FAA publishes first officer qualification rule

March 1, 2012

The FAA has published its expected notice of proposed rulemaking revising the qualifications for air carrier first officers. The NPRM gives the aviation industry its first look at the details of a regulation that could have far-reaching implications for the flight training industry, student starts, and the future pilot population.

The NPRM is a combination of training and experience requirements mandated by Congress in 2010 as a result of the Colgan Flight 3407 crash in Buffalo, N.Y., in 2009 and proposals that originated with the FAA. Members are encouraged to submit comments on the NPRM by April 30.

More hours, ATP requirement

The proposal would change air crew hiring requirements by making it necessary for all air carrier first officers to hold an airline transport pilot (ATP) certificate instead of a commercial pilot certificate, in effect increasing minimum flight time hours from 250 to 1,500. This also causes an increase in training costs.

Applicants for an ATP certificate with an airplane category multiengine class rating or type rating would face an additional requirement to complete a new ATP certification training program. 

Further, the new training program requirement would impose broad training obligations rather than allow ATP certificate applicants to meet the requirement in the specific aircraft and operating environment in which they would work. The training course would require training in a Level C or higher flight simulator, making it only available through a Part 141 pilot school, 142 flight training center, Part 121 air carriers, or Part 135 air carriers—constraining the ability of some training providers to continue offering ATP training. The rule would also impact the ranks of program instructors by requiring them to hold an ATP certificate and have at least two years of experience in a fractional ownership program or at an air carrier.

A 500-hour disadvantage

Under preferential treatment provisions for military pilots and those who take baccalaureate aviation-degree programs, potential students could face the choice of enrolling at a four-year aviation university or take a 500-hour and two-year age disadvantage. Military and pilots who have graduated from baccalaureate aviation-degree programs would be eligible for a “restricted” ATP certificate at age 21, instead of the standard ATP requirement of being 23 years old, with reduced required flight hours of 750 for military pilots and 1,000 for program graduates.

The proposed rule did not adopt an aviation rulemaking committee (ARC) recommendation to give credit for certain high-quality flight experiences in general aviation, such as flight time as an instructor or in a multiengine or multi-crew environment.

AOPA submitted comments to the FAA in 2010 during the advanced notice of proposed rulemaking process, and served on the ARC that considered the effects of possible regulatory changes to pilot qualifications and training. The association pointed out that flight school activity and student starts could be negatively impacted by the proposed rule.

Under other provisions, the ATP airplane multiengine certificate would now require a prerequisite minimum of 50 hours in a multiengine aircraft; ATP practical and knowledge exams would be revised; and air carrier pilots would be required to have 1,000 hours experience as a first officer before upgrading to captain.

AOPA will be fully evaluating the proposed rule change for any possible impact on GA.

Members may submit comments online or by mail to Docket Operations, M–30; U.S. Department of Transportation, 1200 New Jersey Avenue SE, Room W12–140, West Building Ground Floor, Washington, DC 20590–0001. Please refer to Docket Number FAA-2010-0100.

Dan Namowitz

Dan Namowitz | Aviation Writer

Dan Namowitz is an aviation writer and flight instructor. He has been a pilot since 1985 and an instructor since 1990.