June 6, 2007

Good morning and thank you for inviting ALPA to testify before this subcommittee. For 76 years, ALPA has beaten the drum to improve safety in the airline industry. Some even call us the “conscience of the industry.” This morning, our voice will speak clearly.

Let me begin by saying that ALPA agrees with the NTSB that a pressing need exists to provide rational, scientifically based working hour limits for pilots engaged in all airline operations. In this post-9/11 bankruptcy era, pilots are flying to the FAA maximum flight- and duty-time limits and are barely meeting minimum rest requirements. Simply put, pilots are tired.

One reason we’re tired is because we’re working under antiquated federal regulations developed when airliners couldn’t fly across more than a few time zones. Boeing developed the first widely used jet airliner in the late 1950s. It had a range of about 4,200 miles.

Today, however, airliners can cover 12 to 14 time zones, for more than 16 hours of continuous flight, easily traveling more than 9,000 miles. And so-called regional jets fly coast to coast. This different world requires different rules. Unfortunately, current FAA rules do not adequately address fatigue research, circadian rhythms, and realistic sleep and rest requirements. The lack of a defined duty limit in the regulations illustrates our concerns perfectly.

One airline management team tells its pilots to fly from the East Coast to Asia, a 16-hour flight and then to fly the 16-hour trip back, with no rest on the ground. Legal? Yes. Safe? I’ll let you decide.

Federal regulations require airline pilots to receive 8 hours off between flying. This does not equal rest. By the time a pilot finishes up paperwork, catches the airport shuttle, checks into the hotel, and grabs a bite to eat, and then showers, dresses, and leaves in time to get through security the next day, he or she is lucky to get 5 hours to sleep. That leads to a massive sleep deficit and chronic fatigue. ALPA strongly urges you to push the FAA to modernize flight- and duty-time regulations and rest requirements for the safety of the traveling public.

Why is this happening now? Until the bankruptcy era of airlines, pilots were able to negotiate better safety rules as part of our contracts. But to save the airlines, we had to swallow major concessions on contracts and are now forced to fly to the FAR minimums.

Changing gears, I’d like to remind you that the ultimate safety net in our industry is the front-line employee. That’s why ALPA believes that the Aviation Safety Action Program (or ASAP) should be high on the NTSB’s “Most Wanted” list. It allows front-line employees to report safety concerns firsthand, without fear of management, enabling the airline industry to ensure safety while protecting those employees.

We consider ASAP and its partner program FOQA, which collects and analyzes flight data indicating potential risk, standard-issue, must-have items for airline safety. Recently, ALPA’s air safety representatives met with senior FAA officials and developed new language that would improve these programs and encourage creation of additional ASAP programs at more airlines.

As of May 30, 2007, 27 ALPA-represented pilot groups had ASAP. Six U.S. ALPA-represented pilot groups do not have ASAP—and that’s six too many. It’s time to implement both of these programs at every airline. These safety programs are the building blocks of Safety Management Systems. Accident prevention must take priority.

One more issue belongs on the NTSB list. How many of you have ever handed over your unaccompanied grandchildren to an airline or watched your spouse and kids board after you have dropped them off, trusting that they would arrive safely at camp, your parents’ house, or some other destination?

That’s an incredible act of trust: handing over your loved ones to total strangers—who will then take them in a narrow aluminum tube at 30,000 feet for thousands of miles—trusting that they will arrive safe and sound, every time. That level of safety depends on quality pilot training.

When Continental Airlines hired me as a pilot, I had to have 2,500 hours of flight time—hands-on experience. The captain beside me probably had at least 10,000 hours. It took years of flying as a flight engineer, and then first officer, before upgrading finally to captain. Traditional military training programs required several hundred hours of flight time, basic and in advance of airplane trainers, and cost millions of dollars. This pilot supply pipeline is now ancient history.

At some regional airlines, pilots need as few as 200 hours of flight time, the very minimum to obtain a commercial pilot license, to land a job in the right seat of a fast-moving, demanding jet. Increasingly, some pilots are logging their required flight hours in simulators. These pilots, who may become captains of 50-, 70-, or 90-passenger jets in little more than a year, are likely to be bright and talented, but that’s no substitute for experienced, seasoned pilots. Yet under the current training programs, these pilots receive the same training as a pilot hired with thousands of flight hours. This definitely raises safety concerns.

In November 2006, ICAO created a new grade of pilot certificate called the multicrew pilot license, or MPL. This certificate is designed to shorten the time required to train a pilot through extensive use of simulators and very little actual time in an aircraft. It was prompted by pilot shortages, most notably in India and China.

While the FAA hasn’t indicated that it plans to adopt MPL, ALPA warns Congress that this type of training creates pilots who get their experience almost entirely through on-the-job training—with the lives of passengers in their hands. Consider this: The MPL pilot would be certificated to fly as a first officer, second in command, in a passenger-carrying jet airliner, but would not be licensed to fly solo in a Piper Cub at your local airpark.

In a speech FAA Administrator Marion Blakey delivered at the National Press Club, she said, “Experience counts, it’s an added margin of safety, and at the end of the day, that is what counts,” and ALPA agrees. Experience costs a lot, but it costs less than a lack of experience. The traveling public trusts pilots with their lives. As professional aviators who help keep this industry safe, together with the strong support of Congress, we are confident of success—success that is vital to our nation, our industry, and our passengers.

Thank you.