The New ATPA Brief Window Before the Sky Falls?
The new ATP certification test may cost up to $15,000. How will these high costs impact the pool of ATPs available to the airlines?
For any pilot wanting or needing the ATP certificate, the window is about to slam shut on earning that rating at an affordable price. Beginning in August, a new FAR kicks in requiring sharply higher flight experience and training for any pilots who plan to use the ATP in Part 121 operations. Bottom line: The certificate may cost as much as $15,000 more to earn and that has airlines worried about the impact on the potential pilot pool for entry level First Officers. If there's any good news, it's that these changes apply only to the multi-engine ATP. If you're interested in the rating just to have it for insurance purposes, nothing much changes.
Largely as a result of political pressure applied by family members of the deceased in the 2009 Colgan Air Flight 3407 crash near Buffalo, New York to do something—anything—Congress and the FAA mandated regulation changes applicable to airline pilots many consider extraordinary, controversial and of questionable value to safety. There are new, costly training requirements for the Airline Transport Pilot (ATP) Certificate, a requirement that first officers on Part 121 and some other flights hold an ATP and that airline first officers have a type rating for the airplane. The ATP changes have almost all phased in, but a few months are left before the most onerous, and expensive, one becomes effective. For pilots seeking an ATP, there is a window open to pass the written before the cost goes up substantially.
The New Rules
Most of the new ATP requirements have kicked in—for example, the applicant has to have 50 hours in the class of airplane for the rating sought. In plain English, that means 50 hours of multi-engine time for most pilots. If the applicant goes through an approved training course under Part 121, 135, 141 or 142, half of that time can be in a full flight simulator that represents the class of airplane. No matter how you slice it, that’s not cheap—especially since the time-building night freight jobs in Cessna 402s went away years ago.
There are new instrument and cross country time requirements; some can be reduced somewhat if the applicant is going to the correct school or applying for the restricted version of the ATP for right-seaters. However, a very careful reading of the acceptable method of time reduction for aeronautical experience is essential—the new regs are complex. It’s going to be interesting to watch and see how long it will take for an examiner to go through the logbook of an applicant to see if he or she meets the aeronautical experience requirements given all of the exceptions available—if the moon was full on a Friday the 7th, the landings didn’t have to be to a full stop. . .
Things Get Uglier in August
The big deal is the “airline transport pilot certification training program” set out in FAR 61.156. This requirement kicks in on August 1, 2014. It’s staggeringly expensive for a prospective professional pilot and, frustratingly, it’s pretty much the same as a portion of the training a new hire gets at an airline, but now the ATP applicant has to somehow pay for it and pass it before he or she can even take the ATP written. You must complete it successfully and show a graduation certificate from a training provider that has applied for and had its training program approved by the FAA. The training provider must either be an airline operating under Part 135 or 121 or a certified training provider operating under Part 141 or 142. The program must be taught by instructors who hold an ATP and have at least two years of airline experience. I’m curious as to what kind of salary range is going to be necessary to attract and retain instructors with such experience.
As part of the ATP training program, you’ll have to go through at least 30 hours of classroom instruction (a classroom is specified, not on-line training) in aerodynamics, high altitude operations, meteorology, air carrier operations, physiology, communications, checklist philosophy, operational control, minimum equipment list/configuration deviation list, ground operations, turbine engines, transport category aircraft performance, automation, leadership, professional development, crew resource management and—lastly—safety culture.
Along with the classroom instruction you’ll have to buy at least six hours in a Level C (full motion) sim that represents a multi-engine turbine airplane with a max takeoff weight of at least 40,000 pounds. One good thing is that the regs allow the Administrator to approve a deviation from a weight requirement for the simulated airplane—which means that a lot of current bizjet simulators could get approval.
You’ll also need another four hours of sim time, but that can be in a lower cost FSTD of Level four or higher.
I’ve been looking at cost estimates for the ATP certification training program ever since the FAA put out the NPRM on this regulation. According to the AOPA, a Level C sim runs at least $8 million. A room or building, with suitable environmentals, has to be built to house it. Techs have to be hired to keep it working. The instructors have to meet the ATP and two year of airline experience requirement.
Two years ago, AOPA estimated that rental rates for such sims will be $1000 per hour, before considering the cost of building the building and hiring staff. I think that a more realistic number, all things considered, is going to be on the order of $2000 per hour for the six hours in the Level C sim. Based on prices for similar courses at the major simulator training centers, a bare minimum of $15,000 for the ATP certification training program is a fair estimate, with reality probably on the order of $20,000.
A Window of Opportunity
The rules for prerequisites for taking the written (knowledge) portion of the ATP examinations do not change until August 1, 2014. The big deal about that is that you do not have to have to meet the flight time or minimum age requirement when you take the knowledge test. As currently written, the eligibility requirements of FAR 61.153 kick in when you take the practical (flight) test—there is nothing that says you have to have acquired the flight experience required for the rating at the time you take the written.
That means you can take and pass the ATP written (knowledge) exam without meeting the experience requirements for the practical test. If you do so prior to August 1, 2014, your passing test results are good for 24 months from the month in which you took the written. That gives you two years to get the necessary flight experience and pass the practical test without having to go through the painfully expensive new classroom and simulator requirements that will otherwise begin on August 1, 2014. (The FAA explicitly approves this in FAR 61.155(d).) So, if you want to get an ATP, the financial sky is not falling, yet.
However, if you do pass the ATP written prior to August 1, 2014 and do not complete (pass) the practical test within 24 months of the month of taking the written, that written lapses and you have to go through the “airline transport pilot certification training program” specified in 61.156.
Will the Sky Fall?
It is not surprising to me to hear the level of fury expressed at Congress and the FAA for the new ATP rules by pilots who wish to fly professionally and airline executives seeking to hire pilots. A lot of people are going to be watching to see how the new regs play out as the massively higher costs take effect.
For some years, regional airline pilots were hired under the old regs with commercial/instrument/multi-engine tickets, less than 1000 hours of flying time and an education debt that could exceed $50,000. That now seems quaintly cheap. Two years ago, the head of training at a regional airline told me that it was not unusual for 25 percent of their pilots to quit in the first two years because the pay was not enough for them to live on and service their education loans. Student loans are special—Congress mandated that you have to pay them even if you go bankrupt.
The standing joke about the pizza places suddenly losing all their delivery drivers when the commuter airline moved its domicile out of town proved not to be a joke a few years back in Norfolk, Virginia.
How pilots come up with 1500 hours and an ATP prior to being hired by an airline under the new rules is going to be an interesting proposition. Determined individuals have done amazing things. Yet, as requirements get more difficult, the number of successful applicants drops. When requirements are perceived as arbitrary—without rational support on any risk analysis scale—even fewer will bother applying, especially when the reward is perceived as not worth the effort. The smart ones just might go where the rewards are more attractive and the work rules less punitive. When the pool of applicants for airline jobs drops, the ability of an airline to be selective also drops.
The traditional time builder aviation jobs are gone. Do we really want pilots grinding around the pattern getting 1500 of the same hour before going to the right seat of an airliner and thinking we can fix the lack of seasoning by making them fork over money they don’t have for two weeks of training that follows a syllabus designed by a committee reacting to political pressure?
There is a restricted ATP that will allow pilots with certain educational backgrounds and degrees to get into the right seat with fewer total hours. Yet, maddeningly, a pilot who gets a real degree from a top-flight university with something other than an “aviation major”—61.160(b)(1)—while getting his or her ratings through a Part 141 school isn’t eligible for the restricted ATP. So, let’s see . . . come out of school with a load of debt, an “aviation” major, buy multi-engine time, drop $20,000 more for the ATP certification program and then get a $20,000 a year job with an airline, knowing that you can’t use your four-year degree to get into some other line of work if you find you can’t afford to pay your bills. Rational? For some, I suppose.
An optimist at the FAA anticipated that airlines would hire pilots and put them through the training necessary to finish up their ATP, including the ATP certification training program and their written test (as well as obtaining a type rating). That’s why the ATP certification training program can be carried out by Part 135 and 121 airlines. (The airline I spoke with about ATP training said it was not planning to set up such a training program.) Is an airline willing to take such a financial risk on a new hire that does not have an ATP? It’s bad enough it will have to put that new hire through a type rating—according to training personnel at the airlines I spoke with, and who refused to be identified, a pilot without time in type takes two to five times as long in the simulator or airplane to get through a type rating as does a pilot who has spent at least 100 hours in the right seat.
Currently, many air carriers require new hire pilots to sign training agreements under which they will repay the airline the $10,000 to $30,000 in training costs the airline incurred if the pilot doesn’t stay on the job for at least a year or two—or gets fired. “Training” contracts used to be illegal in most states as too close to indentured servitude. Despite coming across as something out of Dickens, legislatures have changed the laws in many states to make them legal.
With the type rating requirement for first officers, the use of training contracts and the amount of money and years for which they will apply may go up. I can’t help but wonder if airlines who set up ATP certification training courses will put that into the mix and either require that pilots pay back from $40,000 to $60,000 if they don’t stick around for three to five years, or keep the new-hire salaries low until the cost of the training is recovered.
Someone is going to have to pay for the expensive new training and certification requirements. As of yet, no one knows whom it will be or how the cost is going to be split between the airlines and the prospective pilots. A lot of people are watching with a lot of interest.
The sky may not be falling, but there isn’t a lot of good news for those aspiring to become airline pilots. If I were seeking my ATP, I’d be doing everything I could to take the written by the end of July and get into position to take the flight test within 24 months of passing the written. If I couldn’t do that, unless some sort of scholarship or government grant program kicks in to cover the cost of the ATP certification training program, I think I’d use what smarts I have to find a job that pays reasonably well and fly for enjoyment and personal transportation.
Rick Durden is the Features/News Editor of AVweb, an aviation attorney and the author of The Thinking Pilot’s Flight Manual, or How to Survive Flying Little Airplanes and Have a Ball Doing it, Vol I.