The FAA’s Final
Rule on pilot certification came into effect August 1st, 2013, with
it, new limits were set on the minimum requirements to become a first officer
for a part 121 airline. The effects of this regulation on the aviation program
here at Eastern Michigan University will be very significant and will be
further discussed.
Since
Eastern is currently not on the list of accredited universities, which lower
the requirements, if one were to graduate in our program today and apply to a
Regional Airline, they would be required to pass the following qualifications.
According to the FAA:
1,500 hours of
total time as a pilot that includes at least:
(1) 200 hours of
cross-country flight time.
(2) 100 hours of
night flight time.
(3) 50 hours of
flight time in the class of aircraft for which the rating is sought. A maximum
of 25 hours of training in a full flight simulator representing a multiengine
airplane may be credited toward the flight time requirement of this paragraph
if the training was accomplished as part of an approved training course in
parts 121, 135, 141, or 142 of this chapter. A flight training device or
aviation training device may not be used to satisfy this requirement.
(4) 75 hours of
instrument flight time, in actual or simulated instrument conditions, subject
to the following:
(i) Except as
provided in paragraph (a)(4)(ii) of this section, an applicant may not receive
credit for more than a total of 25 hours of simulated instrument time in a
flight simulator or flight training device.
(ii) A maximum of
50 hours of training in a flight simulator or flight training device may be
credited toward the instrument flight time requirements of paragraph (a)(4) of
this section if the training was accomplished in a course conducted by a
training center certificated under part 142 of this chapter.
(iii) Training in
a flight simulator or flight training device must be accomplished in a flight
simulator or flight training device, representing an airplane.
(5) 250 hours of
flight time in an airplane as a pilot in command, or as second in command
performing the duties of pilot in command while under the supervision of a
pilot in command, or any combination thereof, which includes at least—
(i) 100 hours of
cross-country flight time; and
(ii) 25 hours of
night flight time.
EMU is currently in the process of
becoming an accredited university to fall under the lower “restricted”
minimums. But unfortunately one of the requirements for this would be that one
would have had to complete both their instrument and commercial training under
part 141 training. And since the majority of past and present students
completed this training under part 61, they will have to adhere to the higher
standards. The effect of this on EMU’s flight training will most likely result
in a discontinuation on part 61 programs and all students with career
aspirations shifting to part 141.
As for my opinion
on this issue, I believe that any effort for higher safety should be encouraged
and promoted. But in this case, the means by which the FAA is trying to
implement this higher safety are misguided. By setting higher hour
requirements, there will certainly be more experienced and older pilots
applying to the Regional airlines. But this is only an immediate and reactive
solution to a bigger issue and will only give the illusion of a higher
standard.
The main problem
with this plan starts with the burden of cost. Since this ruling requires even
more hours of training, which can become very costly, students will have to pay
significantly higher. This is a problem because it has the potential to limit
flight training only to those of a higher income and give the feeling of
“buying” your ratings. Also, because of such a high investment, instructors and
examiners may hesitate on failing students since the debt they may have
incurred to even get to that point could financially ruin them or there family
if they do not pass. The high cost as well could scare potential students and
their parents away from flight programs simply because of the high risk of the
investment. Coupled with the fact that most Regional first officer’s pay is
somewhere in the 20,000 dollar range, there is not much of a return on their
money.
As for the effect
on the Regional airlines, I believe they will have difficulty replenishing their
number of pilots lost to the natural “flow” to the majors or other higher
paying positions. Therefore there will probably have to be some sort of
incentive to attract prospective pilots, perhaps in the form of signing bonuses
or some other benefit. But if they do not attract enough pilots to “fill the
seats”, perhaps there will be route restructuring in the form of cancelled
routes or less flights in a given day. Because of this resulting desperation to
hire and the fixation on higher flight hours, hiring might get so bad as that,
“If you are breathing and have 1,500 hours, you will get an interview
immediately and be hired” (Hilkevitch 2013). Which does not seem like a very
safe practice at all.
References
Electronic
code of federal regulations. (n.d.).
Retrieved from
http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&sid=40760189a03dfea0b501608f33820a45&
Hilkevitch, J. (2013,
August 9). Experts say stricter faa rules for pilots too costly, won't
improve safety. Retrieved from
http://articles.chicagotribune.com/2013-08-09/news/ct-met-airline-pilot-training-20130809_1_regional-carriers-pilots-flight-time/2
Johnson, S. (2012). The
average salary of a regional airline pilot.
Retrieved from
http://work.chron.com/average-salary-regional-airline-pilot-5985.html
Zremski, J. (2013, July
10). Commercial pilots to face stricter faa rules as flight 3407 families
draw praise . Retrieved from
http://www.buffalonews.com/20130710/commercial_pilots_to_face_stricter_faa_rules_as_flight_3407_families_draw_praise.html
I would have to agree that the new requirements have been implemented in a misguided attempt to increase safety, or at least under the influence of inflated optimism. It’s a very easy sell for politicians, of course. It would seem that most of the secondary consequences of the regulations have been overlooked in an attempt to marginally increase safety. Thankfully negative side-effects may be avoided, so long as the aviation industry responds appropriately.
ReplyDeleteYou stated this in your post...
ReplyDelete"By setting higher hour requirements, there will certainly be more experienced and older pilots applying to the Regional airlines. But this is only an immediate and reactive solution to a bigger issue and will only give the illusion of a higher standard."
How do you think that a difference of 1250 hours for those not at an accredited university or a 750 hour difference for those who are will only give the illusion of a higher standard. I think everyone is really upset about the change and are racking their brains on how to create a solution to their financial burden but there is no doubt in my mind that the hour requirements will make a significant increase in safety for the passengers and crews of the industry.
I'm glad I read your post because one of my main concerns was the accreditation process for EMU. I was looking online and seen that they were training under part 61 and was wondering if they had started the process of applying for training under part 141. Incoming students into the program will have to adjust accordingly, but I think this change will soon become a major inconvenience for past graduate students.
ReplyDeleteJ.C.,
ReplyDeleteThank you for testing my opinion. I believe that there will be an illusion of higher safety because there is a strong emphasis on total hours themselves, not how they are obtained. Therefore pilots might take the easiest and quickest route to "pad" there hours by buying their time with local area flights that do not really test their abilities. Similar to the phrase,"quality not quantity", well this ruling could definitely fall under "quantity".