Commuting to your base: fatigue, the rules and how to plan it

A crew member who lives in one city and is based in another starts the first day of every trip with a commute the schedule doesn't see. Duty limits begin at report time. The flight to get there, the wait at the gate and the cab from the airport all happen before it, on your own time. That makes commuting one of the few fatigue risks that sits mostly with the crew member. What follows covers what the regulators say, what one accident investigation found, and how to plan a commute so you arrive fit to fly.

Why a commute is tiring

The FAA's advisory circular on fitness for duty, AC 117-3, describes the problem plainly. Commuters, it says, "normally plan their commute so they have at least 3 options (3 flights) to arrive at their domicile before their report time," which often means arriving several hours early. In its example, a 4-hour commute ends 3 hours before the report for a first day scheduled at 10 hours of duty. That day "could exceed 17 hours without a rest period."

The circular names a second trap. Because commuting eats into time off, commuters often travel "just before their report time, which increases the level of stress and the level of fatigue for that day." Stress adds to it. You watch the loads on standby, check the weather at both ends and know that a missed flight can mean a missed trip.

Hours awake are what matter most. The same circular notes that most adults hold normal alertness for about the first 16 hours awake, after which "most adults begin to notice reductions in the speed of performance and in alertness levels," more so after short sleep on the nights before.

What the FAA says

Under 14 CFR Part 117 a commute counts as your own time, so no limit in the tables covers it. What covers it is fitness for duty. Section 117.5 requires each pilot to "report for any flight duty period rested and prepared to perform his or her assigned duties," and to state before each flight that he or she is fit for duty.

In the preamble to the 2012 final rule, the FAA explained that this is a joint responsibility. The airline must provide "a meaningful rest opportunity," and the pilot "bears the responsibility of actually sleeping during the rest opportunity provided by the certificate holder instead of using that time to do other things." The FAA left commuting itself unregulated. It pointed to a 2011 report by the National Research Council, The Effects of Commuting on Pilot Fatigue, whose authors judged rulemaking on commuting premature, and left the door open to a future rule.

AC 117-3 is blunt about the extreme case. A pilot who commutes overnight for an 8 a.m. report and a 12-hour duty "has the potential for being awake at least 23 consecutive hours" by the end of it. "This kind of behavior is irresponsible commuting," the circular says, "and may contribute to an unsafe operating condition that is contrary to the Federal aviation regulations." It also asks airlines to set commuting policies, and pilots to "commute in a responsible manner."

What EASA says

The European rules take a similar line. Under ORO.FTL.115, crew members must "make optimum use of the opportunities and facilities for rest provided and plan and use their rest periods properly." The definitions in ORO.FTL.105 leave the trip from home to base outside duty: positioning excludes "the time of travel from a private place of rest to the designated reporting place at home base and vice versa."

The certification specifications add one concrete number. Guidance material GM1 CS FTL.1.200, in EASA's CS-FTL.1, says: "Crew members should consider making arrangements for temporary accommodation closer to their home base if the travelling time from their residence to their home base usually exceeds 90 minutes." Most air commuters are far past that.

What Colgan 3407 showed

On February 12, 2009, at about 22:17 EST, Colgan Air Flight 3407 lost control on approach to Buffalo and crashed into a house in Clarence Center, New York, killing 50 people. The NTSB's accident report found the probable cause in the captain's response to the stick shaker, not in fatigue. But fatigue and commuting ran through the investigation.

Both pilots were commuters based at Newark. The first officer left her home near Seattle at 19:51 PST the evening before, changed planes in Memphis and reached Newark at 06:23 EST, for a 13:30 EST report. The captain, who lived in Florida, had spent nights in the company's crew room.

Three of the NTSB's findings bear on commuting. The Board judged that the pilots' performance "was likely impaired because of fatigue," though it couldn't say by how much. It held that every pilot, commuters included, has "a personal responsibility to wisely manage their off-duty time and effectively use available rest periods so that they can arrive for work fit for duty," and that the two accident pilots had fallen short of it. And it put a matching duty on airlines, which must identify the risks of commuting, find ways to reduce them and make sure their commuting pilots are fit to fly.

The Board recommended (A-10-16) that the FAA require airlines to address commuting fatigue, including identifying commuting pilots, setting policies, using scheduling practices that reduce the risk, and finding rest facilities for them.

The 16-hour guide

The most useful single rule of thumb comes from the National Academies report, quoted in AC 117-3: "Pilots should avoid planning commutes or other pre-duty activities that result in being awake beyond approximately 16 hours before the scheduled end of duty, endeavor to sleep at least 6 hours prior to reporting for duty, and obtain more than 6 hours of sleep per day whenever possible."

The guide counts to the end of the duty, which changes the math. A commuter who wakes at 05:00 EDT for an early flight to base, reports at 14:00 EDT and is scheduled to block in at 23:30 EDT will have been awake 18.5 hours at the end of the day, past the guide before the first leg pushes back. Delays only add to it.

Planning the commute

A few habits cover most of the risk.

Work backward from the end of the duty. Take the scheduled release time, count back 16 hours, and that is roughly the latest you should wake. If the commute can't fit after that, it belongs on the day before.

Pick a flight with a backup. The safest choice is usually the latest flight that still has another good option after it. If the first one cancels or fills up, the backup still gets you there on time. The last flight of the day with nothing behind it is a gamble, especially in winter or thunderstorm season.

Go the day before when the numbers say so. An early report with no workable morning flight, a forecast of storms or snow at either end, or a long first day is reason enough to travel the evening before and sleep near base.

Have a real bed at the end of it. A hotel, a crash pad, a friend's spare room. The NTSB found that the Colgan pilots had used "an inappropriate facility" for their last rest, and one of the company's managers told investigators that pilots who slept in the crew room couldn't get adequate rest there.

Use the morning if you travel the same day. If your commute and report allow it, a nap after you get to base can buy back some of the hours awake. The FAA circular notes that for an evening report, a pilot who hasn't napped is more exposed to fatigue than one who has.

Know the policy, and use the fatigue call. Commuter policies differ a lot between airlines. Colgan's, the NTSB noted, said commuting would "in no way" be a mitigating factor; others protect a crew member whose listed flights all fail. Learn yours. If the commute went badly and you are not fit to fly, Part 117 and your company's fatigue program are there for exactly that.

Think about the trip home, too. The commute after the last leg of a trip raises the same questions in reverse. A long final duty followed by a late flight home, or the drive from your home airport, can be the most tired you are all week.

How LogAloft helps

If you set a crew base and a home airport and tick the commuting box in Settings, LogAloft looks for nonstop flights to base before each trip and back after it. It marks the latest flight with a backup behind it, flags tight connections, delays and bad weather at either end, and shows evening-before options when your arrive-by setting calls for them. The rest plan for the trip starts your body clock on home time. Coming up describes the commuting setup, and Rest is not sleep covers how to plan the layovers that follow.

None of this replaces your company's procedures or your own judgment about whether you are fit to fly.

For how LogAloft plans sleep around a trip, see How LogAloft plans your rest.

Sources

1. AC 117-3, Fitness for Duty, FAA, October 11, 2012
2. 14 CFR Part 117, Flight and Duty Limitations and Rest Requirements: Flightcrew Members, Electronic Code of Federal Regulations
3. Flightcrew Member Duty and Rest Requirements, final rule, 77 FR 330, Federal Register, January 4, 2012
4. The Effects of Commuting on Pilot Fatigue, National Research Council, 2011
5. Easy Access Rules for Air Operations, ORO.FTL.105 and ORO.FTL.115, EASA
6. CS-FTL.1, Certification Specifications and Guidance Material for Commercial Air Transport by Aeroplane, Scheduled and Charter Operations (ED Decision 2014/002/R), EASA
7. Loss of Control on Approach, Colgan Air Flight 3407, Clarence Center, New York, February 12, 2009 (NTSB/AAR-10/01), NTSB, February 2, 2010