# REPORT ON TRAINING HOURS REQUIREMENT REVIEW P.L. 111-216, SECTION 209

2011Table of Contents Acknowledgement..............................................................................................2

1.0 Executive Summary.......................................................................................3

2.0 Methodology................................................................................................4

3.0 Introduction..................................................................................................6

4.0 Recommendations of the Training Hours Requirement Review (THRR) Aviation Rulemaking Committee (ARC)..........................................................................7

4.1 The best methods and optimal time needed for flightcrew of Title 14 Code of Federal Regulations (CFR) part 121 and 135 air carriers to master aircraft systems, maneuvers, procedures, takeoffs and landi ngs, and crew coordination......................................7

4.2 The initial and recurrent testing requirem ents for pilots, including the rigor and consistency of testing progr ams such as check rides.............................................10

4.3 The optimal length of time between traini ng events for such flightcrew members, including recurrent training events.................................................................12

4.4 The best methods to reliably evaluate a flight crew member’s mastery of aircraft systems, maneuvers, procedures, takeoffs a nd landings and crew coordination......................14

4.5 Classroom instruction requirements govern ing curriculum contents and hours of instruction............................................................................................15

4.6 The best methods to allow specific academic training courses to be credited toward the total flight hours required to receive an airline transpor t pilot certificate....................16

4.7 Crew leadership training...........................................................................17

5.0 Conclusion................................................................................................19 Appendix 1: Excerpt from Public Law (PL) 111-216...................................................20 Appendix 2: THRR ARC Charter.........................................................................212

Acknowledgements The Federal Aviation Administration (FAA) wish es to acknowledge the participation and ongoing support of the members of the Flightcrew Member Trai ning Hours Requirement Review (THRR) Aviation Rulemaking Committee (ARC) that met between November 2010 and May 2011.3

1.0 Executive Summary This report responds to Section 209 of Pub lic Law (PL) 111-216 (August 1, 2010), the Airline Safety and Federal Aviation Administration Ex tension Act of 2010. Section 209 required the FAA to convene a multidisciplinary expert pane l comprised of, at a minimum, air carriers, training facilities, instructional de sign organizations, airc raft manufacturers, safety organizations, and labor unions to assess and make r ecommendations on part 121 and 135 crewmember training. Section 209 further requires the F AA to submit to the Committee on Transportation and Infrastructure of the House of Represen tatives; the Committee on Commerce, Science and Transportation of the Senate; and the National Tr ansportation Safety Board a report based on the findings of the panel. The FAA chartered the Flightcrew Member Training Hours Requirement Review Aviation Rulemaking Committee (THRR ARC) on September 30, 2010, and tasked them with making recommendations on the following:

 the best methods and optimal time needed for f light crewmembers of part 121 air carriers and flight crewmembers of part 135 air carriers to master ai rcraft systems, maneuvers, procedures, takeoffs and landi ngs, and crew coordination;

 initial and recurrent testing re quirements for pilots, including the rigor and consistency of testing programs such as check rides;

 the optimal length of time between training events for such flight crewmembers, including recurrent training events;

 the best methods reliably to evaluate mast ery by such flight crewmembers of aircraft systems, maneuvers, procedures, takeoffs and landings, and crew coordination;

 classroom instruction requirements governing cu rriculum content and hours of instruction;

 the best methods to allow specific academic trai ning courses to be credited toward the total flight hours required to receive an air line transport pilot certificate; and

 crew leadership training. The THRR ARC met through May 2011 and provide d the FAA with its recommendations on May 23, 2011. The intent of this report is to re lay the findings of the TH RR ARC. It is not intended to communicate our response to the re commendations or how we intend to address them.4

2.0 Methodology The FAA chartered the Flightcrew Member THRR ARC on September 30, 2010. The FAA selected the following organizations to partic ipate in the THRR ARC. Each organization selected an individual to represent its group.

 Aero Micronesia, Inc.

 Air Line Pilots Association (ALPA)

 Air Transport Association (ATA)

 Atlantic Southeast Airlines

 The Boeing Company

 Bombardier Aerospace Mont real Training Center

 CAE SimuFlite, Inc.

 Coalition of Airline Pilots Associations (CAPA)

 Flight Safety Foundation (FSF)

 FlightSafety International

 Key Air, LLC

 National Air Transportation Association (NATA)

 Regional Airline Association (RAA)

 Southwest Airlines The ARC was chaired by representatives of the NATA and the RAA. The FAA provided a designated representative and four subj ect matter experts to assist the ARC. In its charter, the FAA tasked the THRR ARC with making recommendations on the following issues:

1. the best methods and optimal time needed for flight crewmembers of part 121 air carriers and flight crewmembers of part 135 air carriers to master aircraft systems, maneuvers, procedures, takeoffs and landi ngs, and crew coordination;

2. initial and recurrent testing re quirements for pilots, including the rigor and consistency of testing programs such as check rides;

3. the optimal length of time between training events for such flight crewmembers, including recurrent training events;

4. the best methods reliably to evaluate mast ery by such flight crewmembers of aircraft systems, maneuvers, procedures, takeoffs and landings, and crew coordination;

5. classroom instruction requirements gove rning curriculum content and hours of instruction;

6. the best methods to allow specific academic training courses to be credited toward the total flight hours required to receive an airline transport pi lot certificate; and

7. crew leadership training.5

The majority of the THRR report was directed towards answering issues (1) through (5), which address the level of training, valid ation, and evaluation needed to en sure that a pilot in Part 121 or 135 flight operations has mastery of the knowle dge, skills, and attitudes to operate in the complex air carrier arena and that the interv als between recurrent training events do not compromise safety. The five issues shared enough commonality to permit the THRR ARC to develop three sub-committees to address them according to the following areas:

 Training Courseware: Issues ( 1) and (5)

 Intervals of Training: Issue (3)

 Evaluation and Validation: Issues (2) and (4)

The FAA had previously convened two separate ARCs that specifi cally addressed issues (6) and (7). While PL 111-216 and the FAA tasked the THRR ARC with considering these issues, the ARC membership agreed that it wa s prudent to be familiar with the work conducted by the other ARCs and then build upon it. The THRR ARC wa s briefed on the work conducted by the First Officer Qualification (FOQ) ARC and the Mentor ing, Leadership and Professional Development (MLPD) ARC and used that information as a f oundation to develop its recommendations in these

areas.6

3.0 Introduction
The THRR ARC found the issues it was tasked to address to be very broad, making it a challenge to provide meaningful recommendations . However, the THRR ARC determined that methodologies existed which could be applied by an air carrier to deve lop optimum effective training program curricula, determine the corr ect intervals between training events and effectively evaluate and valid ate training. The methodologies utilize the principles of Instructional Systems Design (ISD) to devel op training programs that address the common cohort of the individual flight crewmembers and allow some flexibility for meeting the training needs of the individual pilot. The THRR A RC concluded that the FAA-approved training system known as the Advanced Qualification Program (AQP) currently provides the optimal method for training, assessing, and validating flight crewmembers for commercial air carrier operations. The THRR ARC recogni zed, however, due to practical limitations, AQP is not a readily achievable, or in some cases even a po ssible training solution for many operators and did not recommend requiring all carriers to adopt an AQP. The THRR ARC identified the following effective principles of AQP that would be benefici al for air carriers that do not have an AQP.

 Competency-Based Training: Training deliv ered and evaluated based upon the amount of training each individual needs to achiev e “mastery” of required tasks. Competency may be achieved at different rates for diffe rent people and the amount of elapsed time between training events that competency is ma intained also varies individually and must be considered. Competency-bas ed training varies from pres criptive training in that it recognizes that one size cannot fit all.

 Train to Proficiency: Train to proficienc y provides for the vari ations of individual learning rates. It allows for additional expos ure to task until the pilot is proficient and competency is achieved.

 Data Collection and Feedback: Data colle ction and analysis assesses the skill and knowledge of the individual and crew and mon itors the health of the training program. The data element provides a continuous feedback loop allowing for rapid adjustments when performance indicators warrant action and, in conjunction with other factors, helps determine the correct intervals between training events. One of the biggest challenges to the THRR ARC was addressing both Part 121 and 135 operators simultaneously. The difference in operating philosophies made it difficult to always find common solutions. Ultimately, the ARC chose the appr oach of achieving “one level of safety,” which often required making more conservative recommendations.

The recommendations of the THRR ARC follow.7

4.0 Recommendations of the THRR ARC

4.1 The best methods and optimal time needed for f lightcrew members of Title 14 Code of Federal Regulations (CFR) part 121 and 135 air carriers to ma ster aircraft systems, maneuvers, procedures, takeoffs and landings, and crew coordination

Summary of recommendations:

 Use ISD to develop a training program, recogni zing the scalability challenges for smaller operators

 Use scenario-based training

 Require a “whole-crew” concep t in training and evaluation

 Change training requirements fo r instructors and evaluators

 Use a grading scale that supports ISD

 Convene a new ARC to make recommendations about the relationship between training centers and air carriers Instructional System Design Considering the variability and scope of 14 CF R part 121 and 135 flight operations, the THRR ARC found it impractical to create a prescriptive list of tasks a nd optimal time that adequately addressed all certificate holde rs’ training and qualification requirements. The THRR ARC recommended an analytical approach to traini ng development, characterized by the use of a systematic process of analysis, design, developm ent, implementation and evaluation to define a training program that would adequately address the operational needs of each certificate holder. The systematic process of analysis, design, de velopment, implementati on, and evaluation is referred to as ISD. The optimum time required to complete training would be determined through the process. Typical variab les analyzed through ISD include:

 Experience of crewmember

 Training resources available/utilized

 Scope of the certificate holder’s operation e. g., long haul internat ional, short haul domestic, single pilot operat ion, and associated threats

 Type and complexity of aircraft

 Number of pilots

 Fleet mix, including variants
The THRR ARC recognized that not all air carriers are large enough to maintain a database of sufficient size to properly perform the “evaluation” step in the ISD process. Therefore, the THRR ARC recommended the establishment of a ne w ARC to identify the data necessary to support an ISD training process for those wit hout access to data (i.e. small air carriers).8

The ISD process supports a strategy of training pilots to proficiency. Once a pilot has demonstrated the ability to perform a maneuver or task to proficiency during a training event, it is no longer necessary to train that maneuve r or task during the training event.

The THRR ARC stated all training should integrat e the use of current and future advanced technologies and flight training equipment, incl uding full flight simulators. Air carriers should utilize a suite of equipment matc hed on the basis of analysis of the training requirements at any given stage of a curriculum. Judi cious analysis of these requirements could enable an air carrier to significantly reduce the need for use of a full simulator.

Scenario-based Training

The THRR ARC recommended the use of scenario -based training. Scenario-based training incorporates Standard Operati ng Procedures (SOP), normal, a bnormal and emergency checklists, aircraft performance, crew resource manageme nt, and threat and error management into situations a pilot is likely to encounter during actual revenue operations. Scenarios should contain operationally relevant r eal world situations used to fo cus the students on a particular subject matter. “Whole-crew” Concept Along with its recommendation on scenario-based training, the THRR ARC recommended that qualified crewmembers occupy each seat during training or checking event. The THRR ARC recommended a Pilot-In-Command (PIC) and Second-In-Command (SIC) as the best practice for crew pairing during training and checking, but provi ded alternatives if logistics did not permit this best practice. Additionally, the THRR A RC recommended the FAA convene a new ARC to make recommendations on crew pairing require ments when an air carrier uses a training provider.

Instructor/evaluator Training

The THRR ARC stated that effective validati on and evaluation of pilot skills can only be accomplished by individuals who are specifically trained to conduct evaluations. The THRR ARC recommended that an air car rier should use ISD to develop instructor/evaluator training and this training should be provi ded annually. Currently, instruct or/evaluator tr aining is only required as a one-time event. The THRR ARC r ecommended that instruct or/evaluator training have a requirement for continued professional deve lopment. To ensure consistency in evaluating and recording the result s of an evaluation, the THRR ARC r ecommended instructors/evaluators be trained on how to record a pilot’s performan ce. The training should also include instructor calibration to provide for consistent grading across instructors.

Grading Systems

Current grading practices t ypically rate a pilot as either Satisf actory (S) or as Unsatisfactory (U) during a proficiency check. The THRR ARC found this practice may not tell the entire story of a pilot’s proficiency or provide enough informati on to measure the effectiveness of a training program. The THRR ARC recommended a new sta ndardized grading system be adopted by all U.S. commercial air carriers to better assess the proficiency of p ilots, showing specific strengths, weaknesses, and trends over time. The THRR ARC recommended the grading scale provide9

enough detail to be used in the ISD evaluati on process. The THRR ARC further recommended the grades and comments made by the instructors a nd evaluators only be used as part of the ISD analysis process to evaluate the effectiveness of the training program. Grades and comments should not be maintained in the flig ht crewmember’s permanent record.

The THRR ARC identified an additional benefit of th is type of grading system: to identify and reward highly-proficient pilots by extending thei r training and checking cy cle. Conversely, those pilots who just meet the minimum standard ma y require more frequent training and checking.

ARC to Review Air Carrier/ Training Provider Relationship

Finally, the ARC recommended the FAA establish a new ARC to evaluate the working relationship between air carriers and traini ng providers, to include at a minimum:

 check airman/instructor training

 training program development

 training program maintenance/revision

 crewmember pairing

 multiple training providers used by one operator

 multi operator concurrent training (same traini ng program used by different air carriers)10

4.2 The initial and recurrent testin g requirements for pilots, includ ing the rigor and consistency of testing programs such as check rides

Summary of recommendations:

 Develop new proficiency standards

 Validate pilot monitoring skills

 Revise standards for conduct of line checks

 Require line check airman training

Proficiency Standards

The current evaluations of air carri er pilots’ flight proficiency are based on a list of tasks that may be defined by multiple sources, including the maneuvers listed in parts 121 and 135, FAA Practical Test Standards, and FAA guidance material s. Currently, the standards used to evaluate a pilot’s proficiency are based on the level of pilot certificate (i.e., co mmercial or airline transport pilot) and the proficie ncy standards required by an air carrier’s training program. The pilot certification standards may not evaluate the same tasks used in an air carrier’s operations. Additionally, current regulations ha ve different requirements for ta sks and events for a PIC and a SIC. Training is also separate. For example, current regulations require a PIC to receive more training tasks and more frequent proficiency checks than a SIC. In addition, PICs train on a 6-month basis, and SICs train on a 12-month basis. The disparity between the training requirements for PIC and SIC is not consistent with actual line operations. During actual operations, pilots must work as a single flight crew.

Therefore, the THRR ARC recommended each air carrier develop a list of minimum acceptable standards, independent from the FA A Practical Test Standards or part 121, to apply specifically to tasks required for validation of pilot skills by that air ca rrier. The THRR ARC recommended the validation be tailored to the operational environment in which the pilot operates. For example, validation of instrument approach proc edure skills should be ba sed on those instrument procedures used by the air carrie r in the conditions in which they use them. This would allow operators to focus on areas that need special emphasis. By this recommendation, the THRR ARC intended the air carrier meet or exceed th e minimum required standard. The air carrier should validate the flight profic iency of both the PIC and the SI C using the same standard.

Validation of Pilot Monitoring Skills

Current regulations do not requir e an evaluation of pilot monito ring skills. Typically, today’s flight operations involve the PIC and SIC performing both Pilot Flying (PF) and Pilot Monitoring (PM) duties. Effectiv e crew monitoring and cross-checking can literally be the last line of defense; when a crewmember can catch an error or unsafe act, th is detection may break the chain of events leading to an accident scen ario. Conversely, when this layer of defense is absent, the error may go undetected, lead ing to adverse safety consequences.

The THRR ARC believes that evaluations must en sure satisfactory compliance with PM duties as detailed in the air carrier’s SOP. Therefore, it recommended that training and validation of flight proficiency include the evaluation of PM skills. Each pilot should demonstrate PM duties11

sufficient to determine compliance with and kn owledge of aircraft pr ocedures and company SOPs including normal and abnormal procedures.

Conduct of Line Checks

Current regulations state that no certificate holder may use any person nor may any person serve as PIC of an aircraft unless, within the pr eceding 12 calendar months, that person has passed a line check in which he or she sa tisfactorily performs the duties a nd responsibilities of a PIC in one of the types of airplanes he or she is to fly. The line chec k must be given by an approved check pilot or by an FAA inspector. The line check shall consist of at least one flight over a typical part of the certificate hold er’s route, or over a foreign or federal airway, or over a direct route and shall include takeoffs a nd landings at one or more repres entative airports. Consistent with its recommendation to train and evalua te on both PF and PM duties, the THRR ARC recommended a line check consist of two flight se gments to permit the PIC to perform the duties of the PM during a second segment while the SIC performs the duties of the PF.

The THRR ARC noted the primary objective of th e line check is for a check airman or FAA inspector to observe and evaluate the in-flight operations of a cer tificate holder within the total operational environment of the air transportation system. Line checks provide the FAA with an opportunity to assess elements of the aviation syst em, internal and external to an operator, from the vantage of the airpla ne flight deck. A well run line check program can detect deficiencies and adverse trends and identify th e need to revise or initiate procedures. To best meet the objectives of the line check program, the THRR ARC recommended a line check be conducted during actual revenue operations by a check ai rman or FAA inspector occupying the approved observer’s seat in the flight deck; or if the check airman is qualified, from either pilot seat while also serving as a required crewmember. The THRR ARC recognized some operators may not agree with this recommendation, considering th at if a pilot’s performance does not meet standards, he or she should not be permitted to complete the flight or series of flights. Therefore the THRR ARC also recommended an air carrier have procedures in its operations manual to address when a check airman or FAA inspector de termines that a pilot’s performance does not meet standards. The THRR ARC recommended the individual be permitted to continue to operate. The THRR ARC noted challenges in scheduling lin e checks for part 135 on demand air carriers and for air carriers that use airplanes that do not ha ve an observer’s seat in the flight deck. The THRR ARC made recommendations about expanding th e criteria to define an acceptable check airman and to allow in limited circumst ances a line observation simulation in a full-flight-simulator with either a check airman from a contract traini ng provider or an FAA inspector. The ARC also made recommendati ons about “crediting” line checks for PICs qualified in more than one aircraft for an operator. Line Check Airman Training Finally, current regulations specify the training required to be eligible to be a FAA-approved check airman; however, they do not specify training requirements for a line-check airman. The ARC recommended the FAA develop these requirements.12

4.3 The optimal length of time between training events for such flightcrew members, including recurrent training events Summary of recommendations

 Develop “short-cycle” intervals

 Permit extension of training intervals Short-cycle Intervals Traditional training intervals ha ve historically been based on requirements for evaluations contained in 14 CFR. Training and assessment intervals for these events center around the knowledge and tasks necessary to pass evaluatio ns such as proficiency checks or recurrent ground training, rather than considering the effect of the length of interval a pilot can maintain the cognitive skills needed to handle normal, non -normal, or emergency conditions during flight operations. For the purpose of this discussi on the cognitive skills are referred to as the Knowledge, Skills, or Attitudes (KSA) needed to handle normal, non-normal, or emergency conditions.

The THRR ARC did not consider optimum intervals for opera tors training under an AQP since training intervals for those operators are deri ved from an ISD analysis. As such, the recommendations for optimum training interval s are only appropriate for operators training under part 121, subparts N and O, a nd/or part 135, subparts G and H. Although a number of factors may influence the a ppropriate length between these events for an individual pilot or all pilots flying for an operator, the THRR ARC believed that existing regulatory intervals for these events must be reduced in cases when a pilot re-enters the operator’s training program after an extended absence, or when a pilot demonstrates unsatisfactory performance during an evalua tion. The THRR ARC called this concept a short-cycle. The THRR ARC proposed that a short-cycle would reduce the training and assessment interval by one-half the normal training a nd assessment interval. If a pilot is required to complete requalification training that exceeds the normal recurrent ground and flight training or if the pilot demonstrates unsatisfactory pe rformance, the ARC recommended those pilots be subject to a short-cycle recurrent ground and flight evalua tion after returning to flight operations. This ensures that pilots have maintained the KSA’s covered during thei r requalification training. The THRR ARC stated if a significant number of the operator’s pilots fail to achieve performance standards during KSA assessments, th en the operator’s traini ng program itself must be examined for deficiencies or inability to de liver adequate training. Operators should develop a “train to proficiency and assessment” philo sophy in conducting their flight crewmember recurrent training. This means de livering training that maintains or improves their proficiency and instills a positive attitude for carrying out their responsibilities during flight operations. Although flight crewmembers must demonstrate pr oficiency and competency within a reasonable number of training sessions, it is recognized that there will be occasions where pilots will not achieve required performance st andards during KSA assessments. Extension of Training Intervals

The THRR ARC also considered whether the FAA should consider the merits of extending certain training and evaluation event intervals for operators who meet other criteria, such as the conditions associated with a “single visit exempti on” (currently associated with AQP), having an13

SMS, adopting a Flight Operational Quality Assura nce or flight data monitoring program, having a full-time Director of Safety or demonstra ting an operational tempo that ensures no skill deterioration in piloting tasks beyond current re gulatory standards. The ARC placed additional limitations on extending training intervals. Th e ARC recommended that data collection and analysis be used to support the ex tension of the training intervals.

The ARC recommended that the more of these charact eristics an operator is able to demonstrate, the greater assessment interval the FAA may grant. However, the ARC also concluded that while it may be worthwhile for the FAA to consid er extending training in tervals, it does not recommend extending any interval beyond 12 mont hs. An operator who wishes to extend intervals beyond 12 months should implement a full AQP.14

4.4 The best methods to reliably evaluate a flight crew member’s mastery of aircraft systems, maneuvers, procedures, takeoffs an d landings and crew coordination

Summary of recommendations

 Increase use of Flight Simu lation Training Devices (FSTD)

 Require scenario-based evaluation

Use of Flight Simulation

Current part 121 and 135 regulati ons permit certificate holders to use simulators for varying amounts of the training, testing, a nd checking required by the FAA. The regulations provide a voluntary alternative to training a nd checking in the airplane. The only required use of a FSTD in the current regulations is the windshear requirements in 14 CFR section 121.409(d).

The THRR ARC recommended all assessments of a pilot’s flight proficiency and knowledge be accomplished using the best method and if applicable, in conjunction with, the most appropriate training device to ensure that all pilot perfor mance standards are met. The THRR ARC stated that using FSTD, rather than aircraft, allows fo r more in-depth checking in a safer environment, including the practice of critical emergency procedures using a broad range of scenarios. FSTD can also replicate virtually a ny possible situation and weather and environmental condition. The use of FSTD also reduces noise, air polluti on, and air traffic conge stion, and conserves petroleum resources. The THRR AR C noted this recommendation is consistent with National Transportation Safety Board recomme ndations A–94–191 through 194, which recommended part 121 flight training and checking should be required in FSTD wherever possible.

Scenario-Based Evaluation

Additionally, the THRR ARC advocated that better pilot performa nce would result from realistic training and validation of pilot sk ills. Therefore, pilot validati on events should be accomplished in “line-oriented” events in flight simulators (when simulati on is available). The events should be structured to ensure all pi lot skill tasks are vali dated, but the method by which the tasks are validated should be flexible. This flexibility s hould include the ability to validate the training over multiple sessions rather than one “check ride” event. In addition, the THRR ARC recommended that line-oriented validation focu s on operator-specific requirements, specific operational challenges faced by the operator, or issues identified by the operator’s safety management program.15

4.5 Classroom instruction requirements governing curriculum contents and hours of instruction

 Use ISD to develop a training program, recogni zing the scalability challenges for smaller operators

 Use scenario-based training

 Require a “whole-crew” concep t in training and evaluation

 Change training requirements fo r instructors and evaluators

 Use a grading scale that supports ISD

 Convene a new ARC to make recommendations about the relationship between training centers and air carriers

Classroom training is integral to overall pilot training, therefor e the THRR ARC made the same recommendations as it made to the first focus area, listed previously in 4.1.16 4.6 The best methods to allow specific academic training courses to be credited toward the total flight hours required to receive an airline transport pilot certificate

Summary of recommendations

 Concur with recommendations of FOQ ARC

 Reconcile any academic crediting system with Internati onal Civil Aviation Organization ( ICAO) Standards And Recommended Practices (SARP)

 Maintain current part 135 requirements

Current regulations require an Airline Transport Pilot ( ATP) certificate for pilots acting as PIC and commercial certifi cate for SIC pilots in part 121. Under part 135 operations, PIC are required to hold an ATP certificate for operations in a multi-engine, turbojet powered aircraft that has ten or more passe nger seats. A SIC in those operations is required to hold a commercial certificat e. Public Law (PL) 111-216, Section 216, requires an ATP certificate for a pilot serving as SIC for a part 121 air carrier. PL 111- 216, Section 217 also allows the FAA to c onsider using specific academic training courses towards the ATP flight hour requirements.

Recommendations of the FOQ ARC

The FAA asked the already-chartered FOQ ARC to make recommendations on Section 217 of PL 111-216. The ARC considered what criteria would permit academic training and quality of experience to substitute for the existing aeronautical experience requirements required to obtain an ATP certific ate necessary to exercise SIC privileges under part 121. The FOQ ARC recommended a sy stem to credit aeronautical experience that could be used to meet ATP aeronautical experience requirements, but limited its applicability to the issuance of an ATP certificate for SI C privileges only in part 121 operations. The THRR ARC conc urred with this approach.

Reconcile with ICAO SARP

Additionally, the THRR ARC suggested that a ny aeronautical experience credit system be reconciled, where possible, with ICAO licensing SARP.

Maintain Current 135 Requirements

In addition to the recommendations provi ded by the FOQ ARC, the THRR ARC also suggested that certifica tion requirements for pilots of part 135 air carriers are appropriate to the operations they conduct. The THRR ARC did not recommend any changes to the part 135 pilot certif ication and experience requirements.17 4.7 Crew leadership training

Summary of recommendations

 Concur with the recommendations of the MLPD ARC for crew leadership training, with certain exceptions

 Require air carrier to determine content of training program, but do not include a specific hour requirement

 Require leadership training for a PIC a nd integrate it into all training events through the ISD process endorsed by this ARC. Current regulations require training when a pilo t, serving as SIC in a particular airplane type, upgrades to the PIC position in the same airplane type. This training largely consists of performance of operational tasks and responsibilities spec ific to the new duty station and does not necessarily provide educat ion to the new PIC on his or her leadership role. Crew Resource Manageme nt training, required for all air carriers, contains some elements of the desired leader ship training, but it is not designed to aid the PIC in assuming a leadership role in the aircraft and the air carrier as the training envisioned by this ARC would.

Recommendations of the MLPD ARC The FAA convened the Flight Crewmember MLPD ARC in response to Section 206 of PL 111-216. The FAA tasked the MLPD ARC to provide recommendations for flight crewmember MLPD for part 121 air car riers. The THRR ARC reviewed the recommendations of the MLPD ARC. With some modifications, the THRR ARC concurred with the recommendation to requir e leadership training for the PIC. The THRR ARC considered lead ership training for part 135 operators as well. Air Carriers Should Develop Content of the Leadership Training Program

The THRR ARC disagreed with the recommen dation of the MLPD ARC for a fixed hour requirement for leadership training. Rather , the THRR ARC recommended using an ISD process, which would permit an air carrier to determine, based upon data and operational experience, the optimal training times for pilo ts. To establish a mandatory fixed hourly requirement is contrary to the principles of training endorsed by the THRR ARC. Further, the THRR ARC was concerned that a requirement for 32 hours of training would not address scalability concerns of the small operators with few aircraft and crewmembers, including those operating under part 135. The THRR ARC recommended the FAA consider these scalability concerns.

The THRR ARC stated that each air carrier should develop its leadership course to incorporate air carrier-specific course mate rial. While the THRR ARC concurred with the MLPD ARC that a facilitated discussi on among those attending the course is a key component to the success of this particular aspect of training, the THRR ARC stated that each air carrier may require additional items in a leadership and command course that may be suitable for distance learning.18

Require Leadership Training

The THRR ARC recommends that leadership tr aining be developed as an event separate from the current requirements for upgrade tr aining. The leadersh ip training should be divided into two segments. The initial se gment would be completed prior to upgrade training in order to cover the leadership modules of the course. The second segment would be completed between six and 18 months after completion of operating experience and incorporate lessons learned during the new PIC’s initial experiences as a PIC and reinforce the concepts covered in the initial leadership and command course.19

5.0 Conclusion The intent of this report is to relay th e findings of the THRR ARC, as required by PL 111-216. It is not intended to communicate our response to the recommendations or how we intend to address them. The FAA ha s preliminarily reviewed the work of the THRR ARC and is considering proposal s that would implement many of its recommendations. For example, the FAA is currently engaged in a rulemaking project that proposes substantial ch anges to the crewmember training and qualification requirements for part 121. The Federal Regi ster published the associated supplemental notice of proposed rulemaking on May 20, 2011. We are also engaged in two additional rulemaking projects related to the work of the THRR ARC, one on Flight Crewmember Mentoring, Leadership and Professional Deve lopment and one on Pilo t Certification and Qualification Requirements. While we are pleased the recommendations of this ARC appear to generally support our current activities, the FAA will need to careful ly evaluate these recommendations within the framework of the rulemaking process, and in the context of Agency priorities and the FAA’s overall safety agenda.20

Appendix 1: Excerpt from Public Law (PL) 111-216
SEC. 209. FAA RULEMAKING ON TRAINING PROGRAMS. (b) EXPERT PANEL TO REVIEW PART 121 AND PART 135 TRAINING HOURS.— (1) ESTABLISHMENT.—Not later than 60 days a fter the date of enactm ent of this Act, the Administrator shall convene a multidisciplinary expert panel comprised of, at a minimum, air carrier representatives, traini ng facility representatives, instructional design experts, aircraft manuf acturers, safety organization representatives, and labor union representatives.

(2) ASSESSMENT AND RECOMMENDATIO NS.—The panel shall assess and make recommendations concerning—

(A) the best methods and optimal time needed for flight crewmembers of part 121 air carriers and flight crewmembers of part 135 ai r carriers to master aircraft systems, maneuvers, procedures, takeoffs and landings, and crew coordination;

(B) initial and recurrent testing requirem ents for pilots, including the rigor and consistency of testing programs such as check rides;

(C) the optimal length of time between training events for such flight crewmembers, including recurrent training events;

(D) the best methods reliabl y to evaluate mastery by such flight crewmembers of aircraft systems, maneuvers, procedures, takeoffs and landings, and crew coordination;

(E) classroom instruction requirements go verning curriculum content and hours of instruction;

(F) the best methods to allow specific academic training courses to be credited toward the total flight hours required to receive an airline transport pilot certificate; and

(G) crew leadership training.

(3) BEST PRACTICES.—In making recommendations under subsection (b)(2), the panel shall consider, if appropriate, best practices in the aviation industry with respect to training protocols, methods, and procedures.

(4) REPORT.—Not later than one year after the date of enactment of this Act, the Administrator shall submit to the Committee on Transportation and Infrastructure of the House of Representatives, the Committee on Commerce, Science, and Transportation of the Senate, and the National Transportation Sa fety Board a report based on the findings of the panel.21

Appendix 2: THRR ARC Charter

Effective Date: 9-30-2010

SUBJ: Flightcrew Member Training Hours Requirement Review Aviation Rulemaking Committee

1. PURPOSE. This document establishes the Flightcrew Member Training Hours Requirement Review Aviation Rulemaking Committee (ARC) according to the Administrator’s authority under Title 49 of the United States Code (49 U.S.C.), section 106(p)(5).

2. BACKGROUND.

a. In August 2010 Congress enacted the “Airline Safety and Federal Aviation Administration Extension Act of 2010” (the “Act”). Section 209(b) of the Act, titled “FAA Rulemaking on Training Progr ams,” requires the FAA to convene a multidisciplinary panel to assess and make recommendations to the Administrator

on:

1) The best methods and optimal time needed for flightcrew members of Title 14 Code of Federal Regulations (CFR) pa rt 121 and 135 air carriers to master aircraft systems, maneuv ers, procedures, takeoffs and landings, and crew coordination;

2) The initial and recurrent testing requir ements for pilots, including the rigor and consistency of testing programs such as check rides;

3) The optimal length of time between tr aining events for such flightcrew members, including recurrent training events;

4) The best methods to reliably evaluate a flightcrew member’s mastery of aircraft systems, maneuv ers, procedures, takeoffs and landings, and crew coordination;

5) Classroom instruction requirements gove rning curriculum content and hours of instruction;

6) The best methods to allow specific academic training courses to be credited toward the total flight-hours required to receive an airline transport pilot certificate; and 

### U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION22

7) Crew leadership training.

b. Section 209(b) of the Act also requires the panel to consider industry best practices with respect to training prot ocols, methods, and procedures and to submit a report, based on the findings of the panel, to Congress and the NTSB by July 31, 2011.

c. To carry out the requirements of Secti on 209(b) of the Act, the FAA is chartering an ARC. The ARC will accomplish the task s directed in Section 209(b) of the Act based on the Congressional timelines outlined in the Act and will additionally develop recommendations for the FAA rega rding regulatory action in those same

areas.

3. OBJECTIVES AND SCOPE OF THE ARC. The Flightcrew Member Training Hours Requirement Review ARC will pr ovide a forum for the U.S. aviation community to discuss and provide recommendations to the FAA concerning the development of requirements to meet Section 209(b) of the Act.

a. Specifically, the ARC shall assess and make recommendations concerning:

1) The best methods and optimal time needed for flightcrew members of 14 CFR part 121 and 135 air carriers to mast er aircraft systems, maneuvers, procedures, takeoffs and landi ngs, and crew coordination;

2) The initial and recurrent testing requir ements for pilots, including the rigor and consistency of testing programs such as check rides;

3) The optimal length of time between tr aining events for such flightcrew members, including recurrent training events;

4) The best methods to reliably evaluate a flightcrew member’s mastery of aircraft systems, maneuv ers, procedures, takeoffs and landings, and crew coordination;

5) Classroom instruction requirements gove rning curriculum content and hours of instruction;

6) The best methods to allow specific academic training courses to be credited toward the total flight-hours required to receive an airline transport pilot certificate; and

7) Crew leadership training.

b. The ARC shall consider scalability of its recommendations to address the needs of small businesses.23

c. The ARC will develop recommendations to 14 CFR parts 121, 135, and other associated regulations as ma y be required to comply w ith the intent of Section 209(b) of the Act. These recommendati ons will be presente d to the Associate Administrator for Aviation Safety for rule making consideration on or before July 31, 2011.

4. ARC PROCEDURES.

a. The ARC will provide advice and recommendations to the Associate Administrator for Aviation Safety and acts solely in an advi sory capacity. Once the ARC recommendations are delivered to the Associate Administrator, it is within her discretion to determine when and how the report of the ARC is released to the public.

b. The committee will discuss and present information, guidance, and recommendations that the members of the committee consider relevant in addressing the objectives.

c. The ARC may be reconvened following the submission of its recommendations for the purposes of providing advice and a ssistance to the FAA, at the discretion of the Associate Administrator.

5. ORGANIZATION, MEMBERSH IP, AND ADMINISTRATION.

a. The membership of the ARC will consist of individuals from the government, pilot associations, training organi zations, and other industry organizations that can provide experts in aircraft operations, flightcrew memb er training, human factors, and other appropriate specialties as determined by the FAA.

1) The ARC will consist of no more than 17 individuals.

2) The FAA will identify the number of A RC members that each organization may select to participate. The Asso ciate Administrator for Aviation Safety will then request that each organization name its representative(s). Only the representative for the organization will have authority to speak for the organization or group that he or she represents.

3) Active participation and commitment by members will be essential for achieving the ARC’s objectives and for continued membership on the ARC.

b. The Associate Administrator for Aviation Safety is the sponsor of the ARC and will select an industry chair(s) from the membership of the ARC and the FAAdesignated representative for the ARC. Once appointed, the industry chair(s) will:24

1) Coordinate required committee and subcom mittee (if any) meetings in order to meet the ARC’s objectives and timelines; 2) Provide notification to all ARC memb ers of the time and place for each meeting; 3) Ensure meeting agendas are establ ished and provided to the committee members in a timely manner; and 4) Other responsibilities as required to ensure ARC objectives are met. c. A record of discussions of ARC meetings will be kept.

d. Although not required, a quorum is desirable at each ARC meeting.

6. PUBLIC PARTICIPATION. ARC meetings are not open to the public. Persons or organizations that are not members of th e ARC and are interested in attending a meeting must request and r eceive approval before the meeting from the industry chair(s) and the designate d Federal representative.

7. AVAILABILITY OF RECORDS. Records, reports, age ndas, working papers, and other documents that are made available to or prepared for or by the ARC will be available for public inspection and copying at the FAA Flight Standards Service, Air Transportation Division, AFS-200, 800 I ndependence Avenue, SW., Washington, D.C. 20591, consistent with the Freedom of Information Act, 5 U.S.C. section 522. Fees will be charged for information furn ished to the public ac cording to the fee schedule published in Title 49 CFR part 7.

8. PUBLIC INTEREST. The ARC’s formation is determined to be in the public interest and is designed to fulfill the performance of duties imposed on the FAA by Federal law.

9. EFFECTIVE DATE AND DURATION. This ARC is effective upon issuance of this order. The ARC will remain in existence until September 30, 2012, unless sooner suspended, terminated or extended by the Administrator.

J. Randolph Babbitt Administrator