Sir - The article "Duty bound" (Flight International, 14-20 December, P32) is inaccurate both in detail and in the overall impression given.
The proposed flight and duty time limitations and rest (FTL) requirements contained in the draft JAR-OPS 1 Subpart Q were not "thought up" by the Joint Aviation Authorities (JAA) Operations Committee at the end of November 1994. Subpart Q has been under development since mid-1989 and has been the subject of widespread consultation.
The first took place between January and March 1993. The draft Subpart Q was considerably revised and a second round of consultation then took place between January and the end of April 1994. The Royal Air Force Institute of Aviation Medicine's comment, which you quoted is believed to have been, based on an earlier pre-consultation, draft.
In response to the second consultation, some 750 individual comments were received from unions (flight crew and cabin crew), operators' organisations, medical experts and national authorities. Each comment, was considered by the JAA Operations Committee, many giving rise to extensive debate. Representatives of operators' organisations and the unions have a voice on this Committee as well as the authorities of 18 JAA member states. As a result, Subpart Q has been further revised. The revision is simply the end product of the normal processing of comments arising from consultation on any proposed JAA requirements.
It is correct to say that to legislate on FTL is complex. Any set of rules governing this can only be considered as a total package and it is not possible to address only one aspect.
The data quoted on maximum duty times, do not represent accurately, the contents of the proposed final draft of Subpart Q. For a multi-pilot crew, the normal maximum flight-duty period (FDP), which starts when the crew reports for duty and ends when the crew goes off duty post-flight - is 14h (but only if that FDP begins between 07.00 and 11.59). For such an FDP, the crew will normally be permitted to make only two landings, although the authority may permit a third landing within one FDP on two occasions within seven consecutive days. If crewmembers report for duty at times other than those within this period, then different, lower, maxima will apply.
A more balanced view might have noted that the JAA's latest FTL proposals are substantially more stringent than those which apply in the USA, not noted for laxity on safety, nor for ignorance of aero-medical matters. The Operations Committee believes that these proposals represent the highest level of harmonisation attainable between the European aviation authorities.
K KOPLIN
Secretary-General
Joint Aviation Authorities
Hoofddorp, Netherlands
Source: Flight International
