AVIATION SAFETY

FAA Has An 

Opportunity to 

Enhance Safety and 

Improve Oversight of 

Initial Pilot Training 

Statement for the Record by 

Gerald L. Dillingham, Ph.D., Director 

Physical Infrastructure Issues

Testimony

Before the Subcommittee on Aviation 

Operations, Safety, and Security, 

Committee on Commerce, Science, & 

Transportation, U.S. Senate 

Not to Be Released 

Before 2:45 p.m. EST 

Tuesday, March 20, 2012 

GAO-12-537T 

United States Government Accountability Office

GAO 
United States Government Accountability Office

Highlights of GAO-12-537T, a statement for 

the record for the Subcommittee on Aviation 

Operations, Safety, and Security, Committee 

on Commerce, Science, & Transportation, 

U.S. Senate 

March 2012 

AVIATION SAFETY

FAA Has An Opportunity to Enhance Safety and Improve 

Oversight of Initial Pilot Training

Why GAO Did This Study

Regional airlines have experienced the 

last six fatal commercial airline 

accidents, and pilot performance has 

been cited as a potential contributory 

factor in four of these accidents, 

including the most recent in February 

2009 which resulted in 50 fatalities. 

Public and media concerns about 

aviation safety escalated as a result 

about the level of safety across the 

entire airline industry, particularly about 

pilot education and training before they 

can be hired by regional airlines. The 

Federal Aviation Administration (FAA) 

is responsible for ensuring that pilots 

receive the necessary training and 

undergo the proper certification testing. 

Once hired, all U.S. commercial 

airlines are required to provide the 

advanced training for their pilots. 

However, to become a certified 

commercial pilot, which is currently the 

minimum requirement for being hired 

by an airline as a first officer; 

individuals must undergo several steps 

of pilot training and certification in 

accordance with FAA regulations.

This statement is based on GAO’s 

November 2011 report on initial pilot 

training and focuses on (1) the various 

types of U.S. pilot training 

organizations, the regulatory training 

requirements for commercial airline 

pilots, and how they compare in 

preparing pilots candidates for 

commercial airlines, and (2) how and 

to what extent FAA carries out its 

oversight role of pilot training and 

certification of private and commercial 

pilots.

What GAO Found

FAA’s pilot training requirements for certification of commercial pilots are not 

aligned with airline operations or emphasize skills that airlines consider important 

for greater aviation safety. 

• Requirements do not emphasize training in decision-making, although this 

skill is essential to the airline pilot profession. According to FAA and other 

stakeholders, the regulations regarding ground school and flight training, as 

well as the test standards for a commercial pilot certificate, generally 

emphasize the development of motor skills to master of maneuvers and 

individual tasks to determine competence, and not decision making. 

• Requirements do not emphasize training in using modern technologies, such 

as flight simulation training devices. Modern aircraft used by regional airlines 

have evolved and the operational demands have increased on pilots in highaltitude and complex airline operations. Pilots in today’s newer aircraft have to 

manage automation, advanced avionics and systems, information displays, 

and other new technologies. 

• Requirements and testing do not emphasize situational awareness or 

understanding risk assessment, or provide a complete understanding of 

managing the automation of the aircraft. 

Many of the key industry stakeholders GAO interviewed said the current training 

regulations for commercial pilots should be revised to incorporate additional 

training requirements that would improve the performance capabilities of the first 

officer applicants that seek employment at airlines. Some of the recommended 

types of training are provided to pilots when they are hired by airlines to ensure 

that the newly hired commercial pilots are competent in a range of training 

areas—some per FAA requirements. However, according to the Air Line Pilots 

Association, the lack of specific training requirements to be a commercial airline 

pilot results in a wide range of initial training experiences, not all of which are well 

suited for the commercial airline industry. To compensate, some regional airlines 

use various flight training devices to screen pilots during the hiring process to 

gauge their piloting skills. FAA has an opportunity to ensure that the knowledge 

and skills it requires of commercial pilots is still relevant. 

FAA has an annual inspection program that includes the oversight of pilot 

schools, pilot examiners, and flight instructors, i.e., the gatekeepers for the initial 

pilot training process. However, GAO’s analysis of FAA inspection data found 

that the agency does not have a comprehensive system in place to adequately 

measure its performance in meeting annual inspection requirements for pilot 

schools and pilot examiners, which could make it difficult to ensure regulatory 

compliance and that safety standards are being met. GAO’s report included 

recommendations to improve FAA’s oversight of pilot certification by developing 

a comprehensive system that may include modifying or improving existing data 

systems to: (1) measure its performance in meeting the agency’s annual 

inspection requirements for pilot schools and pilot examiners and (2) better 

understand the scope of discretionary inspections for flight instructors. FAA 

generally agreed with the recommendations.

View GAO-12-537T. For more information, 

contact Gerald L. Dillingham, Ph.D. at (202) 

512-2834 or dillinghamg@gao.gov. 
Page 1 GAO-12-537T Aviation Safety 

Chairwoman Cantwell, Ranking Member Thune, and Members of the 

Subcommittee:

I am pleased to submit this statement on GAO’s work related to the U.S. 

pilot training system. This study was undertaken at the request of the 

House Committee on Transportation and Infrastructure, its Subcommittee 

on Aviation, and members of Congress. Although the U.S. mainline 

airlines are experiencing an unprecedented level of safety, there have 

been several accidents in recent years involving regional airlines.1

Specifically, the last six fatal commercial airline accidents involved 

regional airlines, which account for about 53 percent of the nation’s 

commercial flights. As a result, Congress, the media, and the flying public

have raised concerns about the extent that there is “one level of safety”2

across the entire airline industry. The National Transportation Safety 

Board (NTSB) cited pilot performance as a potential contributory factor in 

four of these accidents, including the one in February 2009, in Buffalo, 

New York, involving Colgan Air, Inc. in which 50 lives were lost.3 The 

focus of our study was the initial pilot education and training required 

before pilots can be hired by airlines, at which time they receive advanced 

training.

4

 

1

Mainline carriers operate aircraft seating 90 or more passengers and regional air carriers 

are airlines that generally operate aircraft seating fewer than 90 passengers.

The continued safety of the U.S aviation system depends in part 

on the roughly 3,400 U.S. pilot schools providing well-trained pilot 

candidates for airlines. This is particularly relevant for regional airlines, 

which are much more likely to hire and train pilots directly from these 

schools, whereas large mainline airlines tend to hire and train pilots who 

already have experience at regional airlines or in the military.

2

Since 1995, FAA has imposed the “one level of safety” on the entire airline industry in 

which all U.S. commercial airlines—mainline and regional—are subject to the same 

standards and requirements, and receive the same level of safety oversight.

3

NTSB Aircraft Accident Report, 2010, Loss of Control on Approach, Colgan Air, Inc., 

Operating as Continental Connection Flight 3407, Bombardier DHC-8-400, N200WQ, 

Clarence Center, New York, February 12, 2009. NTSB/AAR-10/01. Washington, D.C.

4

Mainline and regional airlines provide their pilots with 1) advanced training as entry-level 

indoctrination training when they are hired and 2) continual recurrent training while they 

are employed. 
Page 2 GAO-12-537T Aviation Safety 

This statement is based on our November 2011 report5

The performance audit on which this statement is based was conducted 

from March 2010 through November 2011 in accordance with generally 

accepted government auditing standards. Those standards require that 

we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based on our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based on our audit 

objectives.

and focuses on 

(1) the various types of U.S. pilot training organizations, the regulatory 

training requirements for commercial airline pilots, and how they compare 

in preparing pilots candidates for commercial airlines, and (2) how and to 

what extent FAA carries out its oversight role of pilot training and 

certification of private and commercial pilots. To address our objectives in 

the report, we reviewed and synthesized published literature related to 

pilot certification and training issues in the United States. We also 

reviewed the Federal Aviation Regulations related to training and 

certification for pilots, and legislative provisions that addressed issues 

related to pilot training. We interviewed officials at Department of 

Transportation (DOT), Federal Aviation Administration (FAA), and NTSB. 

We also conducted interviews with representatives from a range of 

aviation stakeholder organizations, including pilot unions, pilot school 

associations, general aviation groups, commercial aviation industry 

associations, international aviation associations, and regional airlines. For 

a more detailed explanation of our scope and methodology, see appendix 

I of our full report.

As the federal agency responsible for regulating the safety of civil aviation 

in the United States, FAA is responsible for the administration of pilot 

certification (licensing) and conducting safety oversight of pilot training. 

Regulations for pilot certification and training are found in three different 

parts of the Federal Aviation Regulations—Parts 61, 141, and 142.6

 

5

GAO, Initial Pilot Training: Better Management Controls Are Needed to Improve FAA 

Oversight, 

All 

GAO-12-117 (Washington, D.C.: November 2011).

6

Part 61 prescribes the minimum training, knowledge, and experience requirements for 

acquiring a pilot certificate. Part 141 prescribes the requirements for issuing pilot school 

certificates and the general operating rules applicable to a holder of the certificate. Part 

142 prescribes the requirements governing the certification and operation of aviation 

training centers.

Background 
Page 3 GAO-12-537T Aviation Safety 

pilots are subject to a series of certification requirements established by 

FAA, but the requirements vary depending on the type of training 

environment.7 Part 61 recognizes six basic types of pilot certification: 

student, sport, recreational, private, commercial, and airline transport.8

Part 61 also establishes the core training requirements for each pilot 

certification, which describes the eligibility requirements, aeronautical 

knowledge and flight proficiency standards, and the required flight hours. 

Pilot training can be provided to students by flight instructors under Part 

61.9 Part 141 outlines the specified personnel, aircraft, facilities, 

curriculum, and other operating requirements that approved pilot training 

organizations (schools) must meet in order to hold an operating certificate 

from FAA. Part 142 outlines specific requirements for training centers that 

primarily relate to the advanced training provided to pilots by employers, 

such as airlines. As previously stated, our report focused on the initial 

pilot training that students are provided prior to being hired as airline 

pilots; thus, advanced training for pilots is not within the scope of our 

study.10

Approximately 3,400 pilot schools exist in the United States and the most 

basic difference among the types of schools is the training environment 

provided to the students. For the reporting purposes of our study, we 

divided them into three categories: (1) non-collegiate flight instructor-

 

7

14 C.F.R. Part 61.

8

The student pilot certificate is necessary to begin pilot training to work toward a 

recreational, sport, or private pilot certificate under the direct supervision of a flight 

instructor. The recreational pilot certificate was introduced in 1989 and limits pilots to stay 

within 50 nautical miles of their departure airport unless other conditions are met. The 

sport pilot certificate was introduced in 2004 and allows pilots to fly smaller, light, less 

complex, one or two-seat airplanes without the limitations of recreational pilots. The 

private pilot certificate allows the pilot to fly solo and carry passengers in any aircraft for 

which they are qualified, but not to fly for compensation. The commercial pilot certificate 

allows a pilot to be compensated for flying and to be hired for a variety of aviation jobs 

(e.g., air ambulance, law enforcement, agricultural spraying, corporate and charter flights, 

and banner towing), including first officer positions with airlines. The airline transport pilot 

certificate is the highest level of pilot certification, requires the highest amount of 

cumulative flight time, and is necessary to qualify as a captain for an airline.

9

The holder of a valid flight instructor certificate may provide pilot training and instruction 

for the pilot certification in any aircraft for which they are qualified. (14 C.F.R. § 181).

10The DOT Office of Inspector General (OIG) reviewed FAA’s oversight of airline pilot 

training, pilot fatigue, and professionalism issues. See DOT OIG Audit Report, New 

Approaches Are Needed To Strengthen FAA Oversight Of Air Carrier Training Programs 

And Pilot Performance, AV-2012-027 (Washington, D.C.: December 2011).
Page 4 GAO-12-537T Aviation Safety 

based schools, (2) non-collegiate vocational pilot schools, and (3) 

collegiate aviation schools.

Non-collegiate flight instructor-based schools (Part 61). Pilot training 

conducted under Part 61 regulations is often provided by an individual, 

for-hire flight instructor who can operate independently as a singleinstructor school at a local airport with a single aircraft on which to train 

students. Other flight instructor-based schools operate as a more 

traditional training school. These schools are the most common type of 

school and the majority of students that complete training in flight 

instructor-based schools are generally interested in recreational flying, 

although most commercial pilots in the United States also undertake this 

type of training as the initial path toward becoming an airline pilot. These 

schools are not subject to direct FAA oversight beyond the initial 

certification and subsequent renewal of the flight instructor’s certificate.11

Non-collegiate vocational pilot schools (Part 141). Vocational schools 

elect to apply for an operating certificate from FAA to provide pilot training 

under Part 141 regulations, which require these schools to meet 

prescribed standards with respect to training equipment, facilities, student 

records, personnel, and curriculums.12 Vocational schools must have 

structured and formalized programs and a detailed training course outline 

or curriculum approved by FAA. Curriculums can vary in content, but FAA 

provides fundamental core training guidelines that must be followed within 

the curriculum for the school to receive a certificate.13

Collegiate aviation schools (Part 61 or Part 141). Pilot training is also 

provided through 2- and 4-year colleges and universities, which typically 

These schools do 

not allow the flexibility of flight instructor-based schools, as the training 

sequence outlined in the curriculum cannot be altered. FAA requires 

annual inspections of these schools, unlike flight instructor-based 

schools.

 

11However, flight instructors may be inspected by FAA when a triggering event—such as 

an aircraft accident—occurs.

12In August 2011, FAA issued a rule that, among other things, will allow vocational pilot 

schools to use internet-based training programs without requiring the schools to have a 

physical ground training facility. The rule will become effective October 31, 2011. 76 Fed. 

Reg. 54095 (August 31, 2011).

1314 C.F.R. § 141.55.
Page 5 GAO-12-537T Aviation Safety 

offer an undergraduate aviation-based degree along with the pilot 

certificates and ratings necessary to become a commercial pilot. In 

general, most of the collegiate aviation schools provide pilot training 

under a Part 141 certificate, although they can provide training under Part 

61. Collegiate schools that provide training under Part 61 regulations 

generally offer similar structured, curriculum-based training as collegiate 

schools with a Part 141 certificate.

For the most part, all pilot schools must provide training that includes both 

classroom and flight training.14 Classroom training, or ground school, 

provides students with the required aeronautical knowledge and cognitive 

skills necessary to perform the tasks required to become a pilot. Flight 

training focuses on learning how to manipulate the controls of an airplane 

and make it perform certain maneuvers. Regardless of the type of school, 

flight instructors must teach students by demonstrating and explaining, on 

the ground and in the air, the basic principles of flight (e.g., airspace, 

aerodynamics, weather factors, and Federal Aviation Regulations). The 

number of training flight hours required for pilot certification varies by the 

aviation regulations being used to provide pilot training. Because training 

under Part 141 regulations requires a school to use an FAA-approved 

curriculum, fewer hours of actual flight training are required than under 

Part 61.15

To obtain a private, commercial, or airline transport pilot certificate from 

FAA to perform various aviation activities, after completing the required 

training, individuals typically have to successfully complete pilot training 

and pass the following two FAA tests for each pilot certificate and rating 

obtained:16

• A knowledge test assesses applicants’ understanding of the 

aeronautical knowledge areas required for a specific certificate or 

 

14Training under Part 61 regulations for the private and commercial pilot certificates can 

accomplish the ground school training requirements through instruction from a flight 

instructor or through an approved home-study course.

15For the airline transport pilot certificate, the same number of total hours is required 

whether pilot training is being conducted under Part 61 or Part 141 regulations.

16A rating defines the conditions or specific aircraft in which a pilot certificate may be used. 

In addition, endorsements may be issued by FAA to further define conditions or specific 

aircraft not covered by ratings.
Page 6 GAO-12-537T Aviation Safety 

rating and can be administered in written form or by a computer.

• A practical test consists of a flight test and an oral examination. The 

flight test assesses applicants’ knowledge of the areas of operations 

of an aircraft and the ability to demonstrate the maneuvers in an 

aircraft while in flight. The oral examination is conducted by having an 

applicant respond to random questions related to aviation knowledge 

and aircraft operations before, during, and after the flight test, and 

typically lasts between 1 and 2 hours.17

To become a certified commercial pilot,18 currently the minimum 

requirement for being hired by an airline as a first officer, individuals also 

must undergo several steps of pilot training and certification in 

accordance with FAA regulations.19 Once cleared by a medical 

examination, students obtain a medical certificate and a student pilot 

certificate from FAA.20

 

17Part 61 requires that pilots must be able to read, write, speak, and understand the 

English language, or a pilot certificate cannot be issued. Each pilot applicant must 

demonstrate an ability to mentally grasp critical information that often must be read and 

understood while conducting a variety of aviation operations.

Figure 1 shows the typical progression of training 

provided by the pilot schools and the associated certifications required to 

become an airline pilot.

18A pilot with a commercial pilot certificate can be employed to tow banners and fly 

sightseeing operations or can be employed as a first officer for a regional airline.

19In commercial aviation, the pilot in command (captain) of an aircraft is the person aboard 

the aircraft who is ultimately responsible for its operation and safety during all phases of 

flight, as well as when it is operating or moving on the ground, in accordance with FAA’s 

rules of the air. The second-in-command (first officer) is the second pilot of an aircraft, and 

has the authority to assume command of the aircraft in the event of incapacitation of the 

captain. However, control of the aircraft is normally shared equally between the captain 

and first officer during flight.

20To be eligible for a student pilot certificate, an applicant must be at least 16 years of age 

and hold at least a third-class medical certificate. Student pilots are generally not allowed 

to operate an aircraft in solo flight unless certain FAA requirements are met.
Page 7 GAO-12-537T Aviation Safety 

Figure 1: The Typical Path to Become a Commercial Airline Pilot 

Figure 2 shows examples of the progression from single-engine trainer, to 

multi-engine trainer airplane—used by some pilot schools to provide 

students with the multi-engine rating—to the much larger, faster jet used 

by regional airlines. Once commercial pilots complete the process of 

initial training, they are qualified to apply for a first officer pilot position at 

an airline. Entry-level positions are typically at regional, and not mainline, 

airlines; mainline airlines typically draw from regional airlines for their 

pilots. If hired, pilots then must complete the airline’s new hire training, 

which consists of indoctrination, ground and aircraft systems, simulator 

training, and the initial operating experience, wherein the pilot applies 

what they learn in the previous training phases. The airline submits these 

training programs for approval by the FAA to ensure they meet Part 121 

requirements. 

Obtain a private pilot certificate from FAA by completing the necessary

knowledge and flight training

Obtain an instrument rating from FAA by completing the necessary knowledge and

flight training (allows a pilot to fly during periods of reduced visibility or when the

ground reference is obscured)

Obtain a commercial pilot certificate from FAA by completing the necessary knowledge

and flight training (required in order to be compensated for performing flying activities)

Obtain a multi-engine rating from FAA by completing the necessary knowledge and

 flight training (required to be qualified to fly aircraft with more than one engine) 

Obtain employment as a pilot for a charter or corporate operation or first officer

for a regional airline

Build flight hours and experience as a flight instructor by teaching new pilot students

how to fly (optional) or through employment in a variety of commercial aviation jobs

Source: GAO.
Page 8 GAO-12-537T Aviation Safety 

Figure 2: Examples of Single- and Multi-Engine Aircraft Used by U.S. Pilot Schools and a Multi-Engine Jet Used by Regional 

Airlines

As part of its oversight responsibility, FAA develops pilot training and 

certification requirements for commercial pilots and ensures that the pilots 

meet them by subjecting the pilots to complete and thorough certification 

examinations. We found that there has been little other study on this 

subject and there is no consensus about how well the different types of 

pilot schools prepare commercial pilots for airline operations.

• On one hand, collegiate curriculums cover a broad range of areas 

above FAA minimum training requirements. The overwhelming 

majority of representatives of the regional airlines we interviewed 

generally told us they strongly preferred, but do not require, first 

officer candidates trained in collegiate aviation schools because 

they perform better in their airline’s training program when hired. 

Due to limited screening, training structure, and variability of 

educational content, according to some of the regional airline 

officials, flight instructor-based schools are less likely to produce 

first officers that are prepared immediately upon completing the 

training to enter the workforce and succeed in an airline 

environment.

Training Varies and 

Requirements Are Not 

Aligned with Airline 

Operations 

Pilot Schools’

Training Varies in 

Applicability to Airline 

Operations, but All 

Students Must Pass the 

Same Tests
Page 9 GAO-12-537T Aviation Safety 

• On the other hand, some stakeholders we interviewed pointed out 

the large number of pilots that matriculate through flight instructorbased schools and many are hired by regional airlines without any 

performance issues. Representatives from two of the regional 

airlines also indicated that the professional pilot experience gained 

through commercial aviation positions after completing pilot 

training is more important than the type of pilot school attended.

Many of the collegiate aviation schools also provide specialized training in 

a flight simulation training device using realistic scenarios, including some 

coursework and advanced flight training in jet aircraft systems and airline 

operational procedures. For example, Embry-Riddle Aeronautical 

University’s Aeronautical Science degree program is designed to prepare 

graduates for a career as a professional pilot in multi-crewmember, jet 

aircraft. Courses include communication theory and skills, aircraft turbine 

engines, crew resource management, aviation weather, jet transport 

systems, and optional upset recovery training. Officials who represented 

10 of the 24 regional airlines we interviewed listed some of these types of 

courses as examples that FAA could require as part of pilot schools’ 

training curriculums that would improve the skill level and competency of 

applicants seeking to be hired as first officers.

Regardless of the type of pilot schools that students attend, once training 

has been completed, pilot candidates must pass the same knowledge 

and practical tests to obtain a pilot certificate.21

 

21Some vocational and collegiate aviation schools with a Part 141 certificate are granted 

examining authority by FAA, as a privilege of their Part 141 certificate, which allows them 

to recommend their graduates for some of the initial pilot certificates and ratings (except 

flight instructor certificates, airline transport pilot certificates and ratings, and jet type 

ratings) without the pilot candidates having to take the FAA knowledge or practical tests or 

both.

FAA uses a multiplechoice, knowledge test to measure the extent to which applicants for FAA 

pilot certificates have mastered the required aeronautical knowledge 

areas provided in ground school. To pass, applicants must achieve an 

overall score of 70 percent or higher. However, some aviation 

stakeholders have voiced concerns related to whether the current 

knowledge test actually requires students to learn the material, as 

opposed to simply studying sample test questions from publicly available 

sources. Literature related to pilot certification and training issues and 

some aviation stakeholders have pointed out that FAA testing is generally 
Page 10 GAO-12-537T Aviation Safety 

based on rote memorization. They stated that this encourages instructors 

and students to focus on memorizing test questions to pass the required 

FAA knowledge test, rather than developing a true understanding of the 

material. In 2004, the National Aeronautics and Space Administration 

(NASA) published a study on FAA’s pilot knowledge tests.22 NASA found 

that many applicants completed the test in far less time than would be 

required for the average human to even read the questions and answers 

on the test—indicating that students had memorized the questions and 

answers—which raises concerns about the extent to which students 

actually mastered the material.

Several industry stakeholders have stated that current training 

requirements for commercial pilots are not aligned with today’s 

commercial airline environment. FAA requires the same initial training for 

a pilot hired as a first officer of a regional airline carrying passengers as it 

does for a pilot hired to fly for a commercial non-airline operation, for 

example crop dusting.23 Modern aircraft used by regional airlines have 

evolved and the operational demands have increased on pilots in highaltitude and complex airline operations. The Air Line Pilots Association 

(ALPA) has suggested that FAA revise the regulations to make a clear 

distinction between training and certification requirements for airline 

operations and those for other types of commercial operations. ALPA 

contends the regulations were developed in an era in which commercial 

pilots were hired by airlines in small, slow, propeller-driven aircraft or as 

flight engineers on jet-powered aircraft. It would traditionally take several 

years and thousands of flight hours before these pilots were given an 

opportunity as a first officer of jet transports.24

 

22NASA, “FAA Pilot Knowledge Tests: Learning or Rote Memorization?” Ames Research 

Center, Moffett Field, California, January 2004.

However, according to 

ALPA, it is not uncommon today for newly hired pilots to be hired directly 

23In practice, regional airlines do typically require newly hired first officers to have a 

certain level of experience above the regulatory flight hour minimums required to obtain a 

commercial pilot certificate, typically hiring pilots that have spent several years working up 

through commercial non-airline jobs, i.e., on-demand and cargo operations. However, the 

extent that they do this may vary based on the cyclical dynamics of the supply of and 

demand for pilots. 

24A flight engineer is the third crewmember on an aircraft that requires a three-person 

flight crew, but this position is seen less often as airlines replace older planes with newer 

aircraft that require only two-person crews.

Several Key Stakeholders 

Recommended that FAA 

Introduce Training Needed 

for Airline Operations into 

Current Training 

Regulations for 

Commercial Pilots
Page 11 GAO-12-537T Aviation Safety 

into airline training programs to become first officers of high-altitude, 

complex aircraft carrying 50 or more passengers, the type of aircraft that 

warrants pilots with more knowledge and greater skills than the new-hire 

airline pilots of the past. Officials from two industry associations and eight 

regional airlines advocated for a separate pilot certification track with 

additional training requirements specific to being an airline pilot. Because 

airline pilots are responsible for the safety of the flying public, according 

to ALPA, it is reasonable that they should be held to a higher standard of 

competency, knowledge, and training than pilots in other flight operations.

Additionally, requirements for a commercial pilot certificate do not 

emphasize training in some areas—like decision-making and using 

modern technologies—that are directly related to the airline pilot 

profession.

• According to FAA and other stakeholders, the regulations regarding 

ground school and flight training, as well as the test standards for a 

commercial pilot certificate, generally emphasize the mastery of 

maneuvers and individual tasks to determine competence. The 

emphasis is on development of motor skills to satisfactorily 

accomplish individual maneuvers—whereas only limited emphasis is 

placed on decision-making—unlike in scenario-based training that 

emphasizes improving operational experience.25

• In addition to traditional skills of flying, navigating, and 

communicating, pilots in today’s newer aircraft have to manage 

automation, information displays, and other new technologies. 

According to the FAA Industry Training Standards’ guidance material 

for the commercial pilot certificate, a growing number of pilots are 

being hired by regional airlines as first officers to operate aircraft with 

these advanced avionics and systems.26

 

25According to literature we reviewed, scenario-based training uses real-world situation 

that introduces situations and circumstances that pilots face in routine flight operations as 

learning experiences. This training method emphasizes the development of critical 

thinking and flight management skills, rather than solely on traditional maneuvers-based 

training skills. Maneuvers-based training emphasizes the mastery of individual tasks or 

elements, such as the development of competency and motor skills to satisfactorily 

accomplish individual piloting maneuvers.

While these pilots may gain 

26The FAA Industry Training Standards program (referred to as FITS) is a partnership 

between FAA, industry, and academia to create scenario-based training materials to help 

pilot schools train pilots for practical application of knowledge and skills of technicallyadvanced aircraft. The FITS commercial pilot syllabus, developed in 2007, is the accepted 

training method to use in developing a specific FITS curriculum.
Page 12 GAO-12-537T Aviation Safety 

flying experience and spend years building flight time in commercial 

non-airline jobs or as flight instructors, this experience may be 

accumulated in smaller, slower, and less advanced aircraft. Modern 

aircraft offer advanced avionics and performance capabilities and 

many of these new aircraft travel faster and further than older 

generation commercial aircraft. While generally considered 

enhancements, these modern technologies require increased 

technical knowledge of newer systems and avionics and new skills for 

managing automation and computerized flight and navigation 

systems. 

According to literature, as airspace complexity and air traffic density 

increase, airline pilots must have increased situational awareness, 

understand risk assessment, and have a complete understanding of

managing the automation of the aircraft.27

Representatives from 10 regional airlines, 4 pilot schools, and 2 industry 

associations we interviewed said the current training regulations for 

commercial pilots should be revised. They suggested that FAA should 

incorporate additional training requirements that would improve the 

performance capabilities of the first officer applicants that seek 

employment at airlines, such as exposure to advanced jet concepts and 

simulation,

The current training 

requirements and testing for a commercial pilot certificate do not 

emphasize the development of these skills.

28 aircraft unusual attitude (i.e., upset and stall recovery),29

 

27However, recent concerns have been raised by industry stakeholders that federal 

regulations and airline operating procedures require airline pilots to have a greater 

reliance on the computerized flight management and automation of today’s aircraft. As a 

result, the implications of decreased opportunities for pilots to manually fly an aircraft 

could potentially result in an increase in accidents and incidents for pilots who are 

suddenly confronted with a loss of computerized controls or emergency situations but 

unprepared to respond immediately or make errors in doing so.

28Advanced jet training is designed to give instruction in airline flight crew operations in a 

multiengine aircraft, emphasizing the transition of the professionally qualified pilot to a 

highly skilled member of an airline flight management team. Course topics include crew 

resource management, flight crew training techniques, high speed and high altitude 

programming of automatic flight control systems, transport aircraft flight techniques, 

turbojet operations in all flight regimes and in difficult operating conditions, and use of 

advanced avionics.
Page 13 GAO-12-537T Aviation Safety 

flight crew coordination and environment,30

The industry concerns about current training regulations for commercial 

pilots and incorporating additional initial training requirements to improve 

first officer applicants’ performance capabilities could be addressed by 

the Airline Safety and Federal Aviation Administration Extension Act of 

2010 for all airline pilots.

and scenario-based training. 

However, when pilots are hired by airlines, these types of training are 

provided by the airline to ensure that pilots are adequately competent in 

these and other advanced training areas—some required by FAA for 

airline operations. For example, FAA regulations for airline operations 

require that all pilots are provided crew resource management training as 

part of the airline’s new hire and recurrent training programs. According to 

ALPA, the lack of specific training requirements to be a commercial airline 

pilot results in a wide range of initial training experiences, not all of which 

are well suited for the commercial airline industry. To compensate, some 

regional airlines, such as SkyWest Airlines, use various flight training 

devices to screen pilots during the hiring process to gauge their piloting 

skills. However, if additional training is required by FAA for pilots prior to 

being hired by an airline, the students would likely be responsible for the 

extra costs involved and would add to the total costs of pilot training 

borne by the student.

31 Currently, while a captain for a commercial 

airline is required to hold an airline transport pilot certificate—the highest 

level of pilot certification requiring the highest number of total flight 

hours—a first officer is required to hold only a commercial pilot certificate, 

which requires a minimum of 250 flight hours.32 However, the recent law 

will require the captain and first officer to have an airline transport pilot 

certificate, which currently requires a minimum of 1,500 total flight 

hours.33

 

29Aircraft upset is a dangerous condition that occurs when an airplane encounters an 

unexpected event that threatens loss of control of the aircraft and may result in an 

accident. Upset recovery training aims at improving a pilot’s ability to maneuver and 

recover an actual airplane from a serious upset to a normal operating condition.

Individuals interested in becoming a first officer for a regional 

airline generally complete training from pilot schools with a commercial 

30Crew (or cockpit) resource management training is designed to improve pilots’ team 

management, situational awareness, communications, task allocation, and decisionmaking skills in an airline crew environment.

31Pub. L. No. 111-216, §217 (c) (1), 124 Stat. 2348, 2368 (2010).

3214 C.F.R. § 61.129(b).

33Pub. L. No. 111-216, §217(c)(1),124 Stat. 2348,2368 (2010).
Page 14 GAO-12-537T Aviation Safety 

pilot certificate and possess about 300 to 500 flight hours. The 2010 law 

directs FAA to conduct a rulemaking and effect the changes no later than 

August 2013.34 FAA issued a notice of proposed rulemaking regarding the 

increased requirements in February 2012.

35

As another potentially relevant factor, the law stated that the FAA 

Administrator may allow specific academic training courses—beyond the 

additional courses required by the legislation to raise the minimum 

requirements for the airline transport pilot certificate—to be credited in 

lieu of flight hours needed to obtain an airline transport pilot certificate. In 

the proposed rule, FAA also would allow pilots with an aviation degree or 

military pilot experience to obtain an airline transport pilot certificate with 

restricted privileges with fewer than 1,500 hours total time as a pilot.

 The proposed rule would 

require airline first officers to hold an airline transport pilot certificate and 

to have a type rating for the aircraft being operated. Representatives of 

the regional airlines we interviewed were concerned this legislation will 

reduce airlines’ hiring flexibility and make it harder to find qualified first 

officers that possess an airline transport pilot certificate. Many other 

stakeholders argued that the key factor that should be considered when 

revising the commercial pilot training requirements is the quality and 

educational content of the training rather than the quantity of flight hours.

36

According to FAA’s First Officer Qualifications Aviation Rulemaking 

Committee Report,37

 

34Pub. L. No. 111-216, §217(f), 124 Stat. 2348, 2368 (2010).

well-structured training programs that feature 

integrated academic content and flight experience optimize the pilot 

learning process, and the committee supported new, higher-level 

minimum certification requirement for first officers. To support the concept 

that academic training courses should be credited for some of the 

3577 Fed. Reg. 12374 (Feb. 29, 2012). 

36FAA is proposing that pilots must 1) be at least 21 years old, 2) pass the airline transport 

pilot knowledge and practical tests, and 3) military pilots must have a minimum of 750 

hours total time as a pilot and a graduate of an aviation degree program must have a 

minimum of 1,000 hours total time as a pilot.

37FAA, The First Officer Qualifications Aviation Rulemaking Committee Report: 

Recommendations Regarding Rulemaking on Flight Experience, Training, and Academic 

Requirements Prior to Operating as a First Officer in Part 121 Air Carrier Operations, 

September 10, 2010. The committee was composed of representatives of AABI, ALPA, Air 

Transport Association, AOPA, Coalition of Airline Pilots Associations, National Air Disaster 

Alliance-Foundation, National Business Aviation Association, Pilot Career Initiative, 

Regional Air Cargo Carriers Association, and RAA.
Page 15 GAO-12-537T Aviation Safety 

additional total flight hours, the report outlined a system for crediting 

academic training courses based on the sources of pilot training, e.g., 

vocational pilot schools, collegiate aviation schools, or military. The 

Coalition of Airline Pilots Associations (CAPA) and National Air Disaster 

Alliance-Foundation presented dissenting opinions to this approach in the 

report and suggested that academic courses, while necessary, should not 

replace an increase in total flight hours required in the law.38

FAA has an oversight framework in place for guiding and tracking 

inspections. FAA uses the National Program Guidelines (NPG) to guide 

its annual oversight activities, including pilot schools, pilot examiners, and 

flight instructors—the gatekeepers for the initial pilot training process.39

The NPG identifies required inspections and optional inspections.40 As 

part of this oversight process, FAA uses the Program Tracking and 

Reporting Subsystem (PTRS)41 and the Enforcement Information System 

(EIS).42

 

38CAPA is a trade association, established in 1997, comprised of over 28,000 professional 

pilots to address safety, security, legislative and regulatory issues affecting the individual 

member unions. The National Air Disaster Alliance-Foundation was founded by air crash 

survivors and victims’ family members in 1995, to raise the standard of safety, security, 

and survivability for aviation passengers, and to support victims’ families.

39FAA’s NPG, developed annually, was initiated in 1985 as the oversight policy guidelines 

for its eight regional offices and their associated local district offices for oversight of pilot 

schools, pilot examiners, and flight instructors. FAA appoints individuals as designated 

pilot examiners to conduct various pilot certification-related activities on behalf of FAA.

40Required inspections are identified by FAA’s headquarters as the mandatory core 

inspections necessary for FAA to fulfill its statutory and regulatory oversight 

responsibilities. Accomplishment of these inspections is essential to provide reasonable 

assurance of continued compliance with regulations, standards, and safe operating 

practices. Planned inspections are identified at the regional and district levels and are 

comprehensive targeted inspections. They make up the depth and substance of each 

office’s annual work and FAA district offices tailor them to the changing local aviation 

environment.

41PTRS was implemented in 1990 and is one of FAA’s data management and analysis 

systems used, among other things, to record inspection records and findings for NPG of 

flight instructors, pilot schools, pilot examiners, and other job functions.

42EIS is the primary internal tool for FAA in initiating enforcement actions and for tracking 

of enforcement and compliance cases and their outcomes.

Better FAA 

Management Controls 

Are Needed to Ensure 

That All Required 

Inspections Are 

Completed 
Page 16 GAO-12-537T Aviation Safety 

As part of its oversight role, FAA monitors pilot schools with a Part 141 

certificate (vocational schools and most collegiate aviation schools) to 

ensure that they meet the required safety and training regulations. To 

fulfill NPG requirements, FAA requires its inspectors to conduct on-site 

inspections of each of these schools at least once a year. The inspections 

focus on five areas related to pilot school operations and the 

airworthiness of training aircraft. Under operations, an inspection must 

cover the school’s facility and student records. Under airworthiness, an 

inspection must cover the pilot school facility, compliance with FAA’s 

airworthiness directives, and a Part 141 ramp check.43

In reviewing PTRS data for fiscal years 2006 through 2010, we were 

unable to determine the extent that required inspections of pilot schools 

with a Part 141 certificate were completed for several reasons.

Inspectors enter 

the details and results of their monitoring in FAA’s PTRS data system.

• In the fiscal years prior to 2010, due to limitations in tracking the 

number of pilot schools that existed in each fiscal year, we were 

unable to determine whether the data were missing because they 

were entered incorrectly into PTRS, or because the inspections 

did not take place as required.44

 

43A ramp check for a pilot school with a 141 certificate typically involves an inspection of 

the paperwork and exterior of the aircraft used by the school for training to ensure each 

meets all regulatory requirements. FAA inspectors conduct various types of ramp checks 

to ensure that aviation activities are being conducted safely and in compliance with the 

Federal Aviation Regulations.

FAA does not maintain a 

historical listing of the active pilot schools with a Part 141 

certificate for a given fiscal year and, thus, we could not define the 

universe of pilot schools that was required to be inspected during 

fiscal years 2006 through 2009. As a result, we could not 

determine the identity and number of schools that needed to be 

inspected. While FAA officials recognized that all required NPG 

inspections are expected to be completed within each fiscal year 

time frame, they provided several reasons to potentially explain 

why some of the required inspections are not recorded in PTRS. 

FAA officials said that inspectors may have conducted the 

44For fiscal year 2010, our analysis of FAA’s PTRS data found that FAA completed about 

78 percent of the required inspections for the 545 pilot schools with a Part 141 certificate.

However, based on one year, we cannot generalize this completion rate to be 

representative of the extent that FAA carries out its oversight role for completing the 

required inspections of pilot schools with a Part 141 certificate.

The Extent that

Required Inspections of 

Pilot Schools Were 

Completed Is Unclear
Page 17 GAO-12-537T Aviation Safety 

required inspections for some schools but incorrectly entered the 

details in PTRS. For example, some FAA inspectors may conduct 

full inspections of schools that cover the five inspection areas, but 

may enter only two of the five inspection numbers into PTRS. The 

officials also said that inspectors had additional duties—such as 

following up on previously identified issues or addressing the need 

for additional oversight for certain inspection areas—in conducting 

inspections for some schools, which can make covering all five 

inspection areas difficult.

• Similarly, many of the required inspections for pilot schools with a 

Part 141 certificate by NPG are incorrectly recorded as 

discretionary inspections in PTRS. As a result, this made it difficult 

to use PTRS to determine if FAA had conducted all of the required 

inspections of part 141 pilot schools for a given year. Specifically, 

35 percent of the 4,551 part 141 pilot school inspections required 

by NPG in fiscal year 2010 were listed incorrectly in PTRS as 

discretionary inspections, and 32 percent of the required 

inspections were listed as discretionary from fiscal year 2006 

through 2010. As a result, those inspections would not show up in 

a list generated in PTRS of required inspections for fiscal year 

2010. FAA officials said that this problem is likely caused by the 

program that populates PTRS with the NPG requirements.

When inspections or other sources revealed compliance issues or 

violations, FAA uses a variety of actions to enforce safety standards and 

regulatory compliance, such as oral or written counseling, administrative 

action, legal enforcement action, and referral for criminal prosecution. 

When an FAA inspector identifies a potential violation, he or she initiates 

an investigation and if FAA determines that a violation has occurred, FAA 

has a wide range of options available for addressing it. From fiscal years 

2006 through 2010, our analysis of FAA’s EIS data found that FAA 

initiated 230 enforcement cases against pilot schools with a Part 141 

certificate. The majority of these cases resulted from an inspection of a 

school, but others may have resulted from other sources. During fiscal 

years 2006 through 2010, FAA used a wide range of enforcement actions 

against pilot schools with a Part 141 certificate (see fig. 3). 

• No action: FAA can determine that no action is warranted. In 26 of 

the 230 cases (about 11 percent), no enforcement action was taken.

• Administrative Actions: In 186 cases (about 81 percent), FAA used 

administrative actions to address violations. These actions refer not 
Page 18 GAO-12-537T Aviation Safety 

only to warning notices and letters of correction but also informal 

actions, such as oral or written counseling, which can also be used by 

inspectors to address an apparent violation, provided that certain 

criteria are satisfied and the apparent violation is a low safety risk.

• Enforcement actions: We found that FAA rarely used punitive means 

such as revoking licenses and assessing penalties against pilot 

schools with a Part 141 certificate. FAA assessed monetary civil 

penalties in 12 cases (about 5 percent) for pilot schools with a Part 

141 certificate and the fines ranged from $500 to $20,000. FAA 

revoked the operating certificates of schools in 3 cases, or slightly 

more than one percent. To illustrate the severity of an action that 

leads to revoking operating certificates, these include knowingly 

permitting school training aircraft to be used to carry illegal controlled 

substances or an intentional action to improperly credit training to or 

graduate students.

Figure 3: FAA’s Outcomes for the 230 Enforcement Cases for Pilot Schools with 

Part 141 Certificates from Fiscal Years 2006 through 2010

Note: Numbers do not add up to 100 percent due to rounding.
Page 19 GAO-12-537T Aviation Safety 

From fiscal years 2006 through 2010, our analysis of FAA’s PTRS data 

found that FAA completed 9,016 inspections of pilot examiners, but it is 

unclear whether FAA met all of its oversight requirements in this area. 

FAA uses private individuals or organizations to supplement its workforce 

and to provide certification activities such as examining and testing of 

pilot applicants for a fee paid for by the applicant.45 Known as designees, 

pilot examiners are generally appointed by FAA’s local district personnel 

for either 3 years (for an individual) or 5 years (for an organization).46 As 

part of its oversight role, FAA requires each pilot examiner to be 

inspected by FAA inspectors at least once annually and high activity pilot 

examiners must be inspected at least twice annually, as outlined in the 

agency’s oversight policy and NPG directives.47 Additionally, several 

other circumstances may require an FAA inspector to inspect a pilot 

examiner, such as noncompliance with the applicable certification 

policies, an excessively high certification passing rate, or involvement in 

an accident, incident, or other violation.48

Although we could not determine the completion percentage of the 

required inspections for pilot examiners, our analysis of PTRS inspection 

data showed 1- and 2-year gaps in the oversight of some pilot examiners. 

Although we know the number 

of inspections conducted for each fiscal year, we could not determine the 

completion percentage of the required inspections for either the routine 

annual or additional inspections for high activity or special circumstances 

for each fiscal year due to limitations in available data for the population 

of pilot examiners.

 

45FAA uses a broad pool of designated personnel nationwide to act as representatives of 

the agency to conduct many safety certification activities, such as administering practical 

tests to pilots and many other activities.

46Part 61 provides the regulatory basis for the conduct of practical tests for pilot 

certification. Section 183.23 of title 14 (subpart C) provides the regulatory basis for the 

designation of pilot examiners. FAA Order 8900.2 contains procedures for the selection, 

appointment, oversight, training, renewal, termination, and appeal of designees.

47High activity pilot examiners are defined as conducting 50 or more practical tests per 

quarter.

48These circumstances may include a designee: (1) who does not comply with the 

applicable certification policies; (2) whose certification passing rate is excessively high; (3) 

who exceeds the allowable amount of certification activity on a given day; (4) who 

conducts any certification activity that requires prior permission from the managing FAA 

office without obtaining that permission in advance; (5) whose certification file error rate is 

excessively high; (6) who is the subject of a valid public complaint; or (7) who has been 

involved in an accident, incident, or violation of federal aviation regulations.

It Is Unclear Whether 

Required Inspections for 

Pilot Examiners Were 

Completed Because FAA’s

Data System Lacks 

Historical Information
Page 20 GAO-12-537T Aviation Safety 

For instance, we found 114 pilot examiners with a 1-year gap between 

inspections, and 11 pilot examiners with a gap of 2 years. This may 

indicate that required inspections of pilot examiners were not completed 

by FAA in a given fiscal year or that inspections were unnecessary due to 

inactivity of the examiners during that year. FAA officials told us that, until 

recently, FAA had not analyzed the extent to which it has conducted all 

required pilot examiner inspections on a national level. However, FAA has 

previously taken steps to improve oversight of pilot examiners, but still 

faces issues in this area. In 2005, FAA developed 14 recommendations to 

improve pilot examiner compliance, 11 of which were implemented. Three 

recommendations were not implemented due to having a low impact on 

oversight and the administrative workload for implementation for district 

offices.

Nevertheless, FAA officials acknowledged they still face some issues in 

oversight of pilot examiners, due, in part, to the FAA’s current data 

systems’ difficulty compiling inspection data at the regional or national 

level. In September 2010, FAA began developing quarterly assessment 

reports covering 12-month periods on the oversight of its designees, 

including pilot examiners, to assist in identifying oversight gaps and 

potential areas of concerns. We reviewed the quarterly reports that 

covered July 2009 through March 2011 and found they identified a 

number of areas of concern regarding the oversight of pilot examiners. 

For example, some pilot examiners with the highest activity had not been 

inspected over the previous 12 months. FAA began creating the quarterly 

assessment reports to better inform management officials at the national 

office level. For example, in the most recent report provided by FAA 

officials, five high-activity pilot examiners were identified who had 

performed a total of 1,623 pilot practical tests, but for whom no 

inspections were conducted for the previous 12 months. Conversely, the 

report found that FAA conducted 218 inspections of the 171 pilot 

examiners with the lowest testing activity during the same period.49

 

49Low-activity pilot examiners were those with seven or less activities between the third 

quarter of 2010 and the second quarter of 2011.

 Based 

on this report, FAA is not conducting most of its inspections of pilot 

examiners that are responsible for conducting the largest numbers of 

practical tests, and conducting more oversight on the examiners 

conducting significantly fewer tests.
Page 21 GAO-12-537T Aviation Safety 

FAA officials said that the quarterly assessment reports are a temporary 

way of assessing the extent to which it is conducting all required 

inspections, and the agency is in the process of developing a new 

designee management system that it expects to be operational by July 

2012. FAA officials told us that the new system is being designed to 

provide more comprehensive data on designees, including pilot 

examiners, by combining data that FAA currently maintains in various 

data systems.

Unlike oversight of pilot schools with Part 141 certificates and pilot 

examiners, annual inspections of individual flight instructors (i.e., under 

Part 61 regulations) are not required by FAA. From fiscal years 2006 

through 2010, our analysis of FAA’s PTRS data found that FAA 

completed 1,761 inspections of flight instructors. Oversight for flight 

instructors is generally limited to initial and subsequent certification 

renewal, but additional oversight of flight instructors is conducted as an 

optional work activity by FAA. According to FAA policy, flight instructor 

certificates are renewed every 24 months. Inspections of flight instructors 

and their training activities should take place on a random basis in the 

interim, but should be prioritized based on, for instance, observations of 

noncompliance made during a pilot school inspection, an instructor or 

student is involved in an accident or incident, or when an instructor has a 

student failure rate of 30 percent or greater on FAA’s certification tests. 

The oversight of flight instructors is critically important because, like the 

examiners, this population serves as a gatekeeper for ensuring that pilot 

students are being properly trained as they seek certification. However, 

similar to pilot examiners, we could not determine the extent of oversight 

that FAA provided for the entire flight instructor population or the specific 

reasons that inspections were conducted during the 5 fiscal years

covered in our analysis. 

Similar to pilot schools, when inspections or other sources revealed 

compliance issues or violations, FAA uses a variety of actions to enforce 

safety standards and regulatory compliance. For fiscal years 2006 

through 2010, our analysis of FAA’s EIS data found 178 cases against 

flight instructors (see fig. 4). 

• No action: FAA can determine that no action is warranted. In 38 of 

the 178 cases (about 21 percent), no enforcement action was taken.

• Administrative Actions: In 109 cases (about 61 percent), FAA used 

administrative actions to address violations. These actions refer not 

While Not Required, FAA 

Conducts Optional 

Oversight Inspections for 

Flight Instructors, but to 

What Extent Is Unclear
Page 22 GAO-12-537T Aviation Safety 

only to warning notices and letters of correction but also informal 

actions, such as oral or written counseling, which can also be used by 

inspectors to address an apparent violation.

• Enforcement actions: We found that FAA rarely used punitive means 

such as suspending or revoking licenses and assessing penalties 

against flight instructors. FAA suspended licenses in 9 cases (about 

5 percent) and revoked licenses in 16 cases (about 9 percent). FAA 

also assessed monetary civil penalties in three cases (about 2 

percent).

Figure 4: FAA’s Outcomes for the 178 Enforcement Cases for Flight Instructors 

from Fiscal Years 2006 through 2010

FAA has initiated several efforts to address issues related to pilot 

certification testing and training.

• In 2010, FAA began revising the standard set of questions the 

agency uses to create its knowledge tests for pilot certification. 

FAA found that a significant percentage of applicants tested on 

the new questions failed the test compared to those that took the 

test with the previous questions. FAA plans to cooperate with 

industry representatives on future changes to the questions for the 

FAA Efforts to Address 

Issues Associated with 

Pilot Training
Page 23 GAO-12-537T Aviation Safety 

knowledge tests and would likely implement any further changes 

over the next 2 years. 

• FAA plans to establish a government and industry working group 

during fiscal year 2012 to address issues related to pilot certification 

testing standards and training. The group will make recommendations 

to FAA on a variety of issues, including knowledge content (i.e., 

ground school training for understanding the aeronautical knowledge 

areas), knowledge test guides, and practical test standards (i.e., 

guidance used for conducting the flight test portion of a practical test). 

• FAA is currently updating its national guidance and associated 

handbook for FAA inspectors on the recurrent training required for 

flight instructors. Based on the guidance, the aviation industry 

provides refresher training courses for flight instructors that are 

designed to keep them informed of changes to pilot training. 

• FAA is also updating its guidance on the review process for the 24-

month certification renewal for pilots and flight instructors. According 

to FAA, the current guidance is outdated and the revised version will 

provide more detailed guidance for the renewal review process, 

updated terminology and references, and reorganized review content.

• FAA plans to make changes to the practical test standards to 

incorporate required testing for runway incursions. FAA’s goal with the 

revised standards is to reduce runway incursions by 2 percent 

annually from the current level.50

• FAA has also initiated efforts to partner with the aviation academic 

community through a 5-year plan initiative, working through AABI and 

the University Aviation Association (UAA), to leverage academic 

expertise and develop best practices for improving all pilot training.51

 

50Runway incursions, which are precursors to aviation accidents, are instances where 

collisions are narrowly avoided on an airport’s runways or taxiways. GAO has reported 

that general aviation aircraft were involved in over 70 percent of the most serious runway 

incursions from fiscal year 2001 through the second quarter of fiscal year 2011. For more 

information on runway incursions, see GAO, Aviation Safety: Enhanced Oversight and 

Improved Availability of Risk-Based Data Could Further Improve Safety, GAO-12-24

(Washington, D.C.: October 2011). 

51UAA is the representative voice of college aviation education to the aviation industry, 

government agencies, and the general public.
Page 24 GAO-12-537T Aviation Safety 

The goal is to identify specific non-regulatory measures that can be 

used to improve training and reduce accidents.

In our November 2011 report, we did not make recommendations for 

specific improvements to initial pilot training because FAA has initiated 

some efforts and has plans for other efforts to address pilot training 

issues. Our report indicated that FAA has an opportunity to ensure that 

the initial pilot training process is still relevant for producing candidates 

who have the necessary knowledge and skills for airline positions. 

Therefore, we encouraged FAA to continue its efforts, with industry and 

academia collaboration to review the initial pilot training process, 

including ground school content, training hour requirements, and 

knowledge testing for commercial pilot certification under the Part 61 

regulations. However, we made two recommendations to the Secretary of 

Transportation to improve FAA’s oversight of pilot certification and 

training.

Specifically, we recommended that FAA develop a comprehensive 

system that may include modifying or improving existing data systems to:

• measure performance for meeting the annual National Program 

Guidelines’ inspection requirements for pilot schools with a Part 141 

certificate and pilot examiners and

• better understand the nature and scope of the discretionary, planned 

inspections for flight instructors.

In responding to our recommendations, FAA officials said that they 

agreed that improvements in oversight data were needed and indicated 

that they believe efforts already in existence or under way address our 

recommendations.

Chairwoman Cantwell, Ranking Member Thune, and Members of the 

Committee, this completes my written statement.

If you or your staff have any questions about this testimony, please 

contact me at (202) 512-2834 or by email at dillinghamg@gao.gov. 

Contact points for our Offices of Congressional Relations and Public 

Affairs may be found on the last page of this statement. GAO staff who 

made key contributions to this testimony include Keith Cunningham, 

Assistant Director; Vashun Cole; and Amy Rosewarne.

Contacts and 

Acknowledgments 

(540239)
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