# T HE 

# F IRST 

# O FFICER 

# Q UALIFICATIONS 

# A VIATION 

# R ULEMAKING 

# C OMMITTEE 

# R EPORT

Recommendations Regarding Rulema king on Flight Experience, Training, and Academic Requirement s Prior to Operating as a First Officer in Part 121 Air Carrier Operations



## September 28, 2010

## FIRST OFFICER QUALIFICATIONS AVIATION RULEMAKING COMMITTEE CHAIR APPROVAL

Scott W. Foose Vice President Regional Airline Association

FOQ ARC Report September 28, 2010 ii

## TABLE OF CONTENTS

Executive Summary ...................................................................................................................... v 1.0 Recommendations Summary ................................................................................................ 1

1.1 Minimum Certification ......................................................................................................... 1
1.2 Minimum Flight Hour Experience ....................................................................................... 1
1.3 Flight Time and Academic Credit System ........................................................................... 1

1.4 Air Carrier Endorsement ...................................................................................................... 2
1.5 Operational Experience ........................................................................................................ 2
1.6 Background Check ............................................................................................................... 2
1.7 Pre-Employment Screening .................................................................................................. 2
1.8 Multiengine Experience ....................................................................................................... 3
1.9 Difficult Operating Experience ............................................................................................ 3
1.10 Air Carrier Quality Assurance ............................................................................................ 3
1.11 Air Carrier Annual Reporting ............................................................................................ 3
2.0 Academic Credit System ....................................................................................................... 4 2.1 Background .......................................................................................................................... 4
2.2 2010 Pilot Source Study ....................................................................................................... 5

2.3 Atlantic Southeast Ai rlines Training Success Study ............................................................ 6
2.4 Recommended First Officer Qualifications ......................................................................... 7
2.5 Recommended First Officer Qualification Standards .......................................................... 7
2.6 Aircraft Type Rating Requirement ....................................................................................... 8
2.7 Aeronautical Experience Credit System .............................................................................. 8
2.8 Quality Assurance and Oversight ....................................................................................... 11
3.0 Knowledge and Skill Competencies ................................................................................... 13 3.1 Supporting Equivalent Con cepts and Improved Standards ................................................ 13
3.2 Aeronautical Knowledge Areas ......................................................................................... 14
3.3 Flight Proficiency ............................................................................................................... 18
3.4 Aeronautical Experience .................................................................................................... 22

FOQ ARC Report September 28, 2010 iiiTable of Contents

FOQ ARC Report September 28, 2010 iv 4.0 Air Carrier Annual Reporting ............................................................................................ 24
5.0 Minority Opinions ................................................................................................................ 25 5.1 Minority Opinions Submitted at the Conclusion of the FOQ ARC ................................... 25
5.2 Minority Opinions Submitted after the Report is Completed ............................................ 43
5.3 Statements in Support of the FOQ ARC Report ................................................................ 44
Appendix A—First Officer Qualifications Aviation Rulemaking Committee Members and Support Staff ........................................................................................................................ 75
FOQ ARC Members .................................................................................................................. 75
Support Staff

............................................................................................................................. 75
Appendix B—Definitions ............................................................................................................ 77
Appendix C—FOQ ARC Tasking ............................................................................................. 81
Appendix D—Pilot Source Study .............................................................................................. 84
Appendix E—ASA Hiring and Training Data ....................................................................... 111
Appendix F—ATP SIC Qualification Pathways .................................................................... 113
Appendix G—Example Training Objectives .......................................................................... 119
Appendix H—References ......................................................................................................... 123FOQ ARC Report September 28, 2010 v 

## EXECUTIVE SUMMARY

The Federal Aviation Administration (FAA) Ad ministrator chartered the First Officer Qualifications (FOQ) Aviation Rulemaking Co mmittee (ARC) to develop recommendations regarding rulemaking on the flight experience and training requirements of a pilot prior to operating as a first officer in a Title 14, Code of Federal Regulations (14 CFR) part 121 air carrier operation. Subsequent to this tasking, the U.S. Congre ss passed the Airline Safety and Federal Aviation Administration Extension Act of 2010 (H.R. 5900) 1 , in response to which the FAA gave the FOQ ARC several additional taskings.

The FOQ ARC was composed of subject matter e xperts from nine organi zations. The FOQ ARC members collectively brought to the deliberations significant levels of experience in air carrier operations; development, implementation, and ma nagement of pilot training and qualification programs; the establishment of pilot training and qualification standards at the domestic and international level; and public advocacy for aviation safety. The FOQ ARC also had expertise available to it through the FAA to answer any technical questions that arose during discussion.

In section 217 of H.R. 5900, Congress legislated both that the total f light hours required for airline transport pilot (ATP) certification “shall be at least 1,500 flight hours” and that “The Administrator may allow specific academic training courses... to be credited toward the total flight hours required....” The recommendations of the FOQ ARC consider both of these legislative directives. However, two FOQ A RC member organizations filed minority opinions disagreeing with the concept of awarding flight hour credits for academic training. That being said, all FOQ ARC members agree that every ef fort should be made by the industry and by the Administrator to encourage all prospective pilots to attain the higher know ledge and experience standards herein recommended by th e FOQ ARC. Few would argue w ith the benefits that come from having pilots in air carrier operations who have completed unive rsity flight training programs, advanced jet training courses, or milit ary flight training programs available today. The FOQ ARC therefore recommends that any new and increased quali fication standard for pilots entering the air carrier industry require a proper bala nce between experience and education.

The FOQ ARC adopted a safety risk assessment pr ogram to identify the e nhanced aeronautical knowledge and flight proficiencies believed to be essential to part 121 first officer qualifications. The same approach was taken when determining levels of credit for alternate academic and flight training paths leading to a professi onal pilot position in air carrier operations.

As a result of the passage of H.R. 5900, and be yond the tasking initially given to the FOQ ARC, the Administrator also asked the FOQ ARC to de fine the flight hours and/or experience in difficult operating conditions necessary to prepare a pilot for part 121 operations. The FOQ ARC based its activity in this rega rd on past recommendations by the National Transportation Safety Board defining difficult ar eas of operation requiring enhanced training. The FOQ ARC extensively discussed the issue of difficult operating conditions and determined

1 Signed into law as Public Law 111–216 by President Obama August 1, 2010.Executive Summary

FOQ ARC Report September 28, 2010 vi that simulator training is an impor tant tool by which to provide fli ght experience to the pilot for recognition and appropriate respons e in the difficult environments experienced by air carriers. Because of safety concerns, the FOQ ARC is not recommending pilots be intentionally placed in these difficult conditions in actual aircraft.

The FOQ ARC would like to thank the Administra tor for the opportunity provided to submit its recommendations in this report. The FOQ ARC’s recommendations achieve a significant enhancement in safety over the current requirements in 14 CFR part 61 and exceed the requirements of H.R. 5900. The majority of th e FOQ ARC recommends that in order to be a qualified second-in-command (SIC) pilot in part 121 operations, the individual must possess an ATP certificate or an ATP SIC certificate, as described in secti on 2.0 of this report. Two FOQ ARC member organizatio ns filed minority opinions disa greeing with the sufficiency of ATP SIC requirements. The FOQ ARC members unanimously ag ree that a pilot be required to have (1) enhanced ae ronautical knowledge and flight profic iency skills, (2) an aircraft type rating, and (3) experience in multiengine, multipilot, turbine-powered aircraft. Although the FOQ ARC has focused on experience and trai ning requirements for an SIC in part 121 operations, the group believes the Administrator should also ensure the knowledge and skills contained in this recommendation, as well as training for command, lead ership, mentoring, and experience requirements, including part 121 experien ce as first officer, are incorporated into the requirements for a pilot in co mmand in part 121 operations.

## 1.0 RECOMMENDATIONS SUMMARY

This section identifies those questions the Administ rator tasked to the First Officer Qualifications (FOQ) Aviation Rulemaking Committee (ARC) (s ee appendix C to this report) and the FOQ ARC’s subsequent recommendations. Sections 1.10 and 1.11 are recommendations the FOQ ARC made in addition to the tasking made by the Administrator. An in-depth explanation and supporting data are found in the appropr iate section for each recommendation.

1.1 M INIMUM C ERTIFICATION Question A . What should be the minimum certifica tion level required of a first officer?

The FOQ ARC agrees there must be a new, hi gher level minimum certification requirement for Title 14, Code of Federal Regulations (14 CFR) part 121 first officers. Our recommendations include changes to subpart G of 14 CFR part 61, Airline Transport Pilot, as well as enhanced knowledge and flight proficiency skills, aircraft type rating, and multiengine, multipilot, turbine experience that exceed current ai rline transport pilot (ATP) standards. See sections 2.0 and 3.0.

1.2 M INIMUM F LIGHT H OUR E XPERIENCE Question B . What should the minimum flight hour experience requirements be for a first officer?

First officers will have 1,500 hours of flight time or of combined flight time and aeronautical experience credit as defined in the recommendati ons. See sections 2.4 and 2.5. The Coalition of Airline Pilots Associations (CAPA) and National Air Disa ster Alliance/Foundation (NADA/F) dissent from this position; see th eir minority opinions in section 5.0.

1.3 F LIGHT T IME AND A CADEMIC C REDIT S YSTEM Question C1 . Can academic training substitu te for hours of experience?

Yes. A credit system is outlined in the r ecommendations in secti on 2.5. CAPA and NADA/F dissent from this position; see th eir minority opinions in section 5.0.

Question C2 . If so, what subjects and how much flight experience?

The recommendations cover a wide range of paths, subjects, and flight training that have been found creditable by the FOQ ARC. See sections 2.0 and 3.0. CA PA and NADA/F dissent from this position; see their mi nority opinions in section 5.0.

FOQ ARC Report September 28, 2010 11.0 Recommendations Summary

1.4 A IR C ARRIER E NDORSEMENT Question D1 . Should there be an air car rier endorsement on a comme rcial pilot certificate?

No. The FOQ ARC has determined the commercial certificate does not qualify a pilot to act as a pilot for a part 121 air carrier. The FOQ A RC made recommendations for enhanced pilot qualifications before acting as a pilot for a pa rt 121 air carrier. See sections 2.0 and 3.0.

Question D2 . If so, what kind of flight and ground training shoul d be required?

The FOQ ARC recommends specific aeronautical knowledge and flight proficiency areas applicable to part 121 operations to be trained and evaluated through a knowledge and practical test. See sections 3.2 and 3.3.

1.5 O PERATIONAL E XPERIENCE Question E . Should there be an operational experience requirement (for example, high altitude and icing) before being permitted to operate as a first officer?

The FOQ ARC recommends training and aerona utical experience, including in difficult operating conditions. The FOQ ARC considered operating experience requirements/flight time requirements for difficult operationa l conditions, and in the interest of safety recommends these be conducted in a flight simula tion training device using realistic scenario-based training. See section 3.4.

1.6 B ACKGROUND C HECK Question F . Background Checks: What additional background checks should be accomplished to ensure the flight crewmembers have proper qualifications and experience?

The FOQ ARC agrees the air carrier should ga in a thorough understanding of each applicant’s airman training and checking history. The FOQ ARC therefore recommends “notices of disapproval” be considered by air carri ers before an empl oyment decision.

1.7 P RE -E MPLOYMENT S CREENING Question G1 . Comprehensive Pre-employment Screenin g: For an employer to assess the suitability, aptitudes, skills, and airmanship of an applicant, should a knowledge and/or skills evaluation be required?

The FOQ ARC considered a variety of best practices from air car riers but decided not to make specific recommendations in this area.

Question G2 . If so, what are the competenci es that should be evaluated?

See above answer to question G1.

FOQ ARC Report September 28, 2010 21.0 Recommendations Summary

FOQ ARC Report September 28, 2010 3 1.8 M ULTIENGINE E XPERIENCE Question H . To ensure part 121 flight crewmemb ers have the proper qualifications and experience, what type of multiengine fli ght experience, if any, is appropriate?

The FOQ ARC recommends a mini mum of 50 hours of multiengine flight time be required, as well as aeronautical experience in multiengine , multipilot, turbine-powered aircraft. The FOQ ARC further recommends the aw ard of a type rating be require d before a pilot may act in part 121 operations. See sections 2.5 and 2.6. CAPA and NADA/F dissent from this position; see their minority opinions in section 5.0.

1.9 D IFFICULT O PERATING E XPERIENCE Question I1 . Difficult operational conditions: Consider ing a part 121 operational environment, what difficult operating conditi ons should a pilot experience prior to operating in that environment?

The FOQ ARC defines difficult ope rating conditions and addresses the required pilot experience in section 3.4. In the interest of safety, the FOQ ARC does not r ecommend an actual flight time requirement to acquire proficiency in di fficult operating conditions. See section 3.4.

Question I2 . How many flight hours in difficult operating conditions?

The FOQ ARC defines difficult ope rating conditions and addresses the required pilot experience in section 3.4. In the interest of safety, the FOQ ARC does not r ecommend an actual flight time requirement to acquire proficiency in di fficult operating conditions. See section 3.4.

1.10 A IR C ARRIER Q UALITY A SSURANCE The FOQ ARC recommends air carriers provide deidentified feedback to the FAA on SIC performance during and afte r training. See section 2.7.

1.11 A IR C ARRIER A NNUAL R EPORTING The FOQ ARC recommends that air carriers prov ide an annual report to the FAA showing flight hours, education, and qualifications for each first officer hire d during that past year. See section 4.0. The National Business Aviation Association (NBAA) and Regional Airline Association (RAA) dissent from this position; see their minority opinions in section 5.0.

## 2.0 ACADEMIC CREDIT SYSTEM

2.1 B ACKGROUND Current regulations (§ 121.437) require a first officer to obtain a commercial pilot certificate in the appropriate category and class with an inst rument rating to perform duty in part 121 air carrier operations. Based on the regulat ory aeronautical expe rience requirements for obtaining a commercial pilot certificat e, it is possible a first offi cer candidate could receive such a certificate with as few as 250 flight hours (or 190 flight hours under 14 CFR part 141 or 14 CFR part 142) of actual flight ex perience. It is also possible for a first officer candidate to gain the majority of this flight time in a singl e-engine, single-pilot, pist on-powered aircraft. A multiengine commercial certificate is awarded for an average of 10 hours of multiengine flight time, which also often is obtained in a piston-powered, single-pilot, multiengine aircraft.

The most common entry-level part 121 air carrier position offered to a new first officer candidate is as a flightcrew member on a multiengine, tu rbine-powered, multipilot aircraft. Comparative review by the FOQ ARC has made it clear there is a significant gap between the knowledge and flight experience required for success as a first officer in part 121 air carrier operations and the knowledge and flight experience acquired by mee ting the minimum regulatory requirements for a commercial pilot certificate. The FOQ ARC also determined that, depending on the manner in which a new first officer candidate chooses to gain flight experience, this gap may remain even after the candidate has complete d the 1,500 flight hours required to obtain an ATP certificate. All flight hours do not impart the same level of aeronautical experien ce. Preparation for part 121 operations requires quality experien ce and learning not necessarily obtained through flight hours alone.

Bridging this knowledge and flight experience gap requires training in important subject areas, such as turbine-powered aircraft, multiengin e aircraft, multipilot operations, air carrier operations and procedures, high-al titude flight conditi ons, and the operation of digital flight systems. These and other subject areas are not co vered in the training that typically leads to the award of a commercial pilot cer tificate. There has been longs tanding debate on the extent to which academic education and advanced training techniques can provide an effective substitute for actual flight hours and in-cockp it flight experience. However, research into training program performance data and how people learn indicate the commercial pilot/part 121 pilot knowledge and flight experience gap can be best and most effectively bridged through successful completion of a modern pilot training program that methodically integrates academic training, practical training, and flight experience.

The design of modern pilot traini ng programs has benefitted from the latest scientific studies about the human learning process. Understa nding this learning pro cess necessitates an understanding of two types of memory, long-term memory and working memory. The learning process occurs in working memory, which is th e “workbench” where information is dissected and reassembled until it can be encoded in long-t erm memory (Wickens, 1992). In order to learn a new concept, the working memory taps into recognized patterns fr om long-term memory (Hunt, 1997). If patterns are easily recognized, it takes less time to l earn and there will be a positive transfer of training. If previous patterns detract from the learning process, there will be

FOQ ARC Report September 28, 2010 42.0 Academic Credit System

FOQ ARC Report September 28, 2010 5 a negative transfer of training. Another challenge to learning occurs if too many new patterns are being evaluated at once (Wickens, 1992). Learning occurs best when only a few new patterns are evaluated at any time. This also promotes an incremental and positive transfer of training. Attempting to learn in several new e nvironments impedes an effective transfer of training. Well-structured training program s that feature integrated academics and flight experience optimize the learning proce ss and achieve efficient knowledge and skill acquisition.

Based on academic references, review of available data in the subject area, and the FOQ ARC’s experience in part 121 operations and traini ng, the FOQ ARC members developed a regulatory construct for part 121 first officer qualificati ons. It recognizes the quality of each potential component of an individual’s education and previ ous experience. This construct, presented and further discussed below, credits both total flight hour experience and specific academic training courses that collectively provide a positive transf er of knowledge and capabilities in the training of a part 121 first officer. As such, it is c onsistent with the latest requirements for ATP certification as defined in sections 216 and 217 of the Airline Safety and Federal Aviation Administration Extension Act of 2010 (H.R. 5900).

Under a flight training program qualified in ac cordance with this construct, successful accumulation of 1,500 hours of actual flight time a nd aeronautical experience credit will begin to provide a first officer candidate with the know ledge and flight experience necessary for certification as a part 121 first officer. To further ensure each first officer ca ndidate trained under such a program maintains a proper balan ce of flight experience and academic training, a majority of the FOQ ARC members have agreed all first officer candidates must have a minimum of 500 hours of flight time for certificat ion, regardless of the num ber of credits they earn through academic training. This requirement more than doubles the current commercial certificate requirements. The majority of the FOQ ARC members believe this ensures sufficient real-world operational experience is gained.

2.2 2010 P ILOT S OURCE S TUDY In the spring of 2010, six particip ating colleges/universities and si x regional air carriers jointly studied the backgrounds of the most successful first officer applican ts at the regional air carrier level. The 2010 Pilot Source Study (see appendix D to this report) was conducted to determine how new-hire first officer pilots from va rious training backgrounds performed in initial air carrier training. These backgrounds incl uded college/university aviation programs, college/university non-aviation programs, fixed-base operator programs, non-college part 141 and non-college part 61 programs, and military flight training programs. 2 The study group examined 2,156 records of pilots hi red within a 5-year period (2005–2009).

2 The number of military pilots captured in th is study was too small to draw conclusions.2.0 Academic Credit System

FOQ ARC Report September 28, 2010 6 The 2010 Pilot Source Study collected data th rough an online data collection instrument designed by five study researchers, all of whom t each in graduate research programs. Data was gathered from each air carrier’s human resources and training department records. This collection was performed at each air carrier by a combination of air carri er personnel, volunteer graduate students, interns, and college professo rs. The research team leader received the resulting six data collection instruments, deid entified them, and combined the data into a single spreadsheet. The research team leader sent this spreadsheet and th e research questions to the researchers. Each researcher independently analyzed the data.

In a series of conference calls, the five researchers came to a consensus on all of the findings. The research team submitted these findings to th e FAA Administrator in response to the advance notice of proposed rulemaking (Docket Nu mber FAA–2010–0100; Noti ce Number 10–02). The research team also submitted it s study to the Internat ional Journal of Applied Aviation Studies, a peer-reviewed publication supported by an interna tional panel of consulting editors. The study was accepted for publication in the summer 2010 issu e of the Internationa l Journal of Applied Aviation Studies.

The findings of the 2010 Pilot Source Study indicated that the new-hire first officer pilots with the highest rate of success 3 in initial first officer training shar ed three attributes: (1) they were graduates of college accredited fl ight degree programs, (2) they ha d experience as certified flight instructors, and (3) they had accrue d between 500 and 1,000 flight hours.

2.3 A TLANTIC S OUTHEAST A IRLINES T RAINING S UCCESS S TUDY Atlantic Southeast Airlines (A SA), a regional air carrier oper ating over 160 Canadair Regional jet aircraft and employing 1,600 pilots, performe d an independent, in -depth study of over 1,000 applicant hiring and training records from Ja nuary 2007 to May 2008 (see appendix E to this report). The study compared how pilots performed during the interview (a 2–day process involving oral and written tests and a simulator evaluation) a nd training process based on each applicant’s training background (either structured or nonstructured). This study suggests pilots who received structured traini ng performed better throughout th e interview process and had greater success in the training phase. They requi red the least amount of additional training to successfully achieve the training program requirement s. It is important to note the median total flight hours for pilots with a structured training program background was approximately 625 hours. The flight hour experience for this category of pilots ranged from a minimum of 200 total flight hours to a maxi mum of 6,590 total flight hours.

3 The two examined outcomes were (1) extra training ev ents before initial operating experience and (2) course completions through initial operating experience. The total pilot group was categorized by nine variables, including the source of training. In the context of this study, a class of first officer trai nees with a high rate of success is one with statistically fewer repeated training events and statis tically fewer training incompletes than the pilot group as a whole (see appendix B to this report).2.0 Academic Credit System

2.4 R ECOMMENDED F IRST O FFICER Q UALIFICATIONS The FOQ ARC was tasked to recommend to the FAA the minimum qualification level for an individual to serve as an SI C pilot in part 121 operations. The FOQ ARC recognizes that H.R. 5900 section 216, signed into law August 2, 2010, directs that, effective August 2, 2013, the ATP certificate, as defined in part 61, subpart G be established as the minimum qualification level for any individual hired as a pilot in part 121 air carrier service. In addition, H.R. 5900 section 217 provides that “The Administrator may allow specific academic training courses to be credited toward the total flight hours required” to meet the ATP requireme nts outlined in part 61, subpart G.

The FOQ ARC therefore recommends qualificati on standards for two methods of compliance with the ATP requirement to permit an individual to serve as an SIC pilot in part 121 revenue operations. The first is a traditional ATP plus additional qualification recommendations. The second method uses a credit system designed to achieve an ATP SIC.

CAPA and NADA/F dissent from this position; see their minor ity opinions in section 5.0.

2.5 R ECOMMENDED F IRST O FFICER Q UALIFICATION S TANDARDS

M

ETHOD O NE Meet the qualification standards for grant of an ATP certificate and an appropriate type rating (see section 2.6) as specified in part 61, subpart G, including ha ving “at least 1,500 hours of total time as a pilot,” and—

• Have a minimum of 50 actual hours of multiengine time.

• Complete an advanced jet tr aining (AJT) program or have demonstrated equivalent aeronautical knowledge and flight proficienc y in multipilot, turbine-powered aircraft before acting in revenue service.

• Have passed a practical and written examinati on (as defined in section 3.0 of this report).

M

ETHOD T WO Hold an appropriate type rating (see secti on 2.6) and an ATP SIC, which requires 1,500 hours “total time as a pilot.” This includes flight ti me and aeronautical experi ence credits. In addition, the first officer must—

• Be at least 21 years of age.

• Hold at least a second cl ass medical certificate.

• Have the appropriate category and class ratings for the aircraft concerned.

• Have passed a practical and knowledge test (a s defined in section 3.0 of this report).

• Have a minimum of—

o 50 actual hours of multiengine time,

o 100 actual hours of cross-country time,

FOQ ARC Report September 28, 2010 72.0 Academic Credit System

o 50 actual hours of night time,

o 50 hours of simulator or actual instrume nt time, of which 25 hours must be actual flight time, and

o 250 actual hours of time as p ilot in command, including—

 75 actual hours of cro ss-country time, and

 25 actual hours of night time, of which 5 hours must also be cross-country hours.

NOTE : The FOQ ARC recommends that pilots holding an ATP SIC certificate not be authorized to provide in struction under § 61.167(b).

CAPA and NADA/F dissent from this position; see their minor ity opinions in section 5.0.

2.6 A IRCRAFT T YPE R ATING R EQUIREMENT Each part 121 SIC must attain an aircraft type rating, pursuant to § 61.63(d) or § 61.157(b), on the aircraft to be operated in revenue service upo n completion of the next initial, transition, or upgrade air carrier training program . (The type rating flight ev aluation may be conducted from either cockpit seat except for those tasks th at are “seat specific” as determined by the FAA Aircraft Evaluation Group.)

2.7 A ERONAUTICAL E XPERIENCE C REDIT S YSTEM There are many possible paths by which an in dividual may obtain the combination of aeronautical knowledge and flight experience necessary to earn an ATP SIC. While much public discussion has focused on raw fli ght hour numbers as the basis fo r a new regulatory qualification standard for the part 121 first officer position, aviation training programs have long proven that the knowledge and skills necessary for success as a part 121 pilot are best imparted through a structured combination of academic and practic al training programs and flight experience.

The legislation wisely allows for a thoughtfully constructed credit syst em by which the various learning paths to the necessary knowledge and flight experience can be credited toward the ATP. Such a system is presented below and provides th e basis for earning an AT P SIC. Section 217 of H.R. 5900 provides the authority necessary for the FAA to authorize the ae ronautical experience credit system recomme nded by the FOQ ARC.

CAPA and NADA/F dissent from this position; see their minor ity opinions in section 5.0.

A CADEMIC AND P RACTICAL T RAINING P ROGRAM V ALUATION The left column in the top half of table 1 (a bove the gray line) presents various pathways by which a pilot may achieve commercial, instrument, and multiengine certificates. An aeronautical experience credit value (right column) has been assigned to each of these pathways. Aeronautical experience credit accounts for academic training and type of f light experience. The most credits are assigned to trai ning achieved through completion of an accredited flight training program at a 4-year aviation univers ity or college. Fewer, but a ppropriate credits are assigned to less-structured training programs.

FOQ ARC Report September 28, 2010 82.0 Academic Credit System

FOQ ARC Report September 28, 2010 9 In the lower portion of the table (below the gray line), the left column details advanced academic training determined to add important value to a pilot seeking a part 121 first officer position. The table details the aeronautical experience cred it value determined appropriate for each of these programs. Pilots can claim only one of the credit values above the gray line. They may claim as many credits as they want from below the line, but, with th e exception of flight instructor ratings, may not claim the same credit twice (for example, pilots may not claim credit for more than one type rating).

The pilot should total actual flight time and the aeronautical experience credit value, as determined by table 1, to determine the equivale nt aeronautical experien ce that should then be compared against the current ATP part 61 flight time requirements. (Refer to table 1 and appendix F to this report to iden tify specific aeronautical experi ence credit values and examples of qualification pathways.)

Table 1—Academic and Practical Training Program Valuation with regard to Aeronautical Experience Credits

An ATP SIC certificate may not be issued to an y candidate with fewer than 500 actual hours of total flight time.

4 Applicable to only certified flight instructor-airplane single engine (CFI), certified flight instructor-instrument airplane (CFII), and certified flight instructor-multiengine-airplane (MEI). Educational Source of Aeronautical Knowledge Aeronautical Experience Credit Value 4-year Aviation University/Colle ge Accredited Flight Training Program 350

4-year Aviation University/Colle ge Flight Training Program 200 2-year Aviation College Accr edited Flight Program 150 2-year Aviation College F light Training Program 100 Flight Academy (part 141/142) Flight Training Program 100 Part 141 Training Program 50 Part 61 Flight Training Program 0 Military “Fixed Wing” F light Training Program 750 Military “Rotary Wing” Flight Training Program 500

Initial certified flight instructor certificate 4 100 Each additional certified flight instructor ratings 3 50 Military Instructor Pilot 200
AJT Course not resulting in a type rating 200 AJT Course resulting in a type rating 2502.0 Academic Credit System

FOQ ARC Report September 28, 2010 10 The FOQ ARC assigned a high aeronautical experience credit value to pilots who complete a military fixed-wing flight training program. The number of aeronautical experience credits for fixed-wing military flight training programs was established based on the following attributes:

• The selection process is highl y competitive and all applican ts are extensively screened.

• Both academic and flight training are intense, which results in a high attrition of those not meeting qualification standards.

• All flight training is conducted in complex turbine aircraft.

• Pilots receive extensive flight training in acrobatics, stalls, spins, and upset recovery procedures.

Advanced flight training involves high-performance aircraft in high-altitude operations.

Military rotary-wing flight tr aining programs share many of the same qualities of fixed-wing flight training programs. Howeve r, rotary-wing pilots receive less training in fixed-wing aircraft and will not achieve as many fixed-wing hours as a military fixed-wing pilot. For this reason, a rotary-wing pilot’s aeronautical experience credit value is less.

The FOQ ARC also debated the applicability of unmanned aerial vehicle (UAV) operations. Because it is unclear whether or not the FAA allows flight hour credit for UAV operations, the FOQ ARC decided UAV flight ti me does not count toward the award of an ATP SIC.

Table 1 reflects credit valuations for currently defined academic training programs. This table should be thought of as a living list to which pr ograms and valuations could be added as new creditable training programs are developed. Examples of such training programs the Administrator might consider include stall and upset recovery programs (currently under industry development) and ab initio 5 training programs that may be developed in the future.

Q UALITY OF F LIGHT H OURS The FOQ ARC agrees there are varying de grees of quality flight hours by which flight experience is acquired. Fl ight hours performed as a flight instructor, on-demand operator, corporate pilot, or in 14 CFR part 91 multiengi ne land flying or its equivalent demonstrate competencies and experiences readily associated with those expected in part 121 operations. For example, pilots performing their duties in a mu ltipilot, turbine-powered aircraft in part 91, subparts F and K operations gain experience much like that required in a part 121 environment, including experience in “diffi cult operational conditions” (such as icing, high altitude, poor weather, difficult airport, and ai r traffic control (ATC) environmen ts). In contrast, flight hours performed in a single-engine aircraft towing a banner or on pipeline or power line patrol generally do not provide the same quality of flight experience.

5 See ab initio definition in appendix B to this report.2.0 Academic Credit System

Table 2 details the categories of flying experi ence the FOQ ARC has determined are the highest quality and complexity, and that provide the greate st value in preparation for part 121 operations. The aeronautical experience credit system r ecommends awarding aeronautical credits on a one-for-one basis for actual fli ght hours operated in the flight categories listed in table 2.

Table 2—Quality of Flight Hours Single-engine turbine Multipilot/Multiengine Multiengine turbine Multiengine piston* Night Instrument Metrological Conditions CFI/CFII/MEI dual-given**

*Aeronautical experience credits for flight hours performed in visual flight rules part 91 multiengine land flight operation are awarded on a one-for-one basis, but such awards only apply to the first 100 hours of such flight. **Aeronautical experience credits for flight hours performed in CFI/CFII/MEI dual-given operation are awarded on a one-for-one basis, but such awards only apply to the first 500 hours of such flight.

2.8 Q UALITY A SSURANCE AND O VERSIGHT The FOQ ARC believes the enhan ced provisions in the recommenda tions to the FAA should, if implemented, be examined and analyzed over time to ensure their effectiveness. This review and followup by the FAA is an essential part of suppor ting broad public confid ence in the national air transportation system. The FOQ ARC has provi ded its recommendations based on the following three items:

1. The most comprehensive and curren t training research available,

2. The most advanced and current operational best practices, and

3. The broadest and most representative expe rt opinion available on aviation safety and performance.

The three recommendations reflec t all of the above knowledge and can be enhanced by an ongoing FAA process committed to continuous improvement via data collection, analysis, feedback, and operational change by part 121 operators.

A data collection process should be instituted fo r continuous feedback on all pilots attaining a restricted ATP certificate. In addition, oversight should be co nducted through a division of the FAA. The FOQ ARC recommends that the Flig ht Standards Service, Air Transportation Division, Voluntary Safety Programs Bran ch (AFS–230) conduct this oversight.

FOQ ARC Report September 28, 2010 112.0 Academic Credit System

FOQ ARC Report September 28, 2010 12 It is further recommended that air carriers provide deidentified feedback to the FAA on each ATP SIC’s performance both during and after trai ning. During training, feedback should include the total number of simulator events over-plann ed, written test scores (testing must not be corrected), results of initial checkrides and any subsequent retraining/r echecking events, and the total number of initial operating e xperience(IOE) hours, or termina tion in any phase of training.

After the completion of training, feedback s hould include performance evaluations during line operations and continuing (recurrent) qualifications. To s upport the feedback after training is completed, the FOQ ARC recommends the F AA create a standardized evaluation tool for part 121 pilots in command to provide period ic comment on an ATP SIC’s performance and knowledge during line operations. All knowledge te sts should be administered and monitored by the FAA. Also, the FAA should explore how to protect the questi ons and answers from public disclosure.

## 3.0 KNOWLEDGE AND SKILL COMPETENCIES

3.1 S UPPORTING E QUIVALENT C ONCEPTS AND I MPROVED S TANDARDS

F

OREWORD The FOQ ARC envisions these recommendations as governed by part 61 for a knowledge and practical test, as appropriate.

1. The term air carrier as used in this do cument refers to operations conducted under part 121.

2. First officers entering into part 121 services must meet the aerona utical knowledge and flight proficiency skills, as outlined in this document.

3. The aeronautical knowledge areas listed in the next section should be defined in greater detail by the Administrator. The cu rriculum and hours shoul d also be defined by the Administrator, to include but not be lim ited to the knowledge a nd flight proficiency areas described in the next section. Appendi x G to the report includes a sample training objectives list. The majority of learning design models follow a similar approach consisting of three categories: analysis, design, and evalua tion. These three categories may be further subdivided into phases, with each phase iden tifying a specific output. Feedback loops are a critical element of any model, and ar e used to confirm assumptions or make adjustments when errors or omissions are discovered.

S

ATISFACTORY P ERFORMANCE “Exhibits knowledge” means the app licant can describe in general or specific terms a response to an evaluator’s question or other knowledge testing system.

Some examples of “demonstrate” ability, flight proficiency, or skill include—

1. Performing tasks and demonstrating satisfact ory proficiency and competency within approved standards.

2. Demonstrating mastery of the aircraft w ith the successful outcome of each task performed never seriously in doubt.

3. Demonstrating sound judgment and multipilot resource management.

4. Demonstrating an overall ability to adapt a nd respond by adjusting aircraft configuration, within appropriate limitations, for changing conditions such as weather, last-minute ATC clearance amendments, or uncharted visual approach procedures.

NOTE : The FOQ ARC recommends the flight pr oficiency tasks that require instrument competency must be demonstrated to the performance standards published in the ATP Practical Test Standards.

FOQ ARC Report September 28, 2010 133.0 Knowledge and Skill Competencies

U

NSATISFACTORY P ERFORMANCE Examples of unsatisfactory performance in exhibiting knowledge or demonstrating flight proficiency would generally be characterized as—

1. The inability to describe or explain in general or in specific terms an aeronautical concept listed in this document in response to an ev aluator’s question or ot her knowledge testing system.

2. Any action or lack of action by the applicant that requires corrective intervention by the examiner to maintain safe flight.

3. Consistently exceeding tolerances stated in the objectives.

4. Failure to take prompt corrective action when tolerances are exceeded.

5. Failure to use proper and effective visual scan ning techniques, when applicable, to clear the area before and while performing flight maneuvers.

I NSTRUCTION AND E VALUATION

1. Criteria for instructors and evaluators that administer the trai ning and evaluation of part 121-specific topics should be re viewed or established as necessary.

2. Instructors and evaluators should be required to demonstrate profic iency in training and evaluating pilots within these recommended knowledge and flight proficiency areas.

3. Criteria are set for FAA oversight for issuing the ATP SIC.

4. Consider the International Civil Aviati on Organization Next Generation Aviation Professionals and the International Air Tran sport Association Trai ning and Qualification Initiatives concerning the establishment of instructor and ev aluator criteria for air carriers.

3.2 A ERONAUTICAL K NOWLEDGE A REAS

This section lists the aeronautical knowledge areas proposed to be required for training pilots to operate as SIC in part 121 air carrier operations, but having no part 121 expe rience. Also, before acting as a pilot in part 121 air carrier service, such pilots should be required to prove their competency in these knowledge areas by receivin g a satisfactory grade on a knowledge test that is developed in accordance with § 61.35 and administered by the FAA.

A DVANCED A IRCRAFT S YSTEMS AND P ERFORMANCE

A. Exhibits satisfactory knowledge of jet transport aerodynamics.

B. Exhibits satisfactory knowledge of speci fic aircraft flight characteristics.

C. Exhibits satisfactory knowledge of turbine engine theory.

D. Exhibits satisfactory knowledge of jet trans port engine monitoring systems, such as the engine indication and crew alerting system.

FOQ ARC Report September 28, 2010 143.0 Knowledge and Skill Competencies

E. Exhibits satisfactory knowledge of flight ope rations engineering to include air carrier aircraft performance, weight and balance (W&B), and hydroplaning, including the ability to determine—

1. W&B loading,

2. Air carrier takeoff performance requirements,

3. Air carrier en route requirements, and

4. Air carrier landing requirements.

F. Exhibits satisfactory knowledge of modern transport aircraft avionics systems.

G. Exhibits satisfactory knowledge of air car rier aircraft emergency, irregular, and non-normal procedures including—

1. Checklist philosophies,

2. Proper use of quick reference handbook/checklists, and

3. Use of flight manual procedures.

N

AVIGATION IN A IR C ARRIER O PERATIONS

A. Exhibits satisfactory knowledge of high altitude airspace.

B. Exhibits satisfactory knowledge of navigation systems for pr actical use in all phases of flight incorporating relative and coordinate-b ased navigation systems.

C. Exhibits Extended-Range Twin-Engine Operational Performance Standards.

D. Exhibits Reduced Vertical Separation Minimum.

E. Exhibits satisfactory knowledge of jet transport navigation and approach chart interpretation.

F. Exhibits satisfactory knowledge of jet tran sport flight management systems (FMS).

G. Exhibits satisfactory knowledge in the selecti on and application of a ll available levels of automation (including hand flying), and the actions necessary to readily transition between levels of automation.

H. Exhibits satisfactory knowledge of flight guida nce systems used in ai r carrier operations.

I. Exhibits satisfactory knowledge of air car rier route planning t echniques and tools.

FOQ ARC Report September 28, 2010 153.0 Knowledge and Skill Competencies

A IR C ARRIER O PERATIONS AND S AFETY AND S ECURITY

A. Exhibits satisfactory knowledge of part 121 Certification and Oper ations: Domestic, Flag, and Supplemental Air Carriers and Commer cial Operators of la rge aircraft. Also, exhibits satisfactory knowl edge of aviation security concepts, including—

1. Transportation Security Ad ministration requirements,

2. Airport security requirements, and

3. Ground/in-flight security ro les and responsibilities.

B. Exhibits satisfactory knowledge of the Depa rtment of Transportation’s dangerous goods requirements to include proper identification, packaging, and loading of dangerous goods aboard air carrier aircraft.

C. Exhibits satisfactory knowledge for the use of air carrier operations specifications.

D. Exhibits satisfactory knowledge of high altitude physiology.

E. Exhibits satisfactory knowledge of the e ffects of fatigue on performance, including mitigation strategies.

F. Exhibits satisfactory practical knowledge of airport surface op erations, including—

1. Taxi route planning,

2. Airport movement areas,

3. Ramp procedures and communications,

4. Charted procedures,

5. Complex taxi procedures,

6. Aircraft configurations for specific weather conditions,

7. Aircraft configurations for fuel economy, and

8. Surface movement guidance and control systems.

G. Exhibits satisfactory knowledge of air carrier operational control, including—

1. Dispatch and flight following,

2. Dispatcher and pilot responsibilities, and

3. Emergencies.

FOQ ARC Report September 28, 2010 163.0 Knowledge and Skill Competencies

H. Exhibits satisfactory knowledge of air carri er maintenance procedures appropriate to flight operations, including—

1. Maintenance release procedures,

2. Use of the master minimum equipment lis t (MEL)/configuration deviation list (CDL) in developing an air carrier MEL/CDL, and

3. Use of the MEL/CDL.

A IR C ARRIER W EATHER P LANNING

A. Exhibits satisfactory knowledge of hi gh altitude weather characteristics.

B. Exhibits satisfactory knowledge of high altit ude weather and weathe r planning tools used in part 121 operations.

C. Exhibits satisfactory knowledge of adverse weather phenomena that affects air carrier operations such as windshear, turbulence, and icing.

D. Exhibits satisfactory knowledge of the use of technology tools to avoid adverse weather.

E. Exhibits satisfactory knowledge of air carri er low-visibility operations, including—

1. Low-visibility surface movement and

2. Category II (CAT II) and CAT III approaches.

C OMMUNICATIONS

A. Exhibits satisfactory knowledge of air carri er communication requirements and systems, including—

1. Voice communication and

2. Advanced communications such as data link.

B. Exhibits satisfactory knowledge of ATC co mmunication requirements and systems.

C. Exhibits ATC phraseology:

1. ATC phraseology,

2. Complex ATC clearances, and

3. Communications at high-density airports.

FOQ ARC Report September 28, 2010 173.0 Knowledge and Skill Competencies

S TALL AND U PSET R ECOGNITION AND R ECOVERY

A. Exhibits satisfactory knowledge of in-f light loss of control and appropriate upset recovery techniques in transport category aircraft.

B. Exhibit satisfactory knowledge of loss of control phenomena, such as—

1. Stalls,

2. Wake turbulence,

3. Flight instrumentation failure, and

4. Flight control failure.

A IR C ARRIER P ILOT P ROFESSIONALISM

A. Exhibits satisfactory knowledge of a pilot’ s professional responsib ility and ethics, to include communications, risk manageme nt, decisionmaking, and leadership.

B. Exhibits satisfactory knowledge of aviation safe ty concepts to include Flight Operational Quality Assurance, Aviation Safety Action Program, Line Operations Safety Audit, Safety Management Systems, and a safety culture.

C. Exhibits satisfactory knowledge of good cu stomer service to include passenger communications, affairs, and regulations.

3.3 F LIGHT P ROFICIENCY

Listed in this section are the fli ght proficiency areas proposed to be required for training pilots to operate as SIC in part 121 air carrier operations , but have no part 121 ex perience. In addition, before acting as a pilot in part 121 air carrier se rvice, such pilots should be required to prove their competency in these flight proficiency areas by receiving a satisfactory grade on a practical test developed in accordance with § 61.43 and administered by the FAA.

G ENERAL S UBJECT A REAS

A. Demonstrates the ability to function in a multipilot environment during a flight under normal and non-normal situations.

B. Demonstrates the ability to perform ai r carrier standard operating procedures.

C. Demonstrates the ability to lead multipilo t briefings to establish expectations and promote effective teamwork during predeparture , departure, en route, and approach and landing. Areas of emphasis include—

1. Sterile cockpit procedures,

2. Effective cabin multipilot briefings,

FOQ ARC Report September 28, 2010 183.0 Knowledge and Skill Competencies

3. Normal procedures,

4. Non-normal procedures,

5. Briefings to assist in mitigating adverse w eather encounters (for example, windshear),

6. Aircraft de-ice/anti-ice procedures, and

7. Deferred maintenance items.

D. Demonstrates the ability to use cockp it check procedures, which can include—

1. Checklist philosophies,

2. Normal and non-normal checklist usage,

3. Flows,

4. Use of quick reference handbooks, and

5. Demonstrating the ability to satisfactorily complete transport aircraft emergency, irregular, and non-normal procedures.

E. Demonstrates the ability to satisfactorily a pply performance, W&B, and navigation data in an operational environment.

F. Demonstrates satisfactory proficiency in ope rating flight management systems (FMS).

G. Demonstrates proficiency in the use of a ll available levels of automation (including hand flying), and the actions necessary to read ily transition between levels of automation.

H. Demonstrates proficient use of transport aircraft systems.

I. Demonstrates the ability in practical use of navigation systems in all phases of flight, which can include incorporating relative and coordinate -based navigation systems.

J. Demonstrates satisfactory proficiency in using air carrier and ATC communication systems including—

1. Company communications systems such as an Aircraft Communications Addressing and Reporting System,

2. Proper use of ATC phraseology, and

3. The ability to receive and understand AT C instructions in high-density airport operations.

FOQ ARC Report September 28, 2010 193.0 Knowledge and Skill Competencies

P

REFLIGHT AND T AXI A REAS

A. Demonstrates the ability to determine comp liance with part 121 W&B and performance requirements before takeoff.

B. Demonstrates the ability to follow aircraft Maintenance Release Procedures before departure.

C. Demonstrates the ability to us e an MEL/CDL, which can include

—

1. Aircraft equipment deferral and dispatch implications and

2. Complying with cockpit placarding requirements.

D. Demonstrates the ability to taxi the aircra ft after receiving comple x taxi instructions from ATC.

E. Demonstrates the ability to taxi the aircraft using appropriate airc raft configuration for adverse weather conditions (for exampl e, ground icing conditi ons or high winds).

F. Demonstrates the ability to taxi the airc raft using appropriate configuration for fuel economy.

G. Demonstrates the ability to taxi the airc raft using surface movement guidance and control systems.

T

AKEOFF

A. Demonstrates the ability to perform low visi bility takeoffs using air carrier takeoff minimums.

B. Demonstrates the ability to apply appropria te precautions for adverse weather during takeoff (for example, windshear).

C. Demonstrates proficient use of automation during departure.

D. Demonstrates the ability to fly the aircra ft during complex departure procedures and noise abatement procedures.

E

N

R OUTE

A. Demonstrates proficient use of an adva nced navigation system while en route—

1. During Reduced Vertical Separa tion Minimum operations and

2. To perform FMS route modifications.

FOQ ARC Report September 28, 2010 203.0 Knowledge and Skill Competencies

B. Demonstrates ability to avoid adverse weather en route, which can include—

1. The use of technology to avoid adverse weather and

2. The use of aircraft icing and de-icing systems in air transport aircraft.

S TALL AND U PSET R ECOGNITION AND R ECOVERY

A. Demonstrates the ability to apply appropria te upset recovery techniques in mitigating in-flight loss of control during realistic scenar io-based training events such as takeoffs, en route, approach, and landing as the resu lt of phenomena. Such phenomena include—

1. Stalls,

2. Wake turbulence,

3. Flight instrumentation failure, and

4. Flight control failure.

A RRIVAL : H IGH A LTITUDE T OP OF D ESCENT TO I NITIAL A PPROACH F IX
A. Demonstrates the ability for descent planning with emphasis on fuel planning.

B. Demonstrates satisfactory use of aircraft energy management (for example, airspeed, altitude thrust, and drag management) during descent.

C. Demonstrates ability to veri fy appropriate descent point.

D. Demonstrates satisfactory use of aircra ft energy management to comply with area navigation arrivals/published approaches in both vertical and lateral components.

A RRIVAL : I NITIAL A PPROACH F IX TO S TABILIZED A PPROACH

A. Demonstrates the ability to apply appropr iate techniques for c onducting nonprecision and visual approaches using constant descent approach procedures.

B. Demonstrates the ability in practical use of navigation systems in all phases of flight, incorporating relative and coordinate-based navigation systems.

C. Demonstrates the ability to conduct charted and uncharted visual approach procedures.

D. Demonstrates the ability to fly the airc raft during CAT II and CAT III approaches.

A RRIVAL : S TABILIZED A PPROACH TO L ANDING R OLLOUT OR M ISSED A PPROACH /G O - AROUND

A. Demonstrates satisfactory use of energy management to achieve a stabilized approach.

B. Demonstrates the ability to use appropri ate windshear precautions for approach and landing.

FOQ ARC Report September 28, 2010 213.0 Knowledge and Skill Competencies

FOQ ARC Report September 28, 2010 22 C. Demonstrates the ability to use appropriate wake turbulence precautions for approach and landing.

D. Demonstrates satisfactory use of energy management during approach to landing.

E. Demonstrates the ability to adhere to aim and touchdown point references.

A RRIVAL : M ISSED A PPROACH /G O - AROUND AREAS

A. Demonstrates ability to fly the aircraft during high workload ATC environments.

B. Demonstrates satisfactory use of energy ma nagement during missed approach/go-around.

3.4 A ERONAUTICAL E XPERIENCE

D

IFFICULT O PERATIONAL C ONDITIONS Pilots must receive aeronautical knowledge a nd flight proficiency training in “difficult operational conditions” that may be encountered during air carrier operations. For the purpose of the FOQ ARC, “difficult ope rational conditions” include—

1. Areas of convective activity 6 such as—

a. Thunderstorm activity,

b. Windshear conditions, and

c. Microburst encounters,

2. Icing conditions,

3. Low visibility conditions,

4. Maximum crosswind conditions,

5. Contaminated runways,

6. Areas of clear air turbulence,

7. Areas of mountain wave activity,

8. Periods of pilot fatigue, and

9. Operations involving non-normal aircraft dispatch configurations in accordance with MEL/CDL requirements.

6 See appendix G to this report for an example of training objectives.3.0 Knowledge and Skill Competencies

FOQ ARC Report September 28, 2010 23 In the interest of safety, flight proficiency training for items 1 through 9 should be conducted in a flight simulation training devi ce using realistic scen ario-based training. The FOQ ARC does not recommend an actual flight time requirement to acquire proficiency in items 1 through 9 beyond an existing training or licensing requirement.

The FOQ ARC also considers the operations list ed below to be difficult operational conditions, but encourages pilots to gain proficiency by acquiring actual fl ight time experience in these conditions, although no minimum flight time requ irement should necessarily be specified.

1. High pilot workload operations such as—

a. Operations during periods of high traffic volume at primar y airports located within Class B airspace.

b. Operations within Special Air Traffic Ru les Airspace described in 14 CFR part 93, and

c. Takeoffs, landings, and instrument appro aches at special qualification airports described in § 121.445.

.

## 4.0 AIR CARRIER ANNUAL REPORTING

The FOQ ARC recommends that all part 121 air carriers subject to the provisions of H.R. 5900 provide an annual filing report to the FAA showing flight hours, education, and qualifications for each first officer hired during that past year. The qualifications would be disclosed individually and deidentified for each pilot hired.

This annual filing report would also include a re port on the air carrier’s first officer annual pay and benefits.

Air carriers have the option to pr ovide additional information about enhanced training programs, and additional information that demonstrates a continuous improvement process such as a mentoring program or other sa fety/security initiatives.

The annual FOQ report would be filed to the FAA July 1, 2011, and annually thereafter to ensure progress toward compliance with H.R. 5900 by August 1, 2013.

FOQ ARC Report September 28, 2010 24

## 5.0 MINORITY OPINIONS

5.1 M INORITY O PINIONS S UBMITTED AT THE C ONCLUSION OF THE FOQ ARC

C OALITION OF A IRLINE P ILOTS A SSOCIATIONS



# Coalition of Airline Pilots Associations First Officer Qualifications (FOQ)— ARC Dissent Statement August 31, 2010 Respectfully submitted by: Captain Paul Onorato, President Coalition of Airline Pilots Associations World Headquarters 444 N. Capitol Street, Suite 532 Washington, DC 20001 (202) 624-3540

FOQ ARC Report September 28, 2010 255.0 Minority Opinions

Introduction The First Officer Qualifications Aviation Rulemaking Committee (FOQ-ARC) has done an excellent job of reviewing, de fining and recommending changes to the educational and training requirements for prospective airlin e pilots. CAPA fully supports the ARC’s efforts in this area, and supports the outlined enhancements recommended within this report.

However, CAPA dissents to the majority view of the FOQ-ARC regarding allowing a reduction in flight experience to attain an Airline Tran sport Pilot certificate (A TP) through a “flight time credit system”. CAPA also dissents to the creat ion of an ATP “SIC – onl y” restriction or any other scheme involving new pilot cer tifications or licenses that ar e established for the purpose of bypassing the flight experience requirements nece ssary to qualify for the ATP. One level of safety in all operations conducted under Part 121 is a CAPA goal and applies to major, regional and cargo airline operators.

CAPA’s dissent is based on the following fundamental concepts:

• The difference between training and experien ce: structured or un- structured training designed for successful completion of a flight -check, does not create the judgment and decision-making ability to ope rate in Part 121 operations.

• The industry’s adoption of CRM in today’s Pa rt 121 operating envir onment: Captains do not fly airliners – flight crews fly airliners.

• The need for experienced flight crew me mbers in today’s Pa rt 121 environment.

CAPA answers to FAA’s ARC Questions: a. What should be the minimum certificatio n level required of a First Officer?

CAPA Safety and Training experts all agree that the Airline Transport Pilot’s (ATP) license must be the minimum certification level for all f light crew members operating under Part 121. A competent professional pilot should hold the certificate commensura te with the responsibilities of the position. A second-in-comma nd (SIC) certification would allow a lesser degree of training or preparedness which is not the purpose of this ARC, the FAA, or the intent of Congress.

In addition to the experience a nd aeronautical knowledge requir ements of the ATP, and in agreement with the ARC, CAPA believes that both flight crew members should have the commensurate knowledge of the aircraft that they are operating. Accordin gly, both flight crew members need to hold the specific type rating for the aircraft they fly in Part 121 operations.

b. What should be the minimum flight hour experience requir ements of a First Officer?

CAPA believes that all the requirements of the Ai rline Transport Pilots license (ATP) must be met by a prospective Part 121 First Officer and th at individual hold an AT P certificate. To align experience requirements with actual flight crew member 3 responsibilities, CAPA recommends enhancements to the ATP flight experience requirements as outlined in the dissenting view.

FOQ ARC Report September 28, 2010 265.0 Minority Opinions

c. 1. Can academic training substitute for hours of experience?

CAPA believes that academic training is a necess ary and vital component to the education of a prospective Part 121 First Officer, but academ ic training cannot substitute for hours of experience as outlined in the dissenting view.

c. 2. If so, what subjects an d how much flight experience?

Academic training cannot subst itute for hours of experience.

d. 1. Should there be an air carrier endorsement on a commercial pilot certificate?

CAPA believes that the Airline Transport Pilots li cense is the minimum certification standard for a Part 121 flight crew member ; First Officer and Captain.

d. 2. If so, what kind of flight and ground training should be required?

CAPA fully supports the additi onal flight and ground training recommended by this ARC. The enhanced flight and ground training should be in corporated into the Ai rline Transport Pilot certificate requirements.

e. Should there be an operational experience re quirement (high altitude, icing, etc.) before being permitted to opera te as a First Officer?

The FOQ-ARC unanimously agreed that actual flight in these conditions is not recommended due to safety considerations, however, Part 121 operations are conducted daily in these challenging conditions. This is the essence of why actual fli ght hours are so essential in qualifying as a first officer. In almost all cases, the flight experience requirements of the ATP allows a reasonable amount of time for the prosp ective airline pilot to experience the hazardous flight conditions listed in this question. While one certain ly would not be able to guarantee actual flight in these conditions, the chances are great ly enhanced as the pilot works towards the aeronautical flight experien ce requirements of the ATP.

CAPA also believes that training requirements need to be significantly increased. Specifically:

• The practice of stalls and spins in an actual aircraft should be mandatory to ensure the prospective pilot has experience with un-cont rolled flight and r ecovery techniques.

• Exposure to high-altitude hypoxia in an altitude chamber shou ld be required to prepare pilots who may be involved in a sudden loss of cabin pressure.

Dissenting View

The Coalition of Airline Pilots Associations (CAPA) represents 28,000 pilots within the industry, has access to the safety and training committees of many of the nation’s most prestigious airline pilot groups, and has a unique perspective on th e requirements and qualifications necessary to pilot a modern airliner in today’s environment.

FOQ ARC Report September 28, 2010 275.0 Minority Opinions

CAPA believes that there are 2 necessary compone nts to the training and maturation of a safe and capable airline pilot. First, they must have the education and training a pplicable to their role on the flight deck of an airliner . Second, they must have a requisit e level of experience to operate in real-world Part 121 operations.

The academic requirements suggested by the F OQ-ARC are quality enhancements that CAPA supports, but only in addition to, and not in lieu of current ATP flight experience and knowledge requirements.

As the prospective professional pilot works toward s the ATP certificate, he /she is developing and honing airmanship skills while providing exposur e to the challenges of flight in difficult conditions. Flying aircraft of a ny size develops airmanship skills. For example, a pilot flying small single engine aircraft near the limits of the aircraft, such as flight instructors, banner towers and fire fighters, over time develop excellent airmanship skills. These aeronautical skills together with the training required for the ATP certificat e allow for a smooth and confident transition to Part 121 operations. The concept of progression is well-defined in FAA-approved Advanced Qualification Programs (AQP Training Programs) us ed to train experience d pilots throughout the major airlines.

The structured learning process, discussed by the ARC at length, is excellent for providing knowledge and practice for a specif ic challenge; for example, a st all recovery technique or a deicing procedure. But structured learning, by its definition, has a known quantity and a known outcome. A student knows and can prepare for the lesson beforehand since the standards for completion of the lesson and the required outcom es are known. Most importa ntly, in the case of simulator training, and regardless of the performan ce, the personal safety of the pilot is never in jeopardy. Airline flying, in cont rast, is highly unpredictable. CAPA realizes the value of simulator training, to teach and practice specific tasks in a safe and controlled environment. However, no amount of training can replace exposure and experience in an aircraft.

Flight Time Credits: CAPA is particularly concerned with the FOQ-ARC’s “flight time credit scheme” whereby the ARC is applying “academic cr edits” in lieu of flight experience for the purpose of bypassing the requirements of the ATP. The ARC proposes reducing the established 1,500 hour ATP minimum to as low as 500 hours by way of credits for both academic training and specific flight hours. As a re sult, allowing “1,000 hours of cred it” a full two-thirds of the total requirement for the ATP.

CAPA vigorously opposes allowing specific academic training courses to be credited toward any of the aeronautical flight e xperience requirements of the ATP certificate, including the 1,500 hour total flight time requirement. CAPA experts agree that while the academic courses proposed by the FOQ-ARC are much needed enhancements, they are not substitutions for the requisite flight hour requirements. CAPA also contends that the “fli ght time credit scheme” goes beyond what HR 5900 permits, and certainly beyond the la ws intention. The ARC majority interpreted the term “academic training” in HR 5900 (Sectio n 217) to include “flight training.” CAPA believes this to be in di rect violation of HR 5900.

2010 Pilot Source Study Data: While CAPA recognizes that m odern pilot training programs have benefited from the latest scientific studi es regarding the human l earning process, CAPA’s

FOQ ARC Report September 28, 2010 285.0 Minority Opinions

Safety and Training Committee experts contend th at the pass-fail training data, used by the ARC to justify the “flight time credit scheme”, is inconclusive and does not support their position. Statistics on whether training is successful or not only reveals how stude nts respond in a training environment and does not validate a pilot’s r eadiness for Part 121 operations and hazardous conditions they may encounter. The flight time cr edit system derived from the 2010 pilot source study data does not support or warrant a redu ction to ATP flight experience requirements.

Flight Crew Concept: The role of Captain and First Offi cer in regional and major airline cockpits has changed dramaticall y. In today’s airline environment, Captains do not fly airliners, ‘flight crews’ fly airliners.

Cockpit Resource Management (CRM) program s were first introduced in the 1980’s and established a flight crew concep t where the Captain no longer dictat es the level of First Officer involvement in the operation of the aircraft. The Firs t Officer is now an integr al part of the flight crew with specific duties, responsibilities, and FAA accountability. He or she is encouraged and expected to challenge the thinking and decisi ons of the Captain. All training and standard operating procedures (SOPs) are now based upon and practiced with the Captain and First Officer interacting as a team and each member of the team conducting th eir duties to comply with SOPs. The dual responsibilities inherent in our modern safety culture mandate that entry-level pilots perform at a leve l consistent with seasoned veterans.

The industry structure has also changed. A new- hire Part 121 pilot is no longer flying slow propeller driven aircraft into less traveled air ports as was the case wh en current qualification regulations were written. Currentl y, new-hire pilots are immediatel y responsible for their role as a flight crew member and as such, expected to have mastered sophisticated high speed, high altitude technologically advanced turbine powered aircraft into sa turated airspace and high traffic density airports.

ATP Enhancements CAPA’s Training and Safety Committees belie ve that the aeronautical experience and knowledge requirements of the FAA Airline Transport Pilo t certificate need to be updated to reflect the realities of mode rn airline operations. Today’s challenging airline operational environment dictates that the ATP requirements be further enhanced by including the following:

• 500 hours of PIC time: Allows exposure to command and judgment decisions and develops flight deck decision making skills.

• 500 hours of multi-engine time (100 of which will be in a turbine multi-engine aircraft): Prepares the flight crew member for Pa rt 121 operations as there are no single engine Part 121 operators. Turbine time is e ssential to master the operation of turbine engines and the higher speeds of multi-engine turbine aircraft ut ilized in Part 121 operations.

• 100 hours of actual instrument or simulated instrument flight time, (50 hours in an aircraft): ATP applicants need time to gain a co mfort level operating aircraft with no visual cues, and navigating w ith reference solely to inst rumentation. Development of strong instrument scan requires practice. A lthough procedures can be practiced in the

FOQ ARC Report September 28, 2010 295.0 Minority Opinions

simulator, there is no substitute for experiencing low-visibility takeoff’s, approaches, landings, weather, and diversion i ssues in an actual aircraft.

Basic ATP Flight Experience Requirements The underlying experience requirements of the Air line Transport Pilot Cert ificate are the vital prerequisites for the ability to perform as a flight crew member. They include:

• 500 hours of cross country time : ATP applicants gain experience by operating in unfamiliar ground and flight operations. Actual experience gained includes; flight, fuel and contingency planning, weather analysis , hazardous flight conditions, practical application of MEA’s, MORA s and/or grid obstruction altitudes, operations on and off airways, ATC and AIM procedural experience.

• 100 hours of night flight time : ATP applicants gain expe rience in night flight and ground operations, airport light ing, visual acuity along with differences in spatial orientation, night landings and take offs, night weather avoi dance and traffic recognition.

• 75 hours of instrument time: CAPA’s position is that this requirement needs to be increased to a minimum of 100 hours as discussed in ATP Enhancements.

• 1,500 hours of total time: CAPA has spent a significant port ion of this document on this requirement and why it is a current FAA requirement.

• 23 years of age: leading to a more mature aviator on the flight deck.

• Type rating: This should be accomplished in the specifi c aircraft flown prior to acting as an airline flight crew member in Part 121 operations. CAPA believes that it is vital for both members of the flight crew to display the appropriate mastery of their specific aircraft and the decision making, judgment skills a nd knowledge required by the Type Rating.

* All permissible FAA approved simulator time must be in a full visual and full motion simulator.

Each one of these experience requirements is necessary to produce operational knowledge and skills that are not available from a text book or simulator. Judgment is not developed through training. In contracts, like airmanship skills, it is onl y practiced and enhanced with exposure in aircraft.

Procedural Background

Four of the last five fatal airline accidents have involved regional carri ers, who in many cases hire less experienced pilots, as opposed to majo r airlines. In July of 2009, the US House of Representatives Transportation and Infrastruc ture Committee conducted an aviation hearing where the issue of First Officer Qualifications was highlighted by professional witnesses. Both the House and the Senate conducted further hear ings on aviation safety that included testimony on pilot experience and first officer qualifications.

On February 8, 2010, the FAA issued an Advanced Notice of Proposed Rulemaking on the subject of “New Pilot Certifi cation Requirements for Air Carrier Operations” and received 1,299 comments from all interested pa rties, groups and organizations.

FOQ ARC Report September 28, 2010 305.0 Minority Opinions

Congress recently passed legislatio n that requires all pilots in Part 121 cockpits to possess an Airline Transport Pilot certif icate (ATP), with a three ye ar implementation window. The legislation also permits the FAA Administrator the discretion to allow credit towards the flight experience requirements of the ATP for certain c oursework exceeding that required for the ATP certificate. Accordingly, the FAA has most recen tly chartered the First Officer Qualifications Aviation Rulemaking Committee (ARC) for which this document is prepared.

Issue Background, Pilot Experience Historically, airlines could choose from a highly experienced pilot applicant pool and have require many thousands of hours of flying expe rience to meet their safety standards. The professional status of an airlin e career allowed the industry to select from groups that included former military pilots and the most highly qualified civil aviation pilots.

With the degradation of financial incentives for men and women entering the airline pilot profession in the last decade, coupled with the cost of initial pilot training and the inability of the airline piloting profession to stay financially competitive with comparative professions, an airline pilot career is far less desirable. The result is ma ny experienced pilots and new prospective pilots have sought other career fields that offer compensation commensurate with the responsibilities of their position.

This drastic change in the indus try’s dynamics has altered the de mographics of the pilot hiring pool, causing the experience levels of new hire p ilots operating transport category aircraft to diminish substantially. Where, at one time, flyi ng airline transport airc raft with passengers on board was a prestigious position in the industry, it is now an entry-level position and FAA minimum licensing requirements are be ing tested today as never before.

The alarming trend brought representatives of over 90,000 professional airline pilots before congress to state that the current situation is an unconscionable safety lapse as demonstrated by the recent fatal accidents of regional airlines, and, at a minimum, the flight standards and experience levels incorporated in the Airline Transport Pilot Cer tificate should be required for pilots engaged in Part 121 air operations.

Summary Recent tragic events have shown the need to revisit the training and experience level requirements of pilots employed in Part 121 serv ice. The First Officer Qualifications ARC has recommended a type rating and educational enhancem ents that if adopted will more closely align pilot training with the actual line environment.

The opportunity to develop airmanship skills is critical in the process of producing safe and capable airline pilots. It is no coincidence that th e major airline with the best safety record also has the highest standards for pilot qualificati ons. Southwest Airlines, which has never had a passenger fatality in its over 38 years of existe nce, requires their new hi re pilots to possess 2,500 total flight hours, 1,000 hours of pilot-in-command time (PIC), an FAA Airline Transport Pilots (ATP) certificate and a type rating in the Boeing 737, the aircraft wh ich that pilot will fly when employed by Southwest Airlines.

FOQ ARC Report September 28, 2010 315.0 Minority Opinions

CAPA therefore is resolute in our stance that any part 121 pi lot should possess the FAA Airline Transport Pilot (ATP) certificate and that the tr aining and experience requirements of the ATP certificate be enhanced as stated above. In a ddition, Part 121 flight crew members need to be type-rated in the aircraft they fly prio r to acting as a line flying crew member.

Congress had the wisdom to pass sweeping airlin e safety legislation including a mandate to increase flight crew experien ce levels and for each flight crew member to possess the ATP certificate. CAPA firmly believe s it was their intent to main tain the ATP certificate as a requirement for Part 121 flying and does not believe that the “flight time credit scheme” or an ATP SIC only restriction advocated by the FOQ ARC is in the spirit of the law. The expectations of Congress and of the American people are for sa fe efficient air travel with qualified, trained, and experienced flight crew profe ssionals at the controls. It is th e responsibility of the regulating body, the FAA, to ensure that the traveling public’ s expectations are met, by requiring that both captain and first officer possess an Airline Tr ansport Pilots certificate with the requisite experience requirements, and training.
Figure 1—Comparison of Current Requirements vs. Recommendations

FOQ ARC Report September 28, 2010 325.0 Minority Opinions

N

ATIONAL A IR D ISASTER A LLIANCE /F OUNDATION

2020 Pennsylvania Ave NW #315 – Washington DC 20006 (888) 444 – 6232 –phone (336) 643 – 1394 – fax

September 6, 2010

w ww.PlaneSafe.org PlaneSafe@gmail.com

The following is filed as a Dissent to the proposed Final Report from First Officer Qualifications Aviation Rulemaking Committee (FOQ ARC ). We reserve the right to file an Amended Dissent after the Final Report is presented and that this Dissent be included in full with the Final Report

. Thank you to the FAA for recognizing the need to addres s this very important safety issue by making a significant investment in this Working Group. It has been a pleasure to work with Greg Kirkland, Catherine Burnett, Anne Moore and others from the F AA, who have worked very hard and professionally. Thank you also to Ryan Gibson, Wendy Stanley, and other s from PAI Consulting for their excellent work.

Our Dissent is filed because the FAA Re-authorization Bill, “Airline Safety and Pilot Training Improvement Act H.R.5900,” clearly states the Airline Transp ort Pilot (ATP) certificate is the minimum level of certification for First Officer (F O) Part 121 type aircraft. The ATP certificate requires 1,500 hours of flight time. The intent of Congress is: “shall be at least 1,500 flight hours.”

Any FAA regulation that would permit a 1,000 hour academic credit and only 500 flight hours drastically diminishes the statute’s intent of requiring 1,500 actual flight hours.

The N ATIONAL A IR D ISASTER A LLIANCE /F OUNDATION is a grass roots advocacy organization representing family members, air crash survivors, and industry professionals, striving to improve aviation safety. We incorporated in 1995 and are true to our Founding Goals: To raise the standard of Safety, Security, Survivability and Support for victims’ families.

Many CO3407 family members have been engaged proposi ng changes to pilot certifications and training based on lessons learned from tragic crashes such as CO3407, Comair 5191, AA4184 and others. They approach this effort with the intention to prevent other families from having to endure the painful and horrific experience of losing a loved one in an avia tion crash. When the circumstances of a particular crash indicate it may have been avoidable, its effects on families and friends as well as the aviation industry are amplified exponentially.

We believe that the end result of the FOQ ARC should have been recommendations that promoted an improved Airline Transport Pilot (ATP), prerequisite for the Part 121 First Officer, including the 1,500 hours of actual flight time, and not relying so heav ily on 1,000 hours of academics intended to serve as a substitute for actual flight experience. We do not su pport fulfillment of the ATP certification requirement with only 500 hours of actual flight time.

FOQ ARC Report September 28, 2010 335.0 Minority Opinions

We do agree that a solid educat ional foundation is important and will likely produce a well trained pilot; however, it simply cannot replace or serve as a substitute for actual flight experience.

The U.S. House of Representatives and the U.S. Senate approved the 1, 500 flight hours as part of the legislation, H.R.5900, and their approval for the 1,500 hours goes back to October 2009. H.R.5900 passed in Congress with strong bipartisan support in both the House and Senate and was quickly signed into law by the President. The language in this legislation clearly indicates it was Congress’ intent to require all Part 121 First Officers, to achieve a minimum of 1,500 flight hours and hold an ATP, Airline Transport Pilot certificate.

H.R.5900 contains a minority provision that states, “ The Administrator may allow specific academic training courses beyond those required under subsection (b)(2), to be credited toward the total flight hours required under subsection (c). The Administrator may allow such credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully co mply with the flight hours requirement.”

We believe a cademic training in lieu of flight hour s for the ATP is not appropriate:

1. The provision “may allow” was inserted into the bill late in the legislative process and does not represent the actual intent of Congress to require 1,500 hours of actual flight time 2. The statute’s language states “may allow,” is not a mandate 3. The FOQ ARC majority opinion failed to present any statistical evidence to demonstrate “specific academic training courses” enhance safety more t han “requiring a pilot to fully comply with the flight hours requirement. “ 4. The FAA Charter that established the FOQ ARC states: PUBLIC INTEREST. Forming the First Officer Qualifications ARC is determined to be in the public interest to fulfill the performance of duties imposed on FAA by law . We believe this Charter language is specific to law, H.R.5900.

ARC majority exhausted enormous time and effort to dem onstrate that pilots trained in “structured flight programs” require less retraining events during their region al airline First Officer flight training, than pilots who train through “non-structured flight programs.” Because pilots in structured flight programs demonstrate greater proficiency during regional airlin e flight training, the FOQ ARC majority erroneously assumed that pilots in these programs will be safer pilots than those who develop aviator skills through non-structured flight programs. But this trend suggests t hat pilots from structured flight training programs have the ability to communicate and network with graduat es of their alma mater, who are familiar with the regional airline interview and training processes, rather than a clear demonstration that they are safer pilots.

FOQ ARC majority recommendation permits a regional First Officer to possess as few as 500 actual flight hours, and offered up to 1,000 additional credit flight hour s if the First Officer completed certain types of structured flight programs and academic programs. It is clear from the sub-working group effort that the FOQ ARC majority was committed to holding the line at 500 actual flight hours. It is not by coincidence that a pilot who completes an Aviation Accreditation Board Internati onal (AABI) flight school will graduate with approximately 500 flight hours.

Deciding on the 500 flight hours was a first step of the majority of the working group, and then they structured the academic progr am credits to enable certain AABI structured schools to fall out favorably. Interestingly, the median for hiring Part 121 Firs t Officers (FO) was reported to be approximately 625 hours in one study, with another denoting as few hours as 250 hours. The 500 flight hour requirement is lower than the previous 625 flight hour average. Ther efore, the Final Report could be viewed as a lower flight hour requirement than the median.

The recommendation of the majority opinion of the ARC raises additional issues such as: an academic institution would then be responsible for two-thirds of a pilot’s training. Are the 4-year academic institutions ready to accept that corp orate responsibility and potential liability?

FOQ ARC Report September 28, 2010 345.0 Minority Opinions

High pilot turn-over rates between the regional and the ma jor airlines has significantly diminished resident pilot corporate knowledge at the regional airlines. We must recognize that the current level of flight hour training for the regional First Offers is inadequat e, and that the new dual requirement of an ATP and 1,500 hours of actual flight time will bring these Fi rst Officers to a level that he/she can adequately exercise command of the aircraft under all circumstances.

The Captain should have additional flight time experience, management and leadership skills, and seniority, but the First Officer, Second-in-Command (SIC), should be equally trained and qualified to act as Pilot-in-Command (PIC) and function as the ai rcraft deputy commander during all phases of flight. Having a lesser trained SIC is counterproductive as t he potential to be exposed to challenges alone is increased. Should the SIC need to exercise command of the aircra ft; it will most likely be under an already extremely stressful condition.

There is a need to raise the standard for new hiring FO’s and we understand that some airlines have been pro-active in improving their training programs. That is good news, but there is much more work to do.

H.R.5900 provisions go into affect August 2013, so airlines have three years to meet the higher standards. Some Part 121 airlines may already be hiring pilots who meet the 1,500 hours and ATP standard, and for those who do not they have three years to comply.

We believe that the FOQ ARC has deviated somewhat from the scope of the following five questions, which were included in the original FAA Charter for FOQ ARC.

1. What should be the minimum certification le vel required of a First Officer (FO) ?

NADA/F answer: The FO shall have an ATP with 1,500 actual flight hou rs as required by H.R.5900. In addition a FO shall obtain an aircraft type rating for the aircraft he/she will fly under Part 121.

2. What should be the minimum flight hour experience requirements of a First Officer?

The majority opinion is the following : “FO shall have 1500 hours of flight time of a combined flight time and aeronautical experience credit as defined in the recommendations.”

NADA/F Dissents with the majority opinion answer , which is actually 500 flight hours and 1,000 hours of academic credit, including bonus academic credit.

NADA/F answer : A FO shall obtain 1,500 actual flight hours and fu lfill all ATP as requirements as legislated by H.R.5900.

3. Can academic training substitute for hours of experience? If so, what subjects and how much flight experience?

NADA/F answer: No. However, we support the FOQ ARC “Recommended Aeronautical Knowledge and Flight Proficiency for Pilots Flying in FAR 121 Operation,” as improving the ATP, but not as a flight hour credit.

4. Should there be an air carrier endorsement on a commercial pilot certificate? If so, what kind of flight and ground training should be required?

NADA/F answer: No. The requirement for Part 121 s hall be the ATP and 1,500 hours, as required by H.R.5900, not a commercial pilot certificate with onl y 250 hours. Early in the FOQ ARC the majority

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focused on commercial pilot, 250 hours, however, t he legislation passed, and the standard is ATP, 1500 flight hours.

5. Should there be an operational experience requirement (high altitude, icing, etc.) before being permitted to operate as a First Officer?

NADA/F answer: Yes, however, in the interest of safety, flight training should not encourage a pilot to take an airplane deliberately into unsafe and extreme weather conditions. Increased use of training devices and simulators may substitute for such traini ng, as well as mentoring from experienced pilots.

A pilot with 1,500 hours or more of flight time may be more likely to have experienced difficult operational conditions than one with only 500 hours. The default is not that a pilot with 1,500 hours could just fly around in a Cessna. This is not a valid argument because the ATP has specific requirements, and the ATP-SIC (Airline Transport Pilot license, Second-in-Command) could be strengthened to require additional flight skills.

The Final Report includes the following two documents:

• Recommended Aeronautical Knowledge and Flight Proficiencies for Pilots Flying in FAR 121 Operations This is an excellent document and many of the re commendations should already be in place with the airlines. We support the recommendations of this document and thank the working group members for their time and dedication to create this working document for Part 121 FO’s.

• FAR 121 First Officer Qualifi cations Time and Credit NADA/F Dissents with the FAR 121 First Officer Qualifications Time and Credit. The document makes good points but we Dissent as we do not support the conclusion that these objectives can best be met in an academic curriculum, per this document, and we ar e opposed to 500 flight hours, and a scheme that gives bonus flight hours for academic time.

Cost Benefit Analysis Cost Benefit Analysis is a requirement of FAA Ru lemaking and should be considered as part of this recommendation. The financial impact of a commercial regional airline disaster could be astronomical and the personal loss is even more significant.

AA4184, Oct. 31, 1994 in Roselawn IN had pilots not trained in those conditions, and mistakes were made in the cockpit. The disaster settled 15 years ago for about $280 million, plus cost of the plane, corporate attorneys, and more. Comair 5191 (August 2006) cases have settled for $264 million so far, plus the value of the aircraft, cor porate attorneys, and more. Two Co mair 5191 cases are reported as not settled, and one is scheduled for a punitive damages trial. Continental Express/Colgan 3407 could settle for more.

Some airlines did not stay in business because of t he economic and corporate impact of a fatal crash. Making a relatively small safety investment before an incident occurs, with the intent of providing the highest level of training, or the pilots with the most experience, skills and knowledge, is clearly the more responsible approach

.
The Statistical Value of a Human Life (SVL) has increased to $5.8 million (from $2.7 million), and, in certain conditions, can go even higher.

To view “ Revised Departmental Guidance: Treatment of the Value of Preventing Fatalities and Injuries in Preparing Economic Analyses” go to: www.PlaneSafe.org , go to Resources , and scroll to the last section of LINKS

.

FOQ ARC Report September 28, 2010 365.0 Minority Opinions

There is also an issue of a corporate culture, and its detrimental effect to the aviation industry when the traveling public learns of $17,000 to $19,000 pay per year for Part 121 FO’s, and learns that they did not have sufficient training or experience in ic ing or other bad weather situations.

The American People and Traveling Public want expe rienced pilots in the cockpit, and we believe that higher pay will attract more experienced pilots.

The Part 121 carriers could provide the needed flight hours to gain that 1,500 flight hours of experience, and they could raise their starting pay to $40,000, or better yet, $60,000 + a year. They would have their choice of thousands of experienced and trained pilots with thousands of hours, who are retired military, and/or formerly with larger airlines, overseas experien ce, or a combination of flight hours and training.

No one has discussed the psychologic al factors that could impact so meone’s performance on the job, when a young pilot is burdened with low pay, student loans, fatigue, and pressure to possibly work two or more jobs. Many young pilots from the 4-year ac ademic programs have student loans, and a $100,000 student loan is about $1,000 a month for 30 years to pay back. Young pilots take the $19,000 a year pilot job and may work second jobs just to pay their studen t loan and rent/food. This pathetic pay puts FO new hire pilots in a terrible personal situation, which is not conducive for the focus and energy needed to be a commercial airline pilot.

Experienced pilots cannot afford to work for $19,000 and probably know it is not safe to be a commercial airline pilot while forced to work two or more jobs.

There are many retired military pilots available today. They have a backgroun d different from flight school. In the military if you fail a proficiency test yo u are usually out of the flight program. Unlike nonmilitary flight training programs t hey cannot transfer to another flight school and try again and again until they pass. The competition is high to qualify for m ilitary flight training, and candidates are especially fit physically and mentally, and must pass a government background check. We have also learned that retired military pilots do not become commuter airline pilots because the pay is so low, plus the major airlines are not hiring, or hiring much less the past few years.

We realize that many pilots pass all their check ride s, and some regional airlines demonstrate their airline training program as disciplined, thorough working with mentors and more. Their pilots and new hires probably already qualify for ATP with 1,500 flight hours . For those who do not qualify, they have three years to raise their standards.

Yes, we support higher levels of training and knowled ge, but flight hours experience in a wide variety of equipment and situations may be the most important component.

PRIA In the case of CO3407 the Captain failed three check rides prior to being hired by Colgan, another failed check ride at Colgan (for an ATP) and required additional training after another check ride. H.R.5900 strengthens PRIA, and all Part 121 carriers will be able to better use PRIA as a screening tool when hiring.

NADA/F strongly supports all provis ions of PRIA in H.R.5900 with a special acknowledgement to the CO3407 family members who worked hard to pass th e recent PRIA improvement provisions, and thank you to NADA/F Founding Members who passed the first PRIA in 1996. With respect to national security these provisions should be on a fast track to more accurately and quickly access pilot records.

Background Checks While discussing Background Checks NADA/F specifically recommended that each Part 121 carrier be required to do the following criminal background checks on each new employee:

NCIC – National Criminal Investigation Center SCIC – State Criminal Investigation Center

FOQ ARC Report September 28, 2010 375.0 Minority Opinions

Process of the FOQ ARC NADA/F requested a document comparing the hours for the current ATP (1,500) and ATP-SIC (500 hours) as proposed by the majority of the FOQ ARC. It appears that mo st organizations in the FOQ ARC were provided this working spreadsheet document, which was requested by NADA/F . We specifically requested that ALL member organizations should have full access to Working Group documents.

Spreadsheet. Please note the table at the end of this Dissent, prepared by NADA/F and similar to what was requested , subject to changes if there is a better way to clarify the numbers. We conclude that the ATP could be strengthened with more specific types of flight training per the 1,500 hours, such as multi-engine, requirement of an aircraft type rating for aircraft they will fly, and more.

Accountability - Transition The FAA needs to have a process in place to ensure that Part 121 carriers are moving forward toward meeting the ATP 1,500 hour goals within three years. At this time the FOQ ARC has approved the following Transition Recommendation for all Part 121 air carriers to file an Annual Report with the FAA to show progress toward meeting the higher standards of H.R.5900. This also provides an option for Part 121 carriers to disclose improved training and safety initiatives.

We very much support the following NADA/F recommendation:

Transition to FAA Extension Act of 2010 (H.R.5900)

The FOQ ARC recommends that all Part 121 air carrier s subject to the provision of H.R.5900 provide an Annual Filing to the FAA showing flight hours, educati on, and qualification, for each First Officer hired during that past year. The qualifications would be disclosed individually, de-identified for each pilot hired.

This Annual Report would also include a report on th e airline’s First Officer annual salary and benefits.

Airlines have the option to provide additional info rmation about enhanced training programs, and provide additional information that demonstrates a contin uous improvement process such as a mentoring program, or other safety/security initiatives.

Request the Annual FOQ report be filed to the F AA July 1, 2011 and annually thereafter to ensure progress toward compliance with H.R.5900 by August 1, 2013.

Respectfully submitted,

Matthew Ziemkiewicz President mrz329@verizon.net

John Cane jhcane@aol.com

Gail Dunham Executive Director GADunham@aol.com

FOQ ARC Report September 28, 2010 385.0 Minority Opinions

NADA/F Dissent: ATP actual requirements, versus FOQ ARC Recommendations

ATP Requirements ATP-SIC recommendations from the majority of the FOQ ARC Total Flight Hours 1,500 500 Cross Country 500 100 Pilot in Command 250 250 Instrument Training – Simulator 75 50 Training for Commercial – night 100 50 Multi-Engine 10 50 Specific Hours Required 935 500 Other actual flight hours 565 Total Flight Hours 1,500 500

Academic aeronautical experience 1,000

NADA/F recommends the following improvements to the ATP:

Increase the multi-engine hours requirement, Require aircraft type rating, for aircraft the pilot will be flying, 14 CFD 61.31 Strengthen the ATP with additional aeronautical educa tion, but not in lieu of actual flight hours.

MISSION: To raise the standard of Safety, Security and Survivability for aviation passengers and to Support victims’ families.

FOQ ARC Report September 28, 2010 395.0 Minority Opinions

N

ATIONAL B USINESS A VIATION A SSOCIATION

NBAA DISSENTING POSITION ON PAY AND BENEFITS FOR ANNUAL REPORT

NBAA supports the recommendation of an annual report from Part 121 air carrier s that documents certain qualifications of newly hired first officers. This info rmation could assist the FAA with monitoring compliance across wide range of operators. With the exception of the data related to pay and benefits, the data identified for inclusion within the report measures elements that Congress believes contribut e to increased pilot qualifications.

Requiring 121 air carriers to submit pay and benefits in a report designed to show compliance with HR 5900 attempts to capture information not relevant in determin ing a pilot’s qualification. Additionally, the requirement raises significant privacy questions that have not been fully explored and no safety benefit has been offered for the use of pay and benefit data.

NBAA supports the additional supporting rationale offe red by the Regional Airline Association and recommends that the report not include data related to pay and benefits.

FOQ ARC Report September 28, 2010 405.0 Minority Opinions

FOQ ARC Report September 28, 2010 41 R EGIONAL A IRLINE A SSOCIATION

RAA D ISSENTING O PINION ON P AY AND B ENEFITS FOR A NNUAL R EPORT

The Regional Airline Association (RAA) fully sup ports the First Officer Qualification Aviation Rulemaking Committee’s recommendation that air ca rriers make an annual report to the FAA Administrator detailing the flight hour experience, education background and qualifications of each First Officer hired during that prior year. However, the RA A does not support reporting pay and benefits to the Federal Aviation Administration (FAA) for the following reasons:

• The ARC recommendations provide no link between airmen pay and benefits and operational safety, and therefore no reason to publica lly report this sensitive information.

• Airmen pay and benefits are collectively ba rgained under Railway Labor Act (RLA) rules residing outside the FAA Administrator’s authority.

• Airmen pay and benefits are determined in the c ontext across a range of factors that are largely unique to each air carriers, such as: schedules, productivity, pay guarantees, airmen group size, aircraft size, etc. Meaningful comparisons betw een carriers thus cannot be made from such data.

• The FAA also does not track pay and benefits for any other air carrier employee group.

• While general information about pilot pay and benefit is available on the Internet, this information is competitive, and therefore proprietary in nature.

RAA and our 32 1 member airlines have a wealth of experience in the qualification of professional airmen conducting air carrier operations. Regional airline pilots have experience and training far exceeding the standards established by the FAA. On average, flight time of captains from RAA member airlines exceeds 8500 hours while our first officers ha ve more than 3200 hours. Our veteran management teams, training professionals and pilot cadres understa nd that good training improves safety. Our pilots, both new pilots and senior pilots, are trained and rout inely tested to the FAA’s Air Transport Pilot (ATP) standards – the agency’s highest standard of flying sk ill. New pilots are also supervised by the industry’s most experienced check pilots and mentored by our more veteran captains as they gain valuable experience. Regional airlines have been at the fore front of industry efforts to continually improve training, especially in the areas of unexpected events and in our understanding of how human factors and enhanced leadership skills can reduce safety risks. As demonstrated by the results of the FAA’s Call to

1 Regional Airline Associatio n members are: Aerolitoral, Air Canada J azz, Air Wisconsin Airlines Corporation, AirNet Systems, American Eagle Airlines, Atlantic Southeast Airlines, Cape Air, Chautauqua Airlines, Colgan Air, Comair, CommutAir, Empire Airlines, Era Aviation, Ex pressJet, Flight Options LLC, Go-Jet, Grand Canyon Airlines, Great Lakes Aviation, Gulfstream Internationa l Airlines, Horizon Air, Hawaiian Island Air, Mesaba Aviation, New England Airlines, Pinnacl e Airlines, PSA Airlines, Piedmont Airlines, Republic Airlines, Shuttle America, SkyWest Airlines, and Trans States Airlines.5.0 Minority Opinions

Action audits last summer -- when the FAA inspector s observed 2,419 training and checking events – our highest priority is to continually improve safety.

In conclusion, the RAA recommends that all other provisions of the recommended annual report be considered by the Administrator but strongly oppos es the inclusion of pay and benefits inclusion as a part of the report.

FOQ ARC Report September 28, 2010 425.0 Minority Opinions

FOQ ARC Report September 28, 2010 43 5.2 M INORITY O PINIONS S UBMITTED AFTER THE R EPORT IS C OMPLETED

A IRCRAFT O WNERS AND P ILOTS A SSOCIATION

AOPA DISSENTING POSITION ON CREDIT AMOUNTS IN THE UPPER PORTION OF TABLE 1

The Aircraft Owners and Pilots Association supports the concept of a credit system that recognizes the value of academic courses, training and additional cer tificates completed in pursuit of a position as a first officer at a part 121 Air Carrier. These courses increase the knowledge and competencies of all professional pilots. Although we recognize the benef it of such courses, we must disagree on the amount of credit recommended for the “structured” training path s relative to the amount of credit given, or not given at all, to the general aviation training paths of part 141 schools or part 61 individual flight instructors. AOPA recommends an increase in the amount of credit given to students of part 61 training and part 141 flight schools.

The effectiveness of a flight training course, depends in great part to the competencies of the individual flight instructor, whether that flight instructor is training under a university program, a flight academy, a part 141 flight school or through individual flight in struction. Many flight instructors giving training under part 61 are actually full time crew members of part 121 air carriers and as such may be more qualified to train pilots wishing to pursue a professional pilot career than any other flight instructors. We believe this point is overlooked in the offering of “0” credit through the part 61 training path.

Also, important to keep in mind is that, regardless of the training path taken, all pilots are required to pass the exact same FAA administered written knowledge exams and must meet the same Practical Test Standards for certificates earned. The core compet encies that must be met are exactly the same.

Although there is definite benefit of additional acad emic courses taken in aviation, AOPA believes that a 350 hour split between pilots who received training th rough a university 4 year degree program and those that earned their certificates through a part 61 sc hool (or 300 hour split for part 141 schools) puts the individual flight instructor and part 141 schools at a great financial disadvantage. Many of the flight instructors who offer training through a part 141 school or individually are the instructors who have dedicated their professional careers to flight training. With the credits currently offered through this recommendation, potential students are faced with the choice of enrolling at a university or flight academy or face a 350 hour disadvantage. That 350 h our disadvantage (at an average of $175 / hour of aircraft rental) equates to over $61,000. Many of professional flight instructors and part 141 schools would likely go out of business as a result of this disparity.

AOPA supports the idea of a credit system for a cademic training; however we recommend a more equitable split between credits earned through part 61, part 141 schools and other training paths.5.0 Minority Opinions

5.3 S TATEMENTS IN S UPPORT OF THE FOQ ARC R EPORT

A VIATION A CCREDITATION B OARD I NTERNATIONAL

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FOQ ARC Report September 28, 2010 515.0 Minority Opinions

FOQ ARC Report September 28, 2010 525.0 Minority Opinions

FOQ ARC Report September 28, 2010 535.0 Minority Opinions

FOQ ARC Report September 28, 2010 545.0 Minority Opinions

FOQ ARC Report September 28, 2010 555.0 Minority Opinions

FOQ ARC Report September 28, 2010 565.0 Minority Opinions

P

ILOT C AREER I NITIATIVE 

# P ilot 

# C areer 

# I nitiative

Dissent to CAPA Dissent of September 6, 2010

September 11, 2010

Pilot Career Initiative (PCI) is an Ad Hoc group of aviation professionals formed in October 2009. PCI is comprised of representatives of higher education, airline executives as well as training experts, aviation academy representatives, and other dedicated aviation professionals. Because of this diversity, PCI is
able to draw on the training as well as safety resources and expertise of airlines, universities, academies
and manufacturers. The group was formed due to there mutual concerns for the image of the career of

a professional pilot and lack of educational funding. At the time the group was forming, H.R. 3379 was being pushed through congress by what appeared to special interest groups and non

‐ aviation groups responding to sensational journalistic reporting in the wake of CO3407 and other regional aircraft
accidents prior to that. While well intended, PCI believed H.R. 3379, as written, would fall short of the objectives of congress.
PIC fully supports the premise that minimum regul atory standard for CFR Part 121 carriers must be raised, as evidenced by PCI’s support of the ARC’s recommendations. PCI did and still does believe that the proposed requirements of H.R .3379 would fail to achieve the enhanced safety standards sought. The bill di d, and two dissenting members of the FOQ ARC including the dissenting member pertinent to this document con tinues to call for higher nu mber of flight hours even though there is no evidence that any of the previous accid ents involved or was caused by lack of experience. In fact, both pilots of CO3407 had far in excess of 1,500 flight hours.

Following are PCI’s dissents of CAPA’s specific statements:

CAPA “CAPA’s dissent is based on the fo llowing fundamental concepts:

• The difference between training and experience: structured or un- structured training designed for successful completion of a flight-check, does not create the judgment and decision-making ability to ope rate in Part 121 operations.

• The industry’s adoption of CRM in today’s Part 121 operating environment: Captains do not fly airliners – flight crews fly airliners.

• The need for experienced flight crew members in today’s Part 121 environment .”

FOQ ARC Report September 28, 2010 575.0 Minority Opinions

PCI

PCI does not agree with the first two bullet points above for the following reason: In a modern structured primary training program, with a properly written curriculum written under the FAA Industry Training Standards (FITS), each lesson is scenario

‐ based, including elements of aeronautical decisionmaking, Risk Assessment, CRM, and SRM.

CAPA

“A second-in-command (SIC) certification would allow a lesser degree of training or preparedness which is not the purpose of this ARC, the FAA, or the intent of Congress.”

PCI

PCI disagrees with this statem ent. The ARC’s proposal more than doubles the minimum flight time currently required and a dds levels of knowledge and skill far in excess of today’s requirements.

CAPA

“Most importantly, in the case of simulator training, and regardless of the performance, the personal safety of the pilot is never in jeopardy . Airline flying, in contrast, is highly unpredictable. CAPA realizes the va lue of simulator training, to teach and practice specific tasks in a safe and controlled environment. How ever, no amount of training can replace exposure and experience in an aircraft.”

PCI

PCI disagrees with this statemen t on several levels. First, it runs counter to everything PCI believes in to put the personal safety of passenge rs or crew in jeopar dy in order to provide “exposure” to pilots. Airline flying is perhaps th e most structured, proce ss and procedure-driven environment currently utilized in industry. Pilots spend countless hours in flight training devices learning how to deal with abnormalities and emerge ncies. Even the most “unpredictable”, such as loss of power all power is practiced from the ear liest days of training. It is the opinion of PCI that once immersed in a simulator of proper qua lity, emergencies can be introduced significantly, effectively, and just as realistically as can be done in any aircraft. We also belive that is not in the professional pi lot’s mindset to fail, whether in a training device or real airplane or when ones “personal safe ty” may be at risk.. PCI advocates manning our nation’s airliners with well tr ained pilots, not “survivors”.

FOQ ARC Report September 28, 2010 585.0 Minority Opinions

CAPA

“CAPA also contends that th e “flight time credit scheme ” goes beyond what HR 5900 permits, and certainly beyond the laws intention.”

PCI

Paragraph 217 of H.R. 5900 states, in pertinen t part, “The Administrator may allow specific academic training courses, beyond those required by s ubsection (b) (2), to be credited toward the total flight hours requir ed under subsection (c).

One can’t use “intention” in an argument without documented clarification. This is especially true when this presumed “intenti on” could easily have been writte n into the law. PCI argues that the law’s silence on this issue w ould be an indication that congre ss had no more specific intent except to allow the Administrator make this determination.

CAPA

“CAPA’s Safety and Training Committee experts cont end that the pass-fail training data, used by the ARC to justify the “flight time credit scheme ”, is inconclusive and does not support their position. Statistics on whether training is success ful or not only reveals how students respond in a training environment and does not validate a pilot’s read iness for Part 121 operations and hazardous conditions they may encounter. The flight time credit system derived from the 2010 pilot source study data does not support or warrant a reduction to ATP flight experience requirements.”

PCI

PCI contends that the majority has produced two data sets suppor ting their position. The dissenter’s position is not supported by any data. Neither is it supported by accident history.

It also has to be emphasized that the ARC’ s recommendations do not propose a reduction of flight hours, knowledge requirements, or skills. To the contrary, it proposes a significant enhancement of all three aforementioned areas.

PCI’s experts, comprised of airline executives, airline pilots, distingui shed leaders of higher education in the field of aviati on, and flight instructors disagree with CAPA’s statement.

CAPA “Cockpit Resource Management (CRM) program s were first introduced in the 1980’s and established a flight crew concept where the Captai n no longer dictates the level of First Officer involvement in the operation of the aircraft. The Fi rst Officer is now an integral part of the flight crew with specific duties, respons ibilities, and FAA accountability.”

FOQ ARC Report September 28, 2010 595.0 Minority Opinions

PCI

PCI agrees that the concept of CRM was forma lized almost thirty years ago. As mentioned previously, modern structured primary training programs inco rporate the elements of CRM, SRM, Risk Assessment, and aeronautical decision making in each lesson.

CAPA

“CAPA’s Training and Safety Committees believe that the aeronautical experience and knowledge requirements of the FAA Airline Transport Pilo t certificate need to be updated to reflect the realities of mode rn airline operations. Today’s challenging airl ine operational environment dictates that the ATP requirements be further enhanced by including the following:

• 500 hours of PIC time: Allows exposure to command and judgment decisions and develops flight deck de cision making skills.

• 500 hours of multi-engine time (100 of which will be in a turbine multi-engine aircraft): Prepares the flight crew member for Pa rt 121 operations as there are no single engine Part 121 operators. Turbine time is es sential to master the operation of turbine engines and the higher speeds of multi-engine turbine aircraft utilized in Part 121 operations.

• 100 hours of actual instrument or simulated instrument flight ti me, (50 hours in an aircraft): ATP applicants need time to gain a comfort level operating aircraft with no visual cues, and navigating with reference solely to instrumentation. Development of strong instrument scan requires practice. Alt hough procedures can be practiced in the simulator, there is no substitute for experi encing low-visibility takeoff’s, approaches, landings, weather, and diversion i ssues in an actual aircraft

.

PCI

PCI obviously disagrees with the above requirements but, in particular, wants to point out that turbine engine flying is of questionable value. Turbine engines are easier to manage than reciprocating engines. Also, it would be difficult for aspiring pilots to obtain turbine time,

With regard to the last underlined sentence, PCI believes these procedures are better practiced in a simulator. The fidelity of today’s simulators allow far better training than actual aircraft.

CAPA

• 75 hours of instrument time: CAPA’s position is that this requirement needs to be increased to a minimum of 100 hours as discussed in ATP Enhancements.

PCI

PCI fails to understand exactly what the significance of the additional 25 hours would be.

FOQ ARC Report September 28, 2010 605.0 Minority Opinions

CAPA

• * All permissible FAA approved simulator time must be in a full visual and full motion simulator.

PCI

PCI is uncertain of what CAPA refers to related to “FAA approved simulator time”. Also, PCI disagrees, based on our collectiv e experience that experiential learning is limited to just vull motion and visual simulator systems.

CAPA

“Four of the last five fatal airline accidents hav e involved regional carriers, who in many cases hire less experienced pilots, as opposed to major airlines.”

PCI

PCI finds this a misleading statement. It is mean t to infer that the acciden ts involved pilots with less experience than proposed by CAPA and that lack experience was casual. This is untrue on both counts.

CAPA

“With the degradation of financia l incentives for men and women entering the airline pilot profession in the last decade, coupled with the cost of initial pilot training and the inability of the airline piloting profession to stay financially competitive with comparative professions, an airline pilot career is far less desirable. Th e result is many experienced pilots and new prospective pilots have sought other career fields that offer compensation commensurate with the responsibilities of their position.”

PCI

PCI started on October 9, 2001 with three objectives:

1. To influence what was then H.R. 3379 in the House of Representative to result in rule making that would, in fact , enhance airline safety, 2. To make the profession of an airline pilot more attractive 3. To find solutions to the lack of financial funding for pilot training

PCI does not find itself in disagreement with CAPA’s above statement. It is PCI’s opinion that the solutions do not lie with any one entity and cannot be legislate d. It will require the devoted focus of a wide range of professional disciplines, as is the PCI membership, to chart the course.

Finally, PCI did wish to respond to this statement by CAPA becau se we are passionately in agreement. Having said that, we find it out of the scope of the FOQ ARC.

FOQ ARC Report September 28, 2010 615.0 Minority Opinions

CAPA

“Recent tragic events have shown the need to revisit the training and experience leve l requirements of pilots employed in Part 121 service.”

PCI

As previously illustrated, dissenters of the qualification recommendations of the ARC continue to ignore and fail to answer to the fact that recent accidents did not involve pilots with low time.

CAPA

Figure 2—Comparison of Current Requirements vs. Recommendations

PCI

This chart, by design, is misleading. It gives the optical illusion that the ARC is proposing lowering the requirements to act as SIC in CFR FAR Part 121 operations. The opposite is true. The first column should reflect current requirements not current ATP requirements. PCI wishes again to emphasize that the ARC is recommending at a minimum doubling actual flight time requirements from current (in some cases multiplying it by a factor of 6) with a significant increase in knowledge and skill requirement.

Respectfully Submitted John A. O’Brien PCI john@jaobrienaviation.com

FOQ ARC Report September 28, 2010 625.0 Minority Opinions



# P ilot 

# C areer 

# I nitiative

Dissent to NADA/F Dissent of September 6, 2010

September 11, 2010

Pilot Career Initiative (PCI) is an Ad Hoc group of aviation professionals formed in October 2009. PCI is comprised of representatives of higher education, airline executives as well as training experts, aviation academy representatives, and other dedicated aviation professionals. Because of this diversity, PCI is
able to draw on the training as well as safety resources and expertise of airlines, universities, academies
and manufacturers. The group was formed due to there mutual concerns for the image of the career of

a professional pilot and lack of educational funding. At the time the group was forming, H.R. 3379 was being pushed through congress by what appeared to special interest groups and non

‐ aviation groups responding to sensational journalistic reporting in the wake of CO3407 and other regional aircraft
accidents prior to that. While well intended, PCI believed H.R. 3379, as written, would fall short of the objectives of congress.
PIC fully supports the premise that minimum regul atory standard for CFR Part 121 carriers must be raised, as evidenced by PCI’s support of the ARC’s recommendations. PCI did and still does believe that the proposed requirements of H.R .3379 would fail to achieve the enhanced safety standards sought. The bill di d, and two dissenting members of the FOQ ARC including the dissenting member pertinent to this document con tinues to call for higher nu mber of flight hours even though there is no evidence that any of the previous accid ents involved or was caused by lack of experience. In fact, both pilots of CO3407 had far in excess of 1,500 flight hours.

Following are PCI’s dissents of NADA/F’s specific statements:

NADA:

“ Our Dissent is filed because th e FAA Re-authorization Bill, “Air line Safety and Pilot Training Improvement Act H.R.5900,” clearly states the Airline Transport Pilot (ATP) certificate is the minimum level of certification for First Officer (F O) Part 121 type aircraft. The ATP certificate requires 1,500 hours of flight time. The intent of Congress is: “shall be at least 1,500 flight hours.”

Any FAA regulation that would permit a 1,000 hour academic credit and only 500 flight hours drastically diminishes the statute’s intent of requiring 1,500 actual flight hours.

PCI: Paragraph 216 calls for the ATP but, as eviden ced by paragraph 217, it was not the “intent” to require 1,500 hours of “actual” flight time. Furt her more, the use for the word “intent” is presumptuous unless one is speak ing of their own intent.

FOQ ARC Report September 28, 2010 635.0 Minority Opinions

NADA: We believe that the end result of the FOQ ARC s hould have been recommendations that promoted an improved Airline Transport Pilot (ATP), prerequisite fo r the Part 121 First Officer, including the 1,500 hours of actual flight time, and not relying so heavily on 1,000 hours of academics intended to serve as a substitute for actual flight experience. We do not support fulfillment of the AT P certification requirement with only 500 hours of actual flight time.

PCI: PCI believes that the ARC is proposing an improved ATP, given the enhanced knowledge and competencies which will be required. We al so believe that since such knowledge and competencies exceed those currently required for th e PIC in airline operations. We believe that the PIC ATP requirements should also be enhanced. However, that issue is out of scope for this ARC.

NADA: The U.S. House of Representatives and the U.S. Senate approved the 1,500 flight hours as part of the legislation, H.R.5900, and their approval for the 1,500 hours goes back to October 2009. H.R.5900 passed in Congress with strong bipartisan support in both the House and Senate and was quickly signed into law by the President. The language in this legislation clearly indicates it was Congress’ intent to require all Part 121 First Officers, to achieve a minimum of 1,500 flight hours and hold an ATP, Airline Transport Pilot certificate

.
PCI: Again, this speaks to “intent” which is speculation and certainly is contradicted by paragraph 217.

NADA: “The provision “may allow” was inserted into the bill late in the legislative process and does not represent the actual intent of Congress to require 1,500 hours of actual flight time”

PCI: Again, NADA/F is speculating as to congress’s int ent while paragraph 217 clearly illustrates the intent of congress as it relates to the iss ue of reduction of hours by credit.

NADA: “The statute’s language states “may allow,” is not a mandate.”

PCI: PCI agrees that “may allow” is not a mandate. It is rather an indication that congress believes that the administrator should have the latitude to do so, as proposed by the ARC.

NADA: “The FOQ ARC majority opinion failed to present an y statistical evidence to demonstrate “specific academic training courses” enhance safety more than “re quiring a pilot to fully comply with the flight hours requirement”

PCI: PCI finds this statement without basis. The FOQ presented two studies or sets of data clearly demonstrating that pilots trained as recommended by the ARC have a higher succ ess rate than others. NADA/F ignores the data presented as we ll as ignoring the facts related to experience of pilots in recent accidents.

FOQ ARC Report September 28, 2010 645.0 Minority Opinions

NADA:

“ It is not by coincidence that a pilot who completes an Aviation Accreditation B oard International (AABI) flight school will graduate with app roximately 500 flight hours.”

PCI: PCI agrees with this statement – it is not a coinci dence. Data presented indicates those pilots have a higher success rate at the airline level. Also, a significant number of AABI-acc redited progra m graduates complete their education with a number of hours far le ss than 500, and usually gain extra time as flight instructors.

NADA: “Deciding on the 500 flight hours was a first step of the majority of the working group, and then they structured the academic program credits to enable certain AABI structur ed schools to fall out favorably.”

PCI: Published data presented clearly indicates that a 500 hour pilot coming out of an accredited, structured training organization such as AABI was most successful in initial airline training. That appears to be the logical place to start since, unlike the 1500 hour level, it is supported by data. It is of note that of the 7 organizations in favor, only 1 is representing AABI.

NADA: “The 500 flight hour requirement is lower than the previ ous 625 flight hour average. Therefore, the Final Report could be viewed as a lower flight hour requirement than the median.”

PCI: PCI agrees that 500 is less than 625 but is confused as to the point here. The ARC has proposed a system which, at a minimum, would double curr ent hour requirements, not to mention increased knowledge and competencies.

NADA: “The recommendation of the majority opinion of the ARC raises additional issues such as: an academic institution would then be responsible for two-thirds of a pilot’s training. Are the 4-year academic institutions ready to accept that corpor ate responsibility and potential liability?”

PCI: PCI will speak for itself on this. Our members take “responsibility” and “liability” seriously, but the use of those words do not change our beliefs. As stated, we vi ew those words as written to to be inflammatory.

NADA: “We must recognize that the current level of flight hour training for the regional First Officers is inadequate , and that the new dual requirement of an ATP and 1,500 hours of actual flight time will bring these First Officers to a level that he/she can adequately exercise command of the aircraft under all circumstances”

PCI: PCI does not recognize this and in fact points out that in the case of the two accidents cited by NADA (CO3074 and Comair 5191) each crewmember had flight hours well in excess of current ATP requirements.

NADA: “The FO shall have an ATP with 1,500 actual flight hours as required by H.R.5900.”

FOQ ARC Report September 28, 2010 655.0 Minority Opinions

PCI: PCI is concerned with the use of the word “shall” be cause that would indicate that the dissenter views their organization as a rule-making body. PCI is also concerned with the phrase “as required” because that would indicate, since it is not required by H.R. 5900, that NADA /F either has not read paragraph 217 of the bill or assumes that the reader has not and will not.

NADA: “The default is not that a pilot with 1,500 hours coul d just fly around in a Cessna. This is not a valid argument because the ATP has specific requirements, and the ATP-SIC (Airline Transport Pilot license, Second-in-Command) could be strengthened to require additional flight skills.”

PCI: NADA’s statement is not a valid statement because under the current requirem ents of CFR FAR Part 61, one could receive an ATP with 100% of his or her time in a Cessna 172.

NADA:

“ Making a relatively small safety investment before an incident occurs, with the intent of providing the highest level of training, or the pilots with the most experience, skills and knowledge, is clearly the more responsible approach

.
The Statistical Value of a Human Life (SVL) has increased to $5.8 million (from $2.7 million), and, in certain conditions, can go even higher.”

PCI: PCI does not agree that one can assign a financial val ue to a human life. Financial considerations have no bearing on the importance of safety in our hearts and minds. Human life does. PCI members put safety as the first priority in all our actions. Having sa id this, it is important to put into prospective that among PCI members are airline executives, universit y educators (including some accredited by AABI) and organizations such as NAFI. PCI members put safety ahead of all financial considerations.

NADA: “There is also an issue of a corporate culture, and its detrimental effect to the aviation industry when the traveling public learns of $17,000 to $19,000 pay per year for Part 121 FO’s, and learns that they did not have sufficient training or experience in icing or other bad weather situations.

The American People and Traveling Public want expe rienced pilots in the cockpit, and we believe that higher pay will attract more experienced pilots.

The Part 121 carriers could provide the needed flight hours to gain that 1,500 flight hours of experience, and they could raise their starting pay to $40,000, or better yet, $60,000+ a year. They would have their choice of thousands of experienced and trained pilots with thousands of hours, who are retired military, and/or formerly with larger airlines, overseas experien ce, or a combination of flight hours and training.

No one has discussed the psycholog ical factors that could impact someone’s performance on the job, when a young pilot is burdened with low pay, student loans, fatigue, and pressure to possibly work two or more jobs. Many young pilots from the 4-year academic programs have student loans, and a $100,000 student loan is about $1,000 a month for 30 years to pay back. Young pilots take the $19,000 a year pilot job and may work second jobs just to pay their student loan and rent/food. This pathet ic pay puts FO new hire pilots in a terrible personal situation, which is not conducive for the focus and energy needed to be a commercial airline pilot.

FOQ ARC Report September 28, 2010 665.0 Minority Opinions

FOQ ARC Report September 28, 2010 67 Experienced pilots cannot afford to work for $19,000 and probably know it is not safe to be a commercial airline pilot while forced to work two or more jobs.”

PCI: PCI finds this statement subjective, out of scope, and unbalanced. PCI agrees that as agreed between senior pilots and the company, the junior F/O pay is unattractive. PCI strongly believes the discussion, while important, has no place in the scope of the FO Q ARC and would prefer not to see a seat on the ARC to be used to further an agenda not specifically within the boundaries of the scope of the ARC.

Respectfully Submitted: John A. O’Brien PCI john@jaobrienaviation.com5.0 Minority Opinions

FOQ ARC Report September 28, 2010 68 R EGIONAL A IRLINE A SSOCIATION

REGIONAL AIRLINE ASSOCIATION (RAA) DISSENT

REGARDING CERTAIN MINORITY OPINION STATEMENTS IN THE

FIRST OFFICER QUALIFICATIONS AVIATION RULEMAKING COMMITTE REPORT

Introduction

The Regional Airline Association 1 (RAA) is honored to have been provided the opportunity to participate in the recent deliberations of the First Officer Qualification Aviation Rulemaking Committee (FOQ ARC). The questions placed before the FOQ ARC are important issues requiring resolution both to better ensure airline safety and to provide the traveling public with assurance of that safety. With one minor exception as noted in Section 5.1 of the First Officer Qualification Aviation Rulemaking Committee Report (Report), the RAA fully supports the Majority positions offered in the Report that was submitted to the FAA Associate Administrator for Aviation Safety on Friday, September 10 th

.

It is therefore unfortunate that the RAA finds it necessary to submit this RAA Dissent in response to portions of the Dissent Statements made by two FOQ ARC members, the Coalition of Airline Pilots Associations (CAPA) and the National Air Disa ster Alliance/Foundation (NADA/F), and presented in Section 5.1 of the Report. There are simply too ma ny misstatements and unsu pported inferences in these two Dissent Statements with regard to the implica tions/mandates of the “Airline Safety and Federal Aviation Administration Extension Act of 2010 (H.R. 5900)”, the FOQ ARC’s adherence or nonadherence to its charter in light of H.R. 5 900, and the deliberations and resulting Majority recommendations of the FOQ ARC, to let them go unchallenged.

The FOQ ARC’s Charter and H.R. 5900

In their separate Dissent Statements, both CAPA and NADA/F essentially make the argument that President Obama’s August 1, 2010 signing of H.R 59 00 (Public Law 111-216) mandated the answers to a number of the questions directed to the FOQ ARC under its July 10, 2010 Charter (see Report Appendix C), and that the FOQ ARC Majority (Majority) chose to ignore those mandated answers in the Majority
recommendations. Based on the dissenters’ reading of H.R. 5900, both groups rejected the Majority

1 Regional Airline Association members are: Aerolitoral, Air Wisconsin Airlines Corporation, AirNet Systems, American Eagle Airlines, Atlantic Southeast Airlines, Cape Air, Chautauqua Airlines, Colgan Air, Comair, CommutAir, Empire Airlines, Era Aviation, ExpressJet, Fl ight Options LLC, Go-Jet, Grand Canyon Airlines, Great Lakes Aviation, Gulfstream International Airlines, Horizon Air, Hawaiian Island Air, Jazz Air, Mesaba Aviation, New England Airlines, Pinnacle Airlin es, PSA Airlines, Piedmont Airlines , Republic Airlines, Shuttle America, SkyWest Airlines, and Trans States Airlines.5.0 Minority Opinions

recommended minimum flight hour experience requirement and the Majority recommendation for creation of an aeronautical experience credit system designed for use in conjunction with that minimum flight hour experience requirement. NADA/F also suggested that the Majority failed in its legal responsibility as an ARC in making its Majority recommendations in these two areas.

Clearly, having H.R. 5900 signed into law midway through the FOQ ARC deliberations raised a number of questions with regard to its potential im pact on the FOQ ARC Charter Tasking and on the recommendations that would remain within the FOQ A RC’s purview to make. Upon first learning of the passage of H.R. 5900, the FOQ ARC Committee Chair immediately discussed these questions with the FOQ ARC Designated Federal Official and further with FAA legal staff. Following a review of the H.R. 5900 language, it was determined that H.R. 5900 pl aced no limits on the FOQ ARC’s deliberations and recommendations, allowing the process to continue.

Among other considerations underlying th is determination were the following:

• The ongoing efforts of the FOQ ARC with rega rd to Knowledge and Skill Competencies (see Report Section 3) were an a ppropriate initial step toward ultimately meeting the H.R. 5900 Section 217(a) directive that “The Administrator of the Federa l Aviation Administration shall conduct a rule-making proceeding to amend part 61 of title 14, Code of Federal regulations, to modify requirements for the issuance of an airline transport pilot certificate.”

• The ongoing efforts of the FOQ ARC with regard to an Academic Credit System (see Report Section 2) were an appropriate initial step in the development of an academic training valuation system to ultimately validate the Administrator’ s authority under H.R. 5900 section 217(d) to “... allow specific academic training courses ... to be credited toward the total flight hours required ... based on a determination ... [that this] will enhance safety more than requiring the pilot to fully comply with the flight hours requirement.”

It has long been accepted that effective rule-making requires pooling the collected expertise and involvement of many industry subject matter experts in the rule-making process and, as chartered, the FOQ ARC was a readymade forum for collecting and considerin g input – studies, practices, public opinion, etc. and recommendations that would su pport the processes directed by H.R. 5900.

The FOQ ARC’s activities and recommendations are consis tent with Administrator Babbitt’s direction, both as initially presented in the July 10, 2010 documen t that established the FOQ ARC and latterly after review of the implication of passage of the Airline Safety and Federal Aviation Administration Extension Act. The Majority recommendations of the FOQ ARC are fully consistent with and appropriate to the language in H.R. 5900.

The Majority Recommended Academic Credit System

In their Dissent Statements, both CAPA and NADA/F reject offering credit for academic training courses that are determined by the Administrator to enhan ce the knowledge and skill of a prospective airline pilot toward meeting ATP “total time as a pilot” requirement s, this despite clear language in H.R. 5900 section 217(d) authorizing such a concept. The two Minority Dissent Statements label the Majority’s recommendations for providing such credits as a “s cheme” when, in fact, these are data-driven recommendations based both on the most current hiri ng and training studies available and on significant

FOQ ARC Report September 28, 2010 695.0 Minority Opinions

learned input and weeks of deliberations within the FOQ ARC. NADA/F goes so far as to make the rather interesting argument that the language in H.R. 5900 providing the Administrator with authority to establish such a credit system is somehow a “m inority provision” in that law that “does not [emphasis in the original] represent the actual intent of Congress.” The RAA is not familiar with any aspect of U.S. law that makes the words voted on by both houses of Congress and signed into law by the President to be anything less than a law that means what its words say.

As fully presented in section 2.7 of the Report, th e Majority applied significant professional experience and science in developing the Majority recommende d “Aeronautical Experience Credit System” (not “scheme”). In reaching its recommendation, the FOQ ARC considered earlier Advanced Notice of Proposed Rulemaking (ANPRM) comments, available studies on training and training program successes and failures, and the considerable expertise and experience of the FOQ ARC members, all of which input fueled lengthy and rigorous discussion during the ma ny small group and plenar y sessions held between July 19 and September 7. The diversity of the gro up and the way that its deliberations were managed assured that no single perspective would prevail without first having been tested by the full group and that all thoughts and concerns would be shared and addressed to ultimately reach a consensus position. This strengthened the Majority’s Aeronautical Experien ce Credit System recommendation and led to it being supported by seven of the nine FOQ ARC members. W ith all due respect to the objections raised in the two minority member Dissent Statements, in group discussions those members offered no alternative to the academic crediting system developed collaborativ ely and painstakingly by the remaining FOQ ARC representatives representing the flight universities, f light academies, general aviation, business aviation, major and regional airlines, and the largest participating pilot safety organization.

Validity of the Majority Recommended ATP SIC Certificate

In its Dissent Statement, CAPA improperly represents the Majority recommendation requiring all pilots serving as a first officer (second-in-command) in FA R part 121 airline operations to hold an ATP SIC certificate. CAPA variously presents the ATP SIC certificate as having been “established for the purpose of bypassing flight experience requirements necessary to qualify for an ATP”, “allow[ing] a lesser degree of training or preparedness which is not the purpose of this ARC, the FAA or the intent of Congress”, and as not being “in the spirit of the law”. None of these statements are true.

As the title clearly indicates, the FOQ ARC was charte red to consider the qualifications necessary for a pilot to serve as a first officer (second-in-command) in FAR part 121 airline operations. Very early in the FOQ ARC’s deliberations, there w as extensive discussion of the name that should be given to the certification that would attest to a pilot having met the qualifications that the FOQ ARC would be recommending. Ultimately, it was determined that the FAA would have to make a final determination in that regard, but it was still necessary for the FOQ ARC to put a “placeholder name” to that certification if for no other reason than to provide a degree of clarity within the Report.

ATP SIC was chosen as the placeholder name for its being descriptive of that which the FOQ ARC was chartered to present – a set of qualification standard s necessary for service as a first officer (second-incommand) in FAR part 121 air carrier operations. The ATP half of the name was a given, since much of the discussion was reasonably centered on existing FAR part 61 ATP requirements. The SIC half of the name was also reasonable since that is the cockpit seat that the FOQ ARC was chartered to review.

FOQ ARC Report September 28, 2010 705.0 Minority Opinions

The FOQ ARC deliberations regarding qualifications to be associated with an ATP SIC certification did not arise from an attempt to “allow a lesser degree of training”, as CAPA alleges – rather the deliberations began with acceptance of the current ATP requirement under FAR part 61.159(a) for “1,500 hours total time as a pilot” and then proceeded with in-depth and sometimes heated discussions of the appropriate credits that might be awarded towards this requireme nt for various levels of academic accomplishment and aviation experience. Both the starting point of 1,500 hours and the Majority recommended academic credits are consistent with the directions and the au thority granted to the Administrator by H.R. 5900.

A not surprising ancillary outcome of the FOQ ARC discussions with regard to ATP SIC qualification standards was recognition that the FOQ ARC’s ATP SIC recommendations had implications for current FAR part 61.159 ATP qualification standards. In a real sense, the Majority recommendations for first officer qualification standards in many areas exceed current ATP requirements, another reason for coining the term ATP SIC as a placeholder name for presentati on of the Majority recommendation to the FAA.

It is important to note that there are a number of important steps between the FOQ ARC presenting its recommendations and the FAA enacting a rule reflecti ng all, some or none of those recommendations. That rulemaking process will involve the issuance of proposed new first officer qualifications rules followed by careful FAA review of the FOQ ARC re commendations in light of comments received in response to those rules. This process will provide ample opportunity for the FAA to consider and determine if the academic credit values assigned in the Re port need to be adjusted or if additional credited academic programs might appropriately be added. It will be up to the FAA to make such determinations before enacting a final rule. But, importantly from the perspective of the FOQ ARC and its meeting the responsibilities assigned to it under its charter, the Report presents recommendations to the FAA that have largely withstood the test of industry subject matter expert involvement and scrutiny.

Majority Recommendation Regarding Minimum Flight Hour Experience – A Part of an Important Whole

The Majority recommendation regarding the minimum f light experience necessary to hold an ATP SIC is stated as follows in the answer to Questi on B presented in Section 1.2 of the Report:

“First officers will have 1,500 hours of flight time or of combined flight time and aeronautical experience credit as defined in the recommendations.”

This recommendation sets the current ATP “1,500 hours of total time as a pilot” standard from FAR part 61.159 as the starting point for ATP SIC certification, but makes allowance for aeronautical experience credits in accordance with the Majority recommended Academic Credit System detailed in Section 2 of the Report. Separately, as detailed in Section 2.7 of the Report, the Majority further recommends setting an absolute floor of 500 actual hours of total flight tim e for award of ATP SIC certification. As shown in the ATP SIC Qualification Pathway examples presen ted in Appendix F of the Report, the minimum number of actual hours of total flight time required for ATP SIC certification will range between 1,500 and 500 hours, depe nding on the manner in which an individual pilot elects to accomplish the necessary training and experience.

Only those individuals who invest in a high quality aviation college education will be able to achieve ATP SIC certification with 500 actual hours of total flight time. Candidates choosing a less intense academic and training experience for achieving the ne cessary qualifications for ATP SIC certification will

FOQ ARC Report September 28, 2010 715.0 Minority Opinions

require a greater number, and in some cases a very much greater number, of actual hours of total flight time before being qualified for award of an ATC SIC. In all cases, no matter what the number of hours flown, ATP SIC certification will not be awarded w ithout the candidate first passing a rigorous written and practical test administered against FAA-established test standards and further meeting the FAA standards set for obtaining an Aircraft Type Rating in the aircraft that the individual will be operating in FAR part 121 service.

In their Dissent Statements, both CAPA and NADA/F focus on the part of the Majority recommendation that sets an absolute floor of 500 actual hours of total flight time for award of an ATP SIC certification, giving little recognition to the other integral parts of the Majority’s recommended standards for ATP SIC certification. Neither do they mention the strength of the Majority recommendations in totality compared to current minimum requirements for serving as a first officer in FAR part 121 air carrier operations, which requirement is only to hold a commercial pilot license that can be awarded to pilots having as few as 250 of total flight time.

The Majority recommendations for a new ATP SIC cer tification standard multiply the current actual hour requirement from two to six times, depending on the qua lity of the learning pathway taken. The Majority recommendations further add aeronautical knowledge a nd skills requirements that exceed current ATP requirements and include FAA testing to confirm pilot compliance. Further still, the Majority recommendations include the requirement for an Aircraft Type Rating in the aircraft that will be operated, which entails passing a further FAA-administered practical test. Taken together, these Majority recommendations represent a significant strengthening of the standards currently required for FAR part 121 first officers. Were it not for the recomme nded enhanced aeronautical knowledge and skill requirement, and the recommended Aircraft Type Rating requirement, and the two recommended FAA test requirements, the RAA might well have found itself in agreement with the CAPA and NADA/F Dissent Statements regarding the adequacy as a minimu m requirement of an absolute floor of 500 actual hours of total flight time. But given the totality of the Majority recommendations and the training, learning and testing environment that they create, RAA is confident that an absolute floor of 500 actual hours of total flight time for award of ATP SIC certifica tion is appropriate to the highest level of airline safety.

Experience as an Effective Approach to Training

In their Dissent Statements, both CAPA and NADA/F emphasize the importance of experience in actual aircraft operations to the making of a qualified and professional airline pilo t, leading to their joint support for 1,500 actual flight hours as the minimum certification standard for FAR part 121 airline pilots. The RAA agrees that experience in the air provides an impor tant learning benefit, but experience also can be acquired through a solid academic educ ation and scenario-based training in modern simulators and flight training devices. The most serious problem with a heavy training dependence on experience in the air is that experience comes along in its own time and at its own pace and there are far from guarantees that the conditions required to gain particular required pieces of experience will present themselves and be learned in a regularly reproducible schedule or fashion. It is also very hard in an experience-based training environment to ensure standardization of the lessons being taught and of the learning that results, as well as to ensure training program safety.

FOQ ARC Report September 28, 2010 725.0 Minority Opinions

That is why the Majority recommendations placed so much emphasis on academic aviation learning programs and on new aeronautical knowledge and sk ills requirements and additional FAA testing and quality assurance oversight as core parts of ensuring that FAR part 121 pilots are qualified for their jobs. Advances in the science of simulators and flight training devices now make possible scenario-based training that realistically simulates most of the f light experiences necessary for training an FAR part 121 airline pilot. This training can be readily sta ndardized, repeated, critiqued and evolved under programs such as Advanced Qualification Progr am (AQP) training. Simulators are effective and provide absolute safety in scenario-based training of flight into icing conditions and stall onset and recovery. High level simulators are also effective in upset recovery tr aining and in training for any number of the more difficult operating condition regimes potentially encountered by FAR part 121 airline pilots. The RAA supports actual experience in aircraft operations as an important teacher, but believes that it should not be depended upon as the primary teacher of all that an FAR part 121 airline pilot needs to know. The RAA therefore fully supports the Majority recommendations regarding first officer qualification standards as providing a proper mix of the experience and academic/tr aining approaches that will best ensure safety.

The Importance of Factual Support for Positions Taken by the FOQ ARC

Throughout the many weeks of meetings, deliberations, analysis and report and recommendation writing, the members of the FOQ ARC stayed focused on the facts and issues brought before them. When there were questions that needed to be answered befo re forward progress could be made, FOQ ARC members were directed by the Chairman to find those answer s and provide the necessary factual backup to support the questioned positions before returning to the flow of the discussions. While it was not always possible to find in-depth scientific answers to the issues that were raised or the questions that needed to be answered, that did not prevent the members of the FOQ ARC from finding whatever was available and sharing that information to support the strongest and most unified possible response to the questions presented to the FOQ ARC in its Charter tasking.

In this light, it is disappointing to find statemen ts in a Dissent Statement such as those below that mischaracterize the deliberations of the FOQ ARC and the manner in which its recommendations, both Majority and Minority, were reached:

“But this trend suggests that pilots from structured flight training programs have ability to communicate and network with graduates of their alma mater, who are familiar with the regional airline interview and training processes, rather than a clear demonstration that they are safer pilots.”

“It is clear from the sub-working group effort that the FOQ ARC Majority wa s committed to holding the line at 500 actual flight hours. ”

“Deciding on the 500 flight hours was a first step of th e majority working group, and then they structured the academic program credits to obtain certain AABI structured schools to fall out favorably”

From the RAA’s vantage point and perspective on th e deliberations and decision-making processes of the FOQ ARC, none of the above is true. The professiona l aviation and public advo cacy group participants on the FOQ ARC worked mightily and openly to come up with the best possible answers to the serious questions that they were charged with answering in the limited time that they were given to develop those answers. In the end, it is less surprising that several differences of opinion/dissents arose from this

FOQ ARC Report September 28, 2010 735.0 Minority Opinions

FOQ ARC Report September 28, 2010 74 intensive effort than it is that there was so much agreement on so many of the recommendations presented in the FOQ ARC Report.

Respectfully Submitted,

Captain Darrin Greubel

RAA FOQ ARC Representative

## APPENDIX A—FIRST OFFICER QUALIFICATIONS AVIATION RULEMAKING COMMITTEE MEMBERS AND SUPPORT STAFF

FOQ ARC M EMBERS Scott Foose, Regional Ai rline Association (RAA), Committee Chair Greg Kirkland, Federal Avia tion Administration (FAA), Designated Federal Official (DFO) Dr. Tim Brady, Aviation Accredita tion Board International (AABI) Steve Brown, National Business Aviation Association (NBAA) John Cane, National Air Disaster Alliance/Foundation (NADA/F) Doug Carr, NBAA J.J. Greenway, Aircraft Owners a nd Pilots Association (AOPA) Darrin Greubel, RAA Kristine Hartzell, Aircraft Owners and Pilots Association Chuck Hogeman, Air Line Pilots As sociation, International (ALPA) Gary Kiteley, AABI Bill Lange, RAA Russ Leighton, The Coalition of Airl ine Pilots Associations (CAPA) Gary Morrison, Pilot Car eer Initiative (PCI) Leja Noe, ALPA John O’Brien, PCI Paul Railsback, Air Transport Asso ciation of America, Inc. (ATA) Jeff Skiles, CAPA David Ward, ATA Matt Ziemkiewicz, NADA/F

S UPPORT S TAFF Barbara Adams, FAA Kelly Akhund, PAI Consulting David Binswanger, PAI Consulting Robert Burke, FAA Catherine Burnett, FAA Emily Dziedzic, PAI Consulting

FOQ ARC Report September 28, 2010 75Appendix A—FOQ ARC Members and Support Staff

FOQ ARC Report September 28, 2010 76 Ryan Gibson, PAI Consulting Keith Hagy, ALPA Scott Harper, PAI Consulting Katie Lewek, PAI Consulting Robin Meredith, PAI Consulting Wendy Stanley, PAI Consulting

## APPENDIX B—DEFINITIONS

Ab initio —Ab initio means “from the beginning.” In the United States, the term refers to the training of professional pilots who have litt le or no flight experi ence upon entry into a flight training program. The training of a professional pilo t usually includes earning the private pilot, instrument pilot, and the co mmercial pilot certificates and ratings. Ab initio training may be conducted at a college or university, fixed-base operator, pilot training academy, or the military.

In Europe, ab initio training is conducted under the authority of the European Aviation Safety Agency, for pilots destined to the air carrier p ilot position. It is constr ucted as an integrated course where the student gets a commercial pilot’s license, instrument rating, multiengine rating, multicrew cooperation training and the passage of all theore tical tests for the European Aviation Safety Agency airline transport pilot’s license before completing the course. The ab initio course s are intended for selected full

- time students.

The multicrew pilot license as defined by the International Civil Aviation Organization is an approved ab initio method for pilot entry into ai r carrier first officer service. This method may be considered by the Administrator.

Accreditation —In the United States, accreditation is a system for recognizing educational programs that meet a defined set of standards. Accreditation is voluntary and is granted by private organizations.

There are two types of accreditation sought by most institutions of higher education: regional accreditation and specialized accreditation. Regional acc reditation accredits entire institutions. There are six regional accreditation associations in geographic regions around the country. A university in California, for example, would seek accreditation from the Western Association of Schools and Colleges.

Specialized accrediting accredits specific prog rams within institutions, provided that institution has received regional accreditati on. For example, aviation programs are accredited by the Aviation Accreditation Board International (AABI), business programs are accredited by the Association to Advance Colle giate Schools of Business, and engineering programs are accredited by th e Accreditation Board for Engineering Technology. The process by which an institution gains specialized accreditation involves: (1) applying to the appropriate accrediting agency for the progr am accreditation is being sought; (2) conducting and submitting a self-assessment of the program; (3) submitting to visitation by a team of peers; and (4) receiving final judgment on the accreditation application by the accrediting association’s board of directors. The process ta kes 2 to 3 years and is repeated periodically. For example, the AABI accred itation cycle is 5 years.

Regional and specialized accrediting agencies in the United States are recognized by the Council on Higher Education Accred itation. It has a 2-year pro cess to determine eligibility and evaluate the procedures and pr ocesses of each accrediting agency.

FOQ ARC Report September 28, 2010 77Appendix B—Definitions

There are other types of agencies that accredit non-university inst itutions of learning, such as vocational schools, training institutes, career schools, and training academies. These accrediting agencies accredit entire institutio ns rather than specific programs. The Accrediting Commission of Career Schools and Colleges is typical of these.

Academic Training —Academic training refers to classroom instruction, flight-training device and/or simulator training, a nd flight instruction for whic h credits may be allowed by H.R. 5900. This definition also includes speci fic credit for those f light experiences the FOQ ARC has determined to be of the highest quality and complexity and that provide the greatest value in a pilot’s prepar ation for part 121 operations (see tables 1 and 2 of this report for more information about these flight experiences).

Advanced Jet Training (AJT) —An advanced jet training course is designed to give instruction in air carrier flightcrew operations in a multiengine aircraft, emphasizing the transition of the professionally qualified pilo t to a highly skilled member of an air carrier flight management team. Course topics in clude crew resource management, flightcrew training techniques, high speed and high altitude programming of automatic flight control systems, transport aircraft flight techniques, tu rbojet operations in all flight regimes and in difficult operating conditions, and use of adva nced avionics. AJ T courses should be approved by the FAA to ensure a stru ctured quality training experience.

Pilots who attend an AJT course need to posse ss a minimum of a commercial pilot certificate with multiengine and instrument ratings. AJT course graduates may or may not receive a type rating for the aircraft type used in their training, depending on the program and the simulator or training device used by that program . An AJT course must employ a level 5 or greater flight training device for students to rece ive the aeronautical experience credit offered in table 1.

Aeronautical Experience —Aeronautical experience is the co mbination of flight time and time spent in a flight simulator or flight-traini ng device to meet the appropriate training and flight time requirements for an airman certif icate, rating, flight review, or recency of flight experience requirement.

Aeronautical Experience Credit —Credit earned through the successful completion of approved academic training courses and certain categories of flight experience that can be applied toward the total flight hours required for certi fication as a part 121 first officer. Section 217 of H.R. 5900 provides authority for the Administrator to approve such credits based on a determination that “allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement.”

ATP SIC Certificate —The task of the FOQ ARC was to recommend to the FAA the minimum qualification level for an indivi dual to serve as an SIC pilo t in part 121 operations. In reviewing current training, qua lification, and certificati on regulations, the FOQ ARC recognized a new license, rating, endorsement, or restriction would have to be established to distinguish between the current licenses, ratings, and endorsement s and the result of the new SIC minimum qualification level. The FOQ AR C did not feel comfor table in identifying which method (license, rating, endorsement, or re striction) would be most appropriate and

FOQ ARC Report September 28, 2010 78Appendix B—Definitions

decided to refer to this new license, rating, endorsement, or restriction as an ATP SIC certificate as a placeholder. It is a certification that entitles the pilot to act as an SIC in part 121 operations.

First Officer Gap Program —The First Officer Gap Program is a set of academic modules designed to impart to commercial pilots the knowledge and skills required to become a part 121 first officer. Each candidate for the fi rst officer qualification must complete all of the modules and successfully complete an FAA-administered FOQ written exam.

Flight Academy —A flight training organi zation that provides the training and education necessary to obtain private and commercial pilot certificates with airplane single-engine land, airplane multiengine land, and instrument ratings, as well as flight instructor certificates with airplane single- and multiengine land ratings and instrument ratings. While training is normally accomplished under part 141 or part 142, it may also be accomplished under part 61. In all cases, less ons at a flight academy are conducted under a syllabus and the conduct of training is monitored and continuously evaluated by the organization. Students at a flight academy are completely immersed in a full-time program. Training accomplished within a flight academy is considered structured training.

Flight Time —Flight time refers to time logged in an ai rcraft in accordance with 14 CFR part 1. Any reference to flight time in this document means “flight hours” as described in H.R. 5900.

Flight Training Device —At the time this document was cr eated (September 10, 2010), a flight training device means a replica of aircraft instru ments, equipment, panels, and controls in an open flight deck area or an en closed aircraft cockpit replica. It includes the equipment and computer programs necessary to represent aircra ft (or a set of aircra ft) operations in ground and flight conditions having the full range of capabilities of the systems installed in the device as described in 14 CFR part 60 and th e qualification performance standard for a specific flight training de vice qualifica tion level.

Nonstructured Training —Nonstructured training is flight training, typically at a fixed-base operator or by an independent instructor, that is led by an instructor and proceeds at the student’s pace. It may not involve supplemental background academic courses, such those as found in colleges, universities, and flight academies. It also ma y not follow a set curriculum
or structure.

Structured Training —Structured training is composed of courses designed to integrate classroom, self-study, practical/laboratory, f light training devices or simulators, and flight training experiences to optimize the pilot’s acquisition of the patterns, knowledge, skills, attitudes, and competencies needed to meet the standards required for FAA and industry certificates, ratings, and endorsements.

FOQ ARC Report September 28, 2010 79Appendix B—Definitions

FOQ ARC Report September 28, 2010 80 Transfer of Training— The concept of transfer of training is derived from learning theory. Researchers have shown that learning and skill acquisiti on can be transferred from one setting to another similar setting, such as from an aircraft simula tion device to the actual aircraft (Gerathewohl, Mohler, & Siegel, 1969). Positive transfer means the skill learned in the simulation device transfers to the aircraft . Negative transfer means the skill did not transfer from the simulation device and the pilo t must then acquire the correct skill in the actual aircraft.

## APPENDIX C—FOQ ARC TASKING

U.S. DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION

Effective Date: July 16, 2010

SUBJ: First Officer Qualifications Aviation Rulemaking Committee

1. PURPOSE. This document establishes the First Offi cer Qualifications 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. On February 8, 2010, the Federal Aviation Ad ministration (FAA) issued the New Pilot Certification Requirements for Air Carrier Operations Advanced Notice of Proposed Rulemaking (75 FR 6164, Docket No. FAA- 2010-0100; Notice No. 10-02). This ANPRM requested public comment on possible changes to regulations relating to certifying pilots conducting domestic, flag, and supplemental ope rations. The purpose of this ANPRM was to gather information on whether current eligibil ity, training, and qualification requirements for commercial pilot certification are adequate for engaging in such operations. The ANPRM asked questions concerning First Officer certification level, additional training and experience needed to perform as a First Officer , if specific ground training can substitute for flight experience, and the need for additiona l carrier specific trai ning. As of April 29, 2010, we received 8,227 comments from 1,299 commenters.

b. To carry out the FAA’s safety mandate, the FAA is chartering an ARC that will develop recommendations regarding rulemaking on flight experience and training requirements prior to operating as a First Officer in a Part 121 air carrier operation.

3. OBJECTIVES AND SCOPE OF THE COMMITTEE . The First Officer Qualifications ARC will provide a forum for the U.S. aviation community to discuss flight experience and training requirements to fly as a First Officer in a part 121 air carri er operation. The ARC will also evaluate the comments received in re sponse to the ANPRM. Specifically, the ARC should consider and address:

a. What should be the minimum certificati on level required of a First Officer?

b. What should be the minimum f light hour experience requiremen ts of a First Officer?

c. Can academic training substitute for hours of experience? If so, what subjects and how much flight experience?

FOQ ARC Report September 28, 2010 81Appendix C—FOQ ARC Tasking

d. Should there be an air carrier endorsement on a commercial pilot certificate? If so, what kind of flight and ground trai ning should be required?

e. Should there be an operational experience requirement (high altitude, icing, etc.) before being permitted to operate as a First Officer?

Within ninety (90) days, the ARC will deve lop recommendations and submit them to the Associate Administrator for Aviation Sa fety for rulemaking consideration.

4. COMMITTEE PROCEDURES.

a. The committee provides advice and recommenda tions to the Associate Administrator for Aviation Safety. The committee acts so lely in an advisory capacity. b. The committee will discuss and present info rmation, guidance, and recommendations that the members of the committee consider rele vant in addressing the objectives.

5. ORGANIZATION, MEMBERSHIP, AND ADMINISTRATION.

a. The FAA will establish a committee representi ng the various parts of the industry and Government.

i. The ARC will consist of no more than 15 individuals.

ii. The FAA will invite selected organizations a nd individuals to participate as a member in the ARC. The ARC will include representatives from the aviation community, including pilot associations, universities, as well as a representative from family members of victims of aviation accidents.

iii. The FAA will identify the number of ARC members that each organization may select to participate. The Associate Admi nistrator for Aviation Safety will then request that each organization name its repr esentative(s). Only the representative for the organization will have authority to speak for the organization or group that he or she represents.

iv. Active participation and commitment by memb ers will be essential for achieving the committee objectives and for continued membership on the ARC.

b. The Associate Administrator for Avia tion Safety will receive the committee recommendations and reports.

c. The Associate Administrator for Aviation Safe ty is the sponsor of the committee and will select an industry chair(s) from the member ship of the committee. Also, the Associate Administrator will select the FAA-designate d representative for the committee. Once appointed, the industry chair(s) will:

(1) Determine, in coordination with the other members of the committee, when a meeting is required.

FOQ ARC Report September 28, 2010 82Appendix C—FOQ ARC Tasking

FOQ ARC Report September 28, 2010 83 (2) Arrange notification to al l committee members of the time and place for each meeting.

(3) Draft an agenda for each meeting and conduct the meeting.

e. A Record of Discussions of committee meetings will be kept. f. Although not required, committee meeting quorum is desirable.

6. PUBLIC PARTICIPATION. The First Officer Qualificatio ns ARC meetings are not open to the public. Persons or organiza tions that are not members of th is committee and are interested in attending a meeting must reque st and receive approval before the meeting from the industry chair(s) or the designated Federal representative.

7. AVAILABILITY OF RECORDS. Under the Freedom of Information Act, 5 U.S.C. § 522, records, reports, agendas, working papers, and other documents that are made available to or prepared for or by the committee will be availa ble for public inspection and copying at the FAA Flight Standards Service, Air Transporta tion Division, AFS-200, 800 Independence Avenue, SW., Washington, DC 20591. Fees will be charged for information furnished to the public according to the fee schedule published in Title 49 of the Code of Federa l Regulations part 7.

8. PUBLIC INTEREST. Forming the First Officer Qualifications ARC is determined to be in the public interest to fulfill the perfor mance of duties imposed on FAA by law.

9. EFFECTIVE DATE AND DURATION. This committee is effective upon issuance. The committee will remain in existence 90 days from July 19, 2010 unless sooner terminated or extended by the Administrator.

J. Randolph Babbitt Administrator

## APPENDIX D—PILOT SOURCE STUDY

FOQ ARC Report September 28, 2010 84Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 85Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 86Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 87Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 88Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 89Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 90Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 91Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 92Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 93Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 94Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 95Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 96Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 97Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 98Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 99Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 100Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 101Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 102Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 103Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 104Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 105Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 106Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 107Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 108Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 109Appendix D—Pilot Source Study

FOQ ARC Report September 28, 2010 110

## APPENDIX E—ASA HIRING AND TRAINING DATA

Table 3—ASA Hiring and Training Data

Hiring Analysis 1/1/2007 to 5/5/2008

Structured Training N onstructured Training

Interviewed 555 502

Median hours 625 855 Rejected by recruiter 48 8.6% 123 24.5% Rejected by simulator 52 9.4% 125 24.9% Rejected by human resources 18 3.2% 31 6.2%

Reviewed or no determination 4 0.7% 21 4.2%

Hired into class 417 75.1% 135 26.9%

Median hours 630 910 Terminated from training 17 4.1% 10 7.4% Required any extra training 200 48.0% 98 72.6% Required extra simulators only 96 23.0% 34 25.2% Required extra IOE only 40 9.6% 13 9.6%

1 extra simulator and <15 IOE 70 16.8% 19 14.1%

2 extra simulators and <15 IOE 44 10.6% 20 14.8%

>2 extra simulators and <15 IOE 25 6.0% 11 8.1%

1 extra simulator and ≥ 15 IOE 8 1.9% 2 1.5%

2 extra simulators and ≥ 15 IOE 4 1.0% 0 0.0%

>2 extra simulators and ≥ 15 IOE 7 1.7% 2 1.5% 1 extra simulator (no extra IOE) 54 12.9% 13 9.6% 2 extra simulators (no extra IOE) 26 6.2% 14 10.4% >2 extra simulators (no extra IOE) 16 3.8% 7 5.2% <15 hours extra IOE (no extra simulators) 30 7.2% 10 7.4%

≥ 15 hours extra IOE (no extra simulators) 10 2.4% 3 2.2%

FOQ ARC Report September 28, 2010 111Appendix E—ASA Hiring and Training Data

FOQ ARC Report September 28, 2010 112

Additional Data

Pilots Successful Pilots Terminated from Training Pilots Not Hired

Median Simulator Score 95 Median Simulator Score 91 Median Simulator Score 74

Median GPA 3.20 Median GPA 3.07 Median GPA 3.00

Median Total Time 676.5 Median Total Time 890 Median Total Time 863

## APPENDIX F—ATP SIC QUALIFICATION PATHWAYS

Figure 3—4-Year Accredited Aviation Program Example

FOQ ARC Report September 28, 2010 113Appendix F—ATP SIC Qualification Pathways

Figure 4—Flight Academy Training Example

FOQ ARC Report September 28, 2010 114Appendix F—ATP SIC Qualification Pathways

Figure 5—Military Training Example (Rotary)

FOQ ARC Report September 28, 2010 115Appendix F—ATP SIC Qualification Pathways

Figure 6—Military Training Example (Fixed-wing)

FOQ ARC Report September 28, 2010 116Appendix F—ATP SIC Qualification Pathways

FOQ ARC Report September 28, 2010 117 Figure 7—Non-structured Training ExampleAppendix F—ATP SIC Qualification Pathways

Figure 7—Non-structured Tr aining Example (Continued)

FOQ ARC Report September 28, 2010 118

## APPENDIX G—EXAMPLE TRAINING OBJECTIVES

These are examples of training objectives that will need to be defined by the Administrator.

E XAMPLE 1
General Meteorology and Principles of Radar

A. Classroom Planned Time: 4:00 Hours (Abbreviated 30 Minutes)

B. Computer Based Training Seat Time: 3:00 Hours

C. Knowledge Objectives:

The pilot candidate will—

1) Accurately interpret aviation routine weather reports.

2) Accurately interpret aerodrome forecast and RAMTAF reports.

3) Describe the air carrier weather packet format and interpret its contents.

4) Identify normal weather patterns common to the air carrier route structure.

5) Identify and describe the various types of airframe icing the aircraft may encounter.

6) Describe the parameters for the possib ility of icing condi tions to exist.

7) Be able to recognize windshear poten tial and describe how to avoid it.

8) Use air traffic control, Automatic Terminal Information Service, flight service station, and weather computer to obtain we ather information during planning.

9) Analyze a weather radar picture and interpret the presentation.

10) Recognize and describe the various cell shapes.

11) Recognize radar shadows and describe methods to avoid them.

12) Calculate TIP, zero tilt, and describe the “parked position.”

13) Describe the function of the weather radar’s GAIN feature.

14) Describe the purpose of the weather radar’s TARGET mode.

FOQ ARC Report September 28, 2010 119Appendix G—Example Training Objectives

E XAMPLE 2

I. Perform Stall Recovery Procedures

A. Phase of Flight: Flight

B. Applicable Duty Position: PIC and SIC

C. Criticality: Yes

D. Currency: No

E. Training Strategy

1) Qualification

2) Continuing Qualification

F. Supporting Proficiency Objectives

1) Participate in Crew Resource Management (CRM) During Stall Recovery Procedures

2) Perform Stall Recovery Procedures

3) Perform Stall Recovery Non Automated Tasks

G. Validation/Evaluation Strategy

1) Maneuver Validation – Level D Full Flight Simulator

H. Conditions

1) IMC

I. Contingencies

1) Takeoff Configuration Stall

2) 20 Degree Bank Angle

3) Landing Configuration Stall

4) Cruise Configuration Stall

5) Low Altitude

6) High Altitude

FOQ ARC Report September 28, 2010 120Appendix G—Example Training Objectives

J. Task Standards

1) Crew initiates stall recovery smoothly and ti mely at the first indication of a stall.

2) Crew returns the aircraft to a normal flight condition exhibiting smooth and positive aircraft control.

II. Participate in CRM durin g Stall Recovery Procedures

A. Performance Elements

1) Retain full responsibility and exercise final authority for the safe operation of the aircraft.

2) Exercise assertiveness with respect.

3) Use communication strategies such as br iefings, clearly communicating decisions, encouraging participation, and s eeking information from others.

4) Use workload management strategies such as distributing tasks, prio ritizing tasks, and managing time.

5) Identify and communicate potential safe ty threats to other crewmembers.

6) Identify and effectively manage errors.

7) Pilot flying (PF) verb alizes action plan.

8) Pilot monitoring (PM) verifies and m onitors critical phases of flight.

9) PM performs secondary tasks only while primary tasks are not occurring.

10) PM backs up the PF, timely identifies and communicates operational errors to the PF and when appropriate, and s uggests appropriate response.

11) During periods of high workload, crewmembers are alert to distraction and effectively prioritize tasks in order of importance and remain focused on the primary tasks.

III. Perform Stall Recovery Non-Automated Tasks

A. Performance Elements

1) The PF will make precise and timely control inputs to maintain the desired pitch attitude.

2) The PF will make precise and timely control inputs to maintain the desired bank angle and heading.

FOQ ARC Report September 28, 2010 121Appendix G—Example Training Objectives

FOQ ARC Report September 28, 2010 122 3) The PF will make precise and timely yaw control inputs to maintain the desired heading/course.

4) The PF will make timely correc tions to aircraft control a nd will respond to deviation calls caused by environmental conditions.

5) The PM will make appropriate deviation cal ls and will expect a response from the PF.

6) The PF will make timely corrections to aircra ft control in response to deviation calls made by the PM.

## APPENDIX H—REFERENCES

Gerathewohl, S. J., Mohler, S. R., & Siegel, P.V. (1969) . Fidelity of simulation and transfer of training: A review of the problem (No. AM 69–24). Federal Aviati on Administration, Office of Aviation Medicine.

Hunt, L. M. (1997). Influences on the learni ng process and learning outcome: Practical implications for the instructor. In G. J. F. Hunt (Ed.), Designing instruction for human factors training in aviation . Aldershot, United Kingdom : Avebury Aviation.

McDade-Morrison, L. (2004). E xperiential learning. In J. S. Stein & S. Farmer (Eds.), Connotative learning; The trainer’ s guide to learning theories and their practical application to training design (pp. 117–128). Dubuque, Iowa: Kendall Publishing.

Wickens, C. D. (1992). Engineering psychology and human performance (2nd ed.), Upper Saddle River, New Jersey: Prentice Hall.

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