Flight duty hours and Cargo Ops

     (1) The Colgan accident is considered a watershed accident for regional airline operations in the US.  That accident pointed out numerous issues with the industry that we could no longer go on ignoring.  One of those issues was that of pilot fatigue.  The old regulations only limited schedulers to giving pilots 8 hours off between up to 16 hour duty periods (Boxer, 2015).  The legislation passed after this accident now requires a scientific based 10 hour rest period for pilots, as well as a duty day maximum of 9-14 hours depending on number of legs flown and the time of day the crew shows up for work (FAA, 2011).  The pilot's commute to work is still not a consideration for interrupting the rest period or counting for duty time.
     A second issue that was approached was flight training standards.  The FAA has mandated specific simulator training for loss of control events following the Colgan captain's failure to prevent and recover from a stall.  These situations were typically covered in simulator training programs, but they weren't specifically legislated to be taught or taught a certain way or number of times.  The FAA also passed the notorious "1500 hour" rule as a result of this accident.  This rule requires part 121 operators to hire pilots that have at least 1500 total hours, whereas the old legal minimum was 250 hours, 23 years of age, commercial certificate with instrument rating (Tumulty, 2014).  There are some exceptions, such as part 141 certified 4 year college programs and military pilots, who can be hired at 1,000 and 750 hours, respectively.
     The last rule that was updated was a result of the crash victims families from the Colgan accident, and that was a requirement for airlines to specifically disclose code-sharing agreements when their flights were being operated by their regional underlings (Tumulty, 2014).  The families demonstrated that they expected Continental safety and Continental training, only to find out after this accident that there is a major gap between regional and major operators.
     (2) Currently, the requirement for cargo pilots to be hired is set by company minimums.  The old rule of 250 hours, commercial license with instrument rating, 23 year old, would have applied until the new regulations were released, I believe.  Furthermore, these pilots only have to be given a rest period of 8 hours (from the time they shut the aircraft down, not the time they get home or in bed) and they can be flown up to as much as a 16 hour duty day.
     (3) I believe the biggest factor in the exemption is cold, hard, cash money.  The preamble to the final rule goes extensively into the cost to benefit ratios for operators, stating that public safety is well worth the $135 million (at least) that operators will spend on training program improvements for pilots that want ATP's under the new regulations.  It states how operators will make up for these costs, but they specifically refer to part 121, 135, and 91 operators.  The cargo operators, especially larger ones like Fed Ex, have spent over $140 million dollars on political lobbying since Obama took the presidential office (Goelz, & Hall 2014).  The cargo carriers were included in the new crew rest rules NPRM, but were stricken from the final rule most likely due to lobbying that costs would outweigh benefits and would put some carriers out of business altogether.
     (4) I do believe these carriers should be included in the new rules.  Fatigue has been an issue for a very long time, and it applies to all humans regardless of what plane they fly.  The new rules aren't created in Oklahoma to make activists happy (in this case), they're based on scientific evidence concerning our circadian rhythms and sleep cycles.  Cargo pilots fly fast, massive jets identical to those of passenger carriers, just as capable of destroying property and killing people on the ground when mistakes are made while flying fatigued.  As far as the 1500 hour rule, I don't think that one should be applied to any airline in the manner that it is being applied.  The Colgan pilots were far beyond 1500 hours, and even more important, they both had over 1,000 hours of turbine time.  They are a perfect example of why training and tracking competency is far more important than total time, and I'm not really sure why the FAA followed through on this requirement.
     (5) From a pilot perspective, the new rules being applied to the cargo operators would limit the opportunities for me to get into a turbine powered aircraft earlier than 1500 hours.  Currently, the cargo operators provide a good path to airline flying by allowing pilots in at company minimums and paying far better than what a flight school pays its instructors.  For me personally, this would make a huge difference because I have a family of 4 to provide for, rather than just myself.  Furthermore, if companies were to go out of business because of the crew rest requirements, this means there are less job opportunities no matter how many hours you have.  The industry is doing great at the moment, so this probably wouldn't make a huge issue for most of us. If the new rules were to put us back into the '90's, as far as difficulty in getting a pilot job is concerned, those positions in a cargo outfit could be instrumental in a pilot's ability to initiate and complete a career in aviation.

References:

Hall, J., & Goelz, P. (2014, September 11). Cargo pilot hours should be regulated, too: Column.
     Retrieved October 18, 2015, from http://www.usatoday.com/story/opinion/2014/09/11/cargo-
     pilot-airline-safety-fatigue-regulations-commercial-column/15474061/

Legislation would extend rest requirements to cargo pilots. (2015, June 24). Retrieved October 18,
     2015, from http://www.safetyandhealthmagazine.com/articles/12556-legislation-would-extend-
     rest-requirements-to-cargo-pilots

Press Release – FAA Issues Final Rule on Pilot Fatigue. (2011, December 21). Retrieved October 18,
     2015, from https://www.faa.gov/news/press_releases/news_story.cfm?newsId=13272

Tumulty, B. (2014, February 11). 5 years after N.Y. crash, some airline safety progress. Retrieved
     October 18, 2015, from http://www.usatoday.com/story/news/nation/2014/02/11/colgan-air-crash-
     prompts-safety-regulations/5372353/