NTAS 2012 Notes in response to the NPRM

NTAS 2012 Notes in response to the NPRM Where will the pilot supply come from? Reaching into the Middle Schools and the children s parents in order to stimulate interest future Airline Transport Pilots Question (Dr. Smith): How many of you (audience) are pilots? Response: About 90% of audience raised their hands Question (Dr. Smith): How many of you (that raised your hands) promote the airline industry and career to your kids? Response: About 10% kept raising their hands Gary Morrison ARC did address the issue, but the NPRM did not regarding the 2 year schools Airlines For America (Paul R.) Military surplus has gone away Competition between Regionals and Majors for University graduates NPRM will discourage people out of Aviation that shouldn t be there, but it will also discourage people that should be within the industry Need about a month for the ground portion of the new ATP requirement; 25 hours is insufficient Pathway explained would allow the non-university graduates to make it through into the airlines and that supply would still be Scott Foose (Regional Airlines of America) Disappointed by the FAA from the release of this NPRM Need to bring the FAA back to reality The data that was shown previously by Dr. Smith is being back up by the industry --BREAK-- Paul R. (A4A) FAA can moderate the NPRM and this will done because of the responses made by the student Page 1 of 20

Scott Foose (RAA) A son is considering leaving college and going to corporate aviation because of the NPRM and that the comments by the students and parents need to heard by the FAA in order to change the provisions made by the NPRM Gary Morrison Affirmed the fact that all comments made to the FAA for the NPRM that all comments that are similar in nature will be thrown together as one comment Is a minimum of 1500 hours adequate in order to receive an unrestricted ATP certificate? Agreement to question 1 is arbitrarily setting up for failure for a latter question Not willing to accept FAA not change 1500 hours and a substantial number that agree that a number (1500 hours) hours is not a proxy to determine competency Peter Dittmer UVU Answer the question and do not assume what the FAA is trying to say Take the question at face value Paul R. FedEx ICAO specifies 1500 hour minimum and we want to harmonize the FAA and ICAO FAA can file a deviation, but encourage harmonization Are we looking at outcome based? YES to question 1 WHY or WHY NOT? Tom Grossman West Michigan University Balance of competency between actual hours and flying at a part 121 carrier\ Hours are not a measure of competency Chris (Delta) Publish minimums for an interview is going against the fact that Hours is not a measure of competency ANSWER A- FAA should stay aligned with ICAO Page 2 of 20

Question 2- AS a result of the new ATP requirement for pilots in part 121 operations, what will be the impact on pilot supply? Gary Morrison ICAO will soon come out with standard training and will we will see some change with the ATP in possibly becoming a part of a new MPL ANSWER- D Question 2.2- What will be the impact on pilot supply Rick Mangor (Kent State U) Adverse if single pilot operation Steve (Cape Air) Paul Need full unrestricted ATP to fly the 402 (confirming Ricks view) Will adversely affect the supply Horizon Air Will it positively affect the 135 carrier operations- it will force the pilots to stay in their positions longer 1000 hours in the left seat of 135 will keep them in their positions and good quality people Gary Morrison (CAE) Don t see much of effect because people already have the 1500 hour mins B ADVERSELY AFFECT PILOT SUPPLY Question 2.3- affect for pilot supply for part 141 university schools Ken Byrnes (ERAU) Is it positive retention of instructor pilots? Jesse (Paradigm) Lower number of pilot enrollment Page 3 of 20

Jason (NIFA) Dan This will force candidates from Part 61 FBOs to the 141 schools (positive enrollment) Students will have a 500 hour credit toward the 1500 ATP Dr. Brady Schools accredited by someone (regional) FAA needs people from accredited AVIATION programs that are accredited by AABI Corky Romeo (2 yr college) Left high and dry from NPRM and not accredited by AABI Part 141 Accredited Middle States College and should not be lumped into this 141 Peter Morten FAA forgot about Part 61 and 2 year schools Mike Miller (Aviation A Washington) Still want to comment on this question even though you may not want to vote on it because it does not apply to you and your educational programs. Have a question about a question ANSWER IS D- Negative affect- lower enrollment Question 2.3.1 Ed We would fit under this, we need more clarity within the rules that differentiates the 2 year programs University of Cincinnati and Sporty s Flight, AeroSim Flight Academy, Beaver County- 2 year programs ANSWER D- Negative- lower number of pilot Question 2.4-142 pilot supply (Aerosim, Riddle, outside Airline training,) Depend on final level of FSTD requirements Answer is B Page 4 of 20

141 v. 142 Ken Byrnes 142- Airline training in flight simulator that give type ratings with use in the FTDs Gary Morrison Boeing FAA pushes back pretty hard for certificate purposes (pilot certificates) if your not 50% or greater if you do not do simulation Part 142 school- all type ratings mostly and transitions and recurrent training Dr. Brady Answer D- should differentiated between type and level of the simulator Question #3 Chris Jones ---BREAK--- Military Pilots- count with aircraft with more than one engine that have center line thrust o F-16, F-35, T-45 Any provisions with a level 5 or 6 Answer is Adequate Question #3 Evidence Chris Jones Too high because there can be 10hours with full flight simulation that can exploit, recommendation Ken Byrnes MPL training is all in a flight simulator and therefore ICAO MPL license training is sufficient for this Answer is ARC recommendation and ICAO MPL as evidence Page 5 of 20

Question #4- Should SICs in P. 121 carrier be required to hold a type rating? Mike Hildebrandt (JetBlue) o SIC only type rating for everyone that goes through the program and it is not a full type rating therefore they need to go back through school to get the full rating How can you convert the SIC type to a full type? Answer is Yes Why would you answer NO? LaMar Haugaard (Horizon) ICAO approval of type rating with paper work All captain duties are captain duties and Pilot Monitoring needs the type rating to use the HUD James Gorman (FedEx) SIC type rating is a full blown type rating except for taxi operations Chris (Delta) Operations that don t require an augmented crew, they do not do type rating in the left seat Question #4- Why or why not? Mike Hildebrant (JetBlue) Current SIC type/training should be grandfathered to the next transition or upgrade (FOQ ARC recommendation) Question #5- Should all SICs be required to an aircraft type if the aircraft currently requires a type rating for the PIC, regardless of the rule part the aircraft is operated under (91k) FedEx Express 91k moves to the 135 world and sometimes may require an ATP certificate Answer is NO Page 6 of 20

Question 5.1- Why or Why Not for 91k? Dr. Smith Want one because if it is a complicated airplane you need someone whom is competent enough for it It s an end road for the FAA to get into other part 91 operations Martin Rottler (Ohio State) Complexity of the aircraft operator NetJets vs. Smaller Operator Mike Miller (American Aviation Institute) There are sufficient regulations in place Mike Hildebrant (Jet Blue) 125, 121, 135, 91k carriers must meet the same requirements (one level of safety) Answer is B- There are sufficient regulations in place Question #5.2 Should all SICs type rating for Part 125 (Corporate Operations) Answer is YES Question #5.2- Why or Why Not? Answer is B- There are sufficient regulations in place Question #5.3- SIC types for part 135 Answer is NO Question #5.3- Why or Why Not Answer is B- There are sufficient regulations in place Question #6.1- Pilots who want an ATP with category multiengine class rating or type rating be required to take an additional training course prior to taking the knowledge test? Paul Railsback Gap between new commercial pilots and 121 operation and this was seen as the bridge for that gap Page 7 of 20

Gary Morrison (CAE) Currently there are multiple paths, bridge paths, jet transition courses (CRJ at Riddle as an example) Why is the knowledge test after the training? Jesse Schoonover (Paradigm) Just another requirement like an end of course evaluation Once in an airline then it deals with the type rating and the full ATP Darren (ExpressJet) ATP will be done before pilot will fly revenue passengers Shove the person through the new ATP course Then through initial training course and sim course Then come out with type rating and straight into IOE Chris Davidson (American Eagle) Have the ATP written already complete before hiring Motivating factor James Gorman (FedEx Express) Try and put it into the INDOC (as of right now, you cannot do it) Will increase time of INDOC, but that s ok Paul Railsback (A4A) Want it to be a separate course because I can watch you through this course This separate course can be used a screening tool Reading NPRM- This course will remain separate from INDOC Help fall within the academic credit Martin Rottler (Ohio U) What happens if you do not pass the test at the airline? Would there be some form of tracking for the student and then go to another regional carrier and take it again? Page 8 of 20

Dr. Brady Are you trying to separate the individuals restrictive ATP vs full ATP- do you need the course both ways? Captain Corky (Beaver) Questions are going to appear on the ATP written They are going to test it and the students need the coursework before the test takes place Rick Mangrum (Kent State) Need this as part of your credentials in order to take the ATP Who has level C or level 6 simulator Answer is YES Question #6.2 Why or Why Not? Ken Byrnes Standardizes the training like the other certificates ATP is glorified Commercial rating and this course is addressing disconnect Jesse (Paradigm) Lasergrade for this and are there facilities for this test? At this point pilots are going to have to be trained in order to take this test Have someone come and set it up Answer- Standardize along w/ other certs./ratings and addresses needed curriculum for ATP rating Question #7- If academic training is required in an ATP certification training course, what topics are appropriate? Bruce Chase Fork in the road- NPRM have a lot of subject areas for large transport category aircraft Choices support elimination of probability of pilot going out and getting an ATP certificate in a light twin or does the ATP only regard to airline jobs Page 9 of 20

Captain Phillips (Cape Air) Require unrestricted ATP and you are able to get full ATP in a 402 and that is sufficient for a 121 carrier operation Paul Lindseth (UND) You do not need simulator training when taking the knowledge test for the ATP Walt Reichard (Liberty University) Envisions new hire 121 has fire hose in the face already and he provides academic course and let them take the ATP written and now to ExpressJet and they train them moved to simulator training, but now it seems that the proposed rule has the list of events out of order Answer B- As Per the NPRM less FFS Question #7.2- How many hours are appropriate for such a course? 25 Hours of contact hours not credit hours Mike Hildebrant Need alternative approval process under AFS-230 Question #8.1- Should an ATP certification training course include non-type specific FSTD training on concepts that are generally universal to transport category aircraft? Dan Macch (ERAU) FSTD v. FTD Answer- YES Question #8.2- Why or Why Not? Reinforces and demonstrates concepts covered academically Negative transfer of learning with a non type specific FSTD There are other ways of demonstrating the curricula Answer- Reinforces and demonstrates concepts covered academically Page 10 of 20

Question #9.1- if FSTD training is required, what level of FSTD is appropriate? No further comments Answer is B- Level 5/ above and visual FOQ ARC Dr. Brady Discussion forthcoming about what level is necessary- did not specify but came with level 5 with visual FSTD- includes non motion devices with the NPRM Question #9.2- How many hours are appropriate? Peter Morton 16 hours for entire demonstration? Dr. Brady Can all of it be taken care of within the FSTD? Answer- TBD per development and evaluation Question #10 Jesse (Paradigm) Schools having level 5 devices and training on all concepts within the law Recommend that advanced jet training courses substituting the ATP CTP course Rick Mangrum Called for survey for of schools with level 5 sim Not with a level 5 sim (transport category)- 13 With a level 5 sim (transport category)- 5 Bottle neck that you need the ATP with multiengine and that no schools virtually have the level 5 simulators Steve Jones Careful with 4,5, or 6 because criteria may not lead to effective use of the device Page 11 of 20

Went to Frasca with maneuvers and that it needs to be a 4,5,or 6 simulator- doesn t answer the question but it is a cause for concern Gary Morrison FAA will align themselves with the ICAO document and they took all 7 levels of the FTD and 4 levels of FFS and combined them into FSTD and now only 7 levels total down to desktop simulation Also did a total task analysis of objectives of pilot certification of every level Jeremy Roesler ICAO 96-25 online for sale Audience Appropriate credit for the ATP CTP FSTD Mike Hildebrant Using this point as an attacking point for the SNPRM Dr. Smith Going off on the wrong course- consolidating knowledge more than demonstration Dr. Brady One part of the NPRM is that employers don t need a part of their training but this question is asking if the air carriers will add the this to their training course and if they do, what kind of reductions will be made? Ali Donway No value in demonstration in airline training AQP- Still dealing with proficiency so it does not fit within the current model Gary Morrison No matter where you get your education, this was a gate that you were going to have to go through and if you the student could demonstrate the knowledge Whichever path you came from and we need to know that you understand these fundamental concepts Did the FAA get it backwards? Page 12 of 20

James Gorman Will add to the training footprint mostly impart for the military pilot supply Chris Davidson Course for the pilot with CTP Course for pilots without the CTP training Mark Hildebrant JetBlue Doing it through AQP What subject matter needs to be added? Expects certain credits for the AQP program, but in the end it will add to the training footprint Answer- is that this requirement will ADD to the 121 carrier training footprint Question #11 Incorrect Assumption Question 12.1 Bruce The fact that 2 year institutions Question #13.2 Paul Gergens What type of military experience do you really have? Leave it to the true negotiations! They have their number you come back with another and let the rule maker deal with it Answer- TOO HIGH Question #13.3-Why or Why Not? Chris Jones (Delta) Quality of military flight training and leadership opportunity surpass civilian training Military training would merit a greater credit than the university programs Page 13 of 20

Gary Morrison Military training meets and exceeds the requirements of the proposed the NPRM Question 14.1- 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 a restrictive ATP? Jesse (Paradigm) FAA didn t disagree with ARC flight experience in an aircraft is that they agree with the philosophy but can t act on it Took accredited and non credited programs with advanced jet training courses and tossed them out o We need to lobby to get jet course back in order to lower the time requirements for the university graduates Capt Corky Comments regarding the acceptance of AJT as more credit toward the NPRM Students in 2 year programs will be able to work toward their 1500 hours while in 4 year programs students will not be able to start working on it until their senior year. Student that graduate from these programs will be at the same time table hour wise and choosing a school comes down to a cost-benefit analysis of choosing the right academic program Gary Morrison If you aren t listening to these universities and employers about what they need then you are shooting yourself in the foot Bruce Chase Don t object to the concept but look from the student s perspective and see if the 200 hour credit will outweigh the cost of the advanced jet training course Question #14.1 Answer is Yes Page 14 of 20

Question 14.2- Is the 1,000 hours too high, low, or adequate? Answer is TOO HIGH Question #14.3- Why or Why Not? Accept ARC recommendations Accept ARC recommendations with modifications (no credit for dual given) Accept NPRM as proposed Accept NPRM as proposed, except include 2 yr and part 61 schools Carl Hoffman Because of the quality of training with the military, 4 year programs should equate as empirical foundations Question 15.1- Military/graduates of 4 year universities allowed to receive an ATP certificate without restrictions with fewer than 1,500 hours? Answer is NO Question 15.3- Why or Why Not? Stay harmonized with ICAO Arc recommendations Help college enrollments All of the above Question #16 Aviation degree from a 4-year college or university and a commercial pilot certificate with instrument rating from a 141 school not affiliated with the college/university Steve FAA is saying that the 141 school not affiliated with the 4 year college/university is receiving enough oversight from the FAA. This will be keeping the student with affiliated college/university instead of going home and finishing the applicable ceritificates/ratings Page 15 of 20

Broke down competitive colleges without aviation degrees and saw that those graduates did fine within the industry o Mostly engineering degrees did very well Darrin Greubel 5/6 questions ago we agreed with the ARC and now as we answer questions it seems that our track left with the ARC and arguing with ourselves. We need to direct the FAA to what was come up with the ARC. Answer is Follow the recommendations of the ARC Question 17- Should the FAA consider an alternative licensing structure for pilots who desire only to fly for a part 121 air carrier (multicrew pilot license) Gary Morrison Totally based on instructional systems designed method One specific purpose- just to train a First Officer Some carriers say that thou shall not take a graduate from this program unless it is under direct supervision of the hiring carrier Dan Machhiarella One specific purpose is that this is for a professional First Officer for one specific carrier Answer is YES Question 17.2- Why or Why Not Chris Jones Predicted pilot shortage demands exploration of non-traditional training pipelines Dan Machhiarella Undeveloped career track Gary Morrison Page 16 of 20

Depends on regulator- if u bail out of MPL there is a written rule you can still get your private, commercial, instrument rating This is an alternative path but it is not an impossible path Answer- Harmonize with ICAO Question 18 Dr. Smith Should not answer this question because it is too speculative Question 19.1 Aerosim Airlines, are there any retention issues? Places they go with their SIC time Dr. Smith Review what the NPRM is proposing for the PIC ATP= 1000hours of part 121 experience No= what we have now is sufficient and that we shouldn t change what we have now ExpressJet Upgrade times range from off the street to as little as 6 months Nobody will fly left seat when they are not ready for it Mike Hildebrant 2 other major rule makings need to happen first o Captains authority o Re-write of Appendix N? 0677 Answer- Yes Question 19.2 Steve 1000 hours in 121 (opportunity to see the varying seasons) Ken Byrnes Page 17 of 20

Airline specific (approved by AFS-200) Experience in type Carl Hoffman Exposure to a variety of operating conditions Chris Jones Problematic because there can be a captain that came from 737 to 757 to 777 then captain of MD-88. That person has no experience in type (MD88), but have more than enough experience in the varying conditions Captain Corky Thought in last answer because competency is competency Take Air Florida accident Chris Jones Leadership and mentorship and these requirements allow the copilots to see some sort of mentoring time. It will be of disservice to them if there is no mentorship before moving over to the left seat. Answer is competency in 121/135 operations Question 21.2- Why or Why Not? Answer- Operations in similar environments Less structured than in part 121 Question 22 Stephen Phillips PIC 135 are better because they learn the decision making skills that are necessary This is better than allowing the SIC transfer time because of the lack in experience Answer is NO Page 18 of 20

Question 22.2- Why or Why Not Similar responsibilities Answer- Non-similar responsibilities ---END OF QUESTIONING--- Page 19 of 20

Finding Faculty that is capable of teaching the ATP CTP Capstone Course Requirement for ATP would exclude someone with an expertise in meteorology and therefore you need someone without that experience in meteorology teaching current pilots- this fact does not make any sense Tie the ground training with 2 years line experience You need to be familiar with capstone courses Majority of materials for this course include 121 carrier experience that is why you need someone with that type of experience Not supporting but we need to keep the intent of the FAA in mind for this Come up with better alternatives Agree- want weather taught by weather people, but those professors couldn t read a dispatch sheet Info for flying a trip- need someone who had that experience so you know (as a captain) what is legal for flight and what is not Definition could be broad enough to open up to the military experience, advanced jet training Recency of experience o If retired for 10 years- how do we know what they are teaching is up to date? Someone confirmed this aspect Delta pilots are not allowed to instruct anywhere else for liability reasons ERAU- uses graduates to teach ground school at an airline and they go to ground school with excitement and knowledge Problems with resources- assigning requirement has no value because the future is uncertain with resources Possible forfeiture of AABI accreditation Boeing- instructors are engineers by trade and they are instructing with no line experience o They teach ground through flight school Economy may not be like this forever and hopefully there will be enough adjunct professors with these credentials Objections to this requirement because there is no value added because he has trouble finding instructors with these requirements Non-CFIs that are current regional pilots teach in part 141 FSTDs (do very well as instructors) Creates a large bottle neck and force schools looking to the airlines for these types of experience Objection to the need of a type rating with the simulator device Page 20 of 20