FAA concedes that the cost of the requirements in its pilot-training proposal far exceed the benefits, but says about 75% of the costs come from congressional mandates, making the costs unavoidable. FAA will publish the proposal in tomorrow’s (Feb. 29) Federal Register, significantly increasing the training, experience and type rating requirements for first officers and captains flying in Part 121 operations. The notice of proposed rulemaking also increases the requirements for obtaining an airline transport pilot (ATP) certificate for all pilots, including those in Parts 91, 135 and 91(k) (fractional) operations.

The single biggest cost of the proposal comes from a requirement that all Part 121 pilots have an ATP rating, which currently requires 1,500 hr. of experience. FAA estimates that this requirement will cost more than $87 million per year, the major portion of which will fall on regional and smaller carriers.

But the Airline Safety and Federal Aviation Administration Extension Act of 2010 already mandates that all pilots under Part 121 have an ATP by Aug. 1, 2013. That requirement was spurred by the investigation of the 2009 Colgan Air crash outside of Buffalo, N.Y.

Currently, Part 121 captains must have ATPs, but first officers only need a commercial license. “The requirement for all part 121 flight crew members to hold an ATP certificate will take effect whether or not a regulation is issued,” FAA says.

U.S. Rep. Jerry Costello (D-Ill.), the ranking Democrat on the House aviation subcommittee and one of the primary drivers behind the Airline Safety and Federal Aviation Administration Extension Act of 2010, says FAA’s proposal “will dramatically increase the training standards for first officers.” He adds the Colgan crash “made very clear [that] making sure pilots have training on how to deal with adverse conditions and situations is essential to maintaining and improving air safety.”

FAA already had begun the groundwork for increasing pilot standards, particularly for first officers. The agency early in 2010 released an advance notice of proposed rulemaking exploring possibilities for increasing standards, possibly giving credit for academic study and first officer training. Shortly before the congressional mandate was adopted, the agency also charged an industry-based Aviation Rulemaking Committee (ARC) to look at the requirements for first officers.

FAA notes that the airline extension act limits its flexibility in incorporate a number of the recommendations of the ARC. But the proposal does attempt to balance some of the recommendations, while still following the directives of Congress.

The proposal for instance creates an ATP restricted privileges category for pilots that first officers could hold in place of a full ATP. The category opens the door for military pilots who have 750 hr. total time to serve as first officer. This is in line with the Obama administration’s push for potential employers to reach out to military personnel leaving the service.

The restricted category also permits 1,000 hr. total time for graduates of aviation degree programs. This balances recommendations of the ARC for credit from academic training. However, to hold a full ATP, a pilot must have 1,500 hr., keeping with the congressional requirements. FAA says the congressional mandate does not give it latitude to change this requirement. The issue of credit for academic training was among the most contentious of the ARC recommendations, split among the industry stakeholders.

FAA seeks input on a number of aspects of the proposal, including whether 1,500 hr. is adequate for an unrestricted ATP and how the new ATP requirement would affect the pilot supply for Part 121 and 135 operations. FAA further asks whether the restricted category should be offered and whether the category stipulations are appropriate.

FAA asked a number of questions about type rating and certification training requirements. The proposal calls for ATP holders to have a minimum of 50 hr. in aircraft type. FAA questions whether this is appropriate and whether first officers should be required to hold a type rating. Also, FAA questions how to implement certification programs and how it would affect Part 121 training programs.