In ALPA's view, the failure to consider the added strains of night flying and circadian stability is a glaring flaw. The FAA's NPRM is woefully deficient in this area because it completely ignores this critical issue. The FAA needs to reconsider this issue in its final rulemaking process. In ALPA's comments to the NPRM, we addressed not only the issues I have mentioned here but others as well. This document has been made available to the Subcommittee staff.
Pilot fatigue is a major safety concern for the traveling public.
ALPA highly urges this Subcommittee to encourage the FAA to finalize their rulemaking on this critical issue promptly.