THE FIRST OFFICER QUALIFICATIONS 

AVIATION RULEMAKING COMMITTEE REPORT

Recommendations Regarding Rulemaking on Flight Experience, 

Training, and Academic Requirements Prior to Operating as a 

First Officer in Part 121 Air Carrier Operations 

September 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 Airlines 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 Concepts 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 iii
Table 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 ......................................................................................................... 123
FOQ ARC Report September 28, 2010 v

EXECUTIVE SUMMARY 

The Federal Aviation Administration (FAA) Administrator chartered the First Officer 

Qualifications (FOQ) Aviation Rulemaking Committee (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. Congress 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 experts from nine organizations. The FOQ ARC 

members collectively brought to the deliberations significant levels of experience in air carrier 

operations; development, implementation, and management 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 flight 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 ARC 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 effort should be made by the industry and by the 

Administrator to encourage all prospective pilots to attain the higher knowledge and experience 

standards herein recommended by the FOQ ARC. Few would argue with the benefits that come 

from having pilots in air carrier operations who have completed university flight training 

programs, advanced jet training courses, or military flight training programs available today. 

The FOQ ARC therefore recommends that any new and increased qualification standard for 

pilots entering the air carrier industry require a proper balance between experience and 

education. 

The FOQ ARC adopted a safety risk assessment program to identify the enhanced 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 professional pilot position in air carrier operations. 

As a result of the passage of H.R. 5900, and beyond the tasking initially given to the FOQ ARC, 

the Administrator also asked the FOQ ARC to define 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 regard on past recommendations by the National 

Transportation Safety Board defining difficult areas 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 important tool by which to provide flight experience to the pilot for 

recognition and appropriate response 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 Administrator 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 the 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 section 2.0 of this report.  

Two FOQ ARC member organizations filed minority opinions disagreeing with the sufficiency 

of ATP SIC requirements. The FOQ ARC members unanimously agree that a pilot be required 

to have (1) enhanced aeronautical knowledge and flight proficiency skills, (2) an aircraft type 

rating, and (3) experience in multiengine, multipilot, turbine-powered aircraft. Although the 

FOQ ARC has focused on experience and training 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, leadership, mentoring, and 

experience requirements, including part 121 experience as first officer, are incorporated into the 

requirements for a pilot in command in part 121 operations. 
1.0 RECOMMENDATIONS SUMMARY 

This section identifies those questions the Administrator tasked to the First Officer Qualifications 

(FOQ) Aviation Rulemaking Committee (ARC) (see 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 appropriate section for each recommendation. 

1.1 MINIMUM CERTIFICATION

Question A. What should be the minimum certification level required of a first officer? 

The FOQ ARC agrees there must be a new, higher 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 airline transport pilot (ATP) standards. See sections 2.0 and 3.0. 

1.2 MINIMUM FLIGHT HOUR EXPERIENCE

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 recommendations. See sections 2.4 and 2.5. The Coalition of 

Airline Pilots Associations (CAPA) and National Air Disaster Alliance/Foundation (NADA/F) 

dissent from this position; see their minority opinions in section 5.0. 

1.3 FLIGHT TIME AND ACADEMIC CREDIT SYSTEM

Question C1. Can academic training substitute for hours of experience? 

Yes. A credit system is outlined in the recommendations in section 2.5. CAPA and NADA/F 

dissent from this position; see their 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. CAPA and NADA/F dissent from 

this position; see their minority opinions in section 5.0. 

FOQ ARC Report September 28, 2010 1
1.0 Recommendations Summary 

1.4 AIR CARRIER ENDORSEMENT

Question D1. Should there be an air carrier endorsement on a commercial 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 ARC made recommendations for enhanced pilot 

qualifications before acting as a pilot for a part 121 air carrier. See sections 2.0 and 3.0. 

Question D2. If so, what kind of flight and ground training should 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 OPERATIONAL EXPERIENCE

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 aeronautical experience, including in difficult 

operating conditions. The FOQ ARC considered operating experience requirements/flight time 

requirements for difficult operational conditions, and in the interest of safety recommends these 

be conducted in a flight simulation training device using realistic scenario-based training. 

See section 3.4. 

1.6 BACKGROUND CHECK

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 gain a thorough understanding of each applicant’s 

airman training and checking history. The FOQ ARC therefore recommends “notices of 

disapproval” be considered by air carriers before an employment decision. 

1.7 PRE-EMPLOYMENT SCREENING

Question G1. Comprehensive Pre-employment Screening: 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 carriers but decided not to make 

specific recommendations in this area. 

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

See above answer to question G1. 

FOQ ARC Report September 28, 2010 2 
1.0 Recommendations Summary 

FOQ ARC Report September 28, 2010 3 

1.8 MULTIENGINE EXPERIENCE

Question H. To ensure part 121 flight crewmembers have the proper qualifications and 

experience, what type of multiengine flight experience, if any, is appropriate? 

The FOQ ARC recommends a minimum 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 award of a type rating be required 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 DIFFICULT OPERATING EXPERIENCE 

Question I1. Difficult operational conditions: Considering a part 121 operational environment, 

what difficult operating conditions should a pilot experience prior to operating in that 

environment? 

The FOQ ARC defines difficult operating conditions and addresses the required pilot experience 

in section 3.4. In the interest of safety, the FOQ ARC does not recommend an actual flight time 

requirement to acquire proficiency in difficult operating conditions. See section 3.4. 

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

The FOQ ARC defines difficult operating conditions and addresses the required pilot experience 

in section 3.4. In the interest of safety, the FOQ ARC does not recommend an actual flight time 

requirement to acquire proficiency in difficult operating conditions. See section 3.4. 

1.10 AIR CARRIER QUALITY ASSURANCE

The FOQ ARC recommends air carriers provide deidentified feedback to the FAA on 

SIC performance during and after training. See section 2.7. 

1.11 AIR CARRIER ANNUAL REPORTING

The FOQ ARC recommends that air carriers provide an annual report to the FAA showing 

flight hours, education, and qualifications for each first officer hired 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 BACKGROUND

Current regulations (§ 121.437) require a first officer to obtain a commercial pilot certificate in 

the appropriate category and class with an instrument rating to perform duty in part 121 

air carrier operations. Based on the regulatory aeronautical experience requirements for 

obtaining a commercial pilot certificate, it is possible a first officer 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 experience. It is also possible for a first officer candidate to 

gain the majority of this flight time in a single-engine, single-pilot, piston-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, turbine-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 meeting 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 completed the 1,500 flight hours required to obtain an ATP certificate. 

All flight hours do not impart the same level of aeronautical experience. Preparation for 

part 121 operations requires quality experience 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, multiengine aircraft, multipilot operations, air carrier 

operations and procedures, high-altitude flight conditions, and the operation of digital flight 

systems. These and other subject areas are not covered in the training that typically leads to the 

award of a commercial pilot certificate. There has been longstanding debate on the extent to 

which academic education and advanced training techniques can provide an effective substitute 

for actual flight hours and in-cockpit 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 training programs has benefitted from the latest scientific studies 

about the human learning process. Understanding this learning process necessitates an 

understanding of two types of memory, long-term memory and working memory. The learning 

process occurs in working memory, which is the “workbench” where information is dissected 

and reassembled until it can be encoded in long-term memory (Wickens, 1992). In order to learn 

a new concept, the working memory taps into recognized patterns from long-term memory 

(Hunt, 1997). If patterns are easily recognized, it takes less time to learn 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 4
2.0 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 environments impedes an effective transfer of 

training. Well-structured training programs that feature integrated academics and 

flight experience optimize the learning process 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 training, the FOQ ARC members developed a regulatory 

construct for part 121 first officer qualifications. It recognizes the quality of each potential 

component of an individual’s education and previous experience. This construct, presented and 

further discussed below, credits both total flight hour experience and specific academic training 

courses that collectively provide a positive transfer of knowledge and capabilities in the training 

of a part 121 first officer. As such, it is consistent 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 accordance with this construct, successful 

accumulation of 1,500 hours of actual flight time and aeronautical experience credit will begin to 

provide a first officer candidate with the knowledge and flight experience necessary for 

certification as a part 121 first officer. To further ensure each first officer candidate trained 

under such a program maintains a proper balance 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 certification, regardless of the number 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 PILOT SOURCE STUDY 

In the spring of 2010, six participating colleges/universities and six regional air carriers jointly 

studied the backgrounds of the most successful first officer applicants 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 various training backgrounds performed in initial 

air carrier training. These backgrounds included 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 hired within a 5-year period (2005–2009). 

                                                           

2

 The number of military pilots captured in this 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 through an online data collection instrument 

designed by five study researchers, all of whom teach 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 carrier personnel, volunteer 

graduate students, interns, and college professors. The research team leader received the 

resulting six data collection instruments, deidentified them, and combined the data into a 

single spreadsheet. The research team leader sent this spreadsheet and the 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 the FAA Administrator in response to the advance 

notice of proposed rulemaking (Docket Number FAA–2010–0100; Notice Number 10–02). The 

research team also submitted its study to the International Journal of Applied Aviation Studies, a 

peer-reviewed publication supported by an international panel of consulting editors. The study 

was accepted for publication in the summer 2010 issue of the International 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 success3

 in initial first officer training shared three attributes: (1) they were 

graduates of college accredited flight degree programs, (2) they had experience as certified flight 

instructors, and (3) they had accrued between 500 and 1,000 flight hours. 

2.3 ATLANTIC SOUTHEAST AIRLINES TRAINING SUCCESS STUDY

Atlantic Southeast Airlines (ASA), a regional air carrier operating over 160 Canadair Regional 

jet aircraft and employing 1,600 pilots, performed an independent, in-depth study of over 

1,000 applicant hiring and training records from January 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) and training process based on each 

applicant’s training background (either structured or nonstructured). This study suggests pilots 

who received structured training performed better throughout the interview process and had 

greater success in the training phase. They required the least amount of additional training to 

successfully achieve the training program requirements. 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 maximum of 6,590 total flight hours. 

                                                           

3

 The two examined outcomes were (1) extra training events 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 trainees with a high rate of success is one 

with statistically fewer repeated training events and statistically fewer training incompletes than the pilot group as a 

whole (see appendix B to this report).
2.0 Academic Credit System 

2.4 RECOMMENDED FIRST OFFICER QUALIFICATIONS

The FOQ ARC was tasked to recommend to the FAA the minimum qualification level for an 

individual to serve as an SIC 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 requirements outlined in part 61, 

subpart G. 

The FOQ ARC therefore recommends qualification 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 minority opinions in section 5.0. 

2.5 RECOMMENDED FIRST OFFICER QUALIFICATION STANDARDS

METHOD ONE

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 having “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 training (AJT) program or have demonstrated equivalent 

aeronautical knowledge and flight proficiency in multipilot, turbine-powered aircraft 

before acting in revenue service. 

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

METHOD TWO

Hold an appropriate type rating (see section 2.6) and an ATP SIC, which requires 1,500 hours 

“total time as a pilot.” This includes flight time and aeronautical experience credits. In addition, 

the first officer must— 

• Be at least 21 years of age. 

• Hold at least a second class medical certificate. 

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

• Have passed a practical and knowledge test (as 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 7 
2.0 Academic Credit System 

o 50 actual hours of night time, 

o 50 hours of simulator or actual instrument time, of which 25 hours must be 

actual flight time, and 

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

 75 actual hours of cross-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 instruction under § 61.167(b). 

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

2.6 AIRCRAFT TYPE RATING REQUIREMENT 

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 upon completion of the next initial, transition, or 

upgrade air carrier training program. (The type rating flight evaluation may be conducted from 

either cockpit seat except for those tasks that are “seat specific” as determined by the FAA 

Aircraft Evaluation Group.) 

2.7 AERONAUTICAL EXPERIENCE CREDIT SYSTEM

There are many possible paths by which an individual may obtain the combination of 

aeronautical knowledge and flight experience necessary to earn an ATP SIC. While much public 

discussion has focused on raw flight hour numbers as the basis for 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 practical training programs and flight experience. 

The legislation wisely allows for a thoughtfully constructed credit system 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 the basis for earning an ATP SIC. Section 217 of 

H.R. 5900 provides the authority necessary for the FAA to authorize the aeronautical experience 

credit system recommended by the FOQ ARC. 

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

ACADEMIC AND PRACTICAL TRAINING PROGRAM VALUATION

The left column in the top half of table 1 (above 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 flight experience. The 

most credits are assigned to training achieved through completion of an accredited flight training 

program at a 4-year aviation university or college. Fewer, but appropriate credits are assigned to 

less-structured training programs. 

FOQ ARC Report September 28, 2010 8 
2.0 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 credit 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 the 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 equivalent aeronautical experience 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 identify specific aeronautical experience 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 any 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/College Accredited Flight Training 

Program 

350 

4-year Aviation University/College Flight Training Program 200 

2-year Aviation College Accredited Flight Program 150 

2-year Aviation College Flight 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” Flight Training Program 750 

Military “Rotary Wing” Flight Training Program 500 

Initial certified flight instructor certificate4 100 

Each additional certified flight instructor ratings3 50 

Military Instructor Pilot 200 

AJT Course not resulting in a type rating 200 

AJT Course resulting in a type rating 250 
2.0 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 highly competitive and all applicants 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 training programs share many of the same qualities of fixed-wing 

flight training programs. However, 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 time 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 programs 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 initio5

 training programs that may be developed in the future. 

QUALITY OF FLIGHT HOURS

The FOQ ARC agrees there are varying degrees of quality flight hours by which 

flight experience is acquired. Flight hours performed as a flight instructor, on-demand operator, 

corporate pilot, or in 14 CFR part 91 multiengine 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 multipilot, 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 “difficult operational conditions” (such as icing, high altitude, poor 

weather, difficult airport, and air traffic control (ATC) environments). 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 experience the FOQ ARC has determined are the highest 

quality and complexity, and that provide the greatest value in preparation for part 121 operations. 

The aeronautical experience credit system recommends awarding aeronautical credits on a 

one-for-one basis for actual flight 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 QUALITY ASSURANCE AND OVERSIGHT

The FOQ ARC believes the enhanced provisions in the recommendations 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 supporting broad public confidence in the national air 

transportation system. The FOQ ARC has provided its recommendations based on the following 

three items: 

1. The most comprehensive and current training research available, 

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

3. The broadest and most representative expert opinion available on aviation safety and 

performance. 

The three recommendations reflect 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 for continuous feedback on all pilots attaining a 

restricted ATP certificate. In addition, oversight should be conducted through a division of the 

FAA. The FOQ ARC recommends that the Flight Standards Service, Air Transportation 

Division, Voluntary Safety Programs Branch (AFS–230) conduct this oversight. 

FOQ ARC Report September 28, 2010 11 
2.0 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 training. During training, feedback should include 

the total number of simulator events over-planned, written test scores (testing must not be 

corrected), results of initial checkrides and any subsequent retraining/rechecking events, and the 

total number of initial operating experience(IOE) hours, or termination in any phase of training. 

After the completion of training, feedback should include performance evaluations during 

line operations and continuing (recurrent) qualifications. To support the feedback after training 

is completed, the FOQ ARC recommends the FAA create a standardized evaluation tool for 

part 121 pilots in command to provide periodic comment on an ATP SIC’s performance and 

knowledge during line operations. All knowledge tests should be administered and monitored by 

the FAA. Also, the FAA should explore how to protect the questions and answers from 

public disclosure. 
3.0 KNOWLEDGE AND SKILL COMPETENCIES 

3.1 SUPPORTING EQUIVALENT CONCEPTS AND IMPROVED STANDARDS

FOREWORD

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 document refers to operations conducted under 

part 121. 

2. First officers entering into part 121 services must meet the aeronautical 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 curriculum and hours should also be defined by 

the Administrator, to include but not be limited to the knowledge and flight proficiency 

areas described in the next section. Appendix 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 evaluation. These three categories may be further 

subdivided into phases, with each phase identifying a specific output. Feedback loops are 

a critical element of any model, and are used to confirm assumptions or make 

adjustments when errors or omissions are discovered.

SATISFACTORY PERFORMANCE

“Exhibits knowledge” means the applicant 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 satisfactory proficiency and competency within 

approved standards. 

2. Demonstrating mastery of the aircraft with 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 and 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 proficiency 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 13
3.0 Knowledge and Skill Competencies

UNSATISFACTORY PERFORMANCE

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 evaluator’s question or other 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 scanning techniques, when applicable, to clear 

the area before and while performing flight maneuvers. 

INSTRUCTION AND EVALUATION

1. Criteria for instructors and evaluators that administer the training and evaluation of 

part 121-specific topics should be reviewed or established as necessary. 

2. Instructors and evaluators should be required to demonstrate proficiency 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 Aviation Organization Next Generation Aviation 

Professionals and the International Air Transport Association Training and Qualification 

Initiatives concerning the establishment of instructor and evaluator criteria for 

air carriers. 

3.2 AERONAUTICAL KNOWLEDGE AREAS

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 experience. 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 receiving a satisfactory grade on a knowledge test that 

is developed in accordance with § 61.35 and administered by the FAA. 

ADVANCED AIRCRAFT SYSTEMS AND PERFORMANCE

A. Exhibits satisfactory knowledge of jet transport aerodynamics. 

B. Exhibits satisfactory knowledge of specific aircraft flight characteristics. 

C. Exhibits satisfactory knowledge of turbine engine theory. 

D. Exhibits satisfactory knowledge of jet transport engine monitoring systems, such as the 

engine indication and crew alerting system. 

FOQ ARC Report September 28, 2010 14 
3.0 Knowledge and Skill Competencies

E. Exhibits satisfactory knowledge of flight operations 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 carrier 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. 

NAVIGATION IN AIR CARRIER OPERATIONS

A. Exhibits satisfactory knowledge of high altitude airspace. 

B. Exhibits satisfactory knowledge of navigation systems for practical use in all phases of 

flight incorporating relative and coordinate-based 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 transport flight management systems (FMS). 

G. Exhibits satisfactory knowledge in the selection and application of all available levels of 

automation (including hand flying), and the actions necessary to readily transition 

between levels of automation. 

H. Exhibits satisfactory knowledge of flight guidance systems used in air carrier operations. 

I. Exhibits satisfactory knowledge of air carrier route planning techniques and tools. 

FOQ ARC Report September 28, 2010 15 
3.0 Knowledge and Skill Competencies

AIR CARRIER OPERATIONS AND SAFETY AND SECURITY

A. Exhibits satisfactory knowledge of part 121 Certification and Operations: Domestic, 

Flag, and Supplemental Air Carriers and Commercial Operators of large aircraft. Also, 

exhibits satisfactory knowledge of aviation security concepts, including— 

1. Transportation Security Administration requirements, 

2. Airport security requirements, and 

3. Ground/in-flight security roles and responsibilities. 

B. Exhibits satisfactory knowledge of the Department 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 effects of fatigue on performance, including 

mitigation strategies. 

F. Exhibits satisfactory practical knowledge of airport surface operations, 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 16 
3.0 Knowledge and Skill Competencies

H. Exhibits satisfactory knowledge of air carrier maintenance procedures appropriate to 

flight operations, including— 

1. Maintenance release procedures, 

2. Use of the master minimum equipment list (MEL)/configuration deviation list (CDL) 

in developing an air carrier MEL/CDL, and 

3. Use of the MEL/CDL. 

AIR CARRIER WEATHER PLANNING

A. Exhibits satisfactory knowledge of high altitude weather characteristics. 

B. Exhibits satisfactory knowledge of high altitude weather and weather 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 carrier low-visibility operations, including— 

1. Low-visibility surface movement and 

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

COMMUNICATIONS

A. Exhibits satisfactory knowledge of air carrier communication requirements and systems, 

including— 

1. Voice communication and 

2. Advanced communications such as data link. 

B. Exhibits satisfactory knowledge of ATC communication 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 17 
3.0 Knowledge and Skill Competencies

STALL AND UPSET RECOGNITION AND RECOVERY

A. Exhibits satisfactory knowledge of in-flight 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. 

AIR CARRIER PILOT PROFESSIONALISM

A. Exhibits satisfactory knowledge of a pilot’s professional responsibility and ethics, to 

include communications, risk management, decisionmaking, and leadership. 

B. Exhibits satisfactory knowledge of aviation safety 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 customer service to include passenger 

communications, affairs, and regulations. 

3.3 FLIGHT PROFICIENCY

Listed in this section are the flight proficiency areas proposed to be required for training pilots to 

operate as SIC in part 121 air carrier operations, but have no part 121 experience. In addition, 

before acting as a pilot in part 121 air carrier service, 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.

GENERAL SUBJECT AREAS

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 air carrier standard operating procedures. 

C. Demonstrates the ability to lead multipilot 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 18 
3.0 Knowledge and Skill Competencies

3. Normal procedures, 

4. Non-normal procedures, 

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

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

7. Deferred maintenance items. 

D. Demonstrates the ability to use cockpit 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 apply performance, W&B, and navigation data 

in an operational environment. 

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

G. Demonstrates proficiency in the use of all available levels of automation (including 

hand flying), and the actions necessary to readily 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 ATC instructions in high-density airport 

operations. 

FOQ ARC Report September 28, 2010 19 
3.0 Knowledge and Skill Competencies

PREFLIGHT AND TAXI AREAS

A. Demonstrates the ability to determine compliance 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 use 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 aircraft after receiving complex taxi instructions 

from ATC. 

E. Demonstrates the ability to taxi the aircraft using appropriate aircraft configuration for 

adverse weather conditions (for example, ground icing conditions or high winds). 

F. Demonstrates the ability to taxi the aircraft using appropriate configuration for 

fuel economy. 

G. Demonstrates the ability to taxi the aircraft using surface movement guidance and 

control systems. 

TAKEOFF

A. Demonstrates the ability to perform low visibility takeoffs using air carrier takeoff 

minimums. 

B. Demonstrates the ability to apply appropriate precautions for adverse weather during 

takeoff (for example, windshear). 

C. Demonstrates proficient use of automation during departure. 

D. Demonstrates the ability to fly the aircraft during complex departure procedures and 

noise abatement procedures. 

EN ROUTE

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

1. During Reduced Vertical Separation Minimum operations and 

2. To perform FMS route modifications. 

FOQ ARC Report September 28, 2010 20 
3.0 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. 

STALL AND UPSET RECOGNITION AND RECOVERY

A. Demonstrates the ability to apply appropriate upset recovery techniques in mitigating 

in-flight loss of control during realistic scenario-based training events such as takeoffs, 

en route, approach, and landing as the result of phenomena. Such phenomena include— 

1. Stalls, 

2. Wake turbulence, 

3. Flight instrumentation failure, and 

4. Flight control failure. 

ARRIVAL: HIGH ALTITUDE TOP OF DESCENT TO INITIAL APPROACH FIX

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 verify appropriate descent point. 

D. Demonstrates satisfactory use of aircraft energy management to comply with 

area navigation arrivals/published approaches in both vertical and lateral components. 

ARRIVAL: INITIAL APPROACH FIX TO STABILIZED APPROACH

A. Demonstrates the ability to apply appropriate techniques for conducting 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 aircraft during CAT II and CAT III approaches. 

ARRIVAL: STABILIZED APPROACH TO LANDING ROLLOUT OR MISSED APPROACH/GO-AROUND

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

B. Demonstrates the ability to use appropriate windshear precautions for approach and 

landing. 

FOQ ARC Report September 28, 2010 21 
3.0 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. 

ARRIVAL: MISSED APPROACH/GO-AROUND AREAS

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

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

3.4 AERONAUTICAL EXPERIENCE

DIFFICULT OPERATIONAL CONDITIONS

Pilots must receive aeronautical knowledge and flight proficiency training in “difficult 

operational conditions” that may be encountered during air carrier operations. For the purpose of 

the FOQ ARC, “difficult operational conditions” include— 

1. Areas of convective activity6

 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 device using realistic scenario-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 listed below to be difficult operational conditions, 

but encourages pilots to gain proficiency by acquiring actual flight time experience in these 

conditions, although no minimum flight time requirement should necessarily be specified. 

1. High pilot workload operations such as— 

a. Operations during periods of high traffic volume at primary airports located within 

Class B airspace. 

b. Operations within Special Air Traffic Rules Airspace described in 14 CFR part 93, 

and 

c. Takeoffs, landings, and instrument approaches 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 report on the air carrier’s first officer annual pay 

and benefits. 

Air carriers have the option to provide additional information about enhanced training programs, 

and additional information that demonstrates a continuous improvement process such as a 

mentoring program or other safety/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 MINORITY OPINIONS SUBMITTED AT THE CONCLUSION OF THE FOQ ARC 

COALITION OF AIRLINE PILOTS ASSOCIATIONS

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 25
5.0 Minority Opinions 

Introduction 

The First Officer Qualifications Aviation Rulemaking Committee (FOQ-ARC) has done an 

excellent job of reviewing, defining and recommending changes to the educational and training 

requirements for prospective airline 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 Transport Pilot certificate (ATP) through a “flight time 

credit system”. CAPA also dissents to the creation of an ATP “SIC – only” restriction or any 

other scheme involving new pilot certifications or licenses that are established for the purpose of 

bypassing the flight experience requirements necessary 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 experience: structured or un-structured training 

designed for successful completion of a flight-check, does not create the judgment and 

decision-making ability to operate 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. 

CAPA answers to FAA’s ARC Questions: 

a. What should be the minimum certification 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 flight crew members operating under Part 121. A 

competent professional pilot should hold the certificate commensurate with the responsibilities 

of the position. 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. 

In addition to the experience and aeronautical knowledge requirements 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. Accordingly, 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 requirements of a First Officer? 

CAPA believes that all the requirements of the Airline Transport Pilots license (ATP) must be 

met by a prospective Part 121 First Officer and that individual hold an ATP 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 26 
5.0 Minority Opinions 

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

CAPA believes that academic training is a necessary and vital component to the education of a 

prospective Part 121 First Officer, but academic training cannot substitute for hours of 

experience as outlined in the dissenting view. 

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

Academic training cannot substitute 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 license 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 additional flight and ground training recommended by this ARC. The 

enhanced flight and ground training should be incorporated into the Airline Transport Pilot 

certificate requirements. 

e. Should there be an operational experience requirement (high altitude, icing, etc.) before 

being permitted to operate 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 flight 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 prospective airline pilot to experience the hazardous 

flight conditions listed in this question. While one certainly would not be able to guarantee actual 

flight in these conditions, the chances are greatly enhanced as the pilot works towards the 

aeronautical flight experience 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-controlled flight and recovery techniques. 

• Exposure to high-altitude hypoxia in an altitude chamber should 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 the requirements and qualifications necessary to 

pilot a modern airliner in today’s environment. 

FOQ ARC Report September 28, 2010 27 
5.0 Minority Opinions 

CAPA believes that there are 2 necessary components to the training and maturation of a safe 

and capable airline pilot. First, they must have the education and training applicable to their role 

on the flight deck of an airliner. Second, they must have a requisite level of experience to operate 

in real-world Part 121 operations. 

The academic requirements suggested by the FOQ-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 towards the ATP certificate, he/she is developing and 

honing airmanship skills while providing exposure to the challenges of flight in difficult 

conditions. Flying aircraft of any 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 certificate 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) used to train experienced pilots throughout the 

major airlines. 

The structured learning process, discussed by the ARC at length, is excellent for providing 

knowledge and practice for a specific challenge; for example, a stall 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 outcomes are known. 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 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 credits” 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 result, allowing “1,000 hours of credit” 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 experience 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 “flight time credit scheme” goes beyond 

what HR 5900 permits, and certainly beyond the laws intention. The ARC majority interpreted 

the term “academic training” in HR 5900 (Section 217) to include “flight training.” CAPA 

believes this to be in direct violation of HR 5900. 

2010 Pilot Source Study Data: While CAPA recognizes that modern pilot training programs 

have benefited from the latest scientific studies regarding the human learning process, CAPA’s 

FOQ ARC Report September 28, 2010 28 
5.0 Minority Opinions 

Safety and Training Committee experts contend 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 successful or not only reveals how students respond in a training 

environment and does not validate a pilot’s readiness 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. 

Flight Crew Concept: The role of Captain and First Officer in regional and major airline 

cockpits has changed dramatically. In today’s airline environment, Captains do not fly airliners, 

‘flight crews’ fly airliners. 

Cockpit Resource Management (CRM) programs were first introduced in the 1980’s and 

established a flight crew concept where the Captain no longer dictates the level of First Officer 

involvement in the operation of the aircraft. The First Officer is now an integral part of the flight 

crew with specific duties, responsibilities, and FAA accountability. He or she is encouraged and 

expected to challenge the thinking and decisions 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 their duties to comply 

with SOPs. The dual responsibilities inherent in our modern safety culture mandate that 

entry-level pilots perform at a level 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 airports as was the case when current qualification 

regulations were written. Currently, new-hire pilots are immediately 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 saturated airspace and high traffic 

density airports. 

ATP Enhancements 

CAPA’s Training and Safety Committees believe that the aeronautical experience and 

knowledge requirements of the FAA Airline Transport Pilot certificate need to be updated to 

reflect the realities of modern 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 Part 121 operations as there are no single 

engine Part 121 operators. Turbine time is essential 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 time, (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. Although procedures can be practiced in the 

FOQ ARC Report September 28, 2010 29 
5.0 Minority Opinions 

simulator, there is no substitute for experiencing low-visibility takeoff’s, approaches, 

landings, weather, and diversion issues in an actual aircraft. 

Basic ATP Flight Experience Requirements 

The underlying experience requirements of the Airline Transport Pilot Certificate 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, MORAs and/or grid obstruction altitudes, operations on and off 

airways, ATC and AIM procedural experience. 

• 100 hours of night flight time: ATP applicants gain experience in night flight and 

ground operations, airport lighting, visual acuity along with differences in spatial 

orientation, night landings and take offs, night weather avoidance 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 portion 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 specific 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 and 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 only practiced and enhanced with exposure in aircraft. 

Procedural Background 

Four of the last five fatal airline accidents have involved regional carriers, who in many cases 

hire less experienced pilots, as opposed to major airlines. In July of 2009, the US House of 

Representatives Transportation and Infrastructure 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 hearings 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 Certification Requirements for Air Carrier Operations” and received 1,299 

comments from all interested parties, groups and organizations. 

FOQ ARC Report September 28, 2010 30 
5.0 Minority Opinions 

Congress recently passed legislation that requires all pilots in Part 121 cockpits to possess an 

Airline Transport Pilot certificate (ATP), with a three year implementation window. The 

legislation also permits the FAA Administrator the discretion to allow credit towards the flight 

experience requirements of the ATP for certain coursework exceeding that required for the ATP 

certificate. Accordingly, the FAA has most recently 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 experience to meet their safety standards. The 

professional status of an airline 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 many 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 industry’s dynamics has altered the demographics of the pilot hiring 

pool, causing the experience levels of new hire pilots operating transport category aircraft to 

diminish substantially. Where, at one time, flying airline transport aircraft with passengers on 

board was a prestigious position in the industry, it is now an entry-level position and FAA 

minimum licensing requirements are being 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 Certificate 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 service. The First Officer Qualifications ARC has 

recommended a type rating and educational enhancements 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 the major airline with the best safety record also 

has the highest standards for pilot qualifications. Southwest Airlines, which has never had a 

passenger fatality in its over 38 years of existence, requires their new hire 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 which that pilot will fly when 

employed by Southwest Airlines. 

FOQ ARC Report September 28, 2010 31 
5.0 Minority Opinions 

CAPA therefore is resolute in our stance that any part 121 pilot should possess the FAA Airline 

Transport Pilot (ATP) certificate and that the training and experience requirements of the ATP 

certificate be enhanced as stated above. In addition, Part 121 flight crew members need to be 

type-rated in the aircraft they fly prior to acting as a line flying crew member. 

Congress had the wisdom to pass sweeping airline safety legislation including a mandate to 

increase flight crew experience levels and for each flight crew member to possess the ATP 

certificate. CAPA firmly believes it was their intent to maintain 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 safe efficient air travel with qualified, trained, 

and experienced flight crew professionals at the controls. It is the 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 Transport Pilots certificate with the requisite 

experience requirements, and training. 

Figure 1—Comparison of Current Requirements vs. Recommendations 

FOQ ARC Report September 28, 2010 32 
5.0 Minority Opinions 

NATIONAL AIR DISASTER ALLIANCE/FOUNDATION

2020 Pennsylvania Ave NW #315 – Washington DC 20006 

(888) 444 – 6232 –phone (336) 643 – 1394 – fax 

September 6, 2010 

www.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 address 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 FAA, who have worked very hard and professionally. 

Thank you also to Ryan Gibson, Wendy Stanley, and others 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 Transport Pilot (ATP) certificate is the 

minimum level of certification for First Officer (FO) 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 NATIONAL AIR DISASTER ALLIANCE/FOUNDATION 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 proposing 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 aviation 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 heavily on 1,000 hours of academics intended to serve as a 

substitute for actual flight experience. We do not support fulfillment of the ATP certification requirement 

with only 500 hours of actual flight time. 

FOQ ARC Report September 28, 2010 33 
5.0 Minority Opinions 

We do agree that a solid educational 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 comply with the flight hours requirement.” 

We believe academic training in lieu of flight hours 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 than “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 demonstrate that pilots trained in “structured flight 

programs” require less retraining events during their regional 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 airline 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 that pilots from structured flight training programs 

have the 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. 

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 hours 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 International (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 program credits to enable certain AABI structured schools to fall out favorably. 

Interestingly, the median for hiring Part 121 First 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. Therefore, 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 corporate responsibility and potential liability? 

FOQ ARC Report September 28, 2010 34 
5.0 Minority Opinions 

High pilot turn-over rates between the regional and the major 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 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. 

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 aircraft deputy commander during all phases of flight. 

Having a lesser trained SIC is counterproductive as the potential to be exposed to challenges alone is 

increased. Should the SIC need to exercise command of the aircraft; 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 level required of a First Officer (FO) ? 

NADA/F answer: 

The FO shall have an ATP with 1,500 actual flight hours 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 fulfill 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 shall be the ATP and 1,500 hours, as required by 

H.R.5900, not a commercial pilot certificate with only 250 hours. Early in the FOQ ARC the majority 

FOQ ARC Report September 28, 2010 35 
5.0 Minority Opinions 

focused on commercial pilot, 250 hours, however, the 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 training, 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 recommendations 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 Qualifications 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 are 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 Rulemaking 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, corporate attorneys, and more. Two Comair 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 the 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 36 
5.0 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 icing or other bad weather situations. 

The American People and Traveling Public want experienced 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 experience, or a combination of flight hours and training. 

No one has discussed the psychological 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 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 background different from flight 

school. In the military if you fail a proficiency test you are usually out of the flight program. Unlike nonmilitary flight training programs they cannot transfer to another flight school and try again and again until 

they pass. The competition is high to qualify for military 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 rides, 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 knowledge, 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 provisions of PRIA in H.R.5900 with a special acknowledgement to the 

CO3407 family members who worked hard to pass the 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 37 
5.0 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 most 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 carriers subject to the provision of H.R.5900 provide an 

Annual Filing to the FAA showing flight hours, education, 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 the airline’s First Officer annual salary and benefits. 

Airlines have the option to provide additional information about enhanced training programs, and provide 

additional information that demonstrates a continuous improvement process such as a mentoring 

program, or other safety/security initiatives. 

Request the Annual FOQ report be filed to the FAA 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 38 
5.0 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 education, 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 39 
5.0 Minority Opinions 

NATIONAL BUSINESS AVIATION ASSOCIATION

NBAA DISSENTING POSITION ON PAY AND BENEFITS FOR ANNUAL REPORT 

 

NBAA supports the recommendation of an annual report from Part 121 air carriers that documents certain 

qualifications of newly hired first officers. This information 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 contribute 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 determining 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 offered by the Regional Airline Association and recommends 

that the report not include data related to pay and benefits. 

FOQ ARC Report September 28, 2010 40 
5.0 Minority Opinions 

FOQ ARC Report September 28, 2010 41 

REGIONAL AIRLINE ASSOCIATION

RAA DISSENTING OPINION ON PAY AND BENEFITS FOR ANNUAL REPORT

The Regional Airline Association (RAA) fully supports the First Officer Qualification Aviation 

Rulemaking Committee’s recommendation that air carriers 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 RAA 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 publically report this sensitive information. 

• Airmen pay and benefits are collectively bargained under Railway Labor Act (RLA) rules 

residing outside the FAA Administrator’s authority. 

• Airmen pay and benefits are determined in the context 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 between 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 321

 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 have more than 3200 hours. Our veteran management 

teams, training professionals and pilot cadres understand that good training improves safety. Our pilots, 

both new pilots and senior pilots, are trained and routinely tested to the FAA’s Air Transport Pilot (ATP) 

standards – the agency’s highest standard of flying skill. 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 forefront 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 Association members are: Aerolitoral, Air Canada Jazz, 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, Flight Options LLC, Go-Jet, Grand Canyon 

Airlines, Great Lakes Aviation, Gulfstream International Airlines, Horizon Air, Hawaiian Island Air, Mesaba 

Aviation, New England Airlines, Pinnacle 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 inspectors 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 opposes the inclusion of pay and benefits inclusion as a 

part of the report.   

FOQ ARC Report September 28, 2010 42 
5.0 Minority Opinions 

FOQ ARC Report September 28, 2010 43 

5.2 MINORITY OPINIONS SUBMITTED AFTER THE REPORT IS COMPLETED

AIRCRAFT OWNERS AND PILOTS ASSOCIATION

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 certificates 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 benefit of such courses, we must disagree on the amount 

of credit recommended for the “structured” training paths 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 instruction. 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 competencies that must be met are exactly the same. 

Although there is definite benefit of additional academic courses taken in aviation, AOPA believes that a 

350 hour split between pilots who received training through a university 4 year degree program and those 

that earned their certificates through a part 61 school (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 hour 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 academic 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 STATEMENTS IN SUPPORT OF THE FOQ ARC REPORT

AVIATION ACCREDITATION BOARD INTERNATIONAL

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PILOT CAREER INITIATIVE

Pilot Career Initiative

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 regulatory 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 did, and two dissenting members of the FOQ ARC including the 

dissenting member pertinent to this document continues to call for higher number of flight hours 

even though there is no evidence that any of the previous accidents 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 following 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 operate 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 57
5.0 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 statement. The ARC’s proposal more than doubles the minimum flight 

time currently required and adds 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 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.”

PCI 

PCI disagrees with this statement on several levels. First, it runs counter to everything PCI 

believes in to put the personal safety of passengers or crew in jeopardy in order to provide 

“exposure” to pilots. Airline flying is perhaps the most structured, process and procedure-driven 

environment currently utilized in industry. Pilots spend countless hours in flight training devices 

learning how to deal with abnormalities and emergencies. Even the most “unpredictable”, such 

as loss of power all power is practiced from the earliest days of training. It is the opinion of PCI 

that once immersed in a simulator of proper quality, 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 pilot’s mindset to fail, whether in a training device 

or real airplane or when ones “personal safety” may be at risk.. PCI advocates manning our 

nation’s airliners with well trained pilots, not “survivors”. 

FOQ ARC Report September 28, 2010 58 
5.0 Minority Opinions 

CAPA 

“CAPA also contends that the “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 pertinent part, “The Administrator may allow specific 

academic training courses, beyond those required by subsection (b) (2), to be credited toward the 

total flight hours required under subsection (c). 

One can’t use “intention” in an argument without documented clarification. This is especially 

true when this presumed “intention” could easily have been written into the law. PCI argues that 

the law’s silence on this issue would be an indication that congress had no more specific intent 

except to allow the Administrator make this determination. 

CAPA 

“CAPA’s Safety and Training Committee experts contend 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 successful or not only reveals how students respond in 

a training environment and does not validate a pilot’s readiness 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 supporting 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, distinguished leaders of higher 

education in the field of aviation, and flight instructors disagree with CAPA’s statement. 

CAPA 

“Cockpit Resource Management (CRM) programs were first introduced in the 1980’s and 

established a flight crew concept where the Captain no longer dictates the level of First Officer 

involvement in the operation of the aircraft. The First Officer is now an integral part of the flight 

crew with specific duties, responsibilities, and FAA accountability.” 

FOQ ARC Report September 28, 2010 59 
5.0 Minority Opinions 

PCI 

PCI agrees that the concept of CRM was formalized almost thirty years ago. As mentioned 

previously, modern structured primary training programs incorporate 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 Pilot certificate need to be updated to 

reflect the realities of modern 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 Part 121 operations as there are no single 

engine Part 121 operators. Turbine time is essential 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 time, (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. Although procedures can be practiced in the 

simulator, there is no substitute for experiencing low-visibility takeoff’s, approaches, 

landings, weather, and diversion issues 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 60 
5.0 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 collective experience that experiential learning is limited to just vull 

motion and visual simulator systems. 

CAPA 

“Four of the last five fatal airline accidents have 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 meant to infer that the accidents 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 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 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 legislated. 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 because 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 61 
5.0 Minority Opinions 

CAPA 

“Recent tragic events have shown the need to revisit the training and experience level 

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 62 
5.0 Minority Opinions 

Pilot Career Initiative

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 regulatory 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 did, and two dissenting members of the FOQ ARC including the 

dissenting member pertinent to this document continues to call for higher number of flight hours 

even though there is no evidence that any of the previous accidents 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 the FAA Re-authorization Bill, “Airline 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 (FO) 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 evidenced by paragraph 217, it was not the “intent” to 

require 1,500 hours of “actual” flight time. Further more, the use for the word “intent” is 

presumptuous unless one is speaking of their own intent. 

FOQ ARC Report September 28, 2010 63 
5.0 Minority Opinions 

NADA: 

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 heavily on 1,000 hours of academics intended to serve as a 

substitute for actual flight experience. We do not support fulfillment of the ATP 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 also believe that since such knowledge and 

competencies exceed those currently required for the 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 intent while paragraph 217 clearly illustrates the intent of 

congress as it relates to the issue 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 any statistical evidence to demonstrate “specific 

academic training courses” enhance safety more than “requiring 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 success rate than others. 

NADA/F ignores the data presented as well as ignoring the facts related to experience of pilots in recent 

accidents. 

FOQ ARC Report September 28, 2010 64 
5.0 Minority Opinions 

NADA: 

“It is not by coincidence that a pilot who completes an Aviation Accreditation Board International (AABI) 

flight school will graduate with approximately 500 flight hours.” 

PCI:

PCI agrees with this statement – it is not a coincidence. Data presented indicates those pilots have a 

higher success rate at the airline level. Also, a significant number of AABI-accredited program graduates 

complete their education with a number of hours far less 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 structured 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 previous 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 current 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 corporate 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 view 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 65 
5.0 Minority Opinions 

PCI: 

PCI is concerned with the use of the word “shall” because 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 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.” 

PCI:

NADA’s statement is not a valid statement because under the current requirements 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 value 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 said this, it is important to put into prospective that 

among PCI members are airline executives, university 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 experienced 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 experience, or a combination of flight hours and training. 

No one has discussed the psychological 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 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. 

FOQ ARC Report September 28, 2010 66 
5.0 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 FOQ 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.com 

 
5.0 Minority Opinions

FOQ ARC Report September 28, 2010 68

REGIONAL AIRLINE ASSOCIATION

REGIONAL AIRLINE ASSOCIATION (RAA) DISSENT 

REGARDING CERTAIN MINORITY OPINION STATEMENTS IN THE

FIRST OFFICER QUALIFICATIONS AVIATION RULEMAKING COMMITTE 

REPORT

Introduction

The Regional Airline Association1

 (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 10th. 

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 Disaster Alliance/Foundation (NADA/F), and presented in 

Section 5.1 of the Report. There are simply too many misstatements and unsupported inferences in these 

two Dissent Statements with regard to the implications/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. 5900, 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 5900 (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, Flight 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 Airlines, 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 impact on the FOQ ARC Charter Tasking and on the 

recommendations that would remain within the FOQ ARC’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 placed no limits on the FOQ ARC’s deliberations and 

recommendations, allowing the process to continue. 

Among other considerations underlying this determination were the following: 

• The ongoing efforts of the FOQ ARC with regard to Knowledge and Skill Competencies (see 

Report Section 3) were an appropriate initial step toward ultimately meeting the H.R. 5900 

Section 217(a) directive that “The Administrator of the Federal 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 considering input – studies, practices, public 

opinion, etc. and recommendations that would support the processes directed by H.R. 5900. 

The FOQ ARC’s activities and recommendations are consistent with Administrator Babbitt’s direction, 

both as initially presented in the July 10, 2010 document 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 enhance the knowledge and skill of a prospective airline pilot 

toward meeting ATP “total time as a pilot” requirements, 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 “scheme” when, in fact, these are data-driven 

recommendations based both on the most current hiring and training studies available and on significant 

FOQ ARC Report September 28, 2010 69 
5.0 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 “minority 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, the Majority applied significant professional experience 

and science in developing the Majority recommended “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 many small group and plenary sessions held between 

July 19 and September 7. The diversity of the group 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 Experience Credit System recommendation and led to it being 

supported by seven of the nine FOQ ARC members. With 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 collaboratively and painstakingly by the remaining FOQ ARC 

representatives representing the flight universities, flight 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 FAR 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 chartered 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 was 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 standards 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. 

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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 requirement 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 authority 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 presentation 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 reflecting 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 recommendations 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 Report 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 flight experience necessary to hold an ATP SIC is 

stated as follows in the answer to Question 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 time for award of ATP SIC certification. As shown in 

the ATP SIC Qualification Pathway examples presented 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, depending 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 necessary qualifications for ATP SIC certification will 

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5.0 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 without 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 certification standard multiply the current actual hour 

requirement from two to six times, depending on the quality of the learning pathway taken. The Majority 

recommendations further add aeronautical knowledge and 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 recommended 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 minimum 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 certification 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 pilot, 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 important learning benefit, but experience also can be 

acquired through a solid academic education 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. 

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That is why the Majority recommendations placed so much emphasis on academic aviation learning 

programs and on new aeronautical knowledge and skills 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 flight experiences necessary for training an FAR part 121 

airline pilot. This training can be readily standardized, repeated, critiqued and evolved under programs 

such as Advanced Qualification Program (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 training 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/training 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 before forward progress could be made, FOQ ARC members 

were directed by the Chairman to find those answers 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 statements 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 was committed to holding the 

line at 500 actual flight hours. ” 

“Deciding on the 500 flight hours was a first step of the 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 the deliberations and decision-making processes of the 

FOQ ARC, none of the above is true. The professional aviation and public advocacy 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 

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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 MEMBERS

Scott Foose, Regional Airline Association (RAA), Committee Chair

Greg Kirkland, Federal Aviation Administration (FAA), Designated Federal Official (DFO) 

Dr. Tim Brady, Aviation Accreditation 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 and Pilots Association (AOPA) 

Darrin Greubel, RAA 

Kristine Hartzell, Aircraft Owners and Pilots Association 

Chuck Hogeman, Air Line Pilots Association, International (ALPA) 

Gary Kiteley, AABI 

Bill Lange, RAA 

Russ Leighton, The Coalition of Airline Pilots Associations (CAPA) 

Gary Morrison, Pilot Career Initiative (PCI) 

Leja Noe, ALPA 

John O’Brien, PCI 

Paul Railsback, Air Transport Association of America, Inc. (ATA) 

Jeff Skiles, CAPA 

David Ward, ATA 

Matt Ziemkiewicz, NADA/F 

SUPPORT STAFF

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 75
Appendix 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 little or no flight experience upon entry into a 

flight training program. The training of a professional pilot usually includes earning the 

private pilot, instrument pilot, and the commercial 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 pilot position. It is constructed 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 theoretical tests for the 

European Aviation Safety Agency airline transport pilot’s license before completing the 

course. The ab initio courses 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 air 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 accreditation 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 programs within institutions, provided that 

institution has received regional accreditation. For example, aviation programs are 

accredited by the Aviation Accreditation Board International (AABI), business programs are 

accredited by the Association to Advance Collegiate Schools of Business, and engineering 

programs are accredited by the Accreditation Board for Engineering Technology. The 

process by which an institution gains specialized accreditation involves: (1) applying to the 

appropriate accrediting agency for the program 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 takes 2 to 3 years and is repeated periodically. 

For example, the AABI accreditation cycle is 5 years. 

Regional and specialized accrediting agencies in the United States are recognized by the 

Council on Higher Education Accreditation. It has a 2-year process to determine eligibility 

and evaluate the procedures and processes of each accrediting agency. 

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

There are other types of agencies that accredit non-university institutions of learning, such as 

vocational schools, training institutes, career schools, and training academies. These 

accrediting agencies accredit entire institutions 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, and flight instruction for which credits may be allowed by 

H.R. 5900. This definition also includes specific credit for those flight experiences the 

FOQ ARC has determined to be of the highest quality and complexity and that provide the 

greatest value in a pilot’s preparation 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 pilot to a highly skilled member of an air carrier 

flight management team. Course topics include crew resource management, flightcrew 

training techniques, high speed and high altitude programming of automatic flight control 

systems, transport aircraft flight techniques, turbojet operations in all flight regimes and in 

difficult operating conditions, and use of advanced avionics. AJT courses should be 

approved by the FAA to ensure a structured quality training experience. 

Pilots who attend an AJT course need to possess 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 receive the aeronautical experience credit offered 

in table 1. 

Aeronautical Experience—Aeronautical experience is the combination of flight time and time 

spent in a flight simulator or flight-training device to meet the appropriate training and 

flight time requirements for an airman certificate, 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 certification 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 individual to serve as an SIC pilot in part 121 operations. In 

reviewing current training, qualification, and certification 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 endorsements and the result of the new 

SIC minimum qualification level. The FOQ ARC did not feel comfortable in identifying 

which method (license, rating, endorsement, or restriction) would be most appropriate and 

FOQ ARC Report September 28, 2010 78 
Appendix 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 first officer qualification must complete all of 

the modules and successfully complete an FAA-administered FOQ written exam. 

Flight Academy—A flight training organization 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, lessons 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 aircraft 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 created (September 10, 2010), a flight 

training device means a replica of aircraft instruments, equipment, panels, and controls in an 

open flight deck area or an enclosed aircraft cockpit replica. It includes the equipment and 

computer programs necessary to represent aircraft (or a set of aircraft) 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 the qualification performance standard for a 

specific flight training device qualification 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 may not follow a set curriculum 

or structure. 

Structured Training—Structured training is composed of courses designed to integrate 

classroom, self-study, practical/laboratory, flight 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 79 
Appendix 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 acquisition can be transferred from 

one setting to another similar setting, such as from an aircraft simulation 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 pilot 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 Officer 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 Administration (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 operations. The purpose of this ANPRM was to 

gather information on whether current eligibility, 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 additional carrier specific training. 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 carrier operation. The ARC will 

also evaluate the comments received in response to the ANPRM. Specifically, the ARC should 

consider and address: 

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

b. What should be the minimum flight hour experience requirements 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 81
Appendix 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 training 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 develop recommendations and submit them to the 

Associate Administrator for Aviation Safety for rulemaking consideration. 

4. COMMITTEE PROCEDURES.

a. The committee provides advice and recommendations to the Associate Administrator for 

Aviation Safety. The committee acts solely in an advisory capacity. 

b. The committee will discuss and present information, guidance, and recommendations that 

the members of the committee consider relevant in addressing the objectives. 

5. ORGANIZATION, MEMBERSHIP, AND ADMINISTRATION. 

a. The FAA will establish a committee representing 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 and 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 Administrator for Aviation Safety will then 

request that each organization name its representative(s). Only the representative for 

the organization will have authority to speak for the organization or group that he or 

she represents. 

iv. Active participation and commitment by members will be essential for achieving the 

committee objectives and for continued membership on the ARC. 

b. The Associate Administrator for Aviation Safety will receive the committee 

recommendations and reports. 

c. The Associate Administrator for Aviation Safety is the sponsor of the committee and will 

select an industry chair(s) from the membership of the committee. Also, the Associate 

Administrator will select the FAA-designated 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 82 
Appendix C—FOQ ARC Tasking 

FOQ ARC Report September 28, 2010 83 

(2) Arrange notification to all 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 Qualifications ARC meetings are not open 

to the public. Persons or organizations that are not members of this committee and are interested 

in attending a meeting must request 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 available for public inspection and copying at the FAA 

Flight Standards Service, Air Transportation 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 Federal Regulations part 7. 

8. 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. 

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 

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Appendix D—Pilot Source Study 

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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 Nonstructured 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 111
Appendix 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 113
Appendix F—ATP SIC Qualification Pathways 

Figure 4—Flight Academy Training Example 

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Appendix F—ATP SIC Qualification Pathways 

Figure 5—Military Training Example (Rotary) 

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Appendix F—ATP SIC Qualification Pathways 

Figure 6—Military Training Example (Fixed-wing) 

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Appendix F—ATP SIC Qualification Pathways 

FOQ ARC Report September 28, 2010 117 

Figure 7—Non-structured Training Example 
Appendix F—ATP SIC Qualification Pathways 

Figure 7—Non-structured Training 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. 

EXAMPLE 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 possibility of icing conditions to exist. 

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

8) Use air traffic control, Automatic Terminal Information Service, flight service station, 

and weather computer to obtain weather 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 119
Appendix G—Example Training Objectives 

EXAMPLE 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 120 
Appendix G—Example Training Objectives 

J. Task Standards 

1) Crew initiates stall recovery smoothly and timely 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 during 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 briefings, clearly communicating decisions, 

encouraging participation, and seeking information from others. 

4) Use workload management strategies such as distributing tasks, prioritizing tasks, and 

managing time. 

5) Identify and communicate potential safety threats to other crewmembers. 

6) Identify and effectively manage errors. 

7) Pilot flying (PF) verbalizes action plan. 

8) Pilot monitoring (PM) verifies and monitors 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 suggests 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 121 
Appendix 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 corrections to aircraft control and will respond to deviation 

calls caused by environmental conditions. 

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

6) The PF will make timely corrections to aircraft 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 Aviation Administration, Office of 

Aviation Medicine. 

Hunt, L. M. (1997). Influences on the learning 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). Experiential 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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