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Friday, 12 February, 2010

FAA Releases ANPRM On Pilot Certification For Air Carrier Operations


February 11, 2010

What’s at Issue

On February 8, 2010, the Federal Aviation Administration (FAA) issued an Advanced Notice of Proposed Rulemaking (ANPRM) titled New Pilot Certification Requirements for Air Carrier Operations.

Why it’s Important

This ANPRM signals the agency’s intent to issue proposed rule changes relating to pilot certification as it relates to Air Carrier Operations. This ANPRM gives interested individuals the opportunity to provide the FAA with comments and suggestions on the direction the agency should take in issuing proposed regulations.

Major Provisions

The FAA indicates that the purpose of this ANPRM is to receive comment on the various paths available to the agency for increasing pilot performance and professionalism. In this ANPRM, the FAA lists five areas and several specific questions for those five areas on which the agency would like to receive comment.

1. Requirement for all pilots employed in Part 121 air carrier operations to hold an Airline Transport Pilot (ATP) certificate with the appropriate aircraft category, class, and type rating, or meet the aeronautical experience requirements of an ATP certificate

a. Should the FAA require all pilot crewmembers engaged in Part 121 air carrier operations to hold an ATP certificate? Why or why not?

b. If a Part 121 air carrier pilot does not hold an ATP certificate, should he or she nevertheless be required to meet the ATP certificate aeronautical knowledge and experience requirements of § 61.159, even if he or she is serving as SIC? Why or why not?

2. Academic Training as a Substitute for Flight Hours Experience. The FAA seeks public comment on the concept of permitting academic credit in lieu of required flight hours or experience

a. Are aviation/pilot graduates from accredited aviation university degree programs likely to have a more solid academic knowledge base than other pilots hired for air carrier operations? Why or why not?

b. Should the FAA consider crediting specific academic study in lieu of flight hour requirements?

c. If the FAA were to credit academic study, should the agency still require a minimum number of flight hours for Part 121 air carrier operations?

3. Endorsement for Air Carrier Operations

a. Should the FAA propose a new commercial pilot certificate endorsement that would be required for a pilot to serve as a required pilot in Part 121 air carrier operations? Why or why not?

b. If so, what kinds of specific ground and flight training should the endorsement include?

c. How many hours, beyond the minimum required for a commercial pilot certificate, should be required for an air carrier endorsement.

d. What additional types of operating experience should an endorsement require? (e.g., crew environment, icing and high altitude experience).

e. Should the FAA credit academic training toward such an endorsement and, if so, how might the credit be awarded against flight time or operating experience?

4. New additional authorization on an existing pilot certificate.

a. Would a carrier-specific additional authorization on an existing pilot certificate improve the safety of Part 121 operations? Why or why not?

b. Should the authorization apply only to a pilot who holds a commercial certificate, or should it also apply to the holder of an ATP certificate?

c. Should such an authorization require a minimum number of flight hours? If so, how many hours should be required?

5. Other areas of concern

a. Can existing monitoring, evaluation, information collection requirements, and enforcement associated with pilot performance be modified to improve pilot performance?

b. If so, what specific modifications should be considered?

NATA Position

NATA is concerned about the FAA’s confusing position on this ANPRM. The FAA states in the ANRPM:

“This ANPRM is seeking comments on issues relating to basic part 61 pilot certification, not air carrier hiring or training requirements”

A brief review of the five comment areas contained within the ANPRM indicates that the FAA is not focusing on “basic part 61 pilot certification” but rather specific training and experience that would be required for employment in a Part 121 operating environment. NATA is concerned that the FAA may be shifting the training required for a pilot to operate effectively in a Part 121 environment from the individual Part 121 operator to the individual pilot. A shift such as this would significantly increase the basic training costs imposed upon individuals aspiring to be pilots in a Part 121 operation. NATA believes that while the foundation received in Part 61 training is vital and valuable for all pilots, the training required to operate in a Part 121 effectively is best provided by Part 121 operators.

NATA requests comments from its membership on this ANPRM. This input will allow NATA to develop comprehensive comments to submit to the FAA.


This ANPRM was published in the Federal Register on February 8, 2010, and is available for download here. This ANPRM will be open for public comment until April 9, 2010.

Staff Contact: Michael France
Director, Regulatory Affairs

For general press inquiries, contact Shannon Chambers at 703-298-1347 or

The National Air Transportation Association (NATA) has been the voice of aviation business for over 75 years. Representing nearly 2,300 aviation businesses, NATA’s member companies provide a broad range of services to general aviation, the airlines and the military and NATA serves as the public policy group representing the interests of aviation businesses before Congress and the federal agencies.