Viewpoint: New Pilot Requirements Are Misguided
By Jeff Schneider
Source: AWIN First
September 11, 2013
In direct response to Colgan Air’s 2009 accident near Buffalo, N.Y., Congress passed the Airline Safety and FAA Extension Act of 2010, requiring all crewmembers to have an Airline Transport Pilot (ATP) license as of July 15, 2013. The rationale: The lack of flight time among pilots at smaller air carriers, also known as regional airlines, was leading to an unacceptable decrease in airline safety. While the FAA has proposed alternative minimums for ATPs, its stance is to keep the new mandate for such a license in place.
But looking at data about crashes suggests the FAA should reverse its 2013 ATP mandate for first officers. Not only will the requirement greatly reduce the available pool of airline pilots, but also there is minimal empirical evidence to suggest an increase in entry-level flight time leads to safer flights. Somehow we have developed a false notion that in air-carrier operations, younger, less-experienced pilots are dangerous.
Through analyzing more than 40 NTSB accident reports from 1991-2012, including Part 91, 121 and 135 scheduled flights, I tested the hypothesis that inexperience was a root cause in aviation fatal accidents. Interestingly enough, there was no direct correlation between a single individual’s inexperience and overall safety of the aircraft. Instead, it was the combination of flight-crew experience that correlated with fatal accidents. Since the majority of aircraft are flown by a crew, not just one pilot, it is the culmination of both pilots’ mistakes that leads to mishaps.
Beyond 37,000 hr.-combined-aircrew time, the data suggest a low probability of fatal accidents caused by the pilots. For instance, in the case of the 2006 loss of a UPS DC-8 at Philadelphia, a 41,500-hr. crew’s aircraft caught on fire. Even though the aircraft was later deemed destroyed, the pilots landed the jet and saved everyone onboard.
It made sense to look at aircrew experience in both fatal and non-fatal accidents. That is because in the case of the non-fatal events, a great deal of luck was involved in whether an incident turned deadly. For instance, in the case of a 2007 runway overrun in Cleveland, the crew of an Embraer 170 operating a Delta Connection flight flew an illegal approach, landed long and fast, incorrectly applied the thrust reversers and departed the runway at 42 kt. Had the terrain not been covered in snow, fairly flat and with no obstructions, this situation could have easily turned fatal, as was the case when an American Airlines MD-82 departed a runway at 82 kt. in Little Rock, Ark., in 1999.
Additionally, when I analyzed the data for both total flying time and hours in airframe, a trend developed that demonstrated minimum individual flight time plays less of a role than hours in the aircraft type.
While it may be counterintuitive, it is actually safer for airlines to hire pilots with fewer hours so they can build time in the airframe under the scrutiny of established airline procedures. Additionally, it is safer for airlines to adjust their pairing model to avoid matching crews that fall near or below a “fatal trend line” I saw when I plotted the data on crew time.
Using this trend line, the culprit for the Colgan Air accident appears to be a lack of aircrew time in airframe and not the fact that they had little combined total hours. Those pilots only had a combined 885 hr. in the airframe—the captain 111 hr. and the first officer 772 hr. Based on their experience levels, they should have never flown with each other. Instead, they should have had 1,230 more combined hours in the airframe to be safely above the trend line.
The data suggest reversing the recent ATP mandate and instead instituting a mandatory aircrew-pairing avoidance model to reduce the likelihood of crew errors. In the Colgan Air case, the first officer actually had the requisite 1,500 hr. in all types, so it is doubtful whether the ATP rating would have prevented that accident. Instead of ATPs, by using an FAA-regulated avoidance tool, the airlines could reduce the airline accident rate substantially with no impact on the ensuing airline pilot-hiring deficit
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