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