Uh Oh: Emirates Cutting Pilot Staffing On Some Longhaul Flights Due To Pilot Shortage

Emirates has a pilot shortage at the moment, which is causing the airline to park planes at Dubai World Central and also to cut routes. Emirates pilots are leaving the airline to work at other airlines (especially in China) that offer more attractive compensation packages. There’s a global pilot shortage at the moment, and other airlines offer more pay and allow commuter contracts, while Emirates requires all of their pilots to live in Dubai.

Emirates claims they have quite a few cadet pilots in the pipeline and that this pilot shortage will be solved within a few months, though it sure seems to me like that’s not the case. Unless they change something, they’re going to keep losing pilots. Rather than trying to make things better for pilots, Emirates has just done something that has really ticked off a lot of pilots.

Emirates is reducing staffing (and thereby rest) for pilots on some ultra longhaul flights. As reported by pilots on PPRuNe, as of July 1, 2018, Emirates is reducing the pilot staffing on select ultra longhaul flights from four pilots to three pilots. Specifically, flights between Dubai and Boston, New York, Sydney, Melbourne, Rio de Janeiro, and Sao Paulo, will go from having four pilots to having three pilots.

The exact regulations regarding pilot rest vary by country. For example, at US airlines, flights between 8 and 12 hours require three pilots, while flights of over 12 hours require four pilots. This allows pilots to get rest during the flight, to ensure they’re well rested and alert. Other countries (not the US) allow “controlled rest,” which means that when two people are in the cockpit, one of them is allowed to doze off.

Regulations in the UAE aren’t as strict, so what Emirates is doing doesn’t violate government regulations, but when the government also owns the airline, that’s not terribly surprising.

Some pilots are in disbelief at this move. Emirates pilots already consistently report fatigue issues, given how many hours they fly, their short layovers, and the fact that they often have flights departing in the middle of the night. For example, Dubai to New York is blocked at 14 hours, so pilots could have to work that flight in the middle of the night, then have only a 24 hour layover in New York (where they’re spending a lot of time in traffic), and then have to fly back, all with reduced rest nowadays. Previously each pilot may have gotten six hours of rest on the flight, while that’s now reduced to four hours (or less).

I don’t want to say that I find this to be alarming, though I do generally find this trend at Emirates to be concerning. An airline’s primary responsibility is to transport passengers safely, and it sure doesn’t seem to me like Emirates is adopting “best practices” here. Airlines should do everything they can to be sure their pilots are experienced and well rested. Not only will their pilots be even more fatigued, but the general trend of putting brand new cadets in the cockpit of widebody jets while more senior pilots leave is problematic.

It’s time Emirates either improve pilot pay or conditions (like allowing pilots to be based in London or New York, for example, where they have several daily flights), or else this problem will only get worse.

Are you concerned about Emirates reducing pilot staffing on ultra longhaul flights?

Comments

  1. Great article but I think there’s a typo… “Airlines should do everything they can to be sure their pilots are experiences and well rested.” Is that correct?

  2. This is genuinely worrying – less experienced and less alert pilots carrying 500+ passengers.

    Surely Emirates would have to comply with the regulations for the countries it flies to as well?

  3. With all due respect Ben, making statements like “regulations in the UAE aren’t as strict” is irresponsible and ignorant. The UAE FDTL limits are based on the CAP 371 guidelines which is essentially the most comprehensive study of crew fatigue and duty time regulations. It isn’t perfect, but it is a different system from the US system that takes into account a variety of factors including circadian rhythms, reporting times, etc.. You are comparing apples and oranges.

  4. Pilots are getting paid a shit load but setting the “perks” being cut. Sounds like the normal working world to me.
    No unions, everyone has to fend for themselves, high stress. Good job boot strap people. Have fun.

  5. @ Sean M. — My apologies if that’s how it came across, that certainly wasn’t the intent, and I’ll always defer to you on this stuff. My point regarding UAE regulations not being as strict was that when it comes to pilot staffing they don’t have the same requirements (and by that I mean that they don’t have the same rules requiring three pilots for 8-12 hour flights, and four pilots for 12+ hour flights?). Maybe “strict” wasn’t the right word there.

  6. Did you mean to point out the irony that Emirates agreed not to add 5th freedom flights to USA at the time they don’t have enough pilots to add any flights at all? Very incisive editorial Lucky.

  7. What could possibly go wrong? At least they have great champagne to make up for the danger, amirite?

  8. @Lucky – There are areas where CAP 371 based regulations are more strict than FAA regulations and areas where the converse is true.

    For example, the FAA requires a clear 24 hours rest period per 7 days. This can be from 1500 hrs to 1500 hrs the next day for example. CAP 371 recommends a calendar day, which means a full “actual” day with 2 “local nights”.

    CAP 371 considers a duty period to commence from reporting time until sign-off and does not differentiate between duty hours spent flying or waiting between flights. FAA regulations allow long sits between flights to simply not count against the total flying hours limit for the day.

    Yes, there are cases where FAA regulations may seem more restrictive and hence “safer” and ULH flights is one such area. But on the flip side, crews operating multiple short sectors (or sectors with start times in the middle of the night) have more restrictive regulations under a CAP 371 regime.

    I suggest you download CAP 371 and read through it sometime if you want to really get a good understanding on fatigue in aircrews and what goes into developing an FDTL. The FAA itself would love to switch to a CAP 371 based regime by all accounts, but it is opposed by ALPA and politicians for reasons other than simple safety.

    Disclaimer : I have authored and had approved FDTL programs in multiple jurisdictions to comply with both FAA and CAP 371 guidelines at different times and have provided advisory services to various entities, including regulators, on this issue. I also currently serve as the Accountable Manager for an AOC where one of my statutory responsibilities is to ensure suitability and compliance with FDTL regulations, which is reviewed on an annual basis by the approving CAA.

  9. @Sean M.:

    You say it’s comparing apples and oranges, but that in itself would also be alarming to a layman like me since we’re talking about pilots being fit to fly. Full stop. That doesn’t seem like an apples/oranges case. Can you break it down further for us simpletons? Or, maybe Ben can have you guest author a post about it… I think that’d be an interesting read.

  10. For once debit finally said something not stupid. The working world sucks because those with leverage will always do everything in their power to screw over and profit from those with less leverage. But rather than telling the pilots tough luck, we should be working to unionize everyone. The only way the average worker can have any leverage is for all of them to band together and fight back for their basic rights that have been taken from them by the holders of capital. It also helps if there is a strong and proactive government to create common sense regulation and slap some huge penalties on those that abuse people with less power. Though in the case of these state owned enterprises it’s hard to believe that the government has the best interests of the people in mind. Middle Eastern princes are a case study in why you need a democratically elected government that can actually be held accountable. The royalty are nothing but criminals.

  11. Ray for once you grew enough brains to understand what I said. Don’t slide back now.

    The problem is there are many professions with ego driven dumb fucks who think they will sign up for mediocrity if the unionize. Engineering, Finance, medicine are all such fields. The pay is good but the stress is killing. And most of the pay is lost to high taxes and high cost of living. But they will still work to get that break considering somehow they are better them the system. Like I said, ego driven.

  12. @AdamR – Let’s use this analogy. In North America, one drives on the right of the street and in many jurisdictions can get a license at age 16. In Japan, one drives on the left of the street and the minimum age to drive is 18. Does that mean Japanese drivers are more safe than American ones because the rules are different and one component taken alone seems to be stricter?

    The purpose of flight duty time restrictions is to ensure that a crewmember is not institutionally required to undertake a flight duty when they have not been given the opportunity to be appropriately free of the effects of fatigue as a result of prior duty requirements. A regulator can achieve this in many different ways and the USA took a different approach to it than Europe did. The UK CAA conducted and published the results of a study called Civil Aviation Publication 371 (CAP 371) back in 1975 which has since been updated multiple times but has served as the inspiration for most of the world in developing comparable regulations in the interim. It should be noted that the FAA’s most recent revision of Part 121 duty limits is also based on CAP 371 and takes into account many but not all of the principles outlined there.

    CAP 371 states the following regarding ULH flying and additional crew (it should be noted that CAP 371 itself is only binding on UK operators and serves as “guidance” elsewhere).

    =============
    When any additional crew member is carried to provide in-flight relief with the intent
    of extending an FDP, that individual shall hold qualifications which are equal or
    superior to those held by the crew member who is to be rested. To take advantage
    of this facility the division of duty and rest between crew members must be kept in
    balance. It is unnecessary for the relieving crew member to rest in between the times
    relief is provided for other crew members.

    When in-flight relief is utilised there must be, for the crew members resting, a
    comfortable reclining seat, or bunk, separated and screened from the flight deck and
    passengers.

    A total in-flight rest of less than three hours does not allow for the extension of an
    FDP, but where the total in-flight rest, which need not be consecutive, is three hours
    or more, then the permitted FDP may be extended as follows:

    If rest is taken in a bunk :
    A period equal to one half of the total
    rest taken, provided that the maximum
    FDP permissible shall be 18 hours.

    If rest is taken in a seat
    A period equal to one third of the total
    rest taken, provided that the maximum
    FDP permissible shall be 15 hours.
    =============

    As you can see, there is a logic behind the regulations, and the limits are set to reflect the facilities available on the aircraft to ensure that crew are able to adequately rest if they want to during their rest periods.

    It should be clarified that current FAA regulations (FAR 117.17) also permit up to 17 hours of flying with 3 pilots provided the aircraft is suitably equipped with “a bunk or other surface that allows for a flat sleeping position and is located separate from both the flight deck and passenger cabin in an area that is temperature-controlled, allows the flightcrew member to control light, and provides isolation from noise and disturbance”.

    Therefore, if Emirates were a US carrier, they could operate exactly the same flights with 3 pilots anyway given the facilities they have on their aircraft.

    Two different systems thus reach the same conclusion by different methodologies. Neither is wrong in its approach, nor safer in its results – just different.

  13. @Sean M: Your information is out of date. FAA (Part 117) requires a 32hour/7day break. The 24/7 only applies to all-cargo operators (e.g. FedEx and UPS) who are exempt from FAA part 117 regulations. I can tell you from first hand experience that a crew of 3 on ULH (>12 hour flights) is a recipe for increased fatigue. This decision will just drive more pilots at Emirates to leave for better employment. I am a commercial airline pilot (former military) and am appalled at this decision. It goes against all safety and common sense principles.

  14. @ Sean:

    I wanted to ask if you had ever flown (as a pilot) ULH flights, or long haul, or crossed multiple time zones? In my experience, those that say “it is no big deal” have not had to live with the effects of their “studies”

  15. Sean M

    Unless you’ve actually operated an aircraft, as flight deck crew, in that type of encironment, I would assert that you are entirely unqualified to assume any authority on the matter of fatigue. I find it extremely worrying that we are at the mercy of pseudo scientists / lawmakers who derive income from airlines or thheir representatives. Until you have boarded an aircraft, operating as a pilot, having only slept a handful of hours and knowing the immense responsibilities you bear, you will never understand how absurd these rules are. Hotels are noisy, changes in time zones and eating patterns affect physiology, we cannot just fall alseep at will…….. These are but a few considerations that the pseudo scientists punting FDP’s either have not contemplated or just don’t care about.

  16. @Jeff – Yes you are correct that FAA has changed to 30/7 (not 32/7) for Part 121 operators, but still doesn’t require 2 local nights which was the point I was making to illustrate the difference.

    @Jeff and @MiddleEasternAviator – I am not saying that ULH with 3 pilots is safe or unsafe – as you point out I am neither a regulator nor a ULH operator and hence not in a position to make that determination at this point. What I am saying is that Lucky’s statement that US regulations are somehow stricter/safer than UAE regulations is inaccurate – the same operation would be permissable under both sets of regulations, for better or for worse.

    I do however believe there is a solid apolitical and scientific basis to the conclusions CAP 371 reaches, but the quantification of the limits imposed is always subject to ongoing review. The type of pan-directional operations with a possible mix of SH/LH/ULH flying in a short period such as the Middle Eastern operators are doing have not been studied in depth and may yet change perspectives in due course once that data is analysed. However, in the meanwhile the existing regulations are what they are and compliance with them is the minimum standard required.

  17. Unfortunately, ‘acceptable’ levels of alertness are now the standard and Flight Duty Limitations have become targets.

  18. @Sean M. You are making a lot of inaccurate statements. No US airline would be able to operate JFK/BOS/EWR-DXB with 3-crew. It has to be 4-crew(2 sets). For heaven sake most flights over 9hrs have 3-crew. Yes, it is up to local CAA where the carrier is registered, until the inevitable happens. There are only a handful countries operating ULR flights like Australia and India. Every one else making the rules stricter, not making easy on airlines.

  19. Sean M,

    I will ask you again, as you are at pains to elucidate that your are a post-holder and clearly have a thorough working knowledge of the regulations such as they are.
    My assumption is that you have rarely if ever operated ULR sectors, moreover I suspect it’s been some time since you’ve operated on the coal-face as it were.
    The brutal reality is Emirates are reducing their safety margin and effectively rolling the dice in their quest to balance profit over safety, anyone seeking to explain or justify their actions based on a “scientific and apolitical” basis are merely using weasel words to fudge the reality.
    CAP 371s Genesis was a fudge to allow UK charter operators to operate back from Caribbean and Florida holiday spots two crew, legally, so please spare many of us on here who have been around long enough to know better.

  20. @Sean M. –
    “I do however believe there is a solid apolitical and scientific basis to the conclusions CAP 371 reaches, but the quantification of the limits imposed is always subject to ongoing review.”

    The information is already out there. You’ll be interested to note the Cathay Pacific has already just spent the last 3 years trialling 3-man ops HKG-LHR and had the trial independently reviewed by an independent third party fatigue sciences company (importantly… chosen by the company management… Not the pilot’s — apart from the flying the pilot’s had no part in the process) and the outcome was that all variations of base crewing and schedule failed on the basis of safety and fatigue (I think maybe one combination worked but was not deemed viable). The company really wanted this to happen, but to their credit have acted responsibly and stepped away from 3-man.

    Now whilst CX’s routes may not be direct apples with apples with EK… I think they are similar enough to compare in this scenario.

    The simple fact is that these FTLs, which are born out of theory rather than reality, & whilst looking good and ‘sciency’ on paper, when taken to their limits have been shown to be unworkable and did not stand up to the reality of the extremely fatiguing effects of LH ops… And the independent research, conducted by a fatigue sciences company engaged by a long haul operator, on real pilot’s flying real patterns, now shows this.

  21. @Sean M

    It is refreshing and delightful to read your comments- a lot of big and unfounded statements are made on a daily basis, it’s great that at least someone knows what they are taking about

  22. Let me put it this way..the CAP371 or any operator FTL is a LIMIT. I say that again in case some didn’t get me the first time. IT’S A LIMIT not a TARGET. Constantly chasing that target is the same as pulling and holding a rubber band to its maximum and expect it not to snap.

  23. @Sean M – excellent comments. So refreshing to have an expert comment on important issues. It’s a disservice to read the irresponsible statements in the article. They should stick to bread and air nozzles etc.

  24. Kudos to Sean M. for actually presenting verifiable facts instead of some people who think they should be the be all and end all solely because of their ‘experience’ and/or age.

  25. Deo, please explain to me as one of those “people” who knows I am the be all and end all when it comes to safety as the Captain of the aircraft, how my experience and/or age isn’t anything other than an advantage?
    When I sign for the aircraft I fly, I am legally obligated and empowered to ensure I am compliant with the relevant laws. I am also solely accountable for its safety as well as the safety of my crew and passengers, so please can you explain to me why when “people” as you eloquently put it believe through experience and maturity that this new policy, regardless of CAP 371, is foolhardy and dangerous, individuals such as yourself have difficulty accepting our hard earned opinions.

  26. When MH17 got shot down, it was flying through airspace that other airlines avoided – however Malyasian management took that risk, on their passengers behalf to save a few dollars on a more direct routing.

    Now here we are, Emirates already with mass Pilot fatigue – many near crashes last year – introducing this policy that no other airline would dream of – all on the passengers behalf, without them knowing about it.

    Does your booking say – ” $1 discount earned by removing a pilot. ” Would you be alarmed to read that?

    At what point do passengers get to say “you know what, we prefer to avoid unnecessary risk you may be taking with our lives by paying an extra $1 on our ticket.”

    Because that’s all it is – a penny pinching race to the bottom – passengers will pay for it, one way or another…

  27. @A380pilot and @Jaytee – Please don’t assume that I’m saying this is either safe or unsafe. I’m not qualified to make that assessment with the limited information that I have.

    What I am saying is that it is compliant with the regulations governing it and that attempting to compare individual aspects of regulatory systems as “stricter” in isolation is disingenuous. Neither CAP 371 nor the FAA system is perfect nor all encompassing and ULH operations in particular are on the cutting edge of new research and regulation.

    FDTL schemes like most safety regulations are not just numbers pulled out of a hat but the products of years of research and collective experiences.

  28. Sean

    The issue with Fatigue reporting Systems in the ME are numerous.

    “We didn’t receive many fatigue reports therefore they can’t be fatigued” is common from management.

    What they don’t say, is “that’s because we silently punish any pilot reporting fatigue, make their life hell and threaten their license”.

    You say fatigue – they hear lazy.
    You say sick – they hear lazy.
    You say discretion – they hear lazy.

    They ‘get away with it’ because in the ME they can. Then ‘getting away with it’ is used as an excuse to further push pilots towards the edge.

    Until one day….. flydubai981. Wasn’t that swept under the carpet very quickly.

  29. And let’s not forget about Emirates’ use of ‘factorisation’ of flying hours for augmenting crew members, ie where bunk time counts for nothing towards 28 day and 12 month limits. Still airborne with all the issues that has on the human body, but accruing nothing towards the above flying hour limits…….

  30. There will be (another) accident and EK will be blamed.
    The authorities allowing EK to fly to/from their territories and accepting these new rules will also be responsible.

  31. @Lucky, Kudos to you for covering these real issues.

    @Sean M, Why don’t you explain how 3-crew safely handle 14hr block flight with a possible diversion crossing more than eight time zones.

    A human is not a machine, an indisputable fact, even if a sophisticated software tells it is possible to push beyond human limits.

  32. I have flown these flights for over 23 years of my life, way before CAP371 was introduce into Aviation.

    In my view CAP371 should be rewritten as it was written many many years ago and outdated. It was written mainly in favor of the Airlines and not the Pilots. The Airlines does not want the govening bodies to change or alter CAP 371 as it will affect their operations badly.

    The duty hours on a Dubai to Rio or JFK can be between 18-22 hours, not counting the time you would be awake at home preparing and getting ready for this duty, which you can add 3 hrs onto the above times.

    This is roughly 21-25 hrs, in that, a Pilot’s get 3:45h maximum time away from the Flight Deck. Notice, I did not say “REST”, effective rest really is 1:45-2hrs. if he / she is lucky.

    CAP371 does not look at these numbers, if it did, it would definitely have to be rewritten. No mention of the turbulence or seat belt sign going on/off, the many announcements to strap in, interrupting this resting period.

    The regulators and planning think, or believe that laying in a bunk or on a seat at 37,000-43,000 feet is the same 1:45h rest as one’s bed at home or, a hotel room. All is aware this is not so.

    From my experience I can say this is a very dangerous and unsafe route that EK have choose to follow. Sad and a shame that such a prestigious company would choose to travel down this road.

    Safe flight guys.

    Captain371

  33. Emirates also has reduced staffing for cabin crews recently. From what i understand, Emirates has the highest passenger density for their aircrafts compared to other airlines. It was already tough job for the cabin crews previously but now they are reducing the staffing. Looks like Emirates is in bad shape. Is there any articles published for cabin crew reduced staffing?

  34. Sean M – I love reading your posts. And I think many here are not reading your post carefully but instead assuming you are on the “less safety” side.

  35. I personally find it more concerning that these experienced pilots whining to Sean are incapable of understanding incredibly simple arguments – even when their misinterpretations are directly corrected. Perhaps their flying regime has left them too fatigued to concentrate?

  36. @Sean

    I have to say this man… You are definitely not a pilot and you are perfect example of a do#chebag.

    Stop talking b**ls!it when you have never even flown anything.

    Its people like you who actually are responsible for accidents due to fatigue.

    By the way what’s your interest in this article ? Why are you so defensive for GCAA ?

  37. Dear Callum,

    The flying regime is also a part of the FDTL. It’s not just how many crew will operate what flight, but how much flying will each pilot do every month.
    Some pilot’s spend half the month out of home. Flying back to back. Jumping time zones. Fatigue is eminent threat in aviation. The problem is, nothing is being done to mitigate the threat.

  38. Callum

    When an individual compares what an entity, under scrutiny for dubious safety practises, does in comparison to benchmark organisations and suggests that it’s all the same, then he’s excusing their actions.

    When accidents occur, please remember your post and the ‘whining’ pilots that may have done a better job, had they been at their best.

  39. Now that you learned egomaniacs got your pissing contest out of the way, Lucky’s original point stands… in terms of that regulation/rule, the US is more strict. Whether the entire fucking system is stricter is a different question.
    But please, inform us of all things tangentially related to show us how smart you are.

  40. @Mattt – No, his point doesn’t stand. The new FAR 117 regulation DOES PERMIT US carriers to operate these flights with 3 pilots only provided certain conditions are met such as start time, prior rest periods, cumulative hours and rest facilities available. Very similar to CAP 371 in that respect.

    I don’t know where Lucky is getting his info about all 12+ hour flights requiring 4 pilots in the US because that is simply NOT the current regulation in FAR 117. Go look at Table C in FAR 117 and you will clearly see the limits for augmented crews, which shows a maximum FDP of 17 hours for 3 pilot crews with Class 1 rest facilities.

    I am calling Lucky out for posting “fake news” and then using those inaccurate assertions to try and draw negative comparisons to a different regulatory system, when the very basis of his assertion is false to begin with.

    I am not taking a position on whether Emirates’ actions are wise or safe or anything else. I don’t have enough knowledge of the basis behind their decision to make any such determination. I am simply saying that Lucky is being irresponsible and ignorant by making statements about flight safety across different regulatory systems by using falsehoods as his justification.

  41. Sean-

    Your assertion that a US carrier could operate this flight with this staffing is flat out wrong!!!!!
    FAR 117 would not allow a 17 hour duty day for these flights (though that is the max duty day if it is do to leave at a specific late morning time of day) In the case of DXB-JFK the duty day limit would be 15 hours for the DXB-JFK leg for one of their flights (leaves at 0250), 16 hours for the next flight, and 17 hours for the flight that leaves in the late morning. However, FAR 117.11 specifically limits the maximum flight time to 13 hours for 3 pilots!!! So, a 14 hour flight with three pilots regardless of rest facility available or time of day of departure is illegal by FAR. Additionally, the FARs now take into account the debilitating effects of traveling so many time zones and give an even further reduced duty day for the flights home, unless you stay at the layover for 36 hours duty free. Which since emirates is doing this because they don’t have enough pilots, I doubt they are willing to let the pilots stay in JFK (or BOS or wherever) for longer. but since they don’t have to comply with the FARs that the US carriers do, they don’t have to worry about that.

    To say that the FARs and CAP371 are different is accurate, to cherry pick the language and try to apply the most restrictive part of CAP371 to a section of the FAR that is less restrictive and not detail that you are not applying the FAR to the same set of circumstances as the CAP371 is misleading at best, and an outright lie at worst.

    To try to assert that CAP371 (which even you state they don’t have to comply with) is fine and nobody should worry about what is going on here is just plain laughable. Read both sets of rules fully and you will see that, while FAR 117 is not perfect, it is much more comprehensive and is based on modern scientific evaluation and takes a much broader (and more scientific) approach to how fatigue effects humans and how the flight time/ duty time rules should apply. What time does your duty day start? How many flights do you have in your duty day, what type of rest facility do you have onboard (for 3 or more pilot flights)? how much duty time have you had in the past week? how much in the past month? How much flight time have you had in the past month (28 days)? How many pilots are onboard? How much rest did you have before the duty period? did you have at least 30 hours of un-iterrupted rest in the last 7 days? Have you had rest of at least 36 hours in the current theater of operations (if more than 60 degrees from home base) ? All of things an more are used to determine duty and flight time in the new FAR, and not just one, but many of them would make what Emirates is doing illegal for a US carrier and for a good reason!

    Emirates is absolutely cutting safety corners and the fact that we let them fly in our airspace while we know they are doing this is unacceptable! To try to deflect this truth by referencing some of the restrictions in CAP371 is completely irresponsible.

  42. @bob – You’re making my point for me. You are asserting that one can’t compare regulatory systems by taking facts in isolation, and I completely agree.

    Just as a point of info though, assuming all other conditions were met with regards to start time, prior rest, etc.., JFK-DXB with 3 pilots would be legal even under FAR 117.11 as it is comfortably under 13 hours of FT (usually between 11:45 and 12:15) and the FDP comes in under 17 hours.

    So we are not talking about a huge disparity between the regulatory systems here. And once again, my comments are NOT intended to be either endorsement or condemnation of Emirates’ alleged plans – simply a holistic attempt to correct the statements made and put them into appropriate context.

  43. @Sean M. – You’re looking at FDP limits only. There’s also flight time limits in 117. To wit:

    §117.11 Flight time limitation.
    (a) No certificate holder may schedule and no flightcrew member may accept an assignment or continue an assigned flight duty period if the total flight time:

    (1) Will exceed the limits specified in Table A of this part if the operation is conducted with the minimum required flightcrew.

    (2) Will exceed 13 hours if the operation is conducted with a 3-pilot flightcrew.

    (3) Will exceed 17 hours if the operation is conducted with a 4-pilot flightcrew.

    Anything over 17 requires a Fatigue Risk Management System exemption, like LAX-SIN.

    Note that this is not “legal to start, legal to finish” or “scheduled.” You cannot block over 13 hours in the US without 4 pilots, period. Lucky’s point stands: Emirates’ plan would not be allowed for US passenger carriers because of stricter rest and augmentation requirements.

  44. @frasca – That is not what he said. He said that any flights over 12 hours REQUIRED 4 pilots under the US system. That is not true. You can operate with “flight time” (effectively the same definition of “block” that you use) of 13 hours and FDP up to 17 hours with 3 pilots. That is exactly what you posted.

  45. @Sean M Don’t be smart by using carefully crafted phrases like “Very similar”, “not talking about a huge disparity between”.

    Simply put, FAA exceptions become norm under GCAA. GCAA rules are bastardized CAP371. No where close to FAA rules.

    Similar is not equal, hence Lucky’s assertion stands. Give it a rest.

  46. Most airlines have a 90 minute report time for international flights. That is counted as part of the flight duty period (FDP) under FAR117. The max FDP is 17 hours for three pilots as long as the REPORT time is between 0700 and 1259 base time. But the longest flight time allowed by FAR 117 is 13 hours for three pilots. So the real max scheduled FDP restriction is 15.5 hours assuming the flight is ontime. If its delayed and the pilots’ report time was between 0700 and 1259 then they would be able to take a 1.5 hour delay before timing out with a 13 hour blocked flight. DXB to JFK is blocked at 13h55m. Flight times change depending in Wx and that is probably padded as well, but for scheduling purposes that is number airlines will use to determine legality. Lets just not include the 13 hour flight time limit and just plug in FDP times to FAR117.

    With an 0238base time departure for DXB to JFK (report time is 0108) max FDP is 15hr. 1355hr plus 1.5 hour is 1525hr duty day. So not legal under FAR117, unless the flight time on the release (pushback to parking) happens to be 26 minutes less. Even in the case of flight time being less that blocked on the schedule, any delay after push back would mean all three pilots time out. No airline operating under FAR 117 would schedule that close to the limit.

    The next flight departs at 0830, so the FDP would be legal under FAR117, but the 13h55m block time would still not be legal as stated in the first paragraph. Even if the flight plan came out with a flight time under 13hours, any delay after push back and before takeoff would lead to a return to the gate for recrewing.

    So, technically yes you can operate a flight up to 13 hours gate to gate with three pilots but most airlines that operate under FAR 117 crew all flights over 12 hours with 4 pilots to for operational integrity and safety.

  47. This kind of sounds like one of those situations where people are trying to raise the alarm… And then there’s gonna be an accident, or God forbid a catastrophe, and then suddenly all these alarm bells are gonna make people incredulous that they weren’t listened to.

  48. @Sean M you are wrong. I do this long haul flying for a US carrier for a living.

    The FARs limit unaugmented flight time during a FDP to eight or nine hours, depending on the time of report. Augmented flights have a limitation of 13 hours for a three-pilot complement, and 17 hours for FDPs with a relief crew. There are no block limits for FRMS flights.

    So no, no US carrier can do 17 hours with 3 pilots.

    Further, our contract requires 3 pilots for any block over 8, 4 pilots for any block over 12. We have a few FMRS flights and they took quite a bit of trials/testing for approval.

  49. There seems to be some sort of cultural arrogance, leading to a belief that the FAA regulations simply have to be better than the GCAA regulations because they are stricter. Over the past couple of decades, Arabs have displayed a far better ability to manage airlines (and airports) than Americans. So maybe we can give them the benefit of the doubt unless there is any evidence to the contrary.
    Dubai and its neighboring cities have dynamic and visionary leadership which believes in flexibility which is why my gut feeling is that this is likely to be a short term move because of a shortage of pilots.Emirates did say they have a large number of highly talented cadets who will be joining the fleet, and at which point we should not be surprised to see them revert to 4 pilots.
    It is flexibility in thinking which has led Emirates to record profits last year, and if it is the same management which has decided the new staffing requirements, I would think they already have done sufficient due diligence.

  50. @Sean M (and others reading…)

    I understand what you are saying and I deliberately did not enter into a debate comparing various rules and regulation. I acknowledge they are complex and there will always be debate as to what is safer.

    My point was that this has been tried very recently, by a comparable carrier who was very very eager to implement this, and their very own appointed fatigue science consultants found it to be less safe after looking at REAL DATA from an ACTUAL TRIAL. And to their the credit, CX management has acknowledged this stepped back from it on the grounds of safety.

    So if you ask the question “Does this decision by EK provide more safety or less safety?” the answer is “LESS SAFETY”.

    And before we go down the well worn trope of ‘just more whingeing lazy greedy pilots’ that I see some of the posters moving towards here, I would like to point out that at CX the pilots stood to receive a 7% increase in hourly duty pay on those sectors as well as more days off down route, more money in per diems, and more days off following the pattern, in return for flying 3-man LH sectors. To be clear, this was not about money and greed, but about passenger safety (and hey your safety is also our safety as we are onboard with you).

    So if pilot’s, who know and live the risks, are willing to turn down a 7% increase in their own duty pay (which is significantly more than a $50 saving on a cheaper ticket) because they think it is unsafe… maybe as a passenger you should consider this when doing your own financial/safety equation… “Why are the pilots willing to give up their own money over this issue?”

    Answer. Because when it comes to choosing more money or more passenger safety… the pilots choose safety.

  51. @JayTee,

    It will be proven unsafe only if you collect and process data, if you discourage your pilots from filing ASRs, there is no data to prove it unsafe, hence it is perfectly safe. FRMS is useless if input data is fudged.

    Passengers care less about flight crew. They care more about cabin crew looks. A simple spin like computers fly modern aircraft and pilots are occasional button pushers will keep passengers happy. Also claim 3-man crew is adequate and helps keep fares cheaper.

    Until the day one experienced captain and two fresh cadets doing canarsie approach after a quick medical diversion and pushing 17 hours.

  52. Also note that HKG-LHR is significantly shorter (blocked skightly less than 13 hours) than any of the routes EK is shifting to 3-person crew operations. (blocked at least close to 14 hours)
    If CX can’t do it at HKG-LHR, no way EK is doing DXB-JFK/etc safely with three crews.

    @Ziad
    That “flexible” approach to safety looks fashionable until safety bends then breaks with mass casualties. Won’t look pretty for EK since their planes are one of the densiest/largest planes operated in the world.

  53. Fatigue can only accurately be defined by Pilots who fly in such fatiguing situations not bookworms and bean counters.FDP limits as per CAP 371 or any other regulator may provide a framework of compliance but does it ensure fatigue free? Why does it not factor the time it takes to get ready for work and then position to work and following post flight duties the time it tskes to get back home and how long it should take to sleep after that? We are humans not robots.General Aviation/Private jets can be even worse with 3 hour reporting time and upto 2 hour post flight before driving off to hotel/home…and that after an 8 hour flight seeing a 13 hour duty period plus commuting time.Even 20 hour cimmulative duty from the time you put on the uniform to the time you remove it has been manifested…and no proper rest period in flight in the tiny jet other than an occasional visit to Mr.John or reclining your station seat a bit(lomited seat pitch!)

    Let us talk FATIGUE ..real fatigue..not compliance! When was CAP 371 born?? Airlines and its crewing fly difgerently now…perhaps time for CAP 372?

  54. Ziad wrote:
    “There seems to be some sort of cultural arrogance, leading to a belief that the FAA regulations simply have to be better than the GCAA regulations because they are stricter. Over the past couple of decades, Arabs have displayed a far better ability to manage airlines (and airports) than Americans. So maybe we can give them the benefit of the doubt unless there is any evidence to the contrary.”

    Well, sure, if you ignore Emirates 521 and FlyDubai 981, both in 2016.

    Sean M has emphasized several times that one must look at the entire picture and not focus on one item. Well, Emirates is well known within the industry as having terrible working conditions and that most of their pilots suffer from chronic fatigue due to the ‘robust’ flying schedules that Emirates’ pilots are subjected to. This change from 4 to 3 pilots is merely another unsafe decision made by Emirates. So stepping back and looking at the big picture, an airline (Emirates) with terrible working conditions have now made the working conditions even worse.

    As far as a pilot shortage, there isn’t a pilot shortage in spite of what’s written by the press. It’s a pay issue – increase pilot pay and there will be more pilots who rejoin the profession … plenty pilots left the business since 2001 due to lack of pay and jobs. Increase pay and change work rules to improve the job and you’ll get plenty more pilots to fly your aircraft.

  55. Sean-

    There you go cherry picking again, right after you said you shouldn’t.

    The JFK -DXB leg could be legally scheduled to operate with 3 pilots by FAR117. However, no airline in their right mind would. Emirates advertises it as a 12:45 or 12:50 gate to gate timed flight (depending on which one you chose. If you were to try to operate this flight as a US carrier with only 3 pilots and you had either a 10 minute or 15 minute increase in taxi out time at JFK (That only happens about every time there is a cloud in the sky East of the Airfield for Atlantic crossings) then you would be illegal to take off!!!!! So, while legal to schedule, no US carrier would ever consider this, even if their pilot contract allowed it.

    More importantly, however, is that you completely ignore the DXB-JFK direction. Where do you think the pilots to fly back are going to come from??? In the DXB-JFK direction the flight is timed as 14 hours gate to gate. That is absolutely illegal by FAR 117, regardless of all other rest facility, duty start time, etc considerations.

    As many others have stated, there can be no question that Emirates is sacrificing safety! If you think it is still “safe enough”, then I can’t help that. For me, however, I am concerned that this erosion of safety poses a real risk for not just Emirates passengers, but also for those of us in the airspace in which they fly and on the ground over which they fly. For that reason, I believe the FAA should step in and do their job in ensuring that our airspace has one level of safety and forbid any carrier (not just Emirates) that doesn’t have any science based rest rules that they are required to adhere to. FAR 117 is the most up to date example of those types of rules (much more so than CAP371) but even you admit, that only the Brits have to comply with those. So, if you want to fly in our airspace, you should have to demonstrate that the rules that you are going to comply with for your crews are supported by modern scientific research methods. If you as an air carrier don’t want to spend the money to do that research, you can either comply with FAR 117 or not fly in US airspace.

  56. @Sean

    I think what you have also forget is that even though something maybe “based” on the CAP371, it doesn’t mean it is interpret the same way. For example, I believe (someone please correct me if I am wrong), in UAE, the monthly hourly limits are based on time in seat, whereas in almost every other jurisdiction that uses CAP371, uses the whole flight including rest. That in itself makes a huge difference. Hence Emirates Pilot can do 6-7 ULR flight a month, where some other airlines like BA, Virgin in the UK, or CX or HX in Hong Kong (also uses rules based on CAP371), their pilot can only do 3, maybe 4 ULR route a month.

    So same rules, different interpretation = significant difference in safety protection. This all comes down the the government, and in this particular case, @Lucky is correct, government is the regulator who also own the airline = NOT the best practice and definitely NOT safe.

  57. @sean

    I haven’t read the plethora of comments, so I do apologize if this is a repeat.

    I operated under UAE regs for 10 years for said carrier. I’ve done those sectors as 3 Crew and can tell you it is EXTREMELY FATIGUING. The FDLs are a limit, not a target. Add onto that, EK gets dispensation to operate many sectors outside the FDLs and you have a perfect storm of cumulative fatigue. Of course this is amplified by the 95-105 monthly hours these folks are doing now.

    Did you know duty starts 60 mins before pushback? Duty ends at brakes set? Add on an industry typical 30-45/30 mins and they are really stretching the rubber band – to a breaking point. This is why so many are leaving, they’re choosing health and safety over money. Others just can’t get past the money, prestige or taking the risk of change.

    I’m glad I left years ago. I’ve never felt better, am healthier and safer than I had ever been there.

    Good luck to the pilots. It’s a razor edged life they’re leading now.

  58. Someone tell Sean M that he needs to read FAR 117 again. Or more carefully. Or less wishfully. “Subject Matter expert” eh ? Funny.

    You cannot have a flight time of 17 hours with a 3 man crew. Those numbers in the table are DUTY HOURS. Not flight time. The maximum flight time is 13 hours for a 3 man crew. Read it again ……… 13 Hours. Most respectable airlines further restrict those times, knowing they they are a maximum, not a goal.

    Emirates new rules are unsafe. They would also be illegal if carried out by a U.S. FAR 121 airline.

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