Why the "night landing" time substitution for ATP?

[RussR]

For the ATP, 61.159 requires an applicant to have 100 hours of night time, but after the first 20 night landings, can substitute 1-for-1 a night landing for an hour of flight, with up to 25 credited in this way.

Why?

I'm asking for the history of this quirk of the regulations, if anybody knows it. For someone to have come up with this formula, there must have been a reason for it. Is it an old regulation, where this calculation was once needed, or valuable?

Chances are, given the "normal" progression, that a Commercial pilot will have a minimum of about 21 night landings anyway, just accumulated in training.

So, if you want to require additional night landings, why didn't they just specify that - 75 night hours and a total of 45 night landings would usually equate to the same thing (not always, I know). Or something similar.

Note I'm not really asking why it hasn't been changed, I'm asking why it was done that way in the first place.

 

[Captain]

Some operators seldom fly at night. A pilot there would still need a way to transition to ATP and the rule lessens the burden on that pilot to buy flight time (or force the operator to fly needless flights simply to build time).

 

[poadeleted20]

Some operators seldom fly at night. A pilot there would still need a way to transition to ATP and the rule lessens the burden on that pilot to buy flight time (or force the operator to fly needless flights simply to build time).

I don't know the actual reason for this rule, but I don't think Captain's explanation is what the FAA was thinking when they did it. I sincerely doubt that the FAA was concerned about the budgets of people buying flight time, since few people buy their way all the way to 1500 hours, and most anyone already working at an operation requiring an ATP to command will spend enough time in the right seat to get those night requirements while flying as SIC without the company having to lay on dead-head flights to get them to that number.

Based on reading a lot of NPRM's, I suspect that the answer is more that a lot of those 100 hours may be built boring holes in the night sky, while takeoffs and landings are probably more reflective of one's ability to handle night operations, since that's where most of the night accidents occur in operations requiring an ATP. So, if you do a lot of night takeoffs and landings (say, running short night freight legs), you may be better prepared for night operations requiring an ATP than someone who flies long night legs with only one landing every four hours or so.

 

[nosehair]

It was just one of those temporary rare moments of clarity in government regulations. Probly won't ever happen again...in our lifetime.