The federal government is considering banning air carrier operations that diverge from the model of American Airlines, United, and Delta in order to operate niche service from small cities and private terminals. And the only reason they’re doing this is as a concession to lobbying by unions and an incumbent airline – groups that don’t want to compete with more pilots and innovative business models.
The FAA is considering requiring carriers currently operating as scheduled charters to instead operate as scheduled air carriers, effectively putting upstarts out of business. The loudest lobbying voice with the ear of the powerful wins?
The 1,500 Hour Rule For Commercial Pilots Is A Joke
No one actually believes that the 1,500 hour rule for commercial pilots has anything to do with safety. For the past dozen years commercial airline pilots have had to have 1,500 hours in order to fly, though military pilots can have 750 hours; those with a B.A. in aviation can fly with 1000 hours; and those with an Associates degree in aviation can fly with 1250 hours. That was an increase from 250 hours.
Forcing pilots to build up hours means clear air touch and go landings in a Cessna, flying through the same airspace and in and out of the same airports. It’s lazy flying, not real world flying experience relevant to life in the cockpit of a commercial airline. Pilots aren’t dealing with stalls, storms, de-icing, or numerous other problems that you want a pilot to be experienced in during this training.
In fact airlines have to re-train the bad habits out of pilots that were acquired during this phase of their experience.
No other country in the world has adopted similar standards, because they do not improve safety. In the U.S. they were adopted in response to a need to ‘do something’ after the 2009 Colgan Air crash where the pilots had far more than 1,500 hours (the captain had 3,379 hours). Congress needed an action, and the Air Line Pilots Association had its hobby horse that would limit entry into the profession, improve their bargaining position and drive up pilot wages by creating scarcity.
European aviation is just as safe as U.S. aviation without this rule. So is Canadian and Australian aviation.
And U.S. pilots do not fear flying over Europe, where most pilots around them haven’t trained under these requirements. Nor do they fear flying in the U.S. where foreign pilots are allowed to operate their airlines’ aircraft.
The FAA itself says that the 1,500 hour rule does not promote safety.
The FAA was unable to find a quantifiable relationship between the 1,500-hour requirement and airplane accidents and hence no benefit from the requirement. For most accidents reviewed by the FAA, both pilots had more than 1,500 hours of flight time and for those SICs that did not, there were other causal factors identified by the NTSB.
And the NTSB doesn’t think pilot hour requirements prevent accidents, either.
We’ve investigated accidents where we’ve seen very high-time pilots, and we’ve also investigated accidents where we’ve seen low-time pilots. We don’t have any recommendations about the appropriate number of hours….
We may see pilots flood the comments here who want to defend their financial interest by maintaining a moat and keeping people out of the profession, and who don’t want to admit that training they’ve had to go through and spend richly for was wasteful and counterproductive.
Not All Air Carriers Are Subject To The 1,500 Hour Rule
Scheduled air charters, where one business sells tickets and pays another to fly, have been able to operate outside of major commercial airline rules for pilot training, among other limitations. Contour Airlines and JSX are examples.
JSX has senior captains, recently retired from American and Southwest, mentoring co-pilots who can have fewer hours like in most of the rest of the world. This is a way to train the next generation of pilots under real world conditions, enhancing overall system safety, and allow pilots to earn a living doing so rather than going into six figures of debt.
The FAA has not expressed concerns – let alone safety concerns – over any of this. Each carrier operates legally, and has been subject to safety oversight. By all accounts the FAA has been happy. It’s only once special interests began making noise that they agreed to open a regulatory docket.
When regional carrier SkyWest proposed to operate a subsidiary, SkyWest Charter, under these rules on small community routes ALPA balked and began lobbying to have the rules changed. (They also pushed cities to reject the service in favor of inferior products.)
The Biden Department Of Transportation Says They May Change This
To the Air Line Pilots Association, the 1,500 hour rule was a hard-won victory and is sacrosanct. But they’ve seen an increase in flying, and in proposed operations, exempt from the rule. They didn’t realize the extent of the carveouts in the law they’d helped to pass. And they were livid.
After intense lobbying by ALPA, joined in by other unions and by American Airlines (which faces competition from JSX, both based in Dallas), the Biden Administration is considering putting smaller carriers benefiting from their exemption out of business – requiring them to follow the same rules as major airlines.
The FAA has published a “Notice of Intent to Consider Revisions” to Title 14, Code of Federal Regulations (14 CFR) part 110.
The FAA is considering issuing a notice of proposed rulemaking that will seek comment on removing the exceptions for part 380 public charter operators from the definitions in 14 CFR 110.2 and delink FAA’s safety regulations from DOT’s economic regulations. If the FAA were to remove the exceptions, operators would then conduct public charter flights under the operating part applicable to their operation based on the same criteria that apply to all other non-part 380 operators, including the size and complexity of aircraft they operate and the frequency of flights.
Were FAA to amend its regulatory framework, some operators conducting public charter operations would need to transition from operating under part 135 to part 121.
This puts new air carrier models out of business. It raises their costs and makes them no longer viable, operating small planes with a limited number of passengers. But it puts a lid on competition for major airline union pilots, and competition with a better product that American Airlines doesn’t want to see.
“One Standard” Compromises Safety
The Air Line Pilots Association says they believe in “one standard” for aviation, that all pilots should be subject to the same rules. This isn’t actually true because they haven’t expressly lobbied to ban most private aviation, where the rule doesn’t apply. To ALPA, private-style aviation is fine if you’re wealthy but shouldn’t be available to everyone else.
Just as there are different standards for individual drivers licenses and commercial drivers licenses – driving big rigs and school buses – it’s also not appropriate for every commercial pilot to have the same level of experience. You don’t need the same experience for short hops on a 50 seat regional jet as you do long haul international flights on a Boeing 787 or Airbus A350. The union actually agrees with this assessment and is one reason that seniority dictates eligibility for widebody aircraft flying at major carriers.
Requiring small operators to abide by the same pilot training rules as major commercial carriers doesn’t improve safety, since the standards themselves don’t. It’s also one reason we’ve seen a disappearance of small market air service.
A pilot with sufficient training to work for a major will go do so, unless they’re paid as much at the smaller airline. But it’s one thing to amortize the cost of a $200,000 – $500,000 per year pilot across 150 to 300 passengers per flight. It’s another thing to spread that same pay across 25 passengers on a half full regional jet. It’s a major reason why “American, Delta, and United together ended flights to 74 cities between 2020 and this May.”
ALPA wants to see all flying done by its members, and flying only done by those at premium pay. But that means that some flying simply will not happen. And that’s what we’re already seeing today. This compromises safety.
Fewer flight options (and in some cases no flight options) out of small airports means that potential airline passengers either make hours-long drives to a larger airport or forego air travel entirely in favor of cars. And flying is much safer than driving.
The FAA Should Focus On Real Risks, Not Get Distracted By Fake Ones
In response to union lobbying, the Biden Administration is considering shutting down innovations in air travel and limiting air service to small cities. This limits consumer choice, and compromises safety.
The FAA needs to address real threats to air system safety in their own back year, like shortfalls in their own air traffic organization, not fake threats conjured up by interest group politics.
As a flight instructor slowly chipping away at 1500 hours, let me confirm that the flying is anything but easy. A dark joke among instructors is that our students are trying to kill us every day, and our job is to make sure they don’t succeed. Every day, I am trying to avoid a stall, stay on the runway, not collide with other planes, do what ATC says, and make sure the blue side stays up – even though my students actively try to do the opposite.
Do I wish there were an alternate path available for me? Yes. Is this “lazy flying”? Asoblutely not. Am I a better pilot now than when I started instructing? Absolutely yes.
Gary should walk a day in a flight instructor’s shoes.
All Part 135 is not equal. There is 9 or less, 10 or more, Commuter, single pilot and crew operations. Most business jet crashes are Part 91 operations, not 135.
Yes, 135 with Commuter Authority under 380 is a higher bar. And the accident rate in that category is even better than the 121 record. And there are no weekly on-board riots, fistfights or other in-terminal assaults on crews.
But anyone who actually studies aviation safety knows that what really makes an air carrier safe is a real SMS program including FOQA and ASAP, and supervised flying for new hires and upgrades. If you don’t know what those are, you probably aren’t qualified to opine on aviation safety. Google them. Those programs, not any arbitrary hourly rule, are what make aviation safe.
For the record, as an insider and with a prior career in 121, I can tell you that JSX has all of those programs and utilizes them to an even greater extent than most airlines. If this were really about safety, the rulemaking proposal would be to require those programs of Part 135 carriers that fly jets with 10 or more seats. The good ones – NetJets, Flexjet, JSX – already have them.
Gary – In your bio, it says nothing about you having line pilot experience at an airline. If you have none, let me give you my experience as a retired 30-year airline Captain. Before the current airline pilot experience requirement was established by the Federal Aviation Administration Extension Act of 2010, a pilot sitting in the right seat of an FAR Part 121 airliner needed a commercial pilot’s certificate and as few as 190 hours of flight experience. With the enactment of the FAA Extension Act, air carrier regulations now required airline new hires to hold an Airline Transport Pilot (ATP) certificate, the same licence the Captain hold, and requires 1500 hours of experience. There is also a restricted airline transport pilot certificate (R-ATP) that could be obtained at age 21 with a minimum of 750 hours of flight experience, depending on the source of pilot training (i.e. military flight experience) and educational background.
Before the FAA Extension Act on 2010, our airline had staffing problems and hired some very low time pilots as First Officers (FO) and while these new hires had plenty of enthusiasm, their lack of experience showed. I had one low time F/O totally freak out as we were manuevering to keep a safe distance around thunderstorms. I was the flying pilot and the F/O was supposed to be talking on the radio to air traffic control, but could hardly do that and I had to take over the radios too until we were clear of the weather. Another low time F/O on an instrument approach decided to raise the aircraft flaps after I asked him to lower them for the landing configuration. And then there was the low time F/O flying an aircraft that was notorious for needing power on the engines down to touchdown, but they decided to reduce the power all the way back at 100 feet above the ground with me having to take over the flying, add power, and land safely.
You said in your article that “No one actually believes that the 1,500 hour rule for commercial pilots has anything to do with safety”. “No one”. Really? Not even airline Captains?
Pardon me, but did the FAA (executive branch) implement the 1500 hour rule or was it the US Congress in the form of legislation in 2010? Just like the post 9/11 mickey mouse “Temporary” flight restrictions over Disney, these were implemented by congress, and the FAA was not the culprit.
It seems pretty clear, on demand charters shouldn’t be in the scheduled airline business.
You made a good start to your argument, but when I can upon the part pasted below, you showed your ignorance:
“You don’t need the same experience for short hops on a 50 seat regional jet as you do long haul international flights on a Boeing 787 or Airbus A350. The union actually agrees with this assessment and is one reason that seniority dictates eligibility for widebody aircraft flying at major carriers.”
For the most part, a jet is a jet. The small 50 seat jets you talk about are just a complex as the larger wide bodies. The operation of the smaller planes at 121 airlines does not require any less training or experience. Certainly the international aspect and over-water conditions do require a fair bit of experience and training, but so too does flying into uncontrolled airports and near significant terrain, something many small regional jets do all the time. And to say that the union agrees is total hogwash. There are no seniority restrictions on flying widebody aircraft at United or Delta. These planes are generally more senior because they pay more, and often have better schedules. But at United, the US’s largest operator of passenger widebody aircraft, it has not been uncommon in recent years to be assigned a 787 or 777 at the start of training.
Is ALPA defending its members? Yes. But prospective passengers should know that not all airlines are created equal. The loophole that JSX and others have been using was never intended for that use.
Just another piece of proof that the FAA doesn’t care about safety and just about lobbyism.
Otherwise, the idiotic 1500h rule would long have been abolished in the first place.
In my humble opinion, the 1500 hour requirement is a judgement “been there, done that, ain’t gonna do that again” issue. Sure…the difference between a Volkswagen Beetle and a Koenigsegg is price. A car is a car. A Cessna 172 and an Airbus A350 are both aircraft. The difference is scale and the capability to understand one’s limitations in handling the differences. My 11 year old grandson can fly the crap out of a Boeing 737 simulator. He handles turbulence with ease. ILS down to minimums…wired. Landing…he’s got it wired right up to just before touchdown because he can’t see over the nose! Engine out…well… the lack leg length and strength is an issue but pitch and roll…he’s got it wired. I do have to put the MDM under his butt to see over the nose. BUT… he has the judgement and experience of a pea. The judgment factor gained by accumulating hours is invaluable. I want a new airline pilot sitting to my right to be able to say back to me, “Eh…I’m not so sure about…”.
Gary does not have to be a pilot to understand the issues at stake and what is going on by all of the groups involved.
There is no doubt that experience matters in every industry and that plenty of young pilots do not have the experience to safely pilot a single engine Piper or Diamon let alone a commercial jet.
But let’s also be honest that the issue is that ALPA is willing to kill the best alternative to providing air service to small cities.
Airlines are to blame for overusing regional jets where they are not necessary. AA and UA chose to ignore the signs that DL saw over a decade ago that the economics of the regional airline industry
The government is to blame for having or allowing slot rules and perimeter restrictions (DCA and LGA) that encourage the overuse of regional jets in markets that should be able to support mainline jets. Exemptions should be for small cities and not an open-ended means to allow JSX or Skywest lite or whatever it will be called to serve medium to large markets.
We need a reasonable pathway for young pilots that provides a mechanism for supporting small cities.
It is shameful that the USA can’t think more than in binary “yes” and “no” answers
@ Tim Dunne
Your comment “But let’s also be honest that the issue is that ALPA is willing to kill the best alternative to providing air service to small cities.” is far from the truth.
Keeping the rules the same for all scheduled air services is not trying to kill service. This is like a food truck complaining they have to follow the same health rules as a fixed restaurant and saying they can’t afford to do that and stay in business.
How many people want their pilots to be learning on the job? While you go to great lengths to prove that the 1500 hour rule doesn’t enhance safety, you show no actual evidence that doesn’t. The U.S. aviation industry has had an exceptionally safe era since the 1500 hour rule was implemented. This rule is a decent attempt to move away from the “Tombstone mentality” to regulation.
DA Pilit,
the consistent level of experience argument is a copout. You and I both know that there are substantial differences in the level of experience of pilots in commercial cockpits today. All of the large jet US airlines are hiring pilots with relatively low levels of experience compared to the average pilot.
There have been reports of captain upgrades at Delta and United with less than one year at the company.
You are undoubtedly aware of the Delta 767 that was flown through hail climbing out of Milan and the United 767 that made a hard landing and bounce in Houston. There are reports – and I don’t want to debate the circumstances – that both involved low time pilots in one or more seats. whether low time or not, there are equally compelling stories of how those same types of damage and risk to life was avoided on other flights
The 1500 or 1000 (for university graduates with a restricted ATP) is just a line. There are different levels of experience and wisdom that come at all levels of experience in any job.
We need to be able to come up w/ solutions to ensure that there is a supply of new pilots and also that small cities can maintain air service.
It is shameful and unacceptable for any side to shoot down any proposal to find a solution built around common ground and shades of gray rather than black and white “can’t do” vs. “give away the farm”
What an idiot! He writes about flying stuff but has zero clue about flying stuff! It is obvious that there is zero minimum requirement to write a blog!
The 1500 Hour rule is a rule, like most in aviation, that was written in blood. As in people died! This strict rule came about because of the Colgan disaster, IIRC. New FO with no real world experience flying much like the mouthpiece was spouting is safe crashed killing all aboard.
Being a flight instructor is not lazy flying hombre. It’s the second most dangerous job in the US. Flight instructors spend their entire days doing stalls and other hair raising maneuvers.
Generally speaking if any agency of the government is for something I am against it. On another note I like to fly ME3 so the bathrooms don’t smell like a pigsty on touchdown.
Why do we all pilots have to say they work for a “major” airline?
I have never yet seen one that would say I work for a minor airline. Why can’t you just say you work for an airline?
@DA Pilit – “Keeping the rules the same for all scheduled air services is not trying to kill service. This is like a food truck complaining they have to follow the same health rules as a fixed restaurant and saying they can’t afford to do that and stay in business.”
Patently specious. So, you mean to tell me that Southern Air Express – a carrier that flies 9 seat Cessna Caravans in scheduled service under Part 380 – should be subject to the same “rules” as, say AA, UA or DL?
DA Pilit,
the consistent level of training or experience is far from reality even among pilots at “major” airlines. You and I both know that there are substantial differences in the level of experience of pilots in commercial cockpits today. All of the large jet US airlines are hiring pilots with relatively low levels of experience compared to the average pilot.
There have been reports of captain upgrades at Delta and United with less than one year at the company.
You are undoubtedly aware of the Delta 767 that was flown through hail climbing out of Milan and the United 767 that made a hard landing and bounce in Houston. There are reports – and I don’t want to debate the circumstances – that both involved low time pilots in one or more seats. whether low time or not, there are equally compelling stories of how those same types of damage and risk to life was avoided on other flights
The 1500 or 1000 (for university graduates with a restricted ATP) is just a line. There are different levels of experience and wisdom that come at all levels of experience in any job.
We need to be able to come up w/ solutions to ensure that there is a supply of new pilots and also that small cities can maintain air service.
It is shameful and unacceptable for any side to shoot down any proposal to find a solution built around common ground and shades of gray rather than black and white “can’t do” vs. “give away the farm”
@aaway
From the definitions page 380.2:
“It does not include scheduled air transportation”
@ Gary. Up until recently Southwest Airlines required both pilots to hold an ATP and be type rated in the Boeing 737. Southwest’s route structure consisted mainly of “see an airport and land.” with up to 9 legs in one day (yes, I’ve done that and never left Texas.) This was not the place for a 250 pilot! And due to the ATP (1500 hours) and B737 Type rating requirement, along with extremely proficient pilots, Southwest Airlines had the best safety record in the world. It’s difficult to argue with success and even the FAA recognized that.
My vote is for safety and the 1500 rule is just one facet of the safest system in the world. I say this as having been an Army Instructor Pilot, FAA Instructor Pilot, Part 121 pilot (several airlines) and an expat pilot for three (3) International Airlines.
Full disclosure though is I’ve never owned or authored a BLOG.
@Da Pilit
Why didn’t you link the entirety of 380.2: https://www.ecfr.gov/current/title-14/chapter-II/subchapter-D/part-380/subpart-A/section-380.2
That way everyone who chooses to read can see.
BTW, Southern Airways Express is certified under FAR Part 298. Part 298 carriers are permitted to operate scheduled services under Part 380.
The question remains – Should the “rules” for a Southern Airways Express pilot flying the Caravan be the same as an AA pilot flying a B777-300?
@aaway: You posted “Southern Air Express – a carrier that flies 9 seat Cessna Caravans in scheduled service under Part 380”
I don’t know about Southern Air Express, but you say they operate under 14 CFR 380. I found a Southern Airways Express, they say they operate as public charters.
And I don’t see anywhere that Part 298 carriers can operate under Part 380. If you find that let me know.
@ Tim Dunn
I’m all in favor of finding solutions. Some are already there to reduce the 1500 hour rule. And yes, this is why you can actually go down to 750 hours. But Gary’s idea always seems to be to eliminate the 1500 rules and he has suggested going to 250. I don’t support just dropping the hour requirement. Ab initio programs are the best ideas that I have seen.
@DA Pilit
You mean this Southern Airways Express, right?
https://iflysouthern.com/
Otherwise, I’ll let you continue to be obtuse.
There is really no way in the airline industry unless your already rich or lucky enough to have military experience. I’ve got 1100 hours of flight experience, but I’ve no desire to teach.
@aaway
Yes but you posted:
“So, you mean to tell me that Southern Air Express – a carrier that flies 9 seat Cessna Caravans in scheduled service under Part 380 – should be subject to the same “rules” as, say AA, UA or DL?”
I guess you meant Southern Airways Express.
According to this it operates as a Public Charter.
https://iflysouthern.com/faq/
I haven’t found anywhere what part it operates under. Maybe you could be so kind as to post a link.
As a retired airline pilot, 1,500 has everything to do with safety.
Removing it is just the industry looking for cheap labor.
@ Brandon. Hang in there, you’re very close. I’ve noticed ads for right seat corporate pilots. But you can take the vow of poverty and flight instruct . . . it’s just how far you are willing to sacrifice in order to POSSIBLY fly that B787.
This article is full of so much garbage. In what world is a more experienced worker not better at their job? Especially in the incredibly complex and unique field of aviation. Coming from a 16-year professional pilot. After reading this, I feel confident that I can write an article about any complex field that I know nothing about and have no experience in. I’ll just do research, and think I know. It’ll be a terrible article that is highly inaccurate, but the general public won’t know any better. ViewFromTheWing.com will still publish it.
@Lawrence ” In what world is a more experienced worker not better at their job? ”
The 1,500 hour flying requirement can be satisfied with a third of those hours in a hot air balloon. The hot air balloon can be tethered.
“Pilots aren’t dealing with stalls, storms, de-icing, or numerous other problems that you want a pilot to be experienced in during this training.” Tell me you have no idea what you’re talking about without telling me. I’d argue you need to pay attention to storms and stalls more as a GA pilot than than I do flying a 175. The rest of your argument is rendered invalid by proving you no idea how aviation training works or the valuable lessons learned during those early hours.
@Thomas Batchelor – tell me you’re being disingenuous without telling me you’re being disingenuos.
there’s no requirement to fly in bad weather and gain that experience when building up these hours.
SkyWest is now saying it will now require all pilots hired to have 1500 hour to keep flying their regulatory work around. If that’s true then the unions are correct. It’s just away to save money crewing aircraft and not operate expensive safety programs. Lets face the facts, are you really going to hop on a remotly operated airliner? Or pay for an electric vehicle to travel the country with? These hair brained philanthropists/airline managers need to be regulated when dealing with the public trust. How many more have to die, to maintain the same level of safety.