Industry comments on proposed FAA Pilot Qualification Regulations are uniformly negative

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The pilot qualification rules are among the most complex and the 2nd most controversial regulations (flight duty time is #1 http://jdasolutions.aero/blog/?p=588) in the FARs. They have achieved this status because they exist at the intersection of the FAA’s safety mandate and labor issues. As noted recently here (http://jdasolutions.aero/blog/?p=634), the reason for the complexity derives the multiple dimensions in which the competence of a pilot can be assessed. Then add to the difficulty in divining a regulatory solution, the intervention of Congress (H.R. 5900, the Airline Safety and Federal Aviation Administration Extension Act of 2010.), the resolution is more likely to be technically flawed. This is a matter for the agency to decide, not the sort of issue with which the Congress has particular competence (a repeated theme of this blog in all areas of aviation issues, (http://jdasolutions.aero/blog/?p=534).

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