On the recordFebruary 16, 2011
Madam President, the supplemental carriers provide a valuable and unique service to our economy as well as our military's ability to move troops and materiel around the world in a safe and timely manner. Current flight and duty rules for carriers recognize differences in operations and provide the necessary flexibility for supplemental carriers, given the challenging worldwide environments they operate in such as Afghanistan, Kyrgyzstan, Iraq, and other Middle East destinations. Supplemental carriers have a long track record of safe operations. In more than 15 years, the National Transportation Safety Board, NTSB, has not cited fatigue as a primary cause in any nonscheduled/supplemental airline accident while flying under supplemental rules, 14 CFR Part 121, subpart S. There have been no fatalities attributed to any accident where fatigue was even remotely considered a contributing factor. In the months preceding FAA's notice of proposed rulemaking, the agency's lack of interest in the operations of nonscheduled carriers led many to believe their unique operating procedures and status as small business entities would be addressed in a separate rulemaking. FAA issued its notice of proposed rulemaking, NPRM, to the public on September 14, 2010, and it was clear supplemental carriers were, indeed, covered by the NPRM, but the impacts of this proposal on supplemental carriers were not taken into consideration. This oversight is unprecedented.…





