In the wake of the Colgan 3407 crash and the NTSB’s probable cause finding of pilot error, the FAA is asking the public for comments regarding pilot certification. In a Press Release issued today, the FAA asked for recommendations to improve pilot qualification and training requirements. Specifically, the FAA wants to know the following:
- Should all pilots who transport passengers be required to hold an Air Transport Pilot (ATP) certificate with the appropriate aircraft category, class and type ratings, which would raise the required flight hours for these pilots to 1,500 hours?
- Should the FAA permit academic credit in lieu of required flight hours or experience?
- Should the FAA establish a new commercial pilot certificate endorsement that would address concerns about the operational experience of newly hired commercial pilots, require additional flight hours and possibly credit academic training?
- Would an air carrier-specific authorization on an existing pilot certificate improve safety?
The FAA’s request is part of its “Call to Action” which “aims to strengthen pilot hiring, training and performance, as well as combat fatigue and improve professional standards and discipline at all airlines.” An Advance Notice of Proposed Rulemaking (“ANPRM”) will be published next week in the Federal Register providing a 60-day comment period within which the public may submit comments regarding the ANPRM. The ANPRM should be available here, possibly before it is published, but definitely after publication.
It will be interesting to see both the comments and how the FAA handles the comments. Interestingly, the area of “pilot judgment and decision making” is absent from the FAA’s request. At least in the Colgan 3407 case, the pilots had received training, but exercised poor judgment and decision making in dealing with the situation. Unfortunately, I am not sure that requiring 1500 hours and an ATP is going to address this issue. Also, requiring 1500 hours and an ATP will significantly decrease the pool of qualified pilots available for hire by the airlines. In any event, hopefully the FAA will give thoughtful consideration to these issues, and the flood of comments I expect it will receive, and issue a rule that will reasonably address the issues without imposing unreasonable limitations that will further damage the aviation industry.
