Aviation Accreditation Board International Response to the Notice of Proposed Rulemaking

Transcription

1 Introduction: The Aviation Accreditation Board International (AABI) is pleased to submit this response to the NPRM. This submittal will be sent both electronically on the FAA Web site and by package courier. The AABI Board of Trustees, based on responses from educator members whose institutions offer AABI-accredited Flight Education programs, formulated this response. Many of these institutions will provide independent responses to the NPRM this response does not replace or supersede those submittals. Accreditation and FAA Recognition of AABI Programmatic Accreditation: Accreditation is a common post-secondary practice in the United States as a peer reviewed process to assure all stakeholders of both institutional and program quality. It is of critical importance that the FAA understands the difference between the types of accreditors: institutional accreditors and programmatic accreditors. Institutional accreditors include regional, national faith-based and national career-related accrediting organizations that review entire institutions; whereas programmatic accreditors include professional and specialized accrediting organizations that review specific programs or subject area offerings. Specialized and professional accreditors, like AABI, accredit degree-granting programs in particular disciplines or program areas. Specialized accreditors review programs or schools/colleges within institutions. Specialized and professional accrediting bodies in the U.S. operate to ensure that students in educational programs receive an education consistent with standards for entry into practice or advanced practice in each of the respective fields: Engineering ABET; Business AACSB; Medicine LCME; Law ABA; and also include nursing, architecture, pharmacy, teacher education and veterinary medicine, to name but a few. AABI is the only professional accreditor for aviation programs. A full listing of national, professional and specialized accrediting bodies as published in the 2012 Higher Education Directory is included as ATTACHMENT 1. Who Accredits the Accreditors? The Council for Higher Education Accreditation (CHEA) is a private organization that recognizes all accreditors that accredit degree-granting institutions or programs. AABI was first recognized by CHEA as a specialized accrediting body in A copy of the CHEA response to the NPRM from Dr. Judith Eaton is included as ATTACHMENT 2. The U.S. Department of Education (USDE) recognizes institutions and schools that seek federal aid for students and/or foreign student visas. Regional and faith-based institutions must be CHEA recognized prior to USDE recognition. USDE typically does not recognize specialized or programmatic accreditors, rather the institutions where such programs reside. CHEA and USDE recognize many of the same accrediting organizations, but not all. As the lack of federal funding continues to decrease, more and more accreditors are opting out of USDE recognition, but choosing to retain CHEA recognition. An important example of this is the Accreditation Board for Engineering and Technology, Inc. (ABET), the premier program accreditor for engineering programs. ABET dropped its USDE recognition approximately eight years ago because it did not benefit engineering students. Similarly, AABI sees no benefit to recognition by the USDE unless funding is restored for aviation students. There has been much debate since the issuance of the NPRM about the definition and meaning of the word accredited as it appears in the NPRM. The NPRM does not clarify the use of the term accredited and because of this some believe the meaning is vague and up for interpretation. Some have argued that any form of accreditation, from any agency meets the NRPM s definition. Some have argued that any form of accreditation, even those that are not specifically related to aviation meets the NPRM s definition. The AABI position is that the definition and use of the word accreditation, in the context of the NPRM, should not be vague as the issue was previously resolved when the FAA transferred the recognition for non-engineering aviation collegiate programs from the Airway Science program to AABI (formerly the Council on Aviation Accreditation [CAA]) effective December 31, After that date, the only formal recognition available for collegiate, non-engineering aviation programs was accreditation by AABI/CAA. A copy of the letter dated March 20, 1995, from the FAA is included as ATTACHMENT 3. The FAA previously transferred accreditation responsibilities to AABI/CAA and therefore it is the position of AABI that the term accredited as it is used in the NPRM, means only AABI-accredited aviation programs. April 25, :15:19 PM

2 It is noteworthy that the AABI Board of Trustees, consisting of 46 members, is comprised of a diverse cross section of aviation organizations and professionals of which 14 represent the academic community; and the remainder come from all segments of the aviation industry including corporate, practitioner, trade associations, public-at-large, international and government liaisons. Current liaisons are with the FAA, Transport Canada and the International Civil Aviation Organization (ICAO). See ATTACHMENT 4 for the full Board listing. Thus, the concept of aviation program accreditation, a rigorous peer-based process involving all segments of the aviation community, confers upon graduates of AABI-accredited programs the benefits of a substantive and rigorous examination of the education and training process which meets to the highest degree the intent of congressional mandate in PL , The Administrator may allow credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement. Academic Credit Recommendation: AABI recognizes that there are many paths by which an individual may obtain the combination of aeronautical knowledge and flight experience necessary to earn an ATP SIC. Section 217 of H.R provides the authority necessary for the FAA to authorize the use of an aeronautical academic training credit system. The FOQ ARC Report dated September 28, 2010, included Table 1 Academic and Practical Training Program Valuation with regard to Aeronautical Experience Credits, which is included as ATTACHMENT 5. AABI was represented on the FOQ ARC and supports its recommendation to establish an aeronautical academic training system that addresses the various pathways. FSTD Recommendation: AABI-accredited Flight Education programs are deeply concerned regarding the possible requirement for Level C simulators. The high cost of Level C simulators would be outside the budget of virtually all collegiate programs and would contribute minimal training value. Even ICAO Document 9625 does not recommend full flight simulation with motion. In Draft Advisory Circular 61-ATP Section 16a, it calls for an FSTD Level 4 or higher with a visual system providing an out-of-cockpit view as an appropriate device. The FOQ ARC discussed this matter at length and defined difficult operating conditions and addressed the required pilot experience (see 3.4, page 22 of the Report). In the interest of safety, the FOQ ARC recommended flight proficiency training be conducted in a flight simulation training device using realistic scenario-based training. AABI is in strong agreement with the FOQ ARC recommendations, which did not specify an FFS. Schedule Concerns: AABI members educators, employers and providers of training support resources are deeply concerned about the schedule to implement the new rule. Scenario 1: If the FAA is able to expedite the publication of the rule to publication before about August 1, 2012: o AABI will have an opportunity to put processes in place to handle new applications for accreditation prior to the new rule being implemented. o Collegiate aviation programs not yet AABI-accredited, associate and baccalaureate programs will have an opportunity to initiate the accreditation process and pursue AABI accreditation. o Training organizations will have a year to plan the implementation. o Employers will know the amount of credit available from academic, military, and flight experience, and can design their employment and indoctrination plans accordingly. o Employers will have an opportunity to develop agreements with AABI-accredited programs defining a career path for first officers specifically and professional pilots in general. o o Students will have an opportunity to plan their education and employment applications. Training equipment manufacturers will be able to plan production of equipment consistent with the provisions of the final rule and the demands of their customers. Scenario 2: If the FAA does not publish the rule until close to the July 2013 time period, all stakeholders must base their planning on worst-case scenarios in equipment acquisition, training content and credit for academic, military, and flight experience. o Training organizations will have to plan on arranging for Level C simulation, either purchased or leased. April 25, :15:19 PM

3 o Overall industry simulation capacity will be strained and may not be able to provide for the demand. o Employers will have to plan for fragmented training of new hire intake based on worst case flight hour requirements; including the possibility of no military or two- or four-year university academic credit; specifically 1500 hours. o Employers will have to develop new parameters for new hires. o Students may opt out of the career path because it is too volatile, compensation too uncertain, and training is fragmented. o Training equipment manufacturers will gear up for production that may not be required, or fail to gear up and create a gap in the flow of new first officers into air carrier service. o In a worst case, aircraft will be grounded because of lack of crews and a significant number of cities could lose service. Scenario 3: If the FAA fails to publish the rule before August 1, 2013: o The delay in publishing the rule will furlough American workers. o The current ATP will be required by the default provision in PL This condition will cause the maximum number of hours to be required, result in the greatest amount of non-constructive and unrelated flying by first officer candidates, and fail to apply the desired new competencies associated with air carrier crew-based operations. o Students may understandably opt out of the career path because it is too volatile, compensation too uncertain, and training is fragmented. o The eventual promulgation of a new rule will require phasing so that incumbent first officers have sufficient time to acquire the requisite competencies and qualify for the provisions of the rule. April 25, :15:19 PM

4 (1) Is a minimum of 1,500 hours adequate in order to receive an unrestricted ATP certificate? Why or why not? Response: Yes, for an unrestricted ATP certificate. However, AABI s position has not wavered in the importance of quality over quantity. The quantity-driven hour requirement does nothing to address the depth and breadth of the education or training received. The empirical data included in the FOQ ARC Report based on the 2010 Pilot Source Study supported the importance of new hire performance in graduates of AABI-accredited programs and a structured training environment. (2) As a result of the new ATP requirement for pilots in part 121 operations, what will be the impact on pilot supply for part 121 operations? For part 135 operations? For part 141 pilot schools? For part 142 training centers? Response: The ATP minimum requirements of 1500 hours and age 23 would have negative consequences for part 121 air carriers. AABI is particularly concerned that the specification of an unreasonably high, arbitrary number of hours not become a proxy for first officer qualifications. Instead, AABI-accredited programs focus on competency-based education concepts, systematic integration of academic and laboratory experiences, and scrupulous development of qualifications required to perform as a first officer. As stated in PL : The Administrator may allow credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement. Part 135 operations can be a constructive way for aspiring first officers to build time; they can earn money and the operation builds experience related to part 121 operations. Generally speaking, a requirement for the SIC to hold an ATP to support two pilot part 135 operations is viewed as an adverse effect, and potentially removing a venue for constructive time building. Part 141 and 61 pilot schools affiliated with collegiate aviation programs could be devastated by the illogical number of flight hours required and believe that the number of hours should be a function of the quality of the education and training experience and suggest academic credit as recommended by the FOQ ARC and included in ATTACHMENT 5 be reconsidered by the Administrator. In addition, AABI educator members with accredited Flight Education programs who would consider teaching under , a major concern is the eight hour requirement in a Level C simulator. The FOQ ARC discussed this matter at length and accepted that a Level 5 FSTD (FTD) with a suitable visual system was the appropriate device for the intended learning. Further, the high cost of Level C simulators would be outside the budget of virtually all collegiate programs and would contribute minimal training value. Even ICAO Document 9625 does not recommend full flight simulation with motion. As stated in PL : The Administrator may allow such credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement. AABI supports academic credit based on various educational tracks, including AABI-accredited two- and fouryear collegiate aviation programs. The NPRM as written completely disenfranchises associatelevel programs across the country, potentially decimating one source of the pilot supply chain. April 25, :15:19 PM

5 Most part 142 training organizations are airline employers and already own level C FSTDs which would have a highly positive effect on part 142 training organizations. However, these devices are highly utilized for transition and recurrent training, and additional devices would need to be manufactured and purchased to meet the incremental requirement for qualifying hundreds of first officers per year. (3) Is 50 hours in class of airplane too high, too low, or adequate in order to receive an ATP certificate with airplane category multiengine class rating? Please provide evidence for your response. Response: The consensus from the AABI-accredited Flight Education programs was that 50 hours is adequate. Additional simulation credit should be considered. (4) Should SICs in part 121 air carrier operations be required to hold an aircraft type rating? Why or why not? Response: Yes, we agree, it is appropriate for SICs to hold an aircraft type rating in the aircraft they are flying. It is an expected responsibility of air carriers prior to revenue service. (5) Should all SICs be required to hold an aircraft type rating if the aircraft currently requires a type rating for the PIC, regardless of the rule part of the aircraft is operated under (e.g. part 91, 125 or 135)? Why or why not? Response: No. There are sufficient regulations in place for part 91, 125 and 135 operations. (6) Should pilots wanting to obtain an ATP certificate with airplane category multiengine class rating or type rating be required to take an additional training course prior to taking the knowledge test? Why or why not? Response: AABI believes that additional training is required but needs to be part of the curriculum and not as a stand-alone-course. However, the sequencing and timing of the tests, the ATP knowledge, the ATP practical, and the type rating should be flexible enough so that a student can take the knowledge tests as part of an advanced jet training module integrated within an AABI-accredited Flight Education program. (7) If academic training is required in an ATP certification training course, what topics are appropriate? How many hours are appropriate for such a course? Response: A. To attain the First Officer ATP Qualification the candidate must: 1. Have completed the requirements for the private, commercial, instrument, and multiengine land certificates and ratings under FAR Part 61, 141, or 142 embedded in an AABIaccredited Flight Education program. 2. Have completed the First Officer Air Transport Pilot Qualification academic and practical modules in D. 3. Have acquired sufficient total hours flying time to demonstrate the associated competencies described in the academic and practical modules in D. 4. Have acquired sufficient number of total hours of operational flying experience in flight activities such as: flight instructor, charter pilot, corporate pilot, Part 91 pilot carrying passengers, or equivalent so as to demonstrate competency and experience associated with D Have completed the knowledge and practical examinations for the Airline Transport Pilot (ATP) certificate April 25, :15:19 PM

6 6. Be of high moral character. B. The requirements for A 1 (certificates and ratings) will have been completed by graduates of a college or university Flight Education program accredited by the Aviation Accreditation Board International. C. Academic and Laboratory Module Outcomes: The successful student will be able to: 1. Explain turbine engine theory 2. Explain high altitude airspace 3. Explain jet transport navigation and approach procedure chart interpretation 4. Describe air carrier aircraft flight guidance systems 5. Explain the effects of high altitude physiology 6. Conduct air carrier flight planning 7. Describe high altitude weather 8. Explain weather radar 9. Describe severe weather avoidance procedures 10. Describe aircraft icing, anti-icing, de-icing, and the possible consequences of airframe icing 11. Explain FAR Part 121 Certification and Operations: Domestic Flag and Supplemental Air Carriers and Commercial Operators of Large Aircraft 12. Explain a jet transport flight management system 13. Explain a jet transport engine monitoring system such as EICAS 14. Explain air carrier operations procedures 15. Explain air carrier safety programs and issues 16. Describe and explain hydroplaning 17. Explain wind shear avoidance 18. Describe air carrier aircraft systems for an air carrier aircraft equipped with modern avionics. 19. Describe jet transport aircraft emergency procedures 20. Compute air carrier aircraft performance, weight and balance 21. Describe appropriate pilot professional responsibility and ethics 22. Explain the elements of good customer service 23. Explain concepts of aviation safety, to include FOQA, ASAP, and SMS 24. Apply crew resource management, crew concept procedures, and Line-Oriented Flight Training (LOFT) concepts in an operational environment such as in a transport category aircraft, FTD (Level 5) or Simulator. The device must be equipped with modern avionics (glass). Airline flows and procedures will be used. An upset training scenario is required. Sufficient hours of instruction are required in the device to demonstrate these competencies to a qualified and recognized FAA testing center. These modules will be an integral part of Flight Education programs accredited by the Aviation Accreditation Board International. Testing for module completion will be accomplished by the FAA or through an FAA-approved or designated testing center. April 25, :15:19 PM

7 (8) Should an ATP certification training course include non-type specific FSTD training on concepts that are generally universal to transport category aircraft? Why or why not? Response: Yes, the ATP certification training course should include non-type specific FSTD training on concepts. This training reinforces and demonstrates concepts covered academically. Faculty teaching in AABI-accredited Flight Education programs should be accepted as meeting the requirements for the FAA ATP CTP. (9) If STD training is required, what level of FSTD is appropriate? How many hours are appropriate? Response: An FSTD Level 4 or higher with a visual system providing an out-of-cockpit view is an appropriate device for the intended learning (DRAFT AC No: 61-ATP). (10) Based on the proposed content of the ATP Certification Training Program, what changes or reductions could be made to a part 121 air carrier training program? This question was intentionally not answered because it is beyond AABI s purview. (11) The FAA assumes parts 121, 135, 141 and 142 certificate holders will be able to provide the ATP Certification Training Program. What factors would these certificate holders principally consider in determining whether or not to offer the course? This question was intentionally not answered because it is beyond AABI s purview. (12) Should the FAA offer an ATP certificate with restricted privileges for pilots with fewer than 1,500 flight hours based on academic training and/or experience? Why or why not? If so, how many hours would be appropriate? Should anyone other than military pilots or graduates of 4-year colleges and universities with aviation-related degrees and commercial pilot certificates with instrument ratings obtained from an affiliated part 141 pilot school be eligible? Why or why not? Response: Yes, see answers for 13 and 14 below for military pilots and graduates of four-year colleges and universities with AABI-accredited Flight Education programs. (13) Should military pilots be allowed to receive an ATP certificate with restricted privileges? Why or why not? If so, is the proposed 750 hours too high, too low or adequate? Response: Yes, with ATP-CTP completion. The 750 hours is too high. The rigor and quality selection process for military pilots linked with highly structured training meets or exceeds the requirements of the NPRM. 500 hour minimum is appropriate. (14) Should graduates of 4-year colleges and universities with aviation-related majors and commercial pilot certificates with instrument ratings obtained from an affiliated part 141 pilot school be allowed to receive an ATP certificate with restricted privileges? Why or why not? If so, is the proposed 1,000 hours too high, too low or adequate? Response: Yes, graduates of four-year AABI-accredited Flight Education programs, with or without 141 certification, should be allowed to receive an ATP certificate with restricted privileges. The proposed 1,000 hours is too high. AABI suggests the FAA accept the FOQ ARC s recommendation because of the empirical data supporting the decreased minimum hours as evidenced in the 2010 Pilot Source Study. 500 to 750 hour minimum is appropriate. AABI recommends FAA give strong consideration for and recognition of the difference between institutional and programmatic accreditation, as was described in the Introduction. FAA also failed to include two-year, associate-level programs, which should be differentiated and afforded April 25, :15:19 PM

8 academic credit as was suggested in the FOQ ARC Report and included in Table 1 (ATTACHMENT 5). As stated in PL : The Administrator may allow such credit based on a determination by the Administrator that allowing a pilot to take specific academic training courses will enhance safety more than requiring the pilot to fully comply with the flight hours requirement. AABI supports academic credit based on various educational tracks, including AABI-accredited two- and fouryear collegiate aviation programs. The NPRM as written completely disenfranchises associatelevel programs across the country, potentially decimating one source of the pilot supply chain. (15) Should military pilots and/or graduates of 4-year colleges and universities with aviation-related majors and commercial pilot certificates with instrument ratings obtained from an affiliated part 141 pilot school be allowed to receive and ATP certificate without restrictions with fewer than 1,500 hours? Why or why not? If so, how many hours would be appropriate? Response: AABI advocates alignment with ICAO Annex 1 as it pertains to flight training. See response to question 18. (16) Should a pilot who obtains a degree with an aviation-related major from a 4-year college or university and a commercial pilot certificate with instrument rating from a part 141 pilot school not affiliated with the college or university be eligible for a restricted privileges ATP certificate? Why or why not? If so, how many hours should they be required to have? And, should there be a time limit between the baccalaureate training and the flight training if they were not done concurrently? Response: No, under the AABI accreditation model, student learning in the classroom is well integrated with learning in the flight laboratory. Programs must provide evidence that graduates possess the necessary knowledge, skills, and attitudes to competently and ethically function as professional pilots in the aviation industry. AABI-accredited programs that utilize either internal or contract flight training as part of a Flight Education program, the institution must assure that: a. Student learning in the classroom is well integrated with learning in the flight laboratory. b. There is a common approach to safety with a single, integrated and verifiable formal aviation safety program. c. Training equipment is acquired or upgraded to reflect current industry practice. d. Students have adequate access to training equipment and resources. The institution must provide instructional control, safety and oversight; and must teach all academic and ground school courses using faculty and instructional staff employed by the institution. Flight laboratory instruction may be taught by either an institution s instructional staff or by one or more qualified contractors. However, if the institution uses one or more qualified contractors to offer flight laboratory instruction, the institution must, through a formal contract or written agreement: a. Designate an appropriately qualified regular Full Time Equivalent (FTE) aviation faculty member to administer the Flight Education option and to provide responsible oversight of the contractor(s) to assure that the program meets or exceeds the performance requirements set forth in the AABI Criteria. b. Employ (as regular faculty, adjunct faculty, or as a consultant) a qualified flight standards pilot, who has no business or employment relationship to the independent contractor(s). The April 25, :15:19 PM

9 flight standards pilot must conduct periodic flight standards evaluations to determine that students enrolled in the Flight Education option meet or exceed the performance standards set forth by the institution and AABI Criteria for the option. Every academic semester or quarter, as appropriate, the flight standards pilot must conduct a formal evaluation of at least one student completing each flight course in the AABI-accredited curriculum. c. Ensure that flight instructors possess the appropriate aeronautical certificates and ratings. d. Ensure that flight instructors meet the employment requirements of the institution for an equivalent position. The relationship with the contractor must be expressed in document form and be available for review by all interested parties, including students, parents, institution departments, faculty and accreditation agencies. The document must include at least the following: a. A description of the relationship between the provider of flight training and the academic department(s) involved in supporting and relating curricula. b. A description of the committee and meeting structure specifying regular interchange of curricular requirements and suggestions between the academic faculty and the provider of flight training. c. The means of scheduling flight training in use by the institution and provider of flight training. d. The means of selecting flight training instructors for students, and the process available to students for changing instructors. e. The means for reviewing student performance in flight training, with their advisor. f. The means for curriculum and flight training program changes as a result of equipment and technology changes that may occur in both the flight training and academic curricula. (17) Should the FAA consider an alternative licensing structure for pilots who desire only to fly for part 121 air carriers (e.g. multicrew pilot license)? Why or why not? Response: Yes, the United States should be harmonized with ICAO Annex 1 as it pertains to flight training and the MPL. FAA has an obligation to align national regulations with international standards. (18) If the FAA were to adopt a licensing structure for a multicrew pilot license, what would be the appropriate amount and type of ground and flight training? Response: According to the ICAO requirements in Annex 1, Subsection , the minimum flight experience is 240 hours as pilot flying and pilot not flying of actual and simulated flight. However, training must be given by an Approved Training Organization (ATO), which means an organization that has a functioning quality management system. Another requirement is that the training be competency-based following a system methodology much like that for AABIaccredited Flight Education programs. (19) If all pilots in part 121 air carrier operations are required to hold an ATP certificate, should there be additional requirements prior to operating as a PIC in part 121 air carrier operations? If so, what should those requirements be? This question was intentionally not answered because it is beyond AABI s purview. April 25, :15:19 PM

10 (20) Is the proposed flight hour requirement for serving as SIC before moving to PIC too long, too short or adequate? Response: Too long. The move from SIC to PIC should not be based on number of hours. Rather, the decision should be competency-based. (21) Should the proposed PIC time in part 91 subpart K or part 135 operations counts towards the part 121 PIC requirement? Why or why not? Response: Yes, operations are in similar environments. (22) Should SIC time outside of part 121 operations count towards the proposed requirement? Why or why not? Response: No, non-similar responsibilities. April 25, :15:19 PM