U.S. Pilot Training Rules Don’t Promote Safety (And May Make It Worse)

The highest paid jobs in the country are doctors, CEOs, and commercial airline pilots. And that was before the recent round of raises in new pilot contracts at Delta, American and United.

While being a pilot at some airlines may mean being away from home, spending nights on the road instead of with family, it also means getting entrusted with expensive machinery that lets you soar through the clouds. Being a pilot is special. It’s a high status career that doesn’t require a college degree.

Yet despite the attractions of the profession, there aren’t nearly enough pilots. And that is because of how long it takes to become one, and how expensive it is to work up the flight hours that are needed. Without enough pilots, small cities are losing air service. And since flying is the safest mode of transportation we have, that means a lot more risky driving instead.

At the urging of the major pilot union, the Biden administration is considering rules that would further serve as a moat for entry into the pilot profession, making it tougher for small cities to sustain air service, and putting innovative air carriers out of business.

Why We Have A Pilot Shortage

During the pandemic the federal government gave airlines subsidies to ensure that employees stayed connection to airlines, that airlines were ready to fly when passengers returned. Except airlines took some of that money and paid senior employees to retire early. They moved pilots off of their rolls, and they weren’t onboarding new ones.

That helped exacerbate a pilot shortage, but wasn’t the main cause. After the 2009 Colgan Air crash, the federal government made it much more time-consuming and costly to become a pilot. Co-pilots would henceforth need 1,500 flight hours.

The rule was a hobby horse of the major pilot union, not a safety measure. It didn’t address the causes of that accident at all. The first officer on the Colgan Air flight had 2,244 hours of flying.

Time and duty rules were changed as part of the Airline Safety and Federal Aviation Administrative Extension Act of 2010 as well, and that makes sense.

  • time between flights was increased from 8 to 10 hours
  • mandatory off duty time was increased from 24 to 30 hours per week

Pilot fatigue is far more important an issue than the additional hours required to become a co-pilot. Europe did not follow the U.S. in increasing the hours requirement. Neither did other countries. The rule just choked off supply here.

Why The Pilot Shortage Means Fewer Flights For Small Cities

When the major airlines found themselves short of pilots returning from Covid, they started hiring out of regional airlines.

  • Major airlines pay better
  • They can amortize the cost of a $250,000 pilot across (say) 150 passengers per flight, rather than 30
  • It’s no longer economical to operate small regionals and turboprops at the prices a pilot shortage requires.

That meant the pilot shortage became acute with the regional carriers. And that’s why major U.S. carriers ended flights to 74 cities over the past 3 years.

ALPA Demands A Crackdown On “Part 380” Flying

SkyWest had a solution to small city flying. They were going to set up a scheduled charter operation that would allow co-pilots with fewer hours of flying experience. It’s technically legal, but the Department of Transportation has sat on the request. The Air Line Pilots Association went bonkers. They saw a proverbial camel’s nose under the tent of their hard-fought occupational licensing restrictions.

At their behest, the Department of Transportation says they’re considering making public charter operators fly under major airline rules so that the 1,500 hour rule for co-pilots applies broadly. That doesn’t just apply to SkyWest Charter, but also JSX, and perhaps Contour Airlines and Southern Airways Express.

The 1,500 Hour Rule Doesn’t Support Safety

The 1,500 hour rule is just an hours requirement and not a substantive experience requirement. It doesn’t benefit safety. Taking off and landing at the same couple of airports in clear weather with a fixed wing aircraft suffices.

The senior pilots at American Airlines, Delta, United and Southwest all got started when there was no 1,500 hour rule. And there’s zero evidence – backed up by both the Department of Transportation itself and the NTSB – that the increased hours requirement has contributed to the safety record of U.S. air travel.

Co-pilots at foreign airlines fly inside the United States every day without complying with the 1,500 hour rule. While ALPA says they encourage the Department of Transportation to enforce ‘one standard of safety’ they aren’t actually calling for this, and DOT’s consideration of new rules wouldn’t require it because they’d continue to allow foreign flag carriers to fly inside the United States with fewer hours. This includes airlines from Southeast Asia and Africa.

There should be different standards for different kinds of operations. There really is something different about a co-pilot with 250, 500, or 750 hours in the right seat of a 50 seat regional jet on a one- to two-hour hop versus flying long haul widebody operations and so it doesn’t make sense to have the same requirement for all forms of commercial operations.

When I wrote about this over the weekend, a bunch of pilots came to the defense of the 1,500 hour rule saying ‘but I built up my hours as a flight instructor‘ so it’s not just useless hours!

  • One common way to get paid to build up flight hours, after doing your first 250, is to become a flight instructor. The people instructing pilots don’t have to have 1,500 hours…

  • Being an instructor is hardly required for building up hours. The hours can be built up in another category and class of flying altogether. In fact hours in a hot air balloon qualify towards the 1,500 hour required. The hot air balloon can be tethered.

One commenter admitted that the 1,500 hour rule is meant to drive up pilot wages rather than promote safety, but noted that pilot wages are higher than they were in the 1990s and needed to be! That actually isn’t true. Similar stage pilot wages are lower today than they were in the 1990s. That’s because someone with 230 hours could earn “low” wages at a regional airline back then. Now they have to pay to accrue hours in the air. Their wages have gone negative.

What We Should Do Instead

Most of the criticisms I’ve gotten from pilots lack any substance whatsoever. They simply argue that I’m not a pilot, and am not entitled to make an argument. But let’s say you’re concerned that there wasn’t enough pilot training prior to the Colgan Air crash. But would you want to do?

  • The law also deals with pilot hours and duty days. Fatigue is a real issue. You want pilots that are alert and ready to react if air traffic control makes a mistake. You don’t want pilots taxiing out in front of other aircraft.

  • The structure of pilot training matters. Getting real experience in a variety of flight conditions and at numerous airports matters. Working through non-normal procedures matters. Focus on content of flight hours, not rote hours.

  • If you’re concerned in particular about part 380 operators, though it’s not clear why you should be, consider restricting 250 hour co-pilots to be paired with more senior captains. A combined 3,000 hours in the cockpit might be required in order for a pilot with a mere 250 or even 500 hours to occupy the right seat.

Pilots are crucial, but a 30,000 hour senior captain mentoring a 300 hour co-pilot in a regional jet is probably safer than a regional carrier with two 1,500 hour pilots. We shouldn’t focus just on hours, and instead on skill-building, real world experience and mentoring.

The 1,500 Hour Rule Is Harmful Cronyism That Shouldn’t Be Extended

The Air Line Pilots Association wanted to create a shortage of pilots. That gives them bargaining leverage. It makes them harder to replace. And it drives up wages.

But it compromises safety. It means there aren’t enough pilots to operate small planes out of small cities. The pandemic was a key driver here, too. The federal government gave airlines subsidies to retain their workers, and in many cases those funds were used to buy pilots into early retirement. Meanwhile new pilots weren’t being onboarded. So major airlines found themselves at a shortage, and they started bidding pilots away from regionals.

Now small cities are losing air service. People drive greater distances to airports, or forego air travel altogether. And driving is far more dangerous than flying. We’ll have more road deaths as a result.

About Gary Leff

Gary Leff is one of the foremost experts in the field of miles, points, and frequent business travel - a topic he has covered since 2002. Co-founder of frequent flyer community InsideFlyer.com, emcee of the Freddie Awards, and named one of the "World's Top Travel Experts" by Conde' Nast Traveler (2010-Present) Gary has been a guest on most major news media, profiled in several top print publications, and published broadly on the topic of consumer loyalty. More About Gary »

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  1. While my flying has been entirely for sport (despite have a commercial license) I will say that sheer hours don’t seem to make much sense. Personally I thought 1500 for first officer was just arbitrary and likely far more than needed given that someone in the right seat would be extensively trained through a type rating for that aircraft. That said, I also wouldn’t exaggerate the balloon time etc. aspects as even pre-2010 a person needed pretty good training. Here’s what is required today for an airline transport pilot certificate.

    Be at least 23 years of age
    Must hold either:
    A commercial pilot certificate with an instrument rating
    Or, meet the military experience requirements to qualify for a commercial pilot certificate, and an instrument rating,
    Or, a foreign airline transport pilot license with instrument privileges
    Medical requirements:
    Hold a 1st class medical certificate to act as Pilot-In-Command
    Hold a 2nd class medical certificate to act as Second-In-Command
    1,500 hours of Total Flight Time
    500 hours of Cross-Country Flight Time
    250 hours as Pilot-In-Command (PIC)
    100 hours of Night Flight Time
    75 hours of Instrument Training
    50 hours of In Class of Rating Sought
    Pass an ATP knowledge test
    Complete and pass an ATP-CTP training program

    The last line refers to a training program. Virtually every ATP holder will have (need) a multiengine rating as well. But flying around and instructing in blue sky conditions and getting an instrument rating solely by under the hood training really doesn’t prove much in the constantly varying real world of real weather. Again, that is an argument against the 1500 hour rule, not that the FAA will listen. The organization arbitrarily put in a 60 year retirement ceiling and it took decades of demands to raise it even to 65. I doubt if they will be any more flexible now.

  2. once, again, well said.
    The only thing that I would add to your list of recommendations is that exemptions should be granted only in market pairs that involve at least one underserved city. The other end of the flight likely would be to a major hub.
    ALPA legitimately doesn’t like exceptions to regional airline rules because major airlines have used regional jets for way more than they should be used – like 3 and 4 hour flights 2/3 of the way across the country.
    Just about every underserved city than needs air service is within a 2 hour flight of multiple major air hubs.
    Limited exceptions. Pairing junior FOs with experienced captains. A strong training program.
    A pathway to the big boys after 2-3 years regional flying minimum.

  3. drrichard,
    just to note that university FAA approved pilot training programs meet all of those requirements except for the number of hours in each. Graduates of those universities (there are 80 or 90 in the US) only need 1000 hours. They do the quality of training that needs to be standard.
    The issue is building time.

  4. So Gary….you have never answered this.

    Why are we in the safest period in aviation history? Since the 1500 rule came into place along with a few other caveats, there have been zero deadly crashes in the hands of US aviators. You clearly have no understanding of ours jobs and the value of airmanship.

    Also…why do you keep posting the same horse crap over and over again? Do you have 250 hours and do not feel like going through the hell it takes to get your CFI? Don’t want to get an aerial survey job where you have to fly 9 hours per day? Just want to skip the hard stuff and go straight to the right seat?

  5. It’s honestly very concerning to me how many pilots simply don’t care about how the data shows that European airlines are just as safe as US ones, without the massive hours requirement, or that aviation in general has gotten safer everywhere in recent years (not just in the US).

    If pilots don’t care about data in this context, can I really be sure they’ll care about crucial data presented to them while flying? Or do they just disregard that too if inconvenient to them?

  6. @SMR The 1,500 hour rule would not make aviation any safer than if there were a 250 hour rule instead. When was the last time there an aviation incident happened in Europe? The reason aviation is as safe as ever is because of technology. As technology improves, aviation will only get safer. The point you are trying to make has no substance and you are merely defending a corrupt system.

  7. @Tony

    What data re you implying pilots ignore while flying since we are “ignoring “ the fact that the 1500 hour rule is working to keep the skies safe.

    Again. Many accidents avoided everyday by great airmen. They don’t make the news. We do our jobs professionally and fly you and your loved ones safety across the country day in and day out and will continue to do so until PiBots come along.

  8. Thanks Tim for the correction. Maybe 1000 is a reasonable number for an ATP. Some people will have great experience working towards 1500, others will just fly the syllabus with students and so their arbitrary “time in grade” won’t mean too much. (In fact, 500 hours of VFR work could degrade skills!) There are a lot of issues that could be raised here, such as having standardized spin training for all fixed wing pilots and whether the third class medical makes any sense today. But government agencies are not very nimble, and as I wrote the other day the FAA seems worse than most. While their are excellent people there the institutional attitude seems to be that it is better to do nothing than be accused of something that cost lives.

  9. 250 hours in a professional 737/A320 simulator is 1000% better than 1500 hours of banner towing in a put-put Cessna.

    ALPA doesn’t care about safety–ALPA only cares about ALPA.

  10. @John. European pilots have been training in single engine aircraft here in the US for 250 hours. And I only agree to an extent. Now who is going to pay for 250 hours @$1200 per hour ?

    You will also deplete the CFIs. There will be no one to teach which is probably why the Europeans come here

  11. @Gary – You have no merit to write about pilot training. The article says the rules do not promote safety yet here we are in the safest era of US commercial Aviation

  12. The Colgan Air crash led to rules that seem to have made flying safer for the passenger. Any
    dismantling of those rules has to be done with extreme caution.

  13. Rules on pilot rest, combating fatigue, contributed to safety. That part of the legislation was helpful. The occupational licensing moat that was the 1,500 hour requirement did not and there is absolutely no logical reason to believe otherwise.

    Banner towing and time in a tethered hot air balloon is not the driver of US safety and Europe is just as safe without this piece of stupidity.

  14. Oh come on.

    The pilot shortage has been predicted and well known by true experts for at least a decade, but the airlines did not do anything because they knew they could buy their way out with Washington bribery (aka lobbying).

    Gary, you work in Washington. How much are you being paid by the airlines for your weekly posts on this topic?

    No, there are no studies showing that a reduction in experience would not reduce safety. Would a 250 hour pilot been able to handle the 737-MAX design flaws?

  15. European airlines require up to 4000 hours. Therefore regulation there isn’t needed because they have higher standards of US one, who as you so clearly show would hire anyone at FAA minimums and therefore need a 1500 hour standard.

    I can’t paste a link.

  16. There is a whole lot of binary thinking going on that is just plain illogical.
    Yes, US aviation is safe – but so is European aviation.
    US aviation is safe because of a whole lot of factors; the number of hours at which pilots enter commercial flying cannot be logical isolated from every other factor.

    SMR,
    university programs almost always include multi-engine ratings; students from those programs get everything they need including all of the ratings EXCEPT the 750 hours to get into a commercial pilot cockpit.

    And if you look at the pilots involved in the majority of commercial aircraft accidents, they involved pilots that had far more than the number of hours being considered.

  17. If the 1500 hour rule is working to keep the skies safe, which accidents in the 30 years prior to its introduction would have been prevented if it existed during that time? 9/11? TWA 800? AA 191? I don’t recall seeing pilot experience in the NTSB reports for those accidents.

    Correlation does not mean causation.

  18. Mean annual salary is a dogsh*t metric by which to rank jobs.

    Pilots are paid well by the yardstick of middle class middle America, but that’s irrelevant to us readers of this blog. The middle class middle American, if flying at all, is flying in the middle seat on a Basic Economy fare and not even earning miles.

    Readers of this blog are coastal elites and highly educated. We’re so highly educated that if you have only an MBA, you’re a Master of Barely Anything. Gary, as you’ve posted before, a good chunk of this blog’s audience has a net worth over $100MM.

    These aren’t doctors, lawyers, or (most) CEOs. So who are they?

    The real highest paying jobs in America are the types of jobs that elite university grads flock to. Let’s have a closer look.

    FINANCE TRACK
    Usually starts with a 2 year stint as an investment banking analyst/associate, then moving on to partner track at a private equity or venture capital firm. By age 30, these financiers make in the ballpark of $5,000,000/year in liquid salary and bonus (carry). If you’re very skilled and lucky in your deals, it’s $50,000,000/year or even $500,000,000/year. These numbers are not a joke. Look up what hedge fund partners make and it’s yet another order of magnitude higher.

    BIGLAW
    First-year analysts make a pittance but partnership, which takes 8 years to achieve, means a mid-high 7 figure annual salary, again liquid.

    MEDICINE (FOR REAL)
    The numbers in the linked Investopedia article are a bad joke. Choose a surgical specialty, work in a major metro, advise health tech startups on the side, and you’re on par with your biglaw peers plus you have equity that could make you a billionaire in the coming decades.

    MANAGEMENT CONSULTING
    This path is less ritzy now as the big firms are specializing and focusing recruitment on experts (PhDs and experienced industry hires) instead of kids straight out of college, but the conventional deal is you grind it out for 10 years and you’re a $5,000,000/year partner. Again, liquid. You’ll also have all the miles and points you could dream of. Ever wonder who’s redeeming 700,000 Skymiles for a one-way flight in Delta One? Newlywed partners on their honeymoon, 2,800,000 Skymiles easy. And the divorce rate is pretty high so they’re going to be dropping another 2,800,000 Skymiles on their second honeymoon before you even know it. Now, before the peons get all snarky about worklife balance in MBB and the high divorce rate, please remember that the highest divorce rate in America is among poorly educated non-elites.

    NERDY PATHS
    If you are only of average intelligence, you can become a software engineer at someplace like Google and with a decent promotion trajectory you will also make 7 figures by age 30–but it will be the low 7 figures. If you are of very high STEM talent, I am talking international olympiad level, then you can become a quant at a prop shop and then your total comp (salary and bonus) in a good year should breach $100,000,000. I have double checked this number to confirm I typed the correct number of zeroes.

    Still think a commercial pilot is highly paid?

  19. “Now small cities are losing air service. People drive greater distances to airports, or forego air travel altogether.”

    Unfortunately, the inexorable march to the situation described above has been in motion for decades now. The installation and continued expansion of the interstate highway system assures this outcome as the costs of providing air transportation to “Small town, USA” outstrips even the yields received via air service monopoly at some single carrier small airports.

    “One commenter admitted that the 1,500 hour rule is meant to drive up pilot wages rather than promote safety….”

    This is really the stalking horse of the matter. At the present, ALPA represented regional drivers are at the apex of their wage earning potential flying for regional carriers due to rules, supply constraints, & black swan events.

    With other carriers providing air transportation under the same model, some may wonder why the SkyWest proposal draws so much ire. That is because ALPA sees with the potential establishment of a SkyWest 135/380 operation a potential entree for “B” scale pilot wages – pilots flying for SkyWest Charters being contractually paid less than SkyWest Airlines crews.

    Even if one were to assess potential CONTRACTUAL “B” scales as cannard, the mere reality (and economics) of hiring crewmembers with lower than Part 121 required hours for Part 135/380 flying will stand on it’s own economic merit as a defacto “B” scale. (Looking at a job board listing, seems SkyWest Charters has minimum requirement for 1000 hours air carrier experience, and total of 2000 hours – for the left seat.)

    Further – and in some defense of ALPA on what this issue is really about – once established, outside of perhaps limited number of airframes and contractual language associated with specific mainline affiliation service agreements, whats to stop SkyWest from transitioning more flying to their 135/380 operation?

  20. “ There should be different standards for different kinds of operations. There really is something different about a co-pilot with 250, 500, or 750 hours in the right seat of a 50 seat regional jet on a one- to two-hour hop versus flying long haul widebody operations and so it doesn’t make sense to have the same requirement for all forms of commercial operations.”

    This seems a bit dogmatic to say with nothing to back it up?
    What makes 53 people on a CR2 less important than ~200 on an a321 or 300+ on a 77W?
    Frankly, a CR2 is tougher to fly with far more complexity than an a320 series or widebody. The technology is far greater and easier to use than some of the small regional jets.
    Plus, the landing and takeoff portions of flight are often the toughest parts of flying and a regional jet does this far more times per day than a widebody or a320 series.
    I’m not suggesting 1500 hours is the right number but I don’t think you’ve made any case for why a plane with fewer passenger seats should require less regulatory oversight vs a larger plane.

  21. @Certified…
    I’d love to live in your 7-figure fantasy world. lol. Those numbers are 0.1% of most of the people in those industries.
    I have no problem with pilots being compensated well to operate complex machinery, but there’s no reason to ridiculously over-exaggerate the normal compensation of other professions.

  22. A question for the pilots here:
    How many of the fatal commercial aviation accidents in the US for the last…..oh we’ll say 30 years involved pilots that had LESS than 1500 hours?

  23. So many who really don’t know how little they don’t know. BTW, that includes the author of the blog article.

  24. Trippe
    But you just can’t stay away can you?
    By the way, do you have an answer to my question about the accidents?

  25. The other Jake is giving us Jake’s a bad rep lol. Per my commercial pilot brother in law, the current 1500 hours requirement is simply a pilot/union tool to create scarcity and every pilot knows and appreciates this. Our country is just creating yet another unnecessary problem.

  26. Imagine if bus drivers, who also take hundreds of lives in their hands every day, had such leverage.

  27. Except it’s not just 1,500 hours tooling around in the sky. It is qualifying for an Air Transport Pilot category certificate.

    Did you note the requirements?

    Be at least 23 years of age
    Must hold either:
    A commercial pilot certificate with an instrument rating
    Or, meet the military experience requirements to qualify for a commercial pilot certificate, and an instrument rating,
    Or, a foreign airline transport pilot license with instrument privileges
    Medical requirements:
    Hold a 1st class medical certificate to act as Pilot-In-Command
    Hold a 2nd class medical certificate to act as Second-In-Command
    1,500 hours of Total Flight Time
    500 hours of Cross-Country Flight Time
    250 hours as Pilot-In-Command (PIC)
    100 hours of Night Flight Time
    75 hours of Instrument Training
    50 hours of In Class of Rating Sought
    Pass an ATP knowledge test
    Complete and pass an ATP-CTP training program

    Tell me how you are going to do that in a tethered balloon.

  28. the FAA could help the pilot shortage by unclogging it’s bureaucracy. I know one individual is almost a year into getting his 1sr Class Medical, with a nine month wait time from final submission of paperwork to decision..

    As for 1500 hours, not all 1500 hours are alike. 1000 hours around the pattern and on short cross-countries in a C-150 is close to worthless. Maybe a more structured training program, subsidized or paid for by the airlines, would produce qualified pilots in say 750 hours. A mix of multi-engine time, all flights filed IFR, followed by simulator time, some programmed jump seat time, etc etc. Anything to get max exposure to ATC, actual IMC, exposure to airline operational routine. 1500 hours and minimum ATP requirements not as good as 750 hours of higher “quality” time!

  29. Nobody has mentioned a real root cause for the Pilot shortage, and that is the great reduction in number of military pilots being trained. The US military has greatly reduced their pilot numbers, and the number of new pilots being trained. This has now bled over to the airlines as they are not able to simply depend on the military pumping out the pilots that airlines need to maintain their staffing levels. This is one reason JetBlue are now creating their own pilot training systems. And why the cost of accumulating 1500 hours is getting more attention.

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