1,500-hour Pilot Rule Presents Challenges And Opportunities
The FAA has issued a final rule that raises to 1,500 the minimum flight hours required by first officers for U.S. air carriers flying under Part 121 regulations, up from the current 250 hours. The new rules stem from a Congressional mandate following the 2009 crash of Colgan Air 3407, a Bombardier Q400, in Buffalo, NY. The rule also requires that first officers hold an ATP certificate and a type rating in the aircraft being flown. To earn the ATP, pilots will need to log a minimum 50 hours of multi-engine flight time and complete a new FAA-approved training program. Before upgrading to captain, pilots will need to have logged at least 1,000 hours as copilots.
The new rule carves out circumstances where new airline pilots won’t have to meet the 1,500-hour minimum. A pilot who is not yet 23 years old or who does not have 1,500 hours will be able to obtain a restricted-privileges ATP, which will allow that pilot to fly as copilot until achieving the minimum 1,500 hours. Restricted-privileges pilots can include military pilots with 750 hours total time; graduates with a bachelor’s degree in aviation with 1,000 hours or associate’s degree with 1,250 hours; or pilots who are 21 and have 1,500 hours.
Quality of Time Logged
The new regulations, however, do not address the quality of the logged time. Both pilots in the Colgan crash had logged more time than the new minimum; the captain had flown 3,379 hours and the first officer 2,244 hours at the time of the accident. Cargo operator Ameriflight has petitioned the FAA to allow pilots to log more time when flying as second-in-command (SIC) in Part 135 cargo operations where just one pilot is required, as one way of helping new commercial pilots gain valuable flying experience.
The petition was filed in February but just recently went live for public comment. (See Regulations.gov Docket No. FAA-2007-0383-0016.) Under certain circumstances, SIC pilots can log a small amount of time when flying on single-pilot cargo flights, but Ameriflight believes that aviation would benefit from the exemption, which, if approved, would allow other operators to file similar exemption petitions. “SICs…would gain real-world flying experience under the supervision of a qualified captain,” Ameriflight noted. And future airline pilots would gain experience far more beneficial than logging time teaching, flying traffic watch, banner towing and so on to bridge the gap between freshly licensed sub-300-hour commercial pilots and the new 1,500-hour minimum, the company said.
It should be noted that there are no regulations that prohibit an operator from charging SICs for flight time that they are logging when flying for Part 135 or 121 air carriers. A commenter to an earlier AINalerts article (see July 16 issue) expressed concern that exemptions like the one Ameriflight seeks could lead to more Part 135 operators requiring that SICs pay to log flight time. According to the NTSB, the captain in the Colgan accident was a student at the Gulfstream Training Academy, where he logged 250 hours flying as an SIC for Gulfstream International Airlines (GIA). In that program, the student pays for those 250 hours of SIC time. He was not offered a job following the 250-hour period.
The NTSB report on the Colgan accident included this information about the captain’s flying abilities, specifically related to airspeed control: “The captain completed initial training and, in December 2004, began flying the BE-1900 for GIA as a fully qualified first officer. GIA maintained comprehensive training records for the captain. His training records showed that, even though he completed all entry, training, and operating phases without a failure, the captain had experienced continuing difficulties with aircraft control. For example, during simulator periods three and four, the captain was graded unsatisfactory in ‘approach to stall–landing configuration,’ although he received a satisfactory grade in later sessions. During simulator period seven, the captain’s altitude and airspeed control was unacceptable, and comments included, ‘airspeed more than 10 knots below Vref + 10. Fly correct airspeed!’ ‘airspeed 10 knots below Vref crossing threshold,’ ‘gear remains up during entire approach’ and ‘repeated deviation from altitude 200 to 300 feet.’”
More pilot training rules are likely coming. On July 10, the architects of the 1,500-hour Congressional mandate, senator Charles Schumer (D-N.Y.) and congressman Brian Higgins (D-N.Y.), wrote a letter to the FAA asking that a new mandate for additional stall and stall recovery training be implemented immediately and applied to non-U.S. pilots through bilateral agreements. Referring to the Asiana 214 crash on July 6, Schumer and Higgins wrote: “While the investigation is still ongoing, one thing is clear: this crash and the other recent crashes like Flight 3407 demonstrate a troubling pattern in which pilots are mishandling airspeed, which can lead to fatal stalls.”