RAA vice president Scott Foose knows the “granularities” of the various issues with which the association grapples every day as well as anyone in the industry. A 9,100-hour, ATP-rated pilot and a former senior manager in Allegheny Airlines’ flight operations and safety department, the RAA veteran also brings as balanced a perspective as one could find on the merits and shortcomings of some of the rulemaking stemming from H.R. 5900, the Airline Safety and Federal Aviation Administration Extension Act of 2010. With this year’s FAA reauthorization and publication of final rules and NPRMs associated with the agency’s 2009 “Call to Action,” Foose and the RAA can finally offer a fairly comprehensive assessment of the fallout from some of the most intense public scrutiny the industry has ever confronted.

In an interview with AIN ahead of this year’s RAA Convention, Foose offered some mixed reviews of the resulting regulatory changes.

For example, while the RAA considers “arbitrary” the 1,500-hour flight time minimum in the February 27 NPRM addressing the law that requires first officers to carry an ATP certificate, Foose wouldn’t completely discount the value of certain elements of the proposal.

“There are some really good things in there,” he said. “One, it addresses and would require pilots to undergo training in some specific airline conditions such as high-altitude operations and severe-weather operations, which we support.”

Foose served as chairman of an aviation rulemaking committee (ARC) established by the FAA about a year-and-a-half ago, and from that perch he was able, in his words, to observe a lot of important “stakeholders” discuss the changes to the qualification standards for airline pilots and to question the wisdom of other components of the proposed rule.

Some particularly troubling aspects, said Foose, center on the requirement that pilot applicants be at least 23 years old and hold an aircraft type rating.

“Frankly, the [requirement for an] aircraft type rating was a surprise,” he said. “We had not anticipated that to be proposed. So we’re really looking at that…There’s no better organization out there than the airlines to understand what it takes to train and qualify a pilot to be safe and professional. They have years of experience; they have veteran instructor staff and they’ve got programs that have been developed and improved over many, many years.

“They have a lot of data that was shared with the FAA through the ARC process, which identified the value of structured training programs before a pilot gets to apply for an airline job,” added Foose. “Going forward, we would like to see the rule, when it’s finalized, recognize that experience level and the data that was already provided. We think that’s quite reasonable.”

Although the public law will allow for 500 hours of credit for university-accredited pilots, and 750 hours for those with a certain level of military experience, Foose expressed concern that it doesn’t give credit for structured training outside a setting that results in a four-year aviation degree. “There are other avenues that have produced excellent, safe pilots who we do not want to be disenfranchised as a result of this rule,” said Foose. “The unfortunate consequence of what is proposed as it is today, and we certainly hope it will change, is that it provides incentive for some young people to jump out of the educational track really just to pursue flight time entirely.”

Foose recounted a case of a father calling him with concerns about his son, who, largely because of the minimum age requirement and accumulating student loan debt, is considering leaving school to join a corporate aviation department, where he would get paid to accumulate the 1,500 hours he needs to fly for an airline. Others, said Foose, might simply choose different careers, leading to a shortage of pilots and loss of service to small communities.

Of course, a pilot shortage could also eventually dictate increases in salaries, and Foose acknowledged that the prospect represents “a focus issue” for both the industry and Congress. But even though better salaries could encourage more trainees to join the profession, making the proposition a more financially viable one starts with more affordable training.

The RAA has scheduled two so-called breakout sessions at this year’s convention covering the subject of “pilot labor supply trends and challenges,” during which panelists representing various segments of the industry will discuss the anticipated demand for pilots and the challenges associated with attracting qualified talent. The panels will feature representatives from regional airlines and universities.

“The challenge here is trying to make sure that students can actually afford training that’s available out there,” said Foose. It’s not just the regional airlines who need these pilots, continued Foose: “The small and medium-size communities that we serve and the airlines that we provide feed for really need these people to be interested in these careers. And we should be doing everything we possibly can to encourage them to pursue these careers. Frankly, student debt, in part as a result of these new rules, is concerning to us.”

Of course, still further concern over a possible pilot shortage stems from the new flight- and duty-time rule, published in January, which will allow pilots a minimum of 10 hours rest before each flight duty period, compared with eight; place new limits on the number of hours a pilot can fly weekly and monthly; and extend the number of consecutive hours off in a seven-day period from 24 to 30.

Although the RAA has yet to calculate the effect on individual regional airlines, Foose cited early estimates that each carrier will need on average between 8 and 10 percent more pilots to comply with the new rule. “It’s significant,” said Foose. “But our members consider it to be a necessary step to continue to improve safety.”

Although Foose expressed satisfaction that the FAA exploited the science available at the time of the rulemaking, the association hopes an ongoing fatigue study it commissioned Washington State University’s Sleep and Performance Research Center to conduct will better inform the industry and regulators about the fatigue effects of multi-segment operations common to regionals.

Researchers have so far concluded the three-phase study’s first phase, which involved developing the first-ever computer model capable of predicting fatigue attributable to pilot workload. Under Phase 2, which the RAA hopes the university will complete in the second half of this year, researchers plan to measure pilots’ activity levels in an effort to validate the Phase 1 findings. “We’re in discussions with airlines and pilot groups and the university created a scientific steering committee that’s independent of RAA,” said Foose. “They are in a position to provide counsel as the study jumps into Phase 2, which is to put pilots into simulators.” Finally, Phase 3, which likely wouldn’t start until next year, would involve developing what Foose called an FRMS (fatigue risk management systems) program, which would allow operators to assess the risk of fatigue individual schedules or routes might have on their pilot groups and use the data to supplement prescriptive rules already in place.

“The FRMS as we see it today, the models that are out there, only consider the science that’s available, and that is science that relates to circadian rhythms and also the quality of sleep,” said Foose. “The gap is in the area of workload-related fatigue.”