In February of 2009, Colgan Air Flight 3407 crashed into a house in Clarence Center, New York, killing all 49 people on board, and one person in the house. An aerodynamic stall was determined to be the cause of the crash, though the US National Transportation Safety Board (NTSB) concluded that the performance of the pilots was likely impaired by fatigue.
As as result, the International Civil Aviation Organization (ICAO) amended their Standards and Recommended Practices (SARPs) to include regulatory requirement suggestions for fatigue management.
The FAA then updated their Flight Crew Member Duty and Rest Requirements in 2012, and EASA updated the EU regulations on flight and duty time limitations in 2014 (came into effect in 2016). They also included a fatigue risk management and flight time specification system to allow some flexibility for operators.
Other countries, including Australia and India, have also enacted new regulations.
Recently, Canada also began looking at updating the Canadian Aviation Regulations (CARs) to take into account factors including:
“the effects of working at different times of the day (i.e. circadian body clock);
factors such as sleep hygiene and sleep quality; and
the effects of cumulative fatigue due to workload or operational context or other reasons, that were only discovered and understood in the second half of the 20th century.” ()
While making aviation safer should always be a priority, there is usually an economic cost whenever regulatory requirements are added.
The proposed amendments in Canada were projected to “cost industry about $337.65 million over 15 years, mainly due to the changes to flight crew scheduling requirements”. It’s useful to note they also estimated that the “potential reduction in accidents would save passengers, flight crew members and air operators approximately $314.30 million over the next 15 years”, so the net cost was projected to be $23.35M over the 15 years, which is still not insignificant.
On an individual level, however, regulatory changes almost always cause problems, confusion, and difficulty for operators as they try to adjust to new regulations.
Causes of Regulatory Switching Pain
There are a variety of causes of problems when operators have to comply to new regulations, but we’re going to look at just a few:
Current lack of accountability/transparency on crew scheduling processes.
Resulting lack of flexibility in adapting to new rules.
Current lack of tracking/monitoring required to show compliance with new regulations or as part of FRMS system.
Expected cost and staffing requirement increases as a result of the new regulations, in a market where many operators already operate under thin margins.
Let’s take a look at each individually:
1. Current lack of accountability/transparency on crew scheduling processes.
We’ve talked about this in detail elsewhere, but in general, we see crew scheduling teams that operate well, work hard day in and day out, and generate solutions that work for their businesses and the problems they deal with.
However, we also generally observe that the processes they use are opaque and vary between individuals; often someone we referred to recently as a “magician” plays a key role in scheduling departments, but their methods and value is overlooked; these types of departments also tend to be reactive, and therefore find it hard to find time to look at potential future changes or developments.
2. Lack of flexibility in adapting to new rules.
Humans are notoriously difficult to predict, and scheduling teams already have a huge task before them in scheduling day-to-day. That makes it very difficult to know how your teams will react to proposed changes.
Most scheduling teams rely upon a few individuals for the majority of problem resolution, and these members often rely on their own intuitive knowledge of the problems to solve them. That intuition is built of years of operating under the same ruleset, to a point where they can look at schedules and see solutions.
Once those regulations change, it’s difficult to predict how it will affect operations - how will those lead schedulers adjust? How will the rest of the team adjust?
For those who rely on first principles, and are still getting used to the current regulations, it may actually be easier - their workflow probably involves regularly consulting the rules, which will benefit them in future. An intuitive scheduler may have difficulty changing their habits and adjusting to the new system.
3. Current lack of tracking/monitoring required to show compliance with new regulations or as part of FRMS system.
While many proposed FRMS systems acknowledge that important metrics may not be tracked initially, the difficulty and cost of beginning to track all the parameters required for such a system is often overlooked, and the time required to implement the systems underestimated.
Generating processes for collecting, storing and analyzing crew fatigue is almost easier; the system can be designed from the ground up, and is relatively simple. Beginning to track and monitor metrics like crew rest, transport time, even flight hours, which is something supposedly inherent in systems already used by operators can be very difficult, and require both a lot of time from IT personnel and operations staff.
4. Expected cost and staffing requirement increase
Usually, with new regulation proposals, there is a decent analysis of overall costs. The proposed Canadian regulatory changes, for example, separated the costs by air operator group, and even by flight crew member in that group:
For additional items like implementing an FRMS system, they include the tasks and time estimates that went into generating their cost predictions, which is also useful.
What is difficult to quantify, however, is how that cost will be spread out; which departments within an operator will be affected; and as a result, how it will really affect the bottom line within an operator.
The cost of getting the data required to comply with an FRMS system is also not taken into account, and can require serious changes within the organization.
While detailed cost estimates for scheduling time increases, and the extra crew required to comply with regulations are certainly useful, it still leaves a lot of questions unanswered from a staffing perspective. Namely, how many people do I need to add to my scheduling team? To my crew? When should I hire them?
As we know, staff members don’t come in fractions; you can’t gradually increase your crew by fractions to adjust to the scheduling requirements. Adding staff at the right times will make the transition to new regulations much easier. But how do we predict it correctly?
How to Make the Transition Easier
The solution to all three issues comes from a combination of two things: systemizing scheduling, and conducting what-if scenarios ahead of time in a systematic manner.
As we mentioned, trying to predict how a scheduling team will adjust to new regulations is extremely difficult. Usually you can choose one of two routes: wait and see, or hire ahead of time and hope you’ve covered the extra burden.
The problem with these two methods is that usually you either end up stuck in a crisis, or you end up overestimating the resources required, and therefore wasting money.
Instead, we’d like to give the scheduling team the tools to both adjust smoothly, and plan ahead of time how they will adjust.
Step 1: As a scheduling team, get on the same page.
Generally, even within one scheduling team, there will be a wide variety of styles and processes used to generate a compliant schedule. As a team, you need to all get on the same page before you can begin examining changes to the process.
In this case, you should also create a short-form list of the current regulatory rules you implement when creating schedules.
Step 2: Compare these lists with the proposed new regulations.
Once you have the lists above, you should compare all changes from the current regulations to the existing regulations. You should highlight the regulatory rules that will be changing first, and then examine your list of organizational rules to see if any need adjustment. Ideally, you can create a quick document with reminders of the changes, and keep this as a reference.
Step 3: Run what-if scenarios on several months’ worth of schedules.
We’ve now systemized how we apply rules, and made sure the whole team is on the same page with regard to regulatory and organizational rules, and how they’re applied. This step is the real test - it will form the basis for staffing plans and cost estimates moving forward.
The goal here is to figure out two things:
How long does it take us to make a schedule that works under the new regulations?
How many extra schedulers, and how many extra crew do we need to really make it work?
The reason for doing this for several months is to pick several months that represent your whole year - a good choice would be your busiest month, your quietest month, and an average-volume month.
Step 4: Examine the results, and determine a plan based on the proposed rollout of regulations.
If the what-if scenarios have gone well, you’ll have determined a couple things:
How many hours it took to generate a new schedule for each type of month (busy, medium, slow), and how this compares with the current scheduling time
What adjustments to staffing make this process faster/easier
With these tests in place, you can make a plan based on the rollout of regulations for increasing your crew, and scheduling staff, and do your recruiting ahead of time. This should allow you to make the transition smoothly, and avoid the crisis many operators face when adjusting to changes, while still making sure you can plan for costs.
What If I Don’t Have Time for Simulations?
Good question. Many scheduling teams are stressed enough as it is, and this often means that they don’t have any time for developing detailed what-if scenarios.
Working to automate your scheduling process as much as possible is our best answer here. One of the main benefits of moving your process towards automation is the ability to run what-if scenarios much faster, even when regulatory changes aren’t on the horizon.
We’ve talked in detail about some of the things you can do to move towards being ready to bring in an outside partner to help with scheduling automation and optimization.
Ultimately, many of the steps are the same:
Recording organizational rules and the hierarchy used in applying them to generate schedules.
Recording individually-applied rules for crew members.
Keep track of all the schedule changes you make during a given scheduling period (1 month, for example).
Track feedback from crew members on a consistent basis.
With these things in place, you can begin to automate some of your scheduling, and preparing for regulatory changes will be as simple as modifying a few rules and running the scheduling engine again. It will be simple to plan for upcoming changes, and the best part is that staffing changes on the scheduling team shouldn’t be required, as an automated solver won’t require any time to adjust to new rules.
If you’re still feeling lost on the process, or where to go in systemizing your scheduling, feel free to reach out with your questions.