866-806-6156 (9 am - 5pm ET)
Propsed Air Carrier Pilot Qualifications May Disenfranchise Smaller Flight Training Providers
By Jonathon Freye
According to recent FAA proposed rulemaking, traditionally busy independent flight instructors, FBOs, and community colleges may not be able to offer their graduates the same benefits as large university or collegiate flight training programs in the future. It is likely that this will make them less appealing to potential students. On Monday last week, immediately after the FAA released a Notice of Proposed Rulemaking (NPRM), staff at the National Association of Flight Instructors began to analyze and interpret the possible impacts to the flight training community. While the aim of the proposal is to "prepare pilots to operate more safely in air carrier operations," it will undoubtedly have a profound impact on who in the flight training community will be able to provide applicable training for individuals seeking Part 121 pilot careers. The FAA acknowledges that the NPRM is a direct response to Congressional mandates in the wake of the 2009 crash of Colgan Flight 3407, and may require all pilots in the cockpit of a commercial airliner to hold an ATP certificate with 1,500 hours, even as a first officer.
Under the proposal, four-year baccalaureate degree programs with Part 141 training curriculums have a significant advantage over the rest of the flight training industry, while community college-based programs and technical/trade schools will lose out. Section III, paragraph E of the NPRM (available at 
http://www.faa.gov/regulations_policies/rulemaking/recently_published/media/2120-AJ67NPRM.pdf)  indicates that the FAA is proposing alternative hour requirements for graduates of university programs and their associated Part 141 flight training curriculums. Such students would be eligible for an ATP certificate with only 1,000 hours, as opposed to flight students who received their training anywhere else.

The NPRM notes it will not "significantly impact" small business entities. Flight training providers operating under Part 61, however, will have a difficult time recruiting career-minded students given their inability to offer a 500-hour reduction in the minimum qualifications for employment. Another section notes that a pilot candidate for Part 121 (also Part 135 and some Park 91 subpart K operations) pilot jobs would also be required to have completed an "FAA approved ATP training course."  While this may be a positive step toward improved ATP training, it will likely limit the sources of the training.  The proposed training course would require level C or better simulation experience as a part of the course along with the FAA approval of a course (something more traditionally present in Part 141 or Part 142 training).  It is unlikely that historic sources of pilots who trained through instructors operating under part 61 would be able to continue to provide this training.
If the contents of the proposal become law, even Part 141 flight training providers at FBOs and community colleges will be disenfranchised. Their graduates will only be eligible for the ATP certificate at 1,500 hours, 500 hours more than their peers who graduated from university programs. Jared Huss, Lead Instructor of Fox Valley Technical College calls the NPRM "discriminatory."  At worst, this proposal stands to drive smaller flight training providers out of business.
"These proposed changes have the potential to split the industry", said NAFI Executive Director Jason Blair.  "It is foreseeable that with these potential changes the traditional Part 61 training options will no longer be able to provide training that is applicable for candidates seeking employment in Part 121 operating environments.  One concern with this potential is the reduction in training throughput capacity, resulting in a smaller supply of pilots for the airlines to hire from to meet commercial service needs."
NAFI staff will continue to evaluate this NPRM and all the potential effects.  NAFI strongly supports improvement in training, pilot knowledge and skill.  NAFI will provide further review of this proposed regulation and seek input from members to allow NAFI to provide a full response and feedback to the FAA regarding the NPRM.