DEFING PILOT COMPETENCE INVOLVES MULTIPLE, VALID VARIABLES- DESIGNING RULES WILL BE DIFFICULT, IMPLEMEMENTING THEM EVEN MORE TESTING

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ARTICLE: FAA Wants Comments on Pilot Certification Rule

This is part of a long term ANPRMè NPRM process, The New Pilot Certification Requirements for Air Carrier Operations and correctly the FAA has indicated that its rule-making perspective is broad. As noted at the National Training Aircraft Symposium, a pilot threshold, that is just based on hours, ignores other potential avenues of becoming qualified to deal with the complexity of the cockpit.

The proposed increase between 250 (commercial) and 1500 hours (ATP) is significant and will likely reduce the number of qualified candidates. Such a single, absolute rule, which limits the pool, will not serve safety.

More seasoned pilots may have deleted habits that may have been appropriate for their previous work environments, but that are not useful in the context of commercial operations. Younger pilots may have better visual acuity, exhibit higher levels of hand/eye coordination and may even be more comfortable with the new computer interactions, but lack the judgment needed to know when to go or not. The point is that there is a gestalt of skills that should be considered and those complex criteria compel greater judgment in the hands of the persons authorizing and hiring pilots.

That is why the alternatives posed by the professionals who participated in the NTAS symposium should be part of any final FAA regulation. Options to be considered include:

Ø  better initial and advanced training,

Ø  programs designed to assure that the new first officer has all of her/his required skills,  

Ø  an array of academic credit options, including program accreditation recognition,

Ø  structured training programs through Part 61 institutions which also rely of academic credit from a university/college curriculum designed for this pilot qualification

Ø  type-rating training that reflects the unique cockpit requirements of a specific airline’s set of instruments, or

Ø  a combination of examinations that demonstrate the candidate’s knowledge and competencies rather than a hard hour

In any event, given the multitude of potentially valid criteria and the need to exercise very delicate discretion, the final rule will have to incorporate the most difficult term for the regulator and the regulate—JUDGMENT. The FAA and carrier personnel will have to communicate well when a rule must involve some vagaries; without some level of understanding, confrontation and contention are most likely.

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