If anyone has a problem with me posting this, please PM me. I offer no opinion.

Riddle's Answers:

1A. No, not for first officers.
The ATP requires 1500 flight hours of and a minimum age of 23. Neither is necessary. Thousands of pilots have entered the Part 121 work force as first officers with less than 1500 hours and younger than 23.
1B. Yes, to knowledge; No, to the age or 1500 hours requirements.
The pilot should also accomplish items in paragraph D of Attachment 1. Graduates from Aviation Accreditation Board, International (AABI) accredited programs meet requirements of paragraph D by virtue of the accreditation.
2A. Yes, supported by results of the Pilot Source Study (2010) conducted by a research team of seven colleges/universities and with new-hire data from six commuter air carriers. This study showed that the most successful pilots in the entry-level airline training were graduates from colleges/universities accredited by AABI.
2B. Yes, pilots from an AABI accredited four-year degree, flight education program should be allowed to enter Part 121 carrier training with degree plus 550 flight hours including at least 100 hours of operational experience as a CFI or some other professional pilot activity. Pilot Source Study supports this conclusion.
2C. Yes, too high. Findings of the Pilot Source Study show that the most successful entry-level first officers are those who have between 500 and 1000 hours, experience as a flight instructor, and graduated from an AABI accredited four-year flight education program.
For pilots from other sources, 750 hours, including 100 hours of operational experience, is about right if academic modules in Attachment 1 completed.
3A. Yes. There should be either a Commercial Pilot Endorsement or a First Officer ATP (Attachment 1).
3B. Attachment 1.
3C. Varies by source of training. The endorsement could be made at 550 hours including 100 hours of operational experience for pilots from AABI accredited programs. For others, endorse at 750 hours including 100 hours of experience plus academic modules.


Part 121 First Officer Airline Transport Pilot Qualification

A. To attain the Part 121 First Officer ATP Qualification the candidate must:

1.have completed the requirements for the private, commercial, instrument, and multi-engine land certificates and ratings under FAR Part 61, 141, or 142
2.have completed the First Officer ATP Qualification academic modules described in paragraph D below.
3.a. for Aviation Accreditation Board International (AABI) accredited four-year flight education degree program graduates, have acquired at least 550 total hours flying time including at least 100 hours of operational flying experience in professional flight activities such as: flight instructor, charter pilot, corporate pilot, Part 91 pilot carrying passengers
b. for graduates from other flight training providers, have acquired at least 750 total hours flying time including at least 100 hours of operational flying experience in professional flight activities such as: flight instructor, charter pilot, corporate pilot, Part 91 pilot carrying passengers
4.have completed the knowledge examination for the Airline Transport Pilot (ATP) certificate
5.be of high moral character.

B. The requirements for A1 may be completed by means of a college/university flight education program or other flight training providers. Graduates from college or university flight education programs accredited by the AABI will have met these requirements by virtue of the accreditation.

C. The requirements for A2 may be completed by the following means:

1.Graduates from college or university flight education programs accredited by the Aviation Accreditation Board International will have met these requirements by virtue of the accreditation.
2.Graduates from other flight training providers must complete the modules described in paragraph D.


D. Academic Module Outcomes.* The successful candidate will be able to:

1.explain turbine engine theory
2.explain high altitude airspace
3.explain jet transport navigation and approach procedure chart interpretation
4.describe air carrier aircraft flight guidance systems
5.explain the effects of high altitude physiology
6.conduct air carrier flight planning
7.describe high altitude weather
8.explain weather radar
9.describe severe weather avoidance procedures
10.describe aircraft icing, anti-icing, de-icing, and the possible consequences of airframe icing
11.explain FAR Part 121 - Certification and Operations: Domestic Flag and Supplemental Air Carriers and Commercial Operators of Large Aircraft
12.explain a jet transport flight management system
13.explain a jet transport engine monitoring system such as EICAS
14.explain air carrier operations procedures
15.explain air carrier safety programs and issues
16.describe and explain hydroplaning
17.explain wind shear avoidance
18.describe air carrier aircraft systems for an air carrier aircraft equipped with modern avionics.
19.describe jet transport aircraft emergency procedures
20.compute air carrier aircraft performance, weight and balance
21.describe appropriate pilot professional responsibility and ethics
22.explain the elements of good customer service
23.explain concepts of aviation safety, to include FOQA, ASAP, and SMS
24.apply crew resource management, crew concept procedures, and Line-Oriented Flight Training (LOFT) concepts in: an operational environment such as in a turbine transport category aircraft; or in a training environment using a transport category Simulator (level D), or transport category FTD (at least level 6). The device must be equipped with modern avionics (glass). Airline flows and procedures will be used. An upset training scenario is required. Flight into icing is required. At least 20 hours of instruction is required in the device.

*It is anticipated that these modules will be outsourced by the FAA to be developed, taught, and completion certificates awarded by the provider(s). All modules, with the exception of Module 24, should be offered in an on-line learning environment. It will be the pilot’s responsibility to accomplish these modules. Testing for module completion would be accomplished through an approved FAA Testing center.

So all of the other time building paths would be excluded - like ban towing, pipeline, fish spotting, check runs, etc...? This professional pilot experience would have to come from some type of passenger service?
Am I reading that part right?

USMCFLYR

What school is going to hire anyone to give 100 hours of instruction? You can do that in a month. 100 hours of dual given and you're JUST starting to figure out HOW to instruct.

All ERAU Alumni, please write to the school and tell them how disgusted and embarrassed you are over them trying to subvert legislation to improve safety, in their own interest of profit.

You can find contacts here....

Embry-Riddle Aeronautical University Alumni - Contact Us

After 12,000 hours of flight time and only 2700 hours of my flight time is as a first officer, I agree with you 100% percent.

ERAU = puppy mill

Time in the caravan taught me that pilots that make bad decisions in the van also make bad decisions in other aircraft as well. The van will not forgive a pilot for not thinking, especially in icing.

I would be glad to email Riddle if someone can help out with a template. I have never been good at expressing my opinions strongly and effectively. If someone can make a template for everyone to send just like for the CVR Bill.

Funny, plenty of people did just this 20+ years ago. Perhaps it had something to do with a worthwhile payoff after a few years of crap - something the industry had done it's very best to eliminate.

You are correct - very few are going to find the rewards worthwhile if the end of the line is left seat of an RJ earning $75K/annum.

PS- Could be a B-747, if the $$$ aren't there, no one worthwhile is going to want to do it...

The bad decision is thinking the airplane would be as fun to fly as a C-172. It was more like flying a King Air 90 around with an engine out.

:D

Although I shouldn't have flown jets prior to C208s. I just expected more. Like climb performance, ice protection while flying in the ice and to be able to see forward even in the rain. It had some good qualities here and there.

Pipeline patrol pilots need immediately in Louisiana, Texas and Mississippi area. Position can expect to fly 20-30 hours per week. 26K to 50,000K per year. Must meet following minimum requirements: 500 TT Commercial Instrument. To apply, email resume to:
---
Wow, thats more than some airline pilots want new hires to be paid. :rolleyes:
---
As to fish spotting, my understanding is that most boat operators want people who've spent time on the boat. Or at least this was the case in the early 1990s in the Chesapeake Bay. You got paid a % of what the boat made as incentive to find fish. Many of the airplanes were owned by the pilots, the 152 was choice because it was cheap. They were mostly lifers flying those planes and happy because that % could be rather lucrative.

Just emailed my opinion to the Alumni contacts. Seriously doubt it will make a difference though.

Hello,

Thank you for taking the time to read my email.

I have recently learned of ERAU’s efforts opposing the portion of the new safety regulations that would require an airline pilot to hold an ATP rating. This makes me ashamed to be an Embry Riddle graduate.

I attended Embry Riddle Prescott campus 1998 through 2001. I graduated with a bachelor’s degree in Aeronautical Science. I was unfortunate on my timing and ended up bagging groceries for a few months. I was able to get a flight instructor job late spring 2002. I then worked with my first employer doing a multitude of flying until early 2005. From there I flew cargo until summer 2006. I then started flying as an airline pilot with my current employer.

Through all of this I have learned many valuable lessons, both about life and about flying. And through those lessons I grew to see my Embry Riddle degree as baggage. Many in the industry do not feel the way about Riddle graduates as Embry Riddle staff and faculty feel. These are what I have encountered, both of which are very true.
1) Embry Riddle pilots are no better and no worse than other pilots trained by other means. In fact, I would say the place I instructed at had far better flight instruction than the average available at Riddle. This is because the business owners were very concerned with not hiring instructors solely focused on building flight time. They wanted instructors that cared for their students progress and exhibited enough professionalism to work hard for it. In my time while a student at Embry Riddle I would say half my flight instructors were true professionals. The other half were only interested in the flight time they could extract from me.
2) Embry Riddle pilots are arrogant. This is a broad generalization and not entirely true. However, the habit of instructors and professors pumping up students as superior to other candidates does tend to make them think to highly of themselves. An arrogance that is not founded in reality.

It is the school’s recent actions though that have made me want to cut all ties. The school is lobbying against much needed safety regulation changes. They are doing so as means to prevent declines in student numbers. Or if their other efforts are successful to even increase the need for Embry Riddle’s services. This effort is transparent to the professionals already working in the field, and it further sours Riddle’s name in their mouths.

Through my first few jobs and the great lessons learned I had the good fortunate to realize that for pilots, experience teaches the most important lessons. Experience that cannot be taught and substituted from books. Experience that is valuable and necessary to improving safety of flight. Experience that is actually severely lacking with pilots coming from Riddle that have their hand held through all decision making.

The propaganda being spread to current students highlights that some fresh commercial pilots have ended up in the airline ranks without adverse safety consequences. This is very misleading and shows how out of touch the writers are. These fresh pilots rarely serve as more than a weight occupying a required seat. They will eventually gain experience and will then be valuable crew members. But in the meantime the travelling public is put at risk. Risk of this person not having the experience when encountering a grey areas that happen far to frequently with operations people only concerned with ‘moving the medal’. Or the experience necessary in an emergency.

Monkeys can be taught to push buttons and respond by rote to situations. The importance of staffing airliners with humans and not monkeys is that humans can apply judgment to their decisions and actions.

Through the school’s actions on this matter I am now ashamed of my degree. I will actively discourage others from attending.

SPLANKY. I applaud you! There is a checkbox on an application. Not a section that says you are special because you went to riddle or UND. I went to riddle for one semester and was not impressed. I was getting just as good or better instruction at a community college and an FBO.

Splanky you pretty much echoed exactly what I wrote. We need more alumns doing this.

Why does Riddle think ASA cut off the direct hire program almost as soon as it started? The inexperience and arrogance were frightening. Finally some 180 hour new hire smoked a motor over temping it and they killed the program.

Is it possible to see the comments before the comment period is up? maybe someone should just attatch this thread to the docket :rolleyes:

THANK YOU!!!! Thank you for your dedication to the aviation industry and doing all you can to make the industry better! I too am writing (at a risk of losing my job that I am not afraid to take) to those involved in this HORRIBLE debacle! I, also at great risk, have the e-mail addresses for the President and CEO of ERAU as well as the Exec. VP of the Prescott Campus available to those who want it. They can also be found on the ERAU website but you have to search for it under the People Search tab and I figured I would make it easier for those who don't have alot of time. So for those of you who would like the e-mail addresses to send your thoughts and concerns just like in the letter above, PM me for those addresses.

I think this is a GREAT idea! I will try and submit this thread, however does anyone else know if submitting a website URL from a forum will work as a comment on an FAA rule change? Any help will be greatly appreciated. Again thank you ALL!!!!

I have to do some research to cite the source, but statisticlly, pilots are most dangerous between 500 - 750 hours. Before that, we are too scared to try anything stupid, after that we've scared ourselves a few times and have developed some humility and caution. I'm curious as to who commisioned the "Pilot Source Survey".

Does anyone else remember when 1500/500 was the unwritten regulation? A year or two flight instructing, maybe another year doing 135 work, and the ATP written before even the lowliest regional would talk to you. 100 hours flight instructing? Would you even have enough time in to endorse more than one private pilot canidate?

Splanky, your post above was one of the best I have seen on this forum. You have a clear vision and see things as they are which is a gift many people do not possess. No need for you to feel ashamed of your degree from Embry Riddle. You went there because you wanted the best education in Aviation because you wanted to fly. Same reason people go to Ivy League schools and on occassions can produce arrogance in certain people who are basically insecure, but you clearly are not in that category. Education is always a good thing no matter where you obtained it from. But more importantly, the ability to care about others and important issues in life is a great thing and you, my friend, have it.

Didn't Spirit hire some 200-300hr pilots a few years ago from ERAU?

Yes, about 20 of them.

As far as I know, there were 8 from Daytona. Most were CFIs but a few weren't. A good friend of mine is one of them. He definitely saw some crazy stuff. Unfortunately they were all furloughed for about a year. They're going back May 3rd.

Splanky,

Spot on. The degree was baggage for the majority of my approach to the majors. Guys saw arrogance with the degree, and it transfers to everyone. It made for some interesting interviews. I still don't tell many people where I went to school until I know them.

Pretty sure one of them had over 100hrs. of OE, but her father is a fed?

I had 1800/200 before I could even get a job flying cancelled checks in a single. Of course, that was in the 1980's.


[QUOTE=gtech88;789500
Does anyone else remember when 1500/500 was the unwritten regulation? A year or two flight instructing, maybe another year doing 135 work, and the ATP written before even the lowliest regional would talk to you. 100 hours flight instructing? Would you even have enough time in to endorse more than one private pilot canidate?[/QUOTE]

Its funny reading some of the comments for this. The ERAU people copy and paste what was posted earlier. In the end, if congress tells the FAA that ATPs are required, it does not matter what the FAA thinks is right. Congress is higher up and controls the FAA's money so I see this happening to matter what.

My personal favorite is a riddle kid saying the ATP requirement would ruin his dream of becoming an airline pilot. I should post his comment.

This isn't as much about which government agency is creating the new requirement. It is about ERAU lobbying congressional officials and apparently convincing some of them to alter the requirements from the originally proposed ATP.

Generally speaking, when congress starts talking about a law change to the FAA, the FAA jumps in and changes the RULE so it is a RULE and not a LAW. Big difference. Kind of like the age 65 thing.

The reason the FAA is not jumping the gun on the rest rigs, and commuting is because the language in the bill is very vague, and is more of a study and report back. If it was tight, direct, and detailed language, the FAA would do everything in its power to beat Congress to the punch.

PLEASE POST! Having a bad day and need a good laugh!

Well they had to write it for us word for word because our English skills SUCK! lmao!

Anyway thank god I am getting my pilot license for something else rather than flying passengers around!
Plus having two other minors isnt bad!

Here are the posted comments of an ERAU student Mr. Cook

i currently have gone through 2 semesters at embry riddle. before i came to Riddle i got my singe engine private at a local FBO. I have to say that I was blown away about how strict and safe oriented Embry Riddle is. They will not let you go onto the next activity unless you perform the one before it with Practical Test Standards. They fully pride themselves with being the safest flight school operation. I have to say that it was a tough transition because before i was flying at manassas in virginia and i had to deal with the ADIZ other than that the flight instruction was a joke compared to Embry Riddles. I had a couple of problems getting stranded on a solo cross country back at manassas because of the poor quality of the planes. But at Embry riddle i have not had any maintenance problems yet because of the schools dedication to making sure everything is super safe. I think embry riddle should have an exception in the new bill because its the quality of the education that counts not the quantity. I have never been through any program that is so tough before in my life. Let me assure you that flying at Embry Riddle is not fun and because of that it teaches every pilot the stresses of what it means to be flying for hire. The program is so strict it feels like i am flying for the military. I am finally used to the strict and rigorous program and feel confident every time i go up that nothing bad is going to happen because i'm monitoring everything that is going on and always making sure i don't use bad judgement or make mistakes. Instead of feeling like a human flying if feel like i am a machine who does not make mistakes. Please do not make the mistake and ruin my dream of flying by passing this bill. its not experience that crashes happen its because of poor pilot judgement. and judgement needs to be taught better at other aviation schools instead of hindering people who work there buts off 3 times a week.



Thanks Mr. Cook. I guess I better start working my butt off three times a week.

Here is another posted comment. For some reason it looks really similar to something ERAU put out. THANKS Mr. VanDette

1A. No, not for first officers. The ATP requires 1500 flight hours of and a minimum age of 23. Neither is necessary. Thousands of pilots have entered the Part 121 work force as first officers with less than 1500 hours and younger than 23. 1B. Yes, to knowledge; No, to the age or 1500 hours requirements. The pilot should also accomplish items in paragraph D of Attachment 1. Graduates from Aviation Accreditation Board, International (AABI) accredited programs meet requirements of paragraph D by virtue of the accreditation. 2A. Yes, supported by results of the Pilot Source Study (2010) conducted by a research team of seven colleges/universities and with new-hire data from six commuter air carriers. This study showed that the most successful pilots in the entry-level airline training were graduates from colleges/universities accredited by AABI. 2B. Yes, pilots from an AABI accredited four-year degree, flight education program should be allowed to enter Part 121 carrier training with degree plus 550 flight hours including at least 100 hours of operational experience as a CFI or some other professional pilot activity. Pilot Source Study supports this conclusion. 2C. Yes, too high. Findings of the Pilot Source Study show that the most successful entry-level first officers are those who have between 500 and 1000 hours, experience as a flight instructor, and graduated from an AABI accredited four-year flight education program. For pilots from other sources, 750 hours, including 100 hours of operational experience, is about right if academic modules in Attachment 1 completed. 3A. Yes. There should be either a Commercial Pilot Endorsement or a First Officer ATP (Attachment 1). 3B. Attachment 1. 3C. Varies by source of training. The endorsement could be made at 550 hours including 100 hours of operational experience for pilots from AABI accredited programs. For others, endorse at 750 hours including 100 hours of experience plus academic modules.

Wow... so in addition to writing the ERAU alumni people, I can write the ERAU English department as well, and tell them they REALLY need to work on their basic English requirements.

The kid is in his second year of college, and he writes like an 8th grader texting about the WWF. Hardly a message I'd want to send to Congress.

Nu

Holy crap, where did you find this? I've gotta get on there and go full throttle on the flame thrower. I may run out of gas before I get through the first kid.

Also, does anyone know the exact title of the bill? We need to be writing congressional representatives and giving them our views from a professional stand point. Not those of wet behind the ear sheep that are being coached on what to say.

Regulations.gov


This is where you can find all of the public comments. Most are pretty boring but there are some funny ones like Mr. Cooks.

I am not sure if people realize that when they post these that their full names get put on the website with their comments.

You can also go to Regulations.gov, click on read comments, search "FAA-2010-0100-0001," and that will pull up all of the public comments.

Enjoy.

Is there a way to read these all at once or do you have to click to open each response individually

S. 1744

Here is what I've sent to my Congressional representation.




Sir,
I would like to voice my opinion on S. 1744, which would mandate an increase in flight time, and experience for FAR Part 121 commercial pilot hiring, and implore you to support this bill.

The current hiring standards at most regional airlines are completely driven by the market. When times are good, the flood gates open and regional airlines will do anything and everything put a commercially licensed pilot in the seat, often with next to no experience and for poverty level pay. They will interview and have a job waiting upon completion. When times are tough like we're seeing now, they raise their hiring standards, but keep pay low. What this leads to is an ebb and flow of talented and experienced pilots carrying paying passengers. I have personally seen hiring standards as low as 250 hours, and know pilots hired with as little as 8 hours of multi engine experience. That's 8 hours in a light piston engine trainer, hired straight into a 50+ seat commercial jet. I have also seen airlines recruit at flight schools, students who haven't even passed their check ride. Up until this point the only thing that has kept passengers safe while these low time pilots gain experience, is the Captain in the left seat who is ultimately in command. However even the most experienced Captain sometimes can not keep up with a poor first officer, or worse yet you get a Captain with a questionable performance history paired with an inexperienced first officer.

This is unacceptable and the culture was a direct contributor to the Colgan crash in Buffalo NY last year.

This bill would mandate that to be eligible for a first officer position a candidate must posses an Airline Transport Pilot certificate, with the flight time commensurate to hold the ticket, 1500 hours of total flight time experience.

Opponents of this bill have tried to justify their position by pointing to the military, which puts pilots in command of multi-million dollar fighter aircraft with as little as 200 hours. What they do not admit to is the fact that the process to get a pilot there is extremely rigid, and only the best ever make it that far, after millions of dollars of training. Even then they are kept under close scrutiny and trained vigorously by senior leadership.

One of the many reason this argument doesn't hold up is because anyone with the money can go out and pay what ever they need to get their commercial pilots license. There is not failing out due to lack of performance. There is no "culling of the herd." The new hire flying your commercial flight today could be a superstar, or someone that has just barely squeaked their way through the training process and barely met the minimums. Those minimums are in small, very simple piston engine aircraft. Not the high speed and complex jets that have become the norm today, operating in complex and demanding airspace and weather.

Another argument is that it's been done in the past safely, so there is no reason for change. Again I ask you to look at the case of Colgan 3407. Past performance is no guarantee of the future, and if we can put in place standards to increase safety, why wouldn't we?

Embry Riddle Aeronautical University, which I am a graduate of, is also starting a campaign to squash this bill. I, along with other ERAU grads have voiced our anger to the school on this, as they are doing it purely on the basis of profit. The schools argument is that it's education process should more than make up for the flight time the students lack. The school sells itself to potential students as a "one stop shop" to an airline pilot position. Students come out the other end with a 4 year degree, and the bare minimums to hold a commercial pilot license. They are incredibly book smart but have no real world experience, which is required to make the judgment decisions in the safe operations of a commercial aircraft with paying passengers in the back. Embry Riddle is just one of what the industry refers to as "Puppy Mills." Schools that just grind out commercially licensed pilots with the minimums for certification. There are other institutions out there as well that are not accredited 4 year schools too. Some advertise as little as 90 days from zero experience to a commercial pilots license. All you need is the money. Do you really want your family flying with someone that just met the minimums in the last 6 months?

This bill would require that pilots go out and get the experience required to safely operate in a complex and unforgiving environment on their own. Often through jobs like flight instructing, flying freight, pipeline surveys, or joining the military. Building the experience necessary to offer the skills required for the safe operation that the flying public has come to expect and demand.

We as Americans have come to rely on the airlines as a critical means of transportation and commerce. The Americans paying for those tickets deserve a well qualified crew up front that have proven themselves before taking command of these aircraft, and not until then should anyone be allowed to occupy these positions. The FAA will not mandate these regulation changes on their own, as the leadership is to entrenched and influenced with airline management that doesn't want to up the pay required to attract quality, experienced talent for entry level positions.

Sir, I ask again for your support in this bill and for you to enlist the help of your peers to see this through. The paying passengers of this country deserve it, and even more so the families of Colgan 3407. Please feel free to contact me for more information on this topic.

Very Respectfully,
xxxxxxxxxxxxxxxxxxxxxx

I sent this comment to my congressman with a small note at the end that said, "Would you really want this guy flying your plane?"

But don't worry, he doesn't feel like a human. He feels like a machine that doesn't make mistakes.

That kids a jackass, and speaking like he has any basis of experience for comparison. He's what, 18 or 19?

Someone throw him a life preserver, he may drown in the kool-aide.

This is an OUTSTANDING letter! Do you mind if I use it as a template to send to my congressman as well?

Do what you gotta do brudda.