General Discussion and Request for Information
In this ANPRM, the FAA requests comments and recommendations on the following concepts for the purpose of reviewing current pilot certification regulations. The sequence of these proposals does not reflect any specific FAA preference. When submitting comments on any of these concepts, please refer to the specific question number.
1. Requirement for all pilots employed in part 121 air carrier operations to hold an Airline Transport Pilot (ATP) certificate with the appropriate aircraft category, class, and type rating, or meet the aeronautical experience requirements of an ATP certificate.
Section 61.155 describes the aeronautical knowledge required to qualify for an ATP certificate. Section 61.159 describes the aeronautical experience requirements, which specify a minimum of 1,500 flight hours. Currently, a pilot who serves as a Second-in-Command (SIC) pilot crewmember is required to hold an instrument rating and commercial pilot certificate. We request comments and recommendations on the following issues relating to the option of requiring ATP certificates for all pilot crewmembers in part 121 air carrier operations:
1A. Should the FAA require all pilot crewmembers engaged in part 121 air carrier operations to hold an ATP certificate? Why or why not?
1B. If a part 121 air carrier pilot does not hold an ATP certificate, should he or she nevertheless be required to meet the ATP certificate aeronautical knowledge and experience requirements of § 61.159, even if he or she is serving as SIC? Why or why not?
2. Academic Training as a Substitute for Flight Hours Experience.
The FAA seeks public comment on the concept of permitting academic credit in lieu of required flight hours or experience. In particular, we request comments on the following issues:
2A. Are aviation/pilot graduates from accredited aviation university degree programs likely to have a more solid academic knowledge base than other pilots hired for air carrier operations? Why or why not?
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?
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?
3. Endorsement for Air Carrier Operations
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 successful 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:
3A. Should the FAA propose a new commercial pilot certificate endorsement that would be required for a pilot to serve as a required pilot in part 121 air carrier operations? Why or why not?
3B. If so, what kinds of specific ground and flight training should the endorsement include?
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 minimum 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?
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?
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.
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?
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?
4C. Should such an authorization require a minimum number of flight hours? If so, how many hours should be required?
5.Other actions.
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.
5A. Can existing monitoring, evaluation, information collection requirements, and enforcement associated with pilot performance be modified to improve pilot performance?
5B. If so, what specific modifications should be considered?