ALPA Supports the Pilot Training and Qualification Requirements of H.R. 5900
ALPA has received several inquiries recently concerning the Association’s position on flight-experience requirements for future first officers. Some of the media reports on this topic have been incomplete and/or inaccurate, which has undoubtedly contributed to confusion and misunderstanding.
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.