Notice of Proposed Rule Making Forum

Agenda• Events leading to the NPRM• Details of the proposed rule• Discuss impact on industry• Discuss impact on collegiate flight program• Explore and share research in regards to issue• Illustrate how to comment on the rule

HR 3371• Background leading up to proposed Legislation

– Last six airline crashes involved regional carriers– February - Colgan Air Accident– May 2009 – NTSB held three day hearing on Colgan

Accident– June 2009 – Both House and Senate started holding

hearings on Regional Airline Safety– June 2009 – FAA Administrator (Babbitt) announced ‘FAA

Call to Action”– Introduce HR 3371 – Late Summer 2009

• Link to Bill

HR 3371• Initial Bill stated: (July 2009)

– SEC. 10. FLIGHT CREWMEMBER SCREENING AND QUALIFICATIONS– (2) MIMIMUM REQUIREMENTS.—

• (B) ALL FLIGHT CREWMEMBERS- Rules issued under paragraph (1) shall ensure that, after the date that is 3 years after the date of enactment of this Act, all flight crewmembers—

– (i) have obtained an airline transport pilot license (sic) under part 61 of title 14, Code of Federal Regulations; and

– (ii) have appropriate multi-engine aircraft flight experience, as determined by the Administrator.

– Many sections of Bill really good for safety!– Collegiate Aviation, concerned about ATP…

Advance Notice to Proposed Rulemaking

• FAA put out an ANPRM…• Encouraged public comment• Commencement of Pilot Source Study…

FAA FOQ Aviation Rulemaking Committee (ARC)

• Started work in mid-July 2010– Aircraft Owners and Pilots Assoc. (AOPA)– Air Line Pilots Assoc. (ALPA)– Air Transport Assoc. (ATA)– Aviation Accreditation Board International (AABI)– Coalition of Airline Pilots Assoc. (CAPA)– National Aviation Disaster Alliance/Foundation (NADA/F)– National Business Aviation Assoc. (NBAA)– Pilot Career Initiative (PCI)– Regional Air Cargo Carriers Assoc. (RACCA)– Regional Airline Assoc. (RAA)

Enter H.R 5900• Airline Safety and FAA Extension Act of 2010

– Introduced to House on July 28, 2010– Passed House on July 29, 2010– Considered in the Senate on July 30, 2010– Passed Senate on July 30, 2010– Signed by President on August 1, 2010

• Public Law 111-216

Public Law 111-216 Main Sections• Title I – Airport and Airway Extension• Title II – Airline Safety and Pilot Training Improvement

– FAA Pilot Records Database– FAA Task Force on Air Carrier Safety and Pilot Training– Flight Crewmember mentoring, professional development

and leadership– FAA rulemaking on training programs– Pilot Fatigue– Safety Management Systems, ASAP and FOQA

Implementation Plans

Public Law 111-216 Main Sections– Flight Crewmember Screening and Qualifications

• All flight crewmembers must have obtained an ATP certificate

– Airline Transport Pilot Certification• Sufficient Flight Hours, as determined by Administrator

– Shall be at least 1500 – Credit toward flight hours

» Administrator may allow specific academic training courses to be credited toward the total flight hours…

FAA Impact due to Law

After a long awaited release…

• Pilot Certification and Qualification Requirements for Air Carrier Operations

Main Areas of Proposed Rule• ATP Certificate for all pilots operating

under Part 121• Requiring 50 hours of multi-engine time if

applying for ATP in a multi-engine aircraft• Aircraft type-rating for all pilots operating

under Part 121•

Main Areas of Proposed Rule• ATP Certification training program for an

Airplane Multiengine to include…– Currently nothing defined– Academic Portion:

• 24 hours of classroom instruction– High altitude ops, meteorology, air carrier operations

– Flight Portion:• 16 hours of flight training

– 8 hours in a Level C or higher FFS– 8 hours in Level 4 or higher

– This would make you eligible for the ATP Written Exam

Main Areas of Proposed Rule• ATP certificate with restricted privileges

based on Academic or Military Training– Bachelor’s degree with an aviation major from

an accredited 4-year institution – Commercial certification obtained through

Part 141 Training– Aeronautical Experience:

• 1000 hours TT• 325 hours Cross-Country• 100 hours night• 75 hours instrument• 50 hours multiengine

Main Areas of Proposed Rule• Minimum of 1000 hours of Part 121 flying

to serve as PIC in a Part 121 operation.

How does this impact the Industry?

Industry Implications• Existing First Officers• Current hiring• Future hiring (final rule)

Industry Implications• Existing First Officers

– ExpressJet• 1526 FOs surveyed• 1328 do not have an ATP

– Air Wisconsin• 78% of it’s FOs do not have an ATP

• Have to start training programs for existing first officers for ATP and Type ratings– ATP written complete before all recurrent training

Industry Implications• Current Hiring

– Position new hire first officers with the Aug. 1 2013 ATP requirement

• ExpressJet hiring minimums at 1100 hours– Time to complete training– Average 37.5 hours/month on reserve– Minimum time for hiring will increase as they get

closer to Aug. 1 2013 (1200, 1300, 1400, 1500)– Currently “0” applications on file that meet this

minimum.

Industry Implications• Future hiring

– Minimum as stated in NPRM will be 1000 (college) 750 (military)

– Plan to incorporate the ATP Certification Training Program (24 hours ground/16 hours sim.)into their training foot print – may or may not be allowed based on NPRM wording

– Screened – Hired - ATP Training - ATP written - ATP Flight training - Certification – 121 training – start line flying (IOE)

Industry Implications• Regional Air Cargo Carriers Association

– Pursuing lowering Part 135 Cargo ATP down to 800 hours

– Trying to make their type of flying more manageable and attractive?

• PL11-216 and this NPRM are affecting your careers right now

Implication for a Collegiate Flight Program

Value of Research in Response to FAA’s NPRM

Pilot Source Study

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Arizona State University – Dr. Mary Niemczyk (Assistant Professor, Air Transportation Management )

Auburn University – Dr. Raymond A. Hamilton II (Associate Professor of Aviation Policy)

Embry-Riddle Aeronautical University – Dr. Guy M. Smith (Associate Professor of Aeronautical Science)

Southern Illinois University – Dr. David A. NewMyer (Professor of Aviation Management & Flight)

University of North Dakota – Dr. Elizabeth Bjerke (Associate Professor of Aviation)

Research Team

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9 Predictors (Independent Variables)

• Year Hired• College Degree• Aviation Degree• AABI Flight Program• Military• Source of Pilot Training• Flight Instructor• Total Flight Hours• Previous Experience

2 Outcomes (Dependent Variables)

• Extra Training Events• Completions

For each Predictor Variable,we show:1. The question2. A description of the variable3. The statistical test results4. The research conclusion

For each Outcome Variable,we show:1. The question2. A description of the variable

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AABI FlightDerived Variable (Only those

programs in the data set that meet the AABI Program Accreditation

Criteria for Flight Education)

Predictor Variable Outcome Variable

Statistical Test Test Statistic Significant?

AABI Flight Programs

Extra Training Events

t-Test t = 6.09*** Yes***p < .001

AABI Flight Programs

Completions Chi-Square 2 = 16.43*** Yes***p < .001

• AABI flight programs produced fewer extra training events

• AABI flight programs produced comparatively fewer incompletes

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PILOT TRAINING:Where did this pilot get Advanced Pilot Training (beyond Private Pilot)?

(N = 2156)

Predictor Variable Outcome Variable

Statistical Test Test Statistic Significant?

Source of Pilot Training

Extra Training Events

ANOVA F = 10.39*** Yes***p < .001

Source of Pilot Training

Completions Chi-Square 2 = 30.16*** Yes***p < .001

• Pilots trained in college had fewer extra training events than non-college pilots

• Pilots trained in college had comparatively fewer incompletes 29

Aviation Degree:Derived Variable (any degree

that contained words like aviation, flight, airport, pilot, etc.

- these are not all flight degrees)

Predictor Variable

Outcome Variable

Statistical Test Test Statistic Significant?

Aviation Degrees Extra Training Events

t-Test t = 1.71* Yes*p < .05

Aviation Degrees Completions Chi-Square 2 = 8.13** Yes**p < .01

• Aviation Degrees produced fewer Extra Training Events

• Aviation degrees produced comparatively fewer incompletes. 30

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TOTAL HOURS:How many Total Hours did the pilot have at the beginning of training with your airline? (N =

2150)

Predictor Variable

Outcome Variable

Statistical Test Test Statistic Significant?

Total Flight Hours

Extra Training Events

ANOVA F = 3.31* Yes*p < .05

Total Flight Hours

Completions Chi-Square 2 = 17.24** Yes**p < .01

• Pilots with 501 to 1000 hours had the fewest extra training events.

• Pilots with 501 to 1000 hours had comparatively fewer incompletes.

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TOTAL HOURS:(Continued)

• Effect of pre-employment total flight hours, in order of performance:

• Group 1: 501 to 1,000 hours• Group 2: 178 to 500 hours• Group 3: 1,001 to 1,500 hours• Group 4: > 1,500 hours

Note: The most significant difference was between Group 1 and Group 4 for both Extra Training Events and Completions.

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• More detailed text was published in FAA’s International Journal of Applied Aviation Studies:– http://www.faa.gov/about/office_org/headquart

ers_offices/arc/programs/academy/journal/pdf/Summer_2010.pdf

Impact of ATP Requirement on CFI career Progression to

Part 121 Carriers

Conducted by,Elizabeth Bjerke, Ph.D.

Daniel MalottUniversity of North Dakota

Methodology• Participants

– Current CFIs employed by UAA member collegiate flight programs

• Materials– Electronic survey including demographic

information, aeronautical experience and career aspirations

• Procedures– Email was sent to CFIs via an institutional

representative

Results• 240 Responses from 17 different

collegiate flight programs– University of North Dakota– Embry Riddle Aeronautical University (Prescott and Daytona)– Purdue– Western Michigan– Arizona State University– University of Oklahoma– Kansas State – Salina– Westminster– Indiana State University– South Dakota State University– Middle Georgia College– Florida Institute of Technology– Saint Louis University– Jacksonville University– Rocky Mountain College– Northwestern Michigan College

Current FAA and ICAO ATP Requirements

• Differences FAA and ICAO–Cross-Country Aeronautical Experience –Cross-Country Definition

Survey Results (n=240)• Average Total Time

– 986.6 hours• Average Cross-Country Time

– 236.6• Only equates to 24% of total time• ATP requires that 33.3% of total time be

cross-country• CFIs do not conduct a lot of cross-country

operations• Will need over 2,000 hours of total time to get the

needed 500 hours of cross-country for FAA ATP

NPRM 61.160 (Restricted ATP)• Aeronautical Experience Requirements

– 1000 Total Time• 325 Cross-Country

• CFI’s teaching in a collegiate program will have to acquire 1,354 hour of total time, to meet the 325 hours of cross-country given the percentages the research found.

Response for NPRM• Match the FAA ATP Requirements to ICAO

– 200 hours of Cross-Country– Change the definition so it does not have to

be 50 nm• Reduce the Cross-Country time for

Restricted ATP to 200 hours (match ICAO min.)– Can assume that once hired by a Part 121

Carrier at 1000 hours, the next 500 hours will be cross-country

Next Step

FAA seeks comment on the following:

• Throughout the NPRM you will see…– Is a minimum of 1,500 hours adequate in

order to receive an unrestricted ATP certificate? Why or why not?

– As a result of the new ATP requirement for pilots in part 121 operations, what will be the impact on pilot supply for part 121 operations? For part 135 operations? For part 141 pilot schools? For Part 142 training centers?

Process to Comment• Deadline for Public Comments:

– April 30, 2012• Who can comment???

– The Public• The process

http://www.regulations.gov/

Questions and Discussion