### FEDERAL AVIATION ADMINISTRATION

EXECUTIVE SUMMARY

TITLE: Pilot Certification and Qualification Requirements for Air Carrier Operations

ACTION: This action would create new certification and qualification requirements for pilots in air carrier operations. The proposal would require a second in command (SIC) in part 121 operations to hold an airline transport pilot (ATP) certificate and a type rating for the aircraft to be flown. The FAA proposes to allow pilots with an aviation degree or military pilot experience to obtain an ATP certificate with restricted privileges with fewer than 1,500 hours total time as a pilot. The proposal also would require at least 1,000 flight hours in air carrier operations in order for a pilot to serve as a pilot in command (PIC) in part 121 air carrier operations. Finally, the FAA is proposing to modify the requirements for an ATP certificate with an airplane category multiengine class ratin g or type rating to include 50 hours of multiengine flight experience and completion of a new FAA

- approved ATP Certification Training Program

. The training would include academic training and training in a flight simulation training device. These proposed requirements would ensure that pilots have proper qualifications and experience in difficult operating conditions and in a multicrew environment prior to serving as flightcrew members in air carrier operations.

STATEMENT OF THE PROBLEM: T he Federal Aviati on Administration is initiating this rulemaking project to address some of the factors that may have influenced the Colgan Air (dba Continental Airlines Express) accident that occurred on February 1 2 , 2009, outside of Buffalo, New York. Additionally, this proposed rule responds to a C ongressional mandate in Public Law 111

- 216, which requires the FAA to revise the eligibility, training, and qualification requirements for pilots engaged in air carrier operations

.



### EFFECT OF THIS ACTION: Pilots preparing to e nter air carrier operations would have a stronger foundation of aeronautical knowledge and experience as a result of the increased flight time and training requirements for obtaining an ATP certificate. Requiring an aircraft type rating for all SICs in par t 121 operations will ensure all part 121 pilots are trained and tested to the same standard with respect to the

aircraft to be flown

. Requiring pilots to have air carrier experience prior to serving as PIC in part 121 operations would assist in their prof essional development and develop the competencies necessary to assume the greater responsibilities of a PIC.



### EFFECT ON FAA: The Air Transportation Division of the Flight Standards Service would be responsible for approving the curriculum of all part 141 pilot schools, part 142 training centers, and part 121 or part 135 certificate holders who would elect to offer the proposed ATP Certificat ion Training Program. Additionally, FAA inspectors or designees would be needed to administer the proposed aircraft

t ype rating test for SICs in part 121 operations. Finally, the FAA would need to revise the ATP knowledge test and practical test standards.

### “SIGNIFICANCE”: This notice of proposed rulemaking is a “significant regulatory action” as defined in section 3(f ) of E.O. 12866, and is “significant” as defined in DOT’s Regulatory Policies and

Procedures due to the C ongressional mandate.



### CONTROVERSIAL ISSUES: Pilots seeking an ATP certificate with airplane category multiengine

class rating or type rating would be required to complete the proposed ATP Certification Training Program, which c ould impose additional time and financial burdens on individual pilots

. Requiring all part 121 SICs to have an aircraft type rating could impose a financial burden on some operat ors. Requiring a pilot to have air carrier experience prior to serving as a PIC in part 121 operations may delay

his or her career advance ment . Finally, although an applicant for an ATP certificate with restricted privileges would be required to pass the s ame written and practical tests , the propos ed reduced

- hour requirement for an ATP certificate may be controversial.



### COSTS AND BENEFITS: We estimate that the cost will be minimal for the requirement of 50 hours

of multiengine time for an ATP certificate wi th airplane category multiengine class rating or type rating

. We also estimate as minimal the costs of the requirement that a pilot have 1,000 hours of air carrier operating experience before serving as PIC in part 121 operations

.

As a result of our prov ision allowing 

### pilots with an aviation deg ree or military pilot experie nce to
hold a restricted

- privile ges ATP certificate with less than 1,500 flight hours, we have reduced by $945 million the costs of the statutory requirement that all pilots in part 121 operations have an ATP certificate by August 2, 2 0 13. Nevertheless, on a pre

- statute baseline

, a bout 75% of the rule’s

costs are the result of this requirement, making the proposed rule not cost

- beneficial

. The requirement

will take effect , however, wheth er or not a regulation is issued . We believe that a post

- statute baseline is appropriate and, therefore

, the costs associated with this provision are attributable to the statute, not this proposed regulation. On a post

- statute baseline, the proposed rule i s cost

- beneficial.

The remaining costs of the rule are associated with the aircraft type rating requirement for part 121 SICs and the ATP Certification Training Program.

Along with the benefits, the table below summarizes the costs of the proposed rule:

Total Cost

($ mil.) PV Cost ($ mil.)

Part 121 ATP Certificate Requirement $ 1,575.2 $ 582.0

Type Rating (Part 121 Operators Only) $

- $ 3.4

ATP Certification Training Program $ 443.3 $ 196.9

Total Soci al Cost (Pre

- statute baseline) $ 2,018.5 $ 782.4
Costs Attributable to Proposed Rule (Post

- statute baseline) $ 443.3 $ 200.4

Total

Benefits ($ mil.) PV

Benefits ($ mil.)

Total Social Benefits $ 896.0 $ 439.8

Note: Column su ms may be off one or more units from totals owing to rounding.

### INFORMATION REQUESTED: Throughout the NPRM the FAA invites commenter s to address specific questions pertaining to the proposed requirements

. The information requested

includes:

• T he adequacy of the minimum hour requirements for an ATP certificate ;

• T he requirement for additional multiengine experience for pilots applying for an ATP

certificate ;

• T he requirement for SICs in part 121 operations to hold an aircraft type rating ;

• T he appropriatenes s of permitting applicants with specific military and academic training to apply for an ATP with fewer than 1,500 hours of flight time ;

• The appropriate combination of academic training and training in a flight simulation training device for the ATP Certif ication Training Program ; and

• Consideration for an alternative licensing structure, such as a multicrew pilot license.

The FAA also added additional questions at the request of OMB. Those questions pertain to the

rule ’ s impact on pilot supply and potenti al areas in air carrier training programs that could be removed as a result of the ATP Certification Training Program. OMB also asked the FAA to

seek comment on accident effectiveness ratios.