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.