Initial Pilot Training
Better Management Controls Are Needed to Improve FAA Oversight Gao ID: GAO-12-117 November 4, 2011Regional airlines have experienced the last six fatal commercial airline accidents, and pilot performance has been cited as a potential contributory factor in four of these accidents. As a result, Congress and others have raised questions about, among other issues, the initial pilot education and training required before pilots can be hired by airlines, at which time they receive further training. The initial training is provided by pilot schools overseen by the Federal Aviation Administration (FAA). As requested, this report discusses (1) the various types of U.S. pilot schools, how they compare, and associated issues; (2) key similarities and differences between the U.S. and international approaches to pilot training; and (3) how and to what extent FAA carries out oversight of pilot training and certification. To address these issues, GAO reviewed literature, legislation, regulations, and FAA documents and inspection and enforcement data; interviewed agency and industry officials; and studied the training approach in Europe because of the different training model and visited four European countries.
The approximately 3,400 pilot schools in the United States can be divided into three types: (1) flight instructor based, (2) vocational, and (3) collegiate. The school types vary in several ways, but all pilot students must pass the same knowledge and flight tests to obtain a pilot certificate from FAA. Airline operations have evolved operationally and technologically, but the pilot training requirements for certification of commercial pilots were last revised in 1997. FAA and some industry stakeholders have indicated that current requirements for commercial pilots should incorporate additional training to improve the competency of entry-level regional airline pilots. FAA has initiated or planned a number of efforts to address these issues and recently enacted legislation requires FAA to implement regulations to increase pilot requirements for airlines by August 2013. The U.S. and Europe both offer the same pilot certifications but the training models differ, in part, due to training philosophies and other circumstances. The U.S. training approach emphasizes proficiency on actual flight training, while Europe's approach tends to emphasize academic instruction with more knowledge training requirements and testing. European pilot schools have also developed more comprehensive student screening processes than in the U.S. FAA has an annual inspection program that includes the oversight of pilot schools, pilot examiners, and flight instructors, the gatekeepers for the initial pilot training process. GAO analysis of FAA inspection data showed a 78 percent completion rate of the required inspections for pilot schools in fiscal year 2010, but, due to insufficient information, GAO was unable to determine completion percentages for prior years. Similarly, GAO could not determine 1) whether FAA completed the required inspections for pilot examiners or 2) the reasons that the discretionary inspections of flight instructors--which are generally optional--were conducted. Furthermore, FAA's national office does not adequately monitor the completion of annual inspection activities due, in part, to an inability to aggregate inspection data from the local district offices that conduct the inspections. Thus, FAA does not have a comprehensive system in place to adequately measure its performance in meeting annual inspection requirements, which could make it difficult to ensure regulatory compliance and that safety standards are being met.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Gerald L. Dillingham Team: Government Accountability Office: Physical Infrastructure Phone: (202) 512-4803GAO-12-117, Initial Pilot Training: Better Management Controls Are Needed to Improve FAA Oversight
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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
November 2011:
Initial Pilot Training:
Better Management Controls Are Needed to Improve FAA Oversight:
GAO-12-117:
GAO Highlights:
Highlights of GAO-12-117, a report to congressional requesters.
Why GAO Did This Study:
Regional airlines have experienced the last six fatal commercial
airline accidents, and pilot performance has been cited as a potential
contributory factor in four of these accidents. As a result, Congress
and others have raised questions about, among other issues, the
initial pilot education and training required before pilots can be
hired by airlines, at which time they receive further training. The
initial training is provided by pilot schools overseen by the Federal
Aviation Administration (FAA).
As requested, this report discusses (1) the various types of U.S.
pilot schools, how they compare, and associated issues; (2) key
similarities and differences between the U.S. and international
approaches to pilot training; and (3) how and to what extent FAA
carries out oversight of pilot training and certification. To address
these issues, GAO reviewed literature, legislation, regulations, and
FAA documents and inspection and enforcement data; interviewed agency
and industry officials; and studied the training approach in Europe
because of the different training model and visited four European
countries.
What GAO Found:
The approximately 3,400 pilot schools in the United States can be
divided into three types: (1) flight instructor based, (2) vocational,
and (3) collegiate. The school types vary in several ways, but all
pilot students must pass the same knowledge and flight tests to obtain
a pilot certificate from FAA. Airline operations have evolved
operationally and technologically, but the pilot training requirements
for certification of commercial pilots were last revised in 1997. FAA
and some industry stakeholders have indicated that current
requirements for commercial pilots should incorporate additional
training to improve the competency of entry-level regional airline
pilots. FAA has initiated or planned a number of efforts to address
these issues and recently enacted legislation requires FAA to
implement regulations to increase pilot requirements for airlines by
August 2013.
Figure: Example of a Single- and Multi-Engine Training and a Regional
Airline Jet:
[Refer to PDF for image: 3 photographs]
Sources: Cessna (single-engine trainer), Piper (multi-engine trainer),
and Bombadier (regional jet).
[End of figure]
The U.S. and Europe both offer the same pilot certifications but the
training models differ, in part, due to training philosophies and
other circumstances. The U.S. training approach emphasizes proficiency
on actual flight training, while Europe‘s approach tends to emphasize
academic instruction with more knowledge training requirements and
testing. European pilot schools have also developed more comprehensive
student screening processes than in the U.S.
FAA has an annual inspection program that includes the oversight of
pilot schools, pilot examiners, and flight instructors, the
gatekeepers for the initial pilot training process. GAO analysis of
FAA inspection data showed a 78 percent completion rate of the
required inspections for pilot schools in fiscal year 2010, but, due
to insufficient information, GAO was unable to determine completion
percentages for prior years. Similarly, GAO could not determine 1)
whether FAA completed the required inspections for pilot examiners or
2) the reasons that the discretionary inspections of flight
instructors”which are generally optional”were conducted. Furthermore,
FAA‘s national office does not adequately monitor the completion of
annual inspection activities due, in part, to an inability to
aggregate inspection data from the local district offices that conduct
the inspections. Thus, FAA does not have a comprehensive system in
place to adequately measure its performance in meeting annual
inspection requirements, which could make it difficult to ensure
regulatory compliance and that safety standards are being met.
What GAO Recommends:
To improve oversight of pilot certification, GAO recommends that FAA
develop a comprehensive system to (1) measure its performance in
meeting the agency‘s annual inspection requirements for pilot schools
and pilot examiners and (2) better understanding the nature and scope
of discretionary inspections for flight instructors. FAA generally
agreed with our recommendations.
View [hyperlink, http://www.gao.gov/products/GAO-12-117]. For more
information, contact Gerald L. Dillingham, Ph.D., at (202) 512-2834 or
dillinghamg@gao.gov.
[End of section]
Contents:
Letter:
Background:
Pilot Schools' Training Varies, and Although All Students Must Pass
the Same Test, Concerns Exist Related to the Quality of the Testing
and Other Training Requirements:
European Pilot Training Differs from the U.S. System, in Part Due to
Varying Philosophies and Circumstances:
FAA Completed Most Required Inspections of Pilot Schools, but
Oversight of Examiners and Instructors Is Difficult to Assess:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Scope and Methodology:
Appendix II: Nature and Scope of the Supply of and Demand for Airline
Pilots:
Appendix III: GAO Contact and Staff Acknowledgments:
Tables:
Table 1: Training and Total Flight-Hour Requirements for FAA's Three
Main Pilot Certificates--Private, Commercial, and Airline Transport
Pilot:
Table 2: Comparison of Pilot Certifications and Training Standards of
ICAO, FAA, and EASA:
Table 3: Completion Percentage of Required Inspections for Pilot
Schools with Part 141 Certificates for Fiscal Year 2010:
Table 4: Agencies, Organizations, Associations, Schools and Airline
Interviewed:
Table 5: Organizations Contacted by Country:
Table 6: Airline Transport Pilot Certifications Issued from 1999
through 2009 from Pilot Schools Operating under Part 61, Part 141, and
Part 142:
Figures:
Figure 1: The Typical Path to Become a Commercial Airline Pilot:
Figure 2: Examples of Single-and Multi-Engine Aircraft Used by U.S.
Pilot Schools and a Multi-Engine Jet Used by Regional Airlines:
Figure 3: The Number and Types of Pilot Schools across the Eight FAA
Regions:
Figure 4: Differences in Regulatory Requirements and General
Characteristics of U.S. Pilot Schools:
Figure 5: SkyWest Airlines' Flight Training Device Used to Test Pilot
Applicants:
Figure 6: Full-Motion Flight Simulator at Arizona State University:
Figure 7: The 230 Enforcement Cases for Pilot Schools with Part 141
Certificates from Fiscal Years 2006 through 2010:
Figure 8: The 9,016 Inspections of Pilot Examiners from Fiscal Years
2006 through 2010:
Figure 9: The 178 Enforcement Cases for Flight Instructors from Fiscal
Years 2006 through 2010:
Abbreviations:
AABI: Aviation Accreditation Board International:
ALPA: Air Line Pilots Association:
AOPA: Aircraft Owners and Pilots Association:
CAPA: Coalition of Airline Pilots Associations:
EASA: European Aviation Safety Agency:
EIS: Enforcement Information System:
FAA: Federal Aviation Administration:
FITS: FAA Industry Training Standards:
IATA: International Air Transport Association:
NASA: National Aeronautics and Space Administration:
NPG: National Program Guidelines:
NTSB: National Transportation Safety Board:
PTRS: Program Tracking and Reporting Subsystem:
SPAS: Safety Performance Analysis System:
UAA: University Aviation Association:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
November 4, 2011:
Congressional Requesters:
The United States' aviation transportation system is an important
component of the U.S. economy and one of the safest and most efficient
systems in the world. However, the continued integrity of this system
depends in part on the roughly 3,400 U.S. pilot schools providing well-
trained pilot candidates for airlines. This is particularly true for
regional airlines, which hire and train pilots from these schools,
whereas large mainline airlines tend to hire and train pilots who
already have experience at regional airlines.[Footnote 1] Although the
large mainline airlines have an unprecedented safety record, in recent
years regional airlines, which account for about 53 percent of the
nation's commercial flights,[Footnote 2] have experienced a number of
fatal accidents; specifically, the last six fatal commercial airline
accidents involved regional airlines. The National Transportation
Safety Board (NTSB) has cited pilot performance as a potential
contributory factor in four of these accidents, including the one in
February 2009, in Buffalo, New York, involving Colgan Air, Inc.
[Footnote 3] As a result, Congress and others have raised questions
about, among other issues, the initial pilot education and training
required before pilots can be hired by airlines, at which time they
receive further training. The initial training is provided by pilot
schools overseen by the Federal Aviation Administration (FAA).
[Footnote 4]
You asked us to examine the initial pilot training system in the
United States, which includes private and commercial pilot
certification (license), up to the training provided once a pilot is
hired by an airline. Because other countries have approached initial
training for future airline pilots differently, we also studied the
training approach in Europe to help inform our review. This report
discusses (1) the various types of U.S. pilot training organizations,
how they compare, and issues associated with training; (2) the key
similarities and differences between the U.S. system and international
approaches to pilot training; and (3) how and to what extent FAA
carries out its oversight role of pilot training and certification. In
addition, you noted that the worldwide demand for commercial airline
pilots has also caused concerns to be raised about the ability of the
current training system to provide an adequate number of pilots and
asked that we examine this issue. We examined what is known about the
future demand for and supply of U.S. commercial airline pilots and
report our findings on this issue in appendix II.
To address our objectives and the pilot supply appendix, we reviewed
and synthesized published literature related to pilot certification
and training issues in the United States and comparable international
pilot training systems; pilot statistics; types and requirements of
pilot training schools; FAA regulatory training requirements for
different levels of pilot certification; FAA oversight of U.S. pilot
training system. Literature sources included federal agency
documentation, academic journals, trade publications, conference
presentations, and newspaper articles. We also reviewed the Federal
Aviation Regulations related to training and certification for pilots,
and legislative provisions that addressed issues related to pilot
training. Specifically, we reviewed the Airline Safety and Federal
Aviation Administration Extension Act of 2010 related to pilot
training requirements and the certification of pilots operating for
airlines.[Footnote 5] We interviewed officials at the Department of
Transportation (DOT), FAA, and NTSB. We conducted semistructured
interviews with representatives from a range of aviation stakeholder
organizations, including pilot unions, pilot school associations,
general aviation groups, commercial aviation industry associations,
international aviation associations, and regional airlines (see
appendix I for the complete list of stakeholders we interviewed). We
visited pilot training stakeholders in six states--Arizona, Florida,
Georgia, Indiana, Maryland, and Utah--which included FAA regions that
had higher number of pilot schools, higher number of pilot
certificates issued in 2009, presence of FAA regional and district
offices, and presence of regional airlines' offices. In our state
visits, we interviewed officials at FAA regional and district offices,
regional airlines, pilot schools, and college aviation schools.
Because we selected these six states as part of a nonprobability
sample, our site visit data cannot be generalized to the nation.
Through the combination of site visits and semistructured telephone
interviews, we interviewed representatives of 24 regional airlines
that transported about 97 percent of regional passengers in 2009,
according to the Regional Airlines Association's 2010 annual report.
We also analyzed data from FAA's data systems for fiscal years 2006
through 2010 that provided information on the oversight activities
related to pilot certification and training. We tested the reliability
of the inspection and enforcement data that we received from FAA with
electronic testing of the data elements that we used, obtained, and
reviewed documentation about the data and the systems that produced
them, and interviewed knowledgeable FAA officials. We found the data
to be sufficiently reliable for our purposes.
In addition, we conducted site visits to a nonprobability sample of
European countries: France, Germany, the Netherlands, and the United
Kingdom. We focused on the European pilot certification and training
requirements because they offer a different model than the United
States. Specifically, individuals with no previous flying experience
are generally trained from the beginning to be commercial airline
pilots. The site visits allowed us to obtain information on European
countries' pilot standards, as well as their efforts to revise their
piloting performance and training standards to competency-based
training models. During these site visits, we interviewed officials at
the European Aviation Safety Agency (EASA) (Europe's aviation
regulatory organization), civil aviation authority officials, and
representatives from international and European aviation stakeholder
groups, airlines, and pilot training schools.
We conducted this performance audit from March 2010 through November
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives. See
appendix I for more information about our scope and methodology.
Background:
Civil aviation in the United States can be generally divided into two
broad categories--general aviation and commercial aviation. General
aviation comprises all aviation activities other than military and
commercial airlines. All civilian students are trained in the general
aviation sector until they are hired as airline pilots. Commercial
aviation generally refers to businesses that carry passengers or cargo
for hire or compensation. To operate as a commercial airline, a
business must have an airline operating certificate issued by FAA,
based on federal aviation regulations, which is determined by the type
of commercial service being provided.[Footnote 6] Airlines that
provide scheduled commercial service are often grouped into two
categories. Mainline airlines are the traditional large airlines that
provide domestic and international passenger service on larger
aircraft such as American Airlines or Delta Airlines. Regional
airlines, such as Mesa and Piedmont Airlines, also provide domestic
and international passenger service, generally using aircraft with
fewer than 90 seats and serving smaller airports. The international
service that regional airlines provide is confined to border markets
in Canada, Mexico, and the Caribbean. More than 13,000 regional
airline flights operate daily, which represents more than half of the
number of U.S. domestic flights.
As the federal agency responsible for regulating the safety of civil
aviation in the United States, FAA is responsible for the
administration of pilot certification (licensing) and conducting
safety oversight of pilot training. Regulations for pilot
certification and training are found in three different parts of the
Federal Aviation Regulations--Parts 61, 141, and 142.[Footnote 7] All
pilots are subject to a series of certification requirements
established by FAA, but the requirements vary depending on the type of
training environment.[Footnote 8] Part 61 recognizes six basic types
of pilot certification: student, sport, recreational, private,
commercial, and airline transport.[Footnote 9] Part 61 also
establishes the core training requirements for each pilot
certification, which describes the eligibility requirements,
aeronautical knowledge and flight proficiency standards, and the
required flight hours (see table 1). Pilot training can be provided to
students by flight instructors under Part 61.[Footnote 10] Part 141
outlines the specified personnel, aircraft, facilities, curriculum,
and other operating requirements that approved pilot training
organizations (schools) must meet in order to hold an operating
certificate from FAA. Part 142 outlines specific requirements for
training centers that primarily relate to the advanced training
provided to pilots by employers, such as airlines. Our report focuses
on the initial pilot training that students are provided until they
are hired as airline pilots; thus, advanced training for pilots is not
within the scope of our study.[Footnote 11]
Table 1: Training and Total Flight-Hour Requirements for FAA's Three
Main Pilot Certificates--Private, Commercial, and Airline Transport
Pilot:
Type of pilot certificate: Private pilot;
Part 61 required ground school training hours for aeronautical
knowledge: No minimum hours specified;
minimum knowledge subject areas must be covered;
Part 61 required flight hours: 40;
Part 141 required ground school training hours for aeronautical
knowledge: 35;
Part 141 required flight hours: 35.
Type of pilot certificate: Commercial pilot;
Part 61 required ground school training hours for aeronautical
knowledge: No minimum hours specified;
minimum knowledge subject areas must be covered;
Part 61 required flight hours: 250;
Part 141 required ground school training hours for aeronautical
knowledge: 35;
Part 141 required flight hours: 190.
Type of pilot certificate: Airline transport pilot;
Part 61 required ground school training hours for aeronautical
knowledge: No minimum hours specified;
Part 61 required flight hours: 1,500;
Part 141 required ground school training hours for aeronautical
knowledge: 40;
Part 141 required flight hours: 1,500.
Source: GAO presentation of information contained in Part 61 and Part
141 of Title 14 of the U.S. Code of Federal Regulations.
[End of table]
To obtain a private, commercial, or airline transport pilot
certificate from FAA to perform various aviation activities,
individuals typically have to successfully complete pilot training and
pass the following two FAA tests for each pilot certificate and rating
obtained:[Footnote 12]
* A knowledge test assesses applicants' understanding of the
aeronautical knowledge areas required for a specific certificate or
rating and can be administered in written form or by a computer.
* A practical test consists of a flight test and an oral examination.
The flight test assesses applicants' knowledge of the areas of
operations of an aircraft and the ability to demonstrate the maneuvers
in an aircraft while in flight. The oral examination is conducted by
having an applicant respond to random questions related to aviation
knowledge and aircraft operations before, during, and after the flight
test, and typically lasts between 1 and 2 hours.[Footnote 13]
To become a certified commercial pilot,[Footnote 14] which is
currently the minimum requirement for being hired by an airline as a
first officer, individuals also must undergo several steps of pilot
training and certification in accordance with FAA regulations.
[Footnote 15] Once cleared by the medical examination, students obtain
a medical certificate and a student pilot certificate from FAA.
[Footnote 16] Figure 1 shows the typical progression of training and
certifications required to become an airline pilot.
Figure 1: The Typical Path to Become a Commercial Airline Pilot:
[Refer to PDF for image: illustration]
Obtain a private pilot certificate from FAA by completing the necessary
knowledge and flight training;
Obtain an instrument rating from FAA by completing the necessary
knowledge and flight training (allows a pilot to fly during periods of
reduced visibility or when the ground reference is obscured);
Obtain a commercial pilot certificate from FAA by completing the
necessary knowledge and flight training (required in order to be
compensated for performing flying activities);
Obtain a multi-engine rating from FAA by completing the necessary
knowledge and flight training (required to be qualified to fly
aircraft with more than one engine);
Build flight hours and experience as a flight instructor by teaching
new pilot students how to fly (optional) or through employment in a
variety of commercial aviation jobs;
Obtain employment as a pilot for a charter or corporate operation or
first officer for a regional airline.
Source: GAO.
[End of figure]
Figure 2 shows examples of the progression from single-engine trainer,
to multi-engine (i.e., jet) trainer--used by some pilot schools to
provide students with the multi-engine rating--to the much larger,
faster jet used by regional airlines. Once commercial pilots complete
the process of initial training, they are qualified to apply for a
first officer pilot position at an airline. Entry-level positions are
typically at regional, and not mainline, airlines; mainline airlines
typically draw from regional airlines for their pilots. If hired,
pilots must complete the airline's new hire training, which consists
of indoctrination, ground and aircraft systems, simulator training,
and the initial operating experience, wherein the pilot applies what
they learn in the previous training phases. The airline submits these
training programs for approval by the FAA to ensure they meet Part 121
requirements.
Figure 2: Examples of Single-and Multi-Engine Aircraft Used by U.S.
Pilot Schools and a Multi-Engine Jet Used by Regional Airlines:
[Refer to PDF for image: 6 photographs and associated data]
Cessna 172 Skyhawk (single-engine trainer):
Length/wingspan: 27'2"/36'1";
Maximum takeoff weight: 2,450 pounds;
Passenger capacity: 4;
Cruise speed: 122 knots;
Range: 696 nautical miles.
Piper Seminole PA-44 (multi-engine trainer):
Length/wingspan: 27'7"/38'7";
Maximum takeoff weight: 3,800 pounds;
Passenger capacity: 4;
Cruise speed: 162 knots;
Range: 700 nautical miles.
Bombardier CRJ700 (regional jet):
Length/wingspan: 106'2"/76'3";
Maximum takeoff weight: 72,750 pounds;
Passenger capacity: 70-78;
Cruise speed: 473 knots;
Range: 1,218 nautical miles.
Sources: Cessna, Piper and Bombardier.
[End of figure]
As part of its oversight responsibility, FAA has safeguards in place
to ensure that pilot applicants are provided the necessary training
and undergo complete and thorough pilot certification examinations.
The National Program Guidelines (NPG), initiated in 1985, are
oversight policy guidelines developed annually by FAA for its eight
regional offices and their associated local district offices for
oversight of pilot schools, pilot examiners, and flight instructors.
[Footnote 17] The NPG identifies required inspections and optional
inspections.[Footnote 18] As part of this oversight process, FAA uses
the Program Tracking and Reporting Subsystem (PTRS) for scheduling and
recording inspection records and findings for NPG inspections of pilot
schools, flight instructors, and pilot examiners.[Footnote 19]
Additionally, FAA uses the Enforcement Information System (EIS) for
tracking and reporting information about any enforcement actions the
agency takes for statutory or regulatory violations.[Footnote 20]
As a member of the International Civil Aviation Organization (ICAO),
the United States conforms to international standards and recommended
practices for pilot training and certification.[Footnote 21] ICAO is
the international body that, among other things, promulgates
international standards and recommended practices in an effort to
harmonize global aviation standards. These standards and recommended
practices are developed to ensure that civil aviation throughout the
world is safe and secure. ICAO has no enforcement powers and only
establishes recommended standards and guidelines, e.g., licensing
requirements for flight crew personnel, including pilots. Therefore,
ICAO members (known as contracting states) decide whether to
incorporate the standards and recommended practices into national laws
or aviation regulations.
Pilot Schools' Training Varies, and Although All Students Must Pass
the Same Test, Concerns Exist Related to the Quality of the Testing
and Other Training Requirements:
The roughly 3,400 U.S. pilot schools can be divided into three
categories: (1) non-collegiate flight instructor-based schools, (2)
non-collegiate vocational pilot schools, and (3) collegiate aviation
schools. The training provided by the school varies in the minimum
requirements for the flight and ground school hours required for each
certification level, level of oversight provided by FAA, and level of
educational instruction being provided by type of school. However, all
student pilots have to successfully complete ground and flight
training and pass the same knowledge and practical tests prior to
receiving a pilot certificate from FAA. Nevertheless, there is no
consensus and little empirical evidence on how the different pilot
training schools compare in preparing professional pilots for the
commercial airline industry. In addition, modern aircraft used by
regional airlines have evolved and the operational demands have
increased on pilots in high-altitude and complex airline operations;
yet, U.S. pilot training requirements for certification of commercial
pilots were last revised in 1997. For example, it is possible for an
individual to obtain all levels of pilot certifications (i.e.,
private, commercial, and airline transport) in a general aviation
flying environment in a single-engine aircraft. However, in order to
qualify to be hired by an airline, a commercial pilot would also need
to obtain instrument and multi-engine ratings. Some stakeholders,
including representatives of regional airlines, we interviewed said
the current training regulations for commercial pilots should be
revised to incorporate additional training that would improve the
competency of entry-level first officer applicants. FAA has initiated
several efforts to address issues related to pilot training and
certification testing. Recent legislation requires that FAA develop
regulations increasing pilot certification requirements for all
airline pilots.
The Three Different Types of Pilot Training Schools Vary in Type of
Training, but All Prepare Students to Take the Same FAA Tests:
Approximately 3,400 pilot schools exist in the United States and the
most basic difference among the types of schools is the training
environment provided to the students. For the reporting purposes of
our study, we divided them into three categories: (1) non-collegiate
flight instructor-based schools, (2) non-collegiate vocational pilot
schools, and (3) collegiate aviation schools.
* Non-collegiate flight instructor-based schools (Part 61). Pilot
training conducted under Part 61 regulations is often provided by an
individual, for-hire flight instructor who can operate independently
as a single-instructor school at a local airport with a single
aircraft on which to train students. Other flight instructor-based
schools operate as a more traditional training school with a small,
physical facility located at a particular airport. These schools are
the most common type (see figure 3). The majority of students that
complete training in non-collegiate, flight instructor-based schools
are generally interested in recreational flying, although most
commercial pilots in the United States also undertake this type of
training as the initial path toward becoming an airline pilot. Flight
instructor-based schools offer flexible training environments to meet
specific students' needs as long as they pass the final tests. These
schools are not subject to direct FAA oversight beyond the initial
certification and subsequent renewal of the flight instructor's
certificate. However, flight instructors may be inspected by FAA when
a triggering event occurs regarding the training being provided, such
as being involved in an aircraft accident.
* Non-collegiate vocational pilot schools (Part 141). Vocational
schools elect to apply for an operating certificate from FAA to
provide pilot training under Part 141 regulations. Part 141
regulations require these schools to meet prescribed standards with
respect to training equipment, facilities, student records, personnel,
and curriculums.[Footnote 22] Vocational schools must have structured
and formalized programs and have their detailed training course
outlines or curriculums approved by FAA. Curriculums can vary in
content, but FAA provides fundamental core training guidelines that
must be followed within the curriculum for the school to receive a
certificate.[Footnote 23] These schools do not allow the flexibility
of flight instructor-based schools as the training sequence outlined
in the curriculum cannot be altered. FAA requires annual inspections
of these schools, unlike flight instructor-based schools.
* Collegiate aviation schools (Part 61 or Part 141). Pilot training is
also provided through 2-and 4-year colleges and universities, which
typically offer an undergraduate aviation-based degree along with the
pilot certificates and ratings necessary to become a commercial pilot.
In general, most of the collegiate aviation schools provide pilot
training under a Part 141 certificate, although they can provide
training under Part 61. Collegiate schools that provide training under
Part 61 regulations generally offer similar structured, curriculum-
based training as collegiate schools with a Part 141 certificate.
Figure 3 displays how each of the three types of pilots schools are
dispersed across the United States.
Figure 3: The Number and Types of Pilot Schools across the Eight FAA
Regions:
[Refer to PDF for image: illustrated U.S. map]
1. Northwest Mountain Region:
Instructor schools: 293;
Vocational schools: 58;
College schools: 23.
2. Western-Pacific Region:
Instructor schools: 352;
Vocational schools: 87.
College schools: 25.
3. Alaskan Region:
Instructor schools: 14;
Vocational schools: 5;
College schools: 1.
4. Great Lakes Region:
Instructor schools: 538;
Vocational schools: 45;
College schools: 35.
5. Central Region:
Instructor schools: 236;
Vocational schools: 11;
College schools: 9.
6. Southwest Region:
Instructor schools: 359;
Vocational schools: 57;
College schools: 20.
7. Southern Region:
Instructor schools: 576;
Vocational schools: 106;
College schools: 25.
8. Eastern Region:
Instructor schools: 505;
Vocational schools: 76;
College schools: 21.
Total:
Instructor schools: 2,873;
Vocational schools: 445;
College schools: 159;
Overall nationwide: 3,477.
Source: GAO analysis of FAA and Aircraft Owners and Pilots Association
information; Map Resources (map).
Note: The total number of schools is approximate because a
comprehensive list for the various types of schools does not exist.
The total number of schools was provided by the Aircraft Owners and
Pilots Association (AOPA) as of June 2010. Association officials noted
that information is entered into the listing database by the schools
and could not guarantee accuracy and the currency of the data. FAA
maintains only a current list of the pilot schools with a Part 141
operating certificate. Since most of the pilot schools are not
directly tracked by FAA, the AOPA listing is considered the best
available. We reconciled the AOPA total list of schools with FAA's
current list of pilot schools with a Part 141 operating certificate as
of June 2011. We eliminated the duplicate schools and added schools
from the FAA list to the total number of schools.
[End of figure]
For the most part, all pilot schools must provide training that
includes both classroom and flight training.[Footnote 24] Classroom
training, or ground school, provides students with the required
aeronautical knowledge and cognitive skills necessary to perform the
tasks required to become a pilot. Flight training focuses on learning
how to manipulate the controls of an airplane and make it perform
certain maneuvers. Regardless of the type of school, flight
instructors must teach students by demonstrating and explaining, on
the ground and in the air, the basic principles of flight (e.g.,
airspace, aerodynamics, weather factors, and Federal Aviation
Regulations). The number of training flight hours required for pilot
certification varies by the aviation regulations being used to provide
pilot training. Because training under Part 141 regulations requires a
school to use an FAA-approved curriculum, fewer hours of actual flight
training are required than under Part 61.[Footnote 25] Figure 4 shows
the differences in general characteristics of the types of U.S. pilot
schools.
Figure 4: Differences in Regulatory Requirements and General
Characteristics of U.S. Pilot Schools:
[Refer to PDF for image: illustrated table]
Type of pilot school: Flight instructor-based (part 61);
Ground school and flight training: [Check];
Knowledge test: [Check];
Practical test: [Check];
FAA-approved curriculum: [Empty];
Degree granted: [Empty];
Accreditation: [Empty].
Type of pilot school: Vocational (part 141);
Ground school and flight training: [Check];
Knowledge test: [Check];
Practical test: [Check];
FAA-approved curriculum: [Check];
Degree granted: [Empty];
Accreditation: [Empty].
Type of pilot school: Collegiate (part 61 or 141);
Ground school and flight training: [Check];
Knowledge test: [Check];
Practical test: [Check];
FAA-approved curriculum: [Check][A];
Degree granted: [Check];
Accreditation: [Check].
Source: GAO.
Note: Although a training curriculum does not require FAA approval
under Part 61, flight instructors must cover the minimum knowledge
subject areas outlined in the regulations.
[A] Not all collegiate aviation schools have a Part 141 certificate.
Therefore, for collegiate schools that provide training under Part 61,
no FAA approval is needed for the training curriculum used for
training.
[End of figure]
FAA regulations do not prescribe the entry requirements, selection
criteria, and screening procedures for students seeking entry into
U.S. pilot schools, and as a result, they could vary considerably
among schools. In general, pilot schools admit those students who can
pay for the training; however, FAA sets a minimum age requirement for
each pilot certification and requires a current FAA medical
certificate and that every pilot student is able to read, speak,
write, and understand the English language.[Footnote 26] FAA's long-
standing requirement for English proficiency complies with the 2008
ICAO standard that all private, commercial, or airline transport
pilots who operate internationally have a pilot certificate with the
level of English language proficiency. If a person is determined to be
proficient during the FAA practical test for pilot certification, FAA
issues pilot certificates with an "English Proficient" endorsement to
attest that the pilot meets the ICAO standard.
One of the distinctive characteristics of collegiate schools is that
they are generally accredited academic programs, which recognizes a
level of program quality.[Footnote 27] However, a recently-created
organization, the Flight School Association of North America,
implemented an accreditation program in August 2011 for non-collegiate
pilot schools intended to establish an educational quality standard.
[Footnote 28] According to association officials, accrediting non-
collegiate pilot schools will help to level the playing field with the
collegiate schools and assist consumers in comparing pilot schools.
Regardless of the type of pilot schools that students attend, once
training has been completed pilot candidates must pass the same
knowledge and practical tests to obtain a pilot certificate.[Footnote
29] FAA uses a multiple-choice, knowledge test to measure the extent
to which applicants for FAA pilot certificates have mastered the
required aeronautical knowledge areas provided in ground school. To
pass, applicants must achieve an overall score of 70 percent or
higher. However, concerns have been voiced by some aviation
stakeholders related to whether the current knowledge test actually
requires students to learn the material, as opposed to simply studying
sample test questions from publicly available sources. Literature
related to pilot certification and training issues and some aviation
stakeholders have pointed out that FAA testing is generally based on
rote memorization. They stated that this encourages instructors and
students to focus on memorizing test questions to pass the required
FAA knowledge test, rather than developing a true understanding of the
material. In 2004, the National Aeronautics and Space Administration
(NASA) published a study on FAA's pilot knowledge tests.[Footnote 30]
NASA found that many applicants completed the test in far less time
than would be required for the average human to even read the
questions and answers on the test--indicating that students had
memorized the questions and answers--which raises concerns about the
extent to which students actually mastered the material.
Little Information Exists for Examining and Comparing How the
Different Types of Pilot Schools Prepare Pilots for Airline Operations:
There is little empirical research that has been conducted comparing
the extent to which different types of pilot schools prepare pilots
for the commercial airline industry. We reviewed a pilot source study,
published in 2010, authored by professors from several accredited
collegiate aviation schools that researched the impact of collegiate
aviation training on preparing students to be regional airline first
officers.[Footnote 31] The researchers analyzed data on how 2,156 new-
hire pilots performed in the training programs of six regional
airlines from 2005 through 2009. The study found that the new-hire
first officer pilots with the highest rate of success--in terms of the
amount of extra training needed to complete training tasks and fewer
number of times tasks were not completed--in the airline training: (1)
were graduates of accredited college flight degree programs, (2) had
experience as flight instructors, and (3) had accrued between 500 and
1,000 flight hours. We reviewed the study and determined that, while
statistically significant, the results of this research showed small
differences in the correlations that supported these three
conclusions. Phase II of the study, completed in early 2011, expanded
the research to include testing of multiple variables with the same
dataset, but the researchers did not report the results of the tests
they conducted of their data. Phase III is currently underway and is
expanding the current dataset to include more than six regional
airlines. Phase IV will include more detailed background data on the
newly hired pilots to determine relationship factors.
Other than the 2010 pilot source study, our literature review found
that little other academic study exists and there is no consensus
about how well the different types of pilot schools prepare commercial
pilots for airline operations. We received a variety of perspectives
from industry representatives and some anecdotal information that
suggested that one major benefit to completing a structured training
program that is the training provides better aeronautical knowledge
(ground school) than an unstructured learning environment. Officials
from two regional airlines, two collegiate aviation schools, and four
industry associations with whom we spoke generally agreed with the
results of the initial phase of the pilot source study. Officials from
the Regional Airline Association (RAA) told us that the broad-based
curriculum used by vocational and collegiate aviation schools is the
better method for preparing a person for a professional airline
career.[Footnote 32] Furthermore, officials from 6 of the 12 industry
associations and one mainline airline we interviewed considered the
quality of education at many of the collegiate aviation schools to be
the highest level of civil aviation pilot training because collegiate
schools are designed to produce professional pilots for airlines,
rather than for other aviation jobs.
Collegiate curriculums also cover a broad range of areas above FAA
minimum training requirements. In addition, representatives from all
but one of the regional airlines we interviewed generally told us they
strongly preferred, but do not require, first officer candidates
trained in collegiate aviation schools because they perform better in
their airline's training program when hired[Footnote 33]. Due to
limited screening, training structure, and variability of educational
content, according to some of the regional airline officials, flight
instructor-based schools are less likely to produce first officers
that are prepared immediately upon completing the training to enter
the workforce and succeed in an airline environment. On the other
hand, stakeholders from 4 of the 12 industry associations pointed out
the large number of pilots that matriculate through flight instructor-
based schools and many are hired by regional airlines without any
performance issues. Representatives from two of the regional airlines
indicated that the professional pilot experience gained through
commercial aviation positions after completing pilot training is more
important than the type of pilot school attended.
Pilot Training Requirements for a Commercial Pilot Certificate Are Not
Aligned with Airline Operations:
Several industry stakeholders have stated that current training
requirements for commercial pilots are not aligned with today's
commercial airline environment. FAA requires the same initial training
for a pilot hired as a first officer of a regional airline carrying
passengers as it does for a pilot hired to fly for a commercial non-
airline operation, for example crop dusting.[Footnote 34] The Air Line
Pilots Association (ALPA) has suggested that FAA revise the
regulations to make a clear distinction between training and
certification requirements for airline operations and those for other
types of commercial operations. ALPA contends the regulations were
developed in an era in which commercial pilots were hired by airlines
in small, slow, propeller-driven aircraft or as flight engineers on
jet-powered aircraft. It would traditionally take several years and
thousands of flight hours before these pilots were given an
opportunity as a first officer of jet transports.[Footnote 35]
However, according to ALPA, it is not uncommon today for newly hired
pilots to be hired directly into airline training programs to become
first officers of high-altitude, complex aircraft carrying 50 or more
passengers, the type of aircraft that warrants pilots with more
knowledge and greater skills than the new-hire airline pilots of the
past. Officials from two industry associations and eight regional
airlines advocated for a separate pilot certification track with
additional training requirements specific to being an airline pilot.
Because airline pilots are responsible for the safety of the flying
public, according to ALPA, it is reasonable that they should be held
to a higher standard of competency, knowledge, and training than
pilots in other flight operations.
Additionally, requirements for a commercial pilot certificate do not
emphasize training in some areas--like decision-making and using
modern technologies--that are directly related to the airline pilot
profession.
* According to FAA and other stakeholders, the regulations regarding
ground school and flight training, as well as the test standards for a
commercial pilot certificate, generally emphasize the mastery of
maneuvers and individual tasks to determine competence. The emphasis
is on development of motor skills to satisfactorily accomplish
individual maneuvers--whereas only limited emphasis is placed on
decision-making--unlike in scenario-based training that emphasizes
improving operational experience.[Footnote 36]
* In addition to traditional skills of flying, navigating, and
communicating, pilots in today's newer aircraft have to manage
automation, information displays, and other new technologies.
According to the FAA Industry Training Standards' guidance material
for the commercial pilot certificate, a growing number of pilots are
being hired by regional airlines as first officers to operate aircraft
with these advanced avionics and systems.[Footnote 37] While these
pilots may gain flying experience and spend years building flight time
in commercial non-airline jobs or as flight instructors, this
experience may be accumulated in smaller, slower, and less advanced
aircraft. Modern aircraft offer advanced avionics and performance
capabilities and many of these new aircraft travel faster and further
than older generation commercial aircraft. While generally considered
enhancements, these modern technologies require increased technical
knowledge of newer systems and avionics and new skills for managing
automation and computerized flight and navigation systems.
According to literature, as airspace complexity and air traffic
density increase, airline pilots must have increased situational
awareness, understand risk assessment, and have a complete
understanding of managing the automation of the aircraft.[Footnote 38]
The current training requirements and testing for a commercial pilot
certificate do not emphasize the development of these skills.
Representatives from 10 regional airlines, 4 pilot schools, and 2
industry associations we interviewed said the current training
regulations for commercial pilots should be revised to incorporate
additional training requirements that would improve the performance
capabilities of the first officer applicants that seek employment at
airlines, such as exposure to advanced jet concepts and simulation,
[Footnote 39] aircraft unusual attitude (i.e., upset and stall
recovery),[Footnote 40] flight crew coordination and
environment,[Footnote 41] and scenario-based training. However, when
pilots are hired by airlines, these types of training are provided by
the airline to ensure that pilots are adequately competent in these
and other advanced training areas--some required by FAA for airline
operations. For example, FAA regulations for airline operations
require that all pilots are provided crew resource management training
as part of the airline's new hire and recurrent training programs.
According to ALPA, the lack of specific training requirements to be a
commercial airline pilot results in a wide range of initial training
experiences, not all of which are well suited for the commercial
airline industry. To compensate, some regional airlines, such as
SkyWest Airlines, use various flight training devices to screen pilots
during the hiring process to gauge their piloting skills (see figure
5). However, if additional training is required by FAA for pilots
prior to being hired by an airline, the students would likely be
responsible for the extra costs involved and would add to the total
costs of pilot training borne by the student. (For more information on
the costs associated with pilot schools, see appendix II.)
Figure 5: SkyWest Airlines' Flight Training Device Used to Test Pilot
Applicants:
[Refer to PDF for image: photograph]
Source: GAO.
[End of figure]
The industry concerns about current training regulations for
commercial pilots and incorporating additional initial training
requirements to improve first officer applicants' performance
capabilities could be addressed by the Airline Safety and Federal
Aviation Administration Extension Act of 2010 for all airline pilots.
[Footnote 42] Currently, while a captain for a commercial airline is
required to hold an airline transport pilot certificate--the highest
level of pilot certification and requiring the highest number of total
flight hours--a first officer is required to hold only a commercial
pilot certificate, i.e., requiring a minimum of 250 flight hours.
[Footnote 43] However, the recent law will require that each pilot
(captain and first officer) must have an airline transport pilot
certificate, which currently requires a minimum of 1,500 total flight
hours.[Footnote 44] Individuals interested in becoming a first officer
for a regional airline generally complete training from pilot schools
with a commercial pilot certificate and possess about 300 to 500
flight hours. The 2010 law directs FAA to conduct a rulemaking and
effect the changes no later than August 2013.[Footnote 45] According
to FAA, it will issue a notice of proposed rulemaking regarding the
increased requirements in the fall of 2011. Representatives of the
regional airlines we interviewed were concerned this legislation will
reduce airlines' hiring flexibility and make it harder to find
qualified first officers that possess an airline transport pilot
certificate.
As another potentially relevant factor, the law stated that the FAA
Administrator may allow specific academic training courses--beyond the
additional courses required by the legislation to raise the minimum
requirements for the airline transport pilot certificate--to be
credited in lieu of flight hours needed to obtain an airline transport
pilot certificate. According to FAA's First Officer Qualifications
Aviation Rulemaking Committee Report,[Footnote 46] well-structured
training programs that feature integrated academic content and flight
experience optimize the pilot learning process, and the committee
supported new, higher-level minimum certification requirement for
first officers. To support the concept that academic training courses
should be credited for some of the additional total flight hours, the
report outlined a system for crediting academic training courses based
on the sources of pilot training, e.g., vocational pilot schools,
collegiate aviation schools, or military. The Coalition of Airline
Pilots Associations (CAPA) and National Air Disaster Alliance-
Foundation presented dissenting opinions to this approach in the
report and suggested that academic courses, while necessary, should
not replace an increase in total flight hours required in the law.
[Footnote 47]
Some Pilot Schools Provide Training That Is More Relevant to Airline
Operations:
Many of the collegiate aviation schools provide specialized training
in a flight simulation training device using realistic scenarios,
including some coursework and advanced flight training in jet aircraft
systems and airline operational procedures. For example, Embry-Riddle
Aeronautical University's Aeronautical Science degree program is
designed to prepare graduates for a career as a professional pilot in
multi-crewmember, jet aircraft. Courses include communication theory
and skills, aircraft turbine engines, crew resource management,
aviation weather, jet transport systems, and optional upset recovery
training. Officials who represented 10 of the 24 regional airlines we
interviewed listed some of these types of courses as examples that FAA
could require as part of pilot schools' training curriculums that
would improve the skill level and competency of applicants seeking to
be hired as first officers.
Some collegiate aviation schools--and some large flight instructor-
based and vocational pilot schools--have developed relationships with
the training departments of some regional airlines, referred to as
bridge programs, in order to qualify their students with advanced
training procedures involving regional jet simulators.[Footnote 48]
Students enrolled in a bridge program will train on flight simulators
and other flight training devices, become familiar with regional jets,
and often learn airline-specific operational procedures in a multi-
crew environment. The airlines, in turn, will offer interviews to
students from those programs that successfully complete the school's
curriculum and earn all of the pilot certification credentials. A
bridge program is designed to bridge the gap between the general
aviation training experience in small single-and multiengine aircraft
and a professional airline career. For example, Arizona State
University's aviation degree program has established a bridge
agreement with a regional airline, Mesa Airlines, which allows the
students to train in full-motion simulators of the regional jets that
Mesa operates (see figure 7).
Figure 6: Full-Motion Flight Simulator at Arizona State University:
[Refer to PDF for image: 2 photographs]
Source: GAO.
[End of figure]
FAA and Industry Efforts to Address Issues Associated with Pilot
Training:
FAA has initiated several efforts to address issues related to pilot
certification testing and training. In 2010, FAA began revising the
repository set of questions that it uses to create its knowledge tests
for pilot certification. FAA found that a significant percentage of
applicants tested on the new questions failed the test compared to
those that took the test with the previous questions. FAA plans to
cooperate with industry representatives on future changes to the
knowledge test questions and would likely implement any further
changes over the next 2 years. Additionally, according to FAA
officials, FAA has developed other plans related to improving pilot
training to be implemented during fiscal year 2012.
* FAA plans to establish a government and industry working group
during fiscal year 2012 to address issues related to pilot
certification testing standards and training. The group will make
recommendations to FAA on a variety of issues, including knowledge
content, technical information related to pilot knowledge and
practical tests, computer testing supplements, knowledge test guides,
and practical test standards.
* FAA is currently updating its national guidance and associated
handbook for FAA inspectors on the recurrent training for flight
instructors that is conducted by the aviation industry by providing
refresher training courses. As stated earlier, part of the oversight
for flight instructor-based schools is the subsequent renewal of the
flight instructor's certificate every 24 months. The refresher
training is designed to keep flight instructors informed of changes to
flight training and is one of several methods by which a flight
instructor may renew a flight instructor certificate.[Footnote 49]
* FAA is also updating its guidance on the review process for the 24-
month certification renewal for pilots and flight instructors.
According to FAA, the current guidance is outdated and the revised
version will provide more detailed guidance for the renewal review
process, updated terminology and references, and reorganized review
content.
* FAA plans to make changes to the practical test standards (i.e.,
guidance used for conducting the flight test portion of a practical
test) to incorporate required testing for runway incursions. FAA's
goal with the revised standards is to reduce runway incursions by 2
percent annually from the current level.[Footnote 50] Currently, the
part of the practical test standards for evaluating a student's
knowledge of runway incursions is not required or specifically
outlined. However, changes to the practical test standards include
labeling runway incursions as a required testing task that includes
specific procedures to be conducted during the test.
* FAA has also recently initiated efforts to partner with the aviation
academic community through a 5-year plan initiative, working through
AABI and the University Aviation Association (UAA), to leverage
academic expertise and develop best practices for improving all pilot
training.[Footnote 51] The goal is to identify specific non-regulatory
measures that can be used to improve training and reduce accidents.
Other efforts to improve pilot training have generally focused on
advanced training for pilots already employed at airlines--not on
initial pilot training for students at pilot schools. Over time, U.S.
pilot schools have become the primary source for producing pilots for
the airline industry. In May 2011, in response to comments to a
January 2009 notice of proposed rulemaking and requirements in the
Airline Safety and Federal Aviation Administration Extension Act of
2010, FAA issued a supplemental notice of proposed rulemaking that
would require existing airline pilots to train as a complete flight
crew and coordinate their actions through crew resource management and
scenario-based training, among other things.[Footnote 52] The rule
would require airlines to provide ground and flight training to all
existing airline pilots in the recognition and avoidance of stalls,
recovery from stalls, recognition and avoidance of aircraft upset, and
the proper techniques to recover from upset--all related factors
evidenced in the Colgan Air crash in 2009--as required in the act.
[Footnote 53] Additionally in May 2011, NTSB issued a series of
recommendations to FAA related to first officer leadership and
communications training. One recommendation to FAA, to which FAA has
not yet formally responded, was that role-playing or simulator-based
exercises that teach first officers to assertively voice concerns and
that teach captains to develop a leadership style that supports first
officer assertiveness be included as part of the already required crew
resource management training for airline operations. These proposals
are designed to enhance the training programs of airlines rather than
the training requirements for pilot students, however, some of these
ideas could be applied to the initial training for students seeking
commercial airline careers.
In addition, other aviation industry efforts are being developed that
focus on improving all pilot training. For instance, one aviation
organization has proposed the development of a global professional
pilot certification to bridge the competency gap between pilot
certification and being employed. The professional pilot certification
would be based on a set of standards to ensure a newly-certified pilot
has the knowledge required by the standards to enter the pilot
profession. A not-for-profit association of pilot training
professionals has proposed the development of an independent,
international clearinghouse for pilot training best practices.
International Air Transport Association (IATA) launched the Training
and Qualification Initiative in 2007 to update and modernize the
training of existing and future pilots. The initiative's goal is to
make pilot training more accurately reflective of the needs of flight
deck operational procedures. Aviation stakeholders, such as Boeing and
Flight Safety International, are offering a first officer's course to
bridge the skill and competency gap between training received at pilot
schools and being employed as a commercial airline pilot.[Footnote 54]
European Pilot Training Differs from the U.S. System, in Part Due to
Varying Philosophies and Circumstances:
Similar to FAA, EASA provides the regulatory framework for oversight
of European countries' national aviation authorities, which carry out
the requirements for pilot licensing and training.[Footnote 55]
Creation of EASA is the centerpiece of the European Union's strategy
for developing one level of aviation safety across Europe. EASA
establishes common safety and environmental regulations and standards,
and monitors the implementation of standards through inspections in
its member states under authorization of the European Union. The
United States and Europe provide a good comparison for aviation
licensing as they offer equivalent pilot certificates, but they
provide training for these certificates in different ways, as we
describe below.
The European Pilot Training System Emphasizes Aeronautical Knowledge
(Ground School) Instruction and Testing While the U.S. System Focuses
More on Training in Practical Skills:
Both FAA and EASA meet the ICAO standards for pilot certification and
offer the private pilot, commercial pilot, and the airline transport
pilot certifications (see table 2). An FAA pilot certificate is the
equivalent of an EASA pilot license (we will only refer to a
certificate--not license--for the simplicity of reporting).
Table 2: Comparison of Pilot Certifications and Training Standards of
ICAO, FAA, and EASA:
Private Pilot Certificate:
Minimum Age:
ICAO: 17;
FAA: 17;
EASA: 17.
Ground school;
ICAO: No specified minimum number of hours;
FAA:
- No specified minimum number of hours for Part 61;
- 35 hours for Part 141;
EASA: No specified minimum number of hours.
Written test;
ICAO: No reference to a test, just demonstrate knowledge;
FAA: Pass an examination and score at least 70 percent overall;
EASA: Pass examination and score at least 75 percent for each subject
tested.
Flight training;
ICAO: 40 hours total time;
35 hours total time if completed during a course of approved training;
FAA: 40 hours (Part 61) or 35 hours (Part 141) total time;
EASA: 45 hours total time;
5 hours may be completed in a Basic Instrument Training Device or a
flight simulator.
Practical test;
ICAO: Demonstrate ability as pilot-in-command of an aircraft within
the appropriate category of aircraft;
FAA: Required in aircraft;
EASA: Required in aircraft.
Commercial Pilot Certificate.
Minimum age;
ICAO: 18;
FAA: 18;
EASA: 18.
Ground school;
ICAO: No specified minimum number of hours;
FAA:
- No specified minimum number of hours for Part 61;
- 35 hours for Part 141;
EASA:
- 250 hours (modular)[A];
- 350 hours (integrated)[B].
Written test;
ICAO: No reference to a test, just demonstrate knowledge;
FAA: Pass an examination and score at least 70 percent overall;
EASA: Pass examination and score at least 75 percent for each subject
tested.
Flight training;
ICAO: 200 hours or 150 hours total time if completed during an
approved training course;
FAA: 250 (Part 61) or 190 hours (Part 141) total time;
EASA: 200 (modular) or 150 hours (integrated) total time.
Practical test;
ICAO: Demonstrate ability as pilot-in-command of an aircraft within
the appropriate category of aircraft;
FAA: Required in aircraft[C];
EASA: Required in aircraft.
Airline Transport Pilot Certificate.
Minimum age;
ICAO: 21;
FAA: 23;
EASA: 21.
Ground school;
ICAO: No minimum number of ground school hours;
FAA:
- No specified minimum number of hours for Part 61;
- 40 hours for Part 141;
EASA:
- 650 hours (modular);
- 750 hours (integrated).
Written test;
ICAO: No reference to a test, just demonstrate knowledge;
FAA: Pass an examination and score at least 70 percent overall;
EASA: Pass examination and score at least 75 percent for each subject
tested.
Flight training;
ICAO: 1,500 hours total time;
FAA: 1,500 hours total time;
EASA: 1,500 hours total time.
Practical test;
ICAO: Demonstrate ability as pilot-in-command of an aircraft within
the appropriate category required to be operated with a copilot;
FAA: Required in aircraft or flight simulator;
EASA: Required in aircraft or full flight simulator of a multi-pilot
aircraft under instrument flight rules as a pilot-in-command.
Source: GAO presentation of ICAO standards, and FAA and EASA
regulations.
[A] Modular training is similar to the training model practiced in the
United States under Part 61 where students are trained through a
building block approach of modular segments of ground school and
flight training at their own pace.
[B] Integrated training is similar to the training model practiced in
the United States under Part 141 where students attend an approved
flight training organization (school) and train through an approved
full-time course of ground school and flight training.
[C] An FAA-qualified and approved flight simulator or flight training
device can be authorized to be used to complete certain flight task
requirements listed in the practical test standards for the commercial
pilot certification.
[End of table]
In particular, for commercial pilots who may be hired as airline
pilots, FAA has less exhaustive ground school requirements and
practical testing requirements for pilot certification than EASA.
Pilot certification in the United States emphasizes piloting skills
and, thus, concentrates more on flight training. While FAA pilot
certification regulations require some ground school instruction, the
regulations do not emphasize the need for formalized training. As
previously stated, FAA's pilot training regulations require that a
person applying for a private and commercial certificate must receive
and log ground training from a flight instructor or complete a home-
study course on the applicable ground school areas. Part 61
regulations do not specify a required number of training hours for
ground school for any pilot certificate--although, they require that
minimum knowledge subject areas are covered during training--but do
specify a minimum number of actual flight hours. On the other hand,
the European system emphasizes and requires ground school training
hours along with actual flight training hours for pilot certification.
EASA has no minimum number of training hours for ground school for a
private certificate similar to FAA, but requires a minimum of 350
hours of instruction for the commercial certificate and 750 hours for
the airline transport certificate.
The United States and Europe also have differing approaches to the
pilot certification knowledge and practical testing. While FAA uses
one multiple-choice knowledge test and requires an overall score of 70
percent or higher to pass, EASA uses multiple tests for each
certificate while utilizing multiple-choice and open-ended questions.
Pilot test applicants must pass with at least a 75 percent pass score
for all questions related to each ground school area being tested.
European officials told us that the quantity and variety of tests
given ensure students have a true understanding and application of the
aeronautical knowledge provided in ground school necessary for being a
skilled pilot. Also, FAA's pilot certification system places greater
emphasis on practical testing on various types of equipment. In
addition to the required number of hours of ground instruction and
tests, the United States and Europe differ on the type of aircraft on
which pilots are trained and tested. As stated earlier, much of U.S.
pilot training takes place only in a single-pilot, single-engine
airplane, which is not reflective of today's modern jet aircraft and
the training needs of an airline pilot, according to aviation
stakeholders. FAA does not require airline transport pilot applicants
to show proficiency in a multi-pilot airplane, either as a captain or
first officer. However, FAA officials stated that airlines are
required to provide that training to their pilots after being hired
and before transporting passengers. EASA, however, requires airline
transport pilot applicants to show proficiency in operating as a first
officer on multi-pilot, multi-engine planes and there is greater
emphasis in Europe for training in a multi-crew environment.
Differences in Training Philosophy and Circumstances Have Led to
Contrasting Pilot Training Methods:
The U.S. pilot training system is based on the traditional aviation
philosophy, which relies on a modular (building block) approach. This
model requires pilots to obtain different certifications through
building the competencies and experience by accruing a certain level
of aeronautical knowledge (ground school training) and minimum number
of flight hours. In a modular training approach, students are provided
different training modules that are independent of each other. Pilot
certification in the United States is based on these building blocks
whereby each level of pilot certificate builds upon the knowledge and
experience gained at the previous level. Thus, commercial airline
pilots are trained through various levels of pilot certification by
meeting ground school and flight training requirements at each level,
and then must gain actual flying experience through various aviation
jobs to build the necessary hours to be hired by a regional airline.
Europe has two training systems for acquiring pilot certificates and
ratings--the step-by-step modular training approach and an integrated
training program approach (ab initio). [Footnote 56] Similar to the
United States, the modular training programs train students through
modular courses and in-flight training at their own pace. This
approach is usually pursued part-time or on a non-continuous basis,
normally focusing on flying solo, and starts with a private pilot
certificate. The integrated training approach requires student pilots
to attend an approved flight training organization for an approved
full-time course and emphasizes a multi-crew environment.[Footnote 57]
European officials we spoke with explained that the integrated
approach is specifically directed towards individuals interested in
becoming an airline pilot. The fundamental philosophy of ab initio
training--which is also the traditional approach by which U.S.
military pilots are trained--is the belief that a competent,
proficient airline pilot can be trained to airline standards with as
little as 350 hours of flight time, provided the student is immersed
in a properly designed aviation curriculum from the outset.[Footnote
58] In other words, the training approach is not based on the quantity
of hours of training, but rather on the quality of the training to
better enable an individual to achieve competency. A few U.S. pilot
schools offer an ab initio training program; however, they are
generally provided by universities and require the student to take
part in a 4-year program, generally a longer timeframe than it takes
to complete a European ab initio program administered by an airline
sponsored school. U.S. ab initio programs train pilots for positions
with regional or commuter airlines, whereas in Europe, ab initio
training is more specifically for pilots being training for mainline
airlines.
Another major difference between the United States and European
countries is the implementation by EASA of regulations to support the
multi-crew pilot license--an ICAO-approved, alternative pilot-training
and certification concept specifically geared toward training
commercial airline pilots.[Footnote 59] According to ICAO, a total of
32 ICAO member states have regulations in place for the multi-crew
pilot license. However, currently only 13 of the 190 ICAO members (7
percent) have approved training organizations to conduct training for
the multi-crew pilot license, with different training schemes in
progress. The training is designed to focus on mastering the
competencies specific for becoming an airline first officer. The multi-
crew pilot license, established by ICAO, requires at least 240 hours
of total flight training and is comprised of actual flight time and
simulation time for meeting competency milestones. However, the
license is not a general pilot certificate and must be granted to an
individual for a specific aircraft type and limits an individual as a
first officer for a specific airline. FAA has not developed
regulations for a multi-crew pilot certification, and there are
differing views on its usefulness and necessity in the United States.
FAA officials said they have been studying the feasibility of
implementing the necessary regulations for U.S.-based commercial
airlines, but they also indicated that U.S. airlines have not publicly
shown interest in a multi-crew pilot certification due to the
availability of a broad pool of commercial and airline transport
pilots in the United States. Representatives from three regional
airlines and one industry association told us that, with the number of
furloughed pilots as a result of the economic downturn in 2008,
application of the multi-crew pilot certification is not needed in the
United States and would be too restrictive in nature. The
certification would limit pilots to being first officers, limit them
to a specific aircraft type, and not allow them to transfer to other
airlines. Traditional pilot certificates require more training hours,
but do not include such restrictions.
Part of the reason European countries and airlines have adopted the ab
initio approach is to address a shortage of qualified airline pilots.
Historically, U.S. airlines have recruited experienced pilots from the
robust U.S. general aviation community and the U.S. military. The
United States also has significantly more pilot schools than Europe.
Conversely, Europe has not benefited from a steady stream of military
pilots or a thriving general aviation sector. As a result, European
schools are mostly focused on producing commercial airline pilots.
European countries and airlines have used the ab initio training model
and multi-crew pilot license to increase the number of available
airline pilots.
At times, in response to pilot shortages, European airlines have
funded the training for their pilot candidates. After the screening
process, many student pilots in the European countries we visited are
provided training by airline sponsorship or an agreement for
employment with an airline. Examples of airlines that follow this
practice include Lufthansa and Air France, where students are offered
the training as part of a partial sponsorship program, wherein
candidates are required to pay a small portion of the training costs
upfront (Lufthansa provides loans to students to cover this cost).
Once training is completed, Lufthansa and Air France enter into an
employment contract with the candidate, and he or she repays the loans
via a lower initial salary. Similarly, while British Airways does not
sponsor students as fully as it has in the past, when it does, the
students pay for their training through their salary once they begin
working for the airline. On the other hand, KLM airline does not
sponsor candidates; however, it does partially fund an insurance
policy to help cover the default risks for the banks that loan the
money to the students for training as a result of early termination
due to poor performance, failed medical examination, and other
unforeseen circumstances. If the insurance policy is executed,
students are contractually obligated to cease pursuit of a pilot
career. U.S. airlines do not sponsor students for initial pilot
training. As mentioned previously, pilot training in the United States
is provided to individuals based on the self-sponsored concept--if
they can pay, they can train. Students do not need to meet certain
qualifications to train. However, once hired, all U.S. commercial
airlines are required to provide the advanced training for their
pilots. Several officials stated that most pilot students in the
United States are not interested in becoming commercial airline pilots
and pursue training to fly recreationally.
According to literature, most pilot schools in the United States
conduct little screening of students that apply, whereas European
schools routinely use comprehensive mechanisms to identify the most
qualified students as to provide the best pilot candidates to their
sponsoring airlines. The candidate screening process is generally the
same across Europe and includes several interviews, various
psychological tests, and scenario-based testing. According to some
European officials, pilot schools in Europe focus on selection
procedures and aptitude screening. According to officials at European
airlines, basing selection on fixed standards instead of selecting
candidates influenced by commercial pressure assures airlines that
they are training a qualified pilot. Officials at these European
airlines and the pilot schools they sponsor noted that pilot training
in Europe is very expensive, and selecting the right pilot candidates
is important because of safety reasons and the upfront investment for
the company. In the United States, however, the most intensive
screening process occurs when pilots seek employment with airlines.
The airlines independently assess candidates' work experience,
technical, and non-technical skills before hiring. (For more
information on the demand for and supply of pilots, see appendix II.)
According to some aviation stakeholders, U.S. pilot schools would lose
revenue if they screened or selected students as is done in Europe and
would be challenged under privacy and anti-discrimination laws.
FAA Completed Most Required Inspections of Pilot Schools, but
Oversight of Examiners and Instructors Is Difficult to Assess:
The Majority of Required Inspections of Pilot Schools Were Completed
from Fiscal Years 2006 through 2010:
For fiscal year 2010, our analysis of FAA's PTRS data found that FAA
completed about 78 percent of the required inspections for the 545
pilot schools with a Part 141 certificate (vocational schools and most
collegiate aviation schools). As part of its oversight role, FAA
monitors pilot schools with a Part 141 certificate to ensure that they
meet the required safety and training regulations. To fulfill NPG
requirements, FAA requires its inspectors to conduct on-site
inspections of each of these schools at least once a year. The
inspections focus on five areas related to pilot school operations and
the airworthiness of training aircraft. Under operations, an
inspection must cover the school's facility and student records. Under
airworthiness, an inspection must cover the pilot school facility,
compliance with FAA's airworthiness directives, and a Part 141 ramp
check.[Footnote 60] Inspectors enter the details and results of their
monitoring in FAA's PTRS data system. In reviewing PTRS data for
fiscal year 2010, we found that FAA completed the majority of the
required inspections of schools with a Part 141 certificate--that is,
the inspections covered all five inspection areas during the year.
However, we found that for 118 of the 545 schools that were inspected
during the fiscal year, all of the five inspection areas were not
covered (see table 3). An annual inspection covering all of the
inspection areas is important for overseeing these schools because it
provides some assurance to FAA that they are meeting the regulatory
requirements for providing adequate training to pilot students.
Table 3: Completion Percentage of Required Inspections for Pilot
Schools with Part 141 Certificates for Fiscal Year 2010:
Required NPG inspection areas completed: 2010.
Required NPG inspection areas completed: 0 of 5;
2010:
Number: 20;
Percent: 3.7;
Cumulative percent: 3.7.
Required NPG inspection areas completed: 1 of 5;
2010:
Number: 17;
Percent: 3.1;
Cumulative percent: 6.8.
Required NPG inspection areas completed: 2 of 5;
2010:
Number: 58;
Percent: 10.6;
Cumulative percent: 17.4.
Required NPG inspection areas completed: 3 of 5;
2010:
Number: 16;
Percent: 2.9;
Cumulative percent: 20.3.
Required NPG inspection areas completed: 4 of 5;
2010:
Number: 7;
Percent: 1.3;
Cumulative percent: 21.6.
Required NPG inspection areas completed: 5 of 5;
2010:
Number: 427;
Percent: 78.3;
Cumulative percent: 100.0.
Required NPG inspection areas completed: Total;
2010:
Number: 545;
Percent: 100.0.
Source: GAO analysis of FAA data.
[End of table]
We were unable to determine whether the data were missing because they
were entered incorrectly into PTRS, or because the inspections did not
take place as required. We were also unable to determine the extent
inspections were completed in fiscal years prior to 2010 due to
limitations in tracking the number of pilot schools that existed in
each fiscal year. FAA does not maintain a historical listing of the
active pilot schools with a Part 141 certificate for a given fiscal
year and, thus, we could not define the universe of pilot schools that
was required to be inspected during fiscal years 2006 through 2009. As
a result, we could not determine the identity and number of schools
that needed to be inspected. While FAA officials recognized that all
required NPG inspections are expected to be completed within each
fiscal year time frame, they provided several reasons to potentially
explain why some of the required inspections are not recorded in PTRS.
FAA officials said that inspectors may have conducted the required
inspections for some schools but incorrectly entered the details in
PTRS. For example, some FAA inspectors may conduct full inspections of
schools that cover the five inspection areas, but may enter only two
of the five inspection numbers into PTRS. The officials also said that
inspectors had additional duties--such as following up on previously
identified issues or addressing the need for additional oversight for
certain inspection areas--in conducting inspections for some schools,
which can make covering all five inspection areas difficult.
In addition, many of the part 141 pilot school inspections required by
NPG are incorrectly recorded as discretionary inspections in PTRS
making it difficult to use PTRS to determine if FAA had conducted all
of the required inspections of part 141 pilot schools for a given
year. Specifically, 35 percent of the 4,551 part 141 pilot school
inspections required by NPG in fiscal year 2010 were listed
incorrectly in PTRS as discretionary inspections. Also, 32 percent of
the required inspections were listed as discretionary from fiscal year
2006 through 2010. As a result, those inspections would not show up in
a list generated in PTRS of required inspections for fiscal year 2010.
FAA officials said that this problem is likely caused by the program
that populates PTRS with the NPG requirements.
When inspections or other sources revealed compliance issues or
violations, FAA uses a variety of actions to enforce safety standards
and regulatory compliance, such as oral or written counseling,
administrative action, legal enforcement action, and referral for
criminal prosecution. When an FAA inspector identifies a potential
violation, he or she initiates an investigation and if FAA determines
that a violation has occurred, FAA has a wide range of options
available for addressing it. From fiscal years 2006 through 2010, our
analysis of FAA's EIS data found that FAA initiated 230 enforcement
cases against pilot schools with a Part 141 certificate. The majority
of these cases resulted from an inspection of a school, but others may
have resulted from other sources. During fiscal years 2006 through
2010, FAA used a wide range of enforcement actions against pilot
schools with a Part 141 certificate (see figure 7).
* No action: FAA can determine that no action is warranted. In 26 of
the 230 cases (about 11 percent), enforcement cases were initiated,
but no enforcement action was taken.
* Administrative Actions: In 186 cases (about 81 percent), FAA used
administrative actions to address violations. These actions refer not
only to warning notices and letters of correction but also informal
actions, such as oral or written counseling, which can also be used by
inspectors to address an apparent violation, provided that certain
criteria are satisfied and the apparent violation is a low safety risk.
* Enforcement actions: We found that FAA rarely used punitive means
such as revoking licenses and assessing penalties against pilot
schools with a Part 141 certificate. FAA assessed monetary civil
penalties in 12 cases (about 5 percent) for pilot schools with a Part
141 certificate and the sanctions ranged from $500 to $20,000. FAA
revoked the operating certificates of schools in 3 cases, or slightly
more than one percent. To illustrate the severity of an action that
leads to revoking operating certificates, these include knowingly
permitting school training aircraft to be used to carry illegal
controlled substances or an intentional action to improperly credit
training to or graduate students.
Figure 7: The 230 Enforcement Cases for Pilot Schools with Part 141
Certificates from Fiscal Years 2006 through 2010:
[Refer to PDF for image: pie-chart]
Administrative: 81%;
No action: 11%;
Sanction: civil penalty: 5%;
Sanction: revocation: 1%;
Other action: 1%.
Source: GAO analysis of FAA data.
Note: Numbers do not add up to 100 percent due to rounding.
[End of figure]
It Is Unclear Whether Required Inspections for Pilot Examiners Were
Completed Because FAA Data System Lack Historical Information:
From fiscal years 2006 through 2010, our analysis of FAA's PTRS data
found that FAA completed 9,016 inspections of pilot examiners, but it
is unclear whether FAA met all of its oversight requirements in this
area (see figure 8). FAA uses private individuals or organizations to
supplement its workforce and to provide certification activities such
as examining and testing of pilot applicants for a fee paid for by the
applicant.[Footnote 61] Known as designees, pilot examiners are
generally appointed by FAA's local district personnel for either 3
years (for an individual) or 5 years (for an organization).[Footnote
62] As part of its oversight role, FAA requires each pilot examiner to
be inspected by FAA inspectors at least once annually and high
activity pilot examiners must be inspected at least twice annually, as
outlined in the agency's oversight policy and NPG directives.[Footnote
63] Additionally, several other circumstances may require an FAA
inspector to inspect a pilot examiner, such as noncompliance with the
applicable certification policies, an excessively high certification
passing rate, or involvement in an accident, incident, or other
violation.[Footnote 64] Although we know the number of inspections
conducted for each fiscal year, we could not determine the completion
percentage of the required inspections for either the routine annual
or additional inspections for high activity or special circumstances
for each fiscal year due to limitations in available data for the
population of pilot examiners.
Figure 8: The 9,016 Inspections of Pilot Examiners from Fiscal Years
2006 through 2010:
[Refer to PDF for image: vertical bar graph]
Year: 2006;
Number of inspections: 1,913.
Year: 2007;
Number of inspections: 1,819.
Year: 2008;
Number of inspections: 1,813.
Year: 2009;
Number of inspections: 1,821.
Year: 2010;
Number of inspections: 1,650.
Source: GAO analysis of FAA data.
[End of figure]
Although we could not determine the completion percentage of the
required inspections for pilot examiners, our analysis of PTRS
inspection data showed 1-and 2-year gaps in the oversight of some
pilot examiners. For instance, we found 114 pilot examiners with a 1-
year gap between inspections, and 11 pilot examiners with a gap of 2
years. This may indicate that required inspections of pilot examiners
were not completed by FAA in a given fiscal year or that inspections
were unnecessary due to inactivity of the examiners during that year.
FAA officials told us that, until recently, FAA had not analyzed the
extent to which it has conducted all required pilot examiner
inspections on a national level.
FAA has previously taken steps to improve oversight of pilot
examiners, but still faces issues in this area. In 2005, FAA developed
14 recommendations to improve pilot examiner compliance, 11 of which
were implemented. FAA officials told us that the implementation of
these recommendations has resulted in improvements in pilot examiner
oversight guidance and in the information technology used to oversee
pilot examiners for local district offices. They also said that, as a
direct result of the recommendations, more of the pilot examiners with
poor performance issues have been terminated and oversight of pilot
examiners has improved. Nevertheless, FAA officials acknowledged they
still face some issues in oversight of pilot examiners, due, in part,
to the FAA's current data systems' difficulty compiling inspection
data at the regional or national level. In September 2010, FAA began
developing quarterly assessment reports covering 12-month periods on
the oversight of its designees, including pilot examiners, to assist
in identifying oversight gaps and potential areas of concerns. We
reviewed the quarterly reports that covered July 2009 through March
2011 and found they identified a number of areas of concern regarding
the oversight of pilot examiners. For example, some pilot examiners
with the highest activity had not been inspected over the previous 12
months. FAA began creating the quarterly assessment reports to better
inform management officials at the national office level. For example,
in the most recent report provided by FAA officials, five high-
activity pilot examiners were identified that performed a total of
1,623 pilot practical tests, but no inspections were conducted for
these pilot examiners for the previous 12 months. Conversely, the
report found that FAA conducted 218 inspections of the 171 pilot
examiners with the lowest testing activity during the same
period.[Footnote 65] Based on this report, FAA's inspection record is
not consistent with the pilot examiners that are responsible for
conducting the largest numbers of practical tests, and conducting more
oversight on the examiners conducting significantly fewer tests.
FAA officials said that the quarterly assessment reports are a
temporary way of assessing the extent to which it is conducting all
required inspections, but FAA is in the process of developing a new
designee management system that it expects to be operational by July
2012. FAA officials told us that the new system is being designed to
provide more comprehensive data on designees, including pilot
examiners, by combining data that FAA currently maintains in various
data systems. Thus, the new system will consolidate the management and
oversight functions for designees to allow for more readily available
data. The officials also told us that they are in the process of
revising oversight policy for designees and improving tools for
selecting which pilot examiners to inspect.
While Not Required, FAA Conducts Optional Oversight Inspections for
Flight Instructors, but to What Extent Is Unclear:
Unlike oversight of pilot schools with Part 141 certificates and pilot
examiners, annual inspections of individual flight instructors (i.e.,
under Part 61 regulations) are not required by FAA. From fiscal years
2006 through 2010, our analysis of FAA's PTRS data found that FAA
completed 1,761 inspections of flight instructors. Oversight for
flight instructors is generally limited to initial and subsequent
certification renewal, but additional oversight of flight instructors
is conducted as an optional work activity by FAA. However, despite
being optional, FAA officials from one local district office told us
that their inspectors make this area a priority in their planned work
activities for a given fiscal year. According to FAA policy, flight
instructor certificates are renewed every 24 months. However,
inspections of flight instructors and their training activities should
take place on a random basis in the interim, but should be prioritized
as a result of, for instance, observations of noncompliance actions
made during a pilot school inspection, an instructor or student is
involved in an accident or incident, or when an instructor has a
student failure rate of 30 percent or greater on FAA's certification
tests. The oversight of flight instructors is important because, like
the examiners, this population serves as a gatekeeper for ensuring
that pilot students are being properly trained as they seek
certification. However, similar to pilot examiners, we could not
determine the extent of oversight that FAA provided for the entire
flight instructor population or the specific reasons that inspections
were conducted during the 5 fiscal years.
Similar to pilot schools, when inspections or other sources revealed
compliance issues or violations, FAA uses a variety of actions to
enforce safety standards and regulatory compliance. For fiscal years
2006 through 2010, our analysis of FAA's EIS data found 178 cases
against flight instructors (see figure 9).
* No action: FAA can determine that no action is warranted. In 38 of
the 178 cases (about 21 percent), enforcement cases were initiated but
no enforcement action was taken.
* Administrative Actions: In 109 cases (about 61 percent), FAA used
administrative actions to address violations. These actions refer not
only to warning notices and letters of correction but also informal
actions, such as oral or written counseling, which can also be used by
inspectors to address an apparent violation.
* Enforcement actions: We found that FAA rarely used punitive means
such as suspending or revoking licenses and assessing penalties
against flight instructors. FAA suspended licenses in 9 cases (about 5
percent) and revoked licenses in 16 cases (about 9 percent). FAA also
assessed monetary civil penalties in three cases (about 2 percent) for
flight instructors.
Figure 9: The 178 Enforcement Cases for Flight Instructors from Fiscal
Years 2006 through 2010:
[Refer to PDF for image: pie-chart]
Administrative: 61%;
No action: 21%;
Certification revoked: 9%;
Certification suspended: 5%;
Fine assessed: 2%;
Other action: 2%.
Source: GAO analysis of FAA data.
[End of figure]
Inspectors also Use the Safety Performance Analysis System to Plan
Their Work:
In addition to using PTRS and EIS, FAA inspectors develop their work
plan using another somewhat limited oversight tool--the Safety
Performance Analysis System (SPAS)--which provides data access and
analysis on pilot schools, pilot examiners, and flight instructors.
[Footnote 66] The SPAS system is a data analysis application that
monitors performance measures and calls attention to trends. SPAS
builds on inspection results and other data and is intended to assist
FAA's local district offices in applying their limited inspection
resources to those entities and areas that pose the greatest risk to
aviation safety. For example, when particular inspection tasks warrant
attention, SPAS will "flag" an advisory notification to a FAA
inspector and prompt the inspector to look into the situation, e.g., a
flight instructor with a high rate of student failure on practical
tests. While SPAS may be useful at the local level, it does not have
the capability to perform national level rollup analysis. Thus, FAA
does not have the ability to measure FAA's annual performance in
meeting the NPG inspection requirements for pilot schools and pilot
examiners based on PTRS inspection data, or to make risk-based, data-
driven decisions about the scope of its discretionary, planned work
activities that include flight instructors. As a result, FAA's
national office cannot readily access comprehensive inspection
completion data and determine the level of oversight its field staff
is providing for pilot schools and pilot examiners.
Conclusions:
Public and media concerns about aviation safety escalated as a result
of the Colgan crash in early 2009, and Congress and FAA have taken
steps to improve aviation safety by making revisions to the training
requirements that airlines must provide for commercial airline pilots.
Our analysis indicates that FAA has an opportunity to ensure that the
initial pilot training process for producing pilots' commercial
certificates is still relevant for the necessary knowledge and skills
for airline positions. Although many of the improvements to training
being considered are for existing airline pilots--such as those
related to decision making and operating in a crew environment--they
may also apply to initial pilot training. We are not making
recommendations in this area, because FAA has initiated some efforts
and has plans for other efforts to address pilot training issues. For
example, FAA plans to establish a government and industry working
group during fiscal year 2012 to address issues related to pilot
certification testing standards and training. Therefore, we encourage
FAA to continue its efforts, with industry and academia collaboration,
in reviewing the initial pilot training process, including ground
school content, training hour requirements, and knowledge testing for
commercial pilot certification under the Part 61 regulations.
FAA's oversight of key functions for the initial pilot training
process in the United States by which commercial pilots become
certificated is reasonably sound. We found that FAA completed most
required inspections of vocational pilot schools (Part 141), but the
agency's data sources did not provide certainty that the level of
oversight is consistently being performed in accordance with the
agency's guidelines and policies, including oversight requirements for
pilot examiners. FAA's national office does not monitor the annual
completion of the requirements outlined in the annual NPGs related to
monitoring pilot schools and pilot examiners. Therefore, the national
office cannot readily determine the level of oversight its field staff
is providing for these key stakeholders and has been unable to produce
this information. Better internal control mechanisms, such as creating
and reviewing agencywide reports using PTRS data periodically, would
improve FAA oversight by providing assurance that all required
inspections were completed. Additionally, FAA could establish standard
procedures for entering PTRS data for inspectors at the local level of
the completed inspection areas to avoid the uncertainty of whether or
not they were completed as required. This would not only help FAA
better measure its performance in meeting the annual NPG inspection
requirements, but would also enable the agency to make more informed
decisions about the scope of its discretionary, planned work
activities for flight instructors. Further, the steps taken by FAA to
develop a quarterly assessment report on the oversight and performance
of pilot examiners is promising, but FAA should also consider
developing a similar process for oversight of flight instructors
because it could identify potential areas of concerns.
Recommendations for Executive Action:
We are making two recommendations to improve FAA's oversight of pilot
certification and training. The Secretary of Transportation should
direct the Administrator of the Federal Aviation Administration to
develop a comprehensive system that may include modifying or improving
existing data systems to:
* measure performance for meeting the annual National Program
Guidelines' inspection requirements for pilot schools with a Part 141
certificate and pilot examiners and:
* better understand the nature and scope of the discretionary, planned
inspections for flight instructors.
Agency Comments and Our Evaluation:
We provided a draft of this report to DOT for review and comment. In
responding to our recommendations, FAA officials said that they agreed
that improvements in oversight data were needed but indicated that the
quarterly assessment reports already measure the level of oversight of
pilot examiners and summary data is being provided to the national
office and regional division managers. Additionally, the designee
management system currently under development will address the
recommendation for pilot examiner designees in a more permanent way.
We retained the recommendation; our report notes the oversight
improvements underway for pilot examiners, and we will assess the
effectiveness of the designee management system once it is
implemented. FAA also provided technical comments that we incorporated
as appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 7 days
from the report date. At that time, we will send copies of this report
to the Secretary of Transportation and appropriate congressional
committees. The report is also available at no charge on the GAO Web
site at [hyperlink, http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-2834 or by e-mail at dillinghamg@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. GAO staff who
made major contributions to this report are listed in appendix III.
Signed by:
Gerald L. Dillingham, Ph.D.
Director, Physical Infrastructure Issues:
List of Requesters:
The Honorable John L. Mica:
Chairman:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Thomas E. Petri:
Chairman:
The Honorable Jerry F. Costello:
Ranking Member:
Subcommittee on Aviation:
Committee on Transportation and Infrastructure:
House of Representatives:
The Honorable Brian Higgins:
The Honorable Louise McIntosh Slaughter:
House of Representatives:
[End of section]
Appendix I: Scope and Methodology:
To address our objectives and the pilot supply appendix, we reviewed
and synthesized literature on pilot training and certification in the
United States. Specifically, we reviewed a range of reports from GAO,
Federal Aviation Administration (FAA), Congressional Research Service,
International Civil Aviation Organization, National Transportation
Safety Board, and Bureau of Labor Statistics that included general
background information on a variety of related issues on U.S. pilot
training, such as pilot certification and training issues in the U.
S.; historical trends, current supply and demand, and forecasts for
commercial airline pilots; types and requirements of pilot training
schools; FAA regulatory training requirements for different levels of
pilot certification; FAA oversight of U.S. pilot training system; and
comparable international pilot training systems. We conducted a
literature review search from databases, such as ProQuest, TRIS, and
Lexis, as well as well as trade publications and literature from
aviation stakeholders. Furthermore, we reviewed the Federal Aviation
Regulations related to training and certification for pilots under
Part 61, Part 141, and Part 142. We also reviewed FAA regulations,
policy, and oversight documentation related to pilot training,
management guidance for overseeing pilot schools, designated pilot
examiners (pilot examiner), and certified flight instructors (flight
instructor). Additionally, we reviewed FAA's national program
guidelines for fiscal years 2006 through 2010 regarding the required
and planned oversight activities as well as FAA's practical test
standards used to certificate pilots as private, commercial, and
airline transport. We also reviewed provisions of the Airline Safety
and Federal Aviation Administration Extension Act of 2010 (Pub. L. No.
111-216) related to "Flight Crewmember Screening and Qualifications"
and "Airline Transport Pilot Certification."
To review FAA's inspection and enforcement activities related to pilot
schools, pilot examiners, and flight instructors, we obtained FAA's
inspection and enforcement policies and analyzed raw data from FAA's
inspection and enforcement databases. We analyzed data from the
Program Tracking Reporting System (PTRS) for inspections that closed
(had a closing date) in fiscal years 2006 through 2010 and data from
the Enforcement Information System (EIS) for enforcement actions with
a date of final action in those fiscal years. To assess the
reliability of the inspection and enforcement data that we received
from FAA, we performed electronic testing of the data elements that we
used, obtained and reviewed documentation about the data and the
systems that produced them, and interviewed knowledgeable FAA
officials. We used these data to determine the extent to which FAA had
completed all required inspections of pilot schools and pilot
examiners, and planned inspections of flight instructors. For pilot
schools with a Part 141 certificate, we analyzed data from PTRS on the
numbers of required inspections that FAA completed, and whether all
five inspection areas were covered, and compared to the requirements
set in FAA's National Program Guidelines (NPG). The NPG for each
fiscal year indicated that an inspection was required for each school
within each region and to include under operations: (1) air agency
facility inspection (PTRS activity number 1640) and (2) student
records (PTRS activity number 1649). The NPG for each fiscal year also
indicated that an inspection was required for each school within each
region and to include under airworthiness: (1) pilot school facility
(PTRS activity number 3650), (2) airworthiness directive compliance
(PTRS activity number 3667 or 5667), and (3) part 141 ramp (PTRS
activity number 3664 or 5664). To determine the nature and scope of
the enforcement actions that FAA closed against pilot schools with a
Part 141 certificate, we analyzed data on these actions from EIS,
including whether the actions were administrative, fines, or
suspensions or revocations of schools' Part 141 operating
certificates. We also analyzed data to determine the minimum, median,
and maximum dollar amounts of fines and durations of suspensions. We
tested the reliability of the PTRS and EIS data that we received from
FAA with electronic testing of the data elements that we used,
obtained and reviewed documentation about the data and the systems
that produced them, and interviewed knowledgeable FAA officials. We
found the data to be sufficiently reliable for our purposes.
For pilot examiners, we analyzed data from PTRS on the numbers of
required inspections that FAA completed and compared to the
requirements set in the NPG. The NPG for each fiscal year indicated
that an inspection was required for each pilot examiner within each
region under: pilot examiner--large-turbojet (PTRS activity number
1664) and pilot examiner--other (PTRS activity number 1665). We also
obtained and reviewed summary data from FAA contained in quarterly
assessment reports on the oversight of its designated representatives,
including pilot examiners. The quarterly reports contained data from
July 2009 through March 2011.
For flight instructors, the PTRS activity number 1662 is used to
record CFI inspections in PTRS. The NPG for fiscal years 2009 through
2010 did not indicate inspections for certificated flight instructors
as a planned work activity. To determine the nature and scope of the
enforcement actions that FAA closed against flight instructors, we
analyzed data on these actions from EIS, including whether the actions
were administrative, fines, or suspensions or revocations of flight
instructors' certificates. We also analyzed data to determine the
minimum, median, and maximum dollar amounts of fines and durations of
suspensions.
We interviewed government officials at the Federal Aviation
Administration and National Transportation Safety Board. We conducted
semistructured interviews with representatives from a range of
aviation stakeholder organizations (see below). We also interviewed
researchers involved in the pilot source study. We visited pilot
training stakeholders in six states included in FAA regions that had
higher number of pilot schools, higher number of pilot certificates
issued in 2009, while taking into consideration the presence of FAA
regional and district offices and regional airlines' offices in some
locations. Thus, in our visits to Arizona, Florida, Georgia, Indiana,
Maryland, and Utah, we interviewed officials at FAA regional and
district offices, regional airlines, pilot schools, and college
aviation schools. However, because we selected these six states as
part of a nonprobability sample, our findings cannot be generalized to
all pilot training stakeholders in the United States. Through the
combination of site visits and semistructured telephone interviews, we
interviewed representatives of 24 regional airlines that transported
about 97 percent of regional passengers in 2009, according to the
Regional Airlines Association's 2010 annual report. (See table 5.)
Table 4: Agencies, Organizations, Associations, Schools, and Airline
Interviewed:
U.S. federal agencies:
Department of Transportation Office of Inspector General;
Federal Aviation Administration;
FAA Civil Aerospace Medical Institute;
National Transportation Safety Board.
International organizations:
International Civil Aviation Organization;
International Air Transport Association.
Industry associations:
Air Line Pilots Association;
Air Transport Association;
Aviation Accreditation Board International;
Coalition of Airline Pilots Association;
Flight Safety Foundation;
Flight School Association of North America;
National Association of Flight Instructors;
Professional Aviation Board of Certification;
Professional Aviation Safety Specialists;
Regional Airline Association;
Society of Aviation and Flight Educators;
University Aviation Association.
Industry organizations:
Airline Apps, Incorporated;
FltOps.com;
Pearson Education, Incorporated;
SIM Services.
Pilot schools:
Aerosim Flight Academy;
Airline Transport Professionals;
Arizona State University College of Technology and Innovation;
Aviation Flight Academy, Incorporated;
Dowling College School of Aviation;
Embry-Riddle Aeronautical University;
Phoenix East Aviation;
Purdue University Department of Aviation Technology;
University of North Dakota Department of Aviation.
Airlines:
Air Wisconsin Airline Corporation;
American Eagle;
Atlantic Southeast Airlines;
Comair;
CommutAir;
Delta Air Lines;
ExpressJet;
Horizon Air;
Kenmore Air Harbor;
Mesa Air Group, Inc; (Mesa Airlines and Freedom Airlines);
Piedmont Airlines;
Pinnacle Airlines Corp; (Pinnacle Airlines, Colgan Air, and Mesaba
Airlines);
PSA Airlines;
Republic Airways Holdings (Republic Airlines, Chautauqua Airlines,
Frontier Airlines, Shuttle America Corp; );
SkyWest Airlines;
Trans States Holdings, Inc; (Trans States Airlines, GoJet Airlines,
Compass Airlines).
Source: GAO.
[End of table]
In addition, we conducted site visits to the France, Germany,
Netherlands, and United Kingdom. We focused on these European
countries' pilot certification and training requirements because they
offer a different model than the United States. The site visits
allowed us to obtain information on European countries' pilot
standards, as well as their efforts to revise their training
requirements from traditional training objectives and methodology to
competency-based training models. However, because we selected these
four countries as part of a nonprobability sample, our findings cannot
be generalized to all European countries. During these site visits, we
interviewed officials at the European Aviation Safety Agency (Europe's
aviation regulator), civil aviation authority officials,
representatives from international and European aviation stakeholder
groups, representatives from airlines, and flight training
organizations (schools). However, because these four countries were
selected as part of a nonprobability sample, the findings from our
interviews cannot be generalized to all European countries. (See table
6.)
Table 5: Organizations Contacted by Country:
France:
Directorate General of Civil Aviation;
Ecole de Pilotage Amaury de la Grange;
Air France Airlines;
Corsairfly (regional airline);
International Civil Aviation Organization (ICAO) European Regional
Office;
Aircraft Owners and Pilots Association (AOPA) France.
Germany:
European Aviation Safety Agency (EASA);
Lufthansa Flight Training Pilot School.
Netherlands:
Ministry of Transport, Public Works and Water Management;
Joint Aviation Authorities Training Organization (JAA TO);
KLM Airlines;
KLM Flight Academy;
Nationale Luchtvaart School (training organization).
United Kingdom:
United Kingdom Civil Aviation Authority;
Oxford Aviation Academy;
Cabair College of Air Training (Cranfield);
British Airways;
Virgin Atlantic;
Willowair (training organization);
Aircraft Owners and Pilots Association United Kingdom;
General Aviation Safety Council;
Royal Aeronautical Society;
Flight Safety Committee;
Peter Metcalfe (flight instructor).
Source: GAO.
[End of table]
We conducted this performance audit from March 2010 through November
2011 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Nature and Scope of the Supply of and Demand for Airline
Pilots:
For several years now, the issue of whether the United States will
maintain an adequate supply of qualified pilots has emerged in
literature, media sources, and aviation industry discussions, but the
scope of the supply of and demand for U.S. airline pilots is unknown
and difficult to determine. The number of pilot certificates held in
the United States has been declining and is expected to continue to
decline in the near future. Demand, which has historically fluctuated,
is projected to significantly increase over the next 20 years.
Nevertheless, the International Civil Aviation Organization (ICAO) is
predicting a surplus of pilots in North America, based, in part, on
the regional capacity to provide pilot training, level of current and
projected pilot population, and the slow growth rate of the aircraft
fleet requiring additional pilots to operate them. However, certain
factors could affect that projected surplus, including the 2007
legislation extending the mandatory retirement age for airline pilots
and the sharp curtailment of military pilots as a hiring resource.
Particularly given the decrease in the number of military pilots
available to be hired by airlines, the number of students who enroll
in and complete training in pilot schools will also affect the supply
of commercial pilots, as the availability of pilots for entry-level
regional airline jobs can be directly linked to the number of pilot
certificates issued. Student enrollment in pilot schools is purported
to be declining and the dropout rate for completing pilot training is
high. Furthermore, others factors present potential challenges to the
pilot training industry, such as available financial sources to fund
pilot training and the impact of the 2010 legislation requiring
additional pilot certification requirements for airline first officers.
The Economy and Demographics Affect Airline Pilot Supply and Demand:
The safety and economic contribution of the air transportation system
not only relies on having well-trained airline pilots but also on
having enough of them to meet demand. The demand for commercial pilots
is a function of the size the commercial airline fleet and the number
of pilots needed to operate that fleet size. Demand for professional
pilots in the United States has historically fluctuated, driven by a
number of factors including consumer demand for air travel and the
general state of the economy, fuel prices, regulatory changes, and
aircraft fleet changes. For example, since 2008, the economic
recession has significantly affected the U.S. airline industry.
Several airlines have filed for bankruptcy and ceased operations,
while other airlines have merged. It is still unknown when and to what
extent the U.S. airline industry will fully recover, but demand for
air travel is highly cyclical and largely reflective of the state of
the economy, and expected to increase significantly over the next 20
years. The total number of pilot certificates held in the United
States has been fluctuating downward over the last 10 years. The
number of active student, private, commercial, and airline transport
pilot certificates held in the United States decreased from 608,079 in
2000 to 554,237 in 2009, or 9 percent. The Aircraft Owners and Pilots
Association (AOPA) predicts that, by 2014, the number of pilots in the
United States will decline to 500,000.[Footnote 67]
In late 2010, Boeing projected the commercial aviation industry in
North America will require over 97,000 new pilots over the next 20
years (over 466,000 new pilots globally) to accommodate the strong
demand for new and replacement aircraft, but noted that emerging
markets in Asia, especially in China, will experience the greatest
need for pilots. As demand for air travel continues to increase
internationally, the demand for qualified pilots will likely continue
to grow in many parts of the world, particularly in Asia and the
Middle East and possibly attract qualified commercial pilots from the
U.S. market. For instance, Boeing forecasts that China will need over
70,000 new pilots by 2029 for new commercial aircraft. In order to
deal with the lack of available pilots today, some foreign airlines
have started training their pilots through established flight training
organizations or sending their students to pilot schools in English
speaking countries, such as the United States. However, if industry
projections are realized and commercial airlines, both mainline and
regional, need large numbers of pilots, it is uncertain whether an
adequate supply of qualified pilots will be available.
However, despite these projections, ICAO is reporting a likely surplus
of pilots in North America. ICAO noted in its 2011 report on the 20-
year global and regional forecast on civil aviation personnel that the
United States, with close to 270,000 professional pilots (i.e.,
commercial or airline transport), accounts for approximately 58
percent of the global pilot population. Furthermore, the United States
has an annual training capacity for producing about 27,000
professional pilots annually. Based on the projected annual need for
new pilots and considering several factors, ICAO determined that the
United States will likely have a surplus of pilots under all of the
scenarios it considered for the North American region (i.e., the
United States and Canada). This may seem surprising considering the
general perception that a pilot shortage in the United States is
inevitable, but was supported by ICAO based on the following reasons.
First, the annual training capacity in the United States represents 60
percent of the worldwide training capacity; thus, the ICAO
calculations indicate that North America has more than enough training
capacity to train the number of new pilots needed in this region.
Second, fleet growth rates--i.e., the number of aircraft needing
pilots--for the North American region for which the United States is
the dominant player, are relatively low. Third, the current number of
licensed professional pilots in the United States represents 58
percent of the global pilot population. Although these factors do
point to a surplus, other economic and demographic factors that can be
difficult to determine could affect the projected surplus.
The temporary impact of recent legislation could affect the
availability of commercial pilots in the future and other measures may
be required to address related long-term issues. When recent concerns
arose about a potential pilot shortage, the Fair Treatment for
Experienced Pilots Act was enacted (age 65 law) in 2007 and allowed
pilots to fly domestic routes until age 65 instead of the prior
mandatory retirement age of 60.[Footnote 68] For international
flights, one pilot may be up to age 65 provided the other pilot is
under age 60, consistent with the November 2006 ICAO standard. This
effort attempted to ensure there would not be a large group of highly
skilled pilots retiring at the same time, but according to ICAO data,
pending age-related retirements will begin to reemerge in 2012. The
2011 ICAO report also indicated that approximately 85,000 professional
pilots (31 percent of the total pilot population) are aged 55 or more;
among this age group, 34,000 (13 percent of the total pilot
population) will be eligible for retirement by 2015. Another 34,000
will be eligible for retirement by 2020. The report also asserted that
it is likely, considering the age structure of pilots in North
America, that retirements will take place at an accelerating rate,
thereby contributing to a potential increase in future pilot demand.
However, all of the pilots holding commercial or airline transport
pilot certificates in the United States may not be automatically hired
by airlines due to performance and skills deficiencies. Therefore,
despite a projected surplus of professional pilots, having only a
potentially limited supply of pilots that airlines determine to be
qualified to hire could still affect the air transportation industry
in the United States.
In addition, one of the traditional, preferred sources of airline
pilots has been severely curtailed, which will likely continue to
affect the availability of pilots in the future. U.S. commercial
airlines are no longer hiring as many pilots from the U.S. military as
they had in the past, which has historically provided airlines with a
steady supply of highly qualified pilots. According to literature
sources, until the 1990s, roughly 90 percent of the pilots hired by
mainline airlines came from the U.S. military, with the remaining
source being from civilian aviation. In 2008, about 30 percent of
pilots hired by commercial airlines had military training backgrounds.
Moreover, the military is training fewer pilots and retaining more of
them with better pay and other financial incentives. In addition, many
commercial airline pilots from Vietnam era are reaching retirement age.
Domestic Student Enrollments in U.S. Pilot School Is Declining and the
Dropout Rate of Student Pilots Is High:
Particularly given the decrease in military pilots as a source of
potential civilian pilots, the number of students who enroll in and
graduate from pilot schools also affects the supply of pilots, and
could affect the ICAO projected surplus of pilots for the North
America region, specifically in the United States. The availability of
pilots for entry-level regional airline jobs can be directly linked to
the number of student pilot starts and the number of pilot
certificates issued. In the past few years, the Federal Aviation
Administration (FAA) has revised its forecast to reflect an uncertain
number of student pilots. In 2008, FAA predicted 100,200 student
pilots in the year 2025, but lowered that estimate in its 2009 through
2025 forecast report to 86,600. However, in FAA's 2011 through 2031
forecast report, FAA predicted the number of student pilots increasing
to 113,500 in 2025 (120,600 in 2031), due to a rule change by FAA that
makes student pilot certificates valid longer for pilots under the age
of 40.[Footnote 69] Also, from 1999 through 2009, the number of
private certificates issued decreased about 26 percent, but commercial
certificates slightly increased about 10 percent. Representatives of
the pilot training industry that we interviewed told us that the
overall trend reflects a lower number of domestic students starting
pilot training, a trend which continued into 2011. Representatives
from a few pilot schools told us that pilot schools across the United
States experienced large declines in enrollments in 2010. For example,
the University of Illinois decided to eliminate its 65-year-old
aviation school after a decade of declining enrollment. The collegiate
aviation school produced fewer degrees and served fewer students than
any other program on the campus during the previous school year and no
aviation students had been accepted for the coming semester.
The decline of student pilot certificates and student dropout rate are
concerns to AOPA. According to AOPA, the number of current student
pilot certificates is the best indicator of the supply of future
pilots. Representatives of several pilot schools with whom we spoke
told us that they were becoming more and more dependent on foreign
students to maintain their pilot training operations. Also, according
to FAA officials, representatives of AOPA, four pilot schools, and
several European organizations we interviewed said that some European
and Asian airlines and pilot training organizations send students to
the United States for pilot training to take advantage of the
relatively inexpensive fuel and the year-round weather conditions for
training in states such as Florida and Arizona. In addition, the
dropout rate of student pilots could affect the supply of pilots.
According to a 2010 AOPA study, almost 80 percent of student pilots
drop out of training for four key reasons: (1) lack of educational
quality, (2) lack of customer focus (not a good value or pricing not
competitive), (3) insufficient sense of community (lacks an atmosphere
that makes students feel welcome in the aviation community), and (4)
lack of information sharing (school does not provide realistic
estimate of time and costs required for a pilot certificate and
statistics on student success rates at schools).[Footnote 70] The
study indicated that while cost of training was a factor, it was less
significant than the other four reasons people did not complete
training--even though some literature suggests otherwise as discussed
below.
AOPA, as a result of this information regarding the dropout rate, has
initiated efforts with close coordination with the pilot training
industry to work on solutions to stop the outflow of students and to
increase the pilot population. AOPA has begun an initiative focused on
student retention in pilot training that will consist of a series of
regional meetings across the United States to collect perspectives and
industry input on potential improvements that can be made in providing
pilot training. AOPA has met with representatives from the aviation
community, including pilots, student pilots, aviation businesses,
pilot schools, and flight instructors who are currently involved in
conducting pilot training. In addition, the association has launched a
Let's Go Flying Web site [hyperlink, http://www.aopa.org/letsgoflying]
and created various publications to inspire more people to become
interested in learning to fly by providing an introduction to and
information about becoming a pilot.
Challenges to Financing Pilot Training Could Affect Enrollment:
Aviation stakeholders from 4 of the 9 pilot schools, two industry
associations, and one industry organization we interviewed told us
that one of most important challenges for maintaining an adequate
supply of students for pilot schools is the availability of financial
support for pilot training. Pilot training costs vary amongst the
pilot schools. According to AOPA and other sources, the cost of
training from the beginning of training through a commercial pilot
certificate and a multiengine rating could be in excess of $40,000 but
varies across the country. According to AOPA, pilot training can cost
about $100,000 or more at most collegiate aviation schools for a 4-
year degree and the flight training provided. The University Aviation
Association (UAA) indicated that there is no single comprehensive
information source regarding the cost of pilot training across the
United States, but AOPA officials told us costs vary between $40,000
and $100,000 for the training needed to obtain a commercial pilot
certificate and a multiengine rating. Furthermore, as previously
stated, pilots would likely be responsible for any increased costs if
additional training requirements were developed by FAA. The costs are
high compared to the low starting salaries. According to a 2009 survey
by the Regional Airline Association (RAA) of member airlines based on
2008 salary data, the salaries for regional pilots generally averaged
between $28,000 and $43,000 for regional airline first officers and
$62,000 to $102,000 for regional airline captains. RAA estimated that
salaries have increased 2 to 5 percent since but it does not have more
current data. Some stakeholders we interviewed said that these
realities could potentially prevent prospective students from
enrolling in a pilot school or reduce the desire to become a pilot.
However, it is important to note that the previously mentioned AOPA
study reported that training costs were not a statistically
significant reason individuals dropped out of training.
A range of tuition resources is available, but some of these sources
are drying up. To pay for pilot training, AOPA officials said that
students typically use personal funds, personal credit (credit cards
and personal loans), scholarships, grants, parent or student loans,
other educational loans, and the Veterans Administration's (VA)
Montgomery GI Bill benefits. For example, AOPA offers loans for pilot
training up to $25,000 and allows flexible funding options for
students since AOPA does not limit the use of funds to certain types
of schools or training. One benefit of collegiate schools and some
vocational schools is that they are generally eligible to receive VA
benefits and federal financial aid (such as federal education loans or
grants). However, flight instructor-based schools do not generally
qualify for federal financial aid or VA benefits. VA benefits allow a
qualified student to be reimbursed up to 60 percent for ground and
pilot training costs to the maximum allowable limit, but do not fund
training for a private pilot certificate. Many financial institutions
have provided financing for pilot training through educational loan
programs, such as the Federal Family Education Loan program, and
personal loans.[Footnote 71] According to literature we reviewed and
representatives of four pilot schools and three industry associations
we interviewed indicated that many of the private banks have been
tightening restrictions on financing available to potential new pilot
students, and others have left the pilot training loan market. The
National Association of Flight Instructors reported that Sallie Mae
took a $1 billion loss in 2009 for educational loans, which explains,
in part, the reason it has become increasingly difficult to obtain
funding.[Footnote 72] We reported in November 2009 that many lenders
offering student loans have exited the market in response to limited
access to capital resulting from the credit crisis.[Footnote 73] Thus,
lenders have begun to give pilot training a higher risk profile than
in the past and have been slowly exiting this loan market.
Recent Efforts to Improve Airline Safety and Pilot Training Could
Impact Pilot Availability:
Representatives of the regional airlines we interviewed and
stakeholder associations have voiced a significant level of concern
regarding the legislative mandate to increase the number of flight
hours needed for first officers to be hired by commercial airlines. As
discussed earlier in the report, the Airline Safety and Federal
Aviation Administration Extension Act requires that FAA develop
regulations requiring all airline pilots, including the first
officers, to hold an airline transport pilot certificate--the highest
level of pilot certification and requiring the highest number of total
flight hours--instead of the commercial pilot certificate that is
required today.[Footnote 74] Aviation stakeholders have voiced
significant concerns that requiring first officers for regional
airlines to possess an airline transport pilot certificate will likely
result in the inability to fill some positions due to the lack of
qualified pilots. The overall decreasing trends in pilot certificates
being issued is illustrated in table 4 with the general decline in the
number of airline transport pilot certifications issued from 1999
through 2009 from pilot schools operating under Part 61, Part 141, and
Part 142 regulations. The number of airline transport certificates
issued decreased about 60 percent.
Table 6: Airline Transport Pilot Certifications Issued from 1999
through 2009 from Pilot Schools Operating under Part 61, Part 141, and
Part 142:
Year: 1999;
Part 61: 6,666;
Part 141: 4;
Part 142: 503;
Total: 7,173.
Year: 2000;
Part 61: 6,652;
Part 141: 5;
Part 142: 1,039;
Total: 7,696.
Year: 2001;
Part 61: 5,735;
Part 141: 2;
Part 142: 957;
Total: 6,694.
Year: 2002;
Part 61: 3,670;
Part 141: 3;
Part 142: 904;
Total: 4,577.
Year: 2003;
Part 61: 3,087;
Part 141: 10;
Part 142: 844;
Total: 3,941.
Year: 2004;
Part 61: 3,490;
Part 141: 2;
Part 142: 987;
Total: 4,479.
Year: 2005;
Part 61: 3,579;
Part 141: 6;
Part 142: 1,130;
Total: 4,715.
Year: 2006;
Part 61: 3,542;
Part 141: 4;
Part 142: 1,191;
Total: 4,737.
Year: 2007;
Part 61: 4,873;
Part 141: 4;
Part 142: 1,123;
Total: 6,000.
Year: 2008;
Part 61: 3,845;
Part 141: 6;
Part 142: 1,022;
Total: 4,873.
Year: 2009;
Part 61: 2,078;
Part 141: 2;
Part 142: 815;
Total: 2,895.
Source: FAA.
Note: Training for the airline transport pilot certificate is
generally provided by pilot schools that train students under Part 61
and Part 142 regulations.
[End of table]
Aviation stakeholders such as AOPA and RAA have both also voiced
concerns that increasing pilot certification requirements to become an
airline pilot could significantly discourage potential pilots from
entering aviation due to the increased time and expense required to
meet the new hiring minimums of airlines. For example, regional
airline officials we interviewed said the new requirement will create
a gap in experience for new pilots seeking entry level airline jobs
that could take several years to fill. Furthermore, AOPA said the cost
of obtaining the additional 1,250 flight hours needed to meet the
total time for an airline transport pilot certificate could deter many
new pilots into pursuing other professional careers by increasing the
number of flight hours to obtain employment as an airline pilot.
Additionally, the 2011 ICAO report mentioned earlier stated that even
though the United States has sufficient training capacities, the
requirement that all commercial airlines' first officers have an
airline transport pilot certificate could drastically limit the
availability of first officers to support existing delivery schedules
for new aircraft at many airlines.
The majority of officials representing the regional airlines we
interviewed also indicated that the proposed FAA rules to revise pilot
duty and rest requirements will potentially create a need for more
pilots.[Footnote 75] Provisions in the Airline Safety and Federal
Aviation Administration Extension Act of 2010 directed FAA to issue a
regulation to specify limitations on the hours of pilot flight and
duty time to address problems relating to pilot fatigue.[Footnote 76]
NTSB has long been concerned about the possible safety effects of
fatigue in the aviation industry--specifically pilots--and have issued
several safety recommendations to FAA after identifying it as a
contributing factor in several aviation accidents. FAA identified the
issue of pilot fatigue as a top priority following the Colgan Air
crash, and the NTSB accident report stated the pilots' performance was
likely impaired because of fatigue, but the degree to which it
contributed could not be conclusively determined. The proposed changes
to the duty and rest requirements of pilots will likely mean airlines
need more pilots to comply with the new rules. The officials said the
industry will likely see a greater demand for these additional pilots
over the next few years, but this will depend on each airline's
staffing ratios for its aircraft and flight operations. However, the
general response was that the rule changes would require more
qualified pilots in order to maintain the same level of service.
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
GAO Contact:
Gerald L. Dillingham, Ph.D., (202) 512-2834 or dillinghamg@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, the following individuals made
important contributions to this report, Keith Cunningham, Assistant
Director; Richard Brown; Owen Bruce; Vashun Cole; Cindy Gilbert; Brian
Hackney; Bob Homan; David Hooper; Amber Keyser; Nitin Rao; Amy
Rosewarne; and Michael Silver.
[End of section]
Footnotes:
[1] Regional air carriers are airlines that generally operate aircraft
seating fewer than 90 passengers, and mainline carriers operate
aircraft seating 90 or more passengers.
[2] Regional Airline Association, 2010 Annual Report, September 2010.
[3] NTSB Aircraft Accident Report, 2010, Loss of Control on Approach,
Colgan Air, Inc., Operating as Continental Connection Flight 3407,
Bombardier DHC-8-400, N200WQ, Clarence Center, New York, February 12,
2009. NTSB/AAR-10/01. Washington, D.C.
[4] The U.S. Department of Transportation Office of Inspector General
is conducting an audit of FAA's oversight of air carrier pilot
training programs at the request of Congress.
[5] Pub. L. No. 111-216, 124 Stat. 2348 (2010).
[6] Federal aviation regulations are found under title 14 of the
United States Code of Federal Regulations. Part 135 of Title 14
prescribes rules governing the commuter or on-demand operations to
hold an air carrier certificate. Nonscheduled-service airlines are
generally issued a Part 135 certificate by FAA and operate aircraft
other than turbojet-powered airplanes having no more than nine
passenger seats and a payload capacity of 7,500 pounds or less. Part
121 prescribes rules governing the domestic, flag, and supplemental
operations to hold an air carrier certificate. Scheduled-service
airlines are generally issued a Part 121 certificate by FAA and
operate turbojet-powered airplanes or airplanes with more than nine
passenger seats or airplanes having a payload capacity of more than
7,500 pounds.
[7] Part 61 prescribes the minimum training, knowledge, and experience
requirements for acquiring a pilot certificate. Part 141 prescribes
the requirements for issuing pilot school certificates and the general
operating rules applicable to a holder of the certificate. Part 142
prescribes the requirements governing the certification and operation
of aviation training centers.
[8] 14 C.F.R. Part 61.
[9] The student pilot certificate is necessary to begin pilot training
to work toward a recreational, sport, or private pilot certificate
under the direct supervision of a flight instructor. The recreational
pilot certificate was introduced in 1989 and limits pilots to stay
within 50 nautical miles of their departure airport unless other
conditions are met. The sport pilot certificate was introduced in 2004
and allows pilots to fly smaller, light, less complex, one or two-seat
airplanes without the limitations of recreational pilots. The private
pilot certificate allows the pilot to fly solo and carry passengers in
any aircraft for which they are qualified, but not to fly for
compensation. The commercial pilot certificate allows a pilot to be
compensated for flying and to be hired for a variety of aviation jobs
(e.g., air ambulance, law enforcement, agricultural spraying,
corporate and charter flights, and banner towing), including first
officer positions with airlines. The airline transport pilot
certificate is the highest level of pilot certification, requires the
highest amount of cumulative flight time, and is necessary to qualify
as a captain for an airline.
[10] The holder of a valid flight instructor certificate may provide
pilot training and instruction for the pilot certification in any
aircraft for which they are qualified. (14 C.F.R. § 181).
[11] The DOT Office of Inspector General has initiated reviews related
to FAA's oversight of airline pilot training, pilot fatigue, and
professionalism issues, and whether there is a direct relationship
among commercial aviation accidents, pilot experience, and pilot
compensation.
[12] A rating defines the conditions or specific aircraft in which a
pilot certificate may be used. In addition, endorsements may be issued
by FAA to further define conditions or specific aircraft not covered
by ratings.
[13] Part 61 requires that pilots must be able to read, write, speak,
and understand the English language, or a pilot certificate cannot be
issued. Each pilot applicant must demonstrate an ability to mentally
grasp critical information that often must be read and understood
while conducting a variety of aviation operations.
[14] A pilot with a commercial pilot certificate can be employed to
tow banners and fly sightseeing operations or can be employed as a
first officer for a regional airline.
[15] In commercial aviation, the pilot in command (captain) of an
aircraft is the person aboard the aircraft who is ultimately
responsible for its operation and safety during all phases of flight,
as well as when it is operating or moving on the ground, in accordance
with FAA's rules of the air. The second-in-command (first officer) is
the second pilot of an aircraft, and has the authority to assume
command of the aircraft in the event of incapacitation of the captain.
However, control of the aircraft is normally shared equally between
the captain and first officer during flight.
[16] To be eligible for a student pilot certificate, an applicant must
be at least 16 years of age and hold at least a third-class medical
certificate. Student pilots are generally not allowed to operate an
aircraft in solo flight unless certain FAA requirements are met.
[17] FAA appoints individuals as designated pilot examiners to conduct
various pilot certification-related activities on behalf of FAA.
[18] Required inspections are identified by FAA's national office as
the mandatory core inspections necessary for FAA to fulfill its
statutory and regulatory oversight responsibilities. Accomplishment of
these inspections is essential to provide reasonable assurance of
continued compliance with regulations, standards, and safe operating
practices. Planned inspections are identified at the regional and
district levels and are comprehensive targeted inspections. They make
up the depth and substance of each office's annual work program and
FAA district offices tailor them to the changing local aviation
environment.
[19] PTRS was implemented in 1990 and is one of FAA's data management
and analysis systems used, among other things, to record inspections
of flight instructors, pilot schools, pilot examiners, and other job
functions.
[20] EIS is the primary internal tool for FAA in initiating
enforcement actions and for tracking of enforcement and compliance
cases and their outcomes.
[21] ICAO members, including the United States, are not legally bound
to act in accordance with ICAO standards and recommended practices.
However, if members decide to deviate from some of the ICAO standards
and recommended practices, they are obligated to notify ICAO of
differences. ICAO is a sovereign body, consisting of 190 members. Each
member is entitled to one vote, and decisions are determined by
majority vote.
[22] In August 2011, FAA issued a rule that, among other things, will
allow vocational pilot schools to use internet-based training programs
without requiring the schools to have a physical ground training
facility. The rule will become effective October 31, 2011. 76 Fed.
Reg. 54095 (August 31, 2011).
[23] 14 C.F.R. § 141.55.
[24] Training under Part 61 regulations for the private and commercial
pilot certificates can accomplish the ground school training
requirements through instruction from a flight instructor or through
an approved home-study course.
[25] For the airline transport pilot certificate, the same number of
total hours is required whether pilot training is being conducted
under Part 61 or Part 141 regulations.
[26] Additionally, the Transportation Security Administration requires
pilot schools to verify a student's proof of U.S. citizenship.
[27] Institutional accreditors review and accredit entire educational
institutions. Program accreditors review and accredit specific
programs or subject area offerings within an educational institution,
such as the Aviation Accreditation Board International (AABI). AABI is
an independent body that advances aviation education through
accreditation and is the only program accreditor for collegiate, non-
engineering aviation education for both 2-year and 4-year programs.
[28] The Flight School Association of North America is a membership-
based association that represents pilot schools and firms that provide
products or services to the pilot training or aviation industry.
[29] Some vocational and collegiate aviation schools with a Part 141
certificate are granted examining authority by FAA, as a privilege of
their Part 141 certificate, which allows them to recommend their
graduates for some of the initial pilot certificates and ratings
(except flight instructor certificates, airline transport pilot
certificates and ratings, and jet type ratings) without the pilot
candidates having to take the FAA knowledge or practical tests or both.
[30] NASA, "FAA Pilot Knowledge Tests: Learning or Rote Memorization?"
Ames Research Center, Moffett Field, California, January 2004.
[31] FAA, International Journal of Applied Aviation Studies, Pilot
Source Study: An Analysis of Pilot Backgrounds and Subsequent Success
in US Regional Airline Training Programs (Oklahoma City: August 2010).
The study was conducted by a consortium of aviation university
researchers in response to FAA's Advance Notice of Proposed Rulemaking
for soliciting comments and recommendations on whether FAA should
consider crediting specific academic study in lieu of flight hour
requirements. 75 Fed. Reg. 6164 (Feb. 8, 2010). FAA was subsequently
required by law to consider allowing specific academic training
courses to count toward the 1,500 flight hour requirement. Pub. L. No.
111-216, § 217(d), 124 Stat. 2348, 2368 (2010).
[32] The Regional Airline Association, founded in 1975, represents
regional airlines and provides technical, educational, and promotional
support to the 32 members and their supply company partners.
[33] U.S. mainline airlines generally require pilot candidates to have
a college degree, but not necessarily an aviation-related degree.
[34] In practice, regional airlines do typically require newly hired
first officers to have a certain level of experience above the
regulatory flight hour minimums required to obtain a commercial pilot
certificate, typically hiring pilots that have spent several years
working up through commercial non-airline jobs, i.e., on-demand and
cargo operations. However, the extent that they do this may vary based
on the cyclical dynamics of the supply of and demand for pilots.
[35] A flight engineer is the third crewmember on an aircraft that
requires a three-person flight crew, but this position is seen less
often as airlines replace older planes with newer aircraft that
require only two-person crews.
[36] According to literature we reviewed, scenario-based training uses
real-world situation that introduces situations and circumstances that
pilots face in routine flight operations as learning experiences. This
training method emphasizes the development of critical thinking and
flight management skills, rather than solely on traditional maneuvers-
based training skills. Maneuvers-based training emphasizes the mastery
of individual tasks or elements, such as the development of competency
and motor skills to satisfactorily accomplish individual piloting
maneuvers.
[37] The FAA Industry Training Standards program (referred to as FITS)
is a partnership between FAA, industry, and academia to create
scenario-based training materials to help pilot schools train pilots
for practical application of knowledge and skills of technically-
advanced aircraft. The FITS commercial pilot syllabus, developed in
2007, is the accepted training method to use in developing a specific
FITS curriculum.
[38] However, recent concerns have been raised by industry
stakeholders that federal regulations and airline operating procedures
require airline pilots to have a greater reliance on the computerized
flight management and automation of today's aircraft. As a result, the
implications of decreased opportunities for pilots to manually fly an
aircraft could potentially result in an increase in accidents and
incidents for pilots who are suddenly confronted with a loss of
computerized controls or emergency situations but unprepared to
respond immediately or make errors in doing so.
[39] Advanced jet training is designed to give instruction in airline
flight crew operations in a multiengine aircraft, emphasizing the
transition of the professionally qualified pilot to a highly skilled
member of an airline flight management team. Course topics include
crew resource management, flight crew training techniques, high speed
and high altitude programming of automatic flight control systems,
transport aircraft flight techniques, turbojet operations in all
flight regimes and in difficult operating conditions, and use of
advanced avionics.
[40] Aircraft upset is a dangerous condition that occurs when an
airplane encounters an unexpected event that threatens loss of control
of the aircraft and may result in an accident. Upset recovery training
aims at improving a pilot's ability to maneuver and recover an actual
airplane from a serious upset to a normal operating condition.
[41] Crew (or cockpit) resource management training is designed to
improve pilots' team management, situational awareness,
communications, task allocation, and decision-making skills in an
airline crew environment.
[42] Pub. L. No. 111-216, §217 (c) (1), 124 Stat. 2348, 2368 (2010).
[43] 14 C.F.R. § 61.129(b).
[44] Pub. L. No. 111-216, §217(c)(1),124 Stat. 2348,2368 (2010).
[45] Pub. L. No. 111-216, §217(f), 124 Stat. 2348, 2368 (2010).
[46] FAA, The First Officer Qualifications Aviation Rulemaking
Committee Report: Recommendations Regarding Rulemaking on Flight
Experience, Training, and Academic Requirements Prior to Operating as
a First Officer in Part 121 Air Carrier Operations, September 10,
2010. The committee was composed of representatives of AABI, ALPA, Air
Transport Association, AOPA, Coalition of Airline Pilots Associations,
National Air Disaster Alliance-Foundation, National Business Aviation
Association, Pilot Career Initiative, Regional Air Cargo Carriers
Association, and RAA.
[47] CAPA is a trade association, established in 1997, comprised of
over 28,000 professional pilots to address safety, security,
legislative and regulatory issues affecting the individual member
unions. The National Air Disaster Alliance-Foundation was founded by
air crash survivors and victims' family members in 1995, to raise the
standard of safety, security, and survivability for aviation
passengers, and to support victims' families.
[48] A bridge agreement is a formal signed document between an
aviation program and a regional airline that generally reduces the
minimum flight time experience required by the airline for students to
be considered for hire. Typical conditions of the agreement stipulate
a specific grade point average, minimum number of flight hours, and
other desirable academic qualifications for the students.
[49] Renewal of a flight instructor certificate can be completed in
three ways: (1) passing a practical test for renewal of the flight
instructor certificate, (2) meeting required FAA minimum of flight
activity conducted as an instructor, or (3) completing a flight
instructor refresher course consisting of ground training or flight
training or both.
[50] Runway incursions, which are precursors to aviation accidents,
are instances where collisions are narrowly avoided on an airport's
runways or taxiways. For more information on runway incursions, see
GAO, Aviation Safety: FAA Has Increased Efforts to Address Runway
Incursions, [hyperlink, http://www.gao.gov/products/GAO-08-1169T]
(Washington, D.C.: September 2008).
[51] UAA is the representative voice of college aviation education to
the aviation industry, government agencies, and the general public.
[52] 76 Fed. Reg. 29336 (May 20, 2011). The original notice of
proposed rulemaking was published in January 2009. 74 Fed. Reg. 1280
(Jan. 12, 2009).
[53] Pub. L. No. 111-216, § 208, 124 Stat. 2348, 2360 (2010).
[54] Flight Safety International is a global professional aviation
training company that operates the world's largest fleet of advanced
full flight simulators and supplier of flight simulators, visual
systems, and displays.
[55] EASA is the European aviation regulatory authority and FAA
counterpart. EASA became operational in September 2003 on the basis of
European Parliament and Council regulation 1592/2002. The agency is an
independent European Union body under European law accountable to the
Member States and the European Union institutions. In February 2008,
Regulation 216/2008 was passed repealing Regulation 1592/2002 and
included the scope of oversight for flight crew licensing.
[56] Ab initio is a Latin term meaning "from the beginning." Ab initio
pilot training programs trains students with little to no pilot
experience to become commercial airline pilots through a continuous
training program.
[57] Approved flight training organizations are required to meet
certain qualifying standards of personnel licensing.
[58] Competency-based training and assessment is defined as
performance orientation with an emphasis on standards of performance
and their measurement, and the development of training to the
specified performance standards.
[59] In November 2006, ICAO enabled the implementation for the multi-
crew pilot license by amending ICAO personnel licensing standards to
include a new pilot certificate and adopting new standards for this ab
initio airline pilot training method.
[60] A ramp check for a pilot school with a 141 certificate typically
involves an inspection of the paperwork and exterior of the aircraft
used by the school for training to ensure each meets all regulatory
requirements. FAA inspectors conduct various types of ramp checks to
ensure that aviation activities are being conducted safely and in
compliance with the Federal Aviation Regulations.
[61] FAA uses a broad pool of designated personnel nationwide to act
as representatives of the agency to conduct many safety certification
activities, such as administering practical tests to pilots and many
other activities.
[62] Part 61 provides the regulatory basis for the conduct of
practical tests for pilot certification. Section 183.23 of title 14
(subpart C) provides the regulatory basis for the designation of pilot
examiners. FAA Order 8900.2 contains procedures for the selection,
appointment, oversight, training, renewal, termination, and appeal of
designees.
[63] High activity pilot examiners are defined as conducting 50 or
more practical tests per quarter.
[64] These circumstances may include a designee: (1) who does not
comply with the applicable certification policies; (2) whose
certification passing rate is excessively high; (3) who exceeds the
allowable amount of certification activity on a given day; (4) who
conducts any certification activity that requires prior permission
from the managing FAA office without obtaining that permission in
advance; (5) whose certification file error rate is excessively high;
(6) who is the subject of a valid public complaint; or (7) who has
been involved in an accident, incident, or violation of federal
aviation regulations.
[65] Low-activity pilot examiners were those with seven or less
activities between the third quarter of 2010 and the second quarter of
2011.
[66] SPAS relies on over 25 databases within FAA and other government
agencies, including PTRS, EIS, and the Vital Information Subsystem,
which maintains a current list and the status of pilot school
certificates.
[67] The Aircraft Owners and Pilots Association is the largest not-for-
profit general aviation association in the world and serves more than
415,000 members.
[68] Pub. L. No. 110-135, §2, 121 Stat. 1450 (2010).
[69] In August 2009, FAA issued a final rule that increased the
duration of validity for student pilot certificates for pilots under
the age of 40 from 36 to 60 months. 74 Fed. Reg. 42500 (Aug. 21,
2009). This resulted in the increase in active student pilots to
119,119 from 72,280 at the end of 2009.
[70] AOPA, The Flight Training Experience: A Survey of Students,
Pilots, and Instructors, October 2010.
[71] The Federal Family Education Loan program allowed private
financial institutions to provide students with loans, but the federal
government assumed the risk of default, and paid the financial fees
while the student attended college. As of July 2010, federal education
loans are now made directly by the U.S. Department of Education under
the Federal Direct Loan Program.
[72] Sallie Mae is the largest servicer of federally guaranteed
student loans and the largest originator and servicer of private
student loans.
[73] GAO, Higher Education: Factors Lenders Consider in Making Lending
Decisions for Private Education Loans, [hyperlink,
http://www.gao.gov/products/GAO-10-86R] (Washington, D.C.: November
2009).
[74] Pub. L. No. 111-216, §217(a), 124 Stat. 2348, 2367.
[75] 75 Fed. Reg. 55852 (Sept. 14, 2010). FAA's proposed rule (1) sets
a 9-hour minimum for rest prior to flying-related duty (a 1-hour
increase over the current rules), (2) establishes a new method for
calculating a pilot's weekly, monthly, and yearly flight time limits
so that pilots can receive at least 8 hours of sleep during that rest
period, and (3) sets a daily flight duty period to 13-hours (currently
it is a 16-hour duty period between rest periods).
[76] Pub. L. No. 111-216, §212, 124 Stat. 2348, 2362.
[End of section]
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