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NAFI Briefing Paper on House Resolution 3371

►The National Association of Flight Instructors represents over 5,000 flight instructors and serves as a voice for the flight instructor community within the industry and with federal agencies.  We are dedicated to promoting professional training within the pilot community and promoting safety in flight operations.

►NAFI is concerned that HR 3371includes a proposal to require an Airline Transport Pilot (ATP) certificate (and, especially, the specific experience requirements inferred by that requirement) will have serious, unintended, deleterious consequences with respect to safety and the efficient career and skill development of professional pilots.

►NAFI is unaware of any research that correlates competency in air carrier operations with the number of raw flight hours held by a pilot. Competency correlations are found in amount and quality of training as well as experience appropriate to the operation.

►HR3371 does not address quality of experience; instead it addresses only the quantity of experience. That experience likely will be in light aircraft that, in most cases, are not particularly applicable to the type of flight operations that pilots encounter in Part 121 air carrier operations.

►Though counterintuitive, an Airline Transport Pilot Certificate requires no new skills or even training beyond that required of an instrument-rated commercial pilot certificate holder.

►The ATP is the one pilot certificate or rating that does not require endorsement from an instructor to take the practical test for the certificate.

►The ATP may be obtained exclusively in light aircraft. It does not infer higher competency in airline equipment used by air carriers than non ATP rated military or well trained civilian pilots.

►Historically, there have been significant numbers of jobs in increasingly complex aircraft that has allowed a career path that moved steadily upwards in level of complexity and therefore applicable to air carrier flying.

►Due to changes in the aviation marketplace (e.g. the virtual disappearance of the transport of checks by air), this career path is, largely, no longer available to lower time pilots.

►Because of the expense involved in obtaining that level of experience by purchasing flight time to build flight hours, we believe that pilots in the early stages of their career will forego spending money on additional training in order to apply their funds to building flight hours.

►The result will be pilots with 1,500 flight hours but little to no foundational training in advanced skills and subjects applicable to air carrier operations.

►The military services produce combat-ready pilots with less than 400 hours of flight time. This is possible because the military puts far more emphasis on training than it does on flight experience.

►Over time, the military pipeline is able to provide well under one half of the pilots required for commercial operations.

►Civilian trained pilots will be increasingly be required to sustain airline operations.

► HR 3371 requires experience “in difficult operational conditions.” Aircraft typically flown by pilots in the experience building phase of a career are largely unequipped to handle these conditions, creating a far more serious and immediate safety threat than it attempts to correct.

NAFI recommends the following approach that we feel will far better accomplish the goals and objectives sought by the Public and Congress:

(1) Establish an intermediate commercial certificate or rating between the ATP for certificates to be used in air carrier operations. Qualified military fixed wing pilots should be granted credit for this requirement. NAFI supports ALPA’s suggestion in the recent regulatory NPRM that perhaps this training should have to be given by a Certificate Flight Instructor. Consideration should be given to a similarly tiered approach to flight instructor certificates for those who would be providing this level of training.

(2) Require type ratings for all pilots flying as crew on any aircraft that currently requires the pilot in command (captain) to hold a type rating. Lack of this rating should not preclude employment with a Part 121 Air Carrier, rather should allow the training to be completed prior to commencing service as a pilot in Part 121 operations. This allows additional specific training on the aircraft to be flown than is currently required.

(3) Allow enhanced simulation training of situations not currently offered due to limitations that require simulation to be verifiable in actual flight conditions. To allow simulation of difficult operational conditions or emergency situations that cannot be practiced during actual flight experience due to danger would allow training programs to safely introduce additional situational training to pilots and enhance their aeronautical decision making experience based upon simulation training.

4) Allow an industry/government expert panel to develop specific, appropriate regulations for implementing the above recommendations