The FAA, In an effort to enhance airline safety following last year’s Colgan Air accident in Buffalo, NY, has announced an Advance Notice of Proposed Rulemaking (ANPRM) which will be published next week in the Federal Register and will have a 60-day comment period. The FAA is soliciting recommendations to improve pilot qualification and training requirements. Specific areas that the FAA is seeking input on are:
· Should all pilots who transport passengers be required to hold an Air Transport Pilot (ATP) certificate with the appropriate aircraft category, class and type ratings, which would raise the required flight hours for these pilots to 1,500 hours?
· Should the FAA permit academic credit in lieu of required flight hours or experience?
· Should the FAA establish a new commercial pilot certificate endorsement that would address concerns about the operational experience of newly hired commercial pilots, require additional flight hours and possibly credit academic training?
· Would an air carrier-specific authorization on an existing pilot certificate improve safety?
SAFE will definitely be a part of this process and is soliciting input from it’s membership as it prepares it’s official response. I would encourage all of you to take part both in submitting your own recommendations to the FAA, as well as sharing any thoughts or comments with the SAFE committee as it prepares the official SAFE NPRM response.
Please send Doug Stewart your input (SAFE@dsflight.com) so that we can be sure to prepare a response that truly reflects the entire membership’s thoughts on this matter that will truly affect all of us.
One Comment
The next 3 paragraphs contains the description from the NTSB on the causes of the Colgan Air crash. Based on this description, I’ve added my comments:
NTSB says pilot error caused crash of Colgan Air Flight 3407: The Board added that Renslow’s response to the “stick shaker activation should have been automatic, but his improper flight control inputs were inconsistent with his training and were instead consistent with startle and confusion. The 24-year-old first officer, Rebecca Lynne Shaw, was noted for her young age and lack of experience.
The Board also concluded that “the pilots’ performance was likely impaired because of fatigue.” Renslow and Shaw had spent the night at the crew lounge at Newark Liberty International Airport in violation of Colgan Air’s company policies. However, the board voted down making fatigue a contributing factor. Shaw, the first officer, had flown the previous night on two separate planes from the Pacific Northwest where she lived with her parents. Shaw also appeared to be suffering from a bad cold.
However, the report also criticized Colgan saying that the airline, “did not pro-actively address the pilot fatigue hazards associated with operations at a predominantly commuter base.” Adding that, “Operators have a responsibility to identify risks associated with commuting, implement strategies to mitigate these risks, and ensure that their commuting pilots are fit for duty.”
ZUEGE’s COMMENTS based on the above: The last sentence is key: “Operators have a responsibility to identify risks associated with cummuting, implement strategies to mitigate these risks, and ensure that their commuting pilots are fit for duty.” Operators are already are responsible for “proactively” ensuring their pilots are trained for the flight environment the equipment they are hired to fly in, the flight systems they will be flying with and required Operators’ standard operating procedures. Performance checks are utilized expressly for this purpose; to proactively identify performance skills that may require virtual repetitive experience to maintain readiness for non-standard procedures.
FAA ANPRM QUESTION #1: Should all pilots who transport passengers be required to hold an Air Transport Pilot (ATP) certificate …. and raise the required flight hours for these pilots to 1,500hrs?
ZUEGE RESPONSE: No. The Colgan Air Captain was the Pilot In Command and had lots of experience. It was not lack of experience that caused this accident. To raise the flight hours for new pilots to reach would be financially prohibitive for the pilot market as a whole. Air carriers will have trouble affording pilots in the future if there is an extreme shortage due to this new requirement. Instead, the 121 air carriers that are hiring low-time pilots should be responsible for providing the necessary ongoing training in flight environment, flight systems and operating standards. And example of operating standards that is typically dismissed and is also a violation of the Federal Aviation Administration’s (FAA) is the sterile cockpit rule. This was reported by a NTSB board member: ” It was continuous and one-sided, with the captain doing most of the talking. It was as if the flight was just a means for the captain to conduct a conversation with this young first officer.” Standard Operating Procedures. In my opinion, if any air carrier is unable to afford ongoing crew training, they should not be in the business of flying passengers.
FAA ANPRM QUESTION #2: Should the FAA permit academic credit in lieu of required flight hours or experience?
ZUEGE RESPONSE: No. The required minimum hours should be just that …. required minimum hours.
FAA ANPRM QUESTION #3: Should the FAA establish a new commercial pilot certificate endorsement that would address concerns about the operational experience of newly hired commercial pilots, require additional flight hours and possibly credit academic training?
ZUEGE’s RESPONSE: No. Again, it wasn’t lack of experience that caused the Colgan crash. As an instructor, the Commercial Certificate is an attractive certificate to endorse after an instrument rating. The usually very new pilot that just completes an instrument rating has had a least 40 hours of keeping their “heads in the cockpit” and their eyes on the instrument panel. This is great for learning how to control the airplane and navigate by but hazardous in VMC when flying VFR. The Commercial training gets their “heads out of the cockpit” again and looking for traffic. It adds to the culture of safety progression of training for ALL aviators.
Once again; when a low-time commercial pilot is hired by any commercial Operator, it is the Operator’s responsibility to provide the training necessary. There are a variety of aircraft systems out there …. too numerous to add to a generic Commercial Knowledge test … not to mention too expensive for actual training. It must fall on the shoulders of the 121 and 135 carriers to do this training extensively based on the equipment and enviroment that is specific to their company.
FAA ANPRM QUESTION #4: Would an air carrier-specific authorization on an existing pilot certifidate improve safety?
ZUEGE’s RESPONSE: Operators that hire pilots should be providing all the training necessary for those pilots to perform legally and safely.