172 Captain

http://pilotpartisan.files.wordpress...-to-huerta.pdf

December 10, 2012
The Honorable Michael Huerta Acting Administrator
Federal Aviation Administration 800 Independence Avenue, SW Washington, DC 20006
Dear Acting Administrator Huerta:
The FAA issued a Notice of Proposed Rulemaking (NPRM) on Pilot Certification and Qualification Requirements for Air Carrier Operations in the February 29, 2012 Federal Register. The NPRM proposed new training and qualification criteria for first officers in airline service, which included a requirement that these crewmembers hold an Air Transport Pilot (ATP) certificate and a type rating for the aircraft flown. The comment period for the NPRM closed April 30, 2012.
The NPRM was initiated as a result of the enactment of Public Law 111-216, the Airline Safety and Federal Aviation Administration Extension Act of 2010 (the Act). The Act requires that, effective August 2, 2013, all pilots in FAR 121 air carrier operations possess an Airline Transport Pilot certificate (ATP). The Act also required the FAA to conduct a rulemaking to “modify requirements for the issuance of an airline transport pilot certificate.” The Act gave the FAA latitude, in consultation with experts, to determine whether flight hour credits should be given to ATP applicants based on pertinent academic achievement and thereby reduce the number of hours needed to qualify for the ATP certificate. The Act required the FAA to issue a final rule to address these issues not later than 24 months after the August 1, 2010 date of enactment, namely, August 1, 2012.
As a result of the relationship between the ATP requirement mandated by PL 111-216 and the rulemaking proposed by this NPRM, it is important that the FAA act on this NPRM and issue a final rule before August 1, 2013. Industry would benefit from knowing, as soon as possible, what actions they will need to take in order to be fully compliant with the new requirements. Without such certitude, hiring, training and scheduling practices are being negatively impacted today at numerous carriers, and the effects are felt by the companies and their flight crew employees.
An additional concern is current pilots employed by FAR 121 airlines that will not meet the provisions of the FAA proposed regulation to qualify for the ATP certificate. Many of these pilots have been flying in airline operations for a considerable amount of time and have successfully completed initial training, a number of recurrent training cycles, and a number of line evaluations. We would also request that you consider the inclusion of a provision in the final rule issued in response to this NPRM that would give flight hour credit to these individuals based on their airline training history and experience that would qualify them for the “restricted” ATP proposed or the current ATP. We would suggest at least 13 months of employment at the FAR 121 airline. This would cover successful completion of initial training, a number of line evaluations, and at least one recurrent training cycle. Accordingly, we would respectfully request that the FAA expeditiously issue a final rule on part 121 pilot certification and qualification requirements. We would be pleased to discuss this matter with you, as desired.
Sincerely,
Lee Moak, President Nick Calio, President Roger Cohen, President
Air Line Pilots Assn. In’tl Airlines for America Regional Airline Association

HSLD

Maybe someone can be the tie breaker, but the way I read the letter is:

"...FAA, please hurry up and make your final ruling so we can figure out hour many pilots to hire. Also, will you grandfather the few incumbent regional F/Os that fall short of the ATP flight hour requirement based on the demonstrated proficiency in the performance of their jobs..."

In fact, I think the article was actually titled:

Full Article with linked letter: ALPA urges FAA to credit pilots for employment and training experience in implementing new pilot certification rules | Pilot Partisan

To be fair, that is an exemption, but only for a few select and currently working pilots. Not an exemption for new hire pilots.

todd1200

I agree. ALPA is advocating an exemption, so the thread title isn't technically incorrect, but the exemption is a very narrow one: only for FOs who have been flying 121 for 13+ months.

Phuz

How many of these people are there, really? Alpa says they have been employed for a 'considerable' amount of time yet they have not reached 1500 hours? The airlines have known about this rule for over 2 years, they should have been hiring with it in mind.

I dont understand how alpa is okay with outsourcing in order to protect (fewer) high paying mainline jobs but they are not okay with allowing some sacrifice of low paying jobs that would hamper or close some bottom feeder outsourced operations. It seems very backward to me.

And if saint alpa is worried about keeping these poor down trodden folk employed at 25k/yr i must point out that you can make that working as a waiter just about anywhere in the country. The newhire pilots would find a way to get by, the only thing that really suffers if they aren't exempted is the regional outsourcing model itself.

Who has been hiring people that wouldnt meet this rule anyhow? Gojet comes to mind, but they aren't alpa.

pilotrob23

Why didnt they make an exemption for pilots who turned 60 before the 60 rule then to come back in seniority? ALPA is losing its mind, and has no idea what it is fighting for anymore. Glad Michigan voted for the right to work. These unions need to go.

Grounded

As someone that currently works for a supplemental that is nonunion and is based out of a state that is "right to work." All I can say is be very careful what you wish for....

rickair7777

Very, very few. I guess I'm OK with grandfathering anyone who's been employed for 13 months or more.

But anyone who took an airline job with 300 hours last month should have known better...they can go back to their Cessna.

As to APA's motives, the same as they always are...people with less than 13 months don't pay dues

pilotrob23

I paid my ALPA dues for seven years, and I could speak for many that wish and didnt want to pay them, or wish they had the option to pay or not to pay dues. Like settling a grievance at about 9% of what should have been paid, losing 15k in the process. Very glad to be out of it from my personal experience. If a union is going to exist, I always thought that some of the "in-house" unions worked better, ie SWA, UPS. I have some wonderful buddies that worked their tail off in the union, but they did enjoy the Florida, and Vegas union "parties"! Cheers, just bad experiences for me, hope they treat everyone else better!

rickair7777

Unions can still function in right-to-work states. They just can't take 2% of your pay and do nothing for you. They become less like a government agency (entitled to exist and tax) and more like free market.

There will always be free-loaders, but I think MOST pilots would pay a reasonable union due in exchange for measurable perceived benefits. Me personally, I'd be willing to pay more dues for better results! The leaders would simply have to explain how the dues are to be used and what the expected results are to be (and how said results are measured).

lolwut

No matter what, its somewhat saddening to see Lee Moak's and Roger Cohen's signatures together for a common cause.