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?