Pilot Certification and Qualification Requirements for Air Carrier Operations

            As we have recently found out, the FAA has issued the final ruling on the Pilot Certification and Qualification Requirements for Air Carrier Operations here. After Congress mandated the FAA to make a change to the then current requirements for First Officers, everyone in the industry knew they would require ATP certificates for all crew members in the cockpit. This news was a shock to the aviation community; how would someone be able to pay for flight training and be able to get enough flight time to meet the stringent requirements of the Airline Transport Pilot certificate? The FAA responded with a promise to have a Restricted ATP for applicants that graduated with a four year degree in aviation. They stated that the hour requirements would be reduced and said nothing else except the fact that they would have to be a graduate of an accredited four year program. Now, the ruling has come out, and of course, as the federal government always does, they have messed it up.

            First of all, the Federal Aviation Administration released the final ruling mere weeks before it was to take effect. For a ruling of this size that would affect so many people, they should have given at least a year before implementing any changes. Congress gave the FAA until the 1st of August of this year to put into operation these amendments, therefore I am not suggesting that the FAA should have postponed the execution of the final ruling until a year from now, but I am saying that they should have published the final ruling a year ago. That would have given flight schools and the students enrolled in flight schools a chance to plan ahead for the future. To release the final ruling just before it is to take effect is absurd.

            Another point is that the FAA failed to give a full picture of this restricted ATP until the final ruling was published. Up until the final ruling, it was thought that the only requirement to fall under this new restricted ATP was to be a graduate of an accredited four year institution. Now we finally have the full picture; there are many levels to the restricted ATP. I will not get into all of them but know that there are other situations in which one could get a restricted ATP at other minimums other than the one I am about to discuss. If one was to graduate from an accredited four year university with a bachelor's in some sort of aviation flight major and graduate from 141 instrument and commercial courses while doing their flight training, then they would only need 1000 hours total time and 200 hours cross country flight time. This is a great alternative to the normal ATP which requires 1500 hours total time and 500 hours cross country. Although this was a step in the right direction, the FAA failed to advise student pilots ahead of time to get their licenses under a 141 flight school. This leaves a set of pilots that have already gotten their ratings under part 61 instead of 141 because they never thought that it would benefit them to go the 141 route. If they knew ahead of time that this would one day be a factor, then they surely would have gone the 141 route. Unfortunately for me, I am one of these pilots; I am certified to teach commercial pilots under 141 curriculum, yet because I myself did not train commercial under a 141 syllabus, I do not qualify under the 1000 hour rule. If the FAA had published the final ruling a little over a year ago, I could have switched to a 141 course for my commercial rating and qualified. This is because I already did my instrument rating under 141.

            Ultimately, the lack of a final decision with enough time for adjustment in the industry and the fact that the FAA decided out of the blue to require pilots to complete a 141 course for both instrument on commercial certificates is ill-advised. By doing this, they have failed a large group of pilots that have not yet gotten into the airlines but already have their commercial licenses. Although I believe this is a ridiculous oversight by the FAA, there is some consolation for this group of pilots.

            If one does not qualify for this part of the (R)ATP, then they can still benefit from it. Anyone, without any requirements as far as graduating with an aviation degree or from a 141 flight program can qualify for a (R)ATP with1500 hours, but with only 200 cross country hours instead of 500. This is a sufficient alternative to flight instructors who build very little cross country time when training applicants in a local environment. When instructing, one stays mostly in the pattern at a local airport or one instructs in a practice area to perform maneuvers with the student, this is almost always accomplished within the 50 nautical mile radius in which a cross country flight is usually defined. The only chance a flight instructor gets to build cross country flight time is when he/she has to go with a student to demonstrate how to fly a cross country flight without getting lost. This is minimal time when looked at in a big picture; with one student, an instructor may only build two hours of flight time, while they have 30-40 hours of instruction locally. Basically, if a pilot builds time to get to the airlines by instructing, it would take well over 2000 hours total time to get the 500 hours cross country time. 

            In the end, I believe that this whole requirement is part of a knee-jerk reaction by Congress after the Colgan Air crash in Buffalo, New York. Also, I believe that the FAA could have implemented the regulation in a more logical fashion. In the end, most pilots will overcome this new obstacle because they will conform to the new training requirements and get into the airlines in a reasonable time. It will just be more difficult for the rest of us instructors to accept the fact that the very same commercial pilots that we are currently training under part 141 may, in fact, get hired by an airline before us.