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A 10-year accident look-back is insufficient. The air
cargo industry has a relatively safe record, but
accidents have occurred. The FAA initially included a
20-year look-back in its analysis. Within those 20
years, four fatigue-related air cargo hull loss
accidents occurred. By reducing the look-back to 10
years, the FAA reduced the overall fatigue-related cargo
accidents to one, even though three had occurred in the
previous 10-year span.
ALPA estimates that, given the FAA’s total cost of
applying Part 117 to cargo air carriers, the net annual
cost of applying the pilot fatigue regulations to
all-cargo pilots would range from $1.1 million to $9.0
million, which for the industry as a whole is nominal.
The cost of this safety investment will be more than
made up by scheduling changes allowed by Part 117, and
if two accidents are assumed, the benefit would outweigh
the costs.
“Cargo pilots fly the same aircraft, over the same
routes, operate in the same airspace and use the same
airports,” said Capt. Moak. ”When you consider the
health benefits and do cost analysis using realistic
aircraft, the cost of protecting all airline pilots from
fatigue becomes nominal and is something the U.S.
airline industry simply must do.”
“While ALPA’s all-cargo members are on the front
lines of this issue, every member of the Air Line
Pilots Association is dedicated to advancing one
level of safety for all who depend on air
transportation in this country,” Capt. Moak
concluded. “We urge Congress in the strongest
possible terms to pass the Safe Skies Act of 2013
and bring all airline pilots under the FAA’s fatigue
rules.”
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