First Officer Epoch Next August

Rob visiting the captain's seat in a 747.
What are airline pilots really made of?

Pilot employment qualifications are changing.  For the potential first officer at a regional or major airline, this change will be huge.

Currently, the requirements for acting as a first officer or second in command (SIC) of an airliner are simple.  All it takes is a commercial pilot license.  The captain is required to have an airline pilot license, but not the first officer.  This is all laid out in the two paragraphs of the applicable regulation number 121.437.  A commercial pilot license can be obtained after meeting the minimum 250 hours of flight time experience.

Starting on August 1, 2013, the Airline Safety and Federal Aviation Administration Extension Act of 2010 will remove all commercial pilots from domestic, flag, and supplemental operations.  By itself, sec. 216(a)(2)(B)(i) of this Act would require “all flight crewmembers” to hold an airline transport pilot (ATP) certificate, which in turn requires at least 1,500 hours of pilot time experience.  That’s six times the current requirement to become a first officer.

The Federal Aviation Administration (FAA) is wisely using the time before August to develop a regulation that does not require 1,500 hours.  Its latest proposal, dated February 29, 2012, allows graduates of a 4-year degree program to obtain the needed license by meeting the following requirements:

Description New Minimum Proposed Regulation Old Minimum Current Regulation
Age 21 years 14 CFR § 61.153(a)(2) 18 years 14 CFR § 61.123(a)
Education Bachelor’s degree 14 CFR § 61.160(b)
Concentration Aviation major 14 CFR § 61.160(b)
Pilot Time 1,000 hours 14 CFR § 61.160(b)
Flight Time 250 hours 14 CFR § 61.129(a)
Cross-Country Time 325 hours 14 CFR § 61.160(b)(1)
Night Time 100 hours 14 CFR § 61.160(b)(2) 7 hours 14 CFR § 61.129(a)(3,4)
AMEL Time 50 hours 14 CFR § 61.160(b)(3)
Instrument Time 75 hours 14 CFR § 61.160(b)(4) 10 hours 14 CFR § 61.129(a)(3)(i)
PIC Time 250 hours 14 CFR § 61.160(b)(5) 100 hours 14 CFR § 61.129(a)(2)
PIC Cross-Country Time 100 hours 14 CFR § 61.160(b)(5)(i) 50 hours 14 CFR § 61.129(a)(2)(ii)
PIC Night Time 25 hours 14 CFR § 61.160(b)(5)(ii) 5 hours 14 CFR § 61.129(a)(4)(ii)
Pilot Certificate ATP + Type Rating 14 CFR § 121.436(b) Commercial 14 CFR § 121.437(b)

These details are not yet carved in stone, and the Final Rule is scheduled for publication in May 2013.

How Will This Affect Me?

There really is no direct comparison between the “old” and “new” career paths for a traditional flight student.  It would take an extraordinary amount of time and money for a student to complete his or her thousand-hour ATP training during a 4-year degree program.  Under these new requirements, most flight major graduates will have no choice but to seek employment as entry-level employees, flying airplanes that do not require more than one pilot.  This raises many important questions.  For example, a student who becomes a flight instructor, sky dive pilot, or banner tow pilot, is not going to spend 10% of his or her new career flying at night.  How does a flight instructor fulfill the 100-hour night time requirement?  Will flight schools be forced to shift their business hours to encourage more flight training at night?

Many of my classmates have raised concerns about whether or not Eastern Michigan University will qualify as a degree program under the new rules.  On this point, there is good news.  One of the requirements is that the degree be “from an accredited 4-year postsecondary institution.”  According to the Department of Education, Eastern Michigan University is officially accredited by the North Central Association of Colleges and Schools.

Another requirement literally says the pilot must hold “a commercial pilot certificate with an airplane category and instrument rating obtained from an affiliated part 141 pilot school.”  Some former advisers of mine are now eating their words for telling me that my pilot certificate won’t say where I learned to fly!  Yes, the name of the school is not printed on a license, but oh how the times have changed when it becomes necessary to do a background check to see how a license was “obtained.”  Here again, there is good news.  Eastern Michigan University’s affiliated pilot school, Eagle Flight Centre, is one of the six FAA-approved pilot schools in the State of Michigan.

Predictions, Opinions, and More Good News

The new ATP section 61.160, as currently proposed, will make air taxi operators a very attractive employment opportunity for newly minted degree holders.  Air taxis, also known as commuter and on demand operations, fall under part 135 and are exempt from the FAA Extension Act of 2010.  Same goes for corporate flight departments, which fall under part 91.  These businesses will still be able to hire commercial pilots.  The biggest change for them will be a substantial increase in the number of commercial pilots looking for work.

Are these new rules necessary?  The FAA wastes no time in pointing out that the Extension Act was a political reaction by Congress to the 2009 crash in Buffalo, and that the ATP license requirement has no basis in safety literature.  If there had been a problem with commercial pilots causing crashes, the FAA would have simply raised the training requirements for commercial pilot certification.  When responding to whether 750 hours would be an appropriate amount of experience for degree-qualified first officers, only 21 out of 1,300 comments received by the FAA said “750 hours was too low.”  I am disappointed there has been no explanation why the minimum experience level jumped from 750 to 1,000 in the latest proposal.

For me, the bottom line is that the ATP requirement doesn’t make sense.  It creates a new standard that is so far removed from the reality of the existing flight training system that it could actually break the supply of new first officers.  Many successful flight students will take jobs at places that will be uniquely positioned to retain them and to compete against airlines like never before.

This is good for me, though.  By the time I have 1,000 hours of flying experience, I will be qualified to take ATP training.  In this one important aspect, the FAA is actually lowering its standards.  Sure, they did some complicated rule-making to make a “restricted” ATP that is effectively equivalent to the old commercial license.  But by title, and by what it will say on my résumé, I could be an officially licensed airline pilot much sooner and with much less experience than I expected when I started flying in 2010.  Now there’s something to think about!

Next article: 2013 First Officer Qualification Rule

9 thoughts on “First Officer Epoch Next August”

  1. Well-written and thorough. I really appreciated your chart comparison of the old and the proposed new regulations. You bring up a very important point – not only is there an increase in hour requirements for those who want to fly for the regionals (from around 600/700 to now the 1000 for the ATP (if allowed a reduction)), but there is also a increase of requirements within those 100 hours (100 night time requirement, for example). Great that you put a positive spin on it at the end of your discussion.

  2. Rob I told you I would respond….

    First off nice job. Second, I’ll answer some of your questions. One being the night requirement. With the new rule you can expect to spend at least two years instructing. You will have no problem building 100 hours of night time. Think about all the private/Commerical students you will have that require dual night cross countries. Second, from what I was told by management the exemption (1000 hours) might not come into play until the pilot pool is completely soaked up which could be a couple years, so the 1500 hours/ 23 year age requirement is a hard number. I agree this is all bogus, and I feel bad for you guys. I have about 1000TT right now, 400 of that time in a Jet, and I feel comfortable enough like flying the jet is almost like flying the Seminole. Low time dosnt make you a bad pilot. It’s your ability to make good cockpit decisions, something that Colgan captain clearly couldn’t do….

    1. Thank you for reading, Justin! Your perspective is valuable. I do see how a larger proportion of non-solo training time is at night, and that will help. I think other positions such as sky dive pilot will still have some challenges.

      The idea that operators are planning to require 1,500 hours minimum for the next couple years answers another question about what happens on August 1. It seemed there was a potential corner case where a pilot could be in your position with 1,000 hours, unable to take ATP before August 1, and unable to fly after July 31. As long as you get your 1,500 before then, you will be fine, and there won’t be any new hires at 1,000 before then.

      It’s awesome that you have 400 jet time!

      1. Honestly skydive pilots and banner towing is a horrible way to build time. I can make the statement that people don’t really learn to be pilots untill they become flight instructors, I thought I knew it all before I started at Eagle, but I learned way more about flying after getting my CFII/MEI. Those are SO valuable. Also, I need to fly exactly 58 hours a month to take my ATP check ride in August. If I don’t have the time (which I should be ok) we are going to have to take a leave of Absence (either paid or un paid) and build the flight time. That is what I’ve been told.

        1. You know it makes no sense for you to have to leave your job with Eagle, a flying job where you are building flight time in a jet to go build flight time in a Cessna to meet some requirement. Am I the only one who sees the lunacy in this?

  3. When the FAA says accredited four year program what does that really mean? I thought it had to do with the AABI accreditation, I guess nobody will really know until the regulation is actually published in May. I just hope we don’t all get screwed over by this thing.

    1. To answer this specifically, there are two things to look at in the NPRM. First, where AABI is mentioned, it’s not in a context about regulated accreditation. They were one of the participants during the 2010 ANPRM comment period. AABI agreed on “the question of whether academic study leads to a stronger knowledge base.” AABI was also one of 700 participants that “believed in crediting only academics from accredited universities.” They were among those who were against using total time as a prerequisite for degree-qualified ATP and “stated any minimum requirement would be arbitrary.” AABI was also on the Aviation Rulemaking Committee that was mentioned several times, though much of its guidance was rejected by the FAA.

      Secondly, look at the proposed definitions. The FAA proposes to amend § 61.1 with “Accredited means the same as defined by the Department of Education in 34 CFR 600.2.” So it is DoE, not AABI, who would be in charge of this. Also, there is a plain-language paragraph in the Discussion:

      The FAA would recognize those postsecondary educational institutions that satisfy the definition of “accredited” as that term is used by the Department of Education in 34 CFR 600.2. The Department of Education maintains a database of accredited postsecondary institutions and programs ( Prior to taking the ATP practical test, pilots would be required to present an official transcript which validates their eligibility for a restricted privileges ATP certificate. The FAA has proposed to amend § 61.39 to reflect this documentation requirement.

      I hope that alleviates some concerns. This could still change in the Final Rule, but so far so good!

  4. Robert your web site is very helpful! Answered many of my questions.

    Big picture I need R-ATP ASAP

    My back ground ; I have a two year degree and A&P an Aviation Subject and a Pvt and Inst rating with 750 hrs.

    My question: Can you help me find an answer to this question ? I received a reply from an FAA person. The reply to was with my back ground, I need to complete my Commercial and Multi ratings from a Part 141 school to qualify for the R-ATP.

    I have come across a barrier and have not been able to get a straight answer from two colleges and and two part 141 schools that contacted.

    A college in PA said “I need to complete their two year program regardless of my back ground ” coming from the their Chief Pilot starting from Pvt to receive the R-ATP #$%!?

    The second College told me only if I enroll at their school for a degree program ? Not set up to accept students who just need R-ATP.

    A Part 141 school had no clue ? The second Part 141 school has not replied.

    The rules and interpertation seems very subjective and Loose .

    Can you suggest several schools that would accept Pilots already have a Two Year and/or Four Year degree in an aviation Subject and hallow them to complete the reminder of the Flight Training to qualify for thr R-ATP ( in my case I need Comm/Multi

    PF Steven / NY

    1. Hi Steven, most Part 141 flight schools are not authorized for R-ATP. You should contact some of the colleges from the R-ATP list on the FAA website and find out if you can transfer into their program as an Instrument Airplane pilot. I honestly don’t know if it’s possible. When a Chief Pilot tells you he can only certify your eligibility starting with student pilot training, you won’t be able to go from commercial training to R-ATP at that college. Also, the multi-engine rating is not required for R-ATP eligibility, although some colleges may require it.

      As for the degree requirement, that is regulatory. Your 2-year degree doesn’t fulfill the requirements of part 61.160, so you will have to enroll for a new FAA-approved degree to be eligible. I am in a similar situation myself. Unless my degree gets approved retroactively, it doesn’t count toward the airline pilot qualification. I have to look at 61.160(f), which does not require an aviation degree.

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