Would the FAA's proposed rule have changed anything in Buffalo?
The FAA is famous for writing proposals using illumination from burning airplane wreckage. The latest is a notice of proposed rulemaking that would increase the requirements for a pilot to serve as a first officer on U. S. passenger and cargo airlines.
To say that this is probably the most sweeping change ever proposed is almost an understatement. Now a first officer has to have a commercial certificate which calls for 250 hour of flight time. Under the proposal a first officer would have to have an airline transport pilot certificate (ATP) which requires 1,500 hours of flight time. Also, currently a first officer does not have to have a type rating for the airplane; under the proposal that would be required. That is a huge and unprecedented increase.
The catalyst for this was the crash of a turboprop airliner on approach to Buffalo, New York. The crew simply failed to fly the airplane properly and caused a low-speed loss of control. It was a failure of basic airmanship and while this crew was relatively inexperienced, pilots with ATP certificates have also been known to do some pretty bad flying and lose control of airplanes.
If enacted, this would literally cause huge upheavals in the pilot business. It is already expensive for a young pilot to qualify for the required certificates. It would become even more expensive, all at a time when the airline flying job is becoming less attractive. Pay is down, job security is not particularly good, and pension plans are looted on a regular basis.
The path to the right seat of an airliner will become a lot more circuitous. This could cause a sharp drop in the number of young pilots willing to jump through all the hoops. And while few airline pilots are hired who have today’s minimum requirements, some are, and many are hired before they reach the 1,500 hour mark.
There are only two primary ways for a lot of young pilots to build hours rapidly. Flight instructing is one, flying freight is another. Both pay low wages and pilots doing that type work are getting a poor return on their investment in training. It would become an even more daunting prospect.
The FAA proposes a couple of limited exceptions. Military pilots could get an ATP if they have 750 hours and graduates of a four-year degree program in aviation would be eligible at 1,000 hours if they earned a commercial and instrument rating from their college program. Do you think that would be fair? In any event, no pilot would be allowed to act as captain until amassing 1,000 hours as a pilot in air carrier operations.
This will have exactly no effect on general aviation flying. Young pilots could still fly as first officers on corporate jets where the regulations would be unchanged.
The reason all citizens of aviation should be interested in this is that it opens a window on how FAA thinking runs. We could conceivably someday read a proposal just as sweeping for pilots to get an instrument rating and operate in the air traffic control system.
There is no question that, if enacted, this would change a lot of the dynamics in flight training. The question that has to be asked, though is this: Airline operations in the U.S. are, hands-down, the safest form of transportation in the world. Would this change make something that is already so safe any safer? That is hardly possible.
It is inevitable that there will be an occasional airline crash but these have become fewer and farther between. It is my opinion that while an accident should cause a review of training methods and changes there if called for, one accident should not cause such a massive regulatory response. The FAA is likely under a lot of Congressional pressure to enact this rule so it will likely come to pass, possibly in some modified form.
What do you think of the proposal?
- From the archives: how valuable are check rides? - July 30, 2019
- From the archives: the 1968 Reading Show - July 2, 2019
- From the archives: Richard Collins goes behind the scenes at Center - June 4, 2019
This is another knee jerk reaction to a bad piloting by the PIC. The reason one is a second officer is because they haven’t gained the experience and knowledge to sit in the left seat, it is not just whether you have a certain amount of hours. We should look further into how the PIC of this accident got to be a PIC. He made of had the hours required by regulation to be a PIC he obviously did not have the experience to control the aircraft in this situation. Do you think someone who has flown 1500 hours as instructor in a C-150 is then ready to be a second officer just because they have reached a magic number? That would be ridiculous. I am not sure there is a measurable way in hours to determine this, but we should put more emphasis on the actual check ride of an individual.
If you think CFI pay is low now, wait until the regs force aspiring commercial pilots to spend even longer working as an instructor. Couple this with less youngsters going into the field and you have a huge CFI glut in the market place. From a consumers point of view it would help reduce the cost of flight training but in all reality the reduction would not be significant. Now if the knee jerkers in Congress could come up with a way to reduce the price of an airplane or the fuel it burns, without passing on the cost to others……….
I am not sure if these guys have an unspoken end game in mind or not but I suspect the proposed changes are meant solely to capitalize politically on the Buffalo crash. As with a lot of things coming out of Washington there doesn’t appear to be much foresight given to the impact of these kinds of changes.
Accumulated hours are a poor substitute for experience. The airlines, like most other industries, no longer want to pay for one’s training.
The passengers (customers) have a rightful expectation that the crew is fully capable. Rather than have a certain number of hours be a requirement for an ATP, it would be far better to have a list of tasks that must be experienced, such as flying in ice and snow, flying with a way aft CG, handling emergencies, etc. the airlines should require their new hires to fly with very experienced pilots until all these tasks are accomplished.
It really is illogical to me. Please explain how more time in the airplane makes you a better pilot. Too much time in the airplane would make you more complacent in my book. I totally disagree with this ruling and I really think because of this ruling the skies will be less safer. Instructors are always safer and more knowledgable than “Joe Pilot”. I say the more instuctors the better. This ruling will certainly lead to less instructors in the sky. And will discourage many to not become instructors at all. Bad rule. FAA stinks with this one.
PLEASE TELL THE OBAMA ADMINISTRATION TO LAY OFF FLIGHT TRAINING it is expensive already cfi don’t make the money and it is up to the pilot even with a lot of time can make mistakes. I flew solo before i couldnt fly no more because of the fuel prices if you want me to get an ATP before going to the airlines you talking training over $100k and making as a cfi $12 to $ 20 salary aint happening an average cfi spend according 5 to 6 years now before moving toa commuter airlines or regional airlines and the burn out rate is great if you have a bad week of bad weather students quit or students never show up you not making money if the airplane cost$140 dollars and the instructor $50 hr i am pretty sure that instructor is only getting $25 for that flight .
To be fair to the FAA; I don’t think it was their idea. This was forced on them by a Congress that was, in turn, pressured by relatives of the accident victims to “do something”. Occassionaly, small groups are able to force bad ideas on to this country. It happens just like airplane accidents.
For those that are against this new rule/regulation, I call you all ignorant. Look at the facts before you make such baseless objections. Fact, the majority of airline pilots support this rule, somewhere around 99%. Why do the majority of airline pilots support this rule? The amount of commercial pilots in the US is over saturated. Theoretically, if it is more difficult to become an airline pilot than less will try, this is America off course. When supply and demand becomes more proportional than wages will increase overtime. Richard Collins is in the business of flight training, thus his income will likely reduce overtime as this rule comes into affect. This rule will reduce the amount of students choosing to learn how to fly, although government cutbacks in student loans has and will reduce the number of students learning how to fly more significantly than this rule will. Keep in mind, the airlines are a very complex industry.
If the goal is to raise airline salaries, then let’s call it the “Airline Pilots Stimulus Package.” But this is being dressed up as a safety initiative and it’s clearly not. That’s my problem with it–it’s fake.
I am not really in the business of flight training. I am mostly retired. That doesn’t keep me from being vitally interested in everything about aviation.
If 99% of commercial pilots agree with it, does it make it right?
If the PIC of that Buffalo flight had 1500 hrs would he not of made the same mistakes? We will never know. However without a diversity in training and experience, my guess is he still would of.
I agree with Steve Phoenix 100%
Joe D-your opening statement, grammar, and the lack of punctuation in your comment, reflects that you are one of those right wingers that spend all day surfing variouse forums trying to find a way to blame President Obama and his Administration for the problems of our country.
en
The burn out rate starts in flight school for American Student Pilots.
It is really tought to attend a Flight Academy, and work a part, or full time job while attending…especially if you have a family.
This is not much of an issue for Students who are sent by the Asian Airlines like Korean, ANA, and China, who pay for everything, including living expenses, allowing their students to devote to the Academy full time.
This is the way it should be for any pre-private student, seeking a flying career.
I agree with Steve Phoenix 100%
Joe D-your opening statement, grammar, and the lack of punctuation in your comment, reflects that you are one of those right wingers that spend all day surfing variouse forums trying to find a way to blame President Obama and his Administration for the problems of our Country.
The burn out rate starts in flight school for American Student Pilots.
It is really tought to attend a Flight Academy, and work a part, or full time job while attending…especially if you have a family.
This is not much of an issue for Students who are sent by the Asian Airlines like Korean, ANA, and China, who pay for everything, including living expenses, allowing their students to devote to the Academy full time.
This is the way it should be for any pre-private student, seeking a flying career.
With the (supposed) upcoming pilot shortage and the additional amount of money that airlines would probably have to spend on training new hires by equipping them with a type rating the logistical and economic impact that this legislation could have is a little bit daunting if ones considers what truly could hit the fan.
With the cash strapped airline industry I can’t see spending extra money on new hire type ratings working out well and possibly even leading to further pay decreases for crew members (especially new hires). I wonder if they’d push the type rating off on the new hire as a prerequisite to interview thereby throwing the ol’ adage “never pay for your own type rating” out the window. While it would not surprise me one bit if the industry attempted to do this, I would certainly hope that ALPA and others would shoot that down. If the prerequisite of an ATP and type rating becomes the responsibility of the incumbent it would cause even more undue burden on them who may possibly (probably) already has tens of thousands of dollars in debt. By forcing a costly ATP and type rating onto them while they get to enjoy a flying job in which they may be losing money (okay not losing but you get the point) would cause them to go even further in dept simply to get to the point where they can make perhaps a tiny smidgen more than they were prior (at least their first few years).
There are plenty of low cost airlines in the EU that already ask their SIC’s to pay for a type rating. It is only a matter of time before that trend comes to the US. The pendulum is swinging the wrong way and I think it has a bit further to go before it comes back to normality. What I mean by that is the great assault on GA through user fees, abysmal pay, pension looting and this rule, just to pick 4 of many examples, will, in 10-15 years, lead to massive pilot shortfall. One can only hope that pay and conditions improve to such an extend that the career actually looks attractive.
Back in 1999 I was very close to jacking in my high-tech career and jumping into full time flight training with the goal of working for the majors. Well, 24 months later I was extremely glad I still had my job and was very thankful that flying was still my hobby and not a career, given that every airline was giving pilots the shaft, from which things have only slid downhill…..
The pilot career is now, IMHO, such an unattractive proposition I really can’t see how, long term, it is going to recover unless there is a massive shortfall and airlines wake up to treating pilots with respect and a living wage.
Sorry, but I’m with Jeff. The fact that the First Officer doesn’t even have to have a type rating in the plane currently is ridiculous!! I spend more time in flight training than some of these first officer pilots. And getting an ATP rating requires a lot more than just the hours. I know of at least two corporate pilots that lost their jobs because they couldn’t pass the ATP exam. Not everyone is ENTITLED to fly people for a living.
Well said! Especially with regards to type rating. Imagine a CFI with 250 hours in mostly 2 and 4 seat Cessnas flying right seat in a King Air for instance. With no type rating?? Really?
I have 800 hours and haven’t the courage to try to land my Cardinal from the right seat. I did fly it coast to coast; east- west; and north-south and to the Bahamas.
I am not opposed to stricter standards for airline first officers and captains, but the way they went about this, increasing the hour-requirement 6-fold, is completely arbitrary. If we want to improve safety, training and testing has to be improved. It is too easy to make it to the right seat of an airliner by brute-force; that is, testing and retesting until you pass. This is precisely what the Captain of Colgan 3407 did; the warning signs were there that he was not fit for his position.
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The best predictor of accident rates for a pilot is time-in-type, NOT total hours. And guess what, the Captain of Colgan 3407 had just transitioned to the Q400, straight into the left seat. So I think the 1000-hours in type requirement to be Captain is justified; the 1500 hour requirement is not.
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There are so few airline accidents that it is impossible that the new rules will result in a demonstrable improvement in safety. Furthermore, the economic impact upon the regional airline industry will be profound. These companies already operate on razor-thin margins and it is likely that many will either go out of business, or at least end many routes and flights. This will result in people taking ground transportation which were previously able to travel by air…which means the new rule may actually worsen the safety of overall travel.
Before you make argumentative remarks educate yourself on the subject first. There is no 1000 in type requirement for captains as you have stated. The new requirement for captains is 1000 hours of 121 time, not time in type.
It is ignorant to say; “regional airlines operate on razer-thin profit margins,” that simply is not true. Please educate yourself on airline economics, and learn how regional airlines operate. I review of SEC fillings might be a great place to start, along with reading a book on economics. This rule will not cause any significant increase in overall costs for the regional airlines. Some regional airlines currently hire pilots with ATPs mins and provide them with a type as well.
DMSpilot,
You are very, very misguided.
Jeff, how can this simultaneously raise salaries for pilots but not raise costs for airlines? Can’t have it both ways.
We have known for a long time that hours alone are not the best indicator of the quality of an individual for piloting ability. It should also be obvious that this ruling will help forge the way for large flight schools, and some commercial operators, to take advantage of this and implement ways to encourage indentured servitude (i.e. pay for training, etc) in order for those who have the resources (financial, not necessarily the talent) to weather the storm. It is furthermore obvious that the rule makers had the fact in mind that quality of training takes precedence over quantity, otherwise they would not have included provisions for reduced mins for military and collegiate trained aviators.
Of course the majority of airline pilots support this ruling – they know that this will only support the push for higher wages and increased quality of life – which they deserve!
Training and testing needs to be revamped. It is clear that the Captain of the Colgan crash had experienced multiple failures in qualifying and training. Airlines need to be held accountable for their hiring and training practices – not the hard-working, dedicated individuals that are willing and able to do what it takes to achieve the competency to keep making America’s air commerce better. This rule is simply one more nail in the coffin that will kill GA. Both of these pilots had ATP mins. One had an ATP and a type in the Q. This rule making solves absolutely no part of the root cause of the tragedy that occurred with the Colgan Air flight in Buffalo.
AMEN AMEN AMEN AMEN!!!!!! Finally someone “gets it” and says the truth!!!
Congress wants these stupid nonsensical rules when BOTH pilots, BOTH had over the mythical and magical 1,500 hrs they want. Now if this magical 1,500 hr mark makes for such a great pilot, than this accident would have never happened.
Another possible factor is that pilots are ingrained to not loose more than 100ft in a stall on an ATP checkride, which now to my understanding has been revised by the FAA to only incur minimum loss of altitude. This is the same situation with the Air France 447.
The biggest issue I feel in this unfortunate accident was the crew rest/fatigue problem. A pilot with 10,000 hrs can make simple mistakes that could lead to a fatal ending if he or she was was in a fatigued condition.
Allowing commercial pilots with minimal hours in the right seat at 250+ hours with so few incidents is actually a testament to how well and successfully our training system actually works. Think about it. It’s pretty amazing that you have pilots from all walks of life, backgrounds and training environments that can come into an airline, get assimilated and build a productive and safe flying career. Way many more than those that have met an unfortunate end either by their hand or some other outside and unforeseen circumstance(s).
This crap the Congress and the FAA is putting forth is utter ridiculous nonsense, and frankly I’m pretty ticked at the Aviation Community leaders just reporting on the NPRM but not offering up outrage and banding folks together to fight against this mess, esp AOPA. They should have lit a fire the day this was announced.
More of our liberty being taken from us. The sweeping hand of government is suffocating every aspect of our lives. You have a better chance of walking out your door and getting killed than dieing in a plane crash. Should that warrant legislation preventing us from leaving our homes? I am afraid we are only slipping further down the slippery slope of losing our freedom under the guise of safety, fairness, et al.
Jason…. You hit it on the nose. Maybe one needs 1500 hours of training walking out the door before actually do so. I agree with you wholeheartedly. where does this end? How much safer will the skies be because of this legislation. What you have is a bunch of lawyers as President and Congress wearing ties and suits who have never spent 1 hour in the left seat of an airplane telling us how to fly.
More of our liberty being taken from us. You have a better chance of walking out your door and getting killed than dieing in a plane crash. Should that warrant legislation preventing us from leaving our homes? I am afraid we are only slipping further down the slippery slope of losing our freedom under the guise of safety, fairness, et al.
Would it not be a better alternative, to increase the number of hours a Pilot it required in the right seat of the type aircraft they are working towards becoming the PIC? Also, shouldn’t this Pilot be put through the proper training and testing for this aircraft? As an Airline, should they not be responsible for verifying the ATP knowledge, and ability of a Pilot before placing them into the position of PIC? I believe there are better Regulations that could have been drawn up, if so necessary. In a Democratic Country, the opinions of a few should not be allowed to force new rules and regulations down other peoples throats. The regulations should be imposed onto the Airlines. Young/Fresh Pilots are going to find the cheapest and possibly, flight time that does not increase ability. All to find a way to the right seat.
After flying commercially in southern Africa for most of the last 20 years I’ve had a chance to observe the results of a system of difficult and time consuming academic requirements to obtain a commercial license. There is something like eight different written tests which must be passed. These tough academic requirements weeds out many wannabes without the time, money and ability to jump through all the hoops. The supply of pilots is cut way down compared to the FAA system; the pay is generally much higher and lower time pilots get “good” jobs. I did a bit of off the cuff research and determined that the accident rate in South Africa was about double the rate in the USA. Many factors play into this result obviously and it would be impossible to pin down any tight cause and effect relationship. However it would be difficult to make the case that low time pilots increase safety.
I agree with Richard that the US system is one of the safest(if not the safest) in the world. The unintended consequence of higher time requirements would be to limit the supply which as shown by the South Africa example would tend to raise the pay. Whether or not safety would improve with higher time pilots earning higher wages would be debated by all biased toward their own self interest. Working commercial pilots should laud the proposal (seems like ALPA sure has). Airline bean counters must be moaning for sure.
The point that hours alone don’t make a good pilot is right on. In the accident that caused all this the first officer had well over 2,000 hours and a second-in-command type rating in the airplane though no ATP. If an accident prompts a proposed rulemaking I don’t think it too much to ask that the proposed rule would have prevented the trigger accident. That does not appear to be the case here.
AMEN Dick, thank you for finally speaking up while so many others have remained silent!
Any idea of why our GA leaders and those organizations who are out there to promote GA and to have our best interest at heart are remaining so eerily silent? I’ve been watching the websites, and no one is saying anything or offering up opinions. At their end of their reporting, they are just saying to go to the FAA website to post your comments during the public commenting period.
I mean if we were talking about a new proposed .05% tax levied by the state for your airplane, or there’s an airport about to be closed because a developer wants to builds condos or a mall, there would be a call from all the aviation groups flooding my inbox and posted all over their websites blinking with urgency.
But we are about to witness a monumental shift in the way aviation is conducted and one of the biggest rewriting of the rules in decades and all I hear is crickets.
Your insight would be greatly appreciated.
And let’s not forget the crew of Air France 447 who made similar mistakes as the Colgan crew. If I’m not mistaken, there was over 30,000 hours of experience in that cockpit.
I think Jeff’s point is one of supply and demand. If the pilot population shrinks as a consequence requiring higher qualifications, than qualified pilots are in greater demand. The reason why you can have it both ways is that pilots are grossly under-compensated compared to say, Airline CEOs. Compare USAirways’ CEO salary to Southwest’s, and you can quickly see which airline values all of its employees.
The reality is that pilots are more eager to be in cockpits than executives are to be in offices, so a pilot’s passion is taken advantage of (as a professional musician, I know exactly what that is like). So, by reducing supply and making pilots more in demand, a compensation allocation shift will have to occur from the top down, but the bottom-line should ultimately not be negatively impacted (probably improved due to happier and more qualified employees).
The other side of it is that the cost of an average ticket might have to increase in order to keep up with the rising costs of running an airline. This too is not necessarily a bad thing (though as a frequently flyer, it pains me to say it!), because air travel is an amazing, technological accomplishment that saves a tremendous amount of time in most cases compared to driving–airlines really shouldn’t be in the business of competing with rental cars…it’s an economic model that just doesn’t work.
The part I don’t get is that if they want to increase the time required from 250 hours, how on earth did they come up with 1500 hours? Six times more time? Why does this not seem reasonable? Because it is not.
1500 hours is generally required for ATP, which is required for captain. So, it is an established benchmark that has been used to define a level of qualification. There are exceptions, however. For example, university program graduates can be deemed qualified with a lower number of hours.
I have always been a corporate and charter pilot in jets and turboprops. I don’t think the 1500 hour rule for first officers sounds very useful.
Having said that, I don’t use 250 hour commercial pilots for right seat work and I don’t like the idea that Part 121 operators have that option. I believe that 250 hours is too inexperienced for air carrier operations. How much more experience do they need? I wish I had an answer for that question. Perhaps something in the range of 800 – 1000 hours of flight time would be more reasonable.
I agree that the truth must lie somewhere in between. 1500 hours is clearly totally unreasonable, and won’t guarantee anything, as witnessed by Air France 447 where two very high time pilots couldn’t determine they were flying the plane into the sea. But my gut feeling tells me that 250 is too low. At least, as a frequent passenger on commercial flights and often on regionals, I always hope that the guy in the right seat doesn’t only have 250 hours of C172 time. On the other hand, the Air Force trusts its F16’s to young guys with probably barely over 100 hours. So with the proper training intensity maybe 250 is enough after all.
Back in the late 1960’s I taught at a major flight training school. I did a lot of work with first officers working on their ATP certificates. Even back then when taken out of the cutting edge airline equipment that did most of the “flying” for them the candidates were lacking in basic flying skills. Put a first officer in a Cessna 172 without an autopilot and clear them direct to an NDB with a hold was an eye opening experience!
Recently a 121 pilot told me that when he hand flew a 6month competency check rather than use the autopilot. He was chastised and told he had to do it over with the autopilot if he wanted to pass the check ride!
30,000 hours of combined flight time in the cockpit does not mean you are without risk.
I believe training pilots in basic flying skills is a key ingredient in safe flying be it 91 or 121 ops. Hours in a log book do not the pilot make! Ongoing flight training is the key from my perspective no matter what you fly. An increase in requirements to ride in the right seat of a 121 carrier is a good thing. The significant increase may be a knee jerk reaction but the basic concept is sound.
It is not the number of total hours but how they were accumulated. When Flight Safety had an Airline Transition Program, pilots from structured flight training programs were tested and graded with written and practical (simulator) evaluations. These low time pilots from schools like Flight Safety’s own Vero Beach academy and various college programs (Auburn, Embry Riddle etc) did very well in the testing and when they were selected as first officers for various regional airlines. After the program was expanded, we found that low time pilots from these programs continued to perform above those from FBO schools who went on to flight instruct. The military has recognized this for years and first tour Navy pilots with 350 hours are flying jets aboard aircraft carriers. Quality not quantity should define the hours necessary for SIC opportunities.
There are aeronautical decisions, rational decisions, and political decisions. The topic at hand concerns a political decision. I like the term “marginal utility.” If our congressmen/women understood the concept of marginal utility, and examined the facts of airline safety in the West, they would never have decided to raise flight hour requirements so arbitrarily. When the risk of airline flying is already extremely low, we couldn’t even detect the difference if that rate were halved. The change in flight hour requirements has only a downside; there is no possible detectable upside. God may want us to fly, but clearly our government does not.
In reading the the Buffalo accident transcript one thing is clearly missing. That is pilot not flying call outs.
At NetJets Standard Operating Procedures had very specific call outs for the pilot not flying on approaches. The target approach speed was Vref +or- 10 knots. Typically we called out the trend at 5 knots and the pilot flying was expected to acknowledge verbally that they were correcting. At 10 knots the pilot not flying starting becoming more insistent and repetitive on the speed call out. This was particularly true if the pilot flying did not respond verbally and correct the wayward airspeed
At no time on the tape do you hear any airspeed call outs to emphasize that the aircraft is getting slow and about to stall. A crew that follows SOPs even with lower experience can stay out of trouble. Does Colgan have SOPs and insist on strict adherence. The public information does not tell us the answers. So far the government action is knee jerk and I don’t believe that safety is advanced in a logical manner.
“Good judgement comes from experience, and often experience comes from bad judgement.”
-Rita M. Brown
Congress not Obama enacted this legislation. Where is the pilot solidarity here? We need a voice with influence to eliminate acts, like this one, and substitute it by statutory in-house training. The pilot supply is decreasing every year and the demand is forecasted to increase every year yet we allow bad rules to be entered by “meant well” ill-advised legislators. Power to the pilot!