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Association that set forth specific scenar- hours in the 14 duty hours. Current rules in advance that exceed the duty time.
ios that could affect a very small number allow up to 16 hours continuous duty • To ensure that pilots have an adequate
of all commercial pilots. The FAA’s re- time. opportunity to rest, off-duty time would
sponse, known as the “Whitlow Letter,” • Additional duty hours would be permit- be increased from eight hours to 10
was consistent with the agency’s long- ted only for unexpected operational hours under the proposal.
standing interpretation of the current rules. problems, such as flight delays. In no • Pilots would have to be given at least
In summary, the FAA reiterated that each event could such delays add more than one 36-hour off-duty period every seven
flight crewmember must have a minimum two hours to the pilot’s duty day. days. Current rules call for a 24-hour
of eight hours of rest in any 24-hour pe- • Airlines could no longer schedule pilots period.

riod that includes flight time. The sched-
uled flight time must be calculated using
the actual conditions on the day of depar-
ture regardless of whether the length of
the flight is longer or shorter than the orig-
inally scheduled flight time.
1999 Federal Register Notice
In response to concerns raised by the
pilot community, the FAA Administrator
notified the aviation community on June
15, 1999 that it had six months to ensure
that it was in full compliance with the
agency’s current flight time and rest re-
quirements. Reviews of airline schedul-
ing practices conducted in December
1999 and discussions with pilot unions
and airlines confirmed that the vast ma-
jority of pilots are receiving the amount
of rest required by the FAA’s rule.
1998 ARAC
In July 1998, the FAA tasked the Avia-
tion Rulemaking Advisory Committee
(ARAC) to work with the industry to
reach a consensus and develop a new pro-
posal. If no consensus could be reached,
the FAA would subsequently enforce the
current regulations. In February 1999,
ARAC reported that there was no consen-
sus. The group offered five different pro-
posals to update the flight and rest
regulations.
1995 Proposal For Pilots
In 1995, the FAA proposed a rule to
change flight time and rest limits. The
agency received more than 2,000 com-
ments from the aviation community and
the public. Most of those comments did
not favor the rule as proposed, and there
was no clear consensus on what the final
rule should say. Highlights of the 1995
proposal:
• Reduce the number of duty hours (the
time a flight crewmember is on the job,
available to fly) from the current 16
hours to 14 hours for two-pilot crews.
It would have allowed up to 10 flight
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