Proposed rule may affect your future as a pilot
You are likely reading this issue of Flight Training in mid-April. That’s good because if you have a vested interest in proposed FAA regulations that will forever change how future pilots will be qualified and eligible for the airline industry, the deadline of April 30 is just days away. After that date, the FAA will no longer consider comments to its notice of proposed rulemaking (NPRM), titled Pilot Certification Requirements for Air Carrier Operations.
In a nutshell, the proposal would require a second in command (first officer) in Part 121 operations to hold an airline transport pilot (ATP) certificate and a type rating for the aircraft to be flown. This comes as no surprise to anyone who has followed both government and citizen reaction to the Colgan crash near Buffalo in February 2009. There has been a loud public outcry over the crew’s deficiencies. Early speculation by airline insiders fueled fears that raising the certification bar would result in a number of significant unintended consequences.
Where will airlines find the 1,500-hour, ATP-certificated pilots to occupy the right seat of a regional jet for $21,000 annually? During the hiring boom in 2007, stories were rampant of 300-hour flight instructors at aviation schools and academies being sucked out of their Skyhawks and deposited into the right seat of a regional jet. Even then, the regional airlines were having difficulty keeping up with the demand.
Airline management will be compelled to seriously review first officer salary and lifestyle. These executives are concerned, and rightly so, that ATP new-hires will demand better pay and benefits because they are no longer new pilots with a couple hundred hours. Thus, regional airline economics will be substantially impacted.
As anticipated, the FAA has plans to reduce the 1,500-hour minimum under certain circumstances. It proposes the following alternative hour requirements for a restricted-privileges ATP certificate with airplane category multiengine class rating or type rating: 750 hours for a military pilot; and 1,000 hours for a graduate of a four-year baccalaureate aviation degree program who also received a commercial pilot certificate and instrument rating from an affiliated Part 141 flight school.
Pilots who meet these alternative hour requirements would be required to pass the same ATP knowledge and practical tests as those pilots who obtain an ATP certificate at 1,500 hours. These pilots would have the following limitation placed on their certificates: “Restricted in accordance with 14 CFR �61.168(a)” and “Holder does not meet the pilot in command aeronautical experience requirements of ICAO.”
The proposal to allow graduates of four-year colleges and universities with aviation-related majors to obtain a restricted-privileges ATP certificate is based on the specific nature of the training that those pilots receive. And the plan to offer a reduction in required time for college graduates is almost guaranteed to prompt controversy.
Not all collegiate aviation curricula are created equal. Big hitters such as Embry-Riddle Aeronautical University and the University of North Dakota, with their advanced simulation devices, can achieve the type of education and training that the FAA references. What about those fine, smaller schools that offer a four-year aviation degree but focus on the basics of pilot training and certification in worn aircraft? How is the FAA going to make judgments regarding the quality of a collegiate program? How will that program be monitored to assure compliance?
What about those institutions that have an excellent pilot training program but opt out of certification as a Part 141 FAA-approved flight school? Some organizations simply do not want to be bothered by the strenuous recordkeeping and oversight requirements.
There appears to be no recency of experience requirement. If Bob graduates from a four-year aviation college at age 21 but decides to run his family’s company for 10 years, can he still get that restricted ATP at 1,000 hours a decade later—when all of that knowledge and training may have dissipated?
Aviation’s training academies that are dedicated exclusively to pilot training—some with advanced programs utilizing regional jet flight training devices (FTDs) and simulators—are seemingly left out in the cold. Their graduates will be faced with the need to build 1,500 hours, rather than 1,000 hours, simply because they were not enrolled at a four-year school. Those airmen who made their way into the airline game in the 1980s will remember the challenge of making it from 300 hours to 2,000 hours, which even the regional airlines required back then. How to cross that bridge to 1,000 or 1,500 hours? That same dilemma will be facing future grads when the rules go into play. More flight instruction? Banner towing? Air taxi? Where are the employers that will provide that opportunity to build more time?
How will the airline employers monitor and comply with the regulations? How will the FAA’s inspectors and designated pilot examiners know that the applicant for an ATP practical test is eligible for the restricted ATP certificate? Will the FAA publish a list of “approved” schools? Will the applicant need to present transcripts and a copy of the degree prior to the practical test? There are other controversial aspects of the proposed regulations, such as a requirement that first officers have a type rating in the aircraft that they fly. This will add more expense to someone. Either the airline will need to foot that bill or pass it along to the new hire. The proposal has many more controversial provisions.
Now is the opportunity to shape the regulation during the comment period. But the clock is ticking.
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