FEDERAL AVIATION ADMINISTRATION
EXECUTIVE SUMMARY
TITLE: Pilot Certification and Qualification Requirements for Air Carrier Operations
ACTION: This action would create new certification and qualification requirements for pilots
in air carrier operations. The proposal would require a second in command (SIC) in part 121
operations to hold an airline transport pilot (ATP) certificate and a type rating for the aircraft to
be flown. The FAA proposes to allow pilots with an aviation degree or military pilot experience
to obtain an ATP certificate with restricted privileges with fewer than 1,500 hours total time as a
pilot. The proposal also would require at least 1,000 flight hours in air carrier operations in order
for a pilot to serve as a pilot in command (PIC) in part 121 air carrier operations. Finally, the
FAA is proposing to modify the requirements for an ATP certificate with an airplane category
multiengine class rating or type rating to include 50 hours of multiengine flight experience and
completion of a new FAA-approved ATP Certification Training Program. The training would
include academic training and training in a flight simulation training device. These proposed
requirements would ensure that pilots have proper qualifications and experience in difficult
operating conditions and in a multicrew environment prior to serving as flightcrew members in
air carrier operations.
STATEMENT OF THE PROBLEM: The Federal Aviation Administration is initiating this
rulemaking project to address some of the factors that may have influenced the Colgan Air (dba
Continental Airlines Express) accident that occurred on February 12, 2009, outside of Buffalo, New York.
Additionally, this proposed rule responds to a Congressional mandate in Public Law 111-216, which
requires the FAA to revise the eligibility, training, and qualification requirements for pilots engaged in air
carrier operations.
EFFECT OF THIS ACTION: Pilots preparing to enter air carrier operations would have a stronger
foundation of aeronautical knowledge and experience as a result of the increased flight time and training
requirements for obtaining an ATP certificate. Requiring an aircraft type rating for all SICs in part 121
operations will ensure all part 121 pilots are trained and tested to the same standard with respect to the
aircraft to be flown. Requiring pilots to have air carrier experience prior to serving as PIC in part 121
operations would assist in their professional development and develop the competencies necessary to
assume the greater responsibilities of a PIC.
EFFECT ON FAA: The Air Transportation Division of the Flight Standards Service would be
responsible for approving the curriculum of all part 141 pilot schools, part 142 training centers, and part
121 or part 135 certificate holders who would elect to offer the proposed ATP Certification Training
Program. Additionally, FAA inspectors or designees would be needed to administer the proposed aircraft
type rating test for SICs in part 121 operations. Finally, the FAA would need to revise the ATP
knowledge test and practical test standards.
“SIGNIFICANCE”: This notice of proposed rulemaking is a “significant regulatory action” as
defined in section 3(f) of E.O. 12866, and is “significant” as defined in DOT’s Regulatory Policies and
Procedures due to the Congressional mandate.
CONTROVERSIAL ISSUES: Pilots seeking an ATP certificate with airplane category multiengine
class rating or type rating would be required to complete the proposed ATP Certification Training
Program, which could impose additional time and financial burdens on individual pilots. Requiring all
part 121 SICs to have an aircraft type rating could impose a financial burden on some operators.
Requiring a pilot to have air carrier experience prior to serving as a PIC in part 121 operations may delay
his or her career advancement. Finally, although an applicant for an ATP certificate with restricted
privileges would be required to pass the same written and practical tests, the proposed reduced-hour
requirement for an ATP certificate may be controversial.
COSTS AND BENEFITS: We estimate that the cost will be minimal for the requirement of 50 hours
of multiengine time for an ATP certificate with airplane category multiengine class rating or type rating.
We also estimate as minimal the costs of the requirement that a pilot have 1,000 hours of air carrier
operating experience before serving as PIC in part 121 operations.
As a result of our provision allowing
pilots with an aviation degree or military pilot experience to
hold a restricted-privileges ATP certificate with less than 1,500 flight hours, we have reduced by
$945 million the costs of the statutory requirement that all pilots in part 121 operations have an
ATP certificate by August 2, 2013. Nevertheless, on a pre-statute baseline, about 75% of the rule’s
costs are the result of this requirement, making the proposed rule not cost-beneficial. The requirement
will take effect, however, whether or not a regulation is issued. We believe that a post-statute baseline is
appropriate and, therefore, the costs associated with this provision are attributable to the statute, not this
proposed regulation. On a post-statute baseline, the proposed rule is cost-beneficial.
The remaining costs of the rule are associated with the aircraft type rating requirement for part 121 SICs
and the ATP Certification Training Program.
Along with the benefits, the table below summarizes the costs of the proposed rule:
Total Cost
($ mil.)
PV Cost
($ mil.)
Part 121 ATP Certificate Requirement
$ 1,575.2
$ 582.0
Type Rating (Part 121 Operators Only)
$ -
$ 3.4
ATP Certification Training Program
$ 443.3
$ 196.9
Total Social Cost (Pre-statute baseline)
$ 2,018.5
$ 782.4
Costs Attributable to Proposed Rule
(Post-statute baseline)
$ 443.3
$ 200.4
Total
Benefits
($ mil.)
PV
Benefits
($ mil.)
Total Social Benefits
$ 896.0
$ 439.8
Note: Column sums may be off one or more units from totals owing to rounding.
INFORMATION REQUESTED: Throughout the NPRM the FAA invites commenters to
address specific questions pertaining to the proposed requirements. The information requested
includes:
The adequacy of the minimum hour requirements for an ATP certificate;
The requirement for additional multiengine experience for pilots applying for an ATP
certificate;
The requirement for SICs in part 121 operations to hold an aircraft type rating;
The appropriateness of permitting applicants with specific military and academic training
to apply for an ATP with fewer than 1,500 hours of flight time;
The appropriate combination of academic training and training in a flight simulation
training device for the ATP Certification Training Program; and
Consideration for an alternative licensing structure, such as a multicrew pilot license.
The FAA also added additional questions at the request of OMB. Those questions pertain to the
rule’s impact on pilot supply and potential areas in air carrier training programs that could be
removed as a result of the ATP Certification Training Program. OMB also asked the FAA to
seek comment on accident effectiveness ratios.