mR-E?-E01E 13:31 From:LIBRARY 7123GE5970 To:2024g3E25l P.1/3 

Docket Operations, M-30, ' ••.'^tNiJlPQisTATlpr) ^ 

U.S. Depanment of Transportation - 'V"i<Pt O'P-'fl'^"^"^^^-"*'^'^ 

1200 New Jersey Avenue, SE, Room W12-140 

West Building Ground Floor ,.,.. ,.^^ ;-[ p 3. 51 

Washington DC 20590-0001 "' ' "" " 

Fax Number 202-493-2251 

www.regulations.gov 

RE: Docket Number FAA-2010-0100 

Question #12. (page 45) "Should anyone other than military pilots or graduates of 4 year colleges or 

universities with aviation related degrees and commercial pilot certificates with instnmient ratings 

obtained from an affilated part 141 pilot school be eligible (for "ATP...with fewer than 1500 hours")? 

Why or why not? 

Response: In addition to military and four year degree graduates, the FAA should provide the same 

reduction in hours for the ATP to graduates of Two year collegiate aviation programs that award 

associate degrees, as those gradiiates meet the same aviation related academic and flight requirements. 

These programs that are certified under FAA Part 141 requirements dictate a formal path to 

certifications and ratings similar to those of the military and four year degree programs. Students 

choose two year programs for a variety of reasons, to include both location and cost. Further 

community college aviation programs have an excellent record of providing high quality training for 

their graduates, leading to direct employment as aircrew members in a variety of aviation flying 

positions. Graduates of these formal two year community college aviation programs deserve the same 

reduction in the flight hour requirement since they complete the same flight hour and academic flight 

instruction requirements, even though they may not complete more academic courses that are 

unrelated to aviation. Based on these facts, it appears somewhat arbitrary to permit this reduction in 

flight hours only to those graduates of a four year program. 

1 currently teach io an Aviation Degree program at Towa Lakes Community College located in 

Esthervillc , Iowa. This is an accredited Associate of Science program, encompassing 68 credit hours 

for the fixed wing Professional Pilot Program. This program has provided cost effective pilot training 

since 1980 to thousands of graduates who are currently flying for the airlines. The Dept of Education, 

the VA, and others consider 12 credit hours full time which would make this a six semester, three year 

program. Our curriculum plans for four semesters or 56 weeks. This compares favorably to the 54 

weeks of training for the Air Force pilot training program referenced on page 42. Incidently, the NPRM 

does not state if military hehcopter pilots could receive the same hour reduction as military fixed wing 

pilots. The experience and training of a heUcopter pilot does not seem to lend itself well to the needs of 

the fixed wing airline pilot. 

As stated by the FAA on page 43, our "students also receive concentrated and focused aviation 

training-'. The FAA describes the academic subjects to be covered for the ATP on page 36ff: "Multi 

pilot [multicrew] environment, high altitude operations, adverse weather conditions'', the abihty to 

"function eflfectivcly in an air carrier operational environment" and to have "experience in difficult 

operational conditions". Additional academic subjects identified by the FOQ ARC include "swept wing 

aerodynamics, automation, air carrier operations, transport category perfortiiance, and navigation," 
riflR-27-E012 13:31 From:LIBRARY 71236E5970 To:£084932251 P.2^3 

The FSTD (simulator) training requirements listed on page 37 include; convective activity, icing 

conditions, low visibility conditions, maximum crosswind conditions, with gusts, contaminated 

runway, areas of clear air turbulence, movmtain wave activity. Low energy states/stalls and upset 

recovery techniques are also listed, as are crew coordination, checklist/briefing items, collision 

avoidance systems, and performance calculations. 

Iowa Lakes Conununity College Aviation program incorporates technology and simulation NOT 

AVAILABLE in many four year aviation universities. We operate Cirrus SR 20 aircraft with a "Glass 

Panel", XM weather and Flight Director. In addition, we have simulation including FTD, Advanced 

Aviation Training Devices, Basic Aviation Training Devices and PC-ATD's. Each level of simulation is 

incorporated in our pilot training at the appropriate time and quantity for the students. All graduates of 

the fixed wing pilot training must complete rigorous training in the ftill motion simulator to airline 

standards, incorporating airline profiles, procedures in a multi crew environment. ALL OF TFTE 

ABOVE SUBJECTS REQUIRED FOR THE ATP ARE INCLUDED IN THE DEGREE PROGRAM. 

Our ground and flight training is conducted under a FAR 141 certificate that WE OWN AND 

OPERATE, NOT AN OUTSOURCED, "AFFILIATED FLIGHT SCHOOL". This provides for closer 

quality control, continuous evaluation of student progress, instructor qualifications, as well as lower 

costs by eliminating the middleman profit center. Our training already includes multi engine cross 

country flights, after receiving the rating, by the students, under IFR, incorporating previously learned 

crew concepts. This provides the smdents with real time weather and decision making opportxmities. 

Iowa Lakes Community College Professional Pilot Program also includes the following training 

required by this Act: 

Crew Resource Management (CRM) training conducted by airline pilots, doctors and other 

experts. 

• Aviation Safety curriculum conducted by an FAA Inspector 

Aviation Weather conducted by a degreed Meteorologist 

Mountain flight training, including mountain wave, conducted by a highly experienced 

mountain pilot. 

Aviation systems class conducted by an Airframe and Powcrplant (A&P) mechanic 

• Wmdshear profiles using the FAA Profiles as well as re-creations of landmark accidents in the 

lull motion, real life visual simulator. 

Use of TIS, TCAS, EFIS, GPS, LPV/LNAV, Radar, and fully coupled, auto sequenced, flight 

director and auto pilot. 

• FITS and LOFT training for pilots and instructors. 

Stage checks in both aircraft and simulators conducted by current airline captains. 

• Oversight of the entire program by an Advisory Board made up of working professionals from 

many areas of aviation, including corporate and airline captains. ATC professionals.. Director of 

Operations of an airline, and others. 

In it's April 8,2010 response to this Docket, the University Aviation Association stated: ''In our view, 

the substimtion of academic study within an aviation degree program at a TWO (emphasis theirs) year 

or a four year aviation program should be considered. IVo year aviation fhght education programs are 

ofiered by many different institutions - UAA members alone account for 26 such programs with 2096 

students enrolled (2008 Survey). Therefore, two year programs are a vital part of the overall collegiate 

aviation pilot supply." 
nAR-£7-20l2 13:32 From:LIBRARY 71B3625970 To:202493B£51 P.3^3 

The community college system nationwide has been providing well trained pilots for the airlines and 

other aviation employers for decades. Now, with the high cost, not only of flight training, but also 

college in general, is not the time to take away an efficient, effective, reasonably priced educational 

opportunity from those who cannot afford the cost and time required for a four year degree. 

As I recall back diuing World War Two, "Civilian Pilot Training Programs" were often associated with 

2 year Junior Colleges, where cadets were often educated, creating the best Air Force in the World. 

Thank you for yoiu- careful consideration, 

Ronald L. Duer 

Chief Flight Instructor/Program Coordinator 

Iowa Lakes Community College 

300 South 18*** Street 

Estherville , Iowa 51334 

712-362-7961