I may have been wrong.
We now appear to be headed for some of the most sweeping regulatory changes the industry has seen since deregulation, or the Federal Aviation Act of 1958 before it.
The FAA has convened an Aviation Rulemaking Committee (ARC) to rewrite the regulations concerning crewmembers' flight time, duty time, and required rest periods. The committee, which is comprised of FAA, industry, and labor representatives, started meeting in early July and has been given a September 1st deadline to make a recommendation to the FAA. Administrator Babbitt has stated that he wishes to have new regulations in place by the end of the year. The Air Transportation Association and other industry groups are rather wisely supporting the aggressive rewrite, in public at least. These are the same airlines that sued the FAA earlier this year to halt a very modest rewrite of rest rules for flights over 16 hours.
The few rumors to emerge from the ARC thus far indicate that maximum duty time will decrease by several hours, weekly and monthly duty time may be restricted, rest periods will be lengthened or will reflect time actually at the layover (right now transportation to and from the hotel is considered "rest"), and maximum duty time may be limited for late afternoon and evening show times. Work is reportedly proceeding very quickly and the airline industry participants have not stonewalled and created deadlock as happened in several past ARCs.
Meanwhile, the members of the House of Representatives' Aviation Subcommittee have introduced bipartisan legislation H.R.3371, "Airline Safety and Pilot Training Improvement Act of 2009." It goes to the full House Transportation and Infrastructure Committee tomorrow, and if approved there, on to the full House sometime after the August recess. A corresponding bill has not yet been introduced at the Senate's aviation subcommittee, but based on statements from both the majority and minority leaders during the June hearings I don't doubt that one will be forthcoming.
The full bill isn't yet available to the public, but the summary linked to above contains the following high points:
- Require all airline pilots, not just Captains, to hold an Airline Transport Pilot certificate (1500 hours total time, among other requirements).
- Establish tougher screening criteria for airline pilot interviews.
- Create a Pilot Records Database to include licenses, ratings, check rides, and "pink slips," both from the FAA and employers, to be used for hiring purposes only.
- Require mentoring programs for new-hire pilots and command/leadership for Captain upgrades.
- Require stall recovery training at the airlines, and forms a FAA task force to study requiring training in stick pusher usage.
- Study whether the airlines' new hire and recurrent programs provide enough time to cover the necessary subjects in great enough detail.
- Require the FAA to implement new flight time and duty rules within one year.
- Requires air carriers to create FAA-approved fatigue management systems.
- Require websites that sell tickets to disclose who actually operates a flight on the first page that flight is displayed on.
First, there is no doubt in my mind that every pilot sitting up front on a Part 121 airliner should have an ATP. For most of the industry's history this hasn't even been an issue. Even back in the late 1990s when the major airlines had multiple years of record hiring and the turnover at the regional airlines was huge, your resumé wouldn't even get looked at if you didn't have ATP minimums. A few years of hard work flight instructing and freight dogging was the norm, and the regionals enjoyed a steady stream of experienced newhires. The conditions of 2005-2007, where it was possible to get hired at many regionals with little more than a fresh commercial certificate, were the direct result of the destruction wreaked upon the piloting profession in the post-9/11 era. There were still plenty of pilots out there with more than ATP minimums, there were just very few willing to prostitute themselves for poverty-level wages and the eventual chance of being hired by one of the major airlines (which themselves had become much less lucrative). Rather than offer higher wages and threaten their business model, regional airline management conveniently took the view that experience doesn't matter, and their major airline partners looked the other way. Well, experience does matter, and if the airlines aren't willing to do what it takes to attract experienced pilots, Congress is entirely right to force it on them.
I've already heard objections to this by some pilots, mostly those without ATP minimums or who were originally hired with low time. I say putting in another year or two of entry level work isn't going to bankrupt anyone - it generally pays as well or better than first year regional wages - and the experience will serve them well throughout their career. It will also weed out less committed pilots, tightening the job market and giving pilots the leverage to make a livable wage at the regional airlines. Heck, the increased labor costs at the regionals could even destroy this accursed two-tier system that was destroying their careers before they even began.
An electronic pilot records database is a welcome and overdue replacement for the inefficient mish-mash verification system in place now. Right now the airlines use a FAA database to verify certificates, type ratings, and medicals, and check whether enforcement action has ever been taken against the candidate. They then contact the candidates' previous employers for the last five years to verify that the candidate's employment, training records, and check for flying-related disciplinary actions; if the previous employer is out of business or doesn't bother to forward the records, the hiring carrier assumes everything is OK. They check the National Drivers Records database for prior DUIs or DWIs. Otherwise, they simply rely on the candidate's word regarding FAA or Part 141 checkride busts, accidents/incidents, and training or disciplinary events at employers more than five years ago. Obviously in this digital age there is a better way to do this. Many pilots will complain that airlines might not hire them based on a long-ago Private Pilot checkride bust but that's simply not true: most airlines today ask about checkride failures and are mostly concerned about a pattern of failures. Presumably they're truthfully answering the questions on the application, so why object to a database that verifies the information they willingly give the airline?
The hiring & training items - pre-employment screening, mentoring & command/leadership programs, stall recovery/stick pusher training, and study of whether airlines alot enough time for training - are all things that the major airlines and the "better" regionals do already. This is really aimed at some of the smaller or more cost-obsessed regionals who have been trying to eke by with the legal minimum. It's a recognition that safety programs and training are not the place to compete on costs.
The requirement that the FAA publish new flight and duty regulations within one year strikes me as odd given that it's well known that such regulations are in the works right now. I suspect this was inserted to put the industry groups on notice that foot-dragging and stonewalling will not be tolerated this time around. The requirement for airlines to create FAA-approved fatigue management systems is intriguing to me, I'd like to hear the details. Depending on how it's structured, it could become either a meaningless formality or a forced change to the airlines' "our crews are legal, therefore they're safe" approach to fatigue.
The final item, requiring ticket sellers to disclose who really operates a flight before the customer selects that departure, seems reasonable from a public-right-to-know standpoint, but I doubt it will actually affect many passengers' purchasing habits. At best it makes the airlines slightly more sensitive to negative publicity concerning safety programs and practices, making the adoption of voluntary programs like ASAP and FOQA more likely. In reality all the major websites (Expedia, Travelocity, Orbitz, Priceline, Hotwire) already make this information readily available before booking, although sometimes not on the first page.
My reaction to the new rest regulations will have to wait for when the FAA actually publishes a Notice of Proposed Rule Making, but based on what we're hearing it sounds like the rules will address the most egregious scheduling practices at the airlines today. Unfortunately it will significantly decrease pay and even time off at some airlines, particularly at those regionals without rigs or daily minimums in their contracts. That's a pill I'm willing to swallow in exchange for a safety improvement we've been demanding for so long, plus the fact that these rules will likely force airlines to increase staffing, putting many currently-furloughed pilots back to work.
Obviously none of this is set in stone; I don't doubt that as the airline industry remains supportive in public, they are furiously lobbying against these changes both at the FAA and Congress. We'll see just how much of this actually makes its way into law. That said, there's more momentum for substantial change than anytime in recent history, and I'm guardedly optimistic.
29 comments:
I hope the tougher rules on the ATP/1500 hour minimum don't go through... I am already getting old and feel so far away from being able to get a terrible regional job. This change would put a terrible regional job, which I want so badly, even further out of my grasp. *sigh*
As someone who very much enjoys getting adequate sleep and flying safely however, I am in full support of any improvements there. And overall, I see these changes as being good for the industry.
And correct me if I'm wrong, but on the famed Colgan Air flight, both pilots held ATP certs.
FO Shaw didn't have an ATP. She met the 1500 total time requirement when hired, but possibly not the 500 hrs of cross-country or 100 hours of night time.
CA Renslow of course had an ATP but wasn't anywhere close when first hired- he had 600 hours, several hundred of which he had bought to sit in the right seat of a B1900. The whole point here is that Renslow had very little time before the airlines to develop PIC skills and possibly scare himself out of complacency a few times. Heck, if he had instructed for a year or two, he might've had stall recovery procedures a little more ingrained. The thing is that while Gulfstream and various other puppy mills that want to take your money like to say that it's all about how quickly you can get to one of those vaunted regionals, 1000 hours of instructing or check hauling is far, far, far more valuable from an experience standpoint than 1000 hours of airline flying. You don't learn a whole lot in airline flying after you have the routine down. If you're lazy enough, you don't necessarily have to learn anything at all.
Incidentally this isn't going to affect anyone in aviation right now. You realistically need about 5000 hrs to get hired at one of the few regionals hiring now; by the time the airlines start hiring in large numbers again, anyone who's been building flight time steadily will have 1500 hours.
I don't think anyone who is pushing for this rule understands how hard it is to build time now. I finished my training a year ago and the only way I accrue additional hours is by renting a c-172. A lot of pilots are commenting on how this will cause an increase in their pay. How can companies that don't make money in the first place afford to increase pilots pay. The public doesn't have money to fly now, so good luck raising fares. The auto companies already showed us what happens when companies that don't make money are strongarmed for higher wages by their labor pools.
Sam, check out the ongoing discussion here:
http://www.airlinepilotforums.com/flight-training/40989-how-do-you-really-build-time.html
"How do you REALLY build time?"
I concur with the above post. Frankly, the mythical time building jobs just aren't out there anymore, for the most part.
And with what this bill will do, good luck getting the time via instructing, either. Very few of us are training as is, and this will continue to put a slowdown on it. Instructors already nearly work for free, they will have to work for free just to keep their jobs due to the massive amounts of pilots willing to instruct for free just to gain their 250-1500 hours.
I think Sam makes a good point that these increased minimum requirements are basically moot right now given that you won't get hired with anywhere near 1500 hours. The first thing that caught my eye reading the last post was not the difficulty of time building, but the increase in rest requirements and decrease in legal flying hours. I'm sure that better rested pilots will be safer, but I'm also sure they won't be paid as much. Fewer hours in the air per day/month means fewer dollars in the paycheck. I'd also expect the airlines to restructure their routes to allow less paid nights away from home if more time needs to be spent resting between flights.
I'm a pilot and I understand that safety is always, always, always of the utmost concern, but we have all heard of the "poverty level wages" paid by regionals many times. Cut those at all and you'll have even more pilots working second jobs on their off days to pay the bills. I would bet those other jobs are more tiring than riding in the crew van to the hotel.
I hate to criticize without offering a solution, but I don't think I'm qualified to offer one here. I'm not an expert on human factors and I don't know the best way to reduce pilot fatigue. Certainly more rest hours on nights away are a good thing. I just think you should be careful how quickly you jump to support cuts in maximum allowable hours.
They certainly won't raise hourly pay to make up for those cuts. I'd guess that they'll reduce pay to pay to train the new pilots they'll need to hire to cover the extra hours AND make it more difficult to accrue the hours needed for pay raises/CA upgrades.
Thoughts?
Forget about the entry level experience. The "work your way up through Cessna's" way is just as fine as any other way but it's not the only one that works! Most major very high standard airlines worldwide recruit cadets with 0 hours, put them through integrated training, a typerating and they will sit right hand on a bus or boeing at 200 hours total time. And it works... no bad habits, all procedures and a rigorous recurrent training and checking system.
It would be far more important to raise the criteria for upgrades.
Over here..the company internal min. hours for upgrades are 3000 sharp and not one earlier (and thats for equipment such as Dash, CRJ, Fokker 100). Also you must pass the whole circus once again.. Simulator, Skill Test, Line Supervision, Line Check, CRM etc.. etc.. etc..
And: Quite a few do fail the upgrading!
I still don't see why someone would profit from a 1000 hours VFR piston when flying a complex multicrew airliner under IFR in IMC, night and icing conditions...
Let's hope for more restrictive duty/rest regulations!!!
FE
Be wary of this whole fatigue manangement system nonsense that the FAA are talking about. They have come out in Australia and all that happens is you end up working longer hours than before. The minimum rest periods under that system are on the verge of dangerous. You can work a 12 hour day with a 8 hour rest and go again for another 12 hours.
Flying Europe,
The airlines in Europe do a descent job of training co-pilots. What should be sought after though are first officers. You mention many first officers in these programs not being able to make the upgrade. In the system I am used to the only difference between first officer and captain checkrides is steep turns. It is far better and safer to have two pilots rather than a pilot and co-pilot; there have been far too many examples of why at the cost of many lives.
A 200 hour wonder-pilot can be safe. But, an average 1,500 hour pilot will be a more competent aviator than the average 200 hour pilot.
I have learned a bit flying in the air transport world. I learned far more instructing and flying freight. Flying bank work around in Chieftain's was far more challenging/rewarding/teaching than any operation at an airline.
Those that don't see value in the experience building jobs usually haven't done them, and that is why they question and fight the idea so much. I see far worse stick and rudder skills among captains that started with the airlines with very little time than those that built up experience first.
On the fatigue side, changes are needed; I just fear what those changes mean with my already limited time with my family.
I always enjoy your blog. I agree that 1500 should be a minimum. I work at a company where 1500 is seen as junior, and we still fly single engine pistons! Without an ATPL, you are not competitive and you will not fly a pressurised turbine. To get command you will usually need 500 multi command as well.
Australia is very backward in Aviation, i will admit, but majority of pilots have good experience and the bush experience usually weeds out those who arent committed to the profession.
Just my 2 cents.
Just also to those saying its hard to get hours. It is hard, and its often not the best lifestyle choice. Moving from Sydney to go live in remote Australia is insane and i dont wish it on anyone. But its whats you do to get hours, its what you do to get where you need to be, its a means to an end. And i can safely say i can fly a plane with no equipment in marginal conditions into strips most people wouldnt believe we land at.
I have enough to say about the experience issue that it warrants a separate post, which I am in the process of writing.
On the changing of rest rules: I recognize that this *may* result in more inefficient trips, or it may just result in the way airlines schedule flights. I've been looking back through my trips and counting the instances where there's more than 14 hrs duty or less than 10 hrs rest. There aren't a ton. In most of the short overnight cases, it's where there's only one crew laying over per hub, so you take out the same airplane you brought in. Now, if the airline were forced to comply with new rules, they would do one of three things: use two crews who have long, inefficient layovers, do away with layovers and do all flights to that city as out-and-backs from the hub, or adjust the schedule so that the last inbound of the day arrives earlier and/or the first outbound departs later.
At airlines where the crew contracts don't have rigs (most regionals) the longer layovers only cost the airlines per-diem, plus the costs of maintaining a higher crew count. IF the regionals respond to new duty/rest rules by using long, inefficient overnights, we'll all be either spending a lot more time away from home OR flying fewer credit hours. Of course nobody wants to see this, but it's not an absolute given.
In many countries with more restrictive rest rules, there aren't nearly as many overnights as in the US, with a lot more day trips and two-day trips. When you serve a smaller destination exclusively with round-trips, however, either you miss the first and last flight banks at the hub, or your last flight out of and first flight into the outstation won't correspond with the hub's banks and will usually be fairly empty. Most of the international carriers don't use the hub-and-spoke system to the degree that American airlines do, so this hasn't been as much of a problem.
The third possibility is that the airlines will adjust their first and last bank times. If it were just the regionals involved, they'd probably prefer to use Option #1 and fly them all inefficiently, but a lot of the major airlines themselves have rigs in their pilot contracts, making inefficient layovers quite costly in "soft time" (credit time that exceeds flight time). It may be the major airline pilot contracts that force structural changes that save the regional pilots from a downturn in pay or quality of life.
If the worst does happen, the degree to which each airlines' pilots are protected will be determined by the minimum credit and minimum days off they have in their contract. Essentially, everyone will have the lifestyle of the most junior pilot on reserve, with min days off and/or min credit. The most senior guys will be protected to the point that they protected the junior guys in the last contract. In the next round of contracts, everyone will have to fight hard for rigs, or higher payrates to make up for the decreased credit hours.
In response to some of the specific comments:
Adam, the "poverty level wages" at regionals are most concentrated among junior FOs who are on reserve, and except for understaffed airlines, generally are at or near min guarantee already. The worst case scenario doesn't really decrease pay for these pilots, it just brings the other pilots closer to their level.
So far as pay-cuts to train more pilots, most pilots contracts are governed by the RLA and cannot be changed unilaterally without a long process that leaves the pilots free to strike, so it's not likely.
Anonymous 6:28- "Fatigue Management System" could mean just about anything, including the rather Orwellian usage you describe, which is why I would like to see details. Slightly off-topic, you DO realize that under current FAA rules we can work 15 hours duty followed by 8 hrs rest (maybe 7 hrs actually at the hotel) followed by 16 hrs duty, right? It doesn't happen often but many airlines - particularly regionals - are shameless about using it when they need to, conveniently deciding "if it's legal, it's safe."
Greg- great post, agree with everything you said.
Hour building opportunities aren't "hard to get". They do not exist. There is a large group of aspiring pilots who would jump at the chance to move to an obscure location to build time. There is a disconnect between new pilots and those farther along in their career who don't have the first hand experience with the current conditions.
Amen to the last comment.
It's all good and well to suggest that the magical time building jobs are a great idea. Are they? Sure, if you can go be a freight dog for awhile, more power to you. But good luck getting that job.
I'm in full support of the proposed hour requirement even though I barely have 200hrs. Hopefully this will drive the puppy mills out of business, and put an end to the kids who are excited to fly a jet for $20,000 while living in the basement.
Yes, I may have a disconnect with the current conditions for time builder jobs. However, when I started out looking for experience building jobs it was early 2002, shortly after the terrorist attacks. So, I can sympathize with how hard it can be to find a descent time building job. I actually ended up bagging groceries at Safeway until I could get my foot in the door.
At no point do I want to see upcoming pilot generations have to suffer. Just because I had to pay my dues doesn't mean I think others should have to as well. However, pilots need to build experience before they are allowed to fly a plane full of passengers. This isn't out of a belief in paying dues. It is because my family is often sitting in the back.
The industry cycles. This down cycle will likely take longer than most. I realize it is damn near impossible to find a pilot job now. In my first pilot job I remember the 3 inch stack of resumes on my boss's desk, so it has happened in the past; and it will happen again. It is also likely that in a couple years it will be extremely easy to find an instructing job.
But through all this, divorce your feelings from the hiring environment and honestly ask yourself; do you want a 1,500 hour captain and 250 hour FO flying your children around? Or do you want a 5,000 hour captain and 2,000 hour FO?
By the way, in the past the hiring environment has been considerable worse; and for prolonged periods. Some of the old-crusties have reminisced when they were working their way up and it took 5,000 hours to get a freight dog job. And this wasn't for the two years of crap we will likely have. It was for a long while. And there have also been extremes in the distant past where major airlines were pulling people from the streets and training them from 0 time.
America has already decided they dont want a 5000hr captain and 2000hr first officer. They choose cheaper fares. Once there is a market for more experienced crews an airline will hire more qualified crews, advertise it, and then charge higher fares. All the pilots supporting the rule changes can wait and apply to this airline when the market dictates the need for it. The FAA provides America with the safest air transportation system in the world and they have already come out against these changes. These changes were intially introduced to promote safety, the pilot groups are latching on to them as a way to manipulate their wages.
Anonymous - by your logic, quite obviously America prefers fatigued pilots. Why overhaul the rest & duty regulations, in this case? Why not do away with them altogether!? We'll let the traveling public make a presumably informed decision over just how rested they want their pilots to be! Yay, free market!
some good thoughts by all, wanted to add my perspective to this amicable discussion.
first, I'm fairly new to the field, still in training at one of the acclaimed 'puppy mills.' while I certainly would have opted for the military route if I were younger, these fast track schools provide opportunities for people like myself to pursue a dream that otherwise may never have happened. there are definitely two ways to look at this: one, people who enroll at such schools have shiny jet syndrome and are looking for the quickest, easiesy route there. the other mentality, of which I am, is that these schools offer full immersion and daily flying, which is conducive to high retention levels and minimal distractions-simulating an airline training environment. this is a good thing, I believe.
not a day goes by that I don't thank the stars that it's only me and the CFI flying the Cessna. not in my wildest dreams do I feel qualified to carry passengers. for every rough landing or botched radio call, however, I'm becoming a better pilot-real experiences that will someday translate to increased safety for me, and the passengers I'll transport. it shouldn't be about 'paying' dues, rather, it should be about accumulating as much knowledge, practical experience, and repetition as possible. I embrace that aspect-even if it's 3, 5 years of building time.
it's laughable to me that I could be qualified to carry passengers at 250 hours! I have so far to go, and so much to learn before that's a reality. for every hour that we're aloft, there's a lesson learned, an incident to gain wisdom from, and insights on how to become a better pilot. I can only imagine how much more I will learn through years of instructing, cargo work, and possibly even some obscure flying jobs before I'm reading for the airlines.
sadly, most of my fellow students do not share this mentality and are looking for the right seat ASAP. my goals are different, and even though the new legislation will likely delay my final goal, it's ultimately a good thing for the aviation field, and the general flying public, overall. above all, perhaps it will weed out those who aren't as dedicated, passionate, or consciencious of safety as I am attempting to be.
Anonymous,
Your reasoning on the surface sounds correct. However, it is less about the fairs being charged and more about the industry's perspective.
The airline best known for the lowest fares is also the airline with the highest paid pilots who is able to be extremely picky with their employment candidates. Southwest has been doing this for a few years now.
Costco makes a descent margin while giving customers great values, and pays their employees a relatively high wage. I was going to mention Google too, but they don't count as tech margins are often high even with high paid employees.
We have enjoyed a lull in accidents and incidents in the past few years. However, we will likely return to historical averages except with a slight improvement. In my safety courses they often mentioned that if the accident rate stayed the same from 1999 to 2020 because of increase in air travel we would see a major airline accident once a week. We need to look for cost effective ways to keep the rate lower. Experienced crews that aren't being worked to exhaustion is a good place to start.
And you mention these times as un-realistic. I fly for a regional airline. I am a 6,000 hour first officer and I am close to our airline's average. Our average captains have 12,000+ hours. We get paid descent. Our cost per available seat mile is actually pretty close to our competitors. We fly branded operations and thus have some extra overhead other regional airlines that only fly capacity purchase agreements do not have. If it wasn't for this we would actually be below the costs of our competitors.
Sam-
Read my post again, my logic says the public relies on the FAA to regulate their air safety. America wants cheap and safe air fare. They have the best system in the world for that. Increased rest rules would be great for safety. It also requires pilots to self enforce those rules, which may rear its head as just as big a problem as the need for improved rest rules.
It seems like there is going to be some big changes in the industry over there.
I wonder if these African countries are ever going to sort out their problems with some kind of shake.
Heck Tanzania's TCAA is suspended from ICAO for a start.
Keep it up mate.
I have put a link from my blog to yours cheers Ryan
Anonymous- I think I read your post correctly the first time. You think that the public is quite satisfied with the current level of safety and is content with a few Colgan 3407s every few years if eliminating them would mean fares being raised by even a few dollars, and the ONLY thing that should increase safety is not Congressional law but consumer demand in the form of safer airlines getting more business. I respectfully disagree on three points: Firstly, I don't believe the public is entirely happy with the current level of safety, the uproar surrounding Colgan 3407 and the revelation of the conditions at the regional airlines have stirred up a hornet's nest of public opinion that has moved the Congresscritters into action. The industry groups obviously see this or they would be publicly opposing the proposed law much more strongly than they are. Secondly, the public lacks useful aviation safety data and the specialized knowledge to use it in making informed purchasing decisions. This is why suggesting that the marketplace should decide the need for increased safety in lieu of FAA regulation and congressional oversight is absurd, as I pointed out with my suggestion that we remove rest requirements altogether. Thirdly, safety is the FAA's only mandate; economic considerations were removed some time ago. The public expects the FAA to enforce "one level of safety" so that it's not even a consideration when they go to buy that lowest fare on Expedia. Right now that is clearly not the case and the FAA has repeatedly failed to take action, so Congress is rightly exercising their FAA oversight responsibility.
Regarding your comment about pilot groups "latching on" to the proposal as a way to manipulate wages... you're right that adding barriers to entry will potentially decrease the supply of pilots at some point in the future but overall the effect will be pretty miniscule compared to the skyrocketing costs of learning to fly compared to the steadily decreasing rewards of an airline career. With or without this law, there will be a major, major shortage in 3-5 years that will give pilots some power to increase wages. Whether or not this law passes will determine whether 250 hour pilots are flying around you and your family for the duration of the shortage.
I wish the FAA would do something about controller fatigue. It continues to be ignored.
Wow.. a bunch of posts disappeared.
Can't take the heat?
Uh I see all 26 comments for *this* posting. Sure you didn't mean to visit the newer post, "Experience Counts?"
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