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Comment from John R
1.All Part 141 flight schools are certified under and by the same set of regulations and standards. Lift (and RAH) are no different in this regard. They may choose to increase the standards, TCO requirements, or instructional methods as they see fit, however they are not required to. What is to stop them from obtaining an exemption with the vague and overly rosy image of a “greater than thou” program, and they slowly erode those “high” standards back to the legal minimum? Nothing. Part 141 and Part 61 do not provide for an enforcement mechanism against a school lowering a standard or expectation unless it is below the FAA published requirements.
2.The 1500 hour rule has unequivocally contributed to the greatest streak in aviation safety the United States has ever seen. Part of that reason is due to the higher level of experience required of new first officers, however another part of that equation has been the affect it has had on the improvement of the profession. Increased experience requirements meant that airlines had to become more aggressive with how they paid and compensated pilots, and consequently had an increase in the quality of life most pilots now enjoy. Any rollback from Republic to this minimum is almost certainly tied directly to their desire to create more pilots without improving pay and QOL to improve recruitment. It is no surprise that this request comes in the middle of a contract negotiation cycle with their current pilot group. Do not be fooled by their desire to “make aviation more accessible”. This is quite simply born of a desire to protect the bottom line.
3.The premise espoused in the Flying Magazine article is laughable “The airline notes that the high cost of training has caused 40 percent of students in its LIFT Academy to withdraw altogether while trying to satisfy the minimums in place today. In its proposition, the cost of the Republic R-ATP Program would include all training costs required to become a Republic pilot, though there are some caveats for when they would be eligible for that.”. Most 141 programs are complete in under 250 hours. That means the remaining 1250 hours to reach 1500 is almost always obtained while working as a flight instructor, cargo pilot, charter pilot, banner tower, crop duster, sight seeing pilot, or surveyor.
4.A 750 hour exemption request is insulting at best to military pilots that go through extensive physical and psychological screening followed by years of training. The assumption that a low time CFI can provide the same level of training as a military flight officer is so beyond the pale of reasonableness that its not worth arguing.
5.An attempt to receive a 750 hour exemption (or even 1000 hour) means that they believe that their program is of a higher caliber than a college education at any of the aviation universities. If the FAA grants this exemption they will tacitly acknowledge that these colleges provide little to no value over the course of a 2 or 4 year education and hundreds of hours of college credit. I believe that they are attempting to obtain a 750 hour exemption in the hopes that the FAA will grant them a compromise at a 1000. Do not be tricked by this play. Lift and RAH have not, and will likely never undergo any collegiate accreditation. Nor will they be subject to Title 9 or any other Federal protections granted to students of higher education.
6.If RAH believes that lowering the total to 750 hours will improve access to disenfranchised individuals, what is preventing them from doing this now? How will this help? Given that the limit exists to prevent fully certified pilots from getting hired at a 121 carrier sooner than 1500 hours (or as currently exempt), how would this help more minorities and women become pilots? I have over 2000 hours of dual given and can tell you without a shadow of a doubt that it made me a better regional FO, regional captain, and mainline FO. Every captain is an instructor or teacher whether they like it or not. 12 months or less of extra flying time is all it takes to get from 750 hours to 1500 hours. RAH cannot logically make the argument that 12 extra months of paid instructing makes the career field narrower for any individual. And if they truly wanted to expand access, they would have to do so at the ab initio level by providing free or discounted tuition to those in need.
7.Finally, the last point. There are over 600 Part 141 flight schools in the United States. If this exemption (or any reduction) is granted to them, it will be an immediate signal that the 1500 hour rules, and all the gains it has brought with it, are up for grabs. Every school will begin to draft courses and lessons they say “are in excess of what is required” either out of a desire to be more competitive, or out of necessary to compete with Lift. There will be a precedent set, and there will be no going back.
Comment Date:2022-05-16T04:00:00Z
Comment On Document ID:FAA-2022-0535-0009
Open regulations.gov Docket Folder
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