Congress continues to make noise about requiring the FAA to increase the minimum number of hours required for pilots of scheduled airline operations, particularly regional airlines. The pressure is a result of the obviously inadequate performance of the crew who crashed the Dash 8-Q400 turboprop on approach to Buffalo last year.
FAA rules require that airline captains have an ATP certificate, but copilots need only a commercial license with instrument rating. To qualify for an ATP, a pilot must have logged a matrix of hours with specific minimums for cross country, IFR, night and so on with 1,500 hours being the lowest number of total hours that qualifies. So in the minds of many there is magic in 1,500 hours making it a point where a pilot becomes truly safe. But I don't buy it.
The problem with using total pilot hours of experience to measure pilot qualification is that hours alone can count for a lot, or maybe only a little. And total hours tells us nothing about a person's aptitude for flying, nor the quality of training they received on the way to logging the hours.
Most importantly, airline flying is different from any other type of flying a pilot will do to build hours. I have had an ATP for nearly 30 years and have logged more total hours than many active airline captains. But I am not qualified to be an airline captain because I have never done that type of flying. I would need very specific training and then right seat experience out on the line before I could ever think of being qualified to fly an airliner even though my total flying experience in a wide variety of airplanes exceeds five digits.
Once again, it still comes down to training, and aptitude, not a simple measure of hours. And each airline is tasked with identifying pilot candidates with the necessary aptitude, and then training them to a consistently high standard. Unfortunately neither Congress nor the FAA can invent a set of rules that will automate that process. For decades the U.S. military performed this task of identifying pilot candidates and then training them to a high level. But now that the military trains only a relative few pilots, and then is successful at keeping them in the service for many years, the job falls to the airlines, particularly the regionals that are the entry level for pilots. I hope, under pressure from Congress and the FAA, they will step up and do the right thing.
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Submitted by jrorosco on February 18, 2010.
As a Regional Airline Captain and Line Check Airman I respectfully disagree. As explanation please allow me to share the thoughts I have submitted to the FAA's Advanced Notice of Proposed Rulemaking public comment forum:
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
Re: Docket No. FAA-2010-0100
To Whom It May Concern:
Thank you for allowing input from the public regarding the ANPRM covering pilot certification and airline training requirements. I feel I may be able to offer some unique perspective on this issue as I consider myself to be on the front line of regional airline pilot training. My background in the flight training world is fairly extensive as I am a Gold Seal Flight Instructor with single, multiengine and instrument ratings. I have both advanced and instrument ground instructor certificates and previously taught an instrument rating ground school course at a large Part 141 flight school. I was also an ab initio instructor for a foreign air carrier First Officer cadet program where we took students from zero time to a commercial multiengine land certificate in minimal hours and then sent them off to fly the line.
Currently I serve as Captain and Line Check Airman on the Canadair Regional Jet for a large U.S. regional airline and have intimate knowledge of the issues you are discussing. In my capacity as an LCA for this regional airline I am responsible for training and checking many new airline pilots who come to us from general aviation backgrounds, or those who have never had turbine or FAR Part 121 experience. The learning curve is steep for these pilots but I have noticed a general trend in those who perform better than others, and it relates to one factor: experience. It is my strong belief that while there is not always a direct correlation between the ability of pilots who have the same number of flight hours, those who have more flight time in general are better than those who have less. For these reasons, I strongly support your efforts to not only to raise the minimum flight hour requirement for Part 121 operations to 1500 flight hours, but to also require an ATP certificate with appropriate category and class type ratings in order to act as Second in Command. I do not believe there should be any exception to this flight time requirement to be satisfied by classroom time. If an improvement in pilot performance is your goal, this can be best served by requiring greater experience, and experience is not gained by any number of hours in a classroom.
Allow me to address your questions individually:
1A. Should the FAA require all pilot crewmembers engaged in part 121 air carrier operations to hold an ATP certificate? Why or why not?
Yes. I believe that the current requirement of a Commercial certificate is inadequate. This minimum was set decades ago when both the airplanes flown and the airspace operated in were much less complex. Raising the requirement to an ATP would multiply the minimum flight time requirement by a factor at least approximating this increase in piloting demanded by our current system. Not only does an ATP certificate require six times more flight hour experience, but is also demands that a pilot demonstrate an increased level of skill during a practical test under the examination by the FAA. This will allow the FAA to further fulfill its role of regulating the industry by keeping closer tabs on those pilots who will be carrying thousands of passengers. The requirements and standards set for achieving the ATP certificate demand the highest level of knowledge and proficiency of any pilot certificate. I truly believe both pilots, Captain and First Officer, operating an aircraft in Part 121 service should achieve this standard. I have no doubt that making this change will have an immediate, direct, and positive influence on pilot performance simply in virtue of the thinning process greater scrutiny and examination creates. Those who cannot meet aviation’s highest standards will simply never set foot in an airline cockpit, nor should they.
1B. If a part 121 air carrier pilot does not hold an ATP certificate, should he or she nevertheless be required to meet the ATP certificate aeronautical knowledge and experience requirements of § 61.159, even if he or she is serving as SIC? Why or why not?
Yes. While I believe the greatest good would come from requiring possession of an ATP certificate, at the very least the experience gaining by satisfying ATP minimums is a tremendous increase over the 250 flight hours now required by the Commercial certificate. Flight time, especially that as pilot in command, hones judgment, develops a healthy sense of skepticism, identifies vulnerability due to one‘s weaknesses, and solidifies confidence in one’s skill. Flight experience is gained and piloting skills are developed no other way than by time spent at the controls of an aircraft.
2A. Are aviation/pilot graduates from accredited aviation university degree programs likely to have a more solid academic knowledge base than other pilots hired for air carrier operations? Why or why not?
Perhaps. I do not believe that any of the large flight school’s academic programs provide any academic background that is not available to pilots on their own. I also question if an “academic knowledge base” is really what is lacking when discussing pilot performance issues. I think we would be better served by requiring more experience, not studies. While I do believe some concepts could be covered in more detail, I do not believe that this is in any way a substitute for experience, but rather an important addition to it.
2B. Should the FAA consider crediting specific academic study in lieu of flight hour requirements? If so, what kind of academic study should the FAA accept, and to what extent should academic study (e.g., possession of an aviation degree from an accredited four-year aviation program) substitute for flight hours or types of operating experience?
Absolutely not. This seems totally counter to the stated goal of increasing pilot performance. If flight time leads to greater experience and experience leads to greater pilot performance, what purpose would be served by lowering flight hour requirements? I can see no reason to set a standard, and then immediately create a way of skirting those requirements. Again: experience is what is lacking in low flight time pilots, and experience cannot be gained in a classroom. The only people who will stand to gain from these types of exceptions are the owners of those large flight schools who would be certified under this program who would see a large increase in admission to costly aviation programs providing dubious classroom training. Those hours and dollars would be better spent at the controls of an airplane.
2C. If the FAA were to credit academic study (e.g., possession of an aviation degree from an accredited four-year aviation program and/or completion of specific courses), should the agency still require a minimum number of flight hours for part 121 air carrier operations? Some have suggested that, regardless of academic training, the FAA should require a minimum of 750 hours for a commercial pilot to serve as SIC in part 121 operations. Is this number too high, or too low, and why?
Yes, but in my opinion this number is too low. The highest pilot certificate that can be attained is the ATP which requires a minimum of 1500 flight hours. We need to value the transport of passengers enough that we require both pilots achieve this highest degree of experience, knowledge, and demonstrated ability. Any time you begin to talk about exceptions or lowered minimums, you are undoubtedly compromising safety. I strongly believe there should be no exception to the 1500 flight hour requirement.
3A. Should the FAA propose a new commercial pilot certificate endorsement that would be required for a pilot to serve as a required pilot in part 121 air carrier operations? Why or why not?
I see this proposal as a non-issue as pilots operating at Part 121 carriers are already required to undergo training dictated by the FAA and provided by their company that covers topics specific to the environment they operate in. Whether the result of this training is a notation in the pilots training record, as it is now, or as an endorsement on their certificate, the end result is the same. Nothing new comes from this proposal.
3B. If so, what kinds of specific ground and flight training should the endorsement include?
N/A. See above.
3C. The FAA expects that a new endorsement would include additional flight hour requirements. At a minimum, the FAA requests comments on how many hours should be required beyond the minimum hours needed to qualify for a commercial pilot certificate. Some have suggested that the FAA require a minimum of 750 hours for a commercial pilot to serve as SIC in part 121 operations. Is this number too high, or too low, and why?
In my opinion this number is too low. The highest pilot certificate that can be attained is the ATP which requires a minimum of 1500 flight hours. We need to value the transport of passengers enough that we require both pilots achieve this highest degree of experience, knowledge and demonstrated ability. Any time you begin to talk about exceptions or lowered minimums, you are undoubtedly compromising safety. I strongly believe there should be no exception to the 1500 flight hour requirement.
3D. The FAA is considering proposing to require operating experience in a crew environment, in icing conditions, and at high altitude operations. What additional types of operating experience should an endorsement require?
No comment.
3E. Should the FAA credit academic training (e.g., a university-awarded aviation degree) toward such an endorsement and, if so, how might the credit be awarded against flight time or operating experience? We are especially interested in comments on how to balance credit for academic training against the need for practical operating experience in certain meteorological conditions (e.g., icing), in high-altitude operations, and in the multi-crew environment.
There should be no credit against flight time or operating experience, period. Any academic study to be done in a classroom should be in addition to flight experience as these are two separate areas. Academic study is no replacement for practical experience, and practical experience for a pilot comes solely from time spent at the controls of an airplane. While knowledge and experience are complimentary in developing skill and increasing performance, neither can replace or substitute for the other.
4A. Would a carrier-specific additional authorization on an existing pilot certificate improve the safety of part 121 operations? Why or why not?
No. Again, I see no practical difference between this and what is already required by the FAA in each airline’s required ground training program. Whether the completion of this training is noted on the company’s documentation or on the pilot’s actual certificate, what difference has been made?
4B. Should the authorization apply only to a pilot who holds a commercial certificate, or should it also apply to the holder of an ATP certificate?
No comment.
4C. Should such an authorization require a minimum number of flight hours? If so, how many hours should be required?
In my opinion the minimum flight hours required to operate an airliner should be the same for both pilots. The highest pilot certificate that can be attained is the ATP which requires a minimum of 1500 flight hours. We need to value the transport of passengers enough that we require both pilots achieve this highest degree of experience, knowledge, and demonstrated ability. Any time you begin to talk about exceptions or lowered minimums, you are undoubtedly compromising safety. I strongly believe there should be no exception to the 1500 flight hour requirement.
5A. Can existing monitoring, evaluation, information collection requirements, and enforcement associated with pilot performance be modified to improve pilot performance?
As a Line Check Airman at a Part 121 regional airline, I feel that the line checking process provides a great opportunity for information to flow both ways: pilots can be observed and monitored to maintain flight standards, while at the same time questions can be asked of the LCA or they can share concepts and ideas that the training department would like to see emphasized by pilots flying the line. I feel an increased frequency of this activity could not help but benefit flight safety.
5B. If so, what specific modifications should be considered?
I think that increasing the frequency of required line checks for the Pilot in Command from the current requirement of once every 12 months to perhaps every six or even three months would be a tremendous improvement. First Officers will see increased observations and opportunities for discussion as well since their oversight will increase in virtue of being line checked at the same time.
In conclusion, thank you again for this opportunity to provide input on the proposed rule change. I feel it is time to make a change that will truly increase the entry level experience of the pilots occupying our flight decks and recommend an ATP certificate be made mandatory for any pilot operating under Part 121. I also strongly oppose any exceptions being made to flight time requirements as this will by definition water down any progress made. I feel that these exemptions are being sought solely by those who would benefit financially from them (large flights schools who would seek this certification or airline management who want lowered minimums to increase the pool of applicants willing to accept low wages). This is a unique opportunity for the FAA to truly demonstrate its oversight of the airline industry and fulfill its responsibility of protecting the flying public by not bowing to the pressure of well-funded lobbyists and special interests who have goals which may be counter to the public good.
I truly wish you the best in your effort. The decisions you make today will determine the caliber of pilot I train tomorrow and the professionalism and proficiency of the pilots carrying you and your families far into the future.
Thank you for your time,
Captain James R. Orosco
Submitted by roberth on March 09, 2010.
The tragedy of the Colgan Air accident on 12 February 2010 was the result of the crew to react properly to a stall. Stall recovery is a maneuver required of the Student Pilot prior to first solo. There is no reason to believe that an Airline Transport certificate for the first officer would have prevented this accident. I therefore stand opposed to the proposal to require an ATP for first officers in Part 121 service (1A, 1B).
Before we jump to additional regulation, we should examine whether the current regulation is sufficient. A Student Pilot certificate is required to allow a pilot to fly alone. A Private Pilot certificate is required to carry passenger without compensation. A Commercial Certificate is required of a pilot to fly passengers for compensation. An Airline Transport Pilot Certificate is required to command a Part 121 aircraft in passenger carrying service. This hierarchy is logical and time-tested. It allows a Commercial Pilot to serve as a journeyman, learning to fly a Part 121 aircraft under the supervision of an ATP.
While there is no evidence that an ATP and the experience it requires would have prevented the Colgan tragedy, it is indisputable that additional training and experience is a good thing in the cockpit. As we consider whether the ATP should be a requirement for the right seat in a regional airliner, we need to take the long view. We need to maintain the logical pilot certificate progression provided by the Student > Private > Commercial > ATP hierarchy.
Currently, there is a surfeit of ATPs, so an immediate escalation of the requirement to the ATP would not affect the industry. As the industry recovers, the need for pilots will rebound. If the entry-level requirement for Part 121 carriers is increased to 1200 hour ATPs, there will be a drought of qualified pilots. A prospective airline pilot would struggle to get 1200 hours before applying to a regional carrier for an entry-level first officer position. There simply aren’t enough flight instructing, airfreight, and Part 135 jobs for the commercial pilot with 300-1200 hours. The only other option is for the prospective Part 121 pilot to pay for those hours himself or herself. The military is not longer a viable source for trained pilots with enough hours to take an airline job. We cannot allow a temporary economic situation (an unfortunate accident, an airline recession, and pilot surplus) to color a decision that will have long term affects on the airline industry.
If we accept the tested hierarchy of pilot certificates, then we should reexamine whether the Commercial certificate meets the needs of the regional carriers in terms of training and experience. I think not. I recommend higher standards for the Commercial certificate. This is counter to certain proposals made by the FAA. For example, the FAA is considering removing the requirement of training for Commercial pilots to eliminate training in airplane with retractable landing gear. This is a retrograde step. I do not support the creation of an additional grade of certificate. I recommend instead that the Commercial certificate have its requirements upgraded, without any additional endorsements (3A, 3B, 3C). The Commercial certificate should not simply by a written test and some additional aerobatic maneuvers.
I recommend instead that the Commercial Certificate requirements be changed as follows. This is a reordering of various existing requirements from other certificates, but no new ones. All of these items are obligatory in a Part 121 flight environment,
•The Instrument Rating should be a prerequisite for the Commercial Certificate.
•High Altitude training should be a prerequisite for the Commercial Certificate.
•Spin training should be a prerequisite for the Commercial Certificate.
•Training in retractable gear aircraft should remain a prerequisite for the Commercial Certificate.
•Crew Resource Management training should be added to the Commercial curriculum
As to other proposals in the ANPRM (4A, 4B, 4C), there is an undertone of indentured servitude. I am opposed to any limitation added to a pilot certificate that is carrier-specific. The carrier is free to institute whatever internal training requirements it desires, subject to the purview of the FAA over it Operating Certificate. To place a carrier specific-limitation on a certificate is to tell the pilot, "Your certificate is good only as long as you work for your current employer." This is contrary to the American precept of freedom of employment.
Overall, the ANPRM describes a scheme under which the existing Commercial certificate is rendered irrelevant. It would make more sense to revise the Commercial certificate to make it relevant again, rather than muddling through a series of half-steps, endorsements, limitations, and academic substitutions. Let us take the Commercial certificate conceived in the thirties and boldly make it relevant to the twenty-first century.
Robert Hadow
Commercial Pilot, Airplane Single Engine Land & Sea, Multiengine Land, Instrument Airplane, Glider
Instructor, Airplane Single and Multiengine, Instrument Airplane
Flight School Owner
FAA Safety Team Lead Representative
Submitted by GatorRob on April 05, 2010.
Wow..great information: Could you please help me get to a commerical academy to help gain the hours. Getting to 1500 hours at 146$ a flight hour is almost impossible today. No one will loan the money anymore. So here is my website..to help a privatepilot up to that level: www.fundapilot.com
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