The FAA, Embraer's Automatic Takeoff System, and the Question of What Pilots Are For

The FAA has published a notice of proposed rulemaking (NPRM) to establish a safety certification framework for an automatic takeoff system Embraer is developing for the E195-E2 regional jet. The proposal addresses crew training, monitoring responsibilities, failure mode management, and mode awareness before any such system enters service. This marks the first time a regulatory body has proactively defined standards for a capability that would remove the physical rotation of the aircraft from pilot control during normal operations.

What Embraer’s Automatic Takeoff System Would Actually Do

On every commercial flight today - from a Cessna 172 to an Airbus A380 - the pilot physically pulls back on the controls at Vr (rotation speed), raises the nose, and initiates the climb. That act has been a defining element of piloting since the Wright brothers flew at Kitty Hawk.

Embraer’s proposed system would change that. At Vr, the aircraft’s computers would take over, raise the nose at the calculated rate, and execute the departure without crew physical input. The pilots would remain present, monitoring, and responsible - but they would not be the ones pulling back on the stick.

No production commercial jet currently offers this as a standard certified feature.

The E195-E2: The Aircraft Behind This Proposal

Embraer is the world’s third-largest commercial aircraft manufacturer, behind Airbus and Boeing. The company has produced regional jets since the 1990s, with the E-Jet family - the E170, E175, E190, and E195 - becoming workhorses of regional airline operations worldwide.

The E2 generation represents a substantial upgrade: new engines, redesigned aerodynamics, and dramatically improved fuel efficiency. The E195-E2, the largest aircraft in the series, seats up to 146 passengers and competes directly with the Airbus A220 and smaller Boeing 737 MAX variants. It is a fly-by-wire, full glass cockpit aircraft - thoroughly modern in every respect.

What the FAA’s Proposed Rule Would Actually Require

The NPRM centers on four areas.

Crew training. If the aircraft can rotate itself, the training syllabus must still ensure pilots can perform a manual takeoff if the system fails. That is not a trivial requirement - proficiency does not survive passive exposure alone.

Monitoring responsibilities. The proposed rule specifies what crews must actively monitor during automated rotation: hand position, instrument cross-checks, and the precise intervention point if the automation deviates from the expected profile.

Failure mode management. An engine failure at rotation speed is one of the most demanding scenarios in commercial aviation, requiring an immediate decision to continue or reject the takeoff. The FAA’s proposal addresses what happens when automation is handling rotation at exactly that moment - what the system does, what the crew does, and who holds authority.

Mode awareness. This refers to whether pilots know what the automation is doing at any given moment. Automation confusion has appeared in accident reports for decades, and the FAA is specifically focused on ensuring crews know the system’s state and can take over cleanly.

Why the FAA Is Acting Now, Before the Technology Arrives

The agency is writing the standard before the first aircraft with this capability enters service. That is the right sequence.

The alternative - waiting for Embraer to complete development, then improvising a certification standard - tends to produce inconsistent outcomes. Defining the framework in advance gives manufacturers a clear target and gives the traveling public a consistent safety baseline across aircraft types.

The NPRM reflects an institutional lesson the FAA drew from accident investigations of the past two decades.

The Accident Record That Shapes This Rulemaking

Air France Flight 447, which crashed over the South Atlantic in 2009, is the most studied example of automation-dependency failure. The autopilot disconnected unexpectedly after ice crystals disrupted the pitot tubes. The crew, confronted with a sudden demand for manual flight in a critical regime, lost control of the aircraft. 228 people died. The investigation found that the crew had not hand-flown at altitude in recent memory - automation proficiency had replaced manual proficiency, and the manual skill was absent when it was needed.

Colgan Air Flight 3407, also 2009, crashed near Buffalo. A different carrier, aircraft, and cause - but the human factors analysis identified automation dependency as a thread in the crew’s performance during the critical moments before impact.

The FAA knows this history. The emphasis on training and monitoring in this proposed rule is not bureaucratic routine. It is a direct acknowledgment of what happens when automation erodes the underlying manual competencies pilots need when systems fail.

The Certification Question the Industry Has to Answer

Current type ratings carry an implicit guarantee: a certificated pilot can manually fly the aircraft they are qualified on. Full stop. The automatic takeoff proposal does not eliminate that assumption, but it pressures it. The FAA will have to define clearly what manual competency looks like on a type where automation handles rotation as part of normal operations.

That definition will shape the initial type rating checkride and recurrent training events. Simulator evaluations for rejected takeoffs and engine failures at Vr are among the most demanding in the catalog. How those evaluations change when the normal rotation sequence is automated is a question the final rule will need to answer.

Embraer Is Not Alone in This Direction

Airbus has been developing automatic takeoff capability under a program called DragonFly. Boeing has its own research programs examining autonomous and semi-autonomous flight operations. The direction the industry is pointing is not ambiguous.

The technology exists. The standard the FAA develops now becomes the template for certifying it across manufacturers. Demonstrating that automated rotation is safer than a trained pilot across the full range of conditions - crosswinds, contaminated runways, mechanical failures at the worst possible moment - remains a high bar. Takeoffs are statistically among the safest phases of flight.

Why This Matters Beyond the Airlines

Regulatory frameworks developed for large commercial aircraft tend to migrate down the market over time. Glass cockpits started in airline service, moved to business jets, and eventually landed in the Cessna 172 via the Garmin G1000. Synthetic vision, terrain awareness, and traffic advisory systems followed the same path.

If the FAA certifies automatic takeoff capability and establishes the training and monitoring framework that makes it work, that certification pathway becomes a template. It is reasonable to expect that framework to appear in business aviation within the next decade or two - and to watch where it goes from there.

The Comment Period Is Open

The FAA is legally required to read and respond to substantive technical comments submitted during an NPRM comment period. The final rule regularly differs meaningfully from the proposal because of what the comment process surfaces. Airline pilots with experience in highly automated cockpits, type rating examiners, and anyone with substantive human factors perspective on automation dependency have standing to contribute to that record. The FAA docket system is publicly accessible.

Why This Matters for Pilots

The deeper question this rulemaking is wrestling with is not technical. It is philosophical. What do we want pilots to do when the aircraft is capable of doing it for them? And what must pilots still be able to do when the aircraft cannot?

Those are not new questions. Aviation has been asking them since the flight management system arrived in the 1980s and fundamentally changed how crews interacted with navigation. The autopilot that followed could fly coupled ILS approaches to minimums. Autoland demonstrated zero-zero landings in appropriately equipped aircraft. Each step generated the same debate.

The fact that the FAA is asking the question now, before the first revenue passenger sits in the back of an aircraft with automated rotation, suggests the agency absorbed something from those accident reports. Getting ahead of the automation question is harder than reacting to it. It is also considerably less costly.

Key Takeaways

• The FAA has published an NPRM establishing a safety certification framework for Embraer’s automatic takeoff system on the E195-E2 - the first such regulatory framework for this capability on a production commercial jet.
• The proposed rule focuses on four areas: crew training, monitoring responsibilities, failure mode management, and mode awareness - all informed directly by automation-related accidents including Air France 447 and Colgan 3407.
• Embraer is not alone; Airbus (DragonFly) and Boeing are pursuing similar capabilities, making this NPRM a de facto industry-wide certification template.
• The rulemaking forces the FAA to define what manual flying proficiency looks like on a type where normal operations no longer require pilots to physically rotate the aircraft.
• Certification frameworks for large commercial aircraft tend to migrate to business aviation and eventually general aviation - this rulemaking is worth watching regardless of what certificate you hold.
• The comment period is currently open; substantive technical input from qualified pilots and examiners carries real regulatory weight.