PLT RPT; B727; EWR-DEN-SMF; GATE AGENTS TRIED TO BOARD PAX BEFORE FAA CABIN CREW MINIMUM ON BOARD. CAPT REFUSED TO ACCEPT PAX; CITES FAR 121.391-3.

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AS THE BACKGND INFO SHOWS; ACR IS DISREGARDING THE SAFETY OF ITS PAX DURING THE BOARDING PROCESS. I HAVE BEEN TOLD THAT THIS IS BECAUSE MGMNT GETS FINANCIAL BONUSES FOR PUSHING FLTS OUT EXPEDITIOUSLY. WE HAD A RECENT INCIDENT WHERE THE GATE AGENT BOARDED A B727 OVER THE OBJECTIONS OF THE CAPT; WHERE THERE WAS A SINGLE FLT ATTENDANT WHO HAD NOT COMPLETED HER SAFETY CHKS. WITH THE EMPHASIS ON INCREASED PAX SAFETY; SUCH AS THE INSTALLATION OF DEFIBRILLATORS AND ENHANCED EMER MEDICAL KITS; ACR IS GOING THE OTHER WAY. INDIVIDUALS WHO HAVE TRIED TO MAKE AN ISSUE OF THIS HAVE BEEN THREATENED BY MGMNT. I WILL ATTEMPT TO EXPLAIN THE THROUGH FLT ISSUE WITH REGARD TO FLT ATTENDANT COMPLEMENT. THERE ARE 2 FARS THAT APPLY TO THIS -- FAR 121.391 AND FAR 121.393. FAR 121.391; FLT ATTENDANTS; STATES (IN PART): A) EACH CERTIFICATE HOLDER SHALL PROVIDE AT LEAST THE FOLLOWING FLT ATTENDANTS ON EACH PAX-CARRYING ACFT USED. 4) FOR ACFT HAVING A SEATING CAPACITY OF MORE THAN 100 PAX; 2 FLT ATTENDANTS PLUS 1 ADDITIONAL FLT ATTENDANT FOR EACH UNIT (OR PART OF A UNIT) OF 50 PAX SEATS ABOVE A SEATING CAPACITY OF 100 PAX. FAR 121.393; CREW MEMBER REQUIREMENTS AT STOPS WHERE PAX REMAIN ON BOARD; STATES (IN PART): AT STOPS WHERE PAX REMAIN ON BOARD; THE CERTIFICATE HOLDER MUST MEET THE FOLLOWING REQUIREMENTS: B) ON EACH AIRPLANE FOR WHICH FLT ATTENDANTS ARE REQUIRED BY 121.391(A); BUT THE NUMBER OF FLT ATTENDANTS REMAINING ON BOARD IS FEWER THAN REQUIRED BY 121.391(A); THE CERTIFICATE HOLDER MUST MEET THE FOLLOWING REQUIREMENTS: 1) THE CERTIFICATE HOLDER SHALL ENSURE THAT: III) THE NUMBER OF FLT ATTENDANTS ON BOARD IS AT LEAST HALF THE NUMBER REQUIRED BY 121.391; ROUNDED DOWN TO THE NEXT LOWEST NUMBER IN THE CASE OF FRACTIONS; BUT NEVER FEWER THAN ONE. ON B737 AND B727 ACFT; THE 121.391 REQUIRED FLT ATTENDANT COMPLEMENT IS 3; WHILE THE 121.393 NUMBER IS 1. FLTS THAT STOP OVER AT INTERMEDIATE STATIONS PRIOR TO CONTINUING ON HAVE GENERALLY BEEN REFERRED TO AS 'THROUGH FLTS;' WHERE SOME PAX MAY ELECT TO REMAIN ON BOARD THE ACFT. THE INTENT OF 121.393 WAS TO ALLOW FLT ATTENDANTS TO LEAVE THE ACFT WHILE AT THE GATE BECAUSE THE NUMBER OF PAX WHO ELECT TO REMAIN ON BOARD IS USUALLY SMALL. IN ADDITION; IT IS ASSUMED THAT THESE PAX HAVE ALREADY RECEIVED A SAFETY BRIEF; USUALLY FROM THE SAME FLT ATTENDANTS. PRIOR TO 121.393; THE FULL COMPLEMENT (121.391) WAS REQUIRED DURING INTERMEDIATE STOPS; EVEN IF ONLY 1 PAX DECIDED TO STAY ON BOARD. ACR HAS DECIDED TO INTERP 121.393 IN A MANNER THAT WAS NOT INTENDED BY THE REG. ACR HAS DECIDED THAT A 'THROUGH FLT' IS A FLT WHERE THE FLT NUMBER DOES NOT CHANGE; AND HAS FURTHER EXTENDED THIS TO THE BOARDING PROCESS. CUSTOMER SVC NOW REQUIRES THAT A FLT ATTENDANT LEAVE THE ACFT TO ASSIST IN TICKET TAKING IN THE GATE ROOM. AN EXAMPLE OF THIS WAS FLT XXX; WHICH ORIGINATED IN EWR AND STOPPED IN DEN PRIOR TO CONTINUING ON TO SMF. THIS FLT; UPON ARR AT DEN; USUALLY HAD A COMPLETE TURNOVER OF COCKPIT CREW; CABIN CREW AND PAX. THE ENSUING SEGMENT IS; FOR ALL INTENTS AND PURPOSES; AN ORIGINATING FLT (WHERE THE FULL COMPLEMENT OF FLT ATTENDANTS IS REQUIRED PER THE FOM); FREQUENTLY WITH A FULL LOAD OF PAX. THESE UNBRIEFED PAX; WITH ALL OF THEIR LUGGAGE; ARE NOW BEING BOARDED ON AN ACFT THAT DOES NOT HAVE THE 121.391 COMPLEMENT ON BOARD; AND HAS ACTUALLY BEEN DONE WITH ONLY 1 FLT ATTENDANT ON THE ACFT. THIS IS CLRLY NOT IN THE BEST INTERESTS OF SAFETY. IT WOULD BE QUITE DIFFICULT TO RESPOND TO A MEDICAL EMER OR TO STOP AN UNPLANNED EVAC. (FOR EXAMPLE; A BOARDING PAX OBSERVES TORCHING FROM THE APU AND YELLS; 'FIRE!') IN ADDITION; ON THE B727; DOOR 2L IS ALWAYS ARMED; AND THE AFT AIRSTAIRS ARE EASILY ACCESSIBLE; PARTICULARLY FOR A NON ENGLISH SPEAKING PERSON LOOKING FOR THE LAVATORY. A FLT ATTENDANT SHOULD BE GUARDING THE AFT PORTION OF THE ACFT FOR SAFETY CONSIDERATIONS. RECENTLY; THERE HAVE BEEN SOME SERIOUS INCIDENTS THAT HAVE OCCURRED WITH THIS PROC. A FEW CAPTS HAVE TOLD CUSTOMER SVC THAT THEY WILL NOT ALLOW THEIR ACFT TO BE BOARDED WITHOUT THE 121.391 COMPLEMENT OF FLT ATTENDANTS ON BOARD. THIS MEANS THAT IF YOU ONLY HAVE 3 FLT ATTENDANTS IN THE B737/727; THE CAPT HAS REQUIRED THAT THEY REMAIN ON THE ACFT WHILE PAX ARE BOARDING. A CUSTOMER SVC SUPVR MADE AN ANNOUNCEMENT IN THE GATE AREA THAT BOARDING WAS BEING DELAYED BECAUSE THE FLT ATTENDANTS WERE TOO LAZY TO TAKE TICKETS. AN ARROGANT AGENT GOT INCHES FROM A CAPT'S FACE AND SAID; 'YOU STICK TO FLYING THE AIRPLANE. WE MAKE THESE DECISIONS. YOU HAVE NO AUTH UNTIL THE DOOR IS CLOSED.' ANOTHER SUPVR SAID; 'IT IS AN FAA REG THAT WE BOARD WITH FEWER FLT ATTENDANTS.' SAY WHAT? CALLBACK CONVERSATION WITH RPTR REVEALED THE FOLLOWING INFO: THE RPTR STATED THAT THIS HAS HAPPENED TO HIM AT LEAST A DOZEN TIMES IN 1 1/2 YRS. THE HOSTILITY OF THE CUSTOMER SVC AGENTS TO HIS ADHERENCE TO THE FAR 121.391-3 REGS; LEAVES HIM QUESTIONING THE PRIORITY OF SAFETY TO THE AIRLINE'S MGMNT. HIS OWN FLT MGR THREATENED HIS FUTURE WITH THE AIRLINE; BECAUSE HE WOULDN'T LET AGENTS BOARD THE ACFT WITHOUT THE FAA MINIMUM FLT ATTENDANTS. HE KNOWS OF SEVERAL OTHER CAPTS WHO HAVE HAD TO GET INTO SHOUTING MATCHES WITH THE GATE AGENTS OVER THIS ISSUE. THE INCIDENT AT THE END OF HIS NARRATIVE ACTUALLY HAPPENED TO HIM IN DENVER. HE KNOWS OF ANOTHER SIMILAR INCIDENT AT ORD TO ANOTHER CAPT ON A THROUGH FLT; WHERE THE AGENT TOLD THE CAPT THAT HE HAD NO AUTH ON THE GND; AND THAT 'THE CAPT DIDN'T KNOW THAT THE FAA REGS MANDATED THE FLT ATTENDANTS TAKE TICKETS IN THE BOARDING AREA.' THE RPTR ADAMANTLY STATES THAT THE FARS BE CHANGED TO NOT HAVING ANY FLT ATTENDANTS TAKING TICKETS OFF THE AIRPLANE.