Yesterday the FAA published it’s Advance Notice of Proposed Rulemaking (“ANPRM”) titled New Pilot Certification Requirements for Air Carrier Operations which I discussed in my February 4, 2010 post. According to the ANPRM, “[t]he purpose of this notice is to gather information on whether current eligibility, training, and qualification requirements for commercial pilot certification are adequate for engaging in such operations” and “[t]he FAA may use this information to determine the necessity of establishing additional pilot certification requirements and to determine what those new requirements might include.”
The ANPRM requests comments and recommendations regarding the following specific questions:
1A. Should the FAA require all pilot crewmembers engaged in part 121 air carrier operations to hold an ATP certificate? Why or why not?
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?
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?
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?
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?
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?
3B. If so, what kinds of specific ground and flight training should the endorsement include?
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?
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? 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.
4A. Would a carrier-specific additional authorization on an existing pilot certificate improve the safety of part 121 operations? Why or why not?
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? 4C. Should such an authorization require a minimum number of flight hours? If so, how many hours should be required?
5A. Can existing monitoring, evaluation, information collection requirements, and enforcement associated with pilot performance be modified to improve pilot performance?
5B. If so, what specific modifications should be considered?
It will be interesting to see the comments to this ANPRM. I suspect the FAA will receive a lot of comments. I would also expect that the comments will vary widely depending upon who is submitting them (e.g. airline, academic institution, flight school etc.). Reconciling and/or incorporating the comments into a notice of proposed rulemaking (the next step in the process) will not be an easy task. How/whether the FAA will be able to accomplish that task in a fair and reasonable manner, as always, will be the key question to answer.
Comments to the ANPRM are due on or before April 9, 2010. If you have questions regarding the ANPRM or need further information, you may contact Craig Holmes, Certification and General Aviation Operations Branch, AFS-810, General Aviation and Commercial Division, Flight Standards Service, Federal Aviation Administration, 800 Independence Avenue, SW., Washington, DC 20591; telephone (202) 493-5385; e-mail to craig.holmes@faa.gov.
