HAI Comments On FAA’s NPRM For Pilot Certification For Powered-Lift Aircraft

HAI Comments On FAA’s NPRM For Pilot Certification For Powered-Lift Aircraft

22-Aug-2023 Source: HAI

Helicopter Association International (HAI) has weighed in on FAA efforts to regulate pilot certification and training for powered-lift aircraft. To view HAI’s comments to the FAA, click here.

Powered-lift aircraft take off and land vertically, then transition to fixed-wing lift for forward flight. This technology is one of many steps toward further adoption of advanced air mobility (AAM) aircraft. 

“This proposal could be very impactful for our industry pilots, since it establishes standards for training and certificating pilots to operate aircraft that are still in development,” says Zac Noble, HAI’s director of flight operations and maintenance, and lead on this project. “We appreciate the FAA’s efforts to address the upcoming changes in powered-lift aviation, as well as the opportunity to provide our input on their draft document.” 

HAI worked with its internal working groups, companies developing AAM aircraft, and other trade associations such as the Air Line Pilots Association (ALPA), General Aviation Manufacturers Association (GAMA), and National Business Aviation Association (NBAA) to develop the response.  

HAI’s response to the FAA’s Notice of Proposed Rulemaking (NPRM) to create a Special Federal Aviation Regulation (SFAR) centered around several key items: 

  • Pilot certification: The NPRM suggests a temporary SFAR to gather information for future rulemaking. That SFAR will require each individual powered-lift aircraft to have its own specific type rating. As HAI states in its response, “[t]here is no doubt that many AAM aircraft will not need type ratings to be operated safely. Adding type ratings for those aircraft that are “so refined that improper or inept handling is likely to be immediately critical will be easier and more cost-effective than removing type ratings already issued.” 
  • Training aircraft: The FAA suggests a need for OEMs to build dual seat aircraft trainers of each aircraft. HAI does not think this is necessary, due to technological advances in training devices, similar to those used by the military.  
  • Flight hours for a type rating: The FAA suggests 50 hours are necessary for a rated pilot in either an airplane or rotorcraft to obtain in a powered-lift aircraft before the pilot can be eligible for a powered-lift rating. HAI believes an airplane or rotorcraft pilot with a commercial or airline transport pilot certificate would not need 50 hours of experience in a powered-lift aircraft to add that rating.    

Finally, HAI urged the agency to expand its current definition of powered-lift aircraft (as defined in FAR 1.1), as it does not adequately capture the many different types of powered-lift machines expected to enter the marketplace.  The association suggested that the FAA definition does not capture the thrust vectoring aircraft that depend solely on propellers, rotors, or directed engine thrust. 

“HAI understands AAM and powered-lift is a rapidly evolving industry,” adds Noble. “The FAA gave us a great starting point for consideration on how regulations need to evolve with them.” 

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