ATA Responds to the Aviation Subcommittee on Pilot Qualifications

October 13,2009

Dear Chairman Oberstar, Ranking Member Mica, Chairman Costello and Ranking Member Petri:

On behalf of the airline members of the Air Transport Association of America (ATA), I am writing in reference to Section 10 of the Airline Safety and Pilot Training Improvement Act, H.R. 3371. As safety remains the industry's top priority, we support your continuing leadership in addressing critical issues relating to pilot training, qualifications and other safety-related measures.

We, however, are concerned that the requirements in Section 10, Flight Crewmember Screening and Qualifications , are overly prescriptive and will result in significant unintended consequences. Section 10 (a) (2) (B) (i) requires all flight crew members for part 121 air carriers to obtain an Airline Transport Pilot (ATP) license under part 61 of Title 14, Code of Federal Regulations, among other requirements. To be eligible for an ATP - an advanced pilot certificate - an individual must have a minimum of 1,500 hours flight time, be at least 23 years of age and satisfy numerous specific technical and testing requirements. Understandably, the laudable intended goal of this mandate is to achieve a more highly skilled pilot work force.

That goal can be achieved without imposing a mandate that will result in unnecessary and artificial barriers for qualified, experienced pilots. Preventing demonstrably capable, highly motivated candidates from applying to fly for the nation's airlines will not benefit any of us.

By equating experience with total flight time or a level of technical certification, the mandate will punish many highly qualified pilots and significantly reduce the pool of pilot candidates, particularly for regional carriers. Seasoned pilots with actual experience as commercial pilots on multi-engine aircraft with a Commercial Multi-Engine instrument rating and a type rating, as well as highly qualified military pilots, will be forced to build hours by instructing or flying small single-engine aircraft. Additional years and additional tens of thousands of dollars spent to obtain the necessary 1,500 hours simply will not result in more competent pilots.

In addition, those who have completed in-depth, focused airline-oriented academic and flight training degrees at nationally recognized flight training academies will be excluded from flying commercially, solely due to the 1,500-hour requirement. Focusing solely on the number of flight hours, as opposed to the overall quality and nature of the combined academic training and flight hours experience, will not result in a safer, more professional pilot work force. It is the quality of the experience and the training that our members focus on in making employment decisions, and which they are committed to improving as necessary.

Rather than prescribing an unnecessarily prescriptive mandate, the formation of an Aviation Rulemaking Committee (ARC) to address pilot licensing requirements will provide a thorough examination of the issues by knowledgeable stakeholders. To ensure that the solutions address any perceived shortcoming of the current requirements, all options should be on the table. As the fundamental issues are considered, it is important to note that Advanced Qualification Programs are used at many airlines to develop tailored training programs and hiring qualifications to ensure the best pilots for their individual operating environments and aircraft as long as the Federal Aviation Administration determines the programs provide an equivalent or higher level of safety to traditional programs.

In closing, the formation of an ARC, with a set timeline and deliverables, including recommendations for enhanced pilot training and licensing, offers the best way forward. The ATA and its member airlines fully support this effort and will participate at the highest levels. I welcome the opportunity to discuss these issues further with you and appreciate your continued leadership and stewardship.

Sincerely,