Small Community Air Service & the Pilot Shortage

Small Community Air Service

& the Pilot Shortage

February 6, 2023

Regional Aircraft Critical to U.S. Air Service Network

Service at U.S. Airports

Regional Airlines Critical to U.S. Air Service Network

State by State Reliance on Regional Airlines

Top 10 U.S. Airports for

Regional Departures

Ranked by total scheduled departures with

regional aircraft in 2021

• Regional airlines are also important at hubs, bringing smaller

community passengers through and beyond.

• Regionals operate more than half the departures at many large

hub airports.

Small Communities in Crisis

• Larger airlines have drawn thousands of pilots from regional

airlines, where pilot shortages preceded the pandemic. The

pipeline of replacement pilots is thousands of pilots below need.

• An acute Captain shortage is yet another symptom of the overall

pilot shortage. Larger airlines draw Captains (and Captain-ready

First Officers) from regional airlines, who can only be replaced by

other Captains. First Officer hiring will be additionally and

artificially constrained by the limited number of eligible Captains,

despite an overall worsening shortage across all ranks.

• Without pilots to fly them, 414 regional jets have already been

parked. Remaining aircraft were flown at a fraction of the norm,

and small community air service is collapsing.

• 76% of U.S. communities have already experienced service cuts.

The average loss among communities with losses was 30% fewer

flights. The situation has continued and will worsen without

intervention.

Sources: UAL 4Q/FY22 Earnings Call, January 18, 2023. See: https://ir.united.com/static-files/5b5b2c9c-aa92-44da-ad37-753035bedd8d. and

“We, along with Delta, American and

Southwest alone are planning to hire

about 8,000 pilots this year, compared

to historical supply in the 6,000 to

7,000 range. Pilots are and will remain

a significant constraint on capacity.”

- Scott Kirby, United Airlines CEO,

January 18, 2023 earnings call

Network Carriers on the Pilot Shortage

“It's really unfortunate that we've had to

reduce service anywhere, most especially to

some of the smaller communities. That's

certainly a result of the issues that we faced

with pilot staffing at our regional airlines.”

– Robert Isom, American Airlines CEO,

January 26, 2023 earnings call

Source: AAL 4Q/FY22 Earnings Call, January 26, 2023. See: https://seekingalpha.com/article/4572686-american-airlines-group-inc-aal-q4-2022-earnings-call-transcript

Network Carriers on the Pilot Shortage

The Pilot Shortage – Data

Qualified Pilot Population is Disproportionately Older

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

• There are 70% more pilots aged 43-64 than there are pilots aged 21-42

• Mandatory retirements will grow in the coming years. Approximately 2,225 pilots will

retire in 2023. Retirements peak, at approximately 3,750, in 2029, remaining high

thereafter.

ATP AMEL Pilots with Valid 1

Class Medicals by Age

Part 121 Airline Pilots must retire at Age 65

Existing Pilots are Rapidly Aging Out

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Decontextualized Data Misleads

Some have proffered misleading data, stripped of relevant context, to suggest

abundant supply of pilots. This is simply inaccurate.

MISLEADING!

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Context Counts with Pilot Qualification Numbers

2022 Produced 9,491 new pilot qualifications (ATP/R-ATP AMEL*), which includes a backlog of certifications

disrupted by Covid in 2020/2021. Once the COVID backlog is accounted for, 2022 produced only 5,386 new

pilots (1,130 below the 5-year average).

(Avg -2020 = 2,517 / Avg -2021 = 1,588)

2022 less backlog = 5,386)

5-year

average

2015-2019

= 6,516

*Part 121 Airline Pilots are required to hold an Air Transport Pilot Certificate with Multi-engine Land Aircraft category class rating (ATP AMEL or R-ATP-AMEL).

ATP AMEL Qualifications Moderated over the Year in 2022

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

FAA’s 2022 monthly issuance rate of ATP/R-ATP AMEL* certificates showed a clear downward trend over the year,

with the highest certifications taking place in the first quarter.

200

400

600

800

1000

1200

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

ATP/R-ATP AMEL Issuances by Month

*Part 121 Airline Pilots are required to hold an Air Transport Pilot Certificate with Multi-engine Land Aircraft category class rating (ATP AMEL or R-ATP-AMEL).

Qualified Pilot Count is Not Keeping Pace with Need

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Despite producing a record number of new ATP AMEL* pilots in 2022 (2,975 above average and 5,491 more than

produced in 2020), the total ATP AMEL population is only 1,961 greater than the prior peak of March 2020. This

further illustrates the clearing of a Covid-disruption backlog and remains far below industry’s need.

*Part 121 Airline Pilots are required to hold an Air Transport Pilot Certificate with Multi-engine Land Aircraft category class rating (ATP AMEL or R-ATP-AMEL).

Future Pipelines Lag Prior Years

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

ME ATP ratings (required for airline part 121 service) have increased, BUT the other categories (pipeline of

future pilots) are not keeping the same pace. The other categories must also grow if there are to be more ME

ATPs in the future.

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Nearly 1 in 5 commercial pilot certificates held by non-U.S. citizens

Commercial certificates are a poor gauge for future ATPs.

Many foreign pilots train in the U.S. but cannot fly here.

What’s Inside the FAA’s Civil Airmen Database?

Some use the FAA’s Air Transport Pilot (ATP) certificate to discuss pilot supply. Notably, more than 1/3 of the

173,161 ATP certificate holders in FAA’s Civil Airmen Database are ineligible for hire.

U.S. ATP

Holders,

160,480,

93%

Non-U.S. ATP

Holders, 12,681,

Other ATPs

48,291, 30%

ATP AMEL Certificated

w/ Current 1st class

medical & under age

65 (112,189),

70%

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Of Remaining, Potentially Eligible Pilots….

• Of the 112,189 remaining ATP potentially eligible pilots, 97,589

are already working for the largest commercial carriers.

• Business aviation and charter operators employ thousands

more ATP pilots not reflected at right – nearly every eligible

pilot is already working.

• Additional disqualifications—in a profession where safety is

paramount—are not quantifiable in the FAA dataset, such as:

• Check-ride failures

• Poor piloting ability

• Instrument proficiency

• Criminal record

• Recency and type of experience

Source: Pilot seniority lists (select airlines only) posted on www.airlinepilotcentral.com as of 1/23/2023

Select Airline Pilot Counts

All RAA Members

18,682

American

15,156

Delta

14,561

United

13,023

Southwest

9,122

FedEx

5,037

JetBlue

4,650

UPS

3,446

Alaska

3,400

Spirit

3225

Atlas

2,500

Frontier

1910

Allegiant

1141

Hawaiian

847

Sun Country

462

Avelo

127

Breeze

300

Total Count

97,589

Pilot Shortage is Parking Regional Aircraft

BLS

Projected

Yearly

Commercial

/ Airline Pilot

Openings

thru 2030 =

18,100

2022*

ATP/R-ATP

new

certificates =

9,491

18,100 –

9,500 =

8,600

potential

pilot shortfall

At 12 pilots

per aircraft,

a shortfall of

8,600 pilots

could park

716 aircraft.

414 Regional

Jets have

already been

parked.

Capacity also

extracted by

lower

utilization of

remaining

fleet.

*2022 output was higher than usual, due to catch up

certifications paused during training – FAA’s five-year average

yearly R-ATP/ATP certification issuance is 6,516 certificates per

year.

Parked Regional Aircraft Cannot Serve Communities

• A4A analysis shows

414 Regional aircraft

have been parked

since 2019.

• 329 small RJs

• 85 large RJs

Pilot Shortage is Reducing Regional Aircraft Utilization

Smallest Aircraft Sharply Reduced (Block hours is a measurement of aircraft use)

Source: Volaire Aviation Consulting Analysis of Scheduled Block Hours by Equipment Type by Month July 2022– January 2023

NETWORK CARRIER BLOCK HOUR CHANGES: JUL 2022 - JAN 2023

Scheduled Block Hours by Equipment Type by Month

July October January Changes Jul - Dec

Mainline 209,357 60.8% 206,579 63.6% 203,335 63.9% -2.9%

Dual Class 112,653 32.7% 101,341 31.2% 99,672 31.3% -11.5%

50-Seat 22,257 6.5% 16,660 5.1% 15,371 4.8% -30.9%

Total 344,267 100.0% 324,580 100.0% 318,379 100.0% -7.5%

Mainline 205,007 71.4% 194,773 72.1% 203,717 74.7% -0.6%

Dual Class 70,882 24.7% 67,701 25.1% 63,877 23.4% -9.9%

50-Seat 11,427 4.0% 7,782 2.9% 5,177 1.9% -54.7%

Total 287,316 100.0% 270,256 100.0% 272,771 100.0% -5.1%

Mainline 176,790 64.5% 168,519 65.3% 177,761 68.9% 0.5%

Dual Class 57,962 21.2% 52,232 20.2% 49,196 19.1% -15.1%

50-Seat 39,223 14.3% 37,334 14.5% 31,133 12.1% -20.6%

Total 273,975 100.0% 258,085 100.0% 258,090 100.0% -5.8%

Group

Mainline 591,154 65.3% 569,871 66.8% 584,813 68.9% -1.1%

Dual Class 241,497 26.7% 221,274 25.9% 212,745 25.1% -11.9%

50-Seat 72,907 8.1% 61,776 7.2% 51,681 6.1% -29.1%

Total 905,558 100.0% 852,921 100.0% 849,240 100.0% -6.2%

Oliver Wyman Research:

• North America will be 17,000 pilots short of need (15% of current workforce) for the next two

years, peak at 24,000 short of need (23% of current workforce) in 2026 and will remain 17,000

(15%) short of need by 2032.

• 84% of recruiters faced challenge or extreme challenge recruiting qualified pilots last year

https://www.forbes.com/sites/oliverwyman/2023/02/02/the-pilot-shortage-may-be-easing-slightly-but-aviation-now-needs-mechanics/?sh=33a417ad2b5e

U.S. BLS Data Shows Pilot Workforce is Shrinking (Despite Pay Increases)

The US Bureau of Labor Statistics (BLS) shows airline and commercial pilots had the second-highest median

pay, behind only medicine. Massive, additional pay increases have been made since 2021.

BLS projects 18,100 openings for airline and commercial each year over the next decade.

Sources: U.S. BLS’ Highest Paying Occupations Report. See: https://www.bls.gov/oes/current/oes532011.htm#top and

U.S. BLS’ Occupations Report. See: https://www.bls.gov/ooh/transportation-and-material-moving/airline-and-commercial-pilots.htm

Median wage for pilots was $202,180, compared to median wage for all occupations of $58,260 in 2021.

Air Service Loss

Small Community Air Service is Collapsing as a Result of the Pilot Shortage;

The Crisis Will Worsen without Intervention.

Air Service Declines

Follow Regional

Airline Industry

Contraction

• Regional airlines operated 41% of U.S. departures in 2021; by 1Q

2023, regional airlines operated just 33% of departures.

• This void is not being filled by larger carriers; 76% of U.S. Airports

have experienced air service loss. The average loss was 30% of

departures.

41%

324 U.S. airports (76%) lost

service – airports losing

service lost average of 30 %

of their flights

152 airports (35%) lost

more than 25% of flights

53 airports (12%) lost more

than half their flights

14 airports (3%) lost all

scheduled, commercial

flights

Source: OAG Published Schedules January 2020 vs. January 2023 (Analysis excludes Alaska)

Smaller Airports Hurt Worst

Comparing January 2020 with January 2023

• 20 large hub airports lost flights;

the average loss was 11%

• 24 medium hub airports lost flights;

the average loss was 15%

• 54 small hub airports lost flights;

the average loss was 19%

• 176 non-hub airports lost flights;

the average loss was 32%

• 50 nonprimary airports lost flights;

the average loss was 45%

https://thepointsguy.com/news/american-cuts-us-cities/

Data Source: OAG Published Schedules January 2020 vs. January 2023

(Analysis excludes Alaska)

https://www.travelweekly.com/Travel-News/Airline-News/Small-communities-see-airlift-vanish-as-pilot-shortage-hits-regional-flyers

Airports that have Lost All

Scheduled Flights:

• San Carlos, CA (SQL)

• Cincinnati, OH (LUK)

• Seattle, WA (BFI)

• Seattle, WA (LKE)

• Williamsport, PA (IPT)

• Atlanta, GA (PDK)

• Grand Canyon West, AZ

(GCW)

• Cleveland, OH (BKL)

• Destin/Ft. Walton

Beach, FL (DSI)

• Morrisville/Stowe, VT

(MVL)

• Mobile, AL (BFM)

• Ogden, UT (OGD)

• Montauk, NY (MTP)

• Dubuque, IA (DBQ)

Airports that have Lost More

than 60% of scheduled flights:

• Fort Dodge, IA (FOD)

• Johnstown, PA (JST)

• Riverton, WY (RIW)

• Alamosa, CO (ALS)

• Kalamazoo, MI (AZO)

• Hilton Head Isl, SC (HHH)

• Sacramento, CA (SCK)

• Las Vegas, NV (BLD)

• Mason City, IA (MCW)

• Pocatello ID (PIH)

• Wenatchee WA (EAT)

• Hawthorne, CA (HHR)

• New York, NY (SWF)

• Yakima, WA (YKM)

• Muscle Shoals/Florence, AL

(MSL)

• Kapalua, HI (JHM)

• Toledo, OH (TOL)

Airports that have Lost More

than 50% of Scheduled Flights:

• Champaign/Urbana, IL

(CMI)

• Decatur, IL (DEC)

• Victoria, TX (VCT)

• Evansville, IN (EVV)

• Columbia, MO (COU)

• Joplin, MO (JLN)

• Akron/Canton, OH (CAK)

• Walla Walla, WA (ALW)

• Burlington, IA (BRL)

• Altoona, PA (AOO)

• Wilkes-Barre/Scranton, PA

(AVP)

• La Crosse, WI (LSE)

• Eau Claire, WI (EAU)

• Wausau WI (CWA)

• Elmira/Corning NY (ELM)

• Newport

News/Williamsburg, VA

(PHF)

• Lansing, MI (LAN)

• Hyannis, MA (HYA)

• Twin Falls, ID (TWF)

• Rochester, MN (RST)

• Everett, WA (PAE)

• Latrobe, PA (LBE)

Major Airlines Have Not and Cannot Replace Most Regional Flights

Regional airlines use aircraft rightsized for smaller markets. When larger aircraft with more

seats can be used, all but the very largest airports lose both destination options and

frequency. Airports of all sizes lose frequency.

Source: OAG Schedule Analyser

Communities Lose Service When Regional Airlines Shrink

Sources: FAA Aerospace Forecast Fiscal Years 2020-2042, Table 27 and OAG Schedule Analyser, July Schedules, US Operations

-1,000

-500

500

1,000

1,500

2,000

2,500

3,000

REGIONAL FLEET COUNT

Total Regional Fleet Change since 2010

Many airports simply cannot support service with larger aircraft at all. Many communities lost all

of their air service when the regional industry contracted.

2010

2013

2017

2021

Small Markets Served by 50 Seat Aircraft are not “Upside Down”

• 50 seat aircraft utilization is

declining because of the pilot

shortage, not "poor market

economics.”

• 50 seat served markets were

growing in ’19 and in ’21,

demonstrating ongoing

demand for air travel in these

markets.

Economic Importance of Air Service

• According to a U.S. Government Accountability Office (GAO) report on

small community air service development released on March 26, 2020:

“Communities of all sizes seek access to air service as a driver for attracting

investment, generating employment, and providing mobility for citizens.

Small communities obtain economic benefits from connection to the global

air transportation network. Direct service to a mainline airline’s hub

provides one-stop access to hundreds of additional destinations around the

globe.”

• According to the Federal Aviation Administration, aviation is important to

economic performance because it supports economic output, attracts

business and tourism, supports local economic development, and helps

retain jobs that might otherwise be relocated elsewhere.

Sources: https://www.gao.gov/assets/700/698730.pdf

and https://www.faa.gov/about/plans_reports/media/2020_jan_economic_impact_report.pdf

• Caterpillar CEO Jim Umpleby: “Locating our headquarters closer

to a global transportation hub means we can meet with global

customers, dealers and employees more easily and frequently.”

• Krystal CEO Doug Pendergast said moving the headquarters to

Atlanta will improve air service to its units.

• “Albemarle has been in Baton Rouge for seven years and has

decided to move its headquarters to Charlotte. One big draw

was better airline service at Charlotte Douglas International

Airport.”

• Charter spokeswoman Anita Lamont: “New York's air service

makes it easier to travel to the 25 states where Charter operates,

and not have two transfers on the flight.”

• Nonstop, global connections were a big reason ConAgra decided

to move from Omaha to Chicago in 2015: “Omaha’s relatively

slim pickings for direct flights to major cities can be a big

detriment when it comes to selling the city.”

• Agriculture giant Archer Daniels Midland cited air service as one

of the benefits of moving its headquarters last year to Chicago

from Decatur, Illinois.

Economic Impact of Air Service Loss

Safety Impact of Lost Air Service

• Without reliable and reasonably frequent air service,

displaced airline passengers become highway drivers.

• The National Highway Traffic Safety Agency projects that an

estimated 42,915 people died in motor vehicle traffic crashes

in 2021, a 16 year high.

• Congress and the Administration must take a multi-modal

approach to transportation safety.

Source: https://www.nhtsa.gov/press-releases/early-estimate-2021-traffic-fatalities

Wages are High; Career Interest is High;

Barriers to Entry are Higher.

The high cost of becoming a pilot puts the career out of reach for most.

Solutions like equitable education financing, expanded training access and

other supports are needed to improve career access, increase pilot supply,

and improve diversity within pilot ranks. Solutions Require Better Pilot

Career Access.

Safety-First Solutions

• Airline outreach, tuition reimbursement, pilot career support,

workforce investments and other strategies will continue.

• High pay has not solved lack of flight education access and financing.

Policymakers must tackle inequitable access to pilot careers.

• Flight education costs exceed student loan caps by $80,000 or more;

those without wealth or credit have inequitable career access. RAA

backs legislation to close the gap, improving pilot supply while

strengthening diversity, equity and inclusion in pilot careers.

• Training-based qualification pathways produce safer pilots vs. hours-

based qualifications, yet access to these proven pathways is limited.

The Airline Safety Act allows FAA to approve training pathways that

enhance safety. FAA must also keep pace with the technological

advantages offered by modern flight simulators. FAA’s decisions

must be based on facts and data, not political pressure.

• Measures like increasing mandatory retirement age to 67 with

robust medical screening and Visa streamlining for qualified pilots,

can provide immediate relief while longer-term solutions take shape.

• All solutions must put safety first and follow the law.

Training-Based Pathways Enhance Safety

Through the Airline Safety Act of 2010, which mandated the FAA’s First Officer

Qualifications (FOQ) Rule, Congress authorized Alternate (R-ATP) Pathways where

a portion of a pilots’ unsupervised flight hours are replaced by intensive

structured training as credit toward qualification.

Military and Academic

Institutions are already

approved for these R-ATP

Pathways, but FAA’s

authority is not limited to

existing programs.

Unbiased, empirical data consistently shows newly-hired pilots

following structured training-based pathways perform better than

hours-based pathways.

More Training =

Higher Safety

• Pilots following hours-based pathways complete training then must

fly hundreds of hours in small, single-engine aircraft with little

resemblance to commercial airliners, before hire. No training is given

during this time.

• Pilots fly alone or with students, often in uncontrolled airspace.

Insurance prohibits flying in weather or other challenging conditions

commercial pilots routinely encounter. Pilots rarely, if ever,

encounter engine outs, wind sheer, unusual altitude/upsets, icing, or

other key skills relevant to commercial flying.

• Training recency is a key component of pilot proficiency. Data shows

the longer the time between training and hire, the worse pilots

performed when hired. Skills soften as training recency fades.

• Structured training pathways give credit for additional training

towards a portion of this unstructured flying. Use of simulators and

other modern training technologies ensure pilots gain relevant

experience alongside superior training. Pilots with these training

credits perform better than pilots with higher flight time when hired.

• Airline-based foundational training pathways improve career access

by shifting costs from aspiring pilots to the airlines who will hire

them, extending career access to those without wealth.

Empirical Data Shows Advantage of Training vs. Hours-Based Qualification

• The Pilot Source Studies (PSS) are independent, academic studies of a pilot’s training and qualification

background relative to success in initial airline training. FAA used PSS2010 to inform development of

the Congressionally-mandated First Officer Qualifications Rule (the Rule), including the Rule’s

structured training pathways. Later studies examined the effects of the rule.

• PSS2015: Pilots hired after the Rule performed worse than before. “The congressionally mandated gap

between earning pilot certificates and beginning airline training reduced the positive effects of pilots’

educational and experience backgrounds.”

• PSS2015 and PSS2018: Successful training completions decreased from 93% before the law to 84%

after the law and Post-Law pilots required significantly more extra (remedial) training and extra Initial

Operating Experience (IOE) to complete training. Post-law pilots needed more than twice as much

extra training than Pre-Law Pilots. By 2018, nearly half (45%) of all new-hire pilots required extra

training.

• Each of the studies found pilots with more than 1,500 hours required more extra training and failed to

complete training more than all other groups. Pilots with fewer than 1,500 hours, had more recent

training graduations, or followed structured training pathways required less extra training and

completed training more often.

For references, including studies, FAA and NTSB presentations, Congressional testimonies and peer-reviewed academic publications, see:

https://www.pilotsourcestudy.org

PSS2015, on the effect of PL 111-216 and the FOQ Rule on

pilot hiring and pilot training in US regional airlines:

“Contrary to intent, PL 111-216 did not create highly successful regional

airline pilots; instead, it eliminated a group of pilots from the pilot pool

who had performed well in the earlier Pilot Source Studies 2010 and

2012. The Pilot Source Study 2015 supports the earlier results—pilots

with fewer than 1,500 total flight hours were more successful than their

counterparts with more total flight hours.”

Source: Smith, MaryJo O.; Smith, Guy M.; Bjerke, Elizabeth; Christensen, Cody; Carney, Thomas Q.; Craig, Paul A.; and Niemczyk, Mary (2017) "Pilot

Source Study 2015: A Comparison of Performance at Part 121 Regional Airlines Between Pilots Hired Before the U.S. Congress Passed Public Law 111-

216 and Pilots Hired After the Law’s Effective Date," Journal of Aviation Technology and Engineering: Vol. 6: Iss. 2, Article 4.

see: https://docs.lib.purdue.edu/cgi/viewcontent.cgi?article=1151&context=jate

Too Few Pilots Access R-ATP (Training-Based) Pathways Today

Source: data files distributed monthly by Registry Services and Information Management Branch, AFB-730, Federal Aviation Administration

Just one-third of recent pilots used enhanced training pathways in lieu of hours-based pathways. Access to

these pathways is limited by financial, geographical and access barriers. Airlines and premier flight training

institutions have asked FAA to approve more of these proven pathways when they enhance safety.

Structured Training Pathway Proposals

have Been Mischaracterized.

Some stakeholders – who perceive a benefit from a labor shortage –

deny a pilot shortage and have sought to discredit airline solutions,

even when solutions improve career access and training and enhance

safety. The claims used to further this agenda are readily disproven.

Flight Time, Flight Training and The Mischaracterization of a Rule

• The chart at right is titled: “Airline Pilot Training Matters,”

but airlines have never proposed to reduce training. No

training is provided at all, as pilots accumulate flight

hours. Airlines propose to add more training.

• The chart at right credits only the Airline Safety Act with

reduced airline fatalities since 2009, but the Rule they

are characterizing was not implemented until August

2013. There were no U.S. commercial airline fatalities

during the intervening four years.

• To the contrary of this chart, FAA found “no accident

value benefit” to increasing flight time. FAA instead

credits the “continuous evolution of safety oversight, risk

detection and response, and collaborative information

sharing” for safety improvements. NTSB has never taken

a position on flight hours, and instead refuted any link

between hours and accidents.

• Hundreds of voluntary and mandated safety advances

have since taken place, like pilot training and screening

improvements and updated fatigue rules. Aircraft and

training technology advances further enhanced safety.

Misleading!

NTSB has refuted any connection between

flight time and accidents.

FAA Source: https://www.faa.gov/newsroom/out-front-airline-safety-two-decades-continuous-evolution

NTSB Source: https://www.govinfo.gov/content/pkg/CHRG-111shrg56412/html/CHRG-111shrg56412.htm

FAA: Safety Oversight, Culture, Programs Reduced Fatalities

“The commercial aviation system in the United States operates at an

unprecedented level of safety. During the past 20 years, commercial aviation

fatalities in the U.S. have decreased by 95 percent as measured by fatalities per

100 million passengers.

We achieved this safety record because the FAA continually evolved in how it

approaches safety oversight – both in detecting risks and in responding to the

risks identified. Key to this approach is a longstanding commitment to sharing

data through an open and collaborative safety culture to detect risks and address

problems before accidents occur.

Our comprehensive, risk-based safety oversight process consists of several key

elements: the Commercial Aviation Safety Team; the Aviation Safety Information

and Sharing program; voluntary reporting programs; Aviation Safety Infoshare;

the FAA’s Safety Assurance System; airline Safety Management Systems; and the

FAA’s approach to ensuring compliance..”

Source: “Out Front on Airline Safety: Two Decades of Continuous Evolution, FAA. Thursday, August 2, 2018

See: https://www.faa.gov/newsroom/out-front-airline-safety-two-decades-continuous-evolution

NTSB: No Correlation between Flight Time and Accidents

Senator Byron Dorgan: “Ms. Hersman, do you want to comment on the

issue of ATP license and the practice of requiring only a commercial

license for the right seat? Has that played a role, in your judgment, in

anything that you have investigated?”

The Honorable Deborah A.P. Hersman, NTSB Chair: “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 for

different categories... we don't have any data supporting the number of

hours for a certificate, or its correlation with being involved in an

accident”

Source: S. Hrg. 111-605 AVIATION SAFETY: ONE YEAR AFTER THE CRASH OF FLIGHT 3407, exchange between Senator Byron Dorgan, Chairman of the

Senate Subcommittee on Aviation Operations, Safety and Security and the Hon. Deborah A.P. Hersman, Chairman, National Transportation Safety

Board. February 25, 2010. See: https://www.govinfo.gov/content/pkg/CHRG-111shrg56412/html/CHRG-111shrg56412.htm

FAA: “No Quantifiable Benefit” from 1,500 Flight Hours

“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.”

Source: FAA OFFICE OF AVIATION POLICY AND PLANS ECONOMIC ANALYSIS DIVISION (APO-300) FINAL REGULATORY EVALUATION PILOT CERTIFICATION

AND QUALIFICATION REQUIREMENTS FOR AIR CARRIER OPERATIONS, June 2013. See: https://www.regulations.gov/document/FAA-2010-0100-1925

Let Experienced Pilots Fly

While Congress pursues long-term policy solutions that improve pilot training and career access,

short term solutions are needed to mitigate against additional air service collapse. One such

solution is raising the pilot retirement age to keep more experienced pilots (and particularly,

Captains, in place).

• In 2007, the retirement age for pilots in the United States was raised from 60 to 65 after medical reports

concluded age had an ‘insignificant impact’ on performance in the cockpit and there were safety

precautions already in place to prevent accidents in case of incapacitation.

• Fifteen years of subsequent data demonstrates raising the pilot age did not detract from safety.

• Despite positive health and longevity trends, as well as improved medical diagnostic and

preventive/predictive tools, the mandatory retirement age for pilots remains capped at 65 for part 121

pilots. However, pilots over the age of 65 are already safely serving in airline Part 135 operations. These

experienced pilots have the additional benefit of providing mentorship and support to younger pilots.

• Canada and nine other countries have no mandatory retirement age. Japan has a retirement age of 68.

• Pilots must maintain a first-class medical certification, which must be renewed every six months for

pilots in this age range. Such pilots who meet FAA’s stringent health standards can continue to fly safely.

• Several U.S. lawmakers introduced the “Let Experienced Pilots Fly Act” in July of 2022, to raise the age for

pilots engaged in commercial aviation operations. RAA supports this legislation and encourages its

reintroduction and passage.

Structured training proposals deserve consideration based on

their safety value alone. Many of the solutions to enhance

aviation safety also improve career access among those facing

financial and other barriers of entry today. As long-term

solutions are implemented, short-term solutions like raising the

pilot age provided are needed.

It’s time for a fact-based conversation.

For more information or questions, please contact [email protected].