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RAA Files Comments: ANPRM, New Pilot Certification Requirements for Air Carrier Operations 

Monday, April 12, 2010   (0 Comments)
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April 9, 2010
Docket Management Facility
U.S. Department of Transportation
Docket Number FAA-2010-0100
400 Seventh Street, SW.
Nassif Building, Room PL-401
Washington, DC 20590-001.

SUBJECT: ANPRM, New Pilot Certification Requirements for Air Carrier Operations


The Regional Airline Association (RAA) submits the following comments on behalf of our airline membership .

The Federal Aviation Administration (FAA) published an Advanced Notice of Proposed Rulemaking (ANPRM) in the Federal Register on February 8, 2010 (see 75 FR 6164), seeking public comment concerning potential changes to the certification of airmen conducting air carrier operations under 14 C.F.R. Part 121.  The Regional Airline Association (RAA) and its members have a wealth of experience in, and commitment to, the qualification of airmen conducting such operations, and we respectfully submit the following comments on behalf of our 31 airline members regarding this important and timely proposal.

Regional Airlines’ Veteran Management Teams and Pilots Support Training Excellence and Pilot Certificate Review

Today, regional airlines operate more than half of the scheduled domestic passenger flights in the United States, and some 75% of the airports currently enjoying scheduled commercial passenger flights have those flights provided exclusively by regional airlines. Virtually all of these scheduled flights are operated under FAR Part 121, operated to the exact same standards as “mainline” airlines.

Regional airline pilots have experience and receive training that far exceeds the minimum requirements established by the FAA.  On average, flight time of captains at RAA member airlines exceeds 8,500 hours while our first officers generally have more than 3,200 hours.  Our veteran management teams and pilot cadre understand that good training improves safety.  Our pilots, new and senior alike, are trained and routinely tested to FAA’s Air Transport Pilot (ATP) standards – the agency’s highest standard of flying skill and the same that is applicable to the major air carriers.  New pilots are also supervised by the industry’s most experienced check pilots and mentored by our more veteran captains as they gain valuable experience.  Regional airlines have been at the forefront of industry efforts to continually improve training, especially in the areas of unexpected events and our understanding of how human factors and developing enhanced leadership skills can reduce safety risks.  As demonstrated by the results of FAA’s Call to Action audits last summer – when the FAA inspectors observed 2,419 training and checking events – our highest priority is to maximize safety.

    RAA strongly endorses a thorough FAA/industry review of all the issues involved in pilot certification standards for air carriers because the aviation industry has voluntarily adopted significant advances in safety systems, aircraft technology and training methodology since the rules last underwent significant changes.

    Parallel to, or as part of, this comprehensive review, consideration must be given to the changing demographics of the pilot population –who they are, how they learn, and what career paths they’ve followed.  All of these factors have a role in a holistic approach to reviewing pilot certification standards. 

Broad-Based Support for Training Quality

    A fundamental element of this review must be recognition of the facts on the ground and, consequently, a shift away from use of arbitrary “flight hours” as an appropriate barometer for measuring pilot skill.  As the FAA Administrator and numerous safety experts have testified, “quantity does not equal quality.” There is no empirical evidence that total time equates to safety and, in fact, the hours experience level of an airline first officer has never been cited as a causal or contributing factor in any Part 121 operator accident.  Total time may provide optical “cover,” but it fails to address the most common causes of airline accidents – i.e., complacency, lack of professionalism, non-adherence to standards, loss of situational awareness, and inappropriate reaction to unexpected events.
    In fact, raising the existing, arbitrary total flight hour requirement could have the unintended and negative effect of reducing the number of highly qualified airline pilot professionals without any demonstrable safety benefit. In piloting, as in virtually every other profession (e.g.,  medicine, law, academia, etc.), the cost burden of obtaining the requisite education and training is borne primarily by the student.  Raising the hour requirement will compel students to obtain the needed hours in the cheapest way possible – precisely the kind of operations providing the least benefit to those learning skills (i.e., two person crew, challenging weather conditions, complex aircraft and airspace) most needed to prepare them for modern airline operations.

RAA’s greatest concern is that a time-based certification standard would create an incentive for bright, career minded trainees to abandon their advanced education to focus entirely on gaining flight time – a detour that often fails to lead to their skill development.  “Hours” for such time-based certifications can be accumulated relatively quickly and cheaply in ways that do not meaningfully prepare students for airline operations (e.g.,  towing banners).

Mission Based, Structured Training Proven Effective

“Mission based” training offers a far more beneficial alternative to arbitrary flight time limits.

The significant role and value of modern structured mission-based training and education programs should be considered as part of the overall review.  Our members’ experience illustrates that pilots successfully completing these advanced programs – many structured in collaboration with major airlines – have consistently demonstrated a higher level of skills set performance in airline training programs and flight operations.

Another advantage of structured programs is that they better reflect the “real world” of a scheduled airline.  At these institutions, students learn a broad, multi-faceted curricula and work alongside individuals from across the demographic spectrum.  This environment prepares pilot professionals for life in the modern airline world far better than traditional pilot training did “back in the day.”

This situation underscores a shortcoming in the existing certification protocol. The current certification testing standard for commercial pilots does not recognize, institutionalize or “give credit” for advanced education that better prepares pilots for flying in airline service.  Universities and training academies now have specific programs designed to train airline pilots.  Additionally, from the minute a prospective pilot walks into the airline “school house” he or she is exposed to an airline “faculty” that is continually teaching and training by building on real world experience in all weather and airport conditions and the full body of work that a professional airline pilot needs to succeed. The certification/licensing requirements should recognize such valuable real-world, hands-on training.


Convene an industry/FAA Aviation Rulemaking Committee (ARC) process to:

- Review all the existing industry best training and education practices, including ICAO and global efforts, and incorporate those proven to be effective into revised/updated certification standards.
- Extend these above-referenced practices into structured training programs (much like regional airlines are already doing today).
- Formalize leadership training into the guidance, and include performance monitoring and analysis for new pilots.
- Determine if any gap in experience and training levels exists between the current requirement for a commercial license and what is most appropriate for an airline license.
- Develop, if needed, the most effective, least administratively and most portable “endorsement” certificate for airline pilots that recognizes and institutionalizes the advanced level of training currently afforded pilots flying in Part 121 operations.

Perhaps most importantly, support the most professional and advanced structured training programs by establishing and funding a formal program for investment in aviation education.  Aviation safety is an issue of national importance, and the need to develop aviation professionals of all types –pilots, mechanics, technicians, and controllers – should be a national priority.  As the federal government embarks on a multi-billion dollar effort to fund NextGen air traffic technology, RAA believes it is equally imperative to invest in the system’s human foundation: the NextGen of aviation professionals.

RAA’s answers to the specific questions follow below:

1A. Should the FAA require all pilot crewmembers engaged in Part 121 air carrier operations to hold an ATP certificate? Why or why not?

    The time and expense necessary to acquire 1,500 hours of total flight time is by far the biggest hurdle in obtaining an ATP certificate.  If an applicant needs an ATP before an airline can hire him or her as a first officer (FO), a prospective pilot will likely reconsider attending a four-year aviation school as a path to a pilot career; or worse yet, he or she may choose an entirely different career because the upfront costs of acquiring 1,500 hours of flight time is so enormous.  We expect the University Aviation Association (UAA) to submit comments that will describe in further detail what impact this proposal would have on their members (Part 141). However, based upon current programs, we estimate that a graduate from a four-year aviation degree program will have acquired approximately 200 to 300 hours of flight time; leaving the remaining 1200-1300 flight hours for an ATP certificate up to the graduate to acquire before he/she is qualified for employment by Part 121 air carrier under this proposal.  RAA members support all current avenues an individual may choose to become a pilot; however many of our members have teamed up with local aviation universities and have had great success in hiring highly competent graduates from these schools.  We cannot support a proposal that rewards “experience” simply in the form of acquired flight hours at the expense of the valuable knowledge that an applicant would otherwise have acquired at a four year aviation university.

    The additional 1,200-1,300 required flight hours may not be in aircraft or environments conducive to gaining "more experience" suitable for commercial flying and may, in fact,  give candidates the opportunity to form “bad habits” that are contrary to commercial flight safety.  U.S. Military pilots fly not only high performance fighter aircraft but also large aircraft similar to commercial aircraft with approximately 300 hours total time after training and in much more challenging conditions.  The FAA should consider a “Professional Pilot” curriculum that differs from the current course to ensure that there is a higher level of training and experience, just as the military does. This specific curriculum could be taught at Part 141 schools or Part 142 academies that adopt and are certified to teach a program that perhaps offers a “professional pilot” degree.

    Furthermore, the additional flight hours required beyond those presently provided upon graduating from a Part 141 school do not necessarily make the individual into a pilot better-suited for commercial operations.  European airlines have been very successful in employing ab-initio training programs where flight crew employment occurs at an all-jet carrier directly upon course completion with as little as 350 hours of flight experience.  Similarly, Canada has an “ATP Integrated” requirement for employment as a FO.  The ground and flight training requirements are more stringent than the FAA ATP requirements; however, the candidate may graduate with as few as 205 hours of flight time.  (See Transport Canada standards 426.75.) The adoption of 1,500 flight hour standard for FO’s cannot be harmonized with existing and highly respected foreign regulatory standards.

 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 Sec. 61.159, even if he or she is serving as SIC? Why or why not?

    If “experience” simply equates to 1,500 hours flying time before a FO can sit in the right seat of a commercial flight, then our answer is “no.”  As noted, most airlines already train all pilots to ATP knowledge standards, and the full certification should be accomplished when the individual fulfills the necessary “experience” requirements.

    In the “old days,” an FO was in the aircraft to assist the Captain with his/her duties; this is no longer the view.  RAA members train and check their FO’s to the same standard as their Captains.  Training programs now found at all Part 121 air carriers train the FO to competently command the aircraft in the event the Captain is incapacitated. The FAA check pilot conducts a check ride to ensure FO’s are capable of commanding the 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?

    We concur that a candidate with an aviation degree is better prepared to transition to the structured training environment of an air carrier.  However, we also consider candidates who have chosen other paths toward acquiring a commercial pilot’s license to be potentially excellent pilots for operating in a Part 121 air carrier environment. The candidate’s actual operating experience and motivation make the most difference.

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?

    This idea has merit. Many of our members have “bridge” programs with aviation universities so that their knowledge training is closely aligned with the training programs provided by the air carrier.  Likely this approach could result in some combination of (reduced) flight experience and additional academic requirements.  We suggest the FAA consider the work done by such groups as the Professional Aeronautics Board of Accreditation (PABC) for possible recommendations

     Again, however, our general concurrence should not be misinterpreted to suggest that Part 141 schools are the only way to start an aviation career in air carrier operations. If this were to become a rule, it could lead to exclusiveness and a non-competitive environment, eventually resulting in increased costs and mediocrity.  Air carriers should be provided the opportunity to select the best FO candidates from a variety of backgrounds and aviation experiences.

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?

    We would expect that a regulation detailing a requirement for FO’s would specify a minimum number of flight hours. What we cannot support is a minimum number of flight hours that adversely impacts existing four-year aviation university programs, particularly to the extent such a requirement would have a detrimental effect a university’s ability to provide a comprehensive four year curriculum.  RAA simply cannot support a requirement where a student would have to attend a Part 141 university for five or six years in order to qualify for a FO position with an air carrier.  Every profession should have a reasonable and achievable entry level position gradient.  For the professional pilot, it is the FO position.

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?

    This is unnecessary since each Part 121 air carrier trains all its pilots in the required subject areas.  If additional subject areas are shown to be lacking in air carrier training programs, then those programs should be revised to include the additional subject areas.  This is best left to the individual air carriers who hire and train pilots for their own operation.  FAA oversight of the air carrier ensures that additional subject areas are covered based on that air carrier's operating environment.  The preamble also indicates that changes to an air carrier’s training program is beyond the scope of this ANRPM.

3B. If so, what kinds of specific ground and flight training should the endorsement include?

    It should be left to an individual air carrier to provide the training and qualification requirements that best address its operating environment.  However, given the current competitive environment, we could envision pilot schools and training centers offering specialized training programs for students seeking a career with a particular air carrier.  Our earlier comment on “bridge programs” is also applicable in response to this question.

 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?

    Regional airlines have an excellent record of hiring recent graduates from accredited four-year aviation universities and, after the new hires have completed rigorous initial indoctrination and training programs, being able to place them in the right seat for commercial operations.  A 750 hour recommendation, while obviously more reasonable than 1500 hour one, nonetheless presents a sizable obstacle to a graduate from a Part 141 university. We question whether the graduate, most likely already in debt from attending a four-year school, will obtain quality flight time in order to make up the difference, or will opt for cheapest – and likely the least appropriate – method of obtaining hours.

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?

    Operating in icing conditions is difficult in simulators since they cannot accurately replicate airfoil distortion, nor the asymmetry of distortion.  High altitude chambers are available to students and pilots, and RAA member air carriers are presently working on an FAA industry task force for changes to the air carrier training curricula. Training for operations in icing conditions and high altitude is highly dependent upon the aircraft type; it is therefore more appropriate that this training be left to individual air carriers under FAA regulation and supervision to provide the optimal training and qualification requirements for each specific operating environment.

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 is no data suggesting that the current balance of credit for academic training versus actual operating experience is not effective. The value of  practical operating experience provided in a pilot school environment should not be diminished.

4A. Would a carrier-specific additional authorization on an existing pilot certificate improve the safety of part 121 operations? Why or why not?

    This approach could minimize the disruption in implementing a new standard for airline FO’s who do not currently hold an ATP. We assume the new standard would be something between a commercial and ATP standard, and we strongly recommend this approach be considered as part of the ARC process noted above. We, again, emphasize that all Part 121 air carriers train and qualify their FO’s to the same standards as their Captains.  If additional subject areas are shown to be missing in air carrier training programs, then those programs should be revised to include the additional subject areas

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?

    There is no data suggesting that the type of certificate a FO possesses will improve safety.  Our members have implemented a variety of voluntary safety programs to measure the quality and performance of their pilots; such programs will yield a much greater safety benefit than what this ANPRM is suggesting.

4C. Should such an authorization require a minimum number of flight hours? If so, how many hours should be required?

    We would expect that a rule detailing a requirement for FO’s would specify a minimum number of flight hours.

 5A. Can existing monitoring, evaluation, information collection requirements, and enforcement associated with pilot performance be modified to improve pilot performance?

    The FAA currently has a database of pilot check ride evaluations and enforcement actions, and it is important that air carriers are able to readily access such data when hiring new pilots.  This recommendation is a cornerstone to RAA’s Strategic Safety Initiative (SSI) and has been incorporated into pending aviation safety legislation in Congress.  However, the data must be coupled with proper assessment and evaluation.  We support LOSA audit programs and analysis of check rides to identify undesirable trends for all pilots.  Once areas are identified, individual pilot training can be focused to rectify such trends.

 5B. If so, what specific modifications should be considered?

    The FAA should more effectively analyze its own database of pilot evaluations and enforcement actions to identify high risk areas.  Once areas are identified, pilot certification requirements could be modified to include training and qualification in those areas.

Your consideration of our comments and the comments of our members is greatly appreciated.


Roger Cohen
President, RAA

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