Autoridades competentes

The FAA received over 120 comments regarding whether the FAA should require a training course prior to taking the ATP knowledge test. More than 30 commenters, including

12 _{The FAA has modified section 61.159(a)(5) to permit pilots to credit FSTD time accomplished in approved} training programs under parts 121, 135, and 141 toward the aeronautical experience requirements for the ATP certificate. Under the prior rule, only FSTD time accomplished as part of an approved training course in part 142 could be credited.

Delta, A4A, CAPA, CAA, Parks College, and the Families of Continental Flight 3407, generally supported such a training course. An equal number of commenters including the University of Dubuque, Delaware State University (DSU), and numerous individual commenters generally stated such a course is unnecessary. Many commenters addressed specific elements of the proposal and suggested some alternatives which will be addressed later in the document.

IATA stated that the additional training for the ATP certificate is appropriate because the current requirements are inadequate and have become irrelevant. Boeing agreed with the FAA’s rationale for the ATP CTP and asserted that pilots who successfully complete the program would have the needed “foundational knowledge to operate as second in command (SIC) in part 121 operations.” AAL echoed Boeing, indicating that the added training would provide valuable experience to future part 121 pilots. The National Air Disaster Alliance Foundation (NADA/F) was also supportive of the proposed course and highlighted the use of a standardized course of training. USAPA supports the additional training maintaining that it is more effective than just having a multiple choice exam. UAA supported pilots completing ground training prior to taking a knowledge test.

Several commenters, including Aerosim, Middle Tennessee State University (MTSU), FSC, and WMU, support additional training but disagree with it being required for the

knowledge test. ERAU, KSU, and 20 individual commenters support the additional training being part of a degree program or collegiate flight training program. Spartan College suggested it be part of an overall collegiate curriculum rather than a single course.

Purdue, OSU, and the University of North Dakota (UND) suggested allowing the academic and FSTD portions of the proposed course to be completed at separate times enabling students to complete the academic portion as part of their degree program. The universities

added that many of the topics are already covered as part of the degree program and graduates should get credit for the academic portion of the proposed course and therefore only have to complete the FSTD portion at a later time. They also suggested allowing the knowledge test to be completed following the academic portion, which falls more in line with how knowledge areas for other FAA pilot certificates are tested.

ExpressJet supported imbedding the ATP CTP training into an air carrier’s initial training program. The Aircraft Owners and Pilots Association (AOPA) equated the ATP CTP to the AJT course the FOQ ARC recommended for pilots entering part 121 service and therefore disagrees that the ATP CTP should apply to all pilots required to have an ATP certificate. AOPA

suggested the FAA “reword the AJT requirement so it is required only of individuals employed by part 121 air carriers, prior to flying in revenue service and not as a prerequisite to all ATP

certificates.”

OSU generally agreed with the academic portion of the course but believed the FSTD portion of the course “represents an overwhelming financial burden” to ATP certificate applicants. Many other individual commenters disagreed with imposing additional training requirements on pilots seeking an ATP certificate, in part due to the additional cost. The General Aviation Manufacturers Association (GAMA) stated an ATP applicant has already gone through ample training and this course would just be an extra cost burden and was unlikely to provide any additional safety benefit. GAMA, however, expressed support for the proposed FSTD portion of the training course, indicating that such training can be “extremely beneficial.” NATA believes the course as proposed is too costly. NATA is supportive of modifications to the ATP certification regulations, but indicated the delivery of any new training should be made available through lower cost methods, such as on-line course delivery.

Based on the support for additional training expressed by many of the commenters, the FAA has decided to require academic and FSTD training for the ATP certificate multiengine class rating and the ATP certificate when obtained concurrently with an airplane type rating.13 This training, required at the ATP certification level, will address the gap in knowledge between a commercial pilot certificate and the knowledge a pilot should have prior to entering an air carrier environment. In addition, the FAA has decided that the safest and most effective way to ensure that applicants for an ATP certificate have met the requirements of section 217 of the Act is to establish specific training requirements and evaluate the pilot’s understanding of those areas of instruction consistent with the regulatory framework for other pilot certificates.

To the extent that several commenters suggested that the coursework in university aviation degree programs already may satisfy the academic training requirements of the ATP CTP, the FAA does not agree. Many colleges and universities teach ground school for other certificates and ratings as part of their academic curriculum that include a general overview of topics for which the collegiate program has comprehensive standalone courses. For example, despite most collegiate programs having a separate aerodynamics course, this topic remains a component of private pilot ground school and is generally reinforced in a concurrent flight training lab. The aerodynamics training for private pilots generally applies to small, single- engine, piston-powered aircraft—the type of airplane most people initially learn to fly. Similarly, the academic portion of the ATP CTP (essentially ground training for ATP certification) will focus on the aerodynamic principles for large turbine aircraft—the type of aircraft flown in part

13 _{The FAA notes that a pilot is not required to take the ATP CTP for a type rating added to any other pilot} certificate. The requirement only applies to pilots obtaining an ATP certificate concurrently with an airplane type rating. In addition, subsequent airplane type ratings added to an ATP certificate that already has a multiengine class rating would not require taking the ATP CTP.

121 operations as well as many operations in part 135 and subpart K of part 91. The ATP CTP will then incorporate those concepts learned in the academic portion of the course into practical scenarios during the FSTD training to reinforce the critical concepts of operating at high altitudes and its effects on the airplane and the importance of stall recognition and recovery. The FAA supports colleges and universities with FAA certificated part 141 pilot schools teaching the ATP CTP but as a standalone course, just as they do with ground schools and flight labs for other pilot certificates and ratings.

The FAA also maintains that the academic training requirements cannot be separated from the FSTD training. The FAA has acknowledged the value of structured university aviation degree programs in other parts of this final rule; however, the design of the ATP CTP ensures the knowledge gained in the academic portion of the course is directly applicable to air carrier operations and operating sophisticated, high performance, large, turbine aircraft. The training in the FSTD portion of the course consolidates the academic concepts with scenario-based training, practical applications, demonstrations, and multiengine experience. The course will consolidate many broader topics and focus on its applicability to air carrier-like operations. For many pilots who take the ATP CTP, it will likely be their first exposure to large turbine aircraft and how those aircraft perform at high altitude, how they perform in low energy states, and in adverse weather phenomena, like thunderstorms and icing conditions. Combining the academic training requirements with the FSTD experience is the most effective method to consolidate the learning and deliver the training and experience mandated by the Act.

Additionally, the FAA has determined that students must complete both the academic and FSTD training prior to taking the knowledge test. By separating the academics and flight

career, the learning objectives are less likely to be achieved. In light of that fact, the knowledge test cannot be taken following completion of only the academic portion of the course. The FAA is retaining the requirement that a pilot complete all of the ATP CTP to be eligible to take the knowledge test.

To those commenters that suggested the ATP CTP be incorporated into air carrier initial training because the subjects are already taught or because the training only applies to pilots in part 121 operations, the FAA disagrees. The ATP CTP is the base upon which a pilot must build. The concepts in the course will apply to any pilot who flies a large turbine aircraft regardless of operating rule part and therefore has value to pilots flying outside of part 121. The ATP CTP will cover topics the air carrier is not required to teach. For those general knowledge areas that are currently part of a part 121 initial training program, the FAA has modified subpart N to remove those requirements and reduce ground training for those pilots who have completed the ATP CTP. A pilot in an air carrier training program receives training specific to the air carrier’s operation and the specific aircraft that pilot is going to fly. Even if the subjects are offered by an air carrier in initial training, the pilot is focused primarily on learning the company operation and the specific type of aircraft they will fly, not on broader, foundational concepts that the ATP CTP is designed to provide.

The FAA recognizes commenters’ concerns regarding the cost of the proposed ATP CTP and considered these costs when establishing the requirements for the course. Section 217 of the Act directed the FAA to modify the requirements for ATP certification to include ensuring that applicants for the ATP certificate have sufficient flight hours in difficult operational conditions “that may be encountered by an air carrier.” The FAA sought input from the FOQ ARC on how to define difficult operational conditions and how a pilot can best obtain experience in those

conditions. As indicated it its report, the FOQ ARC “extensively discussed the issue of difficult operating conditions and determined that simulator training is an important tool by which to provide flight experience to the pilot for recognition and appropriate response in the difficult environments experienced by air carriers.” Because of safety concerns, the FOQ ARC did not recommend that pilots be intentionally placed in these difficult conditions in actual aircraft. The FOQ ARC recommended scenario-based training to address difficult operating conditions including thunderstorms, icing, low visibility, maximum crosswinds for takeoff and landing, and contaminated runways.

Generally, pilots from their earliest training are taught to avoid thunderstorms and icing conditions. Even when flying an airplane approved for flight in icing conditions, a pilot is

cautioned to minimize time flying in icing conditions. The FAA will not encourage pilots to seek experience in hazardous conditions for the purpose of meeting the aeronautical experience requirements for the ATP certificate required by the Act. The FAA has long recognized that flight simulators and flight training devices provide a safe flight training environment that can reduce the number of training accidents by allowing training for emergency situations, such as fire, total loss of thrust, and systems failures, that cannot be safely conducted in flight. 61 FR 34508 (July 2, 1996). Therefore, the FAA has determined that many of the difficult operational conditions can be most safely demonstrated to students through simulation. Simulation will be discussed in greater detail later in this section.

Although the Act permitted the FAA to consider operational experience as a means of ensuring that a pilot has received adequate flight hours in conditions such as adverse weather, high altitude operations, and an air carrier operational environment, the FAA has determined that it is not appropriate to encourage pilots to seek such conditions in an aircraft. In addition it would

be difficult to validate experience in those conditions. Moreover, it would be difficult for pilots to obtain experience in the complex aircraft that would be required to replicate an air carrier operational environment.

Therefore, the FAA has determined that academic and FSTD training, followed by an evaluation through a revised knowledge test that includes the content of the course and subsequent completion of a practical test will meet the requirements of the Act and provide valuable training for the ATP certificate.