Quality or Quantity? 1500 Hours Now Minimum for ATP

The debate of total time versus training is probably as old as aviation itself. In fact, sailors were probably debating this issue centuries before the Wright Brothers ever got anywhere Kill Devil Hill. Would you rather fly on an airliner piloted by two people who have at least 1500 hours of total flight time or by people trained to operate that specific aircraft in all the normal, adverse and emergency situations it might encounter...even if one of them had fewer than 1500 hours? Is that 1500 hour mark magical? In emergency conditions, is a pilot with 1500 hours guaranteed to save your life when a pilot with only 750 might not? Not in the case of Colgan Airlines Flight 3407. The FO was the low-time crew member with over 2200 hours and they still crashed.

However, ever since that accident some people have been clamoring for higher minimum times for all airline pilots. The bill that made it through congress (HR 5900) set that requirement as a 1500 hour ATP rating for all airline pilots, no matter what seat they're in. Though Some Celebrate this the families of those who died on Flight 3407 celebrate this, I worry that the unintended side-effects of this legislation will cause some serious problems for aviation in America. I don't think I'm alone either.

HR 5900 is technically another last-minute extension to fund the FAA until a real reauthorization bill can be passed. However, it also mandates that the FAA keep a comprehensive database on all pilots for reference by airlines, that the FAA re-examine crew day limits, and specifies that anyone flying a part 121 airline be required to have an ATP (meaning a minimum of 1500 hours total time.) It does allow the FAA to make rules giving some credit toward those hours for classroom training. I think this provision is the one saving grace, though they'll still have to be careful how they implement this.

The Airline Pilots Association issued a brief statement about HR 5900. They called it a "welcome first step"...which it is. They definitely made the point that the bill doesn't quite accomplish what it's meant to do.

The National Association of Flight Instructors (NAFI) has opposed this move since it was HR 3371 last year. They published a statement and wrote a point paper that they sent to Washington.

NAFI Executive Director Jason Blair made a pretty telling statement when he said, “The emphasis should be on training and quality of training, not just on total flight experience. In most accidents over recent years, this requirement would have made no difference at all. Further, we are unaware of any research that indicates any significant degree of correlation between raw hours of flight experience and performance in a jet cockpit environment.”

An article in Bloomberg mentions that the airline industry is currently built to allow first officers to build time in increasingly complex environments. They start on shorter trips in smaller aircraft and build experience before moving on to larger jets, longer flight across weather patterns, and more responsibility in the left seat.

I think this points out an important issue. Pilots right now have a few roads to getting an ATP. One is to work as a first officer on a regional airline until they get enough time. This option will soon disappear. Another is to fly for the military. This is a decent option, but it's a high price to pay and isn't an option for everyone. The rest of the aspiring airline pilots have to scrape for whatever flight time they can get. They dust crops, fly freight, instruct and spend their own money to rent airplanes and just fly to build time.

I worry that there aren't enough of those odd flying jobs to go around though. For the average civilian pilot to get to 1500 hours, people are going to have to start paying for their own flight time. This gets expensive very quickly and I don't think many people out there will be able to afford to do it for 1500 hours. What's more, when they finally get the hours they need they aren't going to be willing to work for the $20,000 a year the regionals pay their FOs right now. They'll have invested too much. The problem will be that the airlines, who are already on the ragged edge of profitability, won't be able to afford the salaries that these types of pilots demand. What will happen if fewer people are pursuing the job of airline pilot because it's so expensive to get in to and even then the airlines can't afford to hire them?

The NAFI point paper also emphasized the idea that this new requirement is going to drive pilots to build time in light aircraft. Operating a light piston aircraft is not the kind of experience that HR 5900 wants airline pilots to have. The rule requires training and/or experience in "adverse weather conditions, including icing conditions;" but I don't know many FBOs that rent aircraft capable of such operations. Even if they had such aircraft they'd charge so much for them that they'd be out of reach for the pilot scraping to get to 1500 hours and insurance companies wouldn't want those planes flying in ice and other bad weather.

So, all in all, it looks like this new rule fails to provide airline pilots with a higher degree of useful experience. Unfortunately, I don't think the parties involved looked at the issue close enough to realize this. I'm honestly a little worried that we're going to run out of airline pilots. It already costs people $40K-50K to get enough experience to get hired. If you add to that the cost of renting aircraft for hundreds of hours for time building, those costs could easily quadruple. Unless the airlines start paying people like doctors from day one, I don't know how people will be able to afford it. In the meantime, when a pilot finally makes it, he or she still won't have experience operating complex jets in challenging conditions.

I agree that a certain number of "raw hours of flight experience" does make a difference for a pilot. I don't think the arbitrary number of 1500 is it though. I definitely think that training makes a lot of difference though. The military can take a 25 hour pilot and train him or her to safely act as pilot in command of a very complex, multi-engine turbojet aircraft in just a year or two...all with less than 500 total hours total time. Even larger, crewed aircraft can have aircraft commanders with less than 1000 hours total time.

Part of what makes this system work is great training. Another part is mentorship. A new pilot is always paired with an experience aircraft commander or flight lead. They learn as they go, building experience in challenging conditions until they have enough experience to take the reigns and lead others. The airlines used to be built on this concept too. We've had some accidents recently, but abandoning a system based on experience in that type of operations under a mentor's supervision is definitely the wrong answer.

I'll be very interested to see what happens in three years when these rules go into full effect. I wonder how many airlines will be able to supply crews for their jets and how much applicable experience those crews will actually have.

What do you think?

Comments

Many share this viewpoint

Aside from meeting the FAR requirements for the ATP certification, technically, I could spent the rest of the required 1500 hours of flight experience in the pattern at Jimmy Bob's airfield! Congress is dangerously missing the point. What we need is more TRAINING, TRAINING, TRAINING! Not 1500 hours of teaching students how to do steep turns.

Knee-jerk reaction

The bill was simply a knee-jerk reaction by the congress in response to the crash to make the average citizen believe that something was done to make the skies safer! As you state, it does ZERO for additional safety, BOTH pilots involved in the tragic crash that led to this accident had total time well in excess of the 1500 minimum the new law requires. It simply was done to provide a false sense of security and improvement for the general public. Yes, it was an initial step, but one that, in my opinion is just going to distract from the real issues, and that is quality training, crew fatigue and general safety guidelines.

Andrew Smolenski
blogger at The Aspiring Pilot
and examiner at National General Aviation Examiner and Chicago General Aviation Examiner

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