FAA seeks to raise Airline Pilot Standards

[BTDTB4]

If the first officer is legally second in command then surely he should be certified competent (by being tested in the simulator) on all sequences that the captain is certified competent on. Obviously this is not so in USA!

Actually, much to the chagrin of many in the US, you are correct. However, I have taken the time to read through what the FAA has submitted as a proposed rule change ... but they seem to be dragging their collective feet in doing something/anything about what they are proposing.

Anyway, the new proposal was clear … that both pilots in the airplane would be required to perform exactly the same tasks, to the same level of competency, and, as a result would be qualified to operate the airplane in revenue passenger/cargo operations under the existing regulations in the US. In addition, the proposal went as far as to say that if the F/O had logged the requisite number of hours (i.e., at that time, 1500 hours) and had already taken and passed the written examination for the Airline Transport Pilot Certificate – and had been trained on the accomplishment of all of the tasks required of a Type Rating Candidate, that F/O would be eligible to be issued not only a Type Rating on the specific airplane type, but also the Airline Transport Pilot Certificate.

However – and apparently in the US government, there is always a “however,” … nonetheless, however, the requirement for actual operation of the airplane in that revenue passenger/cargo operation (in accordance with the existing authorities granted to individual airlines), each airline makes a decision as to what pilot will actually conduct the rejected takeoff, if rejecting the takeoff becomes necessary during an actual, live, for-real, takeoff. The thought behind this is that apparently at least some in the FAA believe that only the Captain of the flight should be given that level of authority, and because of the potential seriousness of the result, only the Captain should be authorized to initiate and complete that task. Of course, this means that should the F/O actually be making the takeoff and something were to occur prior to V1 speed indicating that continuing the takeoff might not be safe, it would fall to the Captain to take control away from the F/O (of course the F/O would have to positively relinquish the control – as it might easily serve contrary purposes if both pilots were on the controls at the same time) and then execute the rejected takeoff.

I am told that there was a significant argument within the FAA about whether this was a proper and/or a necessary function – some indicating that the F/O lacked the experience for making such decisions and that the F/O lacked sufficient control of the airplane to safely execute such a task (the thought being that the F/O did not have access to “nose-wheel steering”). I do not know how this particular disagreement was settled, if, indeed, it was settled. However, it seems remarkable to me that anyone would (or could, logically) believe that a F/O had all the necessary training and had demonstrated all the necessary skill through proficiency checks or tests to warrant his/her being authorized to operate the airplane through all that F/O’s typically operate … takeoffs, climbs, cruise, descents, approaches, landings, go-arounds if required, etc., yet do not have the sufficient training or skill to reject the takeoff.

Now apparently, the US Congress has entered the discussion through the passage of a law – requiring the FAA to establish a requirement that F/Os be issued some sort of Airline Transport Pilot Certificate – or that they have a minimum of 1500 hours of logged flight time before they are allowed to operate as a F/O (that specific point was not clear to me) – although there seems to be some conflicting interpretations about one or both of these so-called “requirements” … at least to the degree, it has been heard, that internal discussions within the halls of the FAA are on-going – some centering on what the “cost” will be to the individuals involved or to the airlines – but effectively stalling the finalization of what it will be that the FAA will require of airline pilots and whether or not there will be a differentiation between the Captain and the F/O with respect to qualification, experience, training, testing results, and so forth. Some observers might even get the impression that when the regulator can’t seem to get its priorities straight or make a logical decision … it will be next to impossible for airlines and individual pilots to come even close to complying with whatever it is they are to face.

My question is … who’s running the regulatory program in the US – the FAA, the Congress, the airlines, the public, the press, ??? … and this list can apparently go on to an embarrassing length.

[MarkerInbound]

It's not so much the F/Os don't have the skills but there has to a final authority. The regs say the PIC is that person. I've got a full type in the 744, I've got a tiller, it's still the Captain's call. My job is to keep it on the runway below V1 and fly it it off once we're past V1.

There is no requirement for 1500 hours under the law passed by Congress, only that everyone hold an ATP. Some of the aviation colleges have stomped their feet because now they won't be able promise students an airline career straight out of school and so the FAA is talking about creating a junior ATP if you went to a 4 college and got an aviation degree. So I would add another player to your list.

The FAA has given their estimate of the cost to the airlines and to individual pilots in the NPRM.

[Semaphore Sam]

Considerations for new USA airline pilots:
1. There is going to be a shortage of new candidates...the costs of training for Private/Commercial are skyrocketing. Typically, new pilots were taking out loans of 40k-80k to get qualified, and are looking at typical initial salaries at the Regionals of 18k-22k. Already training for Private pilots is drying up...banks will not make loans with such prospects, and candidates choose more remunerative pursuits, with less initial required investment. Add to that, the Feds (post-Colgan crash) are close watching histories of busted check-rides, with 2 or 3 considered enough to deny any further chance of being hired or upgraded. Besides ckrides, the medical could down you at any time. Banks are NOT loaning to new pilots, with good reason.

2. The experience required to legitimately pass a PIC Type Rating ride for an ATP on a regional jet is usually much higher than the typical CFI flying 172s for 1500 hours has. This gap looks very wide...the training for this ride will take a factor of 1.5 to 2 times the standard training footprint, and may still not be enough, depending on the student. Typically the 250 hr co-pilot got experience watching from the rh seat...this valuable source of experience will be closed.

3. There are two exceptions to the 1500 hour requirement being considered: 1st, military pilots. The rate of military pilots being trained has been drastically reduced. Those that are there have a choice...a military career with guaranteed good pay and benefits, with good retirement AND respect, vrs. leaving the military and joining a Regional with crap pay and benefits, potential furloughs and bankruptcies, and probably a crap retirement (with exceptional luck). A pilot that made such a choice might be considered to lack the judgement to be a good pilot candidate...this is a modern Catch 22. 2nd, students graduating from formal flying schools. These usually graduate CFI's with Private and Commercial...they leave with NO heavy or airline background. To include any airline-type training would be prohibitively expensive, so you still have that huge gap referred to above. Tough times a'comin' I'm thinking. Sam

[Big Pistons Forever]

Originally Posted by Semaphore Sam

2. The experience required to legitimately pass a PIC Type Rating ride for an ATP on a regional jet is usually much higher than the typical CFI flying 172s for 1500 hours has. This gap looks very wide...the training for this ride will take a factor of 1.5 to 2 times the standard training footprint, and may still not be enough, depending on the student. Typically the 250 hr co-pilot got experience watching from the rh seat...this valuable source of experience will be closed.

When the paying public buy a ticket that says "United" or "American" or "Delta" etc etc on it and then get on a regional jet painted in "United" or "American" or "Delta" colours, I think they have a legitimate expectation they should be flown by a fully qualified crew not by a Captain some other guy/gal who is still learning his/her job.

You are right there is a big gap between what FO's are getting now and what they would need to pass a ATP ride and that is exactly where the problem is. I fail to see why doubling the training footprint to allow new hires to get to the required standard is in any way bad. One thing is for sure the airline bean counters consider pilot training a "cost" that must be minimized. The only way the bar is going to be raised is if the industry is forced by regulation to increase training. There is no way the airlines are going to do that on their own.

[Semaphore Sam]

From BPF:
You are right there is a big gap between what FO's are getting now and what they would need to pass a ATP ride and that is exactly where the problem is. I fail to see why doubling the training footprint to allow new hires to get to the required standard is in any way bad. One thing is for sure the airline bean counters consider pilot training a "cost" that must be minimized. The only way the bar is going to be raised is if the industry is forced by regulation to increase training. There is no way the airlines are going to do that on their own.

Well, somebody is going to have to pay for this...the Regionals are on a shoestring (considering they have to pay millions to their CEO's owners, etc, and these costs are fixed). Two possibilities: expenses taken out of pilot/workers pay, or standards for ATP will be lowered. I suspect pressures will be put on Checkers to lower the standards, to lower the costs of training. Pilot/worker pay is now about as low as it can go.

[RandomPerson8008]

Domestic only F/O's in the US do in fact have a type rating with an SIC limitation. We all had to file the paperwork to add these to our licenses several years back. No additional training was required however, as the existing airline training curricula retroactively satisfied ICAO's requirements for issuance of an SIC type rating.

Most international F/O's in the US do in fact have full PIC type ratings; this is done so that the captain can have a break on longer flights whilst two F/Os remain on the flight deck, the senior most of whom is delegated temporary command.

[bubbers44]

That is what AF did to make AF447 legal with two junior guys flying and the captain taking his required rest.

[MarkerInbound]

Random,

If you're only flying domestic you didn't have to get the SIC type. At least not per FAA regs. It was created to allow you to show foreign CAAs you have been trained on the aircraft. An FAA Inspector knows if you are sitting right seat in Brand A Airlines airplane, you have been trained by Brand A as an F/O. Sort of like adding "English Proficient." Since being proficient in English was a requirement to hold a pilot certificate, if you held a pilot certificate an inspector had made the determination you were proficient in English. But ICAO won't follow that logic.

[BTDTB4]

Originally Posted by MarkerInbound

There is no requirement for 1500 hours under the law passed by Congress, only that everyone hold an ATP. Some of the aviation colleges have stomped their feet because now they won't be able promise students an airline career straight out of school and so the FAA is talking about creating a junior ATP if you went to a 4 college and got an aviation degree.

PUBLIC LAW 111–216—AUG. 1, 2010
Section 217: AIRLINE TRANSPORT PILOT CERTIFICATION
* * *
(c) FLIGHT HOURS.—
(1) NUMBERS OF FLIGHT HOURS.—The total flight hours required by the Administrator under subsection (b)(1) shall be at least 1,500 flight hours.
(2) FLIGHT HOURS IN DIFFICULT OPERATIONAL CONDITIONS.—
The total flight hours required by the Administrator under subsection (b)(1) shall include sufficient flight hours, as determined by the Administrator, in difficult operational conditions that may be encountered by an air carrier to enable a pilot to operate safely in such conditions.
(d) CREDIT TOWARD FLIGHT HOURS.—The Administrator may allow specific academic training courses, beyond those required under subsection (b)(2), to be credited toward the total flight hours required under subsection (c). The Administrator may allow such credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement.(e) RECOMMENDATIONS OF EXPERT PANEL.—In conducting the rulemaking proceeding under this section, the Administrator shall review and consider the assessment and recommendations of the expert panel to review part 121 and part 135 training hours established by section 209(b) of this Act.
(f) DEADLINE.—Not later than 36 months after the date of enactment of this Act, the Administrator shall issue a final rule under subsection (a).

[Big Pistons Forever]

Whatever the exact outcome is, the bottom line is clear. Before you get to fly a Part 121 airliner you will have to have a much more training and experience then is required now.

This is ultimately a good news story for both US flight safety and for US pilots.

[Hobo]

I have read this thread with interest.

Am I right in saying that, currently, an F/O on a 737/A320 flying domestic US, does not have to have a type rating?

Am I right in saying that, currently, an F/O on a 737/A320 flying domestic US, may not have practiced engine out flying in the sim?

Am I right in saying that, currently, an F/O on an international flight, may not have a type rating?

[MarkerInbound]

Depends what you call a type rating.

Am I right in saying that, currently, an F/O on a 737/A320 flying domestic US, does not have to have a type rating?

Yes

Am I right in saying that, currently, an F/O on a 737/A320 flying domestic US, may not have practiced engine out flying in the sim?

No. They will have almost all the training the Captain had. They will have engine failures on takeoff both before and after V1. They will shoot ILSs with an engine out and land and go around with one engine inop. They won't do steep turns, they won't have a second engine failure on a three or four engine plane and they won't do a zero flap landing.

Am I right in saying that, currently, an F/O on an international flight, may not have a type rating?

To keep foreign CAAs happy, the FAA created an SIC type rating. The F/O has their Chief Pilot or training department certify they passed their FAA approved F/O training program and takes the paperwork to the FAA. The FAA will issue a type rating limited to SIC only without any further testing.

That being said, many international operators get their F/Os full type ratings since they operate long flights with one Captain and two or three F/Os and someone has to hold a full type while the Captain is sleeping.

[Hobo]

Thanks MI, very helpful.

[BTDTB4]

Originally Posted by Big Pistons Forever

You are right there is a big gap between what FO's are getting now and what they would need to pass a ATP ride and that is exactly where the problem is. I fail to see why doubling the training footprint to allow new hires to get to the required standard is in any way bad. One thing is for sure the airline bean counters consider pilot training a "cost" that must be minimized. The only way the bar is going to be raised is if the industry is forced by regulation to increase training. There is no way the airlines are going to do that on their own.

Originally Posted by MarkerInBound

To keep foreign CAAs happy, the FAA created an SIC type rating. The F/O has their Chief Pilot or training department certify they passed their FAA approved F/O training program and takes the paperwork to the FAA. The FAA will issue a type rating limited to SIC only without any further testing.

For whatever it’s worth, the most recent publication of the proposed revision to the FAA rules regarding pilot training and qualification included statements that strongly suggested that the FAA was proposing doing away with the differences between Captains and First Officers with respect to both the tasks they each had to perform and the standards that had to be met when those tasks were performed by either pilot. My initial response was … it’s about time! But, foolish me … as is typical with regulators who are overly responsive to those they regulate, I now understand that the cost involved in making the training equal is being “reviewed” … because of the significant cost involved. This, together with the continuation of the AQP (where every airline participating has been authorized to do essentially whatever it is they would prefer to do – and does so with the blessings of the regulator) it would seem that the only purpose that the regulators serve is to “codify” whatever it is that the industry would like to have – which is the very best defense an airline could possibly desire should anyone ever decide to take legal action against them (“…but we’re only complying with FAA requirements…”) and these “like-to-have” motivations come – apparently directly from –the cost to that airline … the less the cost … the more they desire it. And it would seem that unless or until a body count of such proportions is achieved in a single “mishap” that the contributing circumstances can no longer be ignored … we are all going to see a proliferation of less training, less pilot qualification requirements, and substantially more dependence on airplane automation. Hmmm … is anyone suspicious of all the increased regulatory interest in “un-manned” air vehicles?