Upcoming 704 Fatigue Rules takeaways

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Sulako
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Upcoming 704 Fatigue Rules takeaways

Post by Sulako »

All planes that do any charter at all will have to follow these regs, but TC has said they will make these rules applicable for private flights also, and very soon. If you read the regs themselves, they are built in such a way that making them applicable to private flights will be really easy. After all, fatigue is fatigue.

To guarantee coverage, we will need the following:

4 crew for 14 out of 24 hours coverage per day, 6 days per week
6 crew for 14 out of 24 hours coverage per day, 7 days per week
8 crew for 24 hours per day coverage, 7 days per week


That sounds nuts but it's just math under the new regs.

As of Dec 12th, If we call a crew during their quiet time (730pm to 730am local for us) to inform them about a new charter flight, we can’t use them for 36 hours after the call. Last-minute trips are heavily penalized under the new regs.

20% reduction in yearly hours allowable per crew

Up to 36% reduction in Flight Duty Period (hours per day they can fly)
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digits_
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Re: Upcoming 704 Fatigue Rules takeaways

Post by digits_ »

Sulako wrote: Thu Jun 23, 2022 8:28 am but TC has said they will make these rules applicable for private flights also, and very soon.
Do you have a source for that? How will they apply them? Would it be an unofficial policy such as a mandatory change in an ops manual (eg, change it or we won't approve any future changes), or will they actually change some CARs?
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RoAF-Mig21
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Re: Upcoming 704 Fatigue Rules takeaways

Post by RoAF-Mig21 »

Sulako wrote: Thu Jun 23, 2022 8:28 am All planes that do any charter at all will have to follow these regs, but TC has said they will make these rules applicable for private flights also, and very soon. If you read the regs themselves, they are built in such a way that making them applicable to private flights will be really easy. After all, fatigue is fatigue.

To guarantee coverage, we will need the following:

4 crew for 14 out of 24 hours coverage per day, 6 days per week
6 crew for 14 out of 24 hours coverage per day, 7 days per week
8 crew for 24 hours per day coverage, 7 days per week


That sounds nuts but it's just math under the new regs.

As of Dec 12th, If we call a crew during their quiet time (730pm to 730am local for us) to inform them about a new charter flight, we can’t use them for 36 hours after the call. Last-minute trips are heavily penalized under the new regs.

20% reduction in yearly hours allowable per crew

Up to 36% reduction in Flight Duty Period (hours per day they can fly)
Thanks for explaining it so well. Reading the actual "regs" sounds like a foreign language to me. Much appreciated.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by digits_ »

Sulako wrote: Thu Jun 23, 2022 8:28 am

To guarantee coverage, we will need the following:

4 crew for 14 out of 24 hours coverage per day, 6 days per week
6 crew for 14 out of 24 hours coverage per day, 7 days per week
8 crew for 24 hours per day coverage, 7 days per week


That sounds nuts but it's just math under the new regs.
Why is that nuts?

If you want 24/7 coverage, it makes sense to have 2 day/night shift groups, so they can alternate to have days on/off.

24 hours per day coverage also sounds a bit misleading, what are you comparing it with? If you're comparing it with a current setup where there are 3 crew members on an eternal standby/callout schedule, then you do not have a truly 24/7 coverage, as your crew can't fly 24 hours straight.

Your 8 crew example improves this, and actually does give you the ability to fly the plane 24/7 if you'd want to. You're likely not comparing exactly the same situation.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by schnitzel2k3 »

digits_ wrote: Thu Jun 23, 2022 8:45 am
Sulako wrote: Thu Jun 23, 2022 8:28 am

To guarantee coverage, we will need the following:

4 crew for 14 out of 24 hours coverage per day, 6 days per week
6 crew for 14 out of 24 hours coverage per day, 7 days per week
8 crew for 24 hours per day coverage, 7 days per week


That sounds nuts but it's just math under the new regs.
Why is that nuts?

If you want 24/7 coverage, it makes sense to have 2 day/night shift groups, so they can alternate to have days on/off.

24 hours per day coverage also sounds a bit misleading, what are you comparing it with? If you're comparing it with a current setup where there are 3 crew members on an eternal standby/callout schedule, then you do not have a truly 24/7 coverage, as your crew can't fly 24 hours straight.

Your 8 crew example improves this, and actually does give you the ability to fly the plane 24/7 if you'd want to. You're likely not comparing exactly the same situation.
Imagine a private jet owner jumping from 2 to 8 crew to have round the clock coverage. Not going to happen. What this means is owners are going to just have to communicate and plan better and an already distressed charter market is going to get even worse.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by PeterParker »

This might be thing that finally does to Canadian aviation what the 1500-hour rule change did for the Americans and bring wages up to a better parity.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by JHR »

I heard some 2pilot companies are hiring a third on each plane. Good luck finding pilots.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by oakmoss1889 »

They've only had what, 4 years to come up with a plan? Any operator waiting til the last moment to adjust to the new regs deserves what they get imo.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by Dias »

Good. Maybe you can convince some airline types to come fly corporate now if they won't have to be married to their phone 24/7.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by ausbtav »

Aren't there private/fractional/charter operators that already have exemptions from the 704 duty regs? AirSprint comes to mind. Just curious if anyone knows for sure that these types of operators aren't going to find a way around the obvious improvements to pilot QOL. This change alone makes a big difference IMO "rest period begins when the flight crew member arrives in the suitable accommodation or when the flight crew member has access to the suitable accommodation"
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Re: Upcoming 704 Fatigue Rules takeaways

Post by JHR »

**** wrote: Thu Jun 23, 2022 9:41 am Good. Maybe you can convince some airline types to come fly corporate now if they won't have to be married to their phone 24/7.
Why would you want to?
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Re: Upcoming 704 Fatigue Rules takeaways

Post by digits_ »

schnitzel2k3 wrote: Thu Jun 23, 2022 8:54 am
digits_ wrote: Thu Jun 23, 2022 8:45 am
Sulako wrote: Thu Jun 23, 2022 8:28 am

To guarantee coverage, we will need the following:

4 crew for 14 out of 24 hours coverage per day, 6 days per week
6 crew for 14 out of 24 hours coverage per day, 7 days per week
8 crew for 24 hours per day coverage, 7 days per week


That sounds nuts but it's just math under the new regs.
Why is that nuts?

If you want 24/7 coverage, it makes sense to have 2 day/night shift groups, so they can alternate to have days on/off.

24 hours per day coverage also sounds a bit misleading, what are you comparing it with? If you're comparing it with a current setup where there are 3 crew members on an eternal standby/callout schedule, then you do not have a truly 24/7 coverage, as your crew can't fly 24 hours straight.

Your 8 crew example improves this, and actually does give you the ability to fly the plane 24/7 if you'd want to. You're likely not comparing exactly the same situation.
Imagine a private jet owner jumping from 2 to 8 crew to have round the clock coverage. Not going to happen. What this means is owners are going to just have to communicate and plan better and an already distressed charter market is going to get even worse.
24/7 coverage with 2 crew shouldn't have existed in the first place. So if that won't be possible anymore, I'd say that would be exactly the point of the new regulations.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by vanislepilot »

24/7 with 2 crew, been there done that for near 10 months. Worst time of my life. The job ceased in summer 2020, was really happy to get laid off because if I quit I'd get no juicy EI...
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Re: Upcoming 704 Fatigue Rules takeaways

Post by Sulako »

I agree that it's great that TC is finally dealing with fatigue - fatigue is real. The implementation is a pain because we are currently really struggling with training availability for corporate jets. An initial Challenger 604 course is now booking into May 2023, and an initial Citation Excel course is booking into January 2024. True story. Finding crew will be one thing, and then training them will be a huge issue. It already is.

The alternative is obvious - without lots of crew, the airplane just won't be available as often, and trips will have to be scheduled well in advance - the new system really penalizes last-minute trips. It's going to be a big task educating owners and changing their previous mindset, but it's going to be the law soon and we will be following it.
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Re: Upcoming 704 Fatigue Rules takeaways

Post by digits_ »

Sulako wrote: Fri Jun 24, 2022 8:35 am I agree that it's great that TC is finally dealing with fatigue - fatigue is real. The implementation is a pain because we are currently really struggling with training availability for corporate jets. An initial Challenger 604 course is now booking into May 2023, and an initial Citation Excel course is booking into January 2024. True story. Finding crew will be one thing, and then training them will be a huge issue. It already is.

The alternative is obvious - without lots of crew, the airplane just won't be available as often, and trips will have to be scheduled well in advance - the new system really penalizes last-minute trips. It's going to be a big task educating owners and changing their previous mindset, but it's going to be the law soon and we will be following it.
But do you have any source that indicates these changes will be applied to 604 operators?
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Re: Upcoming 704 Fatigue Rules takeaways

Post by CL-Skadoo! »

digits_ wrote: Fri Jun 24, 2022 8:50 am
Sulako wrote: Fri Jun 24, 2022 8:35 am I agree that it's great that TC is finally dealing with fatigue - fatigue is real. The implementation is a pain because we are currently really struggling with training availability for corporate jets. An initial Challenger 604 course is now booking into May 2023, and an initial Citation Excel course is booking into January 2024. True story. Finding crew will be one thing, and then training them will be a huge issue. It already is.

The alternative is obvious - without lots of crew, the airplane just won't be available as often, and trips will have to be scheduled well in advance - the new system really penalizes last-minute trips. It's going to be a big task educating owners and changing their previous mindset, but it's going to be the law soon and we will be following it.
But do you have any source that indicates these changes will be applied to 604 operators?
As it stands I haven't seen anything indicating it's being placed on 604 operators, YET. I can't imagine having to explain these regs to owners!
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Re: Upcoming 704 Fatigue Rules takeaways

Post by Sulako »

Fatigue is fatigue. Even TC knows that it doesn't matter if you are on a charter flight or not.

My source is the TC guy in a suit I had breakfast with last week. Feel free to ignore my post entirely if you think it's made-up, I have no emotional investment in "FYI" posts.

I'm gonna lock this post so it dies but I am going to make a larger sticky post about the upcoming changes shortly. It's hard to distill into a post - our company PPT is more than 100 slides on this. But I will try to just convey the relevant stuff.
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