I know this is long but please bare with me. There is a very rare opportunity right now for us pilots as a work force to make comments on a decision the FAA is about to make. So please read this carefully and then go to the FAA's website (instructions and links will follow) and comment on this particular future ruling. We don't have much time. There are 2 different dates for comment period ending and I don't know which is correct. One date is January 26th...next Thursday!! Please make your comments before then. The other date is February 27th...this date is actually on the docket. Comments have to be reviewed before posting and this can take a while...so comment soon!! Keep checking back to this docket and commenting on other peoples comments as long as the comment page allows you to. This is a rare opportunity because we are commenting on an "ORDER" not a proposed rule change. Orders, among other things, are what POIs use to determine what is an acceptable interpretation of a rule and what is not. Lets make our voices heard about this...it affects all of us!!

Specifics

When reading this think AIRCRAFT specific training. What we receive when we go to Flight Safety or Simuflite every six months regardless of the operator sending us. The focus of our comments needs to be toward Aircraft specific training because that's where the additional cost of this will occur...10s of thousands of dollars of additional cost directly attributable to the interpretation of this one rule.

Background

Currently many operators will induct a pilot into their operation. Inspect their Aircraft Specific record of training line for line, module for module, and check ride for check ride. If the pilots training/checking documents met the letter of the law for 293s and 297s and the training the pilot received was equivalent to the new operators training program, and the pilot completes all other indoc training specific to the new operator...the paperwork was generated and the pilot was blessed to work for the new operator. If the aircraft specific training the pilot received was deficient in any module or any check, additional training and checking was required before the operator could count the pilot as qualified. A few years ago some regions of the FAA mounted a charge against operators who commonly followed this practice. The FAA's contention was that "credit for previous training" at one operator did not meet the qualification to be approved on the new certificate holder applying it to their training program. The FAA wanted operators to put every new pilot through an initial new hire program. For whatever reason this ruling got shelved and the FAA never acted on it!! Now the FAA has dug it up again and is finishing up what they started.

This original complaint the FAA had was more focused on initial new hires. However we all know that what goes for INHs goes for recurrents as well. If the FAA requires initial new hires to be completely trained on an Initial New Hire program they will also require every pilot to complete a full recurrent on the operators program. What this means for contract pilots is multiple full recurrent training programs to remain qualified on multiple certificate holders qualified pilot list.

References

N8900.RED - Attached - It's also available in the link following Faa Docket - FAA-2011-1937 - Attached and Docket Folder also available here: http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR%252BPS;rpp=10;po=0;D=FAA-2011-1397

Impact

After the comment period ends the FAA will decide how they interpret "credit for previous training". Each region has 90 days to request a review of all of their certificate holders training programs and pilot qualification documents in order to assess what is really happening in the real world. After the review the POIs will require certain changes to training programs. The operator will have 12 months to resubmit the training program revisions and comply with the new requirements.

This means that under the proposed interpretation there will be no credit for Aircraft Specific training received under another operators training program. Every pilot that works for multiple operators will have to attend every operators specific Simuflite or Flight Safety recurrent course. I know pilots that work for 5 different operators just to get enough work to pay their bills. Is this pilot going to be able to afford 5 recurrents at 25k each...don't think so.

Affect On Safety

There is no data to suggest that what is currently happening in the real world has increased accident or incident rates. Conversely there is no data to suggest that changing the interpretation of the rule will reasonably enhance safety. Operators have been using contract pilot work force for years and years. Look at the accident history and no data suggests that the accidents that did occur were related to the pilot not being trained by the operators specific Aircraft training program. THIS IS BECAUSE WE ALL KNOW THAT THE AIRCRAFT TRAINING WE RECEIVE IS NOT SPECIFIC TO AN OPERATOR!! IT IS SPECIFIC TO AN AIRCRAFT!!

Proposed Options

The simplest of all is for the FAA to continue to allow operators to give credit for aircraft specific pilot training/checking received under a similar operators training program. This is what operators do now.

The next best option is for the training centers to issue duplicate ROTs and 8410s for multiple Training and Checking Authorizations (TCAs) received for the same pilot but for multiple operators at their regularly scheduled recurrent training event. However simple this may seem to be I assure you it is not. This would be a mountain of paperwork for the TCs just to get approval to do. Other problems could be that different operators use different check airman within the same facility. If the check airman was not listed on each operators approved list I doubt any of it would fly with the FAA. So in turn this would cause much stress on the operators to make sure they approve all the correct check airman...and this is just the tip of what would need to happen for this to work.

The last option is a bit of an unknown. The 8900.1 does contain guidance for "Reduced aircraft training hours based on pilot experience and qualifications". Although the 8900.1 does not specially list any minimum hourly requirement for aircraft specific training...consider what we would be applying for...a training program curriculum that is a ZERO hour aircraft training program (for recurrents at least) based on stringent experience prerequisites. I have spoken with several inspectors on this issue and none of them have ever heard of a ZERO hour program regardless of pilot experience. BUT until now we haven't had to apply for one because of the interpretation of the rule. Not that it can't be done!! This would, however, be pretty costly at the TCs because even if the FAA granted the program the pilot applicants would still have to go take check rides so they produce 293s and 297s per the operators program. In my experience stand alone check programs range from $1500 to $5000. This, in addition to the cost of regular 12 month and 6 month recurrents is not efficient for more than 2 operators programs.

The last and most costly option is we do nothing. Send this email directly to the trash and forget you know me. Let the FAA rule however they want. And the next time you have to go to training you have to choose ONE OPERATOR to stick with. Unless of course you're independently wealthy and enjoy going to the same classes at FSI and SF listening to the same curriculum over and over again just so you qualify to work for all of your currently approved operators.

So, please, please, please go to this link: http://www.regulations.gov/#!docketDetail;dct=FR%252BPR%252BN%252BO%252BSR%252BPS;rpp=10;po=0;D=FAA-2011-1397 and post up a comment. I'm not going to tell you what to write. This is a free country. But after reading all of this and reading a few of the posted comments, if you don't know what to say I don't think I can help any further. If someone else has already said exactly what you would say, SAY IT AGAIN!! Copy and paste it if you want. The goal here is volume!!

Comment procedure

If the link above doesn't work go to http://www.regulations.gov.

Near the search button there is a keyword box. Enter FAA-2011-1397-0001. This will result in finding the "Clarification of policy: Approved training programs" docket.

On the right click "Open Docket Folder". Make sure the "Public Submissions" box is checked. This is how you see all of the comments, there are only 6 at this time!!!

To read public comments on the notice just click the commenter's name to read their comment. If you would like to post a reply to a specific comment there is a button for that within the respective comment.

To post your comment directly on the notice click on the "Comment due" link associated with the actual notice..not a comment.

Only 6 comments at this time!! Nobody knows this is happening and the FAA is hoping it stays that way!! Post this on your facebook!! Post this on the forums you subscribe to. Send this email to every pilot and every operator you know. I don't care if I am copied 1000 times on this. And I doubt the operators will care if they see the pilots banding together in order to help everyone preserve the current situation we have. Lets see if the pilot work force will do something to protect their livelihood!!

If anyone has any questions or comments about this please feel free to contact me directly through email. I have researched this extensively and have become fairly knowledgeable on the issues at hand.

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