PILOT CERTIFICATION REQUIREMENTS FOR AIR CARRIER OPERATIONS- Public Comment Process

[JonnyKnoxville]

http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480a8faeb

Your chance to submit your comments. Here is what I wrote:

As an Airline Pilot, I strongly feel that this proposed rule does not go far enough! A pilot with 1500 hours is a very new pilot with limited experience. The Airline Transport Pilot (ATP) Certificate (which requires 1500 hours) should be an absolute minimum qualification to earn money as a pilot in any pilot position throughout this country without exception. The fact that pilots who only hold a commercial pilot certificate can fly an aircraft for compensation needs to be addressed. There just is not enough training that has taken place for a pilot to take on the added pressures of flying for compensation when their training base and operational knowledge are so limited.

Furthermore, I am outraged to hear that exceptions are being considered to protect the universities and flight schools that have aviation programs. An aviation educational program and it's financial success should not be of a higher concern than that of the flying public's safety! The idea of having programs with training exemptions built into them is just a loophole that would put inexperienced pilots in an airline's flight deck. Just because someone reads books and takes test in a classroom on flying does not mean that he/she is capable of flying an airplane. Even with today's modern flight simulators and advanced training technics, nothing replaces the real-world experience of being trained in the flight deck of a real aircraft.

I strongly feel that these changes must take place to advance aviation safety especially at a time when many highly experienced pilots are starting to retire. Please feel free to contact me if you wish to discuss this issue in greater detail.

 

[Flyby1206]

Wouldnt it make sense to require an Airline Transport Pilot Certificate to fly an Airline Transport Category aircraft? Flying SIC for a 121 carrier should require the ATP, but they ATP cert needs some serious overhaul too in terms of min requirements (areas of operating experience) in addition to knowledge requirements (its a freakin joke that you can purchase the Gleim and have every question word-for-word to pass the written).

The commercial pilot certificate reqs should stay right where they are, and it should be kept as a license for those who want to work in other areas of the aviation industry (CFI, banner tow, night freight/light twin, small corp aircraft, etc).




Also- goto http://www.regulations.gov/search/Regs/home.html#home and search for FAA-2010-0100. Then click the submit comments to add your 2cents. If you download the actual docket it references specific questions they want to hear comments about (use the question numbers when submitting comments)

 

[Raoul Duke]

military guys get paid to fly, do they need 1500 hours before getting certified?

 

[Abernathy]

Why did you post this in both forums. I said it there, and I'll say it here. If you require 1500 hours to get paid for any flying job, then everyone would have to pay out of pocket for 1500 hours of flying time.

 

[luckytohaveajob]

military guys get paid to fly, do they need 1500 hours before getting certified?

Military pilots and planes are expendable. Passengers and airliners are not.

 

[JonnyKnoxville]

military guys get paid to fly, do they need 1500 hours before getting certified?

They also get paid to train. 1500 hours seems low to fly in combat but some on here would know more about the military flying than I would. I was referring to civilian training. When a military pilot comes out of the military with a full career and looking for an airline job I would hope he/she has 1500 total time.

 

[JonnyKnoxville]

Why did you post this in both forums. I said it there, and I'll say it here. If you require 1500 hours to get paid for any flying job, then everyone would have to pay out of pocket for 1500 hours of flying time.

WRONG! The airlines would have to pay to get someone to 1500 hours.

Just like doctors who come out of Med school with an average of $200,000 in student loan debt have hospitals that offer to pay that debt back if the doctor agrees to go to work for that hospital.

Higher pilot requirements in Europe caused airlines in Europe to hire pilots with zero time and train them all the way through.

Supply and Demand

Right now, there is a major oversupply of pilots that continue to drive down wages and benefits.

If that supply is limited by raising the barriers to enter this career, pilots will be in higher demand and upward pressure would be placed on pay and benefits.

 

[Flyby1206]

Supply and Demand

Right now, there is a major oversupply of pilots that continue to drive down wages and benefits.

If that supply is limited by raising the barriers to enter this career, pilots will be in higher demand and upward pressure would be placed on pay and benefits.

Beware the laws of unintended consequences. Higher pay means less jobs. We are seeing that play out currently with mainline vs regional carrier outsourcing. If those regional are forced to raise pay then who will they outsource to? Nobody. Instead those routes will disappear and the demand for pilots will disappear (creating a new glut of pilots, vicious circle).

 

[rigger]

Beware the laws of unintended consequences. Higher pay means less jobs. We are seeing that play out currently with mainline vs regional carrier outsourcing. If those regional are forced to raise pay then who will they outsource to? Nobody. Instead those routes will disappear and the demand for pilots will disappear (creating a new glut of pilots, vicious circle).

Then create away.......then only the best most qualified will get the seat and the pay will hold as it does in every other "real" job in America. experience, work ethic, and ambition = pay.... not date you got hired (except in this industry...a little bass ackwards!

 

[doh]

1500 and an ATP for 121. No exceptions.

 

[Raoul Duke]

They also get paid to train. 1500 hours seems low to fly in combat but some on here would know more about the military flying than I would. I was referring to civilian training. When a military pilot comes out of the military with a full career and looking for an airline job I would hope he/she has 1500 total time.

military guys become operational way below 1500 hours.

 

[scoreboardII]

A pilot with 1500 hours is a very new pilot with limited experience.

You should edit to state

A civilian trained pilot with 1500 hours is a very new pilot with limited experience.

Military pilots and planes are expendable. Passengers and airliners are not.

You sure about that?

 

[surveypilot]

One of the things that most people miss is that it is not just the total time that is crucial. It is the PIC time. One of the major problems with hiring guys straight out of a 141 flight school and putting them in the right seat of an RJ, is that when they upgrade to Captain they have 0 PIC time. They do not have the decision making experience necessary to handle the job. The ATP should be 1500 hours of PIC time, not total time.

 

[ACL65PILOT]

It in reality is not flight time compleatly. It is the ability for said pilot to think, analyze, problem solve and do all of it while still flying an airplane. Pilots can do that at 10 hrs or 10,000. More time generally allows more experiences and the ability to see more things, but it my no means should be the only yard stick to measure a pilots ability. I have seen both great and horrible situational awareness from people on both ends of the spectrum.

Why do you think DAL does all of this crazy testing? There is a reason for it. It weeds out people that have processors that would be served doing something besides flying their passengers.

 

[T3700]

The FAA has no jurisdiction over military flying or military pilot certification.

 

[cunchos]

We as pilots need to let our egos down a bit.... I know that is much to ask...... having 1500 hr and a ATP doesn't make you a good pilot. It make you a pilot that at least can learn in a plane. Makes that learning curb less of a risk to the public. We all learn something every time we go in the air. It doesn't mater if you have 1hr or 20000 flight hours, we all learn something. With that said, what you learn is quite different based on your time and experience. ATP and 1500hr gets you thinking outside the plane and into situation awareness. In my opinion that is the least thing a pilot should have if they are flying my family around.

 

[maru657]

Classroom training instead of experience was a trend started long ago in order to to meet manpower requirements. On the whole it sort of worked,,,as long as the new pilots were exposed to greater levels of experience as long time co-pilots with highly experienced captains. With de-regulation and the resultant degradation of labor law it unraveled very quickly. Remember the jokes about Delta in the 80's? Then American in the 90's and their recent spate of landing problems. Almost catching up to SouthWest. The Colgain pilots were simply an egregious example of that attitude. Delta's testing and the pilot puppy mill training schools are just another way of avoiding the most expensive costs a corporation can have. The costs of paying for real experience.

 

[T3700]

The only reason the FAA wants to include academic training is because of lobbying efforts from places such as Embry-Riddle. I guarantee that the FAA has been fielding "enquiries" from the Florida congressional delegation. Anyone who thinks differently is fooling themselves. 1500 hours in an aircraft lets you see things that can never be covered in a classroom, that's why it is called experience.

 

[GoodTimes]

There's no substitute for experience. Plain and simple.

 

[ACL65PILOT]

The only reason the FAA wants to include academic training is because of lobbying efforts from places such as Embry-Riddle. I guarantee that the FAA has been fielding "enquiries" from the Florida congressional delegation. Anyone who thinks differently is fooling themselves. 1500 hours in an aircraft lets you see things that can never be covered in a classroom, that's why it is called experience.

Try the ATA. The need to get bright eyed pilots with 200K of debt that are willing to fly for 19 bucks an hr. Not going to get that without ab initio.

 

[instructordude]

1500 hr and an ATP with exceptions for Academy grads and qualified MPL candidates.

 

[ACL65PILOT]

MPL is the same as ab initio. Do it right or do not do it at all.

Military pilots would more than meet ATP mins after their service.

 

[Flyby1206]

Military pilots are great candidates for being an airline pilot, but after having trained several fighter pilots to get their ATP cert I have found there are a lot of areas where their mil experience does not transfer to the general aviation/121 world. Weight&balance is a foreign concept, fighter pilots point the nose and push the power to go any direction they want without regards to CG. Steep turns take on a whole new meaning when they are used to the roll rate of an F-16. FARs are a completely new arena as well. Vmc is new as well, when coming from a centerline thrust jet.

That being said, what makes a mil pilot desirable as a candidate is you can give them material to study and they will come in the next day having learned the entire book cover to cover. They are extremely trainable and able to absorb huge amounts of new material faster than someone with a non-mil background. For every hour of mil flight time in their logbook they spend several hours in a classroom preparing for that flight.

 

[fandango]

Ill take the guy that got the couple of hours experience for the couple of hours logged. Not the guy that needed the multiplier, or the couple of hours reading about the one hour of flying. There needs to be a one to one ratio of learning to seat time......nothing replaces your butt in the seat.

 

[scoreboardII]

Ok fandango, 11000 hours of "flying" a 737 equals at best 8000 legs, you swap off legs giving you as pilot 4000. Each leg is at best 5 minutes of flying after takeoff to at best 5 minutes flying during landing, giving you a grand total of 666 hours of "butt in the seat actually flying it rather than letting George fly it".

The other 10,333 hours is sitting there watching the old fart next to you sleep...

I'll take the mil guy who had his hand on the stick for 1,500 hours thank you.

 

[waveflyer]

yeah- 1500 hours on the stick is really applicable to airlines. Glad this has devolved into the old civ v mil debate.

I had 300 hour guys in the right seat that were fantastic. I've had 3000 hour pilots in right seat that were awful. Nothing replaces talent and attitude in this gig. Nothing. We need a process that weeds out those who don't have talent. Interviews are supposed to the trick. So are checkrides. They all lack under cost pressures. It's like the rest rules. We all want to dumb this issue down to a couple tag lines- that's not what this issue will ever boil down to.
We need experience- AND PIC experience-*(I completely agree with the poster above!) i've learned a hell of a lot of judgement flying solo part 135 and part 91. We need better academics- there is too wide a range on academics in civilian aviation. Go JAA or model it after the NAVY. There is a huge difference between a graduate of a disciplined 141 school and many podunk flying clubs. But you can't stereotype. We can't let Riddle convince regulators that what they do actually works... the BS 'they can build the plane, but they can't fly it worth a damn' is spot on- and we have to protect against that.

We have to make regulations that fit the many different paths to excellence that we find in this career.
Bottom line- whether you're military or civilian, if you suck and lack talent- we need a process that gets rid of you.
Requiring better academics helps do that. Requiring PIC time before entering the 121 world does that.

 

[ACL65PILOT]

How did I know this would fall under the Mil, Civvie debate.

Really?

Different flying, and different areas of expertise. I am a civvie and the difference is the military guy can do my job but I cannot do his.

See there it is said. Get off this stupid crud!

 

[maru657]

How did I know this would fall under the Mil, Civvie debate.

Really?

Different flying, and different areas of expertise. I am a civvie and the difference is the military guy can do my job but I cannot do his.

See there it is said. Get off this stupid crud!

Having suffered through military training, I'll tell you that yes you probably could do "his" job. The military trains constantly. The quality of the training may sometimes be in question, because sometimes it's scheduled just to fill time and create the image of busy bodies but I've always wondered why the military did not try to hire pilots with prior experience. After all teaching a competent and experienced pilot to be "military" should be far easier than teaching the "military" mind how to actually fly. I sat in on a conversation once when a young man tried to describe how an Airbus operated to a very old retired pilot. The old man, an Icon of aviation listened patiently and then stated " Ahh, so they finally built an airplane for Arabs and military pilots".

 

[Beaver79]

Having suffered through military training, I'll tell you that yes you probably could do "his" job. The military trains constantly. The quality of the training may sometimes be in question, because sometimes it's scheduled just to fill time and create the image of busy bodies but I've always wondered why the military did not try to hire pilots with prior experience. After all teaching a competent and experienced pilot to be "military" should be far easier than teaching the "military" mind how to actually fly. I sat in on a conversation once when a young man tried to describe how an Airbus operated to a very old retired pilot. The old man, an Icon of aviation listened patiently and then stated " Ahh, so they finally built an airplane for Arabs and military pilots".

The military does not discriminate against pilots who join with prior experience. To be honest though - the prior flying experience is not a tremendous help besides the fact you know basic aircraft control. It's a different mindset, a different process, with vastly different rules. You must have an aggressive mindset - you aren't an educated pax with controls. In the military you MUST know how to fly the plane (helo) to the edge of the spectrum because at some point you will need to - both to accomplish the mission and the purpose of survivability. Simple skills like low level flying and tactical approaches demand a hell of a lot more than an ILS.

And inicidentally flying hours have little correlation to knowledge and experience. In most cases, I'd take a 200 hour freshly trained military guy or gal than a 1500 dual given pilot. I've sat in the right seat of a 121 carrier with guys and gals who had 10,000 hours. Most were damn good pilots - others had 10,000 hours and I questioned what box of cereal they got their certificate from. I've done both sides and the training given in the military is substantially better than the civilian side. I'm not saying it doesn't have its strange twist on things but regardless, it is a known training structure with mandatory minimum requirements. I'd like to see the FAA institute something along those lines - a mandatory minimum training - not vague like so many of the regs currently in place. And I see it is typical political bull that the aviation academy's may be getting around some of these new proposals. Just some food for thought.

 

[ACL65PILOT]

Having suffered through military training, I'll tell you that yes you probably could do "his" job. The military trains constantly. The quality of the training may sometimes be in question, because sometimes it's scheduled just to fill time and create the image of busy bodies but I've always wondered why the military did not try to hire pilots with prior experience. After all teaching a competent and experienced pilot to be "military" should be far easier than teaching the "military" mind how to actually fly. I sat in on a conversation once when a young man tried to describe how an Airbus operated to a very old retired pilot. The old man, an Icon of aviation listened patiently and then stated " Ahh, so they finally built an airplane for Arabs and military pilots".

I know, I am just totally over this military versus civilian thing. Both pilots were trained with a specific mission in mind.

I get the cramping three weeks of material in to six months as well. My point was that I am not applying for a Viper job, and we are all talking about qualifications for 121 flying.

DAL like military pilots for many reasons, mainly they are trainable, mission oriented, respect authority, and do not complain. Civilian pilots can be all of that too, but until the last decade they had issues with civilian guys and their base line training. With all of these ab initio courses etc, the baseline for a civilian guy has gone up way up. Overall they can get plug in and learn, do all that the military guys can do, plus if they are going from a regional to a major, the biggest issue which is ground ops is already figured out.

In the end, we are all pilots, we all have a background that has pro and cons for 121 flying, but that is what training does. It gets rid of our rough edges.

What this thread is about is finding something to add to the ATP requirement that is more than just flight time. It needs to be knowledge based. I think a board certification is a good start.