1500 hour rule exemption requested by ALPA
 

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

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.

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.

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.

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.

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....

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 :rolleyes:

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!

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).

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

exactly. I hate Cohen, pretty much the dick cheney of the airline world haha

Oh, I know, Cohen is so full of **** his skin is turning brown.

As of now, I know of at least 2 people at Horizon that still have close to 300 hours to go... The company has been building them lines in order to get them more flying than they would have on reserve.

Which sucks if you're the one just above them on the bid triangle, like me...

Ya, we should all allow the low time pilots to bypass other "Higher time" pilots so they can get their time. And in doing so make more money and have better than reserve schedules.
Sounds fair to me.

Or we send them back to the real world where they can flight instruct, fly 135 day VFR, banner tow or whatever. And earn their airline job.

Can't help but think the number of pilots this would impact number in the tens...

You realize state "right to work" legislation doesn't apply to airlines right?

Unless they signed some kind of MOU or LOA, your union oughta step in and pay protect everyone senior those who get a special line. The company has to do what it has to do to get the pilots qualified, but it also has to pay everyone who was bypassed (assuming no special contractual loopholes).

Yes, because fighting cabotage and foreign ownership, as well as working for better FTDT regs, more strict safety standards, NEXTGEN airspace, more strict lithium battery shipping standards, higher pay, better work rules & job protection is just silly.

I'm not okay with it. I have friends still at regionals, and I'm hearing companies are violating contracts right and left to get low time guys extra hours.

They might need waivers for the 22 year olds with only 100 hrs PIC time and of questionable moral character.

I've seen some CA's with the 61.159(d) ICAO limitation, and they weren't allowed out of the country. I wonder if an ATP with that limitation would be allowed.

I'm one of those "22 year olds who lack character" who will not be eligible for the ATP come next august.... I will be 23 mid september. I was at Colgan before when they closed up, now I'm at CHQ. Meet all the requirements for the rating minus the stupid age requirement. Hopefully they come out with some exemption that would allow me to fly...Although I'd be happy with a few weeks off

I'm in the same boat except I'm trying to get an interview. Been told I will get it except for the fact I won't be 23 until the first week of October.

Where at? Definitely not where I work since I don't think I'm going to make it by the deadline.

Higher pay? Did I miss something or is this a regional thread? I agree with everything else expect for that and job protection.

How much dues did comair pilots pay ALPA? Job protection = 0.

ALPA needs to back away from the RAA.

80+ at Eagle

(Newest guy on the line has less than 700TT, as far as I can tell)

I have a friend that applied at Eagle this summer and was told he didn't have enough time; he had roughly 1150hr and over 100 multi, including some turbine time.

Are those Eagle pilots ATP graduates, or from some other bridge program?

ya, how has that been working for you the past twenty years? You telling me ALPO has done all of that? Wow, well enjoy your deep 6 figure salary, working 8 days a month till your 65. If not, just file a grievance, I'm sure they will get back to you.

The guy I was referring to may have been on ML

Are you against age 65 retirements?

For those folks concerned about people under them unfairly getting some extra time to make the cutoff.. consider that if they dont you'll have fewer folks underneath you.

This works both ways, and I think we're all in it together. I am low time and a new hire this past fall. My company like most had been raising TT to interview each month so that we should all make it, but it is still nerve racking until I get a line and the math works out to show that I can get 1500 in time. Ive got about 400hrs to go and would like to get my 15 with a month to spare, ideally. I'm begging crew sched. every day I go without reserve flying. So far I have been lucky as a reservist, but could still use more.

Fewer qualified folks would be better. There are plenty of pilots in this country with more than enough flight time. They just don't want to work for the crap wages at the regional level or majors for that matter. The more the FAA gives in the less valuable the profession. Either your not qualified your not. How hard is this? The easier it is to become a ATP rated pilot the cheaper we are all worth.

Well considering having a line can bring a 1st year FO an additional $500+ bucks a month ( yes including per diem), Thats a pretty crappy argument you have because you are screwing someone over. Ill admit I have been a given a couple trips in the past to get my consolidation of knowledge done but that was 50 hrs that was in open time, not 5-6 months worth 400+ hours. If I was senior to you I wouldnt be too happy. I would rather have 1 less person below than someone stealing money from me by getting a metric ton a flying while I sit and make guarantee.

If the company is awarding trips outside of seniority, you should get the time off with pay. Consolidation is normally a contractually allowed reason to fly junior reserves ahead of senior folks, but check your contract language...it may be worded such that the company doesn't have the wiggle room to apply it to low-time ATP wannabe's.

Our contract does allow the consolidation awarding. Where I am at we have always had ATP mins, so no low time problem. I was just saying if I was at his regional I would not be happy.

I agree... but our union and our company came out with a letter of understanding regarding the situation, and it basically just stated that they could build lines like IOE/consolidation. The pilot group never had any input, or a vote...