The 1500 Hour Rule: Ah, but what kind of hours?

In order to address the apparent deficiencies in pilot qualifications of some recent, and in particular regional airline accidents, the minimum experience  requirements for air carrier pilots has recently been increased. 

However, it seems to me that the rule still uses the old measuring stick of hours, to attempt to measure a quite different metric - pilot skill.

Effective August 2013,  the Airline Safety and FAA Extension Act of 2010 called for increased minimum requirements for airline first officers, a.k.a: the 1500 hour rule.  The new rule mandates that airline first officers hold an air transport pilot (ATP) certificate (or the new “restricted ATP.”)

An ATP certificate requires, among many other qualifications, that the pilot be at least 23 years old and have logged at least 1,500 hours of flight time.

The “restricted ATP” will require pilots to be at least 21 years old with:

• 750 flight hours if they are military-trained and qualified,
• 1,000 flight hours if trained in a four-year college or university-accredited aviation training program leading to a bachelor’s degree, or
• 1,250 flight hours if trained in a two-year college aviation program leading to an associate’s degree.

Under the "old rules" an airline first officer need only hold commercial pilot certificate

with instrument rating; and at  least a second class medical certificate.

The new rule also increased the requirement for captains to include at least 1,000 flight hours in air carrier operations.

See this link for an excellent summary of the old and new rules:

http://www.alpa.org/portals/alpa/1500Rule/PilotQualificationsSummary.pdf

and the actual final rule http://www.alpa.org/portals/alpa/1500Rule/FinalRule.pdf (134 pages)

I'm not saying this isn't better than to old rule, where a 250 hour commercial rated pilot could potentially be parked in the right seat of a regional jet, leaving the captain no-doubt feeling like it's a single-pilot operation. What I am saying is that the new rule still misses the mark.

Colgan 3407, a Q400 twin engine turboprop that crashed on February 12, 2009 is often cited as a key accident in the study of experience, fatigue, training, and other issues. In fact it is cited in the final rule.  On that flight, the airplane accumulated ice on approach, became slow, the stall warning triggered and  the autopilot disconnected, the airplane stalled, the first officer retracted the flaps and the airplane subsequently crashed. 
Colgan 3407 NTSB report

The captain of Colgan 3407 was hired with 618 hours, but had 3,379 hours of total 

flying time, including 3,051 hours in turbine airplanes at the time of the accident. 

The first officer flight was hired with 1,470 hours and had had 2,244  hours total before the final flight - exceeding even the new rules in hours, except for the ATP.

The pilots flying Air France 447 each had thousands of hours when the autopilot disconnected in cruise with an airspeed indication problem. Within a minute they had lost control. 

But are hours an adequate measure of experience any more?

In decades past, hours flown equaled hours of hands-on flying. Autopilots, if they were installed, were fairly crude and usable mostly in cruise. Flight directors, flight management systems, and fancy electronics were rare in all but the most sophisticated aircraft. Now even a Cessna 172 can have an outstanding autopilot/flight director system.

In my estimation a flight director does 75% of the work (perhaps 90% of the mental work) of instrument flight. With the autopilot on following it, r the value approaches 100%.

But even in the ATP Practical Test Standards (The ATP check ride guide)  while at  least one non-precision approach must be flown without the use of autopilot, the flight director is not 

considered part of the autopilot. It is up to the examiner's discretion if the flight director is used for those approaches. For all other maneuvers (except steep turns and stalls) it is expected that the flight director be "properly configured". 

Any skill is acquired and maintained by deliberate hands on practice. Programming the automation while it flies the airplane does little to increase or maintain instrument flight competence. 

Yet, the new rule continues to use hours as the gauge of experience and competence. 

There is credit given for military hours  - all of which are certainly not equal, and for having a college degree with an aviation major. One would assume the either would assure some deeper level of the physics of flight and other factors. But there seems to have been no attempt to ensure that the experience measured by hours alone is actually providing any hands-on experience! 

Take that same 250 hour commercial pilot and put him behind an autopilot and flight director for another 1300 hours. Is he really going to be that much better than when he started?  In some ways yes, but in terms of being able to hand fly the airplane in instrument conditions during a situation where hand flying is suddenly thrust upon them (e.g., Colgan 3407) , probably not much. Would more hours at cruise have made any difference in the ability of the Colgan crew to fly the airplane?

Here we only see total hours. Not hours hand flying - nor hand flying by reference to instruments, or takeoffs and landings, or even as the pilot flying.

I think we need a new measuring stick, not just a lengthening of the old measuring stick.

What's your opinion?