Flight crew fatigue

With respect to the REPCON [Operator] wishes to respond to several comments made.

Regarding the 'increased commute time from the staff car park to the crew room', the car park used now is vastly closer than that used for many years (until around 2015) when most staff moved from the [Location A] parking facility to the long term car park (noting that a number of crew elected to stay with the longer transfer from the [Location A] parking lot until only a few months ago) and is currently not significantly different to the long term car park that had been used by most staff immediately prior to the COVID lockdowns. The following should be noted when comparing the distances and bus transfer times:

• The closest point distance between the new [Location] airport staff carpark and terminal [x] is 850 m (as the crow flies), versus the 350 m that existed between the long-term car park and terminal [x].
• The greatest distances between the two car parks and terminal though is a different story, with the previously used long term car park being actually further away than the new car park at the furthest point.
• The shuttle bus service runs every 10 minutes from the new car park with a travel time of approximately 3 minutes to the terminal and 4 minutes from the terminal (the time difference being the road pattern used in each direction). Whilst for the long-term car park, the bus times are approximately the same from the closest pick-up point and several minutes longer from the furthest pick-up point respectively (due to proximity and various pick-up points in the long-term car park).

It should be noted that at no stage does [Operator] require any staff to drive to work, as the mode or travel to work is an individual’s personal choice, and we just facilitate the option to use that car park at no expense to [Location]-based crew.

With respect to the statement that there is 'extended time on aircraft post shut down due to delays associated with relatively new disembarkation procedures', we would highlight that [Operator] applies the following policy regarding sign off times:

Sign-off for a duty period is to be:

• 15 minutes after the last flight of a domestic sector; or
• 30 minutes after the last flight of an international sector; or
• if positioning, the arrival time of the flight; or
• for a non-flying duty is that shown on a pilot’s roster.

In the vast majority of cases we find that flight crew complete their final flight deck duties well within the 15 minutes following shut down. This is why the airline can schedule turnaround times of aircraft with complete crew changes on an [aircraft type] in 40 minutes, allowing the signing off crew to complete their duty well within the 15 minutes and the oncoming crew commence their duties and be ready to commence boarding the aircraft with the next set of passengers at 22 minutes before the scheduled departure time (or 18 minutes after arrival).

It is impossible to know exactly when each pilot finished their onboard duties (could be at 8 minutes after shut down or 11 minutes, or even 15 minutes – which CASA recommends as an appropriate allowance). Hence it needs to be understood that the airline and the rostering crew control system used, does need set times that are automatically allowed for (as per those advised earlier from the operating manual). All large airlines log sign-off times in a similar fashion via an automated feed from the aircraft ACARS into the airline’s system and the automatic addition of the 15 (or 30) minutes following a flying duty to create an end to the duty period.

The reporter, in the unusual circumstance that they have completed their final flight deck duty action more than 15 minutes after shutdown (say due to an unforeseen circumstance like a non-normal occurrence after shutdown), is
entitled to choose to call crewing and notify of a delay and the reason why a delay occurred. That said, this is not be the norm though, as experience has shown that the 15 minutes is more than adequate for a domestic flight duty. Should a crew member call in to have crewing log the reason why the duty went beyond the scheduled additional time, then normally the duty pilot or another manager will be involved or made aware of the issue that led to the delay, allowing validation of the reported reason for the delay and then to consider why and manage the outcome (noting the turn-around times previously mentioned do need flight crew to be finished within the 15 minutes).

[Operator] does not believe the 'relatively new disembarkation procedures' take flight crew duties beyond the 15 minutes allowed for in the airlines system. Also of note, we have received no internal reports indicating this. Additionally, given no such reports have been lodged we would suggest to the reporter to use the [internal reporting system] to advise of this (as described in the operating manual).

With respect to the comment that there is 'a lack of written company procedures on the process that crew are to follow in the event of a delay after shut down to ensure extended duty periods are accurately recorded, inadvertently discourages crew from amending duty periods', we are of the belief that the system we have in place is fit for purpose with an automatic 15 (or 30) minute sign-off allowance following an operating duty. Also, when a significant event causes crew to remain on duty beyond that time (e.g. a nonnormal situation) then the involvement of the duty pilot or a manager will include considerations for the addition of extra sign-off time.

Additionally, we assume that the reporter has not considered that their industrial arrangements include a document titled the ‘roster protocol’, which states ‘the company shall record the standard sign-off times unless otherwise notified on a case-by-case basis by the pilot concerned, by telephone to the crewing department’.

Furthermore, as we have had no such reports from flight crew related to what the reporter has raised in the REPCON we would encourage the reporter to provide a report via the [internal reporting system] or write to flying operations management team on the matter.

Finally, as crew may choose where they live and what modes of transport they use to travel to and from work, we cannot build rosters for people who may choose to live great distances from work or for various modes of transport that may be chosen. [Operator] has a long established practice of rostering 12 hours off at home base (noting that this is actually where the 2019 revision to CAO 48.1 also arrived at for multi-pilot operations in Appendix 2 and is similarly reflected in the operator’s FRMS). This decision within [Operator] (as we cannot answer as to CASA’s decision process for CAO 48.1) was based on a review that indicated most people will take 45 minutes to an hour after waking to get ready and depart for work, and need about 30 minute following arrival at home to complete personal tasks and prepare for sleep, which leaves 2 hours and 30 minutes for travel to/from work (including if the pilot elects to use the staff car park, the very short transfer time from the staff car park). Hence, we do believe that the rostering of 12 hours in home base between duties in [Location] does provide a reasonable time to get 8 hours of sleep opportunity.

We trust that the feedback provided to this REPCON will be of benefit to the reporter and that the reporter may in due course also consider to report their concerns via the internal reporting system.