FAA considers report on air carrier flight-hour requirements

October 14, 2010

Much press and public attention has been focused on the qualifications necessary to become a safe and efficient flight crewmember for air carriers. Although the National Transportation Safety Board did not cite first officer qualifications as a contributing factor in the accident involving Colgan Air Flight 3407 near Buffalo, N.Y., on Feb. 12, 2009, the issue has been debated in the news media and in Congress since that time.

In response to this intense focus on pilot hiring requirements at Part 121 air carriers, a law was passed this summer that requires the FAA to “conduct a rulemaking proceeding to require Part 121 air carriers to develop and implement means and methods for ensuring that flight crewmembers have proper qualifications and experience.” AOPA is participating in this process as general aviation’s representative on an aviation rulemaking committee (ARC) convened by the FAA.

This expert panel recently turned in a report to the FAA with recommendations for additional training areas for first officers, as well as recommendations for the airline transport pilot (ATP) certificate. The FAA is weighing those recommendations in the rulemaking process and should publish an official notice of proposed rulemaking (NPRM) early next year. In representing GA on this panel, AOPA is working to ensure that the FAA considers the potential impact of new rules on flight instructors, flight schools, and pilots who use the ATP certificate in Part 91 or 135 operations, as well as those who fly for Part 121 carriers. On April 10, AOPA submitted these comments on the advanced notice of proposed rulemaking on first officer hiring requirements.

The FAA was given 36 months from the enactment of the new law on Aug. 1 to ensure that all Part 121 flight crewmembers have “obtained an airline transport pilot certificate” under Part 61 of the federal aviation regulations.

Although airlines rarely hire pilots with the absolute minimum flight time, in theory a first officer candidate today could have a minimum of 190 hours total flight time. The new law effectively increased that minimum to the 1,500 hours required for the ATP certificate. Another new mandate for the FAA in the next 36 months is to revise the requirements of an ATP certificate to include special areas of emphasis such as operations in a multi-crew environment, adverse weather conditions such as icing, and high-altitude operations among other areas.

There will still be a minimum flight hour requirement of 1,500 hours—but recognizing that an arbitrary number of flight hours does not alone indicate a pilot’s knowledge and abilities, the new law gave the FAA authority to “allow specific academic training courses, beyond those required” under the newly expanded ATP certificate “to be credited toward the total flight hours required.”

The measure states, “The Administrator may allow such credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement.”

AOPA will continue to work for GA’s interests, consistent with the new measure’s language that “the (FAA) Administrator shall review and consider the assessment and recommendations of the expert panel to review Part 121 and Part 135 training hours established by” the legislation.