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How Many Hours Are Enough?

July 19th, 2010

Jul 9, 2010

David Collogan

A notice from the FAA that it may require pilots to meet tougher minimum training and experience standards before serving as copilots in FAR Part 121 flight operations is generating considerable angst throughout the aviation community. Some fear the more-stringent standards could significantly curtail the number of student pilots, siphon experienced pilots to the airlines from other segments of the industry and ultimately result in a nationwide pilot shortage.

The concern results from an Advance Notice of Proposed Rulemaking published in response to the NTSB’s investigation of the Feb. 12, 2009, crash of a Colgan Air DHC-8 into a house during a night approach in light snow and mist to Buffalo-Niagara, N.Y., International Airport.
David Collogan

The NTSB determined that the captain’s inappropriate response to the activation of the stick shaker led to an aerodynamic stall from which the airplane did not recover. Among the contributing factors cited were the flight crew’s failure to monitor airspeed and adhere to sterile cockpit procedures, and the captain’s failure to effectively manage the flight. An examination of the captain’s training records revealed that he had flunked numerous flight checks, some because of an inability to demonstrate proficiency in basic airmanship.

The Buffalo accident, and the multiple deficiencies revealed, would no doubt have caused the FAA to take a close look at training standards without further prompting. But the agency doesn’t have any choice. Congress is prodding the regulators to take action.

Both the House and Senate rushed to enact legislation (H.R. 3371, the Airline Safety and Pilot Training Improvement Act of 2009, and S.1451, the FAA Air Transportation Modernization and Safety Improvement Act), both mandating tougher training standards. Differences between those measures would have to be resolved in a House-Senate conference committee.

The strong congressional reaction is not surprising given the circumstances of the Buffalo crash and the publicity it received. But we must reiterate our long-held view that few creatures are more dangerous than members of Congress reacting to a high-profile event by rushing to legislate technical standards that would be best addressed by federal regulators. You see, if a federal agency proposes a regulation that turns out to be flawed, it can be fixed or amended after a public comment period. Fixing a bad law, however, is akin to parting the Red Sea — it pretty much requires a miracle.

Both the House and Senate bills essentially require all Part 121 airline pilots (including first officers) to hold Airline Transport Pilot (ATP) certificates, which could be obtained only after an applicant had logged a minimum of 1,500 flight hours. Currently, Part 121 first officers need a minimum of 250 hours. It’s worth noting that the 47-year-old Colgan Air captain had accumulated 3,379 flight hours and the 24-year-old copilot 2,244 hours.

Unsurprisingly, the FAA’s ANPRM reflects congressional will. However, a chorus of those submitting comments on the proposal emphatically rejects the 1,500 hour/ATP requirement for Part 121 first officers to occupy the right seat.

GAMA said such a requirement could result in an adverse effect on safety because “pilots would no longer focus on getting the best training to prepare them for 121 operations, but rather the cheapest and easiest.”

The Regional Airline Association echoed that concern, noting that “raising the existing, arbitrary total flight hour requirement could have the unintended and negative effect of reducing the number of highly qualified airline pilot professionals without any demonstrable safety benefit.” Simply building hours can be done quickly and cheaply “in ways that do not meaningfully prepare students for airline operations (e.g., towing banners),” the RAA said.

Using an aircraft rental rate of $90 per hour, the NATA calculated that “a pilot would be required to spend $112,500 to acquire sufficient total time to qualify for an ATP certificate and that experience would be gained in the most simple of aircraft . . . without providing any exposure to Part 121 aircraft or operating procedures.” That, said NATA, “will do little but discourage pilots from pursuing a Part 121 career.”

NATA also criticized the “piecemeal approach” of the ANRPM, which it said “will lead to the shifting of the training and evaluation burden from the air carrier to the individual pilot and likely will only exacerbate any existing issues with Part 121 pilot proficiency and professionalism.”

The AOPA said an increase in hiring requirements by the air carriers would likely discourage potential pilots from entering aviation due to higher costs and longer time to qualify. “Long term this is a problem for the entire aviation community,” the AOPA said. “With fewer student pilots, an eventual pilot shortage may occur. It may be difficult or impossible to staff the vital jobs provided by general aviation as well as the nation’s air carriers.”

The association, like many others who filed comments, observed that “experience is not measured in flight time alone. Safety is a combination of experience and training in specific aircraft type and in specific flight conditions,” which is more important than logging a specific number of flight hours.

The deficiencies uncovered in the Buffalo investigation cry out for improvements in airline training programs. Will the FAA embrace industry calls for truly effective changes that actually improve safety? Or will congressional will prevail with an overreaching total flight time requirement offering only illusory safety payoffs while dramatically increasing training costs? There’s a lot riding on the answers to those two questions.

SRIDs – What Will They Think of Next

July 16th, 2010

\”If SIDs were only applicable to radar airports why don\’t they call them \’SRIDs\’?\”*

This comment really tickled my fancy. Why?

In RSA and a number of other less well endowed countries, the powers that be (CATCOs and CAAs) decided that airports don\’t require departure procedures unless they have radar. This sad situation has been a sad one person campaign for me for some time, since, the odd educated aviator may agree \”Yes, where there are obstacles restrict an omnidirectional departure, there must be an approved departure procedure\”, but still, there are none. I still lie awake at night awaiting the time a foreign pilot – thinking an omnidirectional departure is possible, in the absence of instructions from the AIP otherwise, makes the infamous non-returnable departure into \’cumulo granitus\’.

The commenter further pointed out, somewhat correctly \”Surely it\’s more important to have a DP at an airport that doesn\’t have radar?\”*

Well Yes! Nice to have someone thinking logically!!

I\’d love to hear what the aviation people out there think about this one, especially those from countries that do understand what and why departure procedures are applied.

*These comments were from Richard Moss: Master MCC and fixed base sim instructor.

References: ICAO PANS Ops Section 3 Volume I and II

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