Sunday, September 23, 2012

Public Law 111-216


On February 12, 2009 Colgan Air flight 3407 crashed just outside of the outer marker on the ILS runway 23 approach into Buffalo Niagara International Airport (KBUF). Flight 3407 was just like any other flight from Newark airport to Buffalo aboard a Bombardier Q400 (Dash-8) piloted by Captain Marvin Renslow and First Officer Rebecca Shaw. Clearly there is a reason this airplane crashed and according to the National Transportation Safety Board (NTSB) the accident was caused by an inadvertent stall and was the result of pilot error, they also went on to say that it was specifically the pilots’ inability to respond properly to the stall warned they received (stick shaker) possibly due to improper training and lack of aeronautical experience. All 49 people aboard this flight were killed including 1 person on the ground in the house the airplane struck in Clarence Center, New York.

As history shows aviation regulations are written in blood and clearly this accident deserves its own regulation and in 2010 President Barrack Obama signed Public Law 111-216 otherwise known as Airline Safety and Federal Aviation Administration Extension Act of 2010, basically PL 111-216 is a reaction to Colgan flight 3407 and several other accidents in the past that could possibly be a result of crew training. Public Law 111-216 only effects Part 121 operations and requires increased safety standards such as: a more stringent training process for airlines, any First Officer to have at least an Airline Transport Pilot Certificate (ATP) which would require 1500 hours of total flight time, and more pilot duty time regulations. More can be seen here: http://www.3407memorial.com/index.php/component/content/article/133-pl-111-216-has-been-signed-into-law.

These new regulations which will be effective summer 2013 has great potential to completely change my career pathway. Currently to obtain a job as a First Officer at a part 121 regional airline requires a minimum of multi-engine commercial certificate and an instrument rating (AMEL & Instrument Airplane) now I will be required to obtain an ATP certificate which instead of being obtained upon graduation it will require an additional up to 1000 hours of flight experience and require myself being 23 years of age (Note I will be most likely graduating at age 20, fingers crossed) which is required for an ATP certificate http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=8fcaa9a25ef98dbf2964a25718f42df8&rgn=div8&view=text&node=14:2.0.1.1.2.7.1.6&idno=14. Honestly, I see no benefit in this for myself to me this seems like I will have to flight instruct or find some other means of accruing flight experience for several years. However, (again fingers crossed) if Eastern Michigan Universities (Eagle Flight Center) flight program will qualify as a accredited Part 141 flight school and becomes eligible to train ATP applicants we all in this flight training program could be exempt from this ridiculous amount of flight training requirements and be subjected to a more lenient requirements, this could be a very beneficial thing and get me on my career path just about as planned.

Personally I think this regulation is slightly ridiculous particularly the aeronautical experience requirements. Clearly something had to be done, and many accidents can be accredited to some of these issues addressed above but I think that these issues can be avoided through additional company training such as the requirement of a longer period of flying with an Airline Check Captain/Instructor with intensified scenario based training on the areas specified in the document linked above. By doing all of this I think many of these regulations can be avoided without compromising safety. 

8 comments:

  1. The 1000-hour option age is 21. The age 23 thing is for captains and pilots with no degree only. So it's not quite that bad.

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  2. Thanks for pointing out the 21 vs. 23 age thing, miqrogroove. Yes, this is true. The one question that I am waiting for someone to address is "How many hours did the captain and first officer have when this accident occurred?". If I remember correctly, they both had more than 1500 hours at the time of the accident. If this is the case, is there another motivation for making such a regulation...a motivation beyond "increased safety"?

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  3. Captain had 3263 hours Total with 110 in the type, First Officer had 2200 hours total with 772 in the type. Kind of weird that the First Officer had so much more time in the Dash-8. I think part of the motivation is to calm the public about the people they allow to fly commercial flights, honestly 250 Hours total is really low most people don't know very much about flying a Cessna at that time, but 1500 hours is still way to much.

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  4. After reading these blogs, I think the biggest debate is the actual amount of time required for the certificate. Every pilot has skill levels across the board, but not may not necessarily mean you have the experience that the government is looking for. I think that the number of hours should be attainable and that it should be a good amount of training rather than just building time. Until this is clarified, I think this debate will continue for a long time.

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  5. Not to mention that the Captain (with fewer hours) failed more than one check ride while working with Colgan. Does this beg the question of quality time of the pilots? Going out to the practice area with there student for hundreds of extra of hours doesn't necessarily give quality time. Also good point on bringing up accreditation. Does the lower rule limit only go to those who graduated from an accredited program? There are only about 10 schools in the Nation that are aviation accredited and Eastern Michigan is not on that list. http://www.aabi.aero/programs.html

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    1. Accrediting agencies are regulated by the Department of Education under 34 CFR. AABI is not one of them.

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  6. I have to agree with JackAttack, maybe they need to not change the hour limit and simply put some sort of more intense testing in place to make sure that the cockpit crew has the had enough quality flight time, or make some sort of retraining requirements if you pass check rides.

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  7. I agree that the new hour regulations are excessive. Colgan had serious issues with compliance. Where is the carriers fault in providing the training. If/When this goes into effect, the carriers should get more involved in pre-training applicants as part of the selection process. This could help with meeting the hours requirement.

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