focused on two core issues. First, NTSB found that the crew was flying after a 

shortened rest break, since rest periods were not required for ferry flights. According to the 

report, the crew was fatigued from lack of rest and lack of sleep, and from disrupted circadian 

rhythms. Second, NTSB found that the crew did not have adequate, realistic training in 

techniques or procedures for a 3-engine takeoff. NTSB added that the crew did not adequately 

understand 3-engine takeoff, and did not adequately understand the significance of VMCG.

In response to an NTSB recommendation related to training crews for a 3-engine takeoff 

(A-95-39), FAA issued a Flight Standards Information Bulletin (FSIB). The FSIB directed FAA 

principal operations inspectors to inform their respective operators to take additional measures to 

ensure: (1) that aircraft manual requirements for engine-out ferry flights are clear; (2) that crew 

training segments are clearly outlined for engine-out operations; and (3) that operators use only 

crews specifically trained and certified for engine-out operations. This has become FAA policy 

and NTSB found the action acceptable and closed the recommendation.

Consequently, the comment is appropriate to the degree that it addresses the issue of 

training, which is not part of the proposed rule. However, FAA believes that this flight also 

illustrates the role and risks associated with fatigue, which the FSIB noted above did not address. 

With or without training in three-engine takeoffs, NTSB’s findings on fatigue in this accident 

remain pertinent to this rulemaking.
16

Benefit/Cost Summary

In this Initial Supplemental RIA, we have analyzed the benefits and the costs associated 

with the requirements contained in this final rule and our estimates are summarized in Table 3

and Table 4.

The final rule was changed significantly from the NPRM. The training requirement had

been substantially reduced because the FAA has determined that pilots are already receiving the 

requisite training as part of the statutorily required Fatigue Risk Management Plans. The FAA 

also removed cargo-only operations from the applicability section of the new Part 117 because 

their estimated compliance costs as shown in the original RIA significantly exceed the quantified 

societal benefits.7 This Initial Supplemental RIA revises and corrects the calculations used to 

estimate the costs and benefits of the final rule as it applies to passenger operations and to the 

estimates of costs and benefits if the rule were extended to cargo-only operations.

The costs associated with computer programing and rest facilities occur in the two years 

after the rule is published. The other costs of the rule and the benefits are then estimated over the 

next ten years.

We provide a range of estimates for the quantitative benefits of the final rule as it applies 

to passenger operations. Our base case estimate is $401 million ($263 million present value at 

seven percent and $332 million at three percent) and our high case estimate is $757 million 

($497 million present value at seven percent and $627 million at three percent). The total 

estimated cost of the final rule as it applies to passenger operations is $457 million ($338 million

 

7 Carriers may choose to have their cargo-only operations comply with the new Part 117 but are not required to do 

so. Since the carrier would decide voluntarily to comply with the new requirements, those costs are not attributed 

to the costs of this rule.
17

present value at seven percent and $398 million at three percent). Therefore, the costs of the final 

rule are somewhat higher than the base case benefits estimate but well below the high case 

estimate.

If the final rule were extended to cover cargo-only operations, the base case estimate of 

benefits for that population is $5 million ($3 million present value at seven percent and $4

million at three percent) and our high case estimate is $31 million ($21 million present value at 

seven percent and $26 million at three percent). In comparison total estimated cost of the final 

rule for that same population if it were extended to cargo-only operations is estimated to be $550

million ($377 million present value at seven percent and $464 million at three percent). This cost 

estimate far exceeds both the base and high case estimates of benefits.

Table 3: Summary of Benefits and Costs, Passenger Operations

Estimates

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Total Benefits - Base Case $401 $263 $332

Total Benefits - High Case $757 $497 $627

Total Costs $457 $338 $398

Net Benefits - Base Case -$56 -$75 -$66

Net Benefits - High Case $301 $159 $229
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Table 4: Summary of Benefits and Costs, Cargo-only Operations

Estimates

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Total Benefits - Base Case $5 $3 $4

Total Benefits - High Case $31 $21 $26

Total Costs $550 $377 $464

Net Benefits - Base Case -$545 -$374 -$459

Net Benefits - High Case -$519 -$357 -$438

Benefit Analysis

This rule is intended to address the problem of fatigued pilots flying in Part 121 

commercial service. The nature and extent of the problem is such that the NTSB continues to list 

pilot fatigue as one of the Most Wanted Transportation Safety Improvements. The NTSB 

recommendations are based on accident investigations and the NTSB safety study on airline 

safety. The requirements contained in this final rule address both NTSB recommendations and 

existing public law. This benefit estimate first examines the nature of fatigue, followed by its

causes and how it relates to transportation. Second, we summarize some recent findings on 

fatigue and occupational performance. Next, we look at the magnitude of flightcrew fatigue in 

Part 121 passenger operations by briefly examining fatigue reports in the context of this final 

rule. We then re-analyze the likely effectiveness of the requirements contained in this final rule

and the potential to decrease these types of accidents in the future. We project a likely number of 

preventable events that will occur in absence of this final rule. Finally, we estimate the benefits 

that will be derived from preventing such events. We provide a base case estimate, and a high

case estimate, in addition to a threshold/break even analysis. The Initial Supplemental RIA also 
19

presents both base and high case estimates of the benefits if the final rule were extended to 

cargo-only operations.

The Nature of Fatigue

Most fatigue studies agree that, “fatigue refers to a subjective desire to rest and an 

aversion to further work, coupled with an objective decrease in performance.”8

Fatigue is characterized by: 

• “increasingly frequent lapses in performance, 

• general cognitive slowing, including a lowering of optimum performance,

• memory problems,

• time on task decrements, and

• an increasing inability to maintain the vigilance required to perform the tasks required.”9

Fatigue has been described as “a nonspecific symptom because it can be indicative of 

many causes or conditions including physiological states such as sleep deprivation....[s]ome 

describe fatigue in terms of physiological data or ‘objective’ observations of...decrements in 

work or performance....or time-related deterioration in the ability to perform certain mental 

tasks.”10 While physiological criteria related to fatigue can be readily measureable, subjective 

feelings of fatigue are not directly observable, and in some instances individuals who are 

 

8 Jones, et al., “Working hours regulations and fatigue in transportation: A comparative analysis,” Safety Science, 

Vol. 43, 2005.

9 Ibid.

10 Torres-Harding, Susan and Leonard A. Jason, “What is Fatigue? History and Epidemiology,” Fatigue as a Window 

to the Brain, edited by John DeLuca. The MIT Press, 3-18, 2007.
20

exhibiting diminished performance levels also feel confident in their ability to focus and perform 

assigned tasks.

Causes of Fatigue

A number of factors increase the risk of fatigue.

• Time of day is very important, because the body follows a rhythm over an approximately 

24-hour period, often referred to as a circadian cycle.

• The amount of recent sleep that a person has received also affects the level of fatigue 

risk; most people need an average of eight hours of sleep per 24 hour period. 

• The number of continuous hours awake also increases fatigue risk, and for most 

individuals, once the number of continuous hours awake exceeds 17, fatigue risk 

increases significantly. 

• Sleep debt, the difference between the amount of sleep needed to be fully rested and 

actual sleep, also contributes to fatigue. Sleep debt accumulates over time, and fatigue 

risk is higher if sleep debt exceeds eight hours.

• Work load and time on task can also affect fatigue risk. If work intensity is high and/or 

there is a long continuous period of time on task, the risk of fatigue increases.

Fatigue and Transportation

The nature of work in the transportation sector makes that sector especially susceptible to 

risks to performance, vigilance and response to hazards that are associated with fatigue. 

Workdays of those responsible for the safety of transportation operations can be characterized by 

long work periods, often at nighttime or early morning hours. Because transportation workers 
21

must sometimes rest or sleep away from home, conditions for rest and sleep quality are also 

important.

Analysts have examined the links between the specific features of work in the 

transportation industry, including commercial aviation, and the general features of human 

physiology and fatigue for decades. For commercial aviation, it has been nearly two decades 

since the first citation of fatigue as a probable cause for a major aviation accident. This accident, 

the crash of American International Airways flight 808 at Guantanamo Naval Air Station, Cuba, 

on August 18, 1993, was investigated by the NTSB. Probable causes of the accident identified by 

the NTSB included “the impaired judgment, decision making, and flying abilities of the captain 

and flightcrew due to the effects of fatigue...” 

As part of the investigation of that accident, NASA researchers and contractors 

performed an analysis of the links between aviation risks and the effects of fatigue on human 

vigilance and performance. This research was reported as part of the NTSB report on the 

Guantanamo Bay accident and the research was later revised for inclusion in an NTSB report on 

DOT efforts to address fatigue issues in transportation.11

This NTSB research and literature summary provides a thorough and well-documented 

review of these issues. In the 1999 restatement of the research results in the context of addressing 

fatigue issues in transportation generally, the following summary is provided:

Fatigue, sleep loss and circadian disruption created by transportation 

operations can degrade performance, alertness and safety. An extensive scientific 

 

11 Rosekind, et.al., “Appendix C: Summary of Sleep and Circadian Rhythms,” Evaluation of U.S. Department of 

Transportation Efforts in the 1990s to Address Operator Fatigue. Washington D.C. NTSB Safety Report NTSB/SR99/01, May 1999, pp.67-81. http://www3.ntsb.gov/publictn/1999/sr9901.pdf
22

literature exists that provides important physiological information about the 

human operator, which can be used to guide operations and policy. For example, 

there are human physiological requirements for sleep, predictable effects of sleep 

loss on performance and alertness and patterns for recovery from sleep loss. 

Additionally, the circadian clock is a powerful modulator of human performance 

and alertness, and in transportation operations, it can be disrupted by night work, 

time zone changes, and day/night duty shifts. Scientific examination of these 

physiological considerations has documented a direct relationship to errors, 

accidents and safety. This scientific information can provide important input to 

policy and regulatory considerations.

Recent Findings on Fatigue and Occupational Performance 

Fatigue is prevalent in the U.S. workforce, with nearly 38 percent of workers reporting 

fatigue during a two-week period.12 The National Sleep Foundation conducted a poll in 2008, 

which found that 29 percent have fallen asleep or become very sleepy while at work and two 

percent did not go to work due to sleepiness or a sleep problem.13 Numerous studies have found 

that fatigue can significantly reduce productivity. A review of published studies on shift work 

and productivity found a large decrease in efficiency during the night shift, with the low 

occurring at 3:00 am. On average, the authors found that productivity was five percent lower at 

night.14

 

12 Ricci, et al., “Fatigue in the U.S. workforce: prevalence, and implications for lost productive work time,” Occup 

Environ Med, Vol. 49(1): 1-10, 2007. 13 National Sleep Foundation, “2008 Sleep in America Poll: Summary of Findings.” 14 Folkard and Tucker, “Shift work, safety and productivity,” Occupational Medicine, Vol. 53, 2003.
23

A large-scale study was conducted at 40 companies and institutions in the Netherlands to 

investigate the relationship between fatigue and future sickness absence. The presence of fatigue 

was measured using self-reported symptoms, with employers providing absence data. The study 

controlled for numerous sociodemographic and work characteristics. The investigators found that 

higher levels of fatigue were statistically significant predictors of both short-term and long-term 

sickness absence.15

A study was conducted to estimate fatigue prevalence and associated health-related lost 

productive time (LPT) in U.S. workers. The investigators found that workers with fatigue were 

much more likely to report health-related LPT, with a cost of $136.4 billion annually. This 

amount exceeded health-related LPT reported by workers without fatigue by $101.0 billion.

A study compared the rate of errors made by medical residents working in the ICU on 80-

hour weeks versus those on 63 hour weeks. The residents with the shorter work week schedule 

experienced half the rate of attention failures. The residents with the longer work week schedule 

made serious medical errors (those causing or having the potential to cause harm to a patient) at 

a rate 22 percent higher than the residents with the shorter work week schedule.16

The railroad industry is at a relatively high risk of fatigue, due to typical 24-hour per day 

operations. A number of railroads have implemented fatigue countermeasures, which generally 

reduced absenteeism. For instance, after implementation of fatigue countermeasures for 

CANALERT, absenteeism decreased from 8.1 to 3.2 percent. After fatigue countermeasures 

were implemented for the Conrail-Buffalo-Toledo IMPAC project, a statistically significant 

 

15 Janssen, et al., “Fatigue as a predictor of sickness absence: results from the Maastricht cohort study on fatigue at 

work,” Occup Environ Med, 2003, 60(Suppl I): i71-i76. 16 Board on Health Sciences Policy, “Sleep Disorders and Sleep Deprivation: An Unmet Public Health Problem,” The 

National Academies Press, 2006.
24

increase in attendance from 95.21 percent to 98.06 percent was observed.17 This data 

demonstrates the potential for fatigue issues, which we will now examine within the specific 

requirements of this final rule. 

Aviation Safety Reporting System (ASRS) 

One can observe fatigue in aviation by examining the Aviation Safety Reporting System 

(ASRS). The ASRS collects, analyzes, and responds to voluntarily submitted aviation safety 

incident reports in order to lessen the likelihood of aviation accidents. It is part of a continuing 

effort by government, industry, and individuals to maintain and improve aviation safety by 

collecting voluntarily submitted aviation safety incident/situation reports from pilots, controllers, 

and others. The data in the ASRS is used to:

• Identify deficiencies and discrepancies in the National Aviation System (NAS) so that 

these can be remedied by appropriate authorities.

• Support policy formulation and planning for, and improvements to, the NAS.

• Strengthen the foundation of aviation human factors safety research. This is particularly 

important since it is generally conceded that over two-thirds of all aviation accidents and 

incidents have their roots in human performance errors.

ASRS assures confidentiality and data cannot be traced back to individual operators. So 

although we cannot claim the rule could prevent any specific ASRS events, it is a useful tool in 

evaluating and validating the presence of fatigue in Part 121 operations. We performed a query 

 

17 Sherry, “Fatigue Countermeasures in the Railroad Industry: Past and Current Developments,” Association of 

American Railroads, 2000.
25

for Part 121 ASRS for fatigue.

18 Since June of 2009, there were a total of 256 reports where 

fatigue was cited as a factor. We have neither culled the data nor edited any of the data that was

reported to ASRS. The top seven results are listed in Table 5. 

Table 5: ASRS Part 121 Fatigue Reports

Result Total Relative %

General None Reported / Taken (No action was taken as a result of the 

fatigue issue reported)

68 26.6%

General Work Refused (Fatigue caused a worker to refuse an 21 8.2%

General Maintenance Action (Typically a fatigue event related to a 

maintenance issue—not related to this final rule).

14 5.5%

Flight Crew Became Reoriented (Confusion related to some type of 

malfunction.)

10 3.9%

Flight Crew Took Evasive Action (Crew took action to avoid an accident 

or incident)

8 3.1%

Air Traffic Control Issued New Clearance (Substitute clearance given to 

get back on track)

5 2.0%

Flight Crew Executed Go Around / Missed Approach 5 2.0%

One captain on an international flight described an onerous flight sequence in the Pacific 

he believed to be unsafe due to cumulative and predictable fatigue:

This report concerns a trans-Pacific flight assignment including back to 

back all night pairings (body clock), two un-augmented inter-Asia segments and 

36 hours of flight time. We started the sequence with a 12.7 hour actual flight, 

single augmented with an hour plus delay on the front end. When we arrived we 

 

18 We believe that this is a very conservative approach because other human factors can reveal fatigue, such as 

confusion and communications breakdown. 19 Reason, James. “Human Error,” Cambridge University Press, 1990.
26

cabbed to downtown for an additional 1.5 hours on the body before rest. The first 

internal Asia leg is all night, un-augmented. The return leg is daylight-but all 

night body time-followed by another 1.5 hour cab ride downtown. The 

[opportunities for] rest were insufficient to maintain any alertness particularly on 

the last leg. Both the First Officer and I experienced periods of unintended sleep 

while at the controls. No amount of coffee or mental discipline was sufficient to 

stay awake!!! This is unsafe and made more unsafe by requiring: 1. Over 12 

hours single augmented on the first leg. 2. Two un-augmented legs on the back 

side of the clock with long preflight awake hours. 3. Over 8 extra hours of "duty 

time" in CABS!!! Rework this trip before someone gets hurt. No one in the cockpit 

for the last 6 hours was at their peak to respond to irregular situations. We 

weren't even able to stay awake the whole time in the seat.

Even if no anomalies occur during a flight, a fatigued crew may be poorer problem 

solvers than well-rested crews as noted in the research cited above, and thus add a degree of risk 

to the system. In addition, taking evasive action and missed approaches because of fatigue are 

serious safety events indicating substantial risk manifesting in the current system.

Effectiveness of Final Rule

It is usually the case that multiple factors can be identified as causes of specific accidents, 

and it is seldom the case that a specific rule is 100 percent effective at addressing a variety of 

accident causal factors. In particular, fatigue is rarely a primary or sole cause of an accident, and 

therefore this final rule will not likely prevent all future fatigue related accidents. For this final 

regulatory evaluation, we have established a modified effectiveness ratio to categorize accidents 

for which fatigue may be a contributing causal factor. This number represents the likelihood the 
27

requirements contained in this final rule would have prevented an accident from occurring. It is 

applied in the calculation of the number of forecasted fatigue accidents, if no action was taken to 

address the fatigue problem in Part 121 operations.

In its analysis of the effectiveness of the final rule, the FAA reviewed accidents that 

could have been prevented or could have been influenced by the requirements contained in this 

final rule. The effectiveness analysis works by assessing the likely capability of the requirements 

contained in the final rule to have prevented those accidents. As part of this analysis, the FAA

Office of Accident Investigation reviewed the accident reports from NTSB and foreign 

investigative authorities on all accidents where the NTSB cited fatigue or fatigue was thought to 

be either a cause or factor. This was done in order to assess the likelihood that the provisions of 

the final rule would have averted those accidents (including positioning flights operating under 

Part 91). 

A consistent definition was applied to the 20-year history as the requirements of the rule 

apply to all Part 121 operations. As such, we reviewed the accident history for all operations that 

would currently operate under Part 121. The final analysis takes into account NTSB findings, 

FAA’s independent assessment, and comments to the docket. Some accidents reviewed scored 

“zero” because fatigue could not be established as a significant factor or because the final rule

would not prevent such an event had the requirements been in place today. These accidents were 

removed from our effectiveness analysis and forecast. This discussion focuses on incidents 

involving passenger operations, because this final rule does not mandate compliance with Part 

117 for cargo-only operations. However, this Initial Supplemental RIA provides estimates of 

both base and high case benefits if the final rule were extended to cargo-only operations which 

are based on the same methodology discussed here for passenger operations.
28

Each accident was then re-evaluated by conducting a scoring process similar to that 

conducted by the Commercial Aviation Safety Team (CAST), a well-documented and well 

understood procedure, similar to the NPRM. The FAA Office of Accident Investigation used the 

NTSB recommendations along with narratives, probable cause, contributing factors and other 

pertinent data to score the accidents. When these accidents were not well defined in the probable 

cause or contributing factors statements of the NTSB reports, Accident Investigation used a Joint 

Implementation Monitoring Data Analysis Team (JIMDAT)-like method. The JIMDAT-type 

scoring system is from zero to five, and the score is based on the likelihood that a proposed 

action would have mitigated that accident. The level and percentage of effectiveness criteria are 

detailed in Table 6. 

Table 6: JIMDAT - Type Scoring System

5 90% effectiveness. The proposed requirement directly addresses the NTSB causal factors 

and would very likely prevent the accident in the future.

4

75% effectiveness. The proposed requirement directly addresses the majority of the 

NTSB causal factors and would probably prevent or is likely to reduce the risk of the 

respective accident, given the circumstances that prevailed.

3

50 % effectiveness. The proposed requirement directly addresses one of several NTSB 

causal factors and is likely to reduce the risk of the respective accident, given the 

circumstances that prevailed.

2

35% effectiveness. The proposed requirement generally addresses the NTSB causal 

factors and is likely to reduce the risk of the respective accident, given the circumstances 

that prevailed.

1 15% effectiveness. The proposed requirement is likely to have reduced the risk of the 

respective accident, given the circumstances that prevailed.

0 0% effectiveness. The proposed requirement would not reduce the risk of this type of 

accident in the future.

FAA applied this methodology to each pilot fatigue accident to reach an overall 

effectiveness ratio for the requirements contained in this final rule. The qualitative assessments 

ranged from zero (0) to very low (1), low (2), moderate (3), high (4), and very high (5). The 
29

qualitative assessments then were converted to quantitative effectiveness scores as follows: zero; 

15%; 35%; 50%; 75%; and 90%. 

For both the original RIA and this Initial Supplemental RIA, the FAA presents the 

quantified benefits and effectiveness analysis for a 10-year period. Although we only forecast ten 

years of benefits, we have included a 20-year history of accidents involving passenger 

operations, as these are the circumstances and events which have led to this final rulemaking.

Table 7 summarizes the past 20 years of pilot fatigue accidents. Appendix A contains a summary 

of each accident and the corresponding effectiveness analyses. 
30

Table 7: 20-Year Accident History

Date Location Service Carrier A/C On 

Bd Ftl Ser Damage

Scenario Score

02/17/1991 Cleveland, 

OH 121 Cargo Ryan International

DC-9-15 2 2 0 Dest

LOC Climb-out; 

Icing

0.5

08/18/1993 GTMO, Cuba 121 Cargo Konnie Kallita DC-8 3 0 3 Dest Landed Short 0.9

07/02/1994 Charlotte, 

NC

121 Pax US Air MD-82 57 37 16 Dest

LOC on 

Approach; Icing

0.15

02/16/1995 Kansas City, 

MO Ferry ATI DC-8-63 3 3 0 Dest LOC in RTO; Engine Out

0.9

12/20/1995 Cali, 

Colombia

121 Pax American B757 164 160 4 Dest CFIT High 0.35

08/25/1996 JFK, NY 121 Pax TWA L1011 262 0 0 Sub

Tail Strike 

Landing

0.35

01/22/1999 Hyannis, MA Positioning Colgan Air 

(Part 91)

BE-1900 4 0 0 Dest Hard Landing 

(BETA)

0.15

05/08/1999 JFK, NY 121 Pax American Eagle SF34 30 0 1 Sub RE Landing 0.5

06/01/1999 Little Rock, 

AR

121 Pax American MD-82 145 11 45 Dest RE Landing 0.15

07/26/2002 Tallahassee, 

FL 121 Cargo FedEx

B727-

200

3 0 3 Dest

CFIT Low on 

Approach

0.75

10/19/2004 Kirksville, 

MO

121 Pax

Corporate 

Airlines as 

American 

Connexion

BAE-32 15 13 2 Dest

CFIT Low on 

Approach

0.75

08/27/2006 Lexington, 

KY

121 Pax

Comair as 

Delta 

Connection

CRJ-200 50 49 1 Dest Wrong Runway 

T/O 0.35

02/18/2007 Cleveland, 

OH

121 Pax

Shuttle 

America as 

Delta 

Connection

ERJ-170 74 0 0 Sub RE Landing 0.5

04/12/2007 Traverse 

City, MI

121 Pax

Pinnacle as NW 

Express

CRJ-200 52 0 0 Sub RE Landing 0.9

06/20/2007 Laramie, WY 121 Pax Great Lakes BE-1900 11 0 0 Sub

LOC Bounced 

Landing

0.15

02/12/2009 Buffalo 121 Pax Colgan Air

DHC-8-

Q400

49 50 0 Dest LOC In Flight; RE 

Landing

0.5

Passenger Average 52.5%
31

James Reason characterizes major accidents and catastrophic system failures as the 

consequences of multiple, smaller failures that lead up to the actual accident. It is a “Swiss

cheese” model of human error and also a sequential theory of accident causation.19 Reason’s 

model describes four levels of human failure, each one influencing the next. Organizational 

influences lead to instances of unsafe supervision which in turn lead to preconditions for unsafe 

acts and ultimately the unsafe acts of operators. The unsafe acts of operators are where most 

accident investigations are focused. It is a useful framework to illustrate how analyses of major 

accidents and catastrophic systems failures tend to reveal multiple, smaller failures leading up to 

the actual accident. The chances of the exact same circumstances happening again and causing 

the “same accident” are virtually nil but the possibility of preventing a similar set of 

circumstances is real. 

This sequential “Swiss cheese” formulation is a very appropriate tool for characterizing 

the circumstances leading up to accidents. The nature of fatigue is such that actions, reactions 

and the thought processes of fatigued crews are more susceptible to the types of cascading errors 

of judgment described in Reason’s model of catastrophic failure. The requirements contained in 

this final rule will decrease pilot fatigue and therefore the accompanying accidents that are 

associated with fatigue. While it is very difficult to accurately attribute all past accidents to one 

or more causes indisputably, we have developed the average effectiveness measure to apply to 

the estimates and recognize that there are additional uncertainties with preventing a future 

fatigue related event. First, we examine an accident that occurred on October 19, 2004:

 

19 Reason, James. “Human Error,” Cambridge University Press, 1990.
32

At about 1937 central daylight time, a Corporate Airlines BAE Systems BAE-J3201, 

struck trees on final approach and crashed short of runway 36 at Kirksville Regional Airport, in 

Kirksville, Missouri. The captain, first officer, and 11 of the 13 passengers were fatally injured, 

and two passengers received serious injuries. The airplane was destroyed by impact and a postimpact fire.20

Research and accident history indicate that fatigue can cause pilots to make risky, 

impulsive decisions, to become fixated on one aspect of a situation, and to react slowly to 

warnings or signs that an approach should be discontinued. Fatigue especially affects decision 

making, and research shows that people who are fatigued become less able to consider options 

and are more likely to become fixated on a course of action or a desired outcome. A fatigued 

pilot might fail to discontinue a flawed approach or might make a risky decision to continue a 

dangerous approach.

The fatigued crew reported for duty at 0514. The accident was near end of 6th sector on a 

'demanding' day. Crew had been on duty 14.5 hours and the pilot in command (PIC) is said to 

have slept poorly night before. The captain was observed resting on a small couch in the 

company crew room; however, the quality of rest the captain obtained during this time could not 

be determined. Company pilots stated that the crew room was a noisy meeting area that was not 

ideal for sleeping. 

 

20 The NTSB evaluated fatigue as a possible factor in this accident and looked at the various circumstances present 

the day of the accident that might have contributed to the pilots’ fatigue. The pilots’ available rest time (from 

about 2100 to 0400) did not correspond favorably with either pilots’ reported usual sleeping hours, resulting in 

much earlier than normal times to go to sleep and awaken. Additionally, the early wakeup call times would have 

been challenging to both pilots because the human body is normally physiologically primed to sleep between 0300 

and 0500. 
33

Additionally, the pilots' high workload during their long day may have increased their 

fatigue. The accident occurred during the sixth flight segment of the day while the pilots were 

performing a non-precision approach in low ceilings and reduced visibility. The pilot 

deficiencies observed in this accident are consistent with fatigue impairment. 

Similarly, although the first officer's junior status with the company may have been an 

issue in his failure to challenge the captain during the approach, he may also have been suffering 

from fatigue; his failure to monitor and react to the captain's deviations from non-precision 

approach procedures was consistent with the degrading effects (slowed reactions and/or tunnel 

vision) of fatigue. 

The NTSB concluded that, on the basis of the less than optimal overnight rest time 

available, the early reporting time for duty, the length of the duty day, the number of flight legs, 

the demanding conditions (non-precision instrument approaches flown manually in conditions of 

low ceilings and reduced visibilities) encountered during the long duty day (and the two previous 

days), it is likely that fatigue contributed to the pilots' degraded performance and decisionmaking.

Another fatigue related accident occurred in Traverse City, Michigan on April 12, 2007. 

The accident occurred well after midnight at the end of a demanding day during which the pilots 

had flown 8.35 hours, made five landings, had been on duty more than 14 hours, and been awake 

more than 16 hours. During the accident flight, the cockpit voice recorder (CVR) recorded 

numerous yawns and comments that indicate that the pilots were fatigued. Additionally, the 

captain made references to being tired at 2332:12, 2341:53, and 0018:43, and the first officer 

stated, “jeez, I’m tired” at 0020:41. Additionally, the pilots’ high workload (flying in inclement 

weather conditions, and in the captain’s case, providing operating experience for the first officer) 
34

during their long day likely increased their fatigue. The aircraft ran off the departure end of the 

runway during snowy conditions. Although there were no injuries among the 49 passengers, the 

aircraft was substantially damaged. 

As we observe a clear accident history and the accompanying science dealing with 

fatigue, it is apparent that fatigue threatens aviation safety by increasing the risk of pilot error 

that could lead to an accident. Fatigue is characterized by a general lack of alertness and 

degradation in mental and physical performance. Fatigue manifests in the aviation context not 

only when pilots fall asleep in the cockpit while cruising, but perhaps more importantly, when 

they are insufficiently alert during take-off and landing. Each flight segment that is flown by a 

flightcrew member includes a takeoff and a landing, which are the most task and safety-intensive 

parts of the flight. A flightcrew member whose FDP consists of a single flight segment only has 

to perform one takeoff and landing, while a flightcrew member whose FDP consists of six flight 

segments will have to perform six sets of takeoffs and landings. Because takeoffs and landings 

are extremely task-intensive, it logically follows that a flightcrew member who has performed 

six sets of takeoffs and landings will be more fatigued than the flightcrew member who has 

performed only one takeoff and landing. Reported fatigue-related events have included 

procedural errors, unstable approaches, lining up with the wrong runway, and landing without 

clearances. As such, a fatigued crew is dangerous no matter what “type” or segment of operation 

is examined and the requirements in this final rule will eliminate the distinctions between various 

operations. 

As we have shown, in an airplane accident, there is a series of errors (both causes and 

factors) that contribute to an accident. Accident scenarios can vary greatly depending on phase of 

flight, the type of operation, phase of flight and size of the airplane. While pilot fatigue can occur 
35

during any stage of flight, takeoff and landing are especially critical times for the crew to exhibit 

good judgment and sound decision making. The airplane is close to the ground and there is little 

room for error during these particular phases of flight. 

Quantified Benefits

In this Initial Supplemental RIA, the FAA provides a range of benefit estimates for both 

passenger operations and cargo-only operations. The base case estimates only look at the 

historical events as an exact mirror for the future. The high case estimate for passenger 

operations assumes that regional carriers will begin flying larger planes. The high case estimate 

for cargo-only operations assumes a catastrophic crash with fatalities, in place of the one historic 

cargo-only crash which resulted in a hull loss and injuries, but no fatalities. We understand that 

future accidents will not be identical to historical accidents, but our approach provides a 

conservative look at the benefits of this rule based on a snapshot of the past. 

Here the FAA provides a quantitative benefit estimate of historical-based accidents (base 

case), and a high case of expected benefits from future averted accidents once this rule is 

promulgated. Generally our benefit analysis begins using past history as an important reference 

from which to begin the benefit analysis. We believe the base case benefit estimate, which is 

based solely on the outcome of past accidents, may be low for passenger operations because 

today passenger load factors and aircraft size are already greater than they were in the past 

decade. On the other hand, we also note that this estimate may not fully take into account 

changes in regulatory requirements that postdate those accidents and that may mitigate the 

projected risk. As such, our base case estimate represents a snapshot of risk. 

Airplane accidents are somewhat random both in terms of airplane size and the number of 

people on board. For these reasons, projections of future fatalities may be based on future risk 
36

exposure, and our projections are typically based on expected distributions around the mean. Our 

typical scenario incorporates increasing airplane size, expected load factors, and a breakeven 

analysis. However, our evaluation of the historical accidents showed a disproportionate risk 

among smaller, regional carriers. Accordingly, as we discuss below, the FAA has decided to base 

its high case estimate of passenger operations benefits on preventing an accident in a regional jet 

airplane.

In response to comments, we have reduced the analysis period from the 20 years 

provided in the proposed regulatory analysis to 10 years here. We received comments disputing 

the use of a 20 year time frame for accidents stating the accident rate has declined over time. 

While noting the wide range of operations over the last 20 years, we shortened the accident 

history to the last 10 years. A reduction in the length of the sample period introduces other 

problems, most importantly with less time there are fewer observations. Observations are 

important, as the nature of aviation accidents is that while they are rare events, very often these 

accidents result in severe, high consequences. 

The FAA Office of Accident Investigation assessed the effectiveness of this rule to 

prevent the six fatigue-related accidents which occurred on passenger-carrying aircraft in a 

recent 10-year period. This office used the CAST methodology to assign a value to how effective 

the rule will be at preventing each accident. On average, we expect this rule would have been 

52.5 percent effective in preventing the types of accidents had it been in effect over the last 10 

years.

Passenger Operations Base Case Estimate

The passenger operations base case estimate only looks at the historical events as a 

specific reference point. In this estimate the exact number of fatalities for each past event is 
37

multiplied by the relative rule effectiveness score to obtain the historical number of deaths that 

would have been averted with the requirements contained in this final rule, had this rule been in 

effect at the time. The base case estimate supposes roughly six deaths will be averted annually. 

Multiplying six annual averted deaths by the $6.2 million value of statistical life equals $37.2

million annually. In addition, had the requirements been in place at the time of these historical 

accidents, $4.0 million in hull damage for each accident would have been averted,21 which 

equals $12 million for ten years or $1.2 million annually. Finally, we use $5.6 million as the

estimated accident investigation cost per accident, which equals $1.7 million annually.

22 This 

estimate is based on the investigation costs of federal agencies and private industries and aircraft 

wreckage removal.

23 When summed over the 10-year period 2014 through 2023, the base case 

estimate is $401 million ($263 million present value at seven percent and $332 million present 

value at three percent). 

 

21 This Initial Supplemental RIA revises the base case estimate of hull value found in the original RIA. This estimate 

of hull damage is derived by averaging the low end estimated value of the aircraft types involved in the ten year 

accident history cited in Table 7 as found in Airliner Price Guide (Summer 2012). Note that three of the six historic 

accidents resulted in destroyed aircraft while the other three resulted in substantial damage. As a result, using 

replacement value of the aircraft as the estimate of the hull damage may overestimate benefits if repairing the 

damaged aircraft was less costly than replacing it after an accident. 22 The inclusion of accident investigation costs as a benefit category is new to this Initial Supplemental RIA; it was 

not included in the original RIA. Rather, the cost associated with accident investigations was added to address a 

specific concern raised by pilots for cargo operators in associated litigation who asserted these costs should have 

been included. Since this cost is reasonably quantifiable, the FAA has determined that it is appropriate to consider 

in this Initial Supplemental RIA. 23 The estimated accident investigation cost was derived from “Economic Values for FAA Investment and

Regulatory Decisions, A Guide,” Oct. 3, 2007 by GRA for the FAA, pp. 8-4 and 8-5 and inflated using the GDP 

deflator. Specifically, the value for a major investigation ($10.5 million in 2011 dollars) was used for the three 

catastrophic crashes and the weighted average for air carriers ($0.6 million in 2011 dollars) was used for the noncatastrophic crashes, resulting in an average cost of $5.6 million in 2011 dollars.
38

Passenger Operations High Case Estimate

Because airplane accidents are relatively rare they are not necessarily representative of 

actual risk, especially with regard to airplane size and the number of people onboard. In addition, 

future conditions will be different than they were when the accident occurred. Thus, the base 

case estimate for passenger operations represents a snapshot of the risk that fatigue introduces in 

the overall operating environment. It considers neither the forecasted increase in load factors nor 

the larger aircraft types. The future preventable events that this rule addresses will not exactly 

mirror the past events because the airplane types, utilization, and seating capacity have changed.

To quantify the expected benefits in the passenger operations high case scenario, we 

narrowed the analysis to three of the six historic accidents which were catastrophic (all onboard 

died). In this case the expected number of preventable catastrophic accidents equals the three 

accidents multiplied by the 52.5 percent effectiveness rate. Thus over a 10-year time period the 

expected number of preventable accidents is 1.575. Using the Poisson distribution there is 

roughly a 20 percent chance for no accident; however, there is also a 47 percent probability of 

two or more accidents. 

While the 20-year accident history has a broader range of catastrophic accidents, in the 

shorter 10-year historical period all the three catastrophic accidents were on regional airplanes. 

We recognize that as regional airplanes are smaller than the ‘typical’ passenger jet, assuming all 

future accidents would be on a regional jet understates the relative risk across the fleet of aircraft 

affected by this rule. It does, however, represent historical accidents and may be somewhat 
39

representative of actual future risk, since the mainline carriers typically have collective 

bargaining agreements that are already largely reflective of the requirements of this rule.24

The B737 and A320 represent typical sized airplanes in the forecast period with an 

expected number of passengers and crew of 123 given a forecasted 143 seat airplane and a load 

factor of 83 percent.25 Even though there was a (relatively large) B757 passenger airplane 

accident in the 20 year history, if one looks at the past 10 years as truly representative of risk, the 

preventable accident would likely be on a regional airplane.

For the high case the FAA backed away from a benefit outcome based on mean fleet, 

flight hours, and occupant numbers because ultimately we were persuaded there was information 

which could not be ignored by the three regional passenger accidents occurring without a 

mainline passenger accident. For this reason, we selected an 88 seat regional jet (like an ERJ175) to be the representative airplane for the high case. This size airplane is also consistent with 

the fact that regional operators are expected to fly somewhat larger airplanes in the future.

The expected benefit from this high case follows a simple methodology for estimating 

and then valuing the expected number of occupants in a prevented accident. With a total of 0.3 

accidents per year over the ten year period multiplied by the 52.5 percent effectiveness rate, the 

analysis assumes 0.1575 average accidents per year. The estimated occupant value for each 

averted accident equals the average number of seats (88) multiplied by the load factor of 77

 

24 It is unusual that collective bargaining agreements would closely mirror regulatory requirements. However, flight 

and duty limitations are unique because they address both safety considerations, which are regulatory in nature, 

and lifestyle considerations, which are properly addressed in collective bargaining agreements. Because of the 

impact of collective bargaining agreements on the number of hours that pilots work, those agreements were 

considered by the FAA in calculating both the costs and benefits of this rule. 25 Table 6 and Table 9, FAA Aerospace Forecasts Fiscal Years 2011-2031
40

percent plus four crew members for a total of 72 averted fatalities.

26 Each of these prevented 

fatalities is multiplied by a $6.2 million value of statistical life. The expected value of a 

preventable accident equals the sum of the averted fatalities at $446.4 million added to the value 

of the airplane hull loss ($24.0 million replacement value),27 and accident investigation costs 

($10.5 million for a major investigation) for a prevented accident benefit of $480.9 million. Over 

a ten year period the value of preventing the expected 1.575 accidents equals approximately 

$757 million ($497 million present value at seven percent and $627 million present value at three

percent).

Cargo-only Operations Base Case Estimate

Just as in the benefit analysis for passenger operations, the cargo-only base case estimate 

uses historical events to determine the preventable accident benefits for the future benefits. There 

was one air cargo accident during the ten-year analysis period, which occurred July 26, 2002. In 

this accident three crewmembers were seriously injured and the hull and cargo were destroyed. 

Thus, the benefit of preventing such an accident in the future consists of averting serious injury 

to three pilots, the value of the hull and the cargo, and the public and private cost of the accident 

investigation. After estimating the value of each benefit, we apply an effectiveness rating of 75

percent to the sum of these benefits.

The value of averting three seriously injured pilots is $1.95 million. This value is based 

on the DOT policy guidance that states the value of a person losing productivity from a “serious” 

 

26 Assumed load factor of 77 percent is based on forecasted load factors for regional carriers found in Table 25, 

FAA Aerospace Forecasts Fiscal Years 2011-2031. 27 This Initial Supplemental RIA revises the high case estimate of hull value found in the original RIA. The value for 

an ERJ-175 taken from Airliner Price Guide (Summer 2012).
41

injury is 10.5 percent of the value of statistical life.28 Thus, the value of a serious injury to one 

pilot is $0.65 million (10.5 percent multiplied by $6.2 million), or $1.95 million for three pilots.

If the rule prevented a catastrophic accident today of a B727-200F,

29 the average 

replacement value of such an airplane produced between 1981 and 1984 is approximately $1.8 

million.30

We estimate the average value of cargo on a B727-200F to be $2.7 million. While the 

FAA is unaware of published estimates for the value of air cargo, we derived the average value 

per ton of air cargo by assessing the commodity flow value and commodity flow weight of goods 

transported by air from the 2007 Freight Analysis Framework (FAF) Survey.

31 Because both the 

airfreight weight of shipment and airfreight value of commodities vary by origination or 

destination, the average was used. Inflation adjusted average cargo value per ton of $87,082 was 

calculated by dividing the origin-destination averaged airfreight value of commodities by the 

corresponding averaged airfreight weight of shipment, with inflation rate based upon the Gross 

Domestic Product deflator. The average cargo value of $2.7 million was calculated by 

multiplying the maximum cargo weight capacity of a B727-200F aircraft (31 tons) by the

average cargo value per ton ($87,082).32 This estimate is based on a cargo load factor of 100 

percent.

 

28 This guidance can be found at http://ostpxweb.dot.gov/policy/reports/vsl_guidance_072911.pdf 29 The only cargo accident during the 10 year history involved a B727-200. 30 Airline Price Guide, Summer Edition 2011, volume 68, pp.81-82. As with the passenger base case, use of the 

replacement value of the aircraft as a component of the estimate of benefits from avoiding a non-catastrophic 

crash may be an over estimate, if the costs of repairing the aircraft are lower than the replacement value of the 

aircraft.

31 Data based on Freight Analysis Framework 2007, a joint survey conducted by the Census Bureau and BTS and

updated every 5 years. (http://www.bts.gov/publications/commodity_flow_survey/2007/state_summaries/) 32 NASA/CR- 1998-207655, "Air Cargo Operations Cost Database," Table 5-3, pp. 5-4
42

We include the weighted average cost of accident investigation ($0.6 million) as a benefit 

category.33

The total of the averted costs from three serious injuries of $1.95 million, complete loss 

of a B727-200 hull valued at $1.8 million, complete loss of $2.7 million in cargo value, and 

investigation costs of $0.6 million equals base case benefits of $7.1 million. This rule is 

estimated to have an effectiveness rating of 75 percent.

34 Multiplying the potential benefits of 

$7.1 million by the 75 percent effectiveness yields a base case benefit estimate of $5.3 million.

The FAA assumes the likelihood of an accident occurring in any year of the forecast period is 

equal, or uniformly distributed. The present value benefits are $3.5 million when discounted at 

seven percent rate and $4.4 million when discounted at three percent rate. 

High Case Estimate 

The high benefit case is based on the same accident scenario as in the base case, that is, a 

single accident, but with a more severe outcome. The high case estimate projects preventing one

catastrophic air cargo accident over a 10-year period, thus averting 2 fatalities and avoiding the

loss of a high valued narrow-body hull (B757-200F), along with its entire cargo. In addition, we 

continue to assume a cargo load factor of 100 percent. Similar to the base case analysis, we 

include accident investigation costs, which include public and private accident investigations 

cost, and aircraft wreckage removal.

The estimation of benefits is calculated as follows. First, the value from preventing two 

fatalities equals $12.4 million (2 x $6.2 million/averted fatality). Second, the hull value of a 

 

33 “Economic Values for FAA Investment and Regulatory Decisions, A Guide,” Oct. 3, 2007 by GRA for the FAA, pp.

8-4 and 8-5 and inflated using the GDP deflator. 34 This effectiveness rating was determined using the JIMDAT-type process described earlier in this document.
43

B757-200F equals $15.2 million based on an average replacement value for a B757-200F made 

between 1983 and 1999.35 Third, at a 100 percent load factor, the complete loss of the cargo 

carried is valued at about $3.7 million. The cargo value is determined based on the maximum 

cargo weight capacity of 42.9 tons for a B757-200F aircraft,36 multiplied by an average cargo 

value per ton of $87,081. Lastly, we add the estimated cost of a major accident investigation:

$10.5 million.

37

In total, the estimated benefit of preventing an accident in the high case is $41.8 million.

Multiplying the estimated benefit of a preventing an accident by a 75 percent effectiveness rating

equals $31.4 million. Thus the total benefits for the high case equals $31.4 million ($20.6 million 

present value at seven percent, and $26.0 million present value at three percent).

Benefit Summary

The new requirements in this final rule will eliminate the current rest and duty 

distinctions between domestic, flag and supplemental operations as the requirements apply

universally to all Part 121 certificate holders conducting passenger operations. The sleep science, 

while still evolving, is clear in a few important respects: most people need eight hours of sleep to 

function effectively, most people find it more difficult to sleep during the day than during the 

night, resulting in greater fatigue if working at night; the longer one has been awake and the 

longer one spends on task, the greater the likelihood of fatigue; and fatigue leads to an increased

 

35 Source: Airline Price Guide, summer edition 2011, volume 68, pp.138-141. 36 NASA/CR- 1998-207655, "Air Cargo Operations Cost Database," Table 5-3, pp. 5-4 37 Petitioners in the related litigation argued that the FAA should have included the impact of averted hazardous 

material spills in calculating benefits. Potential costs from hazardous materials on-board are not included here. 

There is no historical basis to project any impact, as DOT reporting indicates there were only two “hazmat” 

accidents involving aviation in the last ten years and there was no cost to the public from those accidents (Hazmat 

Intelligence Portal, U.S. Department of Transportation. Data as of 9/10/2012).
44

risk of making a mistake. The requirements contained in this final rule and the accompanying 

analysis are designed to reduce the factors that lead to fatigue in most individuals and for all 

flight crew. 

The actual benefits of the final rule will depend upon the type and size of accident that 

the rule averts. Because we recognize the potential variability in the quantified benefits of this 

final rule, we provide a base case estimate and a high case estimate for both passenger and cargoonly operations. Our base case estimate of the benefits of the final rule as applied to passenger 

operations is $401 million ($263 million present value at seven percent and $332 million at three

percent) and our high case estimate is $757 million ($497 million present value at seven percent

and $627 million at three percent). We also note that saving just 84 lives in a 10 year period 

would cause this rule to be cost beneficial.

38 Further, even if this rule was only 36 percent 

effective at preventing accidents due to fatigue (as opposed to the 52.5 percent effectiveness 

estimated in this analysis) the rule would still be cost beneficial.39

If the final rule were extended to cargo-only operations, our base case estimate of 

benefits for that population is $5 million ($3 million present value seven percent and $4 million 

present value three percent) and our high case estimate is $31 million ($21 million present value 

at seven percent and $26 million present value at three percent).

 

38 This comparison is made assuming the lives saved are distributed uniformly over the 10 year analysis period for 

benefits and using a seven percent discount rate.

39 This calculation is performed using the parameters from high case benefits analysis and uses seven percent as 

the discount rate.
45

Cost Analysis

The cost of the final rule to Part 121 passenger air carriers can be categorized into three 

main cost components: flight operations, training, and rest facilities. Flight operations cost 

consists of three subcomponents: crew scheduling cost, computer programming of crew 

management systems cost, and cost savings associated with reduced use of sick time by pilots 

because of reduced fatigue. Training cost consists of two subcomponents: dispatchers and 

management fatigue training cost, and curriculum development cost. Rest facilities cost consists 

of four subcomponents: engineering cost, installation cost, aircraft downtime cost, and increased 

fuel usage cost. The final rule costs were calculated using industry-provided data whenever 

possible, along with expert analysis.

The total estimated cost of the final rule is $457 million for the 12-year period from 2012 

to 2023. The present value is $338 million and $398 million using a seven percent and a three 

percent discount rate, respectively. If the rule were extended to cover cargo-only operations, the 

additional cost of the rule would be $550 million in nominal terms, $377 million and $464 

million using seven percent and three percent discount rates, respectively.

The 2014 effective date of the final rule allows two years for carriers to become 

compliant with the final rule. The FAA classified costs into three main components and 

estimated the accompanying costs. Data used for the cost estimation was obtained from various 

industry sources, the sources of which are explained in each section. 
46

Table 8 and Table 9 present the estimates of the three main cost components for 

passenger operations and cargo-only operations, respectively.

40 Flight operations costs account 

for approximately 64 percent of the total nominal cost of the rule. Rest facilities account for 

approximately 32 percent of the total nominal cost of the rule. Roughly four percent of the 

nominal costs contained in this analysis are attributable to training. If the final rule were to be 

extended to cargo-only operations, 87 percent of the total nominal cost of the rule would be from 

flight operations costs, 12 percent from rest facility costs, and one percent from training costs. 

Each of the main cost components are explained in-depth in the following sections of this 

document. 

Table 8: Cost Summary, Passenger Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $294 $195 $245

Rest Facilities $146 $132 $139

Training $17 $11 $14

Total $457 $338 $398

Table 9: Cost Summary, Cargo-Only Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $479 $315 $397

Rest Facilities $66 $59 $62

Training $6 $4 $5

Total $550 $377 $464

 

40 Note that for this table and others, items may not sum to reported totals due to rounding.
47

Flight Operations Cost

The flight operations cost component of the final rule is composed of three 

subcomponents: crew scheduling costs, crew management system computer programming costs, 

and payroll cost savings from reducing flightcrew member fatigue.

41 Table 10 and Table 11

provide a summary of the three subcomponents of the flight operations cost for passenger 

operations and cargo-only operations respectively. The derivations of subcomponent costs are 

explained in-depth in the following sections of the document. The explanation for these different 

cost components found in this Initial Supplemental RIA is structured slightly differently than the 

explanation found in the original RIA. Additionally, in a few instances, the manner of calculating 

these cost components has been modified for clarity, consistency, and to correct some calculation 

and reporting errors.

Table 10: Summary of Flight Operations Costs, Passenger Operations

Flight Operations Cost 

Subcomponent

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Crew Scheduling $479 $315 $397

Computer Programming $8 $7 $7

Payroll Savings from Reducing Fatigue -$193 -$126 -$159

Total Flight Operations $294 $195 $245

 

41 Operators might be able to reduce their flight operations costs by developing and implementing a fatigue risk 

management system (FRMS). The FAA is not imposing an FRMS program requirement on Part 121 carriers, but 

does allow carriers the FRMS option. Carriers might develop an FRMS program as an alternative to the final rule 

flightcrew member duty and rest requirements when the crew scheduling cost savings equal or exceed the costs of 

the FRMS program. Carriers might do this for ultra-long flights, which have flight times over 16 hours. FRMS is 

optional and would only be implemented by an operator if their compliance costs could be reduced as FRMS only 

provides cost relief. We did not estimate this potential savings as we do not know how many operators would use 

FRMS and the cost of FRMS has a wide range.
48

Table 11: Summary of Flight Operations Costs, Cargo-only Operations

Flight Operations Cost 

Subcomponent

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Crew Scheduling $521 $342 $431

Computer Programming $2 $2 $2

Payroll Savings from Reducing Fatigue -$44 -$29 -$36

Total Flight Operations $479 $315 $397

Crew Scheduling

Overview

Numerous commenters objected to FAA’s assumptions regarding the 25 percent costsavings resulting from long-term scheduling optimization in the NPRM. To address these 

concerns, the FAA estimated the scheduling compliance costs using a commercial crew 

scheduling program. The final rule’s impact on crew scheduling costs was evaluated using 

Cygnus, a pairing and bid line optimizer developed by CrewPairings, Inc.42 A selection of Part 

121 air carriers provided actual crew schedule data to the FAA for assistance in the cost analysis 

of the Flightcrew Member Duty and Rest Requirements Rulemaking. Each carrier provided data 

for one or more “cases.” A case is defined as a carrier fleet, which usually consists of one aircraft 

type. In some of the cases, the carrier schedules multiple aircraft types using the same pool of 

flightcrew members; the methodology in the original RIA (also used in this Initial Supplemental 

RIA) mirrors actual carrier practice.

In total, carriers provided data for eight cases. This analysis is necessarily limited by the 

willingness of carriers to provide this detailed crew scheduling data. However, we believe the

 

42 Cygnus has been used by more than 30 major airlines worldwide over the past 40 years.
49

cases used in this analysis represent the spectrum of cost structures present in the Part 121 air 

transportation industry. Mainline passenger carriers were represented with two short-haul, 

narrow-body aircraft cases and two long-haul, wide-body aircraft cases. Regional passenger 

carriers were represented with two cases.43 Freight carriers were represented with one short-haul, 

narrow-body aircraft case and one long-haul, wide-body aircraft case. 

In addition to the eight cases based on actual carrier fleets, a synthetic supplemental 

carrier case was created because no supplemental carriers provided crew schedule data. Creation 

of the synthetic supplemental carrier involved modification of the freight wide-body case. The 

flight schedules and crew bases of the freight wide-body case were retained because cargo 

carriers comprise the major share of supplemental carriers. The freight carrier CBA rules were 

replaced with those reflecting a representative supplemental carrier CBA. The representative 

supplemental carrier CBA reflected rules from a number of actual supplemental carrier CBAs. 

These changes reflect the impacts of this final rule on actual supplemental passenger carriers 

operating wide-body aircraft with route structures similar to the freight wide-body aircraft case. 

The crew schedule data consisted of one scheduling period (month) per case. The specific 

periods varied by carrier, based on data availability. The data included flight schedules, aircraft 

flow information, pairings and the carrier’s rule set (contractual, management, and discretionary 

rules). The use of a pairing and bid line optimizer enabled the FAA to more accurately model the 

impacts of the final rule on industry crew scheduling costs than was possible during NPRM cost 

analysis. The pairing and bid line optimizer has been used worldwide by many types of airlines 

 

43 Most regional carriers operate code-share flights for a number of mainline partners; crew scheduling is usually 

performed separately for each mainline partner. This analysis was conducted using the same process as the actual 

carrier, so each regional carrier case represents a sub-fleet.
50

for their own crew scheduling needs and addresses the optimization and scheduling limitations in 

the NPRM cost analysis. Due to this extensive real-world experience, results for these eight cases 

can be expected to accurately portray the impacts of the final rule on crew scheduling costs for 

the cases studied.

Crew Scheduling Analysis

Accurately analyzing the final rule’s impact on crew scheduling costs for each of the 

cases required isolating the final rule’s impact from the impacts of various contractual, 

management, and discretionary crew scheduling practices. The pairing and bid line optimizer 

was first calibrated to ensure that it was capable of creating crew schedules virtually identical to 

the crew schedules provided by the carriers. After calibration, existing federal regulations 

relevant to flightcrew member scheduling were removed from the optimizer and replaced with 

the final rule requirements. Changes in crew scheduling cost could then be attributed solely to 

the final rule.

The first step in optimizer calibration was receiving and formatting the input data from 

carriers. The input data included flight schedules, aircraft flow information, pairings, regulations,

carrier’s unit costs (credit hour pay rate, per diem, and hotel room costs), and the carrier’s rule 

set from the carriers’ crew management systems. Carrier rule sets included parameters for crew 

bases, maximum/minimum flight time, rest time, duty time, and ground time to allow aircraft 

changes and are based on contractual, management, and discretionary rules. The pairings that 

were received directly from the carriers in this first step are referred to as the “production 

solution.” Since no modifications were made to the production solution by the FAA or the 

optimizer, the production solution accurately represents the current crew scheduling 

environment, including all regulatory, contractual, management, and discretionary rules.
51

Once the production solution was established, the bid lines and pairings were set aside. 

The optimizer was run using only the flight schedules, aircraft flow information, federal aviation 

regulations and the carrier’s rule set. The optimizer then created its own bid lines and pairings, 

which are referred to as the “baseline solution.” The baseline solution was compared to the 

production solution using a number of metrics, such as the amount of credit hours, duty periods, 

hotel room nights required, distribution of time among crew bases, number of aircraft swaps, etc. 

Once the baseline solution was identical or virtually identical to the production solution, the 

optimizer was deemed calibrated for each of the cases.

This calibration of the optimizer verified that the optimizer could accurately reproduce 

the crew scheduling process at each of the carriers. That is, the baseline solution could be 

substituted for the production solution at each carrier with no material change in crew scheduling 

cost. 

To determine the impact of the final rule, the regulations in the baseline solution were 

replaced with the final rule. All provisions of the final rule were implemented in this analysis, 

including maximum flight time, maximum flight duty time, minimum rest time, and cumulative 

limits. All other, non-regulatory rules from the baseline solution were retained. Using these 

inputs, the optimizer created bid lines and pairings referred to as the “final rule solution.” Since 

the only difference between the baseline solution and the final rule solution was the substitution 

of the final rule for the existing regulations, the change in cost components between the solutions 

is solely attributable to the final rule.

In the course of reviewing the calculations used in estimating scheduling costs in support 

of drafting this Initial Supplemental RIA, FAA became aware that in the original RIA, in eight of 

the nine cases, the number of aircraft block hours differed slightly between the baseline run and 
52

the final rule run. This minor difference is due to the treatment of so called “carry-in/carry-out” 

flights. Industry practice is to construct each trip pairing such that each flightcrew member starts 

and ends the scheduling period at their crew base. Consequently, some bid lines outputted by the 

optimizer would have left flightcrew members away from their crew base at the beginning or end 

of the scheduling period (month). In those instances, it is airline practice to include those 

segments as part of the bid lines for the adjoining month (i.e., “carrying” the pilot in or out of the 

month). While that is reasonable practice for airlines, the practice resulted in introducing a 

source of variation between the baseline and final rule run that was not caused by the final rule. 

That is, because the final rule results in different bid lines being constructed, the segments 

identified as carry-in or carry-out often differ as well. 

FAA continues to use the original results as the basis for this Initial Supplemental RIA.

However, Appendix B contains a sensitivity analysis whereby the final rule results are adjusted

to explore the possible magnitude of the impact of the difference in aircraft block hours on the 

crew scheduling cost estimates caused by the carry-in/carry-out variation. 

Table 12 shows the change in cost components attributable to final rule for each case.

Note that cases which had no changes in either domestic or international time away from base 

(TAFB) were cases that were either solely domestic or solely international. More details on the 

analysis of each case used in this analysis can be found in the GRA summary report found in the 

docket associated with this rule-making.

44

 

44 GRA, Incorporated, “Summary of CrewPairings, Inc. Economic Analysis of Flightcrew Member Duty and Rest 

Requirements Rulemaking,” September 2012.
53

Table 12: Change in Monthly Flightcrew Scheduling Cost Elements Due to Final Rule, by 

Case 

Industry Group Case

Baseline 

Solution 

Flightcrew 

Members

Change in 

Credit Hours 

Change in 

Domestic 

TAFB Hours 

Change in 

International 

TAFB Hours 

Change in 

Hotel Stays 

Passenger

Narrow-body

A 924 2,187 18,660 0 660

B 1,698 -429 -15,035 1,030 -944

Passenger 

Wide-body

C 1,121 -70 3,863 8,348 791

D 430 -965 0 -2,741 -34

Regional E 300 57 5,812 0 280

F 240 37 4,148 -16 144

Supplemental I 806 4,642 3,159 9,759 756

Freight 

Narrow-body G 330 560 890 2,390 54

Freight Widebody H 1,053 984 6,197 862 240

It is interesting to note that in some instances, the rule change results in the potential for 

cost savings. For instance, while one provision of the final rule requires increased rests between 

duty periods for domestic operations, the final rule also allows for increased flying time in 

certain situations as well as reduced rest times between duty periods for some international 

operations.

Given that maximum flight time and flight duty period time now depend on time of day, 

acclimation, number of flightcrew members, and number of segments, there are situations where 

flightcrew members can work more hours per duty period under the final rule than under the 

previous rule or where a flight previously requiring additional flightcrew members can now be 

flown with fewer flightcrew members.

In some cases, the changes are small. For instance, maximum flight time per duty period 

for domestic flights was extended from 8 to 9 hours for duty periods beginning from 0500-1959. 
54

However, the flight time limits now are in effect for actual flight time, rather than planned flight 

time, which means in practice carriers will not be able to fully schedule the additional hour of 

flight time but instead will leave a buffer to allow for instances of unplanned flight delays. In 

other cases, though, airlines can potentially see significant savings; international flights with 

three flightcrew members were previously limited to 12 hours flying and have now been 

increased to 13 flight hours and up to 17 flight duty hours under certain time of day and rest 

facility combinations. For some classes of long-haul flying, this means that instead of needing 

two additional flightcrew members, only one additional flightcrew member is needed. Similarly, 

rest periods have also potentially decreased for some route types (particularly international), 

reducing the amount of TAFB and credit hours accruing to pilots.

As an example, Case D depicted in Table 12 shows savings in terms of credit hours, 

international TAFB, and hotel stays due to the final rule. The flight segments in Case D were 

exclusively international flights and the existing schedules already allowed rest periods that 

exceeded the minimum rest period required by the final rule. Additionally, Case D had instances 

where the increase in flight time allowed by the rule was particularly beneficial and allowed 

certain flights to Europe to be operated with one less flightcrew member which resulted in 

significant cost savings. 

One of the passenger narrow-body cases and both passenger wide-body cases (Cases B –

D) demonstrated decreases in credit hours. The other passenger narrow-body case (Case A) 

showed an increase in credit hours of 2.9 percent while both regional carriers (Cases E and F) 

had credit hour increases of only 0.2 percent. The freight and supplemental cases (Cases G – I) 

had credit hour increases ranging from 1.2 percent to 7.2 percent. TAFB and hotel rooms rose for 

some passenger carrier cases and fell for others (but generally less than 7.5 percent in either 
55

direction), depending largely on the relevant schedule and collective bargaining agreement. 

TAFB and hotel rooms increased for the regional cases (between 5 percent and 9 percent) as 

their current scheduling practice is optimized around the minimum rest time of the current rule. 

Freight and supplemental carriers saw across-the-board increases in time away from base and 

hotel rooms.

In terms of the final rule’s impact on the work schedules of flightcrew members at an 

individual level, the most striking change is for the supplemental case. Flightcrew members in 

the supplemental case under the final rule will now have two fewer duty hours per duty period, 

on average, whereas the other cases showed more modest changes in the number of duty hours 

per duty period (fewer than 30 minutes increase or decrease). The discrepancy results because 

the difference between the current rules and final rule was most pronounced for supplemental 

operations.

More details on the specifics of each of the cases can be found in the GRA summary 

report.45

Estimates of Unit Costs

We made separate estimates of each of the unit costs for each cost component (credit 

hour costs, per diem hourly rates, and cost per hotel room) for different types of air carriers. The 

estimates are based on actual cost data for a variety of air carriers, wherever possible.

The first step of the unit cost estimation process was to define a collection of industry 

groups that would collectively cover all Part 121 air carriers and that would group air carriers 

 

45 GRA, Incorporated, “Summary of CrewPairings, Inc. Economic Analysis of Flightcrew Member Duty and Rest 

Requirements Rulemaking,” September 2012.
56

together based on similarity of characteristics that would influence their crew scheduling costs. 

Air carriers were assigned to one of the resulting eight industry groups based on a number of 

metrics such as operating authority, aircraft fleet, aircraft utilization, markets served, collective 

bargaining agreements, etc. In a few cases, a carrier might have been classified as a freight 

carrier even if it did not perform any cargo-only operations (or as a passenger carrier even if it 

did not perform any passenger operations). In these instances other characteristics of the air 

carrier, such as fleet type or collective bargaining agreement, were considered to be a more 

influential factor on crew scheduling costs than whether the carrier transported passengers or 

cargo. Note that the eventual allocation of costs between passenger and cargo-only operations 

was based on what the air carrier actually transports, not its industry group classification. Table 

13 lists the number of air carriers in each group and the number of flightcrew members in each 

group. 46 Table C.1 in Appendix C presents further detail regarding the air carrier classifications.

Table 13: Air Carrier Classification into Industry Groups

Industry Group Number of Part 

121 Carriers

Total Number of 

Flightcrew 

Members

Passenger Integrated 7 36,013

Passenger Narrow-body 14 11,899

Passenger Wide-body 1 150

Regional 38 20,511

Supplemental 8 1,674

Freight Integrated 3 7,230

Freight Narrow-body 16 846

Freight Wide-body 3 914

Total 90 79,237

 

46 The original RIA differed from the classifications used here in a few instances.
57

Table 14 presents a summary of the data and calculations used to estimate average credit 

hour costs per flightcrew member. Bureau of Transportation Statistics Form 41 data (Item 51230, 

Pilots and Copilots, from Schedule P-5.2) was used to determine the total flightcrew cost for 

each carrier. 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 

report. Both data sources were the most current available at the time of the drafting of the 

original RIA, reflecting the first three quarters of 2010.47 Total flightcrew cost data and aircraft 

block hour data were each summed across carriers by relevant industry group.

48 Each industry 

group’s sum of total flightcrew cost was divided by that industry group’s sum of aircraft block 

hours. For the passenger integrated carriers, this information was summarized separately for 

narrow-body and wide-body aircraft to preserve the distinction between narrow-body and widebody flightcrew member pay rates.

49 These calculations resulted in the average total flightcrew 

cost per aircraft block hour (Column [A] in Table 14). To determine the average cost per block 

hour for an individual flightcrew member (Column [C] in Table 14), it was necessary to divide 

 

47 There was no adjustment made for inflation, as pilot wages are negotiated through contracts. 48 Note that here and elsewhere where data on aircraft block hours are used, the block hours associated with 

Beechcraft Beech 18 C-185 and Cessna 208 Caravan have been omitted because corresponding Pilot/CoPilot costs 

were not available. In addition, the records relating to Arrow Air, Inc. have been excluded from this analysis as that 

carrier ceased operations in the middle of 2010.

49 The Form 41 data for freight integrated carriers did not support separate calculations for narrow-body and widebody credit hour costs. The resulting pay rates would have inferred that pay rates for narrow-body pilots are 

higher than wide-body pay rates, a finding which does not correspond with usual industry practice. The issue 

appears to lie with the detailed reporting of this block hour and Pilot/CoPilot cost data by aircraft type. To avoid 

these reporting issues for freight carriers, we use only total Pilot/CoPilot cost and aircraft block hours for each 

carrier in the freight industry groups.
58

the average total flightcrew cost per aircraft block hour by the average number of pilots per flight

(Column [B] in Table 14).50

Further adjustments were necessary to convert the estimates of average cost per block 

hour per flightcrew member to the average cost per credit hour per flightcrew member. First, 

estimated monthly credit hours per flightcrew member for each industry group were derived 

from analysis of AIR Inc. Salary Survey data (Column [D] in Table 14).

51 The AIR Inc. Salary 

Survey provided estimated monthly credit hours per flightcrew member for 36 carriers. 

Weighted average estimated monthly credit hours for each industry group were calculated using 

carrier block hour data from AirHoursRamp item in the Air Carrier Summary Data, T2: U.S. Air 

Carrier Traffic and Capacity Statistics by Aircraft Type report. Next, crew scheduling data 

provided by nine carriers to the FAA were analyzed to estimate the average number of block 

hours per flightcrew member per month for each industry group (Column [E] in Table 14). Each 

of the nine carriers provided data for two separate scheduling periods, with data for one 

scheduling period considered to be a "busy" month and data for the other considered to be a 

"slow" month.

52 The estimates of block hours per pilot for the two months were averaged 

 

50 Narrow-body aircraft (including regional) were assumed to have two pilots per flight in all cases. Note that for 

narrow-body aircraft that require three flightcrew members (such as B727), the third flightcrew member is the 

flight engineer and is not reported in the Pilots and CoPilots cost item on Form 41 Schedule P-5.2. Because no cost 

data specific to flight engineers is available, this analysis uses the calculated pilot and copilot cost as the estimated 

cost for flight engineers. For wide-body aircraft, the average number of flightcrew members per flight was 

estimated using proprietary data provided to the FAA by a number of carriers. The average number of pilots per 

flight for integrated carriers is the average of the number of pilots per flight for narrow-body and wide-body 

flights, weighted by narrow-body and wide-body block hours from AirHoursRamp item in the Air Carrier Summary 

Data, T2: U.S. Air Carrier Traffic and Capacity Statistics by Aircraft Type report. The average number of pilots per 

flight for passenger wide-body has been revised in this Initial Supplemental RIA to correct a calculation error 

present in the original RIA. 

51 Darby, Kit and Dan Gradwohl, “2006 Salary Survey,” Aviation Information Resources, Inc., 2007. 52 The data relating to narrow-body operations of passenger carriers were used as estimates for the passenger 

narrow-body industry group while the data relating to wide-body operations of passenger carriers were used for 
59

together. (These data are provided in Table C.2 in Appendix C.) Dividing the average flightcrew 

member block hours per month by the average flightcrew member credit hours per month 

resulted in a ratio of block hours per month to credit hours per month, for each of the industry 

groups (Column [F] in Table 14).

53 Finally, the average cost per block hour per flightcrew 

member (Column [C] in Table 14) was then multiplied by the ratio of block hours per month to 

credit hours per month (Column [F] in Table 14) to derive the average credit hour cost per 

flightcrew member for each of the industry groups (Column [G] in Table 14).

54

 

the passenger wide-body industry group. The data for all operations of passenger carriers was used for the 

passenger integrated group. The same method was used for the freight industry groups.

53 We note that the estimate of the average credit hours per month comes from a 2006 survey, while the average 

block hours per month comes from carrier data reflecting more recent years. When constructing a ratio, using data 

from the same time periods would obviously be preferred; however, data from contemporaneous time periods 

were not available.

54 This method for estimating credit hour cost per flightcrew member differs from the method used in the original 

RIA, and results in higher estimates of crew scheduling costs due to the final rule. The method used in the original 

RIA produced separate estimates of credit hour cost per flightcrew member for the passenger wide-body and 

passenger narrow-body industry groups. Those two estimates were then combined to produce an estimate of 

crew scheduling costs for the passenger integrated industry group. The revised method used in this Initial 

Supplemental RIA produces separate estimates of credit hour cost per flightcrew member for four different 

passenger industry groups: carriers operating exclusively passenger narrow-body aircraft, those operating only 

passenger wide-body aircraft, narrow-body aircraft operations by air carriers comprising the passenger integrated 

industry group, and wide-body aircraft operations of carriers making up the passenger integrated industry group.

(Three industry groups are used for freight: carriers operating only narrow-body aircraft, carriers operating only 

wide-body aircraft and carriers that operate both narrow-body and wide-body aircraft.)

 The impetus for this change was the observation that the estimate of credit hours per month per flightcrew 

member for the passenger wide-body industry group reported in the original RIA (60 credit hours per month) was 

much different from the estimate of credit hours per flightcrew member per month for passenger integrated 

carriers (78 credit hours per month). One would expect the estimate of credit hours per flightcrew member for 

the passenger integrated group to be approximately equal to the weighted average of the narrow-body and widebody estimates. However, averaging 60 credit hours per month (the estimate for passenger wide-body operations) 

with 82 credit hours per month (the estimate for passenger narrow-body operations) using the relative weights as 

shown in Table B.4 in Appendix B results in an estimate of 72 credit hours per month, which is much different than 

the 78 credit hours per month observed for the passenger integrated industry group. For that reason, the 

observed 60 credit hours per month did not appear to be an appropriate value to use for calculating costs for the 

passenger integrated industry group. (Note that the estimate of 78 credit hours per month per flightcrew member 

for the passenger integrated group that was reported in Table 10 of the original RIA was not used in calculating 

costs for passenger integrated carriers, because that estimate did not differentiate between narrow-body and 

wide-body operations.)
60

This approach to calculating the average credit hour cost per flightcrew member 

addresses NPRM comments made by several commenters. Commenters stated that the salary 

data used in the NPRM RIA “does not approximate current, real world flightcrew unit costs...”55

ATA suggested that the FAA use DOT Form 41 data for calculation of crew salary costs. The 

approach to crew salary costs presented in Table 14 responds to this comment by using the most 

recent 2010 DOT Form 41 data available as of April 2011 for the calculation of average credit 

hour costs per flightcrew member. This approach does not include payroll taxes, because these 

represent a transfer rather than a cost. This approach also does not include pension and benefit 

costs, because these costs will not be affected by the marginal change in credit hours attributable 

to the final rule.

 

 The methodology used in this Initial Supplemental RIA still relies on the estimate of 60 credit hours per month 

per flightcrew member for the passenger wide-body industry group, but minimizes its influence by using it only to 

estimate costs for carriers that conduct passenger wide-body operations exclusively. While using this revised 

method means that the estimate of credit hours per month per flightcrew member for the passenger and freight 

integrated industry groups does not distinguish between the narrow-body and wide-body operations of carriers in 

those groups (since separate credit hour per flightcrew member data for their narrow- and wide-body operations 

are not available), we believe it results in more reliable estimates of their unit costs.

55 Comments of the Air Transport Association of America, Inc. in the matter of Notice of Proposed Rulemaking for 

Flightcrew Member Duty and Rest Requirements, Docket No. FAA-2009-1093, November 15, 2010.
61

Table 14: Average Flightcrew Member Cost per Credit Hour 

Industry 

Group

Total

Flightcrew 

Cost per 

Block Hr

Flightcrew

Members 

per Flight

Average 

Flightcrew 

Member 

Cost per 

Block Hr

Average 

Flightcrew 

Member 

Credit 

Hrs/Month

Average 

Flightcrew 

Member 

Block 

Hrs/month

Ratio of 

Block 

Hrs/Month 

to Credit 

Hrs/Month

Average 

Flightcrew 

Member 

Cost per 

Credit Hr

[A] [B] [C] [D] [E] [F] [G]

Passenger 

Integrated $499 2.16 $231 78 59 0.76 $176

Passenger 

Integrated: 

Narrow-body

$404 2.00 $202 78 59 0.76 $154

Passenger 

Integrated: 

Wide-body

$629 2.37 $265 78 59 0.76 $202

Passenger 

Narrow-body $436 2.00 $218 82 60 0.73 $159

Passenger 

Wide-body $667 2.37 $281 60 59 0.98 $275

Regional $179 2.00 $89 82 48 0.59 $53

Supplemental $712 2.16 $329 71 44 0.61 $201

Freight 

Integrated $1,481 2.09 $709 88 44 0.50 $357

Freight 

Narrow-body $734 2.00 $367 62 34 0.55 $201

Freight Widebody $847 2.09 $405 66 45 0.67 $273

Per-diem costs were calculated by multiplying the change in TAFB from the baseline 

solution to the final rule solution by the appropriate per diem rate. Because flightcrew members 

at some carriers receive different per diem rates based on whether TAFB is domestic or 

international, the pairings summary in each of the solutions provided domestic and international 

TAFB separately. The per diem rates used in this analysis were a block hour weighted average of 
62

carriers reporting per diem rates in the AIR Inc. Salary Survey.

56 Again the block hours for each 

carrier were taken from Air Carrier Summary Data, T2: U.S. Air Carrier Traffic and Capacity 

Statistics by Aircraft Type report. Table 15 shows the weighted average hourly per diem rates by 

operator type used in this analysis.57

Table 15: Hourly per Diem Rates

Operator Type

Weighted Average 

Domestic per Diem

Rate

Weighted Average 

International per 

Diem Rate

Passenger $1.94 $2.28

Regional $1.60 $1.99

Supplemental $2.06 $2.28

Freight $1.99 $2.87

Hotel costs were calculated by multiplying the change in required hotel room nights from 

the baseline solution to the final rule solution by hotel room cost. In practice, hotel costs can vary 

by a number of factors including the carrier’s negotiating power with hotel chains, city size, 

domestic or international location, etc. The hotel room costs used in this analysis were estimated 

based on data provided to the FAA by various carriers and are presented in Table 16.

58

 

56 Darby, Kit and Dan Gradwohl, “2006 Salary Survey,” Aviation Information Resources, Inc., 2007. 57 The per diem rates are from the 2006 AIR, Inc. survey. FAA did not adjust those per diem rates for inflation as 

the rates are negotiated in contracts. However, where the AIR, Inc. survey reported per diem rates for future years 

that had been negotiated into contracts as of the time of the survey, those future rates are included. 58 The hotel costs used in this Initial Supplemental RIA differ slightly from those used in the original RIA, which 

differed by case. This Initial Supplemental RIA uses a simplified hotel room cost structure for ease of explication.
63

Table 16: Hotel Room Costs 

Operator Type

Average 

Hotel 

Room Cost

Passenger $65.00

Regional $58.00

Supplemental $75.00

Freight $75.00

Cost per Flightcrew Member Estimation

As discussed above, eight industry groups were created for the final rule cost analysis.

The changes in each of the cost components for the two narrow-body passenger cases were 

summed for the passenger narrow-body industry group and for the narrow-body component of 

the passenger integrated industry group. The two wide-body passenger cases were summed for 

the passenger wide-body industry group and for the wide-body component of the passenger 

integrated group. The two regional cases were summed for the regional group. The freight 

narrow-body case was used for the freight narrow-body industry group while the freight widebody case was used for the freight wide-body industry group. The freight narrow-body case and 

freight wide-body case were summed for the freight integrated case. Table 17 shows the results 

of combining the case results to form estimates for each industry group and industry group 

subcomponent. Appendix B contains a sensitivity analysis to explore an alternative method for 

combining the individual case results to create an industry group level estimate of crew 

scheduling costs.
64

Table 17: Change in Flightcrew Scheduling Cost Elements due to Final Rule, by Industry 

Group

Industry Group

Baseline 

Solution 

Flightcrew 

Members

Change 

in 

Credit 

Hours 

Change in 

Domestic 

TAFB 

Hours 

Change in 

International 

TAFB Hours 

Change 

in Hotel 

Stays 

Passenger Integrated: 

Narrow-body 2,622 1,758 3,625 1,030 -284

Passenger Integrated: Widebody 1,551 -1,035 3,863 5,607 757

Passenger Narrow-body 2,622 1,758 3,625 1,030 -284

Passenger Wide-body 1,551 -1,035 3,863 5,607 757

Regional 540 94 9,960 -16 424

Supplemental 806 4,642 3,159 9,759 756

Freight Integrated 1,383 1,544 7,087 3,252 294

Freight Narrow-body 330 560 890 2,390 54

Freight Wide-body 1,053 984 6,197 862 240

To estimate the costs of the final rule for each industry group the changes in cost 

elements due to the final rule were then multiplied by industry group and subcomponent-specific 

estimates of the unit costs for those cost components, namely average credit hour pay rates, 

average domestic and international per diem hourly rates, and hotel room costs. The derivations

of those estimates of unit costs are explained above.59 The results of those calculations are shown 

in Table 18.

 

59 The original RIA used a different method whereby first the costs for each case were calculated using the 

respective narrow-body and wide-body unit costs and then the costs were summed to create estimates of the 

integrated industry groups. This Initial Supplemental RIA changes that method so that the unit costs specific to the 

integrated carriers are incorporated.
65

Table 18: Monthly Change in Flightcrew Scheduling Cost due To Final Rule

Industry Group

Baseline 

Solution 

Flightcrew 

Members

Change in 

Credit 

Hour Cost 

Change 

in 

Domestic 

TAFB 

Cost 

Change in 

International 

TAFB Cost 

Change 

in Hotel 

Cost 

Total 

Change in 

Scheduling 

Cost 

Passenger 

Integrated: Narrowbody2,622 $270,504 $7,048 $2,346 -$18,460 $261,438

Passenger 

Integrated: Widebody1,551 -$208,842 $7,510 $12,774 $49,205 -$139,353

Passenger Narrowbody 2,622 $280,437 $7,048 $2,346 -$18,460 $271,371

Passenger Widebody 1,551 -$284,705 $7,510 $12,774 $49,205 -$215,217

Regional 540 $4,953 $15,972 -$31 $24,592 $45,486

Supplemental 806 $930,922 $6,509 $22,270 $56,700 $1,016,401

Freight Integrated 1,383 $551,083 $14,099 $9,330 $22,050 $596,562

Freight Narrowbody 330 $112,588 $1,771 $6,858 $4,050 $125,267

Freight Wide-body 1,053 $268,610 $12,328 $2,472 $18,000 $301,411

For each industry group, the change in each of the cost components was divided by the 

number of flightcrew members in the baseline solution to determine the monthly final rule crew 

scheduling cost per flightcrew member for that industry group. For the passenger integrated 

industry group, the change in each of the cost elements is summed across sub-components 

(narrow-body and wide-body) before dividing by the sum of baseline solution flightcrew 

members. The final rule crew scheduling cost is valued by summing the change in credit hour 

cost, per diem costs, and hotel cost from the baseline solution to the final rule solution. The 

annual final rule crew scheduling cost per flightcrew member was calculated by multiplying the 

monthly cost by 12. Table 19 shows the monthly change in flightcrew scheduling cost due to the 

final rule per flightcrew member.
66

Table 19: Monthly Change in Flightcrew Scheduling Cost per Flightcrew Member due to 

Final Rule

Industry Group

Baseline 

Solution 

Flightcrew 

Members

Change in 

Credit 

Hour Cost 

Change in 

Domestic 

TAFB Cost 

Change in 

International 

TAFB Cost 

Change in 

Hotel 

Cost 

Total 

Change in 

Scheduling 

Cost 

Passenger 

Integrated 4,173 $15 $3 $4 $7 $29

Passenger 

Narrow-body 2,622 $107 $3 $1 -$7 $103

Passenger 

Wide-body 1,551 -$184 $5 $8 $32 -$139

Regional 540 $9 $30 $0 $46 $84

Supplemental 806 $1,155 $8 $28 $70 $1,261

Freight 

Integrated 1,383 $398 $10 $7 $16 $431

Freight 

Narrow-body 330 $341 $5 $21 $12 $380

Freight Widebody 1,053 $255 $12 $2 $17 $286

Extrapolation of Crew Scheduling Analysis

The number of flightcrew members presented in Table 20 reflects the number of 

flightcrew members listed on each Part 121 carrier’s operating certificate in the FAA’s Vital 

Information Subsystem (VIS) as of December 2010. The total industry final rule cost would be 

overstated if extrapolation was based on the number of VIS flightcrew members because not all 

of these flightcrew members are lineholders. Recall that the cost estimates are calculated as the 

change in crew scheduling cost per lineholding flightcrew member. Each carrier employs a 

significant number of reserve flightcrew members. The FAA estimated that, on average, reserves 
67

comprise 15 percent of flightcrew members for the average Part 121 passenger air carrier based 

on APA published information.

60 However, the available information also shows that carriers 

vary widely in regards to the percent of their pilot workforce that are reserves. Appendix B 

contains a sensitivity analysis on this key parameter. The extrapolation of the crew scheduling 

analysis to the Part 121 passenger air transportation industry used the number of flightcrew 

members (lineholders) shown in Table 20 to determine the final rule crew scheduling cost.

Table 20: Tally of Flightcrew Members, By Industry Group

Industry Group Number of Part 

121 Carriers

Total Number 

of Flightcrew 

Members

Total Number of 

Flightcrew Members 

Adjusted For 15% 

Reserves

Passenger Integrated 7 36,013 30,611

Passenger Narrow-body 14 11,899 10,114

Passenger Wide-body 1 150 128

Regional 38 20,511 17,434

Supplemental 8 1,674 1,423

Freight Integrated 3 7,230 6,146

Freight Narrow-body 16 846 719

Freight Wide-body 3 914 777

Total 90 79,237 67,351

The number of flightcrew members in each industry group shown in Table 20 was multiplied by 

the appropriate annual cost per lineholding flightcrew member in Table 19 to extrapolate the 

estimated cost to the Part 121 air transportation industry, as shown in the “Total Annual Crew 

Scheduling Costs” column in Table 21. This total cost figure is then allocated to passenger 

operations and cargo-only operations using the share of revenue departures attributable to each 

class of operation in 2010 as reported in Database T1: U.S. Air Carrier Traffic and Capacity 

 

60 “Productivity,” American Airlines Negotiations. Accessed on August 1, 2012 at 

http://www.aanegotiations.com/apaProductivity.asp.
68

Summary by Service Class from the Bureau of Transportation Statistics. The percentage of 

revenue departures that are passenger and cargo-only for each carrier is presented in Table C.1 in 

Appendix C. As shown in Table 21, there is a total of $48 million a year in flightcrew scheduling 

costs for all passenger operations due to the final rule associated with flightcrew credit hours, per 

diem costs, and hotel room costs. If the final rule applied to cargo-only operations, there would 

be approximately $52 million in additional costs per year.

Table 21: Annual Crew Scheduling Costs

Industry Group

Final Rule 

Annual 

Cost per 

Flightcrew 

Member

ReserveAdjusted 

Flightcrew 

Members

Total 

Annual 

Crew 

Scheduling 

Costs 

(millions)

Passenger 

Operations 

Annual Crew 

Scheduling 

Costs 

(millions)

Cargo-Only 

Operations 

Annual Crew 

Scheduling 

Costs 

(millions) 

Passenger Integrated $351 30,611 $11 $11 $0

Passenger Narrowbody $1,242 10,114 $13 $13 $0

Passenger Wide-body -$1,665 128 $0 $0 $0

Regional $1,011 17,434 $18 $17 $0

Supplemental $15,133 1,423 $22 $6 $15

Freight Integrated $5,176 6,146 $32 $0 $32

Freight Narrow-body $4,555 719 $3 $0 $3

Freight Wide-body $3,435 777 $3 $1 $2

Total $100 $48 $52

Limitations of Crew Scheduling Analysis

The FAA believes that carriers will be able to reduce much of the cost shown in Table 21. 

Carriers will engage in additional network optimization to reduce crew scheduling costs, which 

the FAA is unable to quantify at this point. In the long run, this may involve re-timing flights, 

changing schedule frequency, and entering or leaving markets. However, there may also be costs 

associated with these actions such as changes in aircraft utilization and revenue losses. At this 

time, the FAA has not estimated potential long-run optimization of crew scheduling costs.
69

The final rule economic costs are best measured as society’s willingness to be 

compensated for consumption opportunities forgone as a result of resources being diverted to the 

production of improved aviation safety. Because these opportunity costs are difficult to estimate, 

our estimates of crew scheduling costs reflect, for the most part, financial costs that will be 

incurred by affected air carriers. These financial costs are likely to overstate the economic costs 

of the proposed rule.

A large part of estimated crew scheduling costs is increased compensation to flightcrew

members for the additional time spent in avoiding pilot fatigue. These compensation costs will 

reflect economic costs only if flightcrew wage rates are accurate measures of the forgone value 

of goods and services that could otherwise be produced. However, it is likely that flightcrew 

members will be able to use some of the time spent avoiding fatigue in productive activities, 

including the production of leisure activities. Our cost estimates do not include offsets for the 

value of these activities.

Increased per diem cost estimates do not include offsets that are likely to occur. For 

example, meals consumed on the road by flight crew members are substitutes for meals that 

would otherwise be consumed at home. Resource savings (the value of labor and food used to 

produce meals at home in this example) are not reflected in our cost estimates. Similarly, the 

costs associated with increased hotel expenses do not include offsets for at-home savings that 

will likely occur—e.g., reduced energy and water consumption and avoided cleaning costs.

Computer Programming

Carriers will incur computer programming costs as they will need to update their crew 

management systems and their schedule optimization systems with the constraints imposed by 

the final rule. 
70

A one-time cost will be incurred in 2013 as carriers update their crew management

systems. Crew management system update costs were estimated for each individual carrier, 

based on the number of flightcrew members listed on the carrier’s operating certificate. 

Carriers were assigned to one of three groups based on the number of flightcrew 

members. Computer programming costs, which vary with size of carriers, are estimated using

number of person-days and staff costs. Person-days required to perform the system update were

estimated to be 400, 160, and 80 days for large (more than 1,000 flightcrew members), average

(250 to 1,000 flightcrew members), and small (less than 250 flightcrew members) carriers, 

respectively.61 A daily professional staff cost was assumed to be $625. As shown in Table 22,

crew management system update costs due to the final rule for passenger carriers is estimated to 

be approximately $8 million. If the final rule was extended to cargo-only operations, those 

carriers who perform just cargo-only operations would experience an estimated $2 million in 

costs.62

 

61 The classification of carriers has changed slightly in this Initial Supplemental RIA compared to the original RIA. 62 Since the final rule applies only to passenger operations, a carrier that performs both passenger and cargo-only 

operations was assigned to the passenger carrier category because we assumed they would incur the full 

programming costs necessary to support compliance of their passenger operations with the final rule.
71

Table 22: Crew Management System Update Costs

Flightcrew 

Members

Cost per 

Carrier

Passenger 

Carriers 

(Count)

Freight 

Carriers 

(Count)

Passenger 

Carriers 

(millions)

Freight 

Carriers 

(millions)

>1,000 $250,000 16 2 $4 $1

250-1,000 $100,000 20 3 $2 $0

<250 $50,000 31 18 $2 $1

Total 67 23 $8 $2

Payroll Cost Savings from Reducing Flightcrew Members Fatigue

The final rule is designed to reduce the risk to flight operations attributable to fatigued 

flightcrew members by limiting the maximum number of hours they are permitted to be on duty, 

the number of hours they actually fly during duty periods, and by ensuring that they receive 

adequate rest periods before reporting for duty. According to CDC, “chronic sleep loss is an 

under-recognized public health problem that has a cumulative effect on physical and mental 

health. Sleep loss and sleep disorders can reduce quality of life and productivity, increase use of 

health-care services, and result in injuries, illness, or deaths.”63 It is expected that the final rule

will result in better-rested flightcrew members and reduce flightcrew member fatigue, thus 

reducing the use of sick time by flightcrew members. When a flightcrew member is scheduled 

for duty and calls in sick or fatigued, the carrier must use a reserve flightcrew member to 

complete the scheduled duty. The final rule will reduce the use of reserve flightcrew members to 

cover fatigue-induced sick call-ins by flightcrew members, which will reduce the flight 

operations cost associated with fatigue issues for carriers.

 

63 CDC’s MMWR, Weekly, February 29, 2008 / 57(08);200-203.
72

While the current share of current sick time attributable to fatigue is unknown, it is 

almost certainly greater than zero. Similarly, while the precise amount by which the final rule

will reduce sick time is unknown, it is also most likely greater than zero. Labor representatives 

have informed the FAA that sick time is approximately five percent of payroll costs. This data is 

consistent with data collected in the rail industry (see footnote 17). In light of this information, 

the FAA adopts the assumption that sick time accounts for five percent of total industry 

flightcrew member pay. Moreover, FAA has also assumed for this analysis that the final rule is 

expected to reduce the use of sick time by five percent. As a result, FAA estimates the cost 

savings from reducing use of sick time as 0.25 percent (five percent of five percent) of flightcrew 

payroll costs. Appendix B presents a sensitivity analysis for this assumption whereby it is 

assumed that the final rule will instead reduce use of sick time by three percent or seven percent. 

Total industry flightcrew member pay was calculated from Form 41 pilot cost data.64

Form 41 data covers only those air carriers with at least $20 million in annual revenues. These 

carriers employ approximately 96 percent of all pilots; therefore we factor up the Form 41 pilot 

payroll costs by approximately five percent to account for this small gap in coverage of the 

data.

65

These cost savings were then allocated to passenger and cargo-only operations, again

using share of revenue departures for each carrier that were passenger operations or cargo-only 

operations in 2010 as reported in Database T1: U.S. Air Carrier Traffic and Capacity Summary 

 

64 The original RIA used a different method for estimating total payroll costs for the industry, but the resulting two 

cost estimates are very similar

65 The Form 41 data used in the original RIA only covered the first three quarters of 2010. This analysis factors 

those three quarters of data to account for a full year of pilot payroll costs. Tables C.3 in Appendix C provide details 

of these calculations.
73

by Service Class from the Bureau of Transportation Statistics. Each carrier’s passenger/cargoonly split was weighted by the number of pilots the carrier employs to create an overall 

passenger/cargo-only split for each industry group. The annual nominal value of the cost savings 

is approximately $19 million for passenger operations and an additional $4.4 million if the rule 

were extended to cargo-only operations. Table 23 provides details of these calculations of cost 

savings from reducing flightcrew member fatigue.

Table 23: Payroll Cost Savings from Reducing Flightcrew Member Fatigue

Industry 

Group

Annual 

Adjusted 

Total Pilot 

and CoPilot 

Costs1

(thousands)

Annual 

Total 

Payroll Cost 

Savings

from 

Reducing 

Fatigue2

(thousands)

Percent of 

Payroll 

Cost 

Savings 

Allocated 

to 

Passenger 

Operations

Percent of 

Payroll 

Cost 

Savings 

Allocated 

to Cargoonly 

Operations

Annual 

Passenger 

Payroll Cost

Savings 

(thousands)

Annual 

Cargo 

Payroll Cost 

Savings 

(thousands)

Passenger 

Integrated $4,710,694 $11,777 100% 0% $11,770 $6 

Passenger 

Narrow-body $1,750,075 $4,375 100% 0% $4,375 $0 

Passenger 

Wide-body $13,606 $34 100% 0% $34 $0 

Regional $1,162,836 $2,907 99% 1% $2,871 $36 

Supplemental $154,248 $386 30% 70% $115 $271 

Freight 

Integrated $1,473,257 $3,683 0% 100% $0 $3,683

Freight 

Narrow-body $67,816 $170 15% 85% $25 $145 

Freight Widebody $115,858 $290 21% 79% $61 $228 

Total $9,448,391 $23,621 $19,251 $4,370

1 Source: Table C.3

2 Adjusted Total Pilot and CoPilot Costs x 5% x 5%
74

Flight Operations Cost Summary

The total flight operations cost is composed of the additional crew scheduling costs 

(flightcrew member salary, hotel, and per diem), plus the computer programming costs, and less 

the cost savings from reducing flightcrew member’s fatigue. The total net nominal flight 

operations cost for the period of analysis is approximately $294 million for passenger operations. 

If the final rule were extended to cargo-only operations the total net nominal flight operations 

costs over the analysis period would increase by $479 million. Table 24 presents the nominal 

flight operations costs attributable to the final rule for passenger operations for each year in the 

analysis period. Table 25 presents the nominal flight operations cost for cargo-only carriers.

Table 24: Total Flight Operations Cost, Passenger Operations

Year

Scheduling 

Cost 

(millions)

Computer 

Programming 

Cost

(millions)

Payroll Cost 

Savings from 

Reducing 

Fatigue

(millions)

Total 

Nominal 

Cost 

(millions)

2012 $0

2013 $8 $8

2014 $48 -$19 $29

2015 $48 -$19 $29

2016 $48 -$19 $29

2017 $48 -$19 $29

2018 $48 -$19 $29

2019 $48 -$19 $29

2020 $48 -$19 $29

2021 $48 -$19 $29

2022 $48 -$19 $29

2023 $48 -$19 $29

Total $479 $8 -$193 $294
75

Table 25: Total Flight Operations Costs, Cargo-Only Operations

Year

Scheduling 

Cost 

(millions)

Computer 

Programming 

Cost

(millions)

Payroll Cost 

Savings from 

Reducing 

Fatigue

(millions)

Total 

Nominal 

Cost 

(millions)

2012 $0

2013 $2 $2

2014 $52 -$4 $48

2015 $52 -$4 $48

2016 $52 -$4 $48

2017 $52 -$4 $48

2018 $52 -$4 $48

2019 $52 -$4 $48

2020 $52 -$4 $48

2021 $52 -$4 $48

2022 $52 -$4 $48

2023 $52 -$4 $48

Total $521 $2 -$44 $479

Rest Facilities

The final rule establishes maximum flight-duty period limits for augmented operations 

that are dependent on the start time of the flight duty period, the number of flightcrew members 

assigned to the flight, and the class of rest facility installed on the aircraft. The final rule

establishes detailed specifications for each of the three classes of rest facilities. Class 1 rest 

facilities are most conducive to reducing the risk of fatigue in augmented operations; 

accordingly, the maximum flight duty time permitted for augmented operations conducted with 

Class 1 rest facility-equipped aircraft is greater than the maximum flight duty time permitted for 

augmented operations conducted with either Class 2 or 3 rest facility-equipped aircraft. The 

definitions of the rest facilities are as follows:
76

o A Class 1 rest facility is a bunk or other surface that allows for a flat sleeping 

position and is located separate from both the flight deck and passenger cabin in 

an area that is temperature-controlled, allows the crewmember to control light, 

and provides isolation from noise and disturbance.

o A Class 2 rest facility is a seat in an aircraft cabin that allows for a flat or near flat 

sleeping position; is separated from passengers by a minimum of a curtain to 

provide darkness and some sound mitigation; and is reasonably free from 

disturbance by passengers or crewmembers.

o A Class 3 rest facility is a seat in an aircraft cabin or flight deck that reclines at 

least 40 degrees and provides leg and foot support. 

There are four subcomponents of the rest facility cost component of the final rule. The 

first subcomponent consists of the rest facility design and engineering costs. The second 

subcomponent consists of the cost resulting from the physical installation of the facilities on the 

affected aircraft. The third subcomponent is the value of the aircraft downtime required to install 

the rest facilities. The final subcomponent is additional aircraft fuel consumption cost due to the 

weight of the rest facilities. We estimate that this engineering cost will be incurred in the first 

year that the rule is published (2012) to allow enough time for the facilities to be installed in the 

second year after the rule is published (2013).66 This work will need to be accomplished before 

the rule is implemented in 2014. Once a facility is installed on a particular aircraft, additional 

fuel will be consumed by that aircraft. For that reason, during the second year of the analysis 

 

66 Delay in issuing the final advisory circular related to rest facilities means that carriers may not be able to develop 

all the necessary engineering work in 2012. This means some of the costs anticipated for 2012 may shift to 2013 

and carriers may need to compress the time for installation of rest facilities. This would not change the nominal 

cost of the rule, and might decrease the net present value slightly due to costs being incurred further in the future.
77

period one-half of the estimated annual incremental fuel consumption is included in this cost 

analysis. The following paragraphs discuss how the FAA estimated each of the rest facility cost 

subcomponents, and Table 26 details the total cost of each of subcomponents for passenger 

operations while Table 27 presents the total costs for cargo-only operations. The total restfacility cost for passenger operations is approximately $146 million in nominal terms, $132

million when discounted at seven percent. If the rule were extended to cover cargo-only 

operations, the additional cost would be $66 million in nominal terms, $59 million when 

discounted at seven percent.67

Table 26: Rest Facility Cost Overview, Passenger Operations

Rest Facilities 

Cost 

Subcomponent

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Engineering $13 $13 $13

Installation $100 $94 $97

Downtime $12 $11 $12

Fuel $21 $14 $17

Total $146 $132 $139

 

67 These cost estimates differ slightly from those in the original RIA due corrections of some minor calculation 

errors present in the original RIA, a more significant error in how fuel costs were calculated, and changes in how 

carriers were classified.
78

Table 27: Rest Facility Cost Overview, Cargo-Only Operations

Rest Facilities 

Cost 

Subcomponent

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Engineering $3 $3 $3

Installation $48 $45 $46

Downtime $6 $5 $5

Fuel $10 $7 $8

Total $66 $59 $62

Engineering

During NPRM cost analysis, the FAA obtained detailed cost estimates from two 

supplemental type certificate (STC) holders. For the original RIA and this Initial Supplemental 

RIA, we delineated between engineering and kit/installation costs, as the engineering cost per 

operator would be a one-time, non-recurring cost for each type (make and model) of aircraft. We 

continue using the data provided by the STC holders as the basis for engineering and installation. 

The engineering costs are non-recurring design costs. These consist of system, development, 

engineering, analysis, and certification costs. We conservatively use the engineering cost of $0.5 

million per make/model as estimated by the STC holders. We estimate that 26 designs will be 

required for passenger operators while five additional designs would be required if the rule was 

extended to cargo-only operations.68 The estimates are derived from information gathered by 

FAA inspectors and are proprietary. The estimated engineering cost is approximately $13 million 

($0.5 million x 26) for passenger operators. If the rule were extended to cover cargo-only 

operations there would be additional $2.5 million ($0.5 million x 5) in costs.

 

68 In the original RIA, it was estimated that 25 designs would be needed. This estimate has changed because of 

changes in how carriers are classified.
79

Installation

Based upon public comments in response to the NPRM, the FAA has refined the estimate 

of the number of aircraft that will require rest facility installation. The FAA now estimates, based 

on data collected from FAA inspectors, that 225 aircraft used for passenger operations will need 

crew rest modifications to comply with the final rule.

69 This is an increase from the estimate of 

104 aircraft used in passenger operations in the NPRM cost analysis. However, it is lower than 

the estimates of some NPRM commenters. The FAA believes that the final rule estimate of 225

aircraft represents the worst case scenario because aircraft will be re-optimized based upon 

current configurations. The FAA estimates that any additional aircraft, beyond the approximate 

225 aircraft used in this analysis, will already have adequate rest facilities. Once the additional 

225 aircraft have rest facilities installed, each fleet will be re-optimized for the most efficient 

use. As such, we conservatively assume all of these 225 aircraft will have a Class 1 facility 

installed for an upper-bound estimation. If the final rule were extended to cover cargo-only 

operations, 107 additional aircraft would require facilities to be installed.

We continue to use the equipment and labor cost provided by an STC holder for our 

estimate of installation costs to the carriers. The kit and the installation for each of the individual 

airplanes will cost roughly $350,000 and $95,000, respectively. As such, the total cost of each 

installation will be roughly $445,000 ($350,000 + $95,000). When multiplied by the affected 

fleet of 225 aircraft used for passenger operations, the total facility installation cost will be 

approximately $100 million ($445,000 x 225). If the rule were extended to cover cargo-only 

 

69 All aircraft used in augmented operations by carriers conducting both cargo-only and passenger operations are 

included in this estimate, since it is not possible to identify whether aircraft are used exclusively in cargo-only

operations. In the original RIA it was estimated that 223 aircraft would require facilities to be installed. This 

estimate has changed because of changes in how carriers are classified.
80

operations, the additional total facility installation cost would be approximately $48 million

($445,000 x 107).

Downtime

Commenters indicated that an aircraft could be out of service for two weeks during rest 

facility installation. The FAA estimates the cost to Part 121 operators for this potential additional 

planned time out of service, or downtime, to install the rest facilities. STC designers have 

indicated that with proper planning, a modifier can install rest facilities in two to four days. We 

conservatively use a four-day estimate for the calculation of the downtime cost. The FAA 

conservatively assumes that if an aircraft was to be out of service for any part of a day, that

airplane would be out of service for the entire day.

For this analysis, the FAA uses the opportunity cost of capital to approximate the planned 

downtime cost to the operators. Using guidelines prescribed by the Office of Management and 

Budget, the FAA uses seven percent as a proxy for average annual rate of return on capital. The 

FAA uses $69 million as the estimated market value of an aircraft in this analysis.

70 The yearly 

opportunity cost of capital per aircraft would be $4.83 million, roughly $13,233 per day. When 

multiplied by the affected fleet (225 aircraft) and the days out of service (4 days), the downtime 

cost for the fleet is $12 million (225 x 4 x $13,233) for passenger operations. If the final rule 

were extended to cargo-only operations, the additional cost would be approximately $6 million.

 

70 November, 2010 The Airline Monitor. This number represents the appraised value of a 767-300. p.33
81

Fuel Consumption Costs

We have analyzed the costs associated with the design and installation of Class 1 rest 

facilities. We assume the rest facilities will be installed in the most efficient manner possible, 

with no impact on passenger seats or the revenue that they generate. As such, we do not estimate 

loss of revenue from a Class 1 rest facility because, as defined by the rule, the facilities will be 

located separate from both the flight deck and passenger cabin and will not necessarily require 

the removal of passenger seats. For example, a Class 1 rest facility can be located in the aircraft 

belly or overhead area, neither of which requires the removal of passenger seats. Although there 

will be no revenue impact, there will be an additional cost that will add to the aircraft operating 

costs due to the estimated additional impact of weight changes on each aircraft. Estimates for the 

additional incremental weight impact are used to calculate the additional fuel consumption for 

the affected fleet. 

The estimated cost of fuel uses data from the 2011 FAA Aerospace Forecast. We use the 

fuel consumption methodology as derived from the FAA’s guidance,71 along with the estimated 

average fuel cost of approximately $2.45 per gallon.

72 To calculate the additional annual cost of 

fuel per aircraft, we multiply the 300 additional pounds by the fuel consumption factor of 0.005 

gallons per hour per pound (consistent with a two-engine, wide-body aircraft) and arrive at 1.5 

gallons per hour per aircraft. This product is then multiplied by the average annual flight hours 

per aircraft of 2,380 and finally by the cost of fuel ($2.45) to arrive at the total annual estimated 

 

71 GRA, “Economic Values for FAA Investment and Regulatory Decisions, A Guide,” Oct. 3, 2007. 72 Average of annual system mainline fuel prices forecasts for period 2014 through 2023 (in FY 2010 dollars) from 

Table 18, FAA Aerospace Forecast 2011 – 2031. This estimate of fuel price differs from the original RIA.
82

additional cost of fuel per aircraft of $8,746.50.

73 When multiplied by the affected annual fleet 

(225 aircraft), the annual incremental fuel consumption cost is approximately $2 million. If the 

rule were extended to cover cargo-only operations, the additional annual incremental fuel 

consumption would be approximately $1 million.

Table 28 presents the estimated costs of each of the subcomponents described above. 

Table 29 presents the total rest facility costs for passenger operations while Table 30 presents the 

additional total rest facility costs if the final rule were extended to cargo-only operations. 

Carriers that conduct both passenger and cargo-only operations have all of these facilities costs 

ascribed to their passenger operations because FAA was informed that given the small 

magnitude of the rest facility costs, carriers would avoid having to manage two separate fleets, 

i.e. those aircraft with facilities and those aircraft without facilities.

Table 28: Rest Facilities Costs

Rest Facility Cost 

Subcomponent Unit Cost Passenger 

Quantity Passenger Cost Freight Quantity Freight Cost

Engineering $500,000 26 $13,000,000 5 $2,500,000 

Installation $445,000 225 $100,125,000 107 $47,615,000 

Down Time $52,932 225 $11,909,700 107 $5,663,724 

Annual Fuel Cost $8,746.50 225 $1,967,962.50 107 $935,875.50 

 

73 The estimate of additional weight (300 pounds) was provided by an STC holder. Fuel consumption factor of .005 

gallons per hour is from Table 6.1 of “Economic Values for FAA Investment and Regulatory Decisions, A Guide” 

(October 2007) written by GRA, Inc. The estimate of 2,380 annual flight hours per aircraft comes from BTS Form 41 

Schedule T2-restricted, based on data for the 12-month period October 2009 through Sept 2010 using Account 810

(Aircraft Days Assigned) and Account 650 (HoursAirborne) for a selection of aircraft.
83

Table 29: Rest Facilities Total Costs, Passenger Operations

Year Engineering Installation Downtime Fuel

Total 

Nominal 

Cost 

(millions)

2012 $13 $13

2013 $100 $12 $1 $113

2014 $2 $2

2015 $2 $2

2016 $2 $2

2017 $2 $2

2018 $2 $2

2019 $2 $2

2020 $2 $2

2021 $2 $2

2022 $2 $2

2023 $2 $2

Total $13 $100 $12 $21 $146

Table 30: Rest Facilities Total Costs, Cargo-Only Operations

Year Engineering Installation Downtime Fuel

Total 

Nominal 

Cost 

(millions)

2012 $3 $3

2013 $48 $6 $0 $54

2014 $1 $1

2015 $1 $1

2016 $1 $1

2017 $1 $1

2018 $1 $1

2019 $1 $1

2020 $1 $1

2021 $1 $1

2022 $1 $1

2023 $1 $1

Total $3 $48 $6 $10 $66
84

Fatigue Training

In accordance with the Airline Safety and Federal Aviation Administration Extension Act 

of 2010, Section 212, each air carrier conducting operations under Part 121 must have submitted 

a fatigue risk management plan (FRMP) to the Administrator for review and acceptance. A 

FRMP is an air carrier’s management plan outlining policies and procedures for reducing the 

risks of flightcrew member fatigue and improving flightcrew member alertness. In this final rule 

the FAA kept the requirement for pilots to receive fatigue training, but the original RIA and this 

Initial Supplemental RIA do not include an incremental cost of compliance because the operators 

are already in compliance with FRMP. The final rule introduces a new requirement for 

management, schedulers, dispatchers, and any other individual directly involved in operational 

control of the flight to have fatigue training and the requirement for curriculum development for 

that fatigue training. Therefore the original RIA and this Initial Supplemental RIA estimate the 

costs of these new requirements.

74 As shown in Table 31, this rule change reduces the fatigue 

training cost requirement to $17 million in nominal terms for passenger operations, $11 million 

when discounted using a seven percent discount rate. Table 32 shows that there would be an 

additional nominal cost of $6 million in fatigue training costs if the final rule were extended to 

cover cargo-only operations, $4 million when discounted using a seven percent discount rate.

 

74 The NPRM had originally included estimates costs for fatigue training and curriculum development for pilots.
85

Table 31: Fatigue Training Cost Overview, Passenger Operations

Training Cost Subcomponents

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Initial Training (First Year of Rule) $3 $3 $3

Initial Training (New Hires and Churn) $1 $1 $1

Recurrent Training $12 $7 $10

Curriculum Development $0 $0 $0

Total $17 $11 $14

Table 32: Fatigue Training Cost Overview, Cargo-only Operations

Training Cost Subcomponents

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Initial Training (First Year of Rule) $1 $1 $1

Initial Training (New Hires and Churn) $0 $0 $0

Recurrent Training $4 $2 $3

Curriculum Development $0 $0 $0

Total $6 $4 $5

The final rule requires that dispatchers and upper management having operational control 

over flightcrew members be given fatigue training. The number of dispatchers in the U.S. air 

transportation industry is equal to approximately three percent of the number of pilots.

75 FAA 

estimates the number of management personnel (immediate supervisors and schedulers) to be

approximately nine percent of flightcrew members. Therefore, the total number of dispatchers 

and management personnel required to receive fatigue training is estimated to be approximately 

12 percent of total flightcrew members. We further estimate that each manager and dispatcher 

 

75 VIS, October 22, 2009.
86

will require 5 hours of training when compliance with the final rule is required in 2012 which 

has been valued at a rate of 60 percent of the credit hour cost per flightcrew member for each 

industry group as found in Table 14. In out years, this initial training will need to be given to 

new employees entering the workforce and to employees who switch carriers due to industry 

churn. We estimate these groups account for 3.3 and 1.0 percent of the current workforce 

respectively. Additionally, in the out years the dispatchers and managers will require two hours 

of recurring training each year. These initial training costs are allocated to passenger and cargoonly operations, again using percent of revenue departures for each carrier that were passenger 

operations or cargo-only operations in 2010 as reported in Database T1: U.S. Air Carrier Traffic 

and Capacity Summary by Service Class from the Bureau of Transportation Statistics. Table 33

and Table 34 show the annual costs for these categories of training for passenger and cargo-only 

operations, respectively. For passenger operations, the final rule will result in $3.43 million in 

nominal fatigue training costs for management and dispatchers in the first year of the rule and 

additional $13 million in nominal fatigue training costs during the following nine years. If the 

final rule were extended to cargo-only operations, there would be an additional $1.14 million in 

nominal fatigue training costs for management and dispatchers in the first year of the rule, and an 

additional $4 million in nominal fatigue training costs during the following nine years.

In addition, carriers will incur a one-time cost to develop a fatigue training curriculum. 

According to industry standard, curriculum development takes three hours for each hour of 

course required. Therefore, the time needed to develop the initial training curriculum will be 

fifteen hours and the time needed to develop the recurrent training curriculum will be six hours. 

The FAA assumes that the wage rate of the curriculum developer is approximately $100 per 

hour. Each of the 67 Part 121 air carriers that had passenger operations will need to develop its 
87

own curriculum. The total nominal cost of curriculum training is $140,700. If the final rule is 

extended to cargo-only operations then there will be an additional $48,300 in nominal curriculum

costs for the 23 carriers that conduct only cargo-only operations.

76

Table 33: Total Fatigue Training Costs, Passenger Operations

Year

Initial Training

(First Year of 

Rule)

Initial 

Training 

(New Hires 

and Churn)

Recurrent 

Training

Curriculum 

Development

Total 

Nominal 

Cost 

(millions)

2012 $0.00

2013 $0.00

2014 $3,426,813 $140,700 $3.57

2015 $147,353 $1,311,784 $1.46

2016 $147,353 $1,311,784 $1.46

2017 $147,353 $1,311,784 $1.46

2018 $147,353 $1,311,784 $1.46

2019 $147,353 $1,311,784 $1.46

2020 $147,353 $1,311,784 $1.46

2021 $147,353 $1,311,784 $1.46

2022 $147,353 $1,311,784 $1.46

2023 $147,353 $1,311,784 $1.46

Total $3,426,813 $1,326,177 $11,806,055 $140,700 $16.70

 

76 The curriculum development costs associated with air carriers that conduct both passenger and cargo-only 

operations are counted under the costs associated with passenger operations.
88

Table 34: Total Fatigue Training Costs, Cargo-only Operations 

Year

Initial Training 

(First Year of 

Rule)

Initial 

Training 

(New Hires 

and Churn)

Recurrent 

Training

Curriculum 

Development

Total 

Nominal 

Cost 

(millions)

2012 $0.00

2013 $0.00

2014 $1,143,289 $48,300 $1.19

2015 $49,161 $437,651 $0.49

2016 $49,161 $437,651 $0.49

2017 $49,161 $437,651 $0.49

2018 $49,161 $437,651 $0.49

2019 $49,161 $437,651 $0.49

2020 $49,161 $437,651 $0.49

2021 $49,161 $437,651 $0.49

2022 $49,161 $437,651 $0.49

2023 $49,161 $437,651 $0.49

Total $1,143,289 $442,453 $3,938,859 $48,300 $5.57

Cost Analysis Summary

The cost of the final rule to Part 121 passenger operations over the twelve-year period of 

analysis is estimated to be $457 million in nominal value, $338 million when discounted at seven 

percent, or $398 million when discounted at three percent. Flight operations account for 

approximately 64 percent of the nominal total cost (58 percent of present value cost discounted 

at seven percent); crew scheduling cost is the largest subcomponent of flight operations cost. 

Rest facilities account for roughly 32 percent of the nominal total cost (39 percent of present 

value cost discounted at seven percent); rest facility installation is the largest subcomponent of 

rest facilities cost. Roughly four percent of the nominal cost of the final rule is attributable to 

training (three percent of present value cost discounted at seven percent).

If the final rule were extended to cover Part 121 cargo-only operations, over the twelveyear period of analysis there would be additional costs of $550 million in nominal value, $377
89

million when discounted at seven percent, or $464 million when discounted at three percent. 

Flight operations account for approximately 87 percent of the nominal total cost (84 percent of 

present value cost discounted at seven percent); crew scheduling cost is the largest 

subcomponent of flight operations cost. Rest facilities account for roughly 12 percent of the 

nominal total cost (16 percent of present value cost discounted at seven percent); rest facility 

installation is the largest subcomponent of rest facilities cost. Roughly one percent of the 

nominal cost of the final rule is attributable to training (one percent of present value cost 

discounted at seven percent). 

Table 35 and Table 36 summarize the results of the cost estimation for passenger and 

cargo-only operations, respectively. All final rule cost components were calculated using 

industry-provided data whenever possible, along with expert analysis. 

Table 35: Cost Summary, Passenger Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $294 $195 $245

Rest Facilities $146 $132 $139

Training $17 $11 $14

Total $457 $338 $398

Table 36: Cost Summary, Cargo-only Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $479 $315 $397

Rest Facilities $66 $59 $62

Training $6 $4 $5

Total $550 $377 $464
90

Benefit Cost Summary

The total estimated cost of the final rule as it applies to passenger operations over 12

years is $457 million ($338 million present value at seven percent and $398 million at three

percent). We provide a range of estimates for our quantitative benefits over the same period. Our 

base case estimate of the benefits of the final rule as applied to passenger operations is $401

million ($263 million present value at seven percent and $332 million at three percent) and our 

high case estimate is $757 million ($497 million present value at seven percent and $627 million 

at three percent). Therefore, the costs of the final rule are somewhat higher than the base case 

benefits estimate but well below the high case estimate. We also note that saving just 84 lives in 

a 10 year period would cause this rule to be cost beneficial.

77 Further, even if this rule was only 

36 percent effective at preventing accidents due to fatigue (as opposed to the 52.5 percent 

effectiveness estimated in this analysis) the rule would still be cost beneficial.78

The total estimated cost of the final rule as it applies to cargo operations over 12 years is 

$550 million ($377 million present value at seven percent and $464 million at three percent). We 

provide a range of estimates for our quantitative benefits over the same period. Our base case 

estimate is $5 million ($3 million present value at seven percent and $4 million at three percent) 

and our high case estimate is $31 million ($21 million present value at seven percent and $26 

million at three percent). Neither estimate results in positive net benefits. 

 

77 This comparison is made assuming the lives saved are distributed uniformly over the 10 year analysis period for 

benefits and using a seven percent discount rate.

78 This calculation is performed using the parameters from high case benefits analysis and uses seven percent as 

the discount rate.
91

Appendix A: Relevant Accident History
92

1. Accident DCA91MA021

A/C: DC-9-15, registration: N565PC Injuries: 2 Fatal

Date: 2/17/1991

Accident Summary: After takeoff, aircraft rolled to the right, then severely to the left past 

(90 degrees) and crashed. An ATC and some witnesses saw a fireball come out of the rear of the 

plane.

Probable Cause: Probable cause was determined to be failure of the flight crew to detect 

and remove ice from the aircrafts wings which was largely a result of lack of appropriate 

response by the FAA, Douglass aircraft company, and Ryan International airlines to the known 

critical effect that a minute amount of contamination has on the stall characteristics of the DC-9 

series 10 airplane. NTSB considered possibility that fatigue influenced pilots' judgment & 

decision not to conduct exterior preflight inspection of A/C. Crew had flown same night-time 

schedule for 6 days, & PIC for 12 of 13 days, averaging 3.8 flight hours & 5 landings each night. 

His schedule had recently increased from flying for 5 days, then 9 days off at home in CA. 

Though his family said he was used to night flying, recent increase in duty & flight time could 

have induced fatigue. But BTSB was divided on exact role of fatigue; some wanted fatigue as a 

cause, others did not. But fatigue's presence was not disputed. In the end, however, the Board 

could not reach a firm conclusion & excluded fatigue as a cause or factor.

Flight Crew/Fatigue Related Information: The captain flew six successive night flights 

the week before the incident, and flew another six successive night flights with the same first 

officer each night, including the night of the event. The total flight time for the six successive 

night flights, which included the night of the incident was 19.6 hrs. The first officer's total flight 
93

time in the 7 days prior to the incident was 19.6 hrs, accumulated all during six successive night 

flights with the same captain.

On the six successive night flights, the captain and first officer came on duty around 

2145. On the day before the accident, a van driver for the hotel overheard the pilots talking about 

how little sleep they get. On the day of the incident, an airline mechanic described the pilots as 

normal and rested. On the day of the accident, the operations supervisor stated the crew remained 

in the cockpit; normal crewmembers leave the airplane for a walk around. Supervisor described 

the captain as quiet and expressionless.

The captain was used to flying nights as a result of his military flying. Normal schedule 

was 5 nights on, 9 nights off. But a few weeks before accident, duty schedule changed as a result 

of airline contract to carry mail for US Postal Service. Airline subsequently hired new pilots and 

extended duty hrs of experienced pilots. The 2 weeks between his last visit home and the 

accidents were described as the longest period he had been on duty with the airline.

SCORE: 0.5 Requirements would place 200-hour limit on duty time in 672 consecutive 

hours (4 weeks). That might have changed PIC’s schedule substantially.

August 18,1999 in Guantanamo Bay

A/C: DC-8, N814CK Injuries: 3 Serious

Date: 8/18/1993

Accident Summary: Aircraft collided with level terrain after captain lost control of 

aircraft while approaching airfield.

Probable Cause: Probable cause was determined to be the captains impaired judgment , 

decision making and flying abilities of the night crew due to the effects of fatigue; the captains 
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failure properly assess the conditions for landing and maintaining vigilant situational awareness 

of the airplane while maneuvering onto final approach; his failure to prevent the loss of airspeed 

and avoid a stall while in steep band turn; and his failure to execute immediate action to recover 

from a stall

Flight Crew/Fatigue Related Information: At the time of the accident, the crew had been 

on duty for approx 18 hrs, having flown all night before accepting the accident flight. The board 

believes that the substandard performance by the experienced captain may have reflected the 

debilitating influence from fatigue. Captain testified feeling very lethargic and indifferent during 

the landing. First officer testified he felt fatigued earlier in the trip but felt exhilarated at the time

of the landing.

The board’s analysis revealed the captain had been awake for 23.5 hrs at the time of the 

accident, the first officer 19hrs and flight engineer 21 hrs. the accident occurred at the end of the 

afternoon psychological low period, the crewmembers had been awake the previous 2 nights, and 

had attempted to sleep during the day complicating their circadian sleep disorders - thus fitting 

the 3 scientific criteria for susceptibility to the debilitating effects of fatigue.

At 0830, before crew left airport, chief scheduler found GTMO flight needed crew & was 

told “no legal problem” as it was “international flight.” Scheduler determined crew could 

reposition to Norfolk Naval Base (NGU), pick up A/C, fly to GTMO, then ferry under Part 91 to 

ATL, & remain just within company 24-hour duty limit. Crew discussed timing & agreed to take 

trip, though “it was pushing the edge.”

CAUSE: impaired judgment, decision-making, & flying abilities of PIC & crew due to 

fatigue; PIC's failure to properly assess conditions; loss of situational awareness while 

maneuvering onto final; failure to prevent loss of airspeed & avoid stall while in steep bank turn; 
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& failure to execute immediate action to recover from stall. Factors; inadequacy of Part 121 

flight & duty time regulations, supplemental air carrier, international operations, & 

circumstances that led to extended flight/duty hours & fatigue; inadequate CRM training & 

inadequate training & guidance by carrier for crew on operations at special airports, such as 

GTMO; & Navy's failure to provide system that would assure that local tower controller was 

aware of inoperative strobe light so as to advise crew.

SCORE: 0.9 At time of accident, PIC & FO had been awake about 24 hours & on duty 22 

hours. After such a long day, crew was offered standard straight-in approach over ocean but they 

inexplicably chose very demanding approach in darkness. FE had said he got a rush on approach 

like they were shooting an approach to an aircraft carrier but FE noted that he was “tired & 

lethargic” as A/C approached airport & he “believed that the other 2 crew members were 

fatigued.” By including ferry flights, the requirements in this final rule affect duty-day limits 

would have precluded this crew from taking this flight.

3. Accident DCA94MA065

Date: 7/2/1994

July 2, 1994 in Charlotte, NC

A/C: MD-82, N954VJInjuries: 37 Fatal, 16 Serious

Accident Summary: Aircraft collided with trees and a private residence near the 

Charlotte/Douglas International Airport, Charlotte, North Carolina (CLT), shortly after the 

flightcrew executed a missed approach from the instrument landing system (ILS) approach to 

runway

Probable Cause: Probable cause was determined to be the flightcrew’s decision to 

continue an approach into severe convective activity that was conducive to a microburst: 2) the 
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flightcrew’s failure to recognize a windshear situation in a timely manner, 3) the flightcrew’s 

failure to establish and maintain the proper airplane attitude and thrust setting necessary to 

escape the windshear; and 4) the lack of real-time adverse weather and windshear hazard 

information dissemination from air traffic control, all of which led to an encounter with and 

failure to escape from a microburst-induced windshear that was produced by a rapidly 

developing thunderstorm located at the approach end of runway.

Flight Crew/Fatigue Related Information: The captain was off duty for 3 days before the 

beginning of the accident trip. On the morning of June 28, 1994, he flew with his National Guard 

squadron, which is based at Wright Patterson Air Force Base Ohio, near his home. On the day of 

the accident he awoke about 0455 drove to the airport in Dayton Ohio, and departed on a flight 

to Pittsturgh at around 0745. The reporting time for the trip that included the accident flight was 

0945, and the departure time for LGA was at 1045. The first officer flew a 4-day trip that ended 

around 0930 on July 2. On the day of the accident, he arose about 06 I5 and flew the leg to 

Pittsburgh that departed St. Louis at 0810. He arrived in Pittsburgh at 0030. 

SCORE: 0.15 Fatigue could have affected FO's performance (PF). PIC, who was off-duty 

preceding 3 days, was much less vulnerable to fatigue, but he too had already had a long day. 

Accident occurred 14 hours into PIC’s day. He awoke at 0455, drove to Dayton from home, then 

flew to PIT to begin duty day. Accident occurred at 1843, at end of third of 4 scheduled legs. His 

long day may have contributed to his failure to make 2 standard call-outs on approach at 1000 

AGL & 100 AGL. As NTSB notes, failure to make these call-outs contributed to PIC’s loss of 

situational awareness, his directing FO to go-around “to the right” instead of following runway 

heading as directed, & directing FO to “push down” after FO had initiated 15-degree nose-up & 

right banking turn. 
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FO was more vulnerable to fatigue. His duty day ended June 30 at 2230 at Blountsville, 

TN. NTSB report does not say when that duty day began, nor when FO awoke that day. At 

Blountville, he went to bed at 0130 & awoke at 0900. His next duty day ended at STL at 2040 

EDT. He went to bed at 2230 & awoke at 0615 on accident day. He then flew to PIT & began 

pairing with accident PIC. Like PIC, FO was nearly 14 hours into his day when accident 

occurred. He was PF on PIT-LGA leg & on accident leg from CAE. Fatigue could have 

contributed to incomplete pre-flight brief, failure to maintain sterile cockpit below 10,000 feet, 

approach briefing in which he omitted field elevation, FAF altitude, DH, & MAP altitudes, all of 

which NTSB noted had contributed to lack of situational awareness by both pilots. Finally, all 

the above contributed to crew’s choice to initiate non-standard go-around. Other factors were 

important, including ATC performance, A/C's inadequate windshear algorithm, & abnormally 

severe windshear. In short, hard to justify a high score, but equally hard to argue that fatigue was 

irrelevant.

4. Accident DCA95MA020

Date: 2/16/1995

NTSB Identification: DCA95MA020, Air Transport International

February 16, 1995 in Kansas City, MO

A/C: DC-8-63, N782AL Injuries: 3 Fatal

Accident Summary: Aircraft was destroyed by ground impact and fire during attempted 

takeoff.

Probable Cause: Probable cause was determined to be loss of directional control by pilot 

in command during the takeoff roll, flightcrews lack of understanding of the three-engine takeoff 
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procedures and their decision to modify these procedures and the failure of the company to 

ensure that the flight crew had adequate experience, training and rest to conduct the non-routine 

flight

Flight Crew/Fatigue Related Information: Safety board believes the captain and other 

crew members were experiencing fatigue at the time of the accident. The captain’s performance 

in the accident reveals many areas of degradation in which fatigue is probably a factor. Accident 

report notes a demanding Delaware -Germany overnight round trip flight (6 time zones crossed) 

and a daytime rest period which caused disruptions in circadian rhythms. Additionally, the 

captains last rest period was repeatedly interrupted by the company. Report also notes that since 

flight was non-revenue flight, it was under different duty rules and the same flight, were it a 

revenue flight, would have been illegal given the rest periods the crew had.

SCORE: 0.9 Fatigue was a significant problem in this accident. With or without crew's 

inadequate training & knowledge of 3-engine T/O, NPRM would preclude this crew from this 

ferry trip. Also, all 3 crew performed poorly & all 3 likely were fatigued, per NTSB, & all 3 

exhibited “performance degradation” symptomatic of fatigue (difficulties in setting proper 

priorities & continuation of T/O attempt despite disagreement & confusion on important issues). 

5. Date: 12/20/1995

NTSB Identification: DCA96RA020, American Airlines

December 20, 1995 in Cali, Colombia

A/C: B757-200, N651AA Injuries: 160 Fatal, 4 Serious

Accident Summary: Aircraft crashed 38 miles north of Cali, Columbia into mountainous 

terrain during a descent under instrument flight rules
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Probable Cause: Probable causes were determined to be the flight crew’s failure to 

adequately plan and execute the approach to runway 19 at SKCL and their inadequate use of 

automation; Failure of the flightcrew to discontinue the approach into Cali, despite numerous 

cues alerting them of the inadvisability of continuing the approach; The lack of situational 

awareness of the flightcrew regarding vertical navigation, proximity to terrain, and the relative 

location of critical radio aids; Failure of the flightcrew to revert to basic radio navigation at the 

time when the FMS-assisted navigation became confusing and demanded an excessive workload 

in a critical phase of the flight.

Flight Crew/Fatigue Related Information: 

At 2138 CFIT at 9000; peak at 9190. Night VOR/DME approach from MIA; 2 hrs late. 

PIC concerned to get cabin crew on ground to meet AAL rules on cabin crew rest (for next day 

return flight). Cali in long N/S valley; high terrain west & east. Cleared to Cali VOR; readback 

"cleared direct," entered "direct;" way points go off display. Later cleared to interim Tulua VOR. 

Expecting “direct,” crew became unsure of location. CVR shows crew fumbled with charts & 

Tulua ID, but already past Tulua. When crew finally entered Tulua, A/C began turning back to 

Tulua; PIC overrode. Then ATC offered direct approach from north (was 01; now 19). Crew 

rushed to get down. Put in single-letter ID for ROSO, but Colombia has 2 navaids with singleletter "R." Per ICAO, software defaults to "R" with more traffic (well north at Romeo VOR--

Bogota); had to punch in all 4 letters for ROSO. Again A/C began turning back. Crew now very 

confused & they knew it. FO (PF): "where are we?" PIC says go S/SE – now east of valley, 13 

miles off course & below terrain between A/C & Cali. Now more confused; reading DME to 

ROMEO, thinking it was ROSO. Stepped down early, configured to land as GPWS sounded. 
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Pulled up but did not retract spoilers; slow climb (184 knots at impact). Hit east slope nose up, 

skidded over top & down west side. Both pilots, 6 FA & 152 pax fatal; 4 pax serious.

CAUSE per Colombian CAA: 1. crew's failure to adequately plan & execute approach to 

runway 19 & inadequate use of automation; 2. Failure to discontinue approach, despite numerous 

cues; 3. lack of situational awareness regarding vertical navigation, proximity to terrain, & 

relative location of critical radio aids; 4. Failure to revert to basic radio nav when FMS-nav 

became confusing & demanded excessive workload. Factors: 1. crew's ongoing efforts to 

expedite approach & landing to avoid potential delays from exceeding company duty time limits; 

2. execution of GPWS escape maneuver with speed brakes deployed; 3. FMS logic that dropped 

all intermediate fixes from display(s) upon execution of direct routing; 4. FMS-generated nav 

information that used different naming convention from that published in nav charts."

SCORE: 0.35 Crew certainly would have been tired, despite being first of their duty tour. 

PIC had been awake close to 17 hours & FO had been awake at least 15 hours (14 & 17 hours 

are key thresholds in fatigue). Yet even if each had been operating earlier in their day, they likely 

would not have sorted out confusion created by single-letter identifier for Rozo & Romeo. Yet 

more rested crew may have avoided readback-hearback error related to “direct” with interim way 

points. Crew clearly knew they were very confused & that they were uncertain of their position 

in rugged terrain. More alert crew might have responded more appropriately, either by climbing 

above terrain to sort things out, or by reverting to radio nav until they re-established their 

position, or may have recognized that over-ride of northbound turn had pushed them across ridge 

line, east of valley. Though crew certainly would be tired, fatigue was less than a show-stopper. 

Key factors would have remained with or without alert crew: non-radar environment; confusion 

from multiple identifiers; self-induced pressure; unexpected change to unfamiliar step-down 
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approach at night in mountainous terrain; & significantly delayed flight. The requirements might 

have led to avoiding confusion or to more appropriate response to confusion.

6. NTSB Identification: NYC96FA174, TWA

August 25, 1996 in JFK, NY

A/C: L-1011, N31031 Injuries: None

Date: 8/25/1996

Accident Summary: Aircraft was substantially damaged when the tail struck the runway, 

while landing at John F. Kennedy International Airport, Jamaica, New York (JFK).

On arrival in JFK area, wx was 1⁄4-mile in fog, scattered at 200, & temp/dew of 66/66F. 

Crew expected 4R, but before reaching FAF, 4R went below minimum & ATC offered 4L (still 

above minimum). PIC accepted & FO (PF) transitioned to 4L. Inspection methods from 

Lockheed & adopted by TWA did not adequately specify how to check slat drive system for 

slack. 

But crew failed to reset altimeter bug for new runway (100 feet higher than 4R). PIC also 

missed several required call-outs on approach & no charts for 4L were on board. When PF asked 

for charts, PIC said “just fly the approach.” A/C was slow & unstable throughout approach & 

when altimeter read 50 feet (in fact 150 feet), A/C began to flare. FO recognized they were high 

& pushed nose over. On landing, A/C had tail strike & substantial damage. Failure to reset 

altimeter & absence of charts were fundamental in this accident.

Probable Cause: Probable cause was determined to be the failure of the flight crew to 

complete the published checklist and to adequately cross-check the actions of each other, which 
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resulted in their failure to detect that the leading edge slats had not extended and led to the 

aircraft's tail contacting the runway during the computer-driven, auto-land flare for landing.

Flight Crew/Fatigue Related Information: The captain reported that he had difficulty 

adjusting to disruptions in his sleeping schedule, and for this reason did not bid to fly 

international routes. According to his sleep schedule, he had been awake about 24 hours at the 

time of the accident and reported that he that he felt, ""awful, just tired and exhausted."" The first 

officer said that the captain attempted to rest during the cruise portion of the flight to JFK, with 

his head back in the seat, but that there were visiting crewmembers in the cockpit and the captain 

might not have received good rest. In addition, the captain commented that he had not slept well 

in the hotel.

The first officer reported that he had flown the LAS layover trip several times during 

July, and had learned the importance of good sleep for flying it. He reported that he had in excess 

of 14 hours of rest in the scheduled 24 hours of off duty, which was split over two periods. At the 

time of the accident he had been awake for over 9 hours following a rest in excess of 5 1/2 hours.

The flight engineer reported that she had not slept well in the hotel on the layover. 

Additionally, she reported that she felt rested when the accident trip began; however, at the time 

of the landing she was getting tired

SCORE: 0.35 Had crew been better rested, they may not have missed altimeter reset, 

may have recognized or acted upon unstable approach, or may have gone around, as required by 

company procedures when not stable at 500 feet. NPRM's treatment of night operations may 

have affected this flight. Conversely, crews have made similar errors when well rested & flying 

at mid-day. FAA believes that avoidable fatigue contributed to crew’s failures on approach.
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7. NTSB Identification: NYC99LA052, Colgan Air

January 22, 1999 in Hyannis, MA

A/C: BE-1900, N215CJ Injuries: None

At 1719 (dusk), Beech 1900D by Colgan substantially damaged on landing at HYA. No 

injury to PIC, FO & 2 employees as pax on positioning flight from BOS to HYA in IMC. Started 

taxi at BOS at 1600. T/O & en route uneventful. But RVR at HYA went below minimum while 

en route. Wx was 100-foot ceiling in fog, with variable winds at 3 knots.

On arrival at HYA, PIC performed 2 missed approaches. Before trying 3rd approach, he 

advised tower & pax that this was last shot, or they return to BOS. On third approach, both PIC 

& FO visually acquired runway. FO said PIC lined up with centerline & requested flaps. FO said 

A/C “floated at 20 feet over runway at normal transition when I heard PIC taking power levers 

over flight idle gate by sound of engine/props.' This placed prop in 'BETA' range. A/C then 

started to sink, & PIC pulled back on control yoke. 

Main gear struck ground & fractured during +2.9G touchdown, which occurred 2500 feet 

beyond approach end of 5,252 foot runway. Ran off right side of runway, 4700 feet beyond 

approach end & stopped. To place throttles in BETA, it was necessary to lift power levers over 

flight idle stop. Flight manual included warning: 'Do not lift power levers in flight.'

On accident day, PIC reported for duty at 0535, with first departure from HYA at 0620. 

He returned to HYA at 0920, after 3 flights & 2:31 flight time. Then with different FO, PIC T/O 

for Boston at 1100. They flew 5 more flights for 3:53 flight hours, then returned to BOS at 1540. 

Probable CAUSE: PIC’s improper placement of power levers in BETA position while in 

flight. Factors: fog & dusk conditions.
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SCORE: 0.15 Accident report summarizes only Captain's flight day, not his preceding 72 

hours. Clearly had a long day & difficulty getting into HYA did not help. Started taxi at BOS 

12.5 hours into duty day for flight to HYA, so he needed to be on ground at HYA within halfhour to beat new NPRM max duty day. May have precuded this PIC from this flight (or not –

close call). Also, though better rested PIC may have handled flare better, others have pulled 

throttle & props into beta. Fatigue might help explain PIC’s decision to take 3 shots at landing 

below mimium,

8. NTSB Identification: NYC99FA110, American Eagle

May 8, 1999 in JFK, NY

A/C: SF34, N232AE Injuries: 1 Serious

Accident NYC99FA110

Accident Summary: Aircraft sustained substantial damage during landing at John F. 

Kennedy International Airport (JFK)

Probable Cause: Probable cause was determined to be the pilot-in-command's failure to 

perform a missed approach as required by his company procedures. Factors were the pilot-incommand's improper in-flight decisions, the pilot-in-command's failure to comply with FAA 

regulations and company procedures, inadequate crew coordination, and fatigue

Flight Crew/Fatigue Related Information: On May 6, 1999, the captain went off duty 

about 2030, drove home, and was asleep about 2300. On May 7, 1999, he awoke about 0700. He 

attempted to nap about 1200, but was unsuccessful. He reported for duty about 2200. The first 

officer was off duty on May 6, 1999. He departed Las Vegas, Nevada (commuting on a 

jumpseat) at 1230, and arrived at JFK about 1730. He ate, then rested in the pilot's crew room, 
105

but did not sleep. There was a 3 hour time difference between Las Vegas and JFK. The trip 

sequence scheduled the pilots to depart JFK at 2246, arrive at BWI at 2359, on May 7, 1999; and 

depart BWI for JFK at 0610 on May 8, 1999. They were provided with individual rooms at a 

local hotel, approximately 10 minutes from the airport. Due to a takeoff delay at JFK, the 

flightcrew did not arrive at BWI until 0025. They arrived at the hotel about 0100. The captain 

stated that he was asleep by 0130. He awoke at 0445 for the scheduled 0530 van ide back to the 

airport. The first officer stated that he was asleep between 0130 and 0200. He received a wakeup call at 0445. During post-accident interviews, both pilots stated that they were fatigued.

At 0702, SF34 by American Eagle substantially damaged on landing at JFK; 1 pax 

serious; no injury to 26 pax, FA & 2 pilots. En route from BWI uneventful. On arrival in NY 

area, crew completed checklists & briefings for runway 04 when ATC advised crew that RVR 

for 04 was 1,600. Crew needed 1800 so ATC cleared them to holding fix at 4,000. While flying 

toward holding fix, RVR increased. ATC offered crew ILS approach, but advised that they might 

be too high. PIC accepted clearance nevertheless. Controller asked if crew could make approach 

from their position. PIC said yes & continued entire approach with excessive altitude, airspeed, 

& rate of descent, while remaining above glide slope. This violated company procedures & FAR

91.175. Crew then failed to respond to 4 audible GPWS warnings. During approach, FO failed to 

make required callouts, including missed approach callout. Landed 7,000 feet beyond approach 

end, at 157 knots, & overran. 

During interviews, both pilots said they were fatigued. Crew was working continuous 

duty overnight schedule. Continuous duty overnights (CDO) at American Eagle identifies trip 

sequence that is flown during late night hours, extending into early morning hours, with 

significant elapsed time period between one arrival & next departure. Since break between 
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flights is not sufficient to qualify as free from duty rest period, crew remains continuously on 

duty, though carrier may have provide hotel room for rest.

On May 6, PIC went off duty at 2030, drove home, & was asleep at 2300. On May 7, he 

awoke at 0700. He tried to nap about noon but was unsuccessful. He reported for duty at 2200. 

FO was off duty on May 6. He departed LAS (commuting on jumpseat) at 0930 local time on 

May 7 (1230 EDT) & arrived at JFK at 1730. He ate then rested in crew room, but did not sleep. 

Trip sequence scheduled crew to depart JFK at 2246, arrive BWI at 2359, & then depart BWI for 

JFK at 0610 on 5/8. They were provided with individual rooms at hotel 10 minutes from airport. 

But, due to delays at JFK, crew did not arrive at BWI until 0025. They arrived at hotel at 0100 & 

PIC was asleep by 0130. He awoke at 0445 for scheduled 0530 van ride back to airport. FO said

he was asleep between 0130 and 0200. He received wake-up call at 0445.

CAUSE: PIC's failure to perform missed approach as required by company procedures. Factors: 

PIC's improper in-flight decisions, failure to comply with FARs & company procedures, 

inadequate crew coordination, & fatigue.

SCORE: 0.5 Crew likely was tired, & helps to explain why crew did little right on or 

before the approach. Yet, the requirements would not reach the practice of “Continuous Duty 

Overnight, but it would have reached the FO’s continuous day starting with his commute. This 

would not have helped PI, but it might have ensured at least one alert crewmember.

9. NTSB Identification: DCA99MA060, American

June 1, 1999 in Little Rock, AR

A/C: MD-82, N215AA Injuries: 11 Fatal, 45 Serious

Accident DCA99MA060
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Accident Summary: Aircraft crashed after it overran the end of runway

Flight Crew/Fatigue Related Information: The captain went to sleep about 2200 the night 

before the accident and slept until between 0700 and 0730. On nonflying days, he would 

typically go to sleep between 2130 and 2200, wake up about 0515, and leave for work about 

0600. On May 30, 1999, the first officer traveled from his home outside Los Angeles, California, 

to Chicago. The first officer indicated that he had been commuting from his home to the 

Chicago-O’Hare base for about 3 months and that, as a result, he was adjusted to the central time 

zone. The first officer indicated that he was involved in routine activities while in the Chicago 

area. He went to bed between 2000 and 2200 the night before the accident and woke up about 

0730.

The board found that at the time of the accident (2350:44), the captain and the first 

officer had been continuously awake for at least 16 hours. Also the accident time was nearly 2 

hours after the time that both pilots went to bed the night before the accident and the captain’s 

routine bedtime (between 2130 and 2200), meaning their circadian systems were not actively 

promoting alertness. The Safety Board concludes that the flight crew’s degraded performance 

was consistent with known effects of fatigue.

CAUSE: failure to discontinue approach when severe thunderstorms & associated 

hazards to flight operations had moved into airport area, & crew's failure to ensure that spoilers 

had extended after touchdown. Factors: flight crew's (1) impaired performance resulting from 

fatigue & situational stress associated with intent to land under the circumstances, (2) 

continuation of approach when company's max crosswind component was exceeded, & (3) use 

of reverse thrust greater than 1.3 engine pressure ratio after landing.
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SCORE: 0.15 FO was 5 months into 1-year probation & paired with Chief Pilot from 

ORD base. But FO later testified of good working relationship with PIC & said rank of Chief 

Pilot was no barrier. Accident occurred 14 hours into duty day & nearly 17 hours after 

awakening. Long day & disrupted flight into & from DFW. FO showed signs on CVR of 

recognizing that landing was not a good idea, but PIC focused on landing. Was this fatigue or 

task fixation? Would more rest have made recently hired FO more willing to speak up to PICChief Pilot? Call-outs were made & SOPs indicate crew was engaged. Perhaps a less worn-out 

PIC would have considered diverting (or not), or may at least have responded to implied 

warnings from tower. Would have exceeded the requirements contained in this final rule by 12 

minutes at impact; may have changed sequence before T/O (had to be released by 2316 - - 2304 

might have made a difference).

10. NTSB Identification: DCA02MA054, Federal Express

July 26, 2002 in Tallahassee, FL

A/C: B727-200, N487FE Injuries: 3 Serious

Accident AAR0402

Date: 7/26/2002

Accident Summary: Aircraft struck trees on short final approach and crashed short of 

runway 9 at airport.

At 0537 (night), A/C destroyed by impact & post impact fire when it undershot on visual 

approach to 09, striking trees along extended centerline 3,650 feet short into black hole. FO 

flying. Wx: calm, visibility 8, clouds few at 100 & scattered at 2500. On arrival at TLH, FO 

briefed for visual to 27. Minute later he asked PIC if they should use 09 instead. Some discussion 
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followed but no decision. Ten 10 minutes later, SO asked pilots if they wanted to run approach 

checklist. FO again raised question of 09 vs 27 & crew decided on 09. Turned onto final 2.5 NM 

out. 

At this point PAPI would have indicated 1 white & 3 red (low). But A/C continued to 

descend below glide slope & was at 200 AGL at 0.9 miles out. PAPI would have shown 4 red. 

CVR shows no discussion about PAPI or altitude other than comment by FO that '(I'm) gonna 

have to stay just little bit higher... I'm gonna lose end of runway', to which PIC replied 'yeah... 

yeah, okay.' About 18 seconds later PIC commented 'it's startin' to disappear in there little bit 

(isn't) it? Think we'll be alright, yeah.' Then hit trees 11 seconds later. 

Crew believed they were on glide slope & showed no concern of undershooting. FO later 

said that 'from time I rolled out (on final), I saw that I was on glide slope... & it never changed.' 

Approach to 09 is over forest with no ground lights or other visual references (black hole), which 

can lead pilots to believe they are higher than they really are. NTSB notes that PAPI should have 

prevented this trap but FO's first class medical noted he had color vision defect. After accident, 

he failed 7 red/green vision tests. Specialists' report found that he had severe congenital 

deuteranomaly that could result in 'difficulties interpreting red/green & white signal lights.' 

Report added that '... he would definitely have had problems discriminating PAPIs... because red 

lights would appear not to be red at all, ... more indistinguishable from white than red... it would 

be extremely unlikely that he would be capable of seeing even color pink on PAPI... more likely 

combination of whites & yellows & perhaps, not even that difference.' 

Probable Cause: Probable cause was determined to be the captain's and first officer's 

failure to establish and maintain a proper glidepath during the night visual approach to landing.
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Flight Crew/Fatigue Related Information: The 3 accident flight crewmembers all had 

different flight, duty and sleep schedules before the accident. Flight and duty times since the last 

rest period for the caption, first officer and flight engineer are as follows: Captain (flight time -

1:23, duty time 2:35), first officer (flight time-4:02, duty time-10:29), flight engineer (flight 

time-3:43, duty time-10:41)

Captain reported not sleeping very well the 2 night leading up to the day of the accident 

but reported not feeling fatigued when he reported for the accident flight. Board found evidence 

of a sleep deficit for the captain based on reported sleep quality and small errors made during the 

accident flight the otherwise competent captain wouldn't normally make as indicated by past 

performance. First officer had normal sleep prior to accident, however he reported he felt good 

but he did not recall feeling alert and he seemed tired according to the captain. Board found the 

first officers sleep schedule was disrupted and found his performance deficient, which appears 

inconsistent with characterizations of his past performance. Flight engineer slept normally and 

appeared alert according to the captain and the board found minimal evidence he was fatigues, 

however his performance deficiencies may have been a result of workload during a rushed 

approach.

CAUSE: crew’s failure to establish & maintain proper glidepath in night visual approach. 

Factors: combination of crew fatigue, failure to adhere to SOPs, FO's color vision deficiency & 

PIC & FO's failure to monitor approach. 3 crew serious

SCORE: 0.75 Performance of both pilots was deficient & below their usual standard 

during approach. NTSB believes this was due to fatigue. Besides back-of-clock, both pilots had 

difficulty getting adequate rest before flight. PIC said his sleep 2 days before had 'not really 
111

(been) good' or had been 'marginal' because he kept being woken by family dog. FO said he had 

difficulty adjusting his sleep cycle & inferred he did not sleep well during day. Friend described 

FO as looking tired & PIC commented on same bus that he 'might be little tired.' Even with 

color-blindness, causal statement justifies concluding that a better rested crew may have avoided 

the whole scenario early-on in the approach. But unsure exactly how NPRM would have 

addressed this case, since rest periods were reasonable (even if not well managed) & accident 

occurred on visual approach over a black hole with a color-blind pilot trying to use a PAPI. The 

strongest argument for fatigue must rely on the notion that a better rested crew might have 

monitored the glide slope better and/or might have run a more disciplined checklist & prelanding brief, or that better rested PIC might have chosen the more common instrument approach 

to 27.

11. NTSB Identification: DCA05MA004, Corporate Airlines as American Connection

October 19, 2004 in Kirksville, MO

A/C: BAE-32, N875JX Injuries: 13 fatal, 2 Serious

Accident AAR0601

Accident Summary: Aircraft struck trees on final approach and crashed short of runway.

At 1937 on LOC/DME final at Kirksville in IMC, hit trees at 33 feet QFE on center line 

1.3 NM out. WX: wind 020 at 6, visibility 4, mist & 300 overcast. On final, PIC (PF) maintained 

constant descent of 1200 FPM until impact (met company SOP but exceeded that recommended 

by FAA for descent below 1000 AGL). At MDA, PIC said 'I can see ground there' (as PF, he 

should have been on instruments). Continued through MDA & asked FO 'what do you think?' 

FO: 'I can't see (expletive).' Seconds later PIC said 'yeah, there it is. Approach lights in sight' just 

as GPWS called “200” & FO announced 'in sight, continue'. (Both looking out window; nobody 
112

on instruments). Never recognized low altitude until seeing trees 2 seconds before impact. Wx 

complicated approach but crew never seemed too concerned about wx. Flew approach in casual 

fashion & lack of professionalism: no sterile cockpit (casual conversation); non-standard 

phraseology; humming; etc. PIC known for sense of humor & was said to 'emphasize fun in the 

cockpit'. 

Crew was fatigued: reported for duty at 0514. Accident was near end of 6th sector on 

'demanding' day in IMC. Crew had been on duty 14.5 hours & PIC is said to have slept poorly 

night before. PIC commuted from home in NJ to STL & FO commuted from Ohio. Reported for 

duty at 1345 on 10/17 (2 days before accident). Flew 3 flights in 8-hour duty day & arrived at 

over-night destination (Quincy) at 2125. On 10/18, departed Quincy at 1415 after more than 15 

hours off. Flew 3 flights & 6:20 duty day. Arrived at over-night destination in Burlington at 

1945. On 10/19, duty day began at 0514 after 9 hours off. Departed BRL at 0544 to STL & 

arrived 0644. Next 2 flights cancelled due to wx. T/O for round-trip from STL-Kirksville (IRK) 

at 1236. Landed STL at 1745.

Probable Cause: failure to follow procedures & improper non-precision instrument 

approach at night in IMC, including descent below MDA before acquiring runway environment. 

Factors: non-standard callouts; unprofessional demeanor; & crew fatigue.

Probable cause was determined to be the pilots’ failure to follow established procedures 

and properly conduct a non-precision instrument approach at night in IMC, including their 

descent below the minimum descent altitude (MDA) before required visual cues were available 

(which continued un moderated until the airplane struck the trees) and their failure to adhere to 

the established division of duties between the flying and nonflying (monitoring) pilot
113

Flight Crew/Fatigue Related Information: Captain reportedly did not sleep well the night 

before the accident but did not report feeling tired. He was later observed resting on a couch the 

morning of the accident. First officer reportedly did not have any trouble sleeping the night 

before the accident and the day of the accident seemed alert and happy. 

However, the flight crews rest time (2100-0400) did not correspond favorably with either 

ones sleeping patterns and at the time of the accident, they had been on duty 14.5 hrs and it had 

been 15 hrs since their last rest period. The board suggests that the pilot deficiencies observed 

could be consistent with fatigue impairment

SCORE: 0.75 Accident flight T/O STL at 1842 for IRK on 6th flight of day after 6:14 

flight time & 14.5-hour day already. Long, brutal day in IMC that started with limited rest 

period. Crew was familiar with each other & with IRK. WX & PIC's established practice of "fun 

in the cockpit" also were factors. Fatigue had to be a big player, though PIC's history of "fun in 

cockpit implies other issues. The requirements in this final rule would have precluded this crew 

from taking this flight.

12. NTSB Identification: DCA06MA064, Comair as

August 27, 2006, Lexington, KY

A/C: CRJ-200, N431CA Injuries: 49 Fatal, 1 Serious

Accident AAR0705

Date: 8/27/2007

Accident Summary: Aircraft crashed during takeoff from Blue Grass Airport, Lexington, 

Kentucky.
114

At 0607 Comair 5191 crashed on T/O from Blue Grass Airport (LEX) for ATL. A/C ran 

off end of Runway 26 & was destroyed by impact forces & post crash fire. T/O wrong runway; 

had been cleared to T/O on Runway 22. PIC, FA & all 47 pax fatal; FO serious. Threshold for 22 

& 26 are close & common taxiway had construction near thresholds, possibly inviting confusion 

in darkness after short taxi from nearby terminal. Also, sole controller in tower turned away after 

clearing A/C for T/O (A/C was the only active A/C on the airport).

Runway 22 had minor construction work underway preceding week with NOTAM for 

“some” lights out. Crew also appeared behind the curve early: approached wrong RJ on ramp 

(corrected by ramp staff); called Toledo tower rather than LEX (corrected by tower); called 

wrong flight number (corrected by tower); & vocally ran through checklist on taxi so quickly 

NTSB had to slow CVR read-out to understand it. Crew then taxied onto darkened, closed short 

runway (26). Initiated rolling T/O, further reducing chance to recognize wrong runway, crossed 

intersection with active runway, lighted 7,000-foot Runway 22, 500 feet from start of rolling T/O 

on 26, continued & rotated just as they ran out of pavement. Ran onto grass & nose lifted slightly 

(with main gear tracks deepening in grass) just as A/C struck perimeter fence, then rolled at high 

speed into trees & burned out. PIC, FA & 47 pax fatal; FO serious. CAUSE: crew's failure to use 

available cues & aids to identify A/C's location on airport surface during taxi & their failure to 

cross-check & verify that A/C was on correct runway before T/O. Factors: crew's non-pertinent 

conversation during taxi, which resulted in loss of positional awareness, & FAA's failure to 

require that all runway crossings be authorized only by specific ATC clearances.

Probable Cause: Probable cause was determined to be s the flight crewmembers’ failure 

to use available cues and aids to identify the airplane’s location on the airport surface during taxi 
115

and their failure to cross-check and verify that the airplane was on the correct runway before 

takeoff

Flight Crew/Fatigue Related Information: The captain and the first officer received more 

than the minimum required rest periods during their respective trips in the days before the 

accident, and their flight and duty times in the week and month before the accident would not 

have precluded them from obtaining adequate sleep. Also, both pilots had only been awake for 

about 2 hours at the time of the accident. Two factors in the pilots’ schedules just before the 

accident could have been associated with the potential development of a fatigued state: acute 

sleep loss and circadian disruption - The captain and the first officer also awakened on the day of 

the accident at a time when they would normally be asleep.

Overall, The Safety Board concludes that, even though the flight crewmembers made some 

errors during their preflight activities and the taxi to the runway, there was insufficient evidence 

to determine whether fatigue affected their performance

SCORE: 0.35 Fatigue likely was not an issue for PIC (PNF) but it may have affected 

FO’s performance (PF). FO began his duty tour on 8/25 at JFK. He drove that morning to FLL 

near his home for flight to JFK. Departed FLL at 0559 & arrived JFK at 0832. NTB does not 

note when FO awoke, but it likely would have been around 0400 to reach his 0559 departure at 

FLL. His duty day then began with flight from JFK to ROC at 1305. Return flight to JFK T/O at 

1600 but crew had to divert to BDL for fuel & did not land at JFK until nearly 2000. Due to late 

arrival, crew was asked to reposition A/C to LEX. Departed gate at 2130 but were not able to 

T/O until 2300; arrived at LEX at 0140. FO reached his hotel at 0210 on 8/26. By the time he got 

to bed, FO would have had nearly a 23-hour day. On 8/26, FO had day off. He told his wife that 
116

morning by phone that he had “slept in” & planned to go to bed early that night. Phone records, 

hotel key cards, & credit card records indicate normal day of activity through at least 1830 on his 

rest day, when FO paid for meal in hotel restaurant (probably asleep no earlier than 2000). On 

8/27 he & PIC reported for duty at 0515. FO likely had same wake-up call as PIC (0415).

Though FO had free day before accident, 8/25 was 23-hour day, with very late time to 

bed, followed on 8/27 by very early start to his day. Despite “sleeping in” on 8/26, FO would 

have been coping with sleep deficit. This could partly explain his confusion or inattention prior 

to departing gate. It also could have made him more vulnerable to visual confusion caused by 

minor construction & related barriers, & his failure to respond to visual cues of unlighted runway 

& crossing active runway that was fully lighted. Yet other factors also may explain these 

failures. For example, FO had flown into LEX 2 nights before when “lights were out all over the 

place.” That was at end of his 23-hour day; neither he nor that Captain apparently recognized 

that outages had been NOTAMed on 8/25. On morning of accident, runway end identifier lights 

were out of service. Closeness of 2 runway ends with single taxiway also increases risk of wrong 

runway T/Os. Finally, with terminal close to runway ends, taxi time was short, increasing 

percentage of head-down time, at least for PNF. The requirements would have precluded FO 

from taking positioning flight & extending very long duty day on first day. This may have 

averted the entire scenario.

13. NTSB Identification: DCA07MA072, Shuttle America

February 18, 2007, Cleveland, OH

A/C: ERJ-170, N862RW Injuries: None

Accident AAR0801
117

Accident Summary: Aircraft overran the end of the runway during a landing in snowy 

conditions and stuck an ILS antenna and fence, and the nose gear collapsed.

Flight Crew/Fatigue Related Information: The day of the accident, the captain had been 

awake for all but about 1 hour of the previous 32 hours; he stated that his lack of sleep affected 

his ability to concentrate and process information to make decisions and, as a result, was not “at 

the best of [his] game.” The captain also reported that he had insomnia, which began 9 months to 

1 year before the accident and lasted for several days at a time. From Feb 11-14 the first officer 

flew a total of 18hrs 27 mins. On Feb, he started a 3-day 6-leg trip and by the 18th, his total 

flight time was 11 hrs 50 mins. At the time of the accident, the first officer had been on duty 

about 9 hrs 15 mins with a total flight time of 5 hrs 30 mins. The first officer agreed to be the 

flying pilot because of the captain’s references to fatigue and lack of sleep the night before. 

A contributing factor to the accident was the pilot’s fatigue which affected his ability to 

effectively plan and monitor the approach and landing. The Safety Board concludes that the 

captain was fatigued, which degraded his performance during the accident flight.

CAUSE: failure to execute a missed approach when visual cues for runway were not 

distinct & identifiable. Factors: (1) crew's decision to descend to ILS DH instead of localizer 

(glideslope out) MDA; (2) FO's long landing on short, contaminated runway & crew's failure to 

use reverse thrust & braking to max effectiveness; (3) PIC's fatigue, which affected his ability to 

effectively plan for & monitor approach; & (4) carrier's failure to administer attendance policy 

that permitted crew to call in as fatigued without fear of reprisals.

SCORE: 0.5 A better rested PIC likely would have flown this leg, & likely would have 

increased chances of going around. However, it but probably would not have changed confusion 
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over glideslope & ILS DH versus localizer MDA. Either way, the requirements would have 

enabled PIC to opt out of flight.

14. NTSB Identification: DCA07FA037, Pinnacle as Northwest Express

April 12, 2007, Traverse City, MI

A/C: CRJ-200, N8905F Injuries: None

Accident AAR-0802

Date: 4/12/2007

Accident Summary: Aircraft ran off the departure end of the runway during snowy 

conditions.

Probable Cause: Probably cause was determined to be the pilots’ decision to land at TVC 

without performing a landing distance assessment, which was required by company policy 

because of runway contamination initially reported by TVC ground operations personnel and

continuing reports of deteriorating weather and runway conditions during the approach. This 

poor decision making likely reflected the effects of fatigue produced by a long, demanding duty 

day, and, for the captain, the duties associated with check airman functions

Flight Crew/Fatigue Related Information: The accident occurred well after midnight at 

the end of a demanding day during which the pilots had flown 8.35 hours, made five landings, 

been on duty more than 14 hours, and been awake more than 16 hours. During the accident 

flight, the CVR recorded numerous yawns and comments that indicate that the pilots were 

fatigued. Additionally, the captain made references to being tired at 2332:12, 2341:53, and 

0018:43, and the first officer stated, “jeez, I’m tired” at 0020:41. Additionally, the pilots’ high 

workload (flying in inclement weather conditions, and in the captain’s case, providing operating 

experience for the first officer) during their long day likely increased their fatigue.
119

SCORE: 0.9 Crew was clearly tired & had been on duty 15 hours as of accident time & 

12:44 hours at pushback; The requirements would have precluded this crew from taking this 

flight.

15. NTSB Identification: DEN07LA101, Great Lakes Airlines

June 20, 2007, Laramie, WY

A/C: BE-1900D, N253GL Injuries: None

Accident DEN07LA101

Date: 6/20/2007

Accident Summary: The airplane landed long, bounced, and touched down again. The 

captain tried to slow down and turn the airplane off the runway on to a taxiway at high speed. 

During the turn attempt, the airplane departed the runway and the airplane's right propeller struck 

the top of an electrical box that powered the runway approach lighting system.

Probable Cause: Probable cause was determined to be The pilot's improper decision, his 

misjudgment of his speed and distance, and his failure to perform a go-around resulting in the 

airplane overrunning the runway and striking an electrical box. Factors contributing to the 

accident were the failure of the crew to perform proper crew resource management, the first 

officer's failure to intervene before the accident occurred, and the electrical box.

Flight Crew/Fatigue Related Information: Only mention of flight crew schedule is the 

crew was on the third day of a three-day trip, which had started in Cortez, Colorado, that 

morning at 0520. The crew had flown from Cortez to Denver, Colorado, to Farmington, New, 

Mexico, back to Denver, then to Laramie, and then to Worland. 

SCORE: 0.15 Given number of days & segments flown, the accident occurred precisely 

at NPRM's proposed limit of 11-hour duty day. The requirements might have made a difference.
120

16. NTSB Identification: DCA09MA027, Colgan Air as Continental Connection

February 12, 2009, Clarence Center, NY

A/C: DHC-8-400Q, N200WQ Injuries: 50 Fatal

Accident DCA09MA027

Accident Summary: Aircraft crashed into residence 5 nautical miles northeast of the 

airport and was destroyed by impact and post-crash fires.

At 2217 Dash 8-Q400 by Colgan Air as Continental Connection crashed on ILS approach 

to runway 23 at BUF 5 NM NE of airport in Clarence Center. FO arrived EWR on red-eye from 

West Coast via MEM at 0623. First flight @ 1300 cancelled. Accident flight delayed; T/O EWR 

at 2120. Newly upgraded PIC (110 hours in M/M); FO (PF) had 700 hours in type. Steady, nonpertinent chatter enroute & throughout approach. FO notes little knowledge of icing. Other pilots 

describe light-moderate rime icing b/ 6,500 & 3,500 but none at 2,300. Accident A/C was in 

icing 9 minutes. De-icing system was "on" (which increases speed at which crews get low-speed 

cue, but does not affect actual stall speed). 

At 22:15:14 BUF Approach cleared flight for ILS approach to runway 23 

(acknowledged). At 22:16:02, engine power levers were reduced to flight idle & Approach 

instructed crew to contact Tower. Crew extended gear & auto flight system captured ILS 23 

localizer. PIC then moved engine conditions levers forward to max RPM position as FO 

acknowledged instructions to Tower. At 22:16:28 FO moved flaps to 10°, & 2 seconds later stick 

shaker activated (warning of impending stall) & autopilot disconnected, with ”disconnect” horn 

sounding until impact. Stickpusher then activated (to correct actual stall). Crew added power to 

75% torque. At 2216:37, FO told PIC that she had put flaps up; airspeed now 100 knots, & roll 
121

angle reached 105 degrees right wing down before A/C began to roll back to left & stick pusher 

activated second time (about 2216:40). Roll angle then reached 35 degrees left wing down before 

A/C began to roll again to right. FO then asked whether she should put gear up; PIC responded 

“gear up” with expletive. Pitch & roll had reached 25 degrees nose down & 100 degrees right 

wing down, when A/C entered steep descent. Stick pusher activated third time (at 2216:50), 

followed by impact. All 4 crew & 45 pax fatal; 1 ground fatal. (Not an icing accident.)

Both pilots likely were significantly fatigued. Both pilots were based at EWR. 

PIC lived near Tampa & FO lived near Seattle. Neither had “crash pad” at EWR & both 

regularly used crew room to sleep. PIC tried to bid trips that ensured some nights in hotels at outstations. At EWR he usually slept in crew room. FO always slept in crew room at EWR & was 

open about it. 

PIC, recently upgraded, commuted to EWR on 2/9 from TPA; arrived EWR at 2005 & 

spent night in crew room. Phone records & log-ins to crew tracking system indicate he got little 

sleep. Reported for duty at 0530 on 2/10, flew 3 flights & arrived at BUF at 1300& had hotel 

room. Left hotel at 0515 on 2/11 to report at 0615. Again flew 3 flights & returned to EWR at 

1544; spent rest of day & night in crew room. Again, phone, tracking system & contact with 

others indicate very little sleep. 

FO commuted to EWR from SEA. She awoke on 2/11/ at 0900, arrived at PDX at 1730 

for FedEx flight to MEM; arrived MEM at 0230 EST (2230 PST); had about 90 minutes of sleep 

on flight. She then T/O MEM at 0418 & arrived EWR at 0623, sleeping for “much of” 2-hour 

flight. At EWR, she spent day in crew room & napped, but phone, tracking system & 

conversations show she got little sleep. 
122

On 2/12, crew was scheduled for 3 flights: EWR-ROC; ROC-EWR; & EWR-BUF. First 

2 cancelled due to winds at EWR & ground delays. Dispatch estimated 1910 departure for 

accident flight. Multiple delays; pushed back at 1945 & finally T/O 2120 for BUF. FO noted 

multiple times that she was not feeling well & before T/O said she was “ready to be at hotel” at 

BUF. 

CAUSE: Captain’s inappropriate response to activation of stick shaker, which led to stall 

from which A/C did not recover. Factors: (1) crew’s failure to monitor airspeed in relation to 

rising position of low-speed cue, (2) crew’s failure to adhere to sterile cockpit procedures, (3) 

PIC’s failure to effectively manage flight, & (4) Colgan’s inadequate procedures for airspeed 

selection & management during approaches in icing conditions. NOTE: NTSB Cited fatigue in 

findings, but not in causal statement because NTSB said it could not determine “the extent of 

their impairment & degree to which it contributed to performance deficiencies.” But clearly 

suggests it did contribute. NOTE: NTSB was divided on the issue, with some arguing that the 

overwhelming issue was skills-based: pulling up to 30 degrees, not pushing power up all the way 

even well into the stall, and thereby missing several opportunities to allow the aircraft to fly out 

of the stall. In short, debate is this: though the crew clearly was fatigued, would the outcome 

have been any different if the same crew were better rested?

Flight Crew/Fatigue Related Information: On the day of the accident, the captain was 

scheduled to report to EWR at 1330. Because his duty period on February 11, 2009, had ended 

about 1544, he had a 21-hour, 16-minute scheduled rest period before his report time. However, 

at 0310 on February 12, the captain logged into Colgan’s CrewTrac computer system. This 

activity would have meant that he had, at a minimum, a 5-hour opportunity for sleep followed by 
123

another sleep opportunity of about 4 hours. During the 24 hours that preceded the accident, the 

first officer was reported to have slept 3.5 hours on flights and 5.5 hours in the crew room.

At the time of the accident, the captain would have been awake for at least 15 hours if he 

had awakened about 0700 and for a longer period if he had awakened earlier. The accident 

occurred about the same time that the captain’s sleep opportunities during the previous days had 

begun and the time at which he normally went to sleep. The first officer had been awake for 

about 9 hours at the time of the accident, which was about 3 hours before her normal bedtime. 

The captain had experienced chronic sleep loss, and both he and the first officer had experienced 

interrupted and poor-quality sleep during the 24 hours before the accident

The pilots’ failure to detect the impending onset of the stick shaker and their improper 

response to the stick shaker could be consistent with the known effects of fatigue. The NTSB 

concludes that the pilots’ performance was likely impaired because of fatigue, but the extent of 

their impairment and the degree to which it contributed to the performance deficiencies that 

occurred during the flight cannot be conclusively determined

SCORE: 0.5 Accident had many issues, but fatigue clearly was one of them. Both pilots 

had to be exhausted when they initiated approach to BUF. PIC was completing 4th day since 

awakening on 2/ 9. He had opportunity for quality sleep only on night of 2/10, & that was cut 

short with departure from hotel at 0515 on 2/11. Both pilots essentially stayed up all night on 

2/11, with no opportunities for deep sleep, then found themselves operating late-night flight after 

day-long cancellations & delays. At one level, any rule that might have diminished this crew's 

fatigue could have been a show-stopper with a high score. However, crew had other basic 

problems. PIC clearly was not well versed in stall recognition nor response to stall (never went to 

full power, which likely would have enabled the aircraft to fly out of the stall in at least 2 points 
124

during the sequence). Same lack of recognition & knowledge appears true of FO; she raised flaps 

during a stall. Being well rested would not have provided this crew with any more skill than they 

already had, it would not necessarily have averted the chatter sustained throughout flight, nor 

would it necessarily have led crew to enter proper ref speeds for conditions. BUT more rest may 

have at least kept them tuned in enough to monitor airspeed. That alone could have averted the 

entire scenario. However, too many other fundamental issues to score above 50%.

SCORE: 0.5 Accident had many issues, but fatigue clearly was one of them. Both pilots 

had to be exhausted when they initiated approach to BUF. PIC was completing 4th day since 

awakening on 2/ 9. He had opportunity for quality sleep only on night of 2/10, & that was cut 

short with departure from hotel at 0515 on 2/11. Both pilots essentially stayed up all night on 

2/11, with no opportunities for deep sleep, then found themselves operating late-night flight after 

day-long cancellations & delays. At one level, any rule that might have diminished this crew's 

fatigue could have been a show-stopper with a high score. However, crew had other basic 

problems. PIC clearly was not well versed in stall recognition nor response to stall (never went to 

full power, which likely would have enabled the aircraft to fly out of the stall in at least 2 points 

during the sequence). Same lack of recognition & knowledge appears true of FO; she raised flaps 

during a stall. Being well rested would not have provided this crew with any more skill than they 

already had, it would not necessarily have averted the chatter sustained throughout flight, nor 

would it necessarily have led crew to enter proper ref speeds for conditions. BUT more rest may 

have at least kept them tuned in enough to monitor airspeed. That alone could have averted the 

entire scenario. However, too many other fundamental issues to score above 50%.
125

Appendix B: Sensitivity Analysis
126

This appendix presents results from performing sensitivity analysis on four key 

components of the analysis supporting estimates of the costs of the rule:

• Adjusting for minor difference in aircraft block hours between baseline runs and final 

rule runs

• Weighting of individual case results to represent industry groups

• Percent of pilots who are reserves

• Percent of flightcrew sick time costs that could be saved due to the final rule

Sensitivity #1: Adjusting for Block Hour Discrepancy

As explained the body of this Initial Supplemental RIA, when reviewing the calculations 

supporting the estimates of crew scheduling costs due to the final rule, FAA became aware of a 

small difference in the number of aircraft block hours between the baseline runs and the final 

rule runs. This minor difference is due to the treatment of so called “carry-in/carry-out” flights. 

Industry practice is to construct each bid line such that each flightcrew member starts and ends 

the scheduling period at their home base. Some bid lines outputted by the optimizer would have 

left flightcrew members away from their home base at the beginning or end of the scheduling 

period (month). In those instances, it is airline practice to include those segments as part of the 

bid lines for the adjoining month (i.e., “carrying” the pilot in or out of the month). While that is 

reasonable practice for airlines, it introduced a source of variation in costs that was not caused by 

the final rule. Because the final rule results in different bid lines being constructed, the segments 

identified as carry-in or carry-out often differ as well. For all cases, the discrepancy in aircraft 

block hours was well below one percent. In some cases the aircraft block hours was greater in the 

baseline run while in other cases the final rule run had more aircraft block hours included.
127

To explore the possible impacts of this difference on the estimates of the cost impacts of 

the final rule, we factored the final rule run estimates of each of the four cost elements (credit 

hours, domestic and international TAFB, and hotel rooms) by the ratio of baseline aircraft block 

hours to final rule aircraft block hours for each case. If the final rule had slightly fewer aircraft 

block hours than the baseline run, the ratio would be slightly larger than one and the estimates of 

each cost element would increase slightly. The difference between the adjusted final rule runs 

and the baseline runs for each cost element for each case is presented in Table B.1. 

Table B.1 Adjusted Change in Monthly Flightcrew Scheduling Cost Elements due to 

Final Rule, by Case

Industry 

Group Case

Baseline 

Solution 

Flightcrew 

Members

Change 

in 

Credit 

Hours 

Change in 

Domestic

TAFB Hours 

Change in 

International 

TAFB Hours

Change in 

Hotel Stays 

Passenger 

Narrow-body

A 924 2,203 18,717 0 662

B 1,698 -503 -15,215 947 -952

Passenger 

Wide-body

C 1,121 -104 3,811 8,264 787

D 430 -872 0 -2,441 -30

Regional E 300 68 5,857 0 282

F 240 37 4,149 -15 144

Supplemental I 806 4,656 3,183 9,802 758

Freight 

Narrow-body G 330 594 1,014 2,402 59

Freight Widebody H 1,053 1,014 6,247 943 244

The rest of the scheduling cost estimation methodology is the same as described in the body 

of the Initial Supplemental RIA except that Table B.1 replaces Table 12. This approach in effect 

applies the average scheduling cost per aircraft block hour from the final rule run to the small 

difference in the number of block hours between the baseline and final runs as a method of 
128

neutralizing the impacts of the carry-in/carry-out issue. To precisely estimate the crew 

scheduling costs of each specific flight segment related to the carry-in/carry-out issue, a more indepth analysis would be required. As shown in Table B.2, this adjustment increased the 

estimated cost of the final rule for passenger operations by $2 million in nominal terms. Table 

B.3 shows that the adjustment increased the estimated cost of the rule for cargo-only operations 

by $16 million.

Table B.2 Cost Summary for Block Hour Adjustment, Passenger Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $296 $196 $246

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $458 $339 $399

Initial Supplemental RIA Total $457 $338 $398

Difference $2 $1 $1

Table B.3 Cost Summary for Block Hour Adjustment, Cargo-only Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $494 $325 $410

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $566 $388 $477

Initial Supplemental RIA Total $550 $377 $464

Difference $16 $10 $13
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Sensitivity #2: Alternative Weighting of Case Results

As explained in the body of this Initial Supplemental RIA, the estimates of crew 

scheduling costs from the rule are derived using crew scheduling software to build pairings and 

bid lines for nine cases for a baseline run that replicates current scheduling practices and a final 

rule run that replaces the current requirements with the final rule. These nine cases were 

combined to estimate average costs for each of the eight industry groups used in this analysis. 

The passenger narrow-body, passenger-wide body, and regional industry group each had two 

representative cases. The change in each of the cost elements was summed across the cases, 

multiplied by the appropriate unit price for the industry group, and divided by the combined total 

number of flightcrew members (lines) in the baseline run for both cases to derive the estimate of 

average cost per flightcrew member. For the freight integrated industry group, the change in each 

of the cost elements for the freight narrow-body case and freight wide-body case were summed, 

and then multiplied by the unit costs for the freight integrated industry group. For the passenger 

integrated industry group, the unit costs specific to the particular subcomponent of the passenger

integrated industry group were applied to the sum of the cost elements of the respective 

passenger narrow-body and passenger wide-body cases. Then the narrow-body and wide-body 

results were summed and then divided by the sum of the number of baseline solution flightcrew 

members. Such a method implicitly weights each case in relation to the number of flightcrew 

members in that case, which may or may not be an accurate representation of the prevalence of 

carriers with similar cost structures for the industry as a whole. As can be seen in Table 12, in 

some instances, the final rule caused very different cost impacts even for cases in the same 

industry group. For example, in the passenger wide-body industry group, Case C shows modest 

increases in the cost elements due to the rule, while Case D shows decreases in the cost elements 
130

due to the rule. Several different factors contribute to the differing impacts of the rule, including 

collective bargaining agreements, flight schedules, network structure, etc. Many of these 

attributes are difficult to observe for every carrier in the industry, and the limited number of 

cases means that an exact matching of every carrier to one of the case results is not possible. 

Therefore, it is difficult to determine what the appropriate relative weighting of the cases should 

be for extrapolation to the entire industry group. 

In the absence of information on how to weight the individual cases, an alternative to 

implicitly weighting the case results by the number of baseline flightcrew members, is to weight 

the two cases equally when deriving an estimate for those industry groups derived from multiple 

cases. 

An estimate of the change in each of the cost elements per flightcrew member for 

integrated industry groups was built from a weighted average of the change in cost elements for 

the respective narrow-body and wide-body industry groups. The relative weights for the 

passenger integrated industry group were based on the number of block hours for both narrowbody and wide-body aircraft flown by air carriers classified in the passenger integrated industry 

group multiplied by estimates of average crew size, as shown in Table B.4. A corresponding 

procedure was used for the freight integrated industry group. The resulting estimates of average 

scheduling cost per flightcrew member are found in Table B.5. The resulting total costs of this 

sensitivity are found in Table B.6 and Table B.7. Changing to this weighting scheme reduces the 

estimated cost to the passenger operations by $13 million in nominal terms and $9 million when 

discounted at seven percent. The impact on the estimated costs to cargo-only operations was 

larger, decreasing the costs by $39 million, $26 million at 7%. 
131

Table B.4 Relative Weight of Narrow-body and Wide-body Operations for Integrated 

Carriers

Industry Group Block Hours1 Average 

Crew Size2

Relative 

Weight

Passenger Integrated:

Narrow-body 4,054,243 2.00 54%

Wide-body 2,954,370 2.37 46%

Freight Integrated:

Narrow-body 38,311 2.00 5%

Wide-body 700,230 2.09 95%

1 Source: Form 41 Q1-Q3 2010

2 Source: Proprietary Carrier Data

Table B.5 Sensitivity Analysis on Weighting of Cases: Change in Flightcrew Scheduling 

Cost per Flightcrew Member due To Final Rule

Industry Group Monthly Cost per 

Flightcrew Member

Annual Cost per 

Flightcrew Member

Passenger Integrated $0 -$1

Passenger Narrow-body $185 $2,226

Passenger Wide-body -$292 -$3,507

Regional $83 $994

Supplemental $1,261 $15,133

Freight Integrated $379 $4,544

Freight Narrow-body $380 $4,555

Freight Wide-body $286 $3,435
132

Table B.6 Cost Summary for Alternative Weighting of Case Results, Passenger 

Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $281 $187 $234

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $443 $329 $387

Initial Supplemental RIA Total $457 $338 $398

Difference -$13 -$9 -$11

Table B.7 Cost Summary for Alternative Weighting of Case Results, Cargo-only 

Operations

Cost Component

Total 

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $440 $289 $364

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $511 $352 $432

Initial Supplemental RIA Total $550 $377 $464

Difference -$39 -$26 -$32

Sensitivity #3: Alternative Assumptions Regarding Percent of Flightcrew

Members Who Are Reserves

The estimates of costs are calculated on a per flightcrew member basis for each case. To 

extrapolate the cost impact of the rule to the entire industry, the estimated costs per flightcrew 

member are multiplied by the number of lineholder flightcrew members in the industry group as 

a whole. While the total number of pilots employed by each carrier is readily available from VIS 
133

data, information on the number of lineholders was not readily available. On average, it is 

estimated that 15 percent of pilots are reserves, at least for the large passenger network carriers,79

although this figure apparently varies widely across carriers. Data supplied by nine different 

carriers shows that the percent of total pilot workforce who are reserves varied from a low of 12 

percent at one carrier to as high as 26 percent at another carrier. Table B.8 and Table B.9 show 

the estimated cost of the final rule using a 12 percent assumption, for passenger and cargo-only 

operations respectively. Using a 12 percent reserve figure increases the total estimated cost of the 

rule by $17 million in nominal terms, and by $11 million when discounted at seven percent for 

passenger operations. For cargo-only operations, using a 12 percent reserve figure increases the 

total estimated cost of the rule by $18 million in nominal terms, and by $12 million when 

discounted at seven percent. Table B.10 and Table B.11 show the estimated cost of the final rule 

using a 26 percent assumption, for passenger and cargo-only operations respectively. Using a 26 

percent reserve figure reduces the estimated cost of the rule by $62 million ($41 million when 

discounted at seven percent) for passenger operations. For cargo-only operations, using a 26 

percent reserve figure reduces the estimated cost of the rule by $67 million ($44 million when 

discounted at seven percent).

 

79 “Productivity,” American Airlines Negotiations. Accessed on August 1, 2012 at 

http://www.aanegotiations.com/apaProductivity.asp.
134

Table B.8 Cost Summary for Alternative Assumption that 12% of Pilots are Reserves, 

Passenger Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $311 $206 $259

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $474 $349 $412

Initial Supplemental RIA Total $457 $338 $398

Difference $17 $11 $14

Table B.9 Cost Summary for Alternative Assumption that 12% of Pilots are Reserves, 

Cargo-only Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $497 $327 $412

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $568 $389 $479

Initial Supplemental RIA Total $550 $377 $464

Difference $18 $12 $15

Table B.10 Cost Summary for Alternative Assumption that 26% of Pilots are 

Reserves, Passenger Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $232 $155 $193

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $395 $298 $347

Initial Supplemental RIA Total $457 $338 $398

Difference -$62 -$41 -$51
135

Table B.11 Cost Summary for Alternative Assumption that 26% of Pilots are 

Reserves, Cargo Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $411 $270 $341

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $483 $333 $408

Initial Supplemental RIA Total $550 $377 $464

Difference -$67 -$44 -$56

Sensitivity #4: Alternative Assumption Regarding Percent of Sick Time 

that would be Saved Due to the Final Rule

Since it is not possible to precisely estimate the reduction in sick time that will result 

from the final rule, this section presents a sensitivity analysis to explore the possible range of 

impacts. In the central analysis of this Initial Supplemental RIA, it was explained that five 

percent of payroll costs are generally attributable to sick time and it was assumed that five 

percent of those sick time payroll costs would be saved because of the final rule. Table B.12 and 

Table B.13 show the results of assuming that three percent of sick time pilot payroll costs will be 

saved because of the final rule for passenger operations and cargo-only operations, respectively. 

While Table B.14 and Table B.15 provide the same information when assuming that seven 

percent of sick time will be saved due to the final rule, the two assumptions result in altering the 

total estimated cost of the rule by ±$77 million in nominal terms, and by ±$51 million when 

discounted at seven percent for passenger operations. For cargo-only operations, these two 
136

assumptions result in altering the total estimated cost of the rule by ±$17 million in nominal 

terms, and by ±$11 million when discounted at seven percent.80

Table B.12 Cost Summary for Alternative Assumptions that 3% Sick Time will 

be Saved, Passenger Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $371 $246 $309

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $534 $389 $462

Initial Supplemental RIA Total $457 $338 $398

Difference $77 $51 $64

Table B.13 Cost Summary for Alternative Assumptions that 3% Sick Time will 

be Saved, Cargo-only Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $496 $326 $411

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $567 $389 $478

Initial Supplemental RIA Total $550 $377 $464

Difference $17 $11 $14

 

80 If there were no cost savings from reduced fatigue, the nominal costs of the rule for passenger operations would 

be $649 million, $465 when discounted at seven percent. These estimated costs are still below the high case 

benefits estimates for passenger operations. 
137

Table B.14 Cost Summary for Alternative Assumptions that 7% Sick Time will 

be Saved, Passenger Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $217 $145 $181

Rest Facilities $146 $132 $139

Training $17 $11 $14

Sensitivity Total $380 $288 $334

Initial Supplemental RIA Total $457 $338 $398

Difference -$77 -$51 -$64

Table B.15 Cost Summary for Alternative Assumptions that 7% Sick Time will 

be Saved, Cargo-only Operations

Cost Component

Nominal 

Cost 

(millions)

PV Cost 

at 7% 

(millions)

PV Cost 

at 3% 

(millions)

Flight Operations $461 $303 $382

Rest Facilities $66 $59 $62

Training $6 $4 $5

Sensitivity Total $352 $366 $449

Initial Supplemental RIA Total $550 $377 $464

Difference -$17 -$11 -$14
138

Appendix C: Detailed Data Tables
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 aircraft 

utilization 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%

Explanation3 Operator1 Flightcrew 

Members1 Industry Group

Percent of 

Revenue 

Departures: 

Passenger2

Percent of 

Revenue 

Departures: 

Cargo-only2
Table C.1: Categorization of Air Carriers

Explanation3 Operator1 Flightcrew 

Members1 Industry Group

Percent of 

Revenue 

Departures: 

Passenger2

Percent of 

Revenue 

Departures: 

Cargo-only2

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 Pilots1 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 Pilots1 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 month
Table C.3: Adjusting Form 41 Pilot and CoPilot Cost Data

Industry Group

Pilot and 

CoPilot Costs 

Q1-Q3 20101 

(thousands)

Pilot and 

CoPilot Costs 

Q1-Q4 20102 

(thousands)

Total 

Pilots3

Pilots at 

Carriers 

that 

Report 

Form 41

Adjustment 

Factor

Adjusted Total 

Pilot and 

CoPilot Costs 

(thousands)

Passenger Integrated $3,498,191 $4,710,694 36,013 36,013 100% $4,710,694

Passenger Narrow-body $1,281,923 $1,726,249 11,899 11,737 101% $1,750,075

Passenger Wide-body $10,104 $13,606 150 150 100% $13,606

Regional $757,814 $1,020,479 20,511 18,000 114% $1,162,836

Supplemental $108,319 $145,863 1,674 1,583 106% $154,248

Freight Integrated $1,094,050 $1,473,257 7,230 7,230 100% $1,473,257

Freight Narrow-body $23,811 $32,064 846 400 212% $67,816

Freight Wide-body $86,037 $115,858 914 914 100% $115,858

Total $6,860,249 $9,238,071 79,237 76,027 105% $9,448,390.64

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