Rpr 08 2010 9:13nM DELTR CONNECTION flCRDEMY 407 328 2811 p. 2 

Pilot Career Initiative 

ANPRM Response 

April 6, 2010 

Docket Operations 

M-30 

US Department of Transportation 

1200 New Jersey Ave., SE 

West Biiiliding Ground Floor, Room W12-140 

Washington, DC 20590 

Dear Docket Operations: 

The following is our response to the Advanced Notice of Proposed Rule Making, Docket No. FAA -

2010-0100; Notice No. 10-2 dated April, 6, 2010 from Pilot Career Initiative, an Ad Hoc industry group 

comprised of regional airline executives, m^or aviation academies, colleges, aviation training providers, 

and the accreditation agencies ACCSC (Accreditation Commission of Career Schools and Colleges) and 

AABI (Aviation Accreditation Board International). 

This group is so diverse that any personal agenda or agenda of commerce is not possible. It is the focus 

ofthis group and otir response to the ANPRM Docket No. FAA-2010-0100: Notice No. 10-2 to guide 

rulemaking to the mosi: efficacious direction to make our skies safer. 

Respectfully, 

John A, O'Brien 

r-

•y//^ . 

VP Maintenance and Operations, Delta Coimection Academy 

Chairman, Pilot Career Initiative 
Rpr 08 2010 9:13RM DELTA CONNECTION RCRDEMY 407 328 2811 p . 3 

Endorsing Members of the Training/Qualification Committee: 

Mark Sawyer 

Director of Sales 

Aerosim Technologies, Inc. 

Charlie Tutt 

Vice President Flight 

Operations 

Atlantic Southeast Airlines 

Dan Robertson 

Retired Captain/Pilot 

Recruiter 

Retired Atlantic Southeast 

Airlines 

John Gauch 

Fleet Sales Manager 

Cirrus 

Eduardo Carrasco 

Vice President Global 

Business Development 

Delta Connection Academy 

Gabe Bruno 

Safety Consultant 

Retired FAA 

Dave Bushy 

Chief Operating Officer 

Cape Air 

Drew Bedson 

President & CEO 

Bedson & Associates 

Peter Morton 

Immediate Past President 

Aviation Accreditation Board 

International 

Gary Morrison 

Head of Global MPL 

CAE 

Loren Herren 

Chief Flight/Ground 

Instructor 

Bridgewater State College 

Amy Hoover 

Head of Aviation Department 

Central Washington State 

College 

Kent Lovelace 

Chairman of Aviation 

Department 

Dr. Thomas Q. Carney 

President 

Aviation Accreditation Board 

International 

Eric Morris 

Captain 

Jason Blair 

Executive Director 

NAFI 

Darrin Greubel 

Captain & Manager Flight 

Operations & Aviation 

Standards 

Atlantic Southeast Airlines 

CJ Grisham Jr. 

Captain 

Jan Shakespeare 

Associate Dean Aviation 

Operations 

Broward College Aviation 

Institute 

Andy Smith 

CEO 

Halldale Media Group 

Peter Wolfe 

Executive Director 

Professional Aviation Board 

of Certification 

University of North Dakota 

Paul Woessner 

Sr. Vice President 

Delta Connection Academy 

w^m 

AABIni6rnaiiona! 

„^^^^SSOo,,^^ 

HALLDALE n 

MEDIA GROUP 

A DELT A 

CONNECTIO N 

ACADEM Y 
Rpr 08 2010 9:13RM DELTR CONNECTION RCRDEMY 407 328 2811 

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Rpr 08 2010 9:13flM DELTA CONNECTION RCRDEMY 407 328 2811 

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Response to Advance notice of proposed rulemaking (ANPRM) 

Docket No. FAA-2010-0100; Notice No, 10-2 

Introduction: 

?C\ (Pilot Career Initiative), an Ad hoc group of airline executives and aviation educators, offers the 

contained response to the above referenced ANPRM. 

It is our strong opinion that the requirement for an ATP (Airline Transport Pilot certificate) to serve as 

First Officer in a CFR FAR Part 121 operation would not enhance safety. The written test associated with 

this certificate is published publically and the practical test has minimally more rigor than that of the 

Commercial Pilot, Multi Engine Land certificate. The value of an increased flight hour experience 

requirement is entirely dependent on the nature of that flying. Since currently regional airlines require 

the age of 21 of their applicants, the age requirement for the ATP, 23 years, reduces the number of 

pilots eligible, thus possibly forcing the airline to hire pilots over the age of 23 that they otherwise may 

have determined to be of a lower quality or less desirable background. 

PCI believes strongly that foundational education and training is more pertinent to experiential value of 

a pilot's development than an arbitrary number of flight hours. PCI recommends that the Administrator 

assemble a panel of experts in an Aviation Rulemaking Committee (ARC) to describe the desired 

foundational training and education that could be considered in lieu of flight hours and to determine 

alternative paths to the first officer seat in a part 121 or 135 operation. 

Notes; 

This response to the ANPRM makes frequent reference to training devices and has adopted the ICAO 

designatibn of Flight Simulation Training Device (FSTD). We also use the acronym KSACs when referring 

to a pilot's knowledge, skills, attitudes and competencies. 

Included in this response are two attachments; 

Appendix A; A brief description of structured training mentioned in this response document. 

Appendix B: A graphic showing a sample structured training process covering each phase of a pilot's 

training progression. 
Rpr 08 2010 9:13RM DELTR CONNECTION RCRDEMY 407 328 2811 

The academic based programs, such as tbe programs accredited by the Aviation Accreditatioii 

Board International (AABI) and the Accrediting Commission of Career Schools and Colleges 

(ACCSC), provide a thorongh approach to aviation knowledge that is ovtcome-based. While the 

academic knowledge possessed by any first officer candidate is likely to be a function of individual 

candidate backgrounds, namber of hoars of academic study, quality of the program attended, 

background of the faculty, use and state of the art of practical/labonitory training facUities, and 

integration of academic and practical/laboratory education curriculum, our experience has shown 

that the best candidates come f^om those with the most in-depth curriculums. This has been 

continual^ demonstrated in the successful candidates lower failure rate in training and better 

success in line operations and check rides. 

All other things being equal, the most solid academic knowledge and ability to apply It in a 

practical sitaatlon is likely to emerge from academically-based programs accredited by a 

recognized accrediting body. 

2B. Should the FAA consider crediting specific academic study in lieu of flight hour requirements? If so, 

what kind of academic study should the FAA accept, and to what extent should academic study (e.g., 

possession of an aviation degree from an accredited four-year aviation program) substitute for flight hours 

or types of operating experience? 

2B Response: Yes, credit for academic study In lieu of arbitrary flight hour requirements is 

appropriate. As noted above, there are many variables associated with the training and education 

quality experienced by a first officer candidate. We recommend that the FAA convene an ARC 

composed of a diverse group of education and training experts from a variety of training and 

education institutions and companies into a panel to discuss and determine the extent to which 

academic credit should be granted. We hypothesize that the amount of such credit may be a 

function of the amount and quality of education and training provided by the flight school or 

institution from which the first officer graduates. 

2C. If the FAA were to credit academic study (e.g., possession of an aviation degree from an accredited 

four-year aviation program and/or completion of specific courses), should the agency still require a 

minimum number of flight hours for part 121 air carrier operations? Some have suggested that, regardless 

of academic training, the FAA should require a minimum of 750 hours for a commercial pilot to serve as 

SIC in part 121 operations. Is this number too high, or too low, and why? 

2C Response: Selecting an arbitrary number of flight hours is not appropriate. 750 hours 

might not reflect the competency-based training and education program that needs to be developed. 

Moreover, education quality is better reflected by the totality of contact hours encompassing all the 

training provided. We bdieve that the minimum flight hours required in a measurable competencybased training program will emerge from the analysis of the competencies by the expert panel 

(ARC). Industry experience has shown that pilot candidates with as low as 250 - 350 hours have 

been successful in achieving excellent performance as new first officers. Therefore, it is premature 

to specify exact numbers in response to this ANPRM. We suggest that a matrix that includes types 

of hours flown, and source of education and training, may be a deliverable from the panel of 
Rpr 08 2010 9:14RM DELTR CONNECTION RCRDEMY 407 328 2811 p.7 

experts if they are provided with an extension of the appropriate research involving additional 

regional airline employers. The mere addition of hours in a logbook does not necessarily serve as a 

gauge of future success for any airline crewmember. It Is the specific academic knowledge, 

outcomes achieved, and the ability to learn that provides the best gnarantee of success. Once an 

expert panel decides what training and experience is required, they will be better prepared to 

recommend specific hour requirements. Absent required academic, skill and knowledge outcomes, 

such a specification of hours is premature, arbitrary and less than precise. 

3. Endorsement for Air Carrier Operations 

On October 14, 2009, the U.S. House of Representatives passed bill H.R 3371, the Airiine Safety and 

Pilot Training and Improvement Act of 2D09. The bill is currently being considered by the Senate 

Committee on Commerce, Science, and Transportation. Under this bill, all flight crewmembers who are 

engaged in part 121 air carrier operations would be required to hold an ATP certificate. The bill includes 

a provision that would allow credit toward flight hours for an ATP certificate for specific academic 

training courses, if the Administrator determines that the academic training courses will enhance safety 

more than requiring full compliance with the flight hours requirement. 

The FAA believes that, although the flight hours required to qualify for an ATP certificate can benefit 

pilots, experience is not measured in flight time alone. Other factors, such as certain types of academic 

training, practical training/experience, and experience in a crew environment, are also important. A pilot's 

skills and abilities may also be enhanced by exposure to specific operational conditions, including icing, 

high altitude operations, and other areas common to part 121 air carrier operations. 

An endorsement on a commercial pilot certificate may be an option for addressing concerns about the 

operational experience of newly-hired pilots engaged in air carrier/commercial operations. Under this 

concept, a commercial pilot would not be able to serve as a required pilot in part 121 air carrier operations 

without having obtained an endorsement attesting to successfiil completion of additional training and 

qualified operating experience. 

The FAA is therefore considering the creation of a 14 CFR 61.31 endorsement for a commercial pilot 

certificate that would require specific ground and flight training, as well as additional experience in 

specific areas, in order to receive part 121 air carrier operating privileges. The additional training for the 

endorsement could include operating experience in a crew environment, training and exposure to icing, 

and flight experience in high altitude operations. The current § 61.31(g) endorsement for additional 

training for operating pressurized aircraft capable of operating at high altitudes might serve as a model, 

Additionally, the FAA may consider the type-specific aircraft training endorsement in § 61.31(h) as a 

model. The FAA believes that an endorsement approach would target specific skill sets needed for part 

121 operations, and establish the associated standards for content and quality of training. The FAA notes 

that the endorsement option would also eliminate the time-based requirements that aviation universities 

argue is not a reasonable requirement for graduates of their four-year aviation degree programs. 

We request comments on the following issues regarding the possibility of establishing an endorsement for 

SIC privileges in part 121: 
Rpr 08 2010 9:14RM DELTR CONNECTION flCRDEMY 407 328 2811 p. 8 

3A. Should the FAA propwse a new commercial pilot certificate endorsement that would t>e required for a 

pilot to serve as a required pilot in part 121 air carrier operations? Why or why not? 

3A Response: We can accept tUs approach. 

We note that preparation for a pHot to serve as a required pilot in part 121 air carrier operations 

actuaBy needs two training/education phases. The first takes the pik>t from ab-initio status to the 

acquisition of competencies suitable for employment by a part 121 carrier. The second involves the 

employer indoctrinatioii process, training and education to meet the carrier's operating certificate 

requirements, specific t}rpe training and qualification for the aircraft to be operated, initial 

operating experience supervision, crew pairings to assure appropriate seasoning and mentoring, 

and possibly other systematic seasonal exposure to assure adequate preparation for environmental 

conditions associated with the air carrier operations. 

The US pilot Ucensiag process is based on discrete accomplishment of several certificate steps that 

prepare pilots for a great variety of careers, and Is not focused on any specific career path. This is 

in contrast with an emergent international (ICAO Multiple Crew Pilot License) standard that 

integrates training from ab-iaitio status to type and airline specific qualification to serve as a 

required pilot in commercial airline service. Van Aviation Rulemaking Committee is convened to 

assist the Administrator in creating rules appropriate for service as a required pilot in part 121 air 

carrier operations, it could be charged with examining the MFL process as well as implementing 

other competency requirements derived from responses to this ANPRM. 

If the FAA chooses an endorsement as the mechanism to allow a commercial pilot to serve as a 

required pilot in part 121 air carrier operations, it should consider all the above training, 

education, and competencies and the means to assure them during the preparation of candidates 

for airline indoctrination, and enforce appropriate indoctrination and initial training processes at 

the employing airline. With those provisos, we concur with the creation of a 14 CFR 61.31 

endorsement for a commercial pilot certificate that would require specific ground and flight 

training, as well as additional experience in specific areas and a requirement to demonstrate 

selected competencies in an appropriate Flight Simulation Training Device (FSTD) or aircraft, in 

order to receive part 121 air carrier operating privileges. The use of the endorsement mechanism 

has appropriate precedent and we believe it is an appropriate means to specify experience, 

operational exposure, and specific qualification standards. Assuming for the purposes of this 

submittal that an endorsement Is the chosen administrative tool, we suggest it contain qualification 

standards stipulating licenses that must be held, and also contain a set of detailed competency 

requirements defined by the aforementioned ARC that may be updated if needed, as circumstances 

require. 

3B. If so, what kinds of specific ground and flight training should the endorsement include? 
Rpr 08 2010 9:15flM DELTR CONNECTION RCRDEMY 407 328 2811 p.3 

3B Response: PCI recommends that the ARC consider the following as part of the new preemployment training standards for the proposed endorsement: 

1. Turbine engine theory 

2. High altitude airspace and the characteristics of high altitude operations 

3. Jet transport navlgatton and approach procedure diart interpretation 

4w Typical air carrier aircraft flight guidance systems 

5. The effects of high altitude physiology 

6. Air carrier and business avbtf on flight planning 

7. High altitude weather 

S. Weatiier radar 

9. Severe weather avoidance procedures 

10. Aircraft: idng, anti-lcing, de-idng, and the consequences of alrfkame, engine and otiier forms 

ofldng 

i 1. FAR Part 121 - Certlflcation and Operations: Domestic Flag and Supplemental Air Carriers and 

Commercial Operators of Lai^ge Aircraft 

12. l^pical air carrier flight management systems 

13. fet engine monitoring systems such as EICAS 

14. Air carrier operating procedures 

15. Air carrier safety programs and Issues 

16. Hydroplaning 

17. Wind shear detection and avoidance 

18. Jet aircraft systems^ Including typical air carrier avionics. 

19. fet transport aircraft emei^ency procedures 

ZO. Air carrier aircraft performance, weight and balance 

21. Pilot profiesslonallsmj authortfy and responsibiUfy, and ethics. 

22. The elements of good customer service 

23. Aviation safefy concepts Indudfaig FOQA, ASAP, and SMS 

24. Grew Resource Management (CUM) 

25. Typical air carrier crew procedures indudlng flows and other forms of checklist usage 

26. Line-Oriented Flight Training (LOFT). 

27. Stalls and upset recovery training. 

3C. The FAA expects that a new endorsement would include additional flight hour requirements. At a 

minimum, the FAA requests comments on how many hours should be required beyond the minimiun 

hours needed to qualify for a commercial pilot certificate. Some have suggested that the FAA require a 

minimum of 750 hours for a commercial pilot to serve as SIC in part 121 operations. Is this number too 

high, or too low, and why? 

3C Response: Selecting an arbitrary number of flight hours is not appropriate. 750 hours 

might not reflect the competency-based training and education program that needs to be developed. 

Moreover, education quality is better raflected by the totality of contact hours encompassing all the 

training provided. We believe that the minimnm flight hours required in a measurable competencybased training program will emerge from the analysis of the competencies by the expert panel 

(ARC). Industry experience has shown that pilot candidates with as low as 250 - 350 hours have 

been successful in achieving excdlent performance as new first officers. Therefore, it Is premature 

to specify exact numbers in response to this ANPRM. We suggest that a matrix that includes types 

of hours flown, and source of education and training, may be a deliverable from the panel of 

experts if they are provided with an extension of the appropriate research involving additional 

regional airline employers. The mere addition of hours In a logbook does not necessarily serve as a 
Rpr 08 2010 9:15RM DELTR CONNECTION RCRDEMY 407 328 2811 p.10 

gauge of future success for any airline crewmember. It is the specific academic knowledge, 

ontcomes achieved, and the abiBfy to leam that provides the best guarantee of success. Once an 

expert panel deddes what training and experience is required, they will be better prepared to 

recommend specific hour requirements. Absent required academic, skill and knowledge outcomes, 

such a specification of hours is premature, arbitrary and less than precise. 

3D. The FAA is considering proposing to require operating experience in a crew environment, in icing 

conditions, and at high altitude operations. What additional types of operating experience should an 

endorsement require*? 

3D Response: Practically speaking, operating experience is a term used in part 121 and 135 to 

reflect the initial line operation of a pilot at the completion of an employer qualification program. 

Therefore we do not agree that operating experience should be required as part of the preparation 

training prior to employment. We agree that academic anderstanding of crew environment, icing 

conditions, and high altitude operations, and some actual experieace in a crew environment is an 

appropriate requirement Though difficult to measure, there should also be emphasis on 

professionalism in aviation. It is also appropriate to require training in Fatigue Countermeasures 

and Alertness Management. The KSACs defined by the aforementioned ARC are intended to 

ensure the initial qualification of a first officer to serve in any airline environment, and contain 

specific academic knowledge about icing conditions, high altitude operations, and many additional 

competendes. A separate requirement already exists and should be enforced that requires the 

employer to train and examine applicants with regard to airiine specific operational requirements 

as well as administering type specific training. 

3E. Should the FAA credit academic training (e.g., a university-awarded aviation degree) toward such an 

endorsement and, if so, how might the credit be awarded against flight time or operating experience? We 

are especially interested in comments on how to 

balance credit for academic training against the need for practical operating experience in certain 

meteorological conditions (e.g., icing), in high-altitude operations, and in the multi-crew environment. 

3E Response: We believe that the FAA should credit academic training toward a first 

officer qualification endorsement, the amount of credit to be recommended by the aforementioned 

ARC as a fhnction of the variables noted in question 2C above. 

PCI further recommends that the ARC also define the standards for assessing those ICSACs 

through written and practical testing using oral examinations, FSTDs and aircraft We believe 

these demonstrations must Indude training in idng conditions, high altitude operations, upset and 

wind shear demonstrations. We also suggest that acquisition of the first officer endorsement is not a 

substitute for airline indoctrination training and specific type training and rating. A mechanism to 

prove that a pilot has specific FSTD training in such subjects as idng and high-altitude operations, 

as well crew coordination and resource managemeat is critical to any training program. 
Rpr 08 2010 3:15flM DELTR CONNECTION RCRDEMY 407 328 2811 1 1 

4. New additional authorization on an existing pilot certificate. 

The FAA may also consider proposing a new authorization on a commercial pilot certificate for any pilot 

employed as a required flight crewmember for part 121 operations. This new authorization would be 

limited to a specific part 121 operator, and would be issued only after the pilot successfully completed 

that part 121 operator's approved training and qualification program. The pilot would surrender this 

authorization upon leaving the employ of the specific part 121 operator. The purpose of such an 

authorization would be to ensure that each air carrier has provided its pilot employees with the training 

and qualifications specific to its operating environment (e.g., aircraft, routes, meteorological conditions). 

The FAA seeks comments on the following question: 

4A. Would a carrier-specific additional authorization on an existing pilot certificate improve the safety of 

part 121 operations? Why or why not? 

4A Response: No, not under current US licensing regulations. Air carriers are already 

required to provide this level of training for new First Officers. In oar response to 3E above, we 

mention the requirement for operation-speciflc Indoctrination training as well as type training and 

ratings. It seems that existing administrative procedures, if enforced, are sufficient to assure that 

first officers are trained, qualified, and examined to fiy the airiine routes as weU as acquire the 

requisite type ratings that include operation of the aircraft throughout their entire flight envelope 

and in all normal and non-normal procedures. Superimposing a new certificate, particularly one 

that requires the additional administration of surrender upon leaving employment, adds 

complexity bnt not public safety compared to proper implementation and administration of existing 

practices. 

4B, Should the authorization apply only to a pilot who holds a commercial certificate, or should it also 

apply to the holder of an ATP certificate? 

4B Response: Whatever duposition is made of the question In 4A should also apply to the 

hoMerofan ATP. 

4C. Should such an authorization require a minimum number of fli^t hours? If so, how many hours 

should be required? 

AC Response: We do not recommend the authorization as described, and therefore do not 

have a recommendation on minimnm flight hours. 

5. Other actions. 
Rpr 08 2010 9;15RM DELTR CONNECTION RCRDEMY 407 328 2811 p. 12 

The FAA is seeking comment on whether existing monitoring, evaluation, information collection 

requirements, and enforcement associated with current pilot performance could be modified to achieve 

improved pilot performance. 

5 A. Can existing monitoring, evaluation, information collection requirements, and enforcement associated 

with pilot performance be modified to improve pilot performance? 

SA Response: Our perception is that existing monitoring, evaluation, information collection, 

and enforcement provides the FAA with the necessary tools to assure public safety with one 

exception: the possibilify that an applicant for a first officer endorsement may have a poor 

performance history unknown to the FAA examiners or designee and the employers. 

5B, If so, what specific modifications should be considered? 

5B Response: The entire airman examination, acddent, and incident record most be disclosed 

to the examiner and/or employer whenever a pilot candidate presents herself or himsdf for a new 

rating or endorsement 
Rpr 08 2010 9;16RM DELTR CONNECTION RCRDEMY 407 328 2811 p. 13 

Structured Training 

A Iraining program composed of courses designed to integrate classroom, self-study, pfaciical/latwratory, simulator and flight training 

experiencas 1o optimize the pilots acquisition of the knovvledge, skills, attitudes and competendes needed to meet Ihe standards 

required for FAA and industry certificates, ratirtgs and endorsements. The process includes written and oral examinations, simulator 

and aircraft flight checks to ensure eac^ pilot's preparedness to move from one ptiase of training to the next. 

Aviation Ground Courses 

Aerodynamics (Topics lo include stalls / upset recovery) 

HighAKiiude Operations 

Meteorology (Topics such as; hazardous weather / ice / thunderstorms / windstiear / etc.} 

Aviation Law 

Basic Aircraft Systems 

Advanced / Jet Aircrafl Systems 

General /Advanced Performance 

Navigation / Airspace / ATC 

Aviation Operations 

Technologies (FUS / HUO / ACARS / EFIS / AuloFlight / GPS / other) 

Threat and Error Management 

Crew Resource Management/Aeronautical Decision Making 

Multl Crew concepls and Operallcms 

Professionalism 

Aviation Practical/Laboratory 

Practical / laboratory activtties are designed to enhance the pilots' at>illty to apply theoretical knowledge through the use of flight 

simulation and/or training devices and aircratl filgttts. Labs support the pilots' acquisition of the following FAA Pilot Cerilficates. Ratings 

and Ertdorsements: 

Private / Instrument * 

Commercial / Multj-Engine * 

Inlraductkin of multi-crew concepls 

Advanced Aircraft Flying (Flight Training Device)** 

Scenario Based Training for Advanced Aircraft 

FTD Training for MuM-Crew Jet aircraft 

Line Oriented Flight Training 

* Flight training consisting of organized lesson plans Integrated with ground school subjects along with associated checking 

and completion standards. 

** Flight simulation and/or training devices should be utilized In all phases of flight training to establish and enhance student 

experience and alhjw the training of hazardous situations (I.e. upset recovery, windshear, ennergencies, etc.) 

Proposed New Airline First Officer (AFO) Qualification Requirements 

"Airline First Oflicer" (AFO) qualification is awarded upon satisfactory completion of requirements specified by Uie ARC. 

Mandatory FAA raporting of perfomiance from Flight Schools and Part 121^35 Airlines 

ReportlngAradcing of academic/tight performance to the proposed FAA Pilot Records Database as specified by the ARC. 

Pilot performance during Initial airline training must also be reported to the FAA per ARC-defined requirements. 

Oversight fay 

Accrediting Bodies such as: 

Formal Education: Aviation Accreditation Board International (AABI) 

Technical Schools: Accrediting Commission of Career Schools and Colleges (ACSSC] 

The FAA: 

Through FAA approval and monitoring of Part 141 arxJ 142 Flight Schools per ARC requirements 

Pilot Written & Practk:al Testing p*r ARC-defined requirements 

Other Avenues 

Successful completion of any military branch flight school would be considered acceptable "structured' training. 

The swarding of AFO qualilication to milltafy-lralned pilots will be per ARC-dsfined requirements. 

Testing / crediting pilots witti previous experience for the AFO qualification will be per ARC requirements. 
Rpr 08 2010 9:1GRM DELTR CONNECTION RCRDEMY 407 328 2811 14 

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