ALPA (Still) Supports Pilot Training, Qualification Provisions of H.R. 5900
Misleading information was published this week in the Thursday edition of
USA Today regarding ALPA’s position on pilot training and qualifications.
ALPA is still not at liberty to divulge the contents of the FAA’s Aviation
Rulemaking Committee (ARC) that addressed this subject, but it continues to
support the provisions of H.R. 5900, which contains the legislative language
used by the FAA as the basis for its deliberations with industry. The FAA is
working to turn the ARC’s recommendations into a Notice of Proposed Rulemaking
and it is on track to be published early next year.
ALPA’s September 2009 white paper
“Producing a Professional Airline Pilot” describes the complexity of this
issue. We concur with the recent statement by the Flight Safety Foundation that
the public deserves “a more sophisticated solution than a blanket move to 1,500
hours.”
The following is the content of a Nov. 4, 2010, FastRead on this
subject, which still accurately represents ALPA’s views:
This subject was considered at length by the
FAA’s First Officer Qualifications Aviation Rulemaking Committee (FOQ ARC).
Members of ALPA’s Air Safety Committee with expertise in pilot training, plus
the director of ALPA’s Engineering & Air Safety department, served on the FOQ
ARC earlier this year. As an ARC member, ALPA is prohibited from making public
comments on the committee’s recommendations until the FAA publishes its final
report. Therefore, ALPA is not yet authorized to specifically comment on the
content of the media reports. However, we can explain some of the history behind
the ARC and point to reference documents that clarify ALPA’s position on this
important subject.
The tasking of the FOQ ARC
was focused on sections 216 and 217 of H.R. 5900, which was signed into law on
August 1, 2010, as Public Law (PL) 111-216. In summary, the law directed FAA to
increase the minimum training and qualification requirements for pilots to be
hired at a future date by FAR Part 121 airlines, and set a minimum flight-time
threshold of 1,500 flight hours for that purpose. ALPA strongly and publicly
voiced support for the 1,500-hour minimum flight experience provision in the
law. However, the law also gives the FAA administrator the ability to give
flight-hour credit toward the 1,500-hour requirement for “specific academic
training courses [that] will enhance safety more than requiring the pilot to
fully comply with the flight hours requirement.” The FOQ ARC was tasked,
therefore, with defining the credit to be given toward flight hours on the basis
of specific academic classroom coursework completed by the pilot.
The final FOQ ARC report was delivered to the
FAA in September 2010; the agency has not yet made that report public. The FAA
will consider the FOQ ARC recommendations in producing a Notice of Proposed
Rulemaking (NPRM) that is consistent with PL 111-216. In accordance with that
law, the ARC report recommends new training and qualification standards for FAR
Part 121 pilots and establishes 1,500 flight hours as the minimum
flight-hour-experience threshold for pilots before they can be hired by a FAR
121 airline, but it does give the administrator the ability to allow some
credits toward flight hours on the basis of specific types of academic training.
ALPA strongly supports the work of the FOQ ARC
because its recommendations, if adopted, will create a much higher level of
safety than was required by Section 216 of the law. If the FAA adopts the
recommendations of the FOQ ARC, new pilots will be much better trained and have
considerably more experience than is required by current regulations. We believe
that the law’s flight-hour credit provision is entirely justified on the basis
of quality of experience and not merely quantity of experience. The military,
which gives its pilots extensive aviation-related academic and leadership
training as part of the flight training program, has proven that pilots with
many fewer hours than 1,500 are fully capable of operating high-speed, very
complex aircraft in demanding airspace.
Prior to the creation of the FOQ ARC, ALPA went
on record in April 2010 with
recommendations to the FAA about this subject in
comments to the Advance Notice of Proposed Rulemaking (ANPRM) on “New Pilot
Certification Requirements for Air Carrier Operations.” These comments, and the
ALPA white paper (September 2009) entitled “Producing a Professional Airline
Pilot,” provide much more detail about ALPA’s views on how to significantly
upgrade first officer qualifications.
We expect that the final ARC report will be made
public by the FAA in the near future. ALPA will release a summary of the report,
along with ALPA’s position on the report and its recommendations, at that time.
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