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AOPA supports ATP applicant's exemption requestAOPA supports ATP applicant's exemption request

US Air Force pilot was deployed overseas when rules changedUS Air Force pilot was deployed overseas when rules changed

A U.S. Air Force pilot who was deployed overseas when stringent new rules for knowledge testing of airline transport pilot (ATP) applicants took effect in 2014 is seeking an exemption from the new requirement to take an FAA-approved ATP pilot certification training program (CTP) before he can take the ATP knowledge exam.

Air Force Capt. Edward Silva, a Boeing C-17 Globemaster III pilot and AOPA member, was deployed in Romania, flying primarily to Afghanistan for Operation Enduring Freedom, when the new ATP training rule took effect on Aug. 1, 2014.

The deployment on short notice caused him to be unable to visit a testing center and take the multiengine airplane ATP knowledge test before time ran out under the old regulations, he said in the exemption request to the FAA, submitted with AOPA’s assistance.

“AOPA was honored to assist Captain Silva in submitting the petition for exemption request,” said David Oord, AOPA senior director for regulatory affairs.  

Had Silva been able to take and pass the written exam by July 31, 2014, he would have been able to take the ATP practical test during a two-year window thereafter. Pilots who did not take the knowledge test before Aug. 1, 2014, faced the requirement to take the ATP CTP first—a scenario that generated a large spike in pilots taking the ATP multiengine-airplane knowledge test in July 2014.

Pilots acted to take the ATP knowledge test before the deadline because the ATP CTP “consists of, at a minimum, 30 hours of academic coursework and 10 hours of training in Flight Simulation Training Devices (FSTDs): six hours in a Level C or higher Flight Simulation System (FSS) and four hours in a Level 4 or higher Flight Training Device (FTD). The ATP CTP costs ATP candidates several thousand dollars, mostly paid out of pocket by the airman, and must be completed prior to taking the new multiengine airplane ATP written exam,” Oord wrote in AOPA’s February 2015 letter to the Department of Transportation, supporting Silva’s exemption request.

The letter noted that the rule was one of several regulatory changes arising from congressional mandates approved after the February 2009 crash of Colgan Air 3407.

Another of those provisions was that all air carrier second-in-command pilots hold an ATP certificate—requiring the flight crewmembers to have at least 1,500 hours total time as a pilot. Silva already had more than the required flight experience, and already held a commercial pilot certificate, airplane single- and multiengine land, with an instrument rating and type ratings in the BE-400 and MU-300 jets.

“The exemption would also ensure a member of the U.S. armed forces, assigned outside of the United States, preserving, protecting, and defending the American public, obtains additional time to take the knowledge exam. Granting of the exemption would successfully build upon the existing allowances afforded to U.S. military personnel under SFAR No. 100-2 and stands to maintain or enhance the current level of safety,” AOPA wrote.

Culminating a process that continued for more than two years, the FAA published notice of Silva’s exemption request on July 19, noting that the purpose of the notice “is to improve the public's awareness of, and participation in, the FAA's exemption process.”

The agency will accept comments on the petition for exemption until Aug. 8. Members can send comments identified by Docket No. FAA-2015-0226 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.

Dan Namowitz

Dan Namowitz

Associate Editor Web
Associate Editor Web Dan Namowitz has been writing for AOPA in a variety of capacities since 1991. He has been a flight instructor since 1990 and is a 30-year AOPA member.
Topics: Advocacy, Airman Regulation, Advanced Training

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