A Descriptive Analysis of Public Comments Submitted in Response to Notice of Proposed Rules on Air Carrier Pilot Qualification

In 2009, the crash of Colgan Flight 3407 in Buffalo, NY raised concerns regarding the adequacy of current pilot qualification standards for entering air carrier operations. In response, the U.S. Congress enacted Public Law 111-216, which requires a pilot to hold an Airline Transport Pilot (ATP) certificate in order to be qualified as a flight crewmember under 14 CFR, part 121, and also allows the Federal Aviation Administration (FAA) to modify the requirements to obtain an ATP certificate. In February 2012, the FAA issued a Notice of Proposed Rulemaking (NPRM) outlining these requirements and calling for public comments on the proposal. This study was a descriptive analysis of those comments. The results indicated several different findings, including a need for more qualitative standards. The majority of respondents suggested replacing the specific flight hour requirement to obtain an ATP certificate with competency-based standards. The majority of respondents indicated that full-motion simulation training is not necessary for the ATP Certification Training Program (CTP), and many suggested that the specific level of simulation should depend on the type of training being conducted. Responses were also vastly in favor of an ATP certificate with restricted privileges offered to those with military and/or academic training and experience, and many suggested expanding this option to other types of candidates