RAA Response to Pilot/Flight Attendant/Dispatcher Training NPRM
1. RAA requests that this proposal be withdrawn and that it be rewritten as a
supplemental NPRM with “performance based” provisions and accompanied by a
draft Advisory Circular that provides for “one method of compliance” for public
review and comment
The preamble states that “the primary purpose of the NPRM is to establish new
requirements for traditional air carrier training programs to ensure that safety-critical
training is included.” The Regulatory Evaluation states that “rulemaking is necessary
because the existing regulations have not been revised since 1970. They do not reflect
current best practices or technological advances that have emerged over the last 30
years.” We consider such statements distort the reality that current air carrier training
programs fully address safety critical training and have done so for some time. The fact
that a particular safety training program is not found in the regulations does not indicate
that the program is not already incorporated in the air carrier’s training programs. The air
carrier training programs for Pilots, Flight Attendants and Dispatchers have always
required FAA approval and the enhancements to theses programs have routinely been
added to these programs as they become available. This proposal implies that if it isn’t a
rule, then an air carrier won’t do it; this proposal is therefore very misleading by not
commenting on the current state of our nation’s air carrier training programs. The
Commercial Aviation Safety Team (CAST) over the years has developed well over 100
safety enhancements that have been adopted voluntarily by the nation’s air carriers; many
enhancements have been written to improve their training programs; FAA surveys have
validated that these enhancements have been incorporated into all the Part 121 air carrier
training programs. All air carriers routinely adopt numerous FAA safety initiatives such
as the Runway Safety Program on their own without question. Within the last 20 years
and certainly since 1970, significant technological improvements have been made on
aircraft training simulators currently in use and significant advancements have been made
with training programs that were introduced on the newer aircraft put into operation
within the last 20 years. If one is looking for training programs that truly enhance safety,
then we are very confident in stating that they already exist within our member airlines.
Our primary concern with this proposal is with its vagueness and its radical departure
from the traditional performance based style of writing regulations to a control and
command style that this proposal calls Quality Performance Standard (QPS); QPS offers
no advantage over current training materials but simply adds hundreds of pages to the
regulations. This proposal is extremely vague because with nearly every other provision
specific FAA approval is required without providing any guidance on how such approval
is achieved. Surely the FAA’s approval process requires some boundaries. The lack of
clarity with this proposal also extends to what isn’t stated; it’s characteristics is similar to
that of the current optional Advanced Qualification (training) Program (AQP- Subpart Y
of Part 121) but no where does the proposal state that it is the same or that it provides the
differences from AQP. We know what is required for AQP; we have no idea what is
required to receive FAA approval for numerous provisions within this proposal.
2. RAA requests that this proposal not be adopted until Advisory Circulars
necessary to explain what will actually be required to gain FAA approval for the
proposed changes are available for public review and comment.
Despite its size, the proposed rule lacks sufficient advisory material. The preamble
provides an overview of the proposal. The separate section-by-section analysis document
for the most part simply highlights the differences between the proposed provision and
the replaced provision. The majority of the proposed provisions within Part 121 and its
appendices require specific FAA approval. Both the operators and the local FAA
inspectors need guidance on how much/how little is required to satisfy the FAA approval
process. For example Attachment 1, Appendix Q provides no baseline/minimum hours
for re-qualification, differences and special training but simply states as “Determined by
Administrator”; surely the FAA must recognize that without guidance defining the
boundaries of the FAA approval process, the rule simply becomes a “place marker” for
further FAA requirements, outside the rulemaking process.
Over the years the FAA has developed excellent guidance materials for enhancing air
carrier training programs. The proposed QPS information material list such documents as
“recommended references” yet much of the material contained within these referenced
documents is in direct conflict with this proposal. For example, the latest revision to
Advisory Circular 120-53A, dated 10/15/08 contains information crediting training
commonality to encourage cockpit standardization yet the proposal provides no
commonality provision. Indeed this AC and the numerous POI guidance documents in
FAA Order 8900 illustrate just how out of step this NPRM and particularly QPS is with
airline improvement and other FAA programs aimed at improving air carrier training
Absent additional guidance and given the uncertainties in satisfying the intent of this
proposal, if this rule is adopted without change, all operators will simply opt into the
Advanced Qualification Program (AQP). Again we are given no guidance in comparing
this proposal to AQP other than a statement in the cost benefit analysis indicating that
current AQP training programs meet the safety improvements contained in this proposal.
Indeed we wonder why the FAA simply didn’t propose to mandate AQP for pilots, in lieu
of expending the massive number of work hours taken to develop this proposal.
3. RAA requests that the phrases denoting a requirement for a specific FAA
approval process found in numerous provisions be deleted; one provision requiring
FAA approval for the entire training program should suffice.
FAR 121.405 currently describe the FAA process to approve an initial training program
and to make subsequent revisions, including those requested by the FAA. Proposed
provision 121.1335 provides a similar process for the FAA to approve initial training
program and subsequent revisions. In reviewing the proposed provisions within Part 121
and its appendices, we found nearly 100 instances in which the phrases “acceptable to the
Administrator”, “when the Administrator finds”, “the Administrator may require”, “as
determined by the Administrator”, “must be approved by the Administrator” etc., were
imbedded in the various provisions in addition to 121.1335. We don’t see why it is
necessary in this proposal to indicate FAA approval with the numerous specific
provisions when one provision such as 121.405 or proposed 121.1335 is sufficient. This
style of rulemaking is extremely confusing and as mentioned above without further
guidance, requires the air carriers to accept numerous requirements that are totally
undefined and we should add, totally unsubstantiated.
4. RAA requests that the regulatory appendices contain in the qualification
performance standards (QPS) be withdrawn and that the updated training
materials contained within the proposed QPS be incorporated into an Advisory
Circular and the training materials currently found in the Flight Standards
Information Management System (FSIMS; FAA Order 8900.1).
We are completely mystified why the FAA is proposing a new process for containing
training materials when they have already spent significant resources in developing
FSIMS. The training documents found in FSIMS for pilots, flight attendants, and
dispatchers are just excellent; they are clear, concise and extremely well written; we see
no valid reason why would you want to introduce a redundant, confusing process such as
QPS. The only possible reason for adding hundreds of QPS pages to the regulations is
that you would make it more clear that each provision is mandatory but the current rules
now mandate that these training programs must be first approved by the FAA and
therefore have always been mandatory, so why does the complete training curricula
described by QPS need to be in the regulations?
An obvious disadvantage to adding QPS to the regulations is that once adopted, it is
extremely costly for the FAA to process even a minor change in a rule. Any one familiar
with the FAA’s rulemaking process knows QPS is a pure control and command standard.
FAA rulemaking policy stipulates that “performance based regulations, be used whenever
possible”. We saw the concept of QPS first introduced in FAR Part 60, the rules
pertaining to certification of flight simulators. RAA submitted comments to the Part 60
rule pointing out that the Federal Register Document Drafting Handbook stipulates that
regulatory appendices are to be used to “improve the quality or use of a rule but not
impose requirements or restrictions”. QPS clearly imposes requirements. Nonetheless the
Part 60 rule with QPS was adopted and published on October 30, 2006. Since then it has
been revised several times and grown in size so now the regulations pertaining to the
certification of flight simulators are considerably greater in size than the regulations
needed to certify large transport category aircraft. QPS made no sense for Part 60 and it
makes even less sense for Part 121.
5. RAA requests that the proposed rule be revised to satisfy the intent of FAA Order
8000.369, Safety Management Guidance.
The FAA has committed its own organizations to adopt the concepts of safety risk
management to the rulemaking process. FAA Order 8000.369 describes regulations as
“risk controls” that “identify hazards in the air transportation system and provide
boundaries on the acceptability of design and performance of products and services.
Compliance with the regulations would thus move beyond viewing them as administrative
requirements and into an environment where compliance entails effective control of
clearly identified hazards. This would enhance the value of regulations as effective
instruments of safety management.” Most of the proposed rule and in particular the
introduction of QPS, is simply revising the current administrative process of approving
the air carrier’s training program. No explanation is provided on why QPS enhances
safety. For the most part we have no objection over the FAA’s desire to update the
regulations to reflect the latest training programs since as we mentioned above, they have
already been incorporated. What we do object to, is that the majority of this proposal
seeks to implement a “command and control” process of regulating air carrier training
programs without providing any safety benefit.
6. RAA requests that the proposed rule to mandate use of flight simulation devices
incorporate the initial recommendations of the Volpe study.
Several years ago, the FAA’s Office of the Chief Scientific and Technical Advisor for
Human Factors sponsored a study (i.e., the Volpe Study) to compare the effectiveness of
full motion simulators to fixed based devices. Their study concluded that “Initial research
on the training effectiveness of a fixed-base simulator with a wide FOV visual system
compared to a like system having platform motion failed to find an operationally
significant effect of motion using FAA qualified equipment.” While we agree with the
basic premise of this proposal that full motion simulators are excellent training devices
we are extremely disappointed that this proposal chose to totally ignore the findings of
the FAA’s chief officer for human factors. We request that the provision mandating the
use of flight simulation training devices (FSTD) be revised to allow the use of fixed
based simulators upon a demonstration of “equivalent” effectiveness.
7. RAA requests that the proposal clarify that individuals are not expected to be
trained on equipment not installed on the aircraft they operate
This should be obvious but it’s not in reading this proposal. In some instances the “where
applicable” phrase is adjacent to the equipment description but in many other instances, it
is missing. We request that either a note indicating that training on some of the affected
training is not applicable because the equipment or system is not on the aircraft for which
operators are being trained, or the use of the “not applicable” phrase be added where
8. RAA requests that Part 135 operators be exempt from this proposal.
Proposed Part 135.3 states that this proposal is applicable to “Each certificate holder that
conducts commuter operations under this part with airplanes in which two pilots are
required by the type certification rules.” We are not aware of any commuter operations
(i.e., Part 135 scheduled) that operate in a certified two pilot cockpit airplanes (there may
be some in Alaska) so on its face, this proposal affects no one. However we view this
proposal as discouraging Part 135 operators from purchasing future airplanes that are
certified for two pilot operations and as policy, the FAA should be encouraging two pilot
operations. We also view a FAA mandate to create two training standards for the same
type of operation, namely the scheduled carriage of 9 passengers, as undesirable. As a
result we request that you exempt all Part 135 operations from this proposal.
9. RAA requests that this proposal not be adopted until a realistic (and updated)
cost benefit analysis be prepared and be available for public review and comment.
The benefit cited by this proposal is extremely misleading to the point of being deceptive.
It is based upon an analysis of 169 accidents over a period from 1985 to 2004. It assumes
that all these accidents (which had a human error component in the cause of the accident)
will be averted in the future by the adoption of this proposal. Based upon this assumption
and discounting the operators who “conduct training under an Advanced Qualification
Program (AQP)”, the “FAA believes the proposed training improvements, both in content
and application, are expected to produce safety benefits (i.e., accidents avoided) of
“between $476 million and $1.05 billion over a 10-year period.”
The benefits analysis does account for any FAA rules that have been adopted since 1985
and were cost justified based upon an identical benefit analysis. For example the
“Commuter Rule” (Docket 28154) and the Air Carrier Training Program rule (Docket
27993; mandated Crew Resource Management (CRM) training) both published in
December 20, 1995 cited the same 67 accidents (1985 to 1994) that were cited in the
benefits analysis of this proposal. The stated benefit of both these rules (accident
avoidance) was estimated at $579 million over a 10 year period. The authors of the
economic analysis cited in these 1995 rule were not as presumptuous as the authors of
this proposal since they concluded that these rules need only be 21% effective to be cost
beneficial. We find it difficult to accept that this proposal is presumed to be 100%
effective in eliminating accidents within the next 10 years in which “human error” will be
a contributing factor.
The required economic assessment further states that “rulemaking is necessary because
the existing regulations have not been revised since 1970. They do not reflect current best
practices or technological advances that have emerged over the last 30 years.” Without
belaboring the point and listing additional rules that have been adopted and improved the
training programs of operators since 1970, we can unequivocally state that both the FAA
through their rulemaking efforts and the operators through voluntary programs and the
purchase/use of state of the art training devices have made tremendous improvements in
their training programs since the 70’s.
The benefit analysis is based solely on accident avoidance yet a substantial cost of this
proposal is for training program changes for flight attendants and dispatchers. While we
certainly recognize the safety benefits provided by a well trained staff of flight attendants
and dispatchers, we are not aware of any accidents attributed to the lack of training on the
part of flight attendants and dispatchers. We request that the benefit analysis elaborate on
at least one accident to quantify the benefit flight attendants and dispatchers provided in
reducing the injuries and total cost of an accident cited by the study.
10. RAA requests that a cost assessment be conducted comparing the operator cost
of complying this proposal to that of complying with the optional AQP.
AQP remains optional to that which is proposed. The cost benefit analysis references
AQP only in recognizing that those carriers “under the current AQP training program
already meet the safety improvements contained in the NPRM.” In our comments that
follow we highlight numerous provisions of this proposal that are more stringent for an
air carrier than converting to AQP. We estimate the costs of compliance with this
proposal as greater than converting to AQP and given the lack of guidance for this
proposal compared to that provided for AQP, there is a greater likelihood the costs would
significant greater. The FAA therefore needs to access the cost of this proposal to that of
AQP. At a minimum the FAA is obligated under the Regulatory Flexibility Act to
consider alternatives for small businesses and certainly adoption of AQP is one of those
11. RAA requests that proposed Part 121. 683 be withdrawn and that the current
rule be retained.
The section-by section document states that this provision must be revised to conform to
the statutory requirements in the Pilot Records Improvement Act of 1996 (PRIA). Air
carriers are obviously already in compliance with PRIA. However this proposal goes
considerable beyond what is required under PRIA to require detailed training records for
flight crewmembers such as “both satisfactory and unsatisfactory performance
evaluations and comments and evaluations made by an evaluator under sections
121.1251, 121.1271, or 135.337 of this chapter” The recordkeeping requirements of AQP
does not require such detail yet this proposal describes AQP as providing an “equivalent
level of safety”. The proposal provides no rationale for requiring these additional training
records and again no guidance information is provided on how operator compliance with
these provisions will be “acceptable to the Administrator”. Without further guidance we
are uncertain whether this proposal violates current confidentiality agreements with labor
unions and employee protection standards under PRIA.
12. RAA requests that the proposed 121.1221 Flight Crewmember: Training and
evaluation be revised to remove subpart (b) and (c ).
Proposed subparts (b) and (c ) requires that all training must be complete within 120 days
and that failure to complete such training within this 120 day window requires the
applicant to repeat the entire training curriculum. No reason is provided on why this will
enhance safety. It is not uncommon that training for a number of applicants will require
more than 120 days to accommodate personal issues or because simulators or instructors
cannot be scheduled within that time frame. Other professions such as doctor’s or
lawyers certainly don’t have such time constraints within their educational programs such
that they need to start over with their education should their years of schooling not be
consecutive or that they may sneak in a summer vacation. Without further explanation we
remain unconvinced that a pilot’s training is somehow deficient should it require more
than 120 consecutive days until completion.
13. RAA requests that to the proposed 121.1223 Flight Crewmember: Recurrent
training provision be revised to remove subpart (f) and that distance learning be
recognized as an learning alternative.
Proposed subpart (f) requires that pilots must complete academic training within 30 days
of beginning it and that Job Performance Training and Evaluation completed within a 96
hour time frame. Similar to our comments regarding proposed 121.1221 we request that
arbitrary time limitations be removed since no basis is provided maintaining these
requirements. We fail to see how such time constraints on improves on the quality of
training/checking nor on the proficiency and competency of flight crews. This proposal
limits the potential benefits of conducting ground training over an extended period of
time which actually improves knowledge retention.
There is no provision made for Distance Learning that may take place prior to classroom
recurrent training. Distance Learning programs were highly recommended by the training
ARC yet they are only mentioned within the Dispatcher training proposal.
14. RAA requests that the proposed time constraints within proposed 121.1225 be
removed; that a line check remain as a single flight cycle and that the current .
Subpart (b) 1 requires that operating experience (OE) commence within 60 days and
completed within 120 days of completing the proficiency test or another proficiency test
is required to re-initiate operating experience. Pilots already have a similar limitation if
before completing consolidation of knowledge a pilot loses their 90-day currency, he/she
must have a proficiency check; That is difficult enough without adding further time
constraints. As an example when an operator receives a new fleet of aircraft, there may
not be enough airplanes to allow pilots to commence to OE quickly. If for example the
air carrier receives 2 new airplanes in a month, but anticipate that 4 more will be
delivered 6 weeks hence, they recognize the need to gear up for more training, but will be
unavoidably delayed doing OE. RAA requests that the 60 day completion of OE within a
120 day period be withdrawn as redundant.
RAA requests that proposed required that the line check consist of at least two operating
cycles [subpart (b)(2)(i)(C)] be withdrawn. A line check is now satisfied by a single flight
cycle. This allows a more efficient use of an air carriers line check airmen. The proposal
cited no study nor was persuasive for doubling the frequency of line checks.
RAA requests that this proposal incorporate the common exemption from current FAR
121.434(c)(l)(ii) that allows a qualified and authorized check airman to substitute for an
FAA Inspector provided certain conditions are satisfied.
15. RAA requests that the proposed 121.1227 Pilot: Consolidation provision be
corrected and that subpart (e) be withdrawn.
Subpart (a) refers to 100 hours of “LOFT”. LOFT refers to Line Oriented Flight Time
which takes place in a simulator. Shouldn’t this “LOFT” be replaced with “Line
Operating Flight Time”?
Subpart (e) proposes if consolidation is not completed by the time the proficiency check
is completed then consolidation must start over. If consolidation is not completed within
120 days (or extended to 150), air carriers now provide a proficiency check. This
proposal would require operators to repeat the PC at 9 months following the initial type
which is difficult for APD’s and check airmen. When pilot classes are full, it is difficult
the APD’s and check airmen to fly for long periods. Nonetheless, they remain among the
most skillful pilots an air carrier has. Restarting consolidation is unnecessary and
burdensome and as we have mentioned numerous times, the proposal lacks any reason to
change the current requirements.
16. RAA requests the following changes to the proposed 121.1229 Pilot: Recent
experience provision be withdrawn, particularly subpart (e).
The proposal to require three operating cycles during line operations or in a single
simulator module lacks justification particularly for instructors and check airmen. What is
the rationale from proposing three cycles instead of two operating cycles?. Again we
have a change seemingly proposed just for change without reason. Air carriers typically
have instructors and check airmen who might do a couple of take-offs and landings in the
aircraft, but would now need another set to remain current for an upcoming trip; lacking
three sets of flight cycles this provision require them to be re-qualified under proposed
Subpart (c ) requires one takeoff and landing be conducted in a LOFT environment under
121.1353. No reason is given for this change. This proposal requires the pilot to
complete in a single simulator session, at least three cycles doing the maneuvers and
procedures prescribed in the QPS. One cycle must be included in a LOFT environment
under 121.1353. Which maneuvers and procedures? LOFT – 4 hours? Should a pilot
lose currency, he/she must be observed by a check airman doing 3 take offs/landings
including a V1 cut and an ILS to minimums. We fail to see what is gained by the further
expenditure of time in cruise? This can only be viewed as an added expense of
simulation time whild providing little of any benefit.
Subpart (e) requires a pilot to complete “core conversion” training should he/she out of
recency for more than 90 days. Core conversion training consists of 52 hours (Baseline)
Ground Training, 20 hours of Flight Training, and 4 Hours of Emergency Equipment
Drills and Demonstrations. This requirement therefore goes considerable beyond current
ground school requirements and greatly exceeds what an instructor must do when he/she
is out of recency for 24 months. We fail to see what skills a pilot would lose in a 90 day
period and is another example of a provision that greatly exceeds the current
requirements of AQP that is viewed by this proposal as “equivalent in safety”
17. RAA requests the following changes to the proposed 121.1233 Line checks
121.1233 (h) Line Checks – A PIC that fails a Line Check is required to complete
recurrent academic training (18 hours), a proficiency check, a qualification LOFT (4
hours), 2 cycles under supervision of a Check Pilot or APD. Train to proficiency
followed by a line check. This proposal is another example of a provision that greatly
exceeds the current requirements of AQP that is viewed by this proposal as “equivalent in
safety”. Should a PIC fail a Line Check we would think that a process would be applied
that analyzed what part of the line check the PIC failed and that the corrective action
would focus on the failed part; certainly this proposal does not address this and provides
no justification for the additional requirements.
Additionally, if a PIC does not complete the above training within 60 days of the failed
Line Check, they must complete Full Conversion Training (includes 68 hours academic
training, 20 hours simulator training, 4 hours emergency drills demonstrations), a
proficiency check , a Qualification LOFT, and two operating cycles of OE, all without
adjusting their base month. This is equivalent to what a new hire from another airline
could need to satisfy their training requirements. Again this provision that greatly
exceeds the current requirements of AQP that is viewed by this proposal as “equivalent in
RAA requests that this proposal incorporate the common exemption from current FAR
121.434(c)(l)(ii) that allows a qualified and authorized check airman to substitute for an
FAA Inspector provided certain conditions are satisfied.
18. RAA requests that the Part 121.1253(d)(2)(ii), Check Pilot requirements to
attend all “aircraft type standardization meetings” be revised as part of a
“performance based” regulation that describes a Check Pilot’s training program
and that the specific reference to attending a meeting be placed in an Advisory
Circular, available for public review and comment, that provides how a check pilot
would meet the requirements.
121.1253 Check Pilot; (d)(2)(B)(ii)(A) states that check pilots must attend all “aircraft
type standardization meetings” It seems highly irregular that a rule would be proposed
mandating that anyone must attend a meeting(s). If he/she got sick at the last minute and
missed the meeting, would this individual be cited for non compliance of a regulation?
Surely we don’t need rules with such specificity; attendance at a standardization meeting
should be characterized as part of the check pilot’s required training program. AQP
doesn’t require this and is characterized as “equivalent in safety”. We suggest that any
reference to a meeting be stated in an accompanying Advisory Circular such that if check
pilot could not attend a meeting, they could later be briefed by someone who attended. A
subsequent briefing should be viewed as “equivalent” to attending a meeting. Attendance
at a particular meeting should be viewed as a company issue and certainly not a
(d)(2)(i)Placing minimum number of events- eight activities- could be that the eight
activities have not occurred within the 12 months; one of each authorized to conduct.-
look at others
19. RAA requests that the Part 121.1271(d)(2)(ii), APD requirements to attend all
“aircraft type standardization meetings” be revised as part of a “performance
based” regulation that describes a APD’s training program and that the specific
reference to attending a meeting be placed in an Advisory Circular, available for
public review and comment, that provides how a check pilot would meet the
See comments above for a Check Pilot’s requirements under Part 121.1253(d)(2)(ii).
20. RAA requests the following changes to the proposed 121.1281 Flight instructor:
Qualification and training provision:
RAA requests that Part 121.1281 (c)(1) be revised to withdraw the sentence that states
“The flight instructors must be acceptable to the FAA”. The acceptability of a flight
instructor should only be determined by the criteria provided in the provision.
RAA requests that the Part 121.1281(d)(2)(i)(C)(ii)(B)(ii), flight instructor’s
requirements to attend all “aircraft type standardization meetings” be revised as part of a
“performance based” regulation that describes a Flight Instructor’s training program and
that the specific reference to attending a meeting be placed in an Advisory Circular,
available for public review and comment, that provides how a check pilot would meet the
See comments above for a Check Pilot’s requirements under Part 121.1253(d)(2)(ii).
21. RAA requests that the proposed requirements of 121.1331(a) stating that the
training program be “kept current” with respect to any changes in the certificate
holder’s policies and operation be withdrawn and that the wording of the current
rule [121.401(a)(3) be retained.
121.1331(a) requires that the training program be “kept current” with respect to any
changes in the certificate holder’s policies and operation. The current rule [121.401(a)(3)
requires that the training materials be kept current with respect to each airplane type and
if applicable, the particular variations within that airplane type. Obviously the new
language is much more stringent. Certainly a pilot needs to be kept current on any
information affecting the aircraft that they fly, but we don’t see why it is necessary that
they be kept informed of changes to an air carrier’s policies and operation. For example
why should a pilot need to know changes in the air carrier’s maintenance program? At a
minimum this proposal should be restated to require that pilot’s be kept current on subject
matter that affects their performance.
22. RAA requests the following changes to the proposed 121.1337 Training program:
Approval and amendment process provision:
RAA requests that Part 121.1337(e)(2) be withdrawn since it is redundant to Part 119.51,
Amending operations specifications. 121.1337(e)(2) states that in an emergency (as
defined by the FAA) the FAA can require a change in your training program “effective
without stay”. Existing part 119.51 now provides for a process in which the FAA can
initiate immediate action of an air carrier’s operation “with respect to safety in air
transportation or air commerce”; an operators training program is certainly included
within the Part 119 regulation. The Part 121.1337(e)(2) proposal is actually more
stringent than the Part 119 regulation. If the FAA insists that they need additional
authority to change an operators training program “without stay”, then the FAA should
propose a revision to the Part 119.51 rule.
RAA requests that Part 121.1337(f) be withdrawn and that the criteria for considering
revisions to an operator’s training program be provided in an Advisory Circular available
for public review and comment. 121.1337(f) provides “factors” in considering revisions
to an operator’s training program. Without further guidance, we don’t see how any small
operators would ever be able to reduce their baseline hours; indeed given complete
authority of the FAA to approve revisions on a piece meal basis, the smaller operators
may actually see their hours increased over the initial baseline number. The “factors”
provided by this proposal such as “experience level of the student population” are biased
against ab-initio training programs and smaller operators and without further explanation,
such factors are arbitrary.
This covers everything!!! Not just reductions
23. RAA request that the proposed 121.1353 provision that LOFT must include 4
hours of training be withdrawn.
The proposal that LOFT must include at least 4 hours is another example that this
proposal greatly exceeds the requirements of AQP. Currently all the elements of LOFT
can be accomplished in 2.5 hours; we see no reason why it is necessary to extend 2
operating cycles into a 4 hours training module. This proposal should focus on what
should be taught and not propose minimum training periods that are unrelated to the tasks
being taught; in this case the air carriers can make much better use of the time doing
“spot” training with the extra 90 minutes.
Proposed subpart (b)(4) Flight simulation Training Device Course of Instruction states
that “Any person … who does not perform satisfactorily, may not serve…without
training to correct the deficiency. The subpart also states the training must occur “during
a separate training session.” If it is a “Course of Instruction,” we do not understand why
the “deficiency” training cannot be accomplished during the same session.
Later, on p. 1353, it says “During a scheduled FSTD course, if a task is performed
unsatisfactorily the pilot may retrain….” These paragraphs are in conflict.
24. RAA requests that CAP (Part 121.1355) not be adopted until guidance material
in the form of a draft Advisory Circular, available for public review and comment,
be first developed to explains how CAP will be administered.
The provision provides very little detail in how operators will receive approval for a
Continuous analysis process (CAP). It is certainly more stringent than AQP in that AQP
requires only an annual standardization meeting; the proposal requires semi annual
meetings. This proposal “suggests” that individual performance of pilots must be
measured and monitored; AQP assess the training program is total. We at least know
what changes are needed to qualify for AQP; we have no idea what is required to achieve
approval for CAP.
Subparts (b) and (c ) are redundant to previous proposed requirement found in the
proposed 121.1337 Training program: Approval and amendment process provision;
please see our comments about 121.1337 indicating that it is also redundant to the current
revision process found in Part 119.
25. FAR 121.1345 Training Program: Mandatory use of flight simulation training
devices. RAA requests that this proposal be withdrawn. If the proposal to mandate
use of flight simulation devices is nonetheless adopted, RAA requests that the rule
provide a process for approving deviations be greatly expanded.
Our members support extensive use of simulators as a cost effective training tool but we
cannot support a proposal that mandates their exclusive use when situations arise when
their use is highly impractical and costly for an operator. The preamble points out that
using a FSTD rather than airplanes for training allows for “more in-depth training in a
safer environment”. We agree that this is a valid reason why the use of FSTD’s is a first
choice for flight crewmember training; however we cannot agree it should be the “only
choice”. There are numerous valid reasons why an air carrier may choose to conduct a
limited amount of their training in an aircraft; a mandate for mandatory simulator usage
severely limits the flexibility every carrier needs to efficiently meet their training needs.
For example we have one member stationed on the East Coast and the FSTD’s for their
aircraft type located on the East Coast are usually booked up solid several months in
advance; should this member require one more operating cycle of training for a check
airmen and should this proposal be adopted, they would have to send this airman to the
only other simulator for their aircraft type on the West Coast; in other instances their only
other options would be to sit and wait until a simulator becomes available. Certainly you
cannot argue that training in an aircraft is less effective than a FSTD in every instance.
We are also disappointed that the preamble makes it very clear that the deviations that
will be granted are very limited in scope; “The FAA does not intend that deviation
provide a loophole for certificate holders who want to continue training and evaluating
in aircraft.” Certainly the FAA’s grant of a deviation would not occur for our example
above. We cannot state with any certainty that among all the FAA approved simulators
currently in use, that all advanced maneuver scenarios can be performed with full motion
simulators currently in use; for example many simulators cannot duplicate full stall
conditions. In most cases the expense of reworking existing simulators or purchasing new
ones is cost prohibitive. We note that cost benefit analysis did not include any costs for
simulator rework or the purchase of new simulators so, we assume that the current
simulators are acceptable for meeting the intent of this proposal. Our assumption
however contradicts the basic premise of this proposal, namely that “the primary purpose
of the NPRM is to establish new requirements for traditional air carrier training
programs to ensure that safety-critical training is included.”
Proposed FAR 121.1345 states that deviations are allowed provided operators submit
their requests within 120 days after the effective date of the rule. RAA requests that no
time period be specified for requesting a deviation.
90 day currency- considered
26. RAA requests that proposed provisions 121.1355(b) and (c ) be withdrawn as
Proposed provisions 121.1355(b) and (c ) are redundant to 121.1337(d) and (e). It should
not be necessary to have repetitive provisions to state that the FAA has complete
authority over an operator’s training program.
27. RAA requests that 121.1361 Job Performance Training remain unchanged at 4?
QPS 9 months cycle!!
AQP requires once a year-continuing
121.1361 Annual Job Performance Training proposes 8 hours of training; this translates
into two days of 4 hour simulator training. For most operators they will need to bring in
their pilots for 3 days of Ground School, then do a check-ride the next day. Since you
would need to provide a travel day for before and after the training session on either side.
With the new 2 days of just Job Performance..that runs our guys up against 7th day off
(Extra hotels, etc.)
28. RAA requests that crew training for and initial or upgrade class of first officers
not be required (Reference: proposed Part 121.1365)
Qualification LOFT is conducted after a person completes the proficiency test ….
This order of events has not been mandatory till now. It is not unusual for a crew to be
scheduled for checking, but for some reason it cannot be accomplished on the date. Now,
we can use the time to accomplish the LOFT, but under the proposal we would lose the
More stringent than AQP!
Substitution policy- two FO is acceptable under AQP
Labor uion conflicts
36hours initial vs 20 so how do you match up!
121.1365: All Initial training has to utilize crews. This is HUGE. If we just want to run
an Upgrade class or a class of new First Officers…we can’t do it without very expensive
instructors as seat fills. – 121.1365 states “qualification LOFT is required after a person
completes proficiency test at end of initial, or upgrade- is this a big issue? Iis there any
research to point to that justifies the added benefit?
29 RAA request that 121.1367 (b) 1
…The first recurrent job recurrent LOFT.
… the first recurrent job performance training module … following the proficiency test
… must include a proficiency test.
So, when a new CA comes in for his first check following the Type Rating, he must have
both a 4-hour LOFT and a proficiency test – with no allowance for training to
proficiency as now provided in a 441 PC or a 427 RFT. And how does this fit with the
“at least 8 hours” of training we were already distressed with on the call? The
suggestion that there be a test conflicts with the spirit of AQP, which is cited as superior
training. One would expect the LOFT to be revealing, and that would provide instructors
insight on the specific areas that might deserve further training. This proposal makes no
accommodation for such training.
30 RAA request that 121.1377(c)
The required subject matter includes the current requirements in App. H training. Can
we anticipate that this recurrent will suffice for the App. H as well?
31. RAA requests that the baseline hours for initial ground training for turboprop
pilots remain unchanged at 80 hours
Is new hire in addition to initial?? Not clear Table 2A
Different cirriculums between table 1A and 2A-clarification definition is the same
Minimum is minium!
For New Hire/Initial ground training, a turboprop operator must increase the initial
ground training from 80 hours [121.419(b)] to 120 hours (Baseline -Appendix Q,
Attachment 1 Table 1A); turbojet operator training stays the same. The new requirements
states that the “baseline hours” can be reduced “if the certificate holder demonstrates that
the reduction is warranted”. Proposed 121.1335(d) states that the FAA will allow a
reduction in academic training to certificate holders described in Part 135 but as we
mentioned above, there are no Part 135 operators affected by this proposal..
No rationale was provided on why the turboprop ground school program should be
identical to that of the turbojet operators. Ground school training is where the pilot learns
about the aircraft systems and we see is a significant difference in complexity between
the systems on for example, a Beech B1900 turboprop and a Boeing 747; given this
difference it makes no sense to treat all Part 121 aircraft as equal. We request that the
hours provided in FAR 121.419(b) remain unchanged.
If the FAA nonetheless adopts the same baseline hours for all aircraft operating under
Part 121 again we request that guidance in the form of an Advisory Circular available for
public review and comment that defines the authority of the POI in granting a reduction.
121.1281 (d) (1) – Requires Flight Instructors who are authorized under 121.1229 (c)
(use of FFS to maintain 90 day takeoff and landing currency) complete 5 takeoffs and
landings and the maneuvers and procedures prescribed in the QPS in an FFS. Not sure
what this refers to. It could be the Takeoff and Landing 90-Day Recency of Experience
subparagraph #3 on NPRM Page 1348.
Training done within 30 days when it starts-military leave, drops out recycles –hard
rules, holiday –labor agreements, death in family- take a week off; facility lost
121.1343 Test questions have to be approved by FAA for every class? Look in QPS-
random bank of test questions: AQP isn’t as stringent- the form and content (table
2A) must approve every test!! Have to approve every question in your bank
121.392(a) requires any person serving as a flight attendant to meet all the flight
attendant training requirements whether or not they are a “required” flight attendant
(above the minimum required for the airplane type). Is this a problem?
121.1369 (d): States that New Hire training must be completed prior to the start of Initial
Training. This could be impractical and is not based on the building block theory of
learning. Example – based on Appendix s Attachment 2 (NPRM Page 1421 and 1423, a
new hire flight attendant would complete training on Emergency Equipment, Safety
Equipment, Cabin and Cabin Systems prior to any aircraft training including components
of aircraft, aviation terminology, etc.
26. RAA requests that proposed provision FAR 121.1303 Flight Attendant:
Continuing qualification be withdrawn
We see no need why the proposal must introduce a new term, “continuing qualification”
to describe a flight attendant standing. between the different duty positions. As we have
mentioned above much of this proposal has no basis in safety but simply seeks to add
complexity and change to the administrative requirements that have been in place for
years. This proposal is unnecessary and its administrative value could easily be
incorporated into other proposed provisions.
121.1305 eliminates operating experience while working from one certificate holder to
count for another certificate holder; is this a burden?
(g) eliminates operating experience credit (50%) for training in a full-scale cabin training
device- this seems to contradict what’s required of pilot, i.e. that all training be in a sim.
Is this a burden?
121.1321 Check flight attendant: Is it necessary that a check flight attendant be FAA
approved? Why can’t they simply meet the criteria in (b)?
121.1323 Check flight attendant: initial cadre:
Have served at least 3 years in the past 6 years as a flight attendant on an aircraft of the
same group in which the person is to perform duties as an initial cadre check flight
attendant.- how would a turboprop operator convert to an RJ operation?
QPS states that a flight attendant should “review 382”- this should at least state, “where
The proposal is not scalable, particularly for flight attendants and dispatchers; We have
members that will have a flight attendant on a Saab 340 carries 34 passengers; compare
this to a mainline flight attendant that may operate on a Boeing 747 and/or 777.
Relocate flight attendant training to its own subpart
I don’t see language where it says “where appropriate” flight attendant talks about
“galley lift, carts, etc. and regional airplanes don’t have that
Appendix T (NPRM Pages 1442-1443) – Limitation on Distance Learning not justifiable.
FAA will not allow more than 50% of programmed hours to be credited for as DL.
(Dispatch) Computer Systems – DL Not Allowed
Contingency Operations for Maintaining Operational Control in the Event of Single or
Multiple System Failures - no DL allowed. This appears to be a knowledge element.
30. RAA request that “distance learning” be added as an option to the Pilot and
Flight Attendant training process
Distance Learning is mentioned in the preamble as an option for academic training;
however within QPS appendices it is mentioned only within the Dispatcher training
program (Appendix T). The benefits of the Distance Learning process have long been
recognized; to avoid confusion and for the same reasons that this proposal has added it to
the Dispatcher training curriculum we request it be added to the Flight Crewmember and
Flight Attendant training programs.