Washington, D.C. - (August 15, 2013). Greetings from Capitol Hill! As pilots, we’ve seen enormous change in the airline industry over the past decade. We’ve witnessed airline bankruptcies and consolidations, resulting in the loss of pilot jobs and pensions. On a daily basis, we deal with issues affecting safety and security in both the international and domestic arenas.
As a trade association, we cover industry-wide and carrier-specific issues, and represent over 25,000 professional pilots at the Allied Pilots Association (American Airlines), Independent Pilots Association (UPS Airlines), US Airline Pilots Association (US Airways), Teamsters Union Local 1224 (ABX Air, Horizon Airlines, Atlas Air, Allegiant Air, Kalitta Air, Miami Air, Silver Airways, Cape Air, Omni Air, Southern Air) and our newest member Teamsters Union Local 357 (Republic Airlines, Frontier Airlines, Shuttle America, Chautauqua Airlines).
CAPA is not a union. CAPA's mission is to address safety, security, legislative and regulatory issues as a trade association affecting its professional flight deck crew members on matters of common interest, and is bound by the collective will of its' individual member unions.
Our member associations firmly believe a unified voice is critically important as it provides the greatest benefit to the pilots we represent, the crew members with whom we serve and the passengers and cargo that we have been entrusted with. It is only through a collective effort that we are able to accomplish this.
We remain firmly committed to aggressively pursuing all matters of mutual member concern. We have a diverse group of professional pilots who serve as subject matter experts on numerous Aviation Rulemaking Committees (ARCs), Aviation Security Advisory Committees (ASAC) in addition to representing our pilots on Capitol Hill. Our profession is under constant attack; in response, we have an incredibly dedicated Board of Directors, Officers, Committee members and professional staff constantly working on your behalf.
We are a key industry stakeholder and have a long history of supporting the highest level of safety and security. As professionals, we simply can never stop in our efforts to ensure the highest standards are upheld. We remain ever vigilant to protect the programs that ensure the safety and security of our profession and that of the traveling public.
Thank you for your comments and responses to our advocacy "CapWiz" efforts over the past several months. We appreciate your continued support and efforts with the tens of thousands of messages that have been delivered to Congress. Rest assured, your voice is being heard on Capitol Hill.
To ensure that your voice is heard, we participate in high-level meetings with the FAA and TSA Administrators as well as their senior staff. The focus is to share the perspective that CAPA brings to the table as a trade association. In addition, we have a well-respected history of actively engaging senior leaders of Congress. We continue to work tirelessly to ensure all branches of government and global industry stakeholders are fully educated as to CAPA's position on the myriad of covered issues impacting the industry.
First Officer Qualifications: The FAA recently announced the First Officer Qualification (FOQ) regulations. We have long advocated that the Airline Transport Pilot (ATP) license must serve as the minimum qualification standard for all Code of Federal Regulations (CFR) Part 121 pilots. The new requirements will greatly increase Part 121 airline pilot qualifications and are a significant improvement in providing "One Level of Safety" for the traveling public.
During the summer of 2010, we participated in an FAA Aviation Rulemaking Committee (ARC) to help create new standards for First Officers flying for Part 121 carriers. We strongly believe that in order to safely operate aircraft today's complex, high-speed aircraft through a congested, multi-faceted air traffic control network in difficult weather environments, both pilots must be highly qualified.
We recommended that the new requirements include the Air Transport Pilot (ATP) rating, in addition to aircraft-specific type ratings. These requirements combined with a curriculum of aeronautical knowledge and flight training, and a specific amount of flight experience will provide for better qualified professional aviators. As professional airline pilots and experts in the field we believe that the requirement to possess an ATP is a definable common-sense standard and prerequisite experience requirement for all pilots who shoulder the responsibility of safely transporting the traveling public in our air transportation system.
The FAA has greatly enhanced the safety of the traveling public with these new regulations. We applaud their efforts by recognizing the value of experienced and well-trained crews in U.S. commercial airline cockpits. Also, we would like to recognize the tireless efforts by all CAPA representatives whose considerable contributions over the years have served to make these new regulations a reality.
In discussions with our member associations, we can confirm that there is no shortage of applicants for carriers that offer adequately compensated positions with inviting and rational career paths. Carriers that don’t, face new-hire classes with few prospects to fulfill their hiring needs.
Abu Dhabi Pre-Clearance Facility: We strongly oppose the Department of Homeland Security's (DHS) efforts to establish a U.S. Customs and Border Protection (CBP) facility at the Abu Dhabi International Airport. As a result of sequestration, we are seeing budget cuts and furloughs resulting in security programs being cut or completely eliminated in the United States while the DHS proposes to establish a preclearance facility in a the United Arab Emirates (UAE). If allowed to proceed, this would result in providing a DHS-sanctioned competitive advantage to a wealthy (state-backed) foreign airline. As such, we believe this decision must be stopped.
While we understand the need to alleviate an already congested air travel industry, the misguided use of taxpayer dollars for overseas facilities is deeply concerning. Unless safeguards are put in place when these agreements are negotiated, foreign airlines will be given a significant competitive advantage over their US counterparts.
Additionally, U.S. carriers will be forever barred in their ability compete on a level playing field in the global marketplace. This plan represents a real threat to aviation and sets a disturbing precedent for national security. All incoming flights to the U.S. will be treated as "pre-cleared" and will not be subject to additional security upon arrival. Removing important layers of protection would place the safety and security of the traveling public at risk.
The DHS must adequately support the U.S. aviation system and its carriers before the use of overseas facilities is expanded. We must fix the problem in our domestic aviation system by addressing the misallocation of fees that are not being properly used for aviation services. We are working with Congress and Administration officials to resolve these critical issues.
Trans-Atlantic Trade and Investment Partnership (TTIP) & International Trade Talks: We attended the role out of the TTIP talks. We reiterated our position that commercial airline traffic, citizenship, ownership and control issues belong in the regular talks currently taking place under the guidance of the Department of Transportation and the State Department. Furthermore, those issues should not be viewed as bargaining chips in any broader context negotiations (omnibus). The aviation industry traditionally has not been a part of trade negotiations. We support and contribute an effort to maintain this separation between Trade and Aviation Treaties/Agreements.
Immigration Reform Legislation: Proposed language in the Immigration Reform bill does not define the piloting profession in FAA terms, and does not make it clear that to be an airman in the employ of an FAR Part 121 or Part 135 air carrier requires "considerable preparation" and should be considered a Zone 4 occupation. We continue the effort on Capitol Hill working with members of Congress to clarify the language as it relates to the pilot profession, so as to preclude Part 121 and/or Part 135 air carriers from having access to the H1B Visa Program.
ICAO/LOCART ARC: We are participating in the ground-breaking "Loss of Control Avoidance and Recovery Training (LOCART)" aviation rulemaking committee convened by the FAA in concert with ICAO and industry participants to develop a training manual. This work is described by ICAO as: "ICAO collaborated with numerous state and industry partners to develop a training manual on Upset Avoidance and Recovery. The manual will be finalized during 2013 and is also intended to support implementation of new ICAO Standards for upset and recovery training to be proposed by the end of 2013. ICAO and its partners are also actively examining the human performance issues that are associated with this type of accident. The manual on Upset Avoidance and Recovery will be enriched with additional guidance once these materials are available." We believe the potential benefits for the pilot profession cannot be overstated, as they will help provide an enhanced skill set to effectively deal with what could otherwise be a catastrophic event.
Flight Time/Duty Time (Cargo Carve-Out and "One Level of Safety"): We have long-advocated for "One Level of Safety" for both passenger and cargo operations. Our objection to the FAA "carving out" cargo carriers from the new Flight Time/Duty Time requirements has been emphasized to lawmakers. Both cargo and passenger airlines share the same airspace, and fatigue can have devastating effects on the performance of a pilot regardless of the carriage. Our efforts continue to solicit additional sponsors to legislate against the exclusion of the Cargo industry from the long sought improvements to Flight Time/Duty Time regulations contained in CFR 117.
TSA's Aviation Security Advisory Committee: Over the past two years, we have served as vice-chair of the TSA's "Aviation Security Advisory Committee" (ASAC). Our CAPA Security Chairman has served as our representative and continues to be a strong voice for our pilots on these issues. This is significant because it is the first time a pilot group has served as vice-chair on this committee. Crew members are a critical component to aviation security and, as trusted partners to the TSA, should be involved in the decision-making process.
TSA & the Prohibited Items List: As a key industry stakeholder, we have played an active role in advocating for maintaining the Prohibited Items List, "as is". We objected to the TSA's decision without first consulting the ASAC. We are pleased the TSA has reaffirmed its commitment through this recent decision to maintain the prohibition on small knives and other potentially dangerous items. We would like to thank the TSA for re-evaluating their decision based on stakeholder and congressional input.
Federal Flight Deck Officer (FFDO) Program Funding: The Senate Appropriations Committee recently approved $25 million in funding for the Federal Flight Deck Officer (FFDO) program for FY2014. With the House of Representatives having approved funding earlier this year, we take pride in the ability of our committees, along with our numerous supporters and allies to promote this effort on Capitol Hill.
We worked hard to restore funding to this critical security program after the proposed budget indicated the FFDO program would receive no funding for FY2014. In conjunction with the National Association of Police Organizations (NAPO) and the Federal Flight Deck Officers Association (FFDOA), we took our message to Congress and re-emphasized that the FFDO program is one the most cost-effective aviation security programs available.
Our FFDOs represent the last line of defense for the security of the flying public and many members of Congress agreed. We believe the FFDO program is already underfunded and should be strengthened. In addition, we are pleased Congress has recognized the value of this program by maintaining level funding during sequestration. We would like to express our gratitude to the many Senators and Congressman who have long supported the FFDO program.
Jumpseat/International CASS: The TSA has conceptually approved the International Cockpit Access Security System (ICASS) for a number of years. We are in discussions with stakeholders to proceed with the initial implementation of this initiative. Additionally, we are promoting the implementation of international jumpseat procedures amongst all member and non-member airlines, and are encouraging airlines to participate to the maximum extent possible. As these initial phases are rolled out, we intend to keep our members informed through further updates.
Lithium Batteries: Lithium batteries are a known safety hazard and have been banned on both domestic and foreign passenger aircraft since 2004. However, no such restrictions exist for the nation's all-cargo carriers. The advancement of battery technology has outpaced existing procedures and regulations regarding the safe shipping of these products by any air carrier.
Recently, the General Civil Aviation Authority (GCAA) of the UAE issued a final report on the tragic crash of UPS Flight 6 which highlighted the risks of lithium batteries. In addition, the FAA's recent and sobering safety analysis predicts that approximately six aircraft accidents are likely to occur on U.S. domestic freighters between now and 2021. We fully support continued efforts for well-defined regulations regarding quantities of lithium batteries that can be transported, as well as, where and how they are packaged and carried on board the aircraft.
FAA ARC-Passenger Notification of Hazardous Materials Regulations: We have been invited to participate on the FAA's "Passenger Notification of Hazardous Materials" ARC. The purpose of this ARC is to develop recommendations on the hazardous material notifications conveyed to passengers at the point of check-in or ticket purchase, and the format in which they will be conveyed across the airline industry. This ARC is expected to run through November 2013.
Sequestration & Air Traffic Controller Staffing: We joined other pilot groups and airlines in a strong message to Congress and the Administration that the furlough of thousands of air traffic controllers was unacceptable. We are pleased that the FAA has provided the necessary funding that has temporarily prevented a potential crippling disaster to our nation’s airspace and are hopeful Congress will reaffirm its commitment to maintain adequate funding for the nation's Air Traffic Control System.
We are committed to keeping you informed as events dictate a vigorous response from your trade association. Additionally, we will continue to solicit your support through our advocacy efforts directed at our nations’ regulators and Congress.
In closing, we believe a collaborative approach that provides Congress with stakeholder input is crucial in maintaining the standard the traveling public expects, the aviation industry deserves and our members demand.
Please continue to visit the CAPA website, for updates and information from your CAPA Headquarters in Washington, D.C.
First Officer Mike Karn, President
Captain Larry Rooney, Executive Vice President
Captain Mark Niles, Vice President
Maryanne DeMarco, Executive Director
Posted on Thu, August 15, 2013