AOPA voices concerns about proposed ATP requirement

May 3, 2012

Proposed rules that would significantly increase airline pilot training requirements—and cost—could force many would-be pilots to abandon aviation careers, exacerbating shortages that threaten the future of general aviation and commercial air travel alike.

That was among a detailed list of concerns voiced by AOPA (among others) in response to a proposed FAA regulation, mandated in broad strokes by Congress, that would require airline first officers (who may currently qualify with a commercial pilot certificate) to hold airline transport pilot (ATP) certificates.

In effect, the rule would increase from 250 to 1,500 hours the minimum requirement to serve as a Part 121 first officer for many pilots. Part 121 pilots must currently hold an ATP certificate to serve as captain.

AOPA and other industry groups take issue with many of the details.

The FAA proposes allowing students enrolled in four-year degree programs to qualify for an ATP certificate with 1,000 hours, placing students training outside of those programs, including those training at Part 141 flight schools and with individual instructors or flight schools under Part 61, at a distinct disadvantage: Students would be forced to spend an additional $90,000, approximately, to accumulate the flight time and complete training outside of a bachelor’s degree program.

“Although there is definite benefit of additional academic courses taken in aviation, AOPA believes that a 500 hour advantage given to pilots who received training through a university four-year degree program puts the pilots who are not able to pursue a four-year degree program, the individual flight instructor and part 141 schools at a great financial disadvantage,” said AOPA Vice President of Regulatory Affairs Rob Hackman.

The FAA also, arbitrarily, lowered the ATP certificate age requirement from 23 to 21—but only for students enrolled in a four-year college program.

The proposed rule also requires simulator training in full-motion systems that are beyond the means of many flight schools and students, Hackman noted in comments submitted April 30.

Congress in 2010 passed Public Law 111-216 requiring the FAA to revise training requirements in response to the Feb. 12, 2009, crash of a Colgan Air DHC-8 outside of Buffalo, N.Y. The FAA proposal, AOPA noted, exceeds the mandate in several respects without evidence of an associated safety benefit.

Hackman detailed 10 specific concerns about the proposed regulation in a 14-page letter, recommending six changes including removal of simulator training requirements that are more applicable to type ratings than to certificates. Hackman noted students required to receive 16 hours of simulator training, including at least eight hours in a full flight simulator (Level C), would be forced to compete for scarce simulator slots in Part 142 schools.

“Part 142 training center simulators are frequently scheduled many months in advance and run 24 hours a day, seven days a week in order to meet demanding training schedules,” Hackman wrote. “In fact, many Part 135 certificate holders report reserving simulator training time a year or more in advance.”

AOPA urged the FAA to reverse the proposed addition of advanced jet training requirements for the ATP certificate, noting that many pilots seek an ATP for reasons other than working for a Part 121 carrier. AOPA believes advanced jet training should be required only for pilots seeking Part 121 jobs.

AOPA noted that the proposed regulation could exacerbate an already serious shortage of pilots that is projected to worsen in years to come. An estimated 20 percent of current ATP and commercial certificates are held by pilots 60 and older, and the number of new certificates issued has been in steep decline for years. Just more than 3,000 ATP certificates were issued in 2009, compared to nearly 8,500 in 1990. Private pilot certificates have likewise declined, from about 40,000 new certificates granted in 1990 to 20,000 in 2009.

“This proposed rule adds cumbersome requirements to pilots seeking a career in the airline industry at just the time when additional pilots will be needed to meet demand,” Hackman wrote, noting the shortage impacts all aspects of aviation.

AOPA was not alone in urging significant revisions. Airlines for America, a trade organization of leading carriers, also opined that the regulation as proposed will worsen the pilot shortage.

"Hard-hour minimum requirements are not a substitute for the quality of a pilot's training and experience," Airlines for America said in comments filed on the proposed rule. "Failure to provide additional options for meeting the requirements, as recommended by safety experts, will result in an unnecessary pilot shortage and significant barriers to recruiting regional and mainline pilots."

Air cargo carriers also raised objections, noting the FAA does not have enough staff to keep up with demand for checkrides that would only increase under the proposed rule changes.