The FAA has released a notice of proposed rulemaking that will drastically alter the landscape of the professional flight training industry. The NPRM is the next step toward creating a set of FARs to put into action the law passed by Congress and signed by President Obama in 2010. There are numerous safety initiatives contained within the law, but the one that likely will have the most dramatic effect will be the provision that calls for first officers to hold an Airline Transport Pilot certificate.
As we wrote at the time the bill came to the fore, there’s no data to correlate a FO having an ATP certificate with any change in safety. There very well might be some safety advantage to be found there, but we know of no study that suggests a link. Moreover, we don’t know how, given the exceedingly small number of air transport accidents and the causal complexity of those accidents, that any such link possibly could be established.
The change in hours required for FO’s is staggering. Currently they can start flying the right seat of an RJ with 250 hours, the minimum needed for a commercial. In reality, few have even close to as few hours as that, but many have far fewer than 1,000 hours. The ATP requirement will boost that number to 1,500 hours, a level of experience that takes years to accumulate. Congress’ intent seemed sincere. The Buffalo disaster showcased the shortcomings of the regional airline industry in a shocking way.
The costs associated with the new requirement, unfortunately, will be borne largely by the (for the most part) young people aspiring to an airline career. This is a double tragedy. Even with the current requirements, professional training is a huge investment, one that seems a dicey call given the current state of airline affairs. (See Les Abend’s "The B Word" in the March issue for more on that sad story.) Raising the bar to six times its current height will make it next to impossible for most would-be airline pilots to find their way into the cockpit. Many of those who do will surely have built up hundreds of hours doing the kinds of flying — banner towing, primary instruction, pipeline patrol — that, while valuable in many respects, are largely irrelevant to the skills required in airline flying. Maybe this is an indictment of the value of an ATP certificate as currently defined.
There’s more confusion in the proposed rules, however, and these provisions, if passed, will likely drag the FAA to federal court. For reasons that are unclear, under the proposed rule there would be two kinds of ATP certificate, the regular old 1500 variety and a different one for former military pilots and for students who graduate from a four-year baccalaureate program and who have ammassed 750 hours of total time. The latter group could get a restricted ATP, allowing them to serve as FO but not as captain. The provision makes a distinction that is discriminatory in nature and seems based on unfounded assumptions about the quality of training that pilots receive at different kinds of training organizations.
The NPRM is available for comment here. We urge you to read it and give the FAA your feedback.
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