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FAA Issues Proposed Rule Affecting Airline Transport Pilot Certificates And Training


March 5, 2012

What’s at Issue
Yesterday, the Federal Aviation Administration (FAA) published a Notice of Proposed Rulemaking (NPRM) titled Pilot Certification and Qualification Requirements for Air Carrier Operations.

Why It’s Important
This proposed rule would amend federal regulations to increase the certification and experience requirements for eligibility to act as second-in-command (SIC) in Part 121 operations.  This proposed rule also includes significant changes in the training that is required for issuance of an Airline Transport Pilot (ATP) certificate.  This rule change will dramatically alter the current training path and practices for all individuals seeking to obtain an ATP.

Major Provisions
New Requirements for Part 121 SICs
As required by the Airline Safety & FAA Extension Act of 2010 (Pub. L. 111-216), the FAA is proposing that all airline pilots hold an ATP certificate. Currently, serving as a SIC in Part 121 requires a commercial pilot certificate.  The FAA is also proposing that all pilots operating in a Part 121 environment must hold a type rating (if the aircraft requires a type rating) for the type of aircraft flown.  Currently, only the PIC would be required to hold a type rating.

Changes to the Experience and Training Requirements for ATP issuances
The FAA also has proposed significant changes to the experience and training necessary to obtain an ATP.  These changes will impact any pilot seeking to obtain an ATP certificate.

  • Proposed requirement for a minimum of 50 hours of multi-engine experience for ATP/ multi-engine applicants
  • Establishment of a new ATP Certification Training program that would require pilots seeking an ATP rating to complete significant classroom and simulator training on topics relating to air carrier operations and transport category aircraft operations.  This requirement is placed upon the student pilot, not necessarily the Part 121 or Part 135 operators.  The proposed rule would allow Part 121 and 135 operators to reduce the amount of training they provide based upon the students’ prior completion of this program.  Likewise, if a Part 135 carrier is upgrading an SIC to PIC (where the PIC position requires an ATP) the certification training program hours could reduce the hours of training otherwise required.  Importantly, the FAA is mandating that this training be conducted in a flight simulator.  No provisions for conducting this training in an aircraft are included.
  • Creation of a “restricted privileges ATP certificate.”  Under this proposal, former military pilots and graduates of a four-year baccalaureate program with an affiliated Part 141 flight training program would be eligible to receive a restricted privileges ATP certificate with only 750 and 1000 hours total time respectively.  The holder of a restricted privileges ATP certificate would be eligible to serve as an SIC in a Part 121 environment.  Such a pilot would need to meet the standard ATP eligibility requirements prior to serving as a PIC (where an ATP is required for the operation/aircraft).

NATA Position
NATA understands that the FAA is under a statutory mandate to require ATP certification for all airline pilots; however, we strongly question the rationale and impact of requiring prospective pilots seeking an ATP certificate to shoulder the cost of both new and existing training requirements themselves.  This shifting of the burden for providing airline and transport category specific training from the operator to the student pilot will have little positive impact and will reduce the overall supply of new airline pilots.  NATA will fully evaluate this rulemaking and submit formal comments to the FAA.

This notice of proposed rulemaking is open for public comment until April 30, 2012.

Staff Contact: Michael France
Director, Regulatory Affairs

Click to view as pdf.