The 1500 Hour Rule Has Broken The Pilot Pipeline In The U.S.

In 2009, Colgan Air flight 3407 crashed just outside of Buffalo, NY. It was a terrible accident and killed 50 people, including one in a house. Following this, the Federal Aviation Administration (FAA) passed two new regulations in reaction to the crash. One, the flight time and duty rule regulations, also known as FAR 117, put more science to how much rest pilots need. These rules are widely accepted as important and necessary by airlines and pilot groups. The second was a ruling changing the minimum flight hours needed to earn an Air Transport Pilot (ATP) license from 250 hours to 1,500 hours. This has become known as the 1500 Hour rule.

The 1500 Hour rule is not as universally accepted as being helpful as the flight time and duty rule regulation. The rule has made it very expensive to decide to become a pilot — about $250,000 out of pocket and two or three years for people not trained by the military. It also has made it difficult to attract new populations, including women and minorities, into the pilot profession. Most importantly, it is seen by some as actually reducing safety since people spend years getting flight experience in areas not necessarily associated with flying commercial aircraft in a complex system, and end up entering that system unprepared.

Pilot Supply Is Not Keeping Up With Pilot Demand

According to the FAA, there are about 164,000 ATP licenses granted in the U.S. This includes people who can no longer legally fly commercially due to age or illness, and pilots who have not maintained medical certification. Estimates for pilots needing to be hired by the airlines for 2022 range from 12,000 to 15,000. Yet, the current rate of training is expected to produce only about 6,000 pilots this year. This means the pilot pipeline in the U.S. is producing less than half of the pilots needed to support the fleet plans of the U.S. airlines.

The biggest reason for this is the huge hurdle it takes to enter into this career now. Prior to the 1500 Hour rule, prospective pilots could earn their ATP with a Commercial pilots license, a minimum of 250 hours of flying, plus airline-specific training. Typically, new hires had closer to 500 hours before being hired. This process created an apprentice-based solution. New first officers were paired with seasoned captains over their next 1,000 or so hours, learning how to fly in the U.S. airspace system, and into big commercial airports. This apprentice-based system produced the safest air transportation system in the world and operated for over 80 years in the U.S, and was copied by virtually every other nation on the globe.

Having to get 1,500 hours before being hired requires an enormous financial and time commitment that effectively shrinks the number of people who are willing to become pilots. As importantly, these 1,500 hours can all be earned flying small, single engine planes in rural areas, or even flying hot air balloons. During the years of building these hours, most applicants do very little to train themselves in the career they plan to enter, such as flying big jets into New York and Chicago.

Paying Pilots More Will Help, But Not Fix, The Problem

Economists don’t like the word shortage. They see shortages as a pricing problem, and when goods are priced correctly, markets will always clear. Using this idea, the simple answer to this issue would be to raise pilot pay until the incentive to become a pilot overwhelms the investment needed to make it happen. There is little doubt that, to some extent, raising pilot pay is part of a complete solution.

There are two big challenges with this as a unique response, however. The airline pilot career is the second-highest paid in the U.S., behind only medicine. In 2021, the median airline pilot pay in the U.S. was $202,000. Maybe pilots should be paid more than alldoctors eventually, but the point is that there isn’t significant headroom for a career that already is paying its participants at the top end of all career choices. The second is is that the higher pay would go to pilots after they are hired and working for a number of years. This is a long way off to a young person wanting to earn their ATP but looking at three years and $250,000 just to get their first, low-paid pilot job. Yes, eventually they will earn more pay, but at that decision point many other career choices may have more pragmatic economics.

The 1500 Hour Rule Was Not Related To The Cause Of The Colgan Crash

The National Transportation Safety Board (NTSB) ruled that the Colgan crash was primarily due to the pilot inappropriately responding to his situation, and they pointed out that fatigue was a contributing factor. They did not conclude that either of the pilots were inexperienced. In fact each of the pilots had over 2,000 flight hours and so the 1500 Hour rule would not have kept either of them out of that cockpit. They identified that fatigue was a contributing factor, but it was a 7am flight in the morning. To be fatigued at that hour suggests not having enough rest the evening before, but the 1500 Hour rule does nothing about that. No post-Colgan regulation has addressed that.

The families who lost people in the Colgan crash, and anyone who wants the safest air transportation system, deserve regulations that will in fact make the system safer. There is no evidence that the 1500 Hour rule has made our air transportation system safer. There is some evidence that it has been made it less safe. When a child bruises their knee, and the mother kisses the bruise and says everything will be okay, that mother knows the act of kissing does nothing to actually heal the bruise. But it does tell the child that the mother cares, is there for support, and gives the child confidence. The 1500 Hour rule is like that kiss – it makes people feel good that something changed, but the change does nothing to address the NTSB-determined cause of that crash.

No One In The World Has Matched This, And The U.S. Has Become Uncompetitive As A Result

The apprentice-based pilot system, pioneered in the U.S. and used around the world, is still in effect everywhere outside the U.S. Since the 1500 Hour rule was enacted in 2010, 12 years ago, not a single country has matched it. You’d think that if this really was a safety issue, at least some countries would have moved to this new standard by now. The European Union requires a minimum of 230 hours along with specific airline training, and Canada still requires what the U.S. used to — a Commercial license, minimum of 250 hours, and specific training.

Every day, hundreds of foreign airline airplanes land at U.S. airports with first officers using this apprentice-based system. If there is really a safety issue with this, why would the FAA allow all of these flights to operate at our airports? This regulation has put U.S. airlines in a uncompetitive position with foreign airlines worldwide. If there was a clear safety advantage to this, it would be fine being uncompetitive in this way. However, no such safety advantage has been proven for the 1500 Hour rule.

A Practical Solution To The Problem

An outright repeal of the 1500 Hour rule would require an act of Congress, and that is highly emotional, not likely, and would take years even if there were support. But within current FAA authority, Secretary Buttigieg could create a probationary ATP and offer it to pilots with 500 or 750 hours, and specific airline training. This probation could be removed, becoming a standard ATP license, after a pre-defined set of hours and experiences gained on the job and certified by check airmen. This approach still is more onerous than the original 250 hour standard used by the rest of the world, but significantly lessens the financial commitment and time to get into the workplace for aspiring pilots.

This proposal is practical, and puts the U.S. airlines back on a somewhat even playing field as they compete with airlines from the rest of the world. It would still take time to rebuild the pipeline, meaning that for the next few years, the smallest U.S. airlines, including the regional airlines, will still struggle to to find the crews they need. Temporary financial incentives can help this. The real fix, though, is to be able to attract a wide, diverse group of men and women to become commercial airline pilots. With only 5% of ATPs being female today and only 14% non-white, the net can clearly be cast much wider. The training academies started by many airlines are a good way to get started, and having a more realistic target of hours before earning a paycheck will balance the scales and bring supply in line with demand. Most importantly, it will do this with no reduction in safety of our national air transport system.