Rule up for Public Comment by April 27th approx
https://www.faa.gov/news/press_relea...m?newsId=13373
Document as to be reviewed...
http://www.gpo.gov/fdsys/pkg/FR-2012.../2012-4627.pdf
There are some interesting points in the proposal...
"As noted previously, currently only PICs are required to hold an ATP certificate and an aircraft type rating for the airplane flown in revenue service. Based on information provided by industry, the FAA estimates that about 85% of the SICs for regional airlines and approximately 15% of the SICs of major and cargo airlines do not have an ATP
certificate."
"As previously noted following the Congressional mandate of the Act, the
proposed rule requires all SICs in part 121 air carrier operations to have an
ATP certificate by August 2, 2013."
"From a social point of view, the reduced salary and benefits reflects the loss of pilot
productivity the 1,500-hour restriction brings about by delaying the entrance of
pilots into part 121 operations and, consequently, delaying their career path.
A common career path of a pilot in part 121 operations is to start out as an
SIC (first officer) in a regional airline, upgrade to PIC (captain) at that airline
and, subsequently, to become an SIC and a PIC at a major airline. Based on
a survey of industry, the FAA estimates the career path of a ‘‘typical’’ pilot in
part 121 operations as follows: Upgrade to regional airline PIC after five years,
move to a position as SIC at a major airline after two years as PIC at the
regional airline, and upgrade to PIC at the major airline after an additional ten
years."
"There is considerable cross-sectional variation in the hiring minimums of
regional airlines, but the average total hours minimum appears to be about 750
hours. The number of flight hours the FAA assumes pilots can accumulate in
one year is also about 750 hours. Accordingly, the FAA estimates that the
proposed requirement for an ATP certificate with 1,500 hours of flight
time would, on average, delay a new pilot’s part 121 career approximately
one year."
"Benefits of This Proposed Rule
The FAA expects that this proposed rule would reduce the number of future
accidents. The bulk of the benefits of the proposed rule, particularly with part
121 operations, would be the value of the averted fatalities and injuries. The
value of averted fatalities and injuries is based on the value of a statistical life,
which the Office of the Secretary of Transportation currently estimates to be
$6 million. "
"The proposed rule would affect small firms in part 121, part 135, and part 91,
subpart K, operations in the following North American Industry Classification
System (NAICS) industries, which shows that the Small Business Administration (SBA) size standard is 1,500 employees for all four industries"
"This requirement will necessitate changes in the ATP knowledge and practical tests.
In addition to all pilots in part 121 operations, this requirement would apply to PICs in part 135 air carrier operations that require the PIC to hold an ATP certificate, and PICs in part 91,
subpart K, Fractional Ownership Operations, which require the PIC to hold an ATP certificate.
4. An aircraft type rating for all SICs serving in part 121 operations. The FOQ ARC made the same recommendation. Current part 121 requirements require only the PIC to hold an aircraft type rating. The FAA has determined that this requirement would improve safety in part 121 operations by further exposing the pilot to an advanced multiengine aircraft and a multicrew
environment. Also the training and testing for an aircraft type rating requires a pilot to be tested to the same standard as the PIC and demonstrate proficiency in difficult operational
conditions, including adverse weather and high altitude operations."
"5. A minimum of 1,000 hours in air carrier operations to serve as PIC in part 121 operations. An unintended consequence of the Act’s requirement for all part 121 pilots to hold an ATP certificate is that the natural mentoring of SICs may not occur. The 1,000-hour
requirement would ensure that a pilot would have at least one full year of relevant operational experience before upgrading to PIC. The FAA proposes to allow a pilot to count SIC time in part
121 operations as well as PIC time in part 135 operations and in part 91, subpart K, Fractional Ownership Operations, that require an ATP certificate per the operating rule part."
The amended Rule will look like this...
§ 121.436 Pilot qualification: Certificates
and experience requirements.
(a) No pilot may act as pilot in
command of an aircraft unless he holds
an airline transport pilot certificate, an
appropriate aircraft type rating for the
aircraft being flown, and has 1,000
hours as second in command in part 121
operations, pilot in command in
operations under § 91.1053(a)(2)(i) or
§ 135.243(a)(1) of this chapter, or any
combination thereof.
(b) No certificate holder may use nor
may any pilot act as second in
command unless the pilot holds an
airline transport pilot certificate and an
appropriate aircraft type rating for the
aircraft being flown. A pilot type rating
obtained under § 61.55 does not satisfy
the requirements of this section.
(c) Compliance with the requirements
of this section is required by August 1,
2013.
§ 121.437 [Removed]"
I see an interesting scenario for all those who were hired into Part 121 operations (All majors & regionals plus others)... with low time as with a deadline of August 2013 an SIC is going to have to achieve 1500hrs total time and 1000 hours in the operation in order to have an ATPL by that time frame. If a pilot flys only 600 hours a year, it may be impossible to achieve and at that point, I wonder what will happen to that pilot when the clock strikes August 2013 if he/she does not have the required hours?
Secondly, this may add to the problem of low-time SIC when the company needs upgrades... Before, an SIC only had to make 1500hours so if hired with, say 1000 hours he/she would achieve this in less than 1 year normally. But now, there will be a 1000hr requirement in the Part 121 operation.. and those hours take 18 months to accumulate... interesting.....