INITIAL PILOT 

TRAINING 

Better Management 

Controls Are Needed 

to Improve FAA 

Oversight 

Report to Congressional Requesters

November 2011 

GAO-12-117 

United States Government Accountability Office

GAO 
 United States Government Accountability Office 

Highlights of GAO-12-117, a report to 

congressional requesters 

November 2011 

INITIAL PILOT TRAINING 

Better Management Controls Are Needed to Improve 

FAA Oversight 

Why GAO Did This Study 

Regional airlines have experienced the 

last six fatal commercial airline 

accidents, and pilot performance has 

been cited as a potential contributory 

factor in four of these accidents. As a 

result, Congress and others have 

raised questions about, among other 

issues, the initial pilot education and 

training required before pilots can be 

hired by airlines, at which time they 

receive further training. The initial 

training is provided by pilot schools 

overseen by the Federal Aviation 

Administration (FAA). 

As requested, this report discusses 

(1) the various types of U.S. pilot 

schools, how they compare, and 

associated issues; (2) key similarities 

and differences between the U.S. and 

international approaches to pilot 

training; and (3) how and to what 

extent FAA carries out oversight of 

pilot training and certification. To 

address these issues, GAO reviewed 

literature, legislation, regulations, and 

FAA documents and inspection and 

enforcement data; interviewed agency 

and industry officials; and studied the 

training approach in Europe because 

of the different training model and 

visited four European countries. 

What GAO Recommends 

To improve oversight of pilot 

certification, GAO recommends that 

FAA develop a comprehensive system 

to (1) measure its performance in 

meeting the agency’s annual 

inspection requirements for pilot 

schools and pilot examiners and (2) 

better understanding the nature and 

scope of discretionary inspections for 

flight instructors. FAA generally agreed 

with our recommendations.

What GAO Found 

The approximately 3,400 pilot schools in the United States can be divided into 

three types: (1) flight instructor based, (2) vocational, and (3) collegiate. The 

school types vary in several ways, but all pilot students must pass the same 

knowledge and flight tests to obtain a pilot certificate from FAA. Airline operations 

have evolved operationally and technologically, but the pilot training 

requirements for certification of commercial pilots were last revised in 1997. FAA 

and some industry stakeholders have indicated that current requirements for 

commercial pilots should incorporate additional training to improve the 

competency of entry-level regional airline pilots. FAA has initiated or planned a 

number of efforts to address these issues and recently enacted legislation 

requires FAA to implement regulations to increase pilot requirements for airlines 

by August 2013. 

Example of a Single- and Multi-Engine Training and a Regional Airline Jet 

Sources: Cessna (single-engine trainer), Piper (multi-engine trainer), and Bombadier (regional jet). 

The U.S. and Europe both offer the same pilot certifications but the training 

models differ, in part, due to training philosophies and other circumstances. The 

U.S. training approach emphasizes proficiency on actual flight training, while 

Europe’s approach tends to emphasize academic instruction with more 

knowledge training requirements and testing. European pilot schools have also 

developed more comprehensive student screening processes than in the U.S. 

FAA has an annual inspection program that includes the oversight of pilot 

schools, pilot examiners, and flight instructors, the gatekeepers for the initial pilot 

training process. GAO analysis of FAA inspection data showed a 78 percent 

completion rate of the required inspections for pilot schools in fiscal year 2010, 

but, due to insufficient information, GAO was unable to determine completion 

percentages for prior years. Similarly, GAO could not determine 1) whether FAA 

completed the required inspections for pilot examiners or 2) the reasons that the 

discretionary inspections of flight instructors—which are generally optional—were 

conducted. Furthermore, FAA’s national office does not adequately monitor the 

completion of annual inspection activities due, in part, to an inability to aggregate 

inspection data from the local district offices that conduct the inspections. Thus, 

FAA does not have a comprehensive system in place to adequately measure its 

performance in meeting annual inspection requirements, which could make it 

difficult to ensure regulatory compliance and that safety standards are being met. 

View GAO-12-117. For more information, 

contact Gerald L. Dillingham, Ph.D., at (202) 

512-2834 or dillinghamg@gao.gov. 
Page i GAO-12-117 Pilot Training 

Letter 1 

Background 3

Pilot Schools’ Training Varies, and Although All Students Must Pass 

the Same Test, Concerns Exist Related to the Quality of the 

Testing and Other Training Requirements 11

European Pilot Training Differs from the U.S. System, in Part Due 

to Varying Philosophies and Circumstances 29

FAA Completed Most Required Inspections of Pilot Schools, but 

Oversight of Examiners and Instructors Is Difficult to Assess 36

Conclusions 45

Recommendations for Executive Action 46

Agency Comments and Our Evaluation 46

Appendix I Scope and Methodology 49 

Appendix II Nature and Scope of the Supply of and Demand for Airline Pilots 55 

Appendix III GAO Contact and Staff Acknowledgments 64

Tables 

Table 1: Training and Total Flight-Hour Requirements for FAA’s 

Three Main Pilot Certificates—Private, Commercial, and 

Airline Transport Pilot 6

Table 2: Comparison of Pilot Certifications and Training Standards 

of ICAO, FAA, and EASA 30

Table 3: Completion Percentage of Required Inspections for Pilot 

Schools with Part 141 Certificates for Fiscal Year 2010 37

Table 4: Agencies, Organizations, Associations, Schools and Airline 

Interviewed 51

Table 5: Organizations Contacted by Country 53

Table 6: Airline Transport Pilot Certifications Issued from 1999 

through 2009 from Pilot Schools Operating under Part 61, 

Part 141, and Part 142 62

Contents 
Page ii GAO-12-117 Pilot Training 

Figures 

Figure 1: The Typical Path to Become a Commercial Airline Pilot 8

Figure 2: Examples of Single- and Multi-Engine Aircraft Used by 

U.S. Pilot Schools and a Multi-Engine Jet Used by 

Regional Airlines 9

Figure 3: The Number and Types of Pilot Schools across the Eight 

FAA Regions 13

Figure 4: Differences in Regulatory Requirements and General 

Characteristics of U.S. Pilot Schools 15

Figure 5: SkyWest Airlines’ Flight Training Device Used to Test 

Pilot Applicants 22

Figure 6: Full-Motion Flight Simulator at Arizona State University 25

Figure 7: The 230 Enforcement Cases for Pilot Schools with Part 

141 Certificates from Fiscal Years 2006 through 2010 39

Figure 8: The 9,016 Inspections of Pilot Examiners from Fiscal 

Years 2006 through 2010 41

Figure 9: The 178 Enforcement Cases for Flight Instructors from 

Fiscal Years 2006 through 2010 44
Page iii GAO-12-117 Pilot Training 

Abbreviations 

AABI Aviation Accreditation Board International 

ALPA Air Line Pilots Association 

AOPA Aircraft Owners and Pilots Association 

CAPA Coalition of Airline Pilots Associations 

EASA European Aviation Safety Agency 

EIS Enforcement Information System 

FAA Federal Aviation Administration 

FITS FAA Industry Training Standards 

IATA International Air Transport Association 

NASA National Aeronautics and Space 

 Administration 

NPG National Program Guidelines 

NTSB National Transportation Safety Board 

PTRS Program Tracking and Reporting Subsystem 

SPAS Safety Performance Analysis System 

UAA University Aviation Association 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

without further permission from GAO. However, because this work may contain 

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 
Page 1 GAO-12-117 Pilot Training 

United States Government Accountability Office

Washington, DC 20548 

November 4, 2011 

Congressional Requesters 

The United States’ aviation transportation system is an important 

component of the U.S. economy and one of the safest and most efficient 

systems in the world. However, the continued integrity of this system 

depends in part on the roughly 3,400 U.S. pilot schools providing welltrained pilot candidates for airlines. This is particularly true for regional 

airlines, which hire and train pilots from these schools, whereas large 

mainline airlines tend to hire and train pilots who already have experience 

at regional airlines.1

 Although the large mainline airlines have an 

unprecedented safety record, in recent years regional airlines, which 

account for about 53 percent of the nation’s commercial flights,2

 have 

experienced a number of fatal accidents; specifically, the last six fatal 

commercial airline accidents involved regional airlines. The National 

Transportation Safety Board (NTSB) has cited pilot performance as a 

potential contributory factor in four of these accidents, including the one in 

February 2009, in Buffalo, New York, involving Colgan Air, Inc.3

 As a 

result, Congress and others have raised questions about, among other 

issues, the initial pilot education and training required before pilots can be 

hired by airlines, at which time they receive further training. The initial 

training is provided by pilot schools overseen by the Federal Aviation 

Administration (FAA).4

You asked us to examine the initial pilot training system in the United 

States, which includes private and commercial pilot certification (license), 

up to the training provided once a pilot is hired by an airline. Because 

other countries have approached initial training for future airline pilots 

differently, we also studied the training approach in Europe to help inform 

 

1

Regional air carriers are airlines that generally operate aircraft seating fewer than 90 

passengers, and mainline carriers operate aircraft seating 90 or more passengers. 

2

Regional Airline Association, 2010 Annual Report, September 2010. 

3

NTSB Aircraft Accident Report, 2010, Loss of Control on Approach, Colgan Air, Inc., 

Operating as Continental Connection Flight 3407, Bombardier DHC-8-400, N200WQ, 

Clarence Center, New York, February 12, 2009. NTSB/AAR-10/01. Washington, D.C. 

4

The U.S. Department of Transportation Office of Inspector General is conducting an audit 

of FAA’s oversight of air carrier pilot training programs at the request of Congress. 

 
 

Page 2 GAO-12-117 Pilot Training 

our review. This report discusses (1) the various types of U.S. pilot 

training organizations, how they compare, and issues associated with 

training; (2) the key similarities and differences between the U.S. system 

and international approaches to pilot training; and (3) how and to what 

extent FAA carries out its oversight role of pilot training and certification. 

In addition, you noted that the worldwide demand for commercial airline 

pilots has also caused concerns to be raised about the ability of the 

current training system to provide an adequate number of pilots and 

asked that we examine this issue. We examined what is known about the 

future demand for and supply of U.S. commercial airline pilots and report 

our findings on this issue in appendix II. 

To address our objectives and the pilot supply appendix, we reviewed 

and synthesized published literature related to pilot certification and 

training issues in the United States and comparable international pilot 

training systems; pilot statistics; types and requirements of pilot training 

schools; FAA regulatory training requirements for different levels of pilot 

certification; FAA oversight of U.S. pilot training system. Literature 

sources included federal agency documentation, academic journals, trade 

publications, conference presentations, and newspaper articles. We also 

reviewed the Federal Aviation Regulations related to training and 

certification for pilots, and legislative provisions that addressed issues 

related to pilot training. Specifically, we reviewed the Airline Safety and 

Federal Aviation Administration Extension Act of 2010 related to pilot 

training requirements and the certification of pilots operating for airlines.5

We interviewed officials at the Department of Transportation (DOT), FAA, 

and NTSB. We conducted semistructured interviews with representatives 

from a range of aviation stakeholder organizations, including pilot unions, 

pilot school associations, general aviation groups, commercial aviation 

industry associations, international aviation associations, and regional 

airlines (see app. I for the complete list of stakeholders we interviewed). 

We visited pilot training stakeholders in six states—Arizona, Florida, 

Georgia, Indiana, Maryland, and Utah—which included FAA regions that 

had higher number of pilot schools, higher number of pilot certificates 

issued in 2009, presence of FAA regional and district offices, and 

presence of regional airlines’ offices. In our state visits, we interviewed 

officials at FAA regional and district offices, regional airlines, pilot schools, 

and college aviation schools. Because we selected these six states as 

 

5

Pub. L. No. 111-216, 124 Stat. 2348 (2010). 
 

Page 3 GAO-12-117 Pilot Training 

part of a nonprobability sample, our site visit data cannot be generalized 

to the nation. Through the combination of site visits and semistructured 

telephone interviews, we interviewed representatives of 24 regional 

airlines that transported about 97 percent of regional passengers in 2009, 

according to the Regional Airlines Association’s 2010 annual report. We 

also analyzed data from FAA’s data systems for fiscal years 2006 through 

2010 that provided information on the oversight activities related to pilot 

certification and training. We tested the reliability of the inspection and 

enforcement data that we received from FAA with electronic testing of the 

data elements that we used, obtained, and reviewed documentation 

about the data and the systems that produced them, and interviewed 

knowledgeable FAA officials. We found the data to be sufficiently reliable 

for our purposes. 

In addition, we conducted site visits to a nonprobability sample of 

European countries: France, Germany, the Netherlands, and the United 

Kingdom. We focused on the European pilot certification and training 

requirements because they offer a different model than the United States. 

Specifically, individuals with no previous flying experience are generally 

trained from the beginning to be commercial airline pilots. The site visits 

allowed us to obtain information on European countries’ pilot standards, 

as well as their efforts to revise their piloting performance and training 

standards to competency-based training models. During these site visits, 

we interviewed officials at the European Aviation Safety Agency (EASA) 

(Europe’s aviation regulatory organization), civil aviation authority 

officials, and representatives from international and European aviation 

stakeholder groups, airlines, and pilot training schools. 

We conducted this performance audit from March 2010 through 

November 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. See appendix I 

for more information about our scope and methodology. 

Civil aviation in the United States can be generally divided into two broad 

categories—general aviation and commercial aviation. General aviation 

comprises all aviation activities other than military and commercial 

airlines. All civilian students are trained in the general aviation sector until 

they are hired as airline pilots. Commercial aviation generally refers to 

Background 
 

Page 4 GAO-12-117 Pilot Training 

businesses that carry passengers or cargo for hire or compensation. To 

operate as a commercial airline, a business must have an airline 

operating certificate issued by FAA, based on federal aviation regulations, 

which is determined by the type of commercial service being provided.6

Airlines that provide scheduled commercial service are often grouped into 

two categories. Mainline airlines are the traditional large airlines that 

provide domestic and international passenger service on larger aircraft 

such as American Airlines or Delta Airlines. Regional airlines, such as 

Mesa and Piedmont Airlines, also provide domestic and international 

passenger service, generally using aircraft with fewer than 90 seats and 

serving smaller airports. The international service that regional airlines 

provide is confined to border markets in Canada, Mexico, and the 

Caribbean. More than 13,000 regional airline flights operate daily, which 

represents more than half of the number of U.S. domestic flights. 

As the federal agency responsible for regulating the safety of civil aviation 

in the United States, FAA is responsible for the administration of pilot 

certification (licensing) and conducting safety oversight of pilot training. 

Regulations for pilot certification and training are found in three different 

parts of the Federal Aviation Regulations—Parts 61, 141, and 142.7

 All 

pilots are subject to a series of certification requirements established by 

FAA, but the requirements vary depending on the type of training 

environment.8

 Part 61 recognizes six basic types of pilot certification: 

 

6

Federal aviation regulations are found under title 14 of the United States Code of Federal 

Regulations. Part 135 of Title 14 prescribes rules governing the commuter or on-demand 

operations to hold an air carrier certificate. Nonscheduled-service airlines are generally 

issued a Part 135 certificate by FAA and operate aircraft other than turbojet-powered 

airplanes having no more than nine passenger seats and a payload capacity of 7,500 

pounds or less. Part 121 prescribes rules governing the domestic, flag, and supplemental 

operations to hold an air carrier certificate. Scheduled-service airlines are generally issued 

a Part 121 certificate by FAA and operate turbojet-powered airplanes or airplanes with 

more than nine passenger seats or airplanes having a payload capacity of more than 

7,500 pounds. 

7

Part 61 prescribes the minimum training, knowledge, and experience requirements for 

acquiring a pilot certificate. Part 141 prescribes the requirements for issuing pilot school 

certificates and the general operating rules applicable to a holder of the certificate. Part 

142 prescribes the requirements governing the certification and operation of aviation 

training centers. 

8

14 C.F.R. Part 61. 
 

Page 5 GAO-12-117 Pilot Training 

student, sport, recreational, private, commercial, and airline transport.9

Part 61 also establishes the core training requirements for each pilot 

certification, which describes the eligibility requirements, aeronautical 

knowledge and flight proficiency standards, and the required flight hours 

(see table 1). Pilot training can be provided to students by flight 

instructors under Part 61.10 Part 141 outlines the specified personnel, 

aircraft, facilities, curriculum, and other operating requirements that 

approved pilot training organizations (schools) must meet in order to hold 

an operating certificate from FAA. Part 142 outlines specific requirements 

for training centers that primarily relate to the advanced training provided 

to pilots by employers, such as airlines. Our report focuses on the initial 

pilot training that students are provided until they are hired as airline 

pilots; thus, advanced training for pilots is not within the scope of our 

study.11

 

9

The student pilot certificate is necessary to begin pilot training to work toward a 

recreational, sport, or private pilot certificate under the direct supervision of a flight 

instructor. The recreational pilot certificate was introduced in 1989 and limits pilots to stay 

within 50 nautical miles of their departure airport unless other conditions are met. The 

sport pilot certificate was introduced in 2004 and allows pilots to fly smaller, light, less 

complex, one or two-seat airplanes without the limitations of recreational pilots. The 

private pilot certificate allows the pilot to fly solo and carry passengers in any aircraft for 

which they are qualified, but not to fly for compensation. The commercial pilot certificate 

allows a pilot to be compensated for flying and to be hired for a variety of aviation jobs 

(e.g., air ambulance, law enforcement, agricultural spraying, corporate and charter flights, 

and banner towing), including first officer positions with airlines. The airline transport pilot 

certificate is the highest level of pilot certification, requires the highest amount of 

cumulative flight time, and is necessary to qualify as a captain for an airline. 

10The holder of a valid flight instructor certificate may provide pilot training and instruction 

for the pilot certification in any aircraft for which they are qualified. (14 C.F.R. § 181). 

11The DOT Office of Inspector General has initiated reviews related to FAA’s oversight of 

airline pilot training, pilot fatigue, and professionalism issues, and whether there is a direct 

relationship among commercial aviation accidents, pilot experience, and pilot 

compensation. 
 

Page 6 GAO-12-117 Pilot Training 

Table 1: Training and Total Flight-Hour Requirements for FAA’s Three Main Pilot Certificates—Private, Commercial, and 

Airline Transport Pilot 

Type of pilot 

certificate 

Part 61 required ground school training 

hours for aeronautical knowledge 

Part 61 

required 

flight hours

Part 141 required ground 

school training hours for 

aeronautical knowledge

Part 141 

required 

flight hours

Private pilot No minimum hours specified; minimum 

knowledge subject areas must be covered 

40 35 35 

Commercial pilot No minimum hours specified; minimum 

knowledge subject areas must be covered 

250 35 190 

Airline transport pilot No minimum hours specified 1,500 40 1,500 

Source: GAO presentation of information contained in Part 61 and Part 141of Title 14 of the U.S. Code of Federal Regulations. 

To obtain a private, commercial, or airline transport pilot certificate from 

FAA to perform various aviation activities, individuals typically have to 

successfully complete pilot training and pass the following two FAA tests 

for each pilot certificate and rating obtained:12

 A knowledge test assesses applicants’ understanding of the 

aeronautical knowledge areas required for a specific certificate or 

rating and can be administered in written form or by a computer. 

 A practical test consists of a flight test and an oral examination. The 

flight test assesses applicants’ knowledge of the areas of operations 

of an aircraft and the ability to demonstrate the maneuvers in an 

aircraft while in flight. The oral examination is conducted by having an 

applicant respond to random questions related to aviation knowledge 

and aircraft operations before, during, and after the flight test, and 

typically lasts between 1 and 2 hours.13

 

12A rating defines the conditions or specific aircraft in which a pilot certificate may be used. 

In addition, endorsements may be issued by FAA to further define conditions or specific 

aircraft not covered by ratings. 

13Part 61 requires that pilots must be able to read, write, speak, and understand the 

English language, or a pilot certificate cannot be issued. Each pilot applicant must 

demonstrate an ability to mentally grasp critical information that often must be read and 

understood while conducting a variety of aviation operations. 
 

Page 7 GAO-12-117 Pilot Training 

To become a certified commercial pilot,14 which is currently the minimum 

requirement for being hired by an airline as a first officer, individuals also 

must undergo several steps of pilot training and certification in 

accordance with FAA regulations.15 Once cleared by the medical 

examination, students obtain a medical certificate and a student pilot 

certificate from FAA.16 Figure 1 shows the typical progression of training 

and certifications required to become an airline pilot. 

 

14A pilot with a commercial pilot certificate can be employed to tow banners and fly 

sightseeing operations or can be employed as a first officer for a regional airline. 

15In commercial aviation, the pilot in command (captain) of an aircraft is the person aboard 

the aircraft who is ultimately responsible for its operation and safety during all phases of 

flight, as well as when it is operating or moving on the ground, in accordance with FAA’s 

rules of the air. The second-in-command (first officer) is the second pilot of an aircraft, and 

has the authority to assume command of the aircraft in the event of incapacitation of the 

captain. However, control of the aircraft is normally shared equally between the captain 

and first officer during flight. 

16To be eligible for a student pilot certificate, an applicant must be at least 16 years of age 

and hold at least a third-class medical certificate. Student pilots are generally not allowed 

to operate an aircraft in solo flight unless certain FAA requirements are met. 
 

Page 8 GAO-12-117 Pilot Training 

Figure 1: The Typical Path to Become a Commercial Airline Pilot 

Figure 2 shows examples of the progression from single-engine trainer, to 

multi-engine (i.e., jet) trainer—used by some pilot schools to provide 

students with the multi-engine rating—to the much larger, faster jet used 

by regional airlines. Once commercial pilots complete the process of 

initial training, they are qualified to apply for a first officer pilot position at 

an airline. Entry-level positions are typically at regional, and not mainline, 

airlines; mainline airlines typically draw from regional airlines for their 

pilots. If hired, pilots must complete the airline’s new hire training, which 

consists of indoctrination, ground and aircraft systems, simulator training, 

and the initial operating experience, wherein the pilot applies what they 

learn in the previous training phases. The airline submits these training 

programs for approval by the FAA to ensure they meet Part 121 

requirements. 

Obtain a private pilot certificate from FAA by completing the necessary

knowledge and flight training

Obtain an instrument rating from FAA by completing the necessary knowledge and

flight training (allows a pilot to fly during periods of reduced visibility or when the

ground reference is obscured)

Obtain a commercial pilot certificate from FAA by completing the necessary knowledge

and flight training (required in order to be compensated for performing flying activities)

Obtain a multi-engine rating from FAA by completing the necessary knowledge and

 flight training (required to be qualified to fly aircraft with more than one engine) 

Obtain employment as a pilot for a charter or corporate operation or first officer

for a regional airline

Build flight hours and experience as a flight instructor by teaching new pilot students

how to fly (optional) or through employment in a variety of commercial aviation jobs

Source: GAO.
 

Page 9 GAO-12-117 Pilot Training 

Figure 2: Examples of Single- and Multi-Engine Aircraft Used by U.S. Pilot Schools and a Multi-Engine Jet Used by Regional 

Airlines 

As part of its oversight responsibility, FAA has safeguards in place to 

ensure that pilot applicants are provided the necessary training and 

undergo complete and thorough pilot certification examinations. The 

National Program Guidelines (NPG), initiated in 1985, are oversight policy 

guidelines developed annually by FAA for its eight regional offices and 

their associated local district offices for oversight of pilot schools, pilot 

Sources: Cessna, Piper and Bombardier. 

27’ 2” / 36’ 1”

2,450 lbs

4

Length/wingspan

Maximum takeoff weight

Passenger capacity

Cruise speed

Range

Length/wingspan

Maximum takeoff weight

Passenger capacity

Cruise speed

Range

Length/wingspan

Maximum takeoff weight

Passenger capacity

Cruise speed

Range

Cessna 172 Skyhawk (single-engine trainer) Piper Seminole PA-44 (multi-engine trainer) Bombardier CRJ700 (regional jet)

106’ 1” / 76’ 3”

72,750 lbs

70-78 

122 knots 473 knots

696 nautical miles 1,218 nautical miles 

27’ 7” / 38’ 7”

3,800 lbs

4

162 knots

700 nautical miles
 

Page 10 GAO-12-117 Pilot Training 

examiners, and flight instructors.17 The NPG identifies required 

inspections and optional inspections.18 As part of this oversight process, 

FAA uses the Program Tracking and Reporting Subsystem (PTRS) for 

scheduling and recording inspection records and findings for NPG 

inspections of pilot schools, flight instructors, and pilot examiners.19

Additionally, FAA uses the Enforcement Information System (EIS) for 

tracking and reporting information about any enforcement actions the 

agency takes for statutory or regulatory violations.20

As a member of the International Civil Aviation Organization (ICAO), the 

United States conforms to international standards and recommended 

practices for pilot training and certification.21 ICAO is the international 

body that, among other things, promulgates international standards and 

recommended practices in an effort to harmonize global aviation 

standards. These standards and recommended practices are developed 

to ensure that civil aviation throughout the world is safe and secure. ICAO 

has no enforcement powers and only establishes recommended 

standards and guidelines, e.g., licensing requirements for flight crew 

personnel, including pilots. Therefore, ICAO members (known as 

contracting states) decide whether to incorporate the standards and 

recommended practices into national laws or aviation regulations. 

 

17FAA appoints individuals as designated pilot examiners to conduct various pilot 

certification-related activities on behalf of FAA. 

18Required inspections are identified by FAA’s national office as the mandatory core 

inspections necessary for FAA to fulfill its statutory and regulatory oversight 

responsibilities. Accomplishment of these inspections is essential to provide reasonable 

assurance of continued compliance with regulations, standards, and safe operating 

practices. Planned inspections are identified at the regional and district levels and are 

comprehensive targeted inspections. They make up the depth and substance of each 

office’s annual work program and FAA district offices tailor them to the changing local 

aviation environment. 

19PTRS was implemented in 1990 and is one of FAA’s data management and analysis 

systems used, among other things, to record inspections of flight instructors, pilot schools, 

pilot examiners, and other job functions. 

20EIS is the primary internal tool for FAA in initiating enforcement actions and for tracking 

of enforcement and compliance cases and their outcomes. 

21ICAO members, including the United States, are not legally bound to act in accordance 

with ICAO standards and recommended practices. However, if members decide to deviate 

from some of the ICAO standards and recommended practices, they are obligated to 

notify ICAO of differences. ICAO is a sovereign body, consisting of 190 members. Each 

member is entitled to one vote, and decisions are determined by majority vote. 
 

Page 11 GAO-12-117 Pilot Training 

The roughly 3,400 U.S. pilot schools can be divided into three categories: 

(1) non-collegiate flight instructor-based schools, (2) non-collegiate 

vocational pilot schools, and (3) collegiate aviation schools. The training 

provided by the school varies in the minimum requirements for the flight 

and ground school hours required for each certification level, level of 

oversight provided by FAA, and level of educational instruction being 

provided by type of school. However, all student pilots have to 

successfully complete ground and flight training and pass the same 

knowledge and practical tests prior to receiving a pilot certificate from 

FAA. Nevertheless, there is no consensus and little empirical evidence on 

how the different pilot training schools compare in preparing professional 

pilots for the commercial airline industry. In addition, modern aircraft used 

by regional airlines have evolved and the operational demands have 

increased on pilots in high-altitude and complex airline operations; yet, 

U.S. pilot training requirements for certification of commercial pilots were 

last revised in 1997. For example, it is possible for an individual to obtain 

all levels of pilot certifications (i.e., private, commercial, and airline 

transport) in a general aviation flying environment in a single-engine 

aircraft. However, in order to qualify to be hired by an airline, a 

commercial pilot would also need to obtain instrument and multi-engine 

ratings. Some stakeholders, including representatives of regional airlines, 

we interviewed said the current training regulations for commercial pilots 

should be revised to incorporate additional training that would improve the 

competency of entry-level first officer applicants. FAA has initiated several 

efforts to address issues related to pilot training and certification testing. 

Recent legislation requires that FAA develop regulations increasing pilot 

certification requirements for all airline pilots. 

Approximately 3,400 pilot schools exist in the United States and the most 

basic difference among the types of schools is the training environment 

provided to the students. For the reporting purposes of our study, we 

divided them into three categories: (1) non-collegiate flight instructorbased schools, (2) non-collegiate vocational pilot schools, and (3) 

collegiate aviation schools. 

 Non-collegiate flight instructor-based schools (Part 61). Pilot training 

conducted under Part 61 regulations is often provided by an 

individual, for-hire flight instructor who can operate independently as a 

single-instructor school at a local airport with a single aircraft on which 

to train students. Other flight instructor-based schools operate as a 

more traditional training school with a small, physical facility located at 

a particular airport. These schools are the most common type (see fig. 

Pilot Schools’ 

Training Varies, and 

Although All Students 

Must Pass the Same 

Test, Concerns Exist 

Related to the Quality 

of the Testing and 

Other Training 

Requirements 

The Three Different Types 

of Pilot Training Schools 

Vary in Type of Training, 

but All Prepare Students to 

Take the Same FAA Tests 
 

Page 12 GAO-12-117 Pilot Training 

3). The majority of students that complete training in non-collegiate, 

flight instructor-based schools are generally interested in recreational 

flying, although most commercial pilots in the United States also 

undertake this type of training as the initial path toward becoming an 

airline pilot. Flight instructor-based schools offer flexible training 

environments to meet specific students’ needs as long as they pass 

the final tests. These schools are not subject to direct FAA oversight 

beyond the initial certification and subsequent renewal of the flight 

instructor’s certificate. However, flight instructors may be inspected by 

FAA when a triggering event occurs regarding the training being 

provided, such as being involved in an aircraft accident. 

 Non-collegiate vocational pilot schools (Part 141). Vocational schools 

elect to apply for an operating certificate from FAA to provide pilot 

training under Part 141 regulations. Part 141 regulations require these 

schools to meet prescribed standards with respect to training 

equipment, facilities, student records, personnel, and curriculums.22

Vocational schools must have structured and formalized programs and 

have their detailed training course outlines or curriculums approved by 

FAA. Curriculums can vary in content, but FAA provides fundamental 

core training guidelines that must be followed within the curriculum for 

the school to receive a certificate.23 These schools do not allow the 

flexibility of flight instructor-based schools as the training sequence 

outlined in the curriculum cannot be altered. FAA requires annual 

inspections of these schools, unlike flight instructor-based schools. 

 Collegiate aviation schools (Part 61 or Part 141). Pilot training is also 

provided through 2- and 4-year colleges and universities, which 

typically offer an undergraduate aviation-based degree along with the 

pilot certificates and ratings necessary to become a commercial pilot. 

In general, most of the collegiate aviation schools provide pilot training 

under a Part 141 certificate, although they can provide training under 

Part 61. Collegiate schools that provide training under Part 61 

regulations generally offer similar structured, curriculum-based 

training as collegiate schools with a Part 141 certificate. 

 

22In August 2011, FAA issued a rule that, among other things, will allow vocational pilot 

schools to use internet-based training programs without requiring the schools to have a 

physical ground training facility. The rule will become effective October 31, 2011. 76 Fed. 

Reg. 54095 (August 31, 2011). 

2314 C.F.R. § 141.55. 
 

Page 13 GAO-12-117 Pilot Training 

Figure 3 displays how each of the three types of pilots schools are 

dispersed across the United States. 

Figure 3: The Number and Types of Pilot Schools across the Eight FAA Regions 

Source: GAO analysis of FAA and Aircraft Owners and Pilots Association information; Map Resources (map).

Nebr.

Kans.

Iowa

Mo.

N.Mex.

Tex.

Okla.

Ark.

La.

Miss.

Ky.

Tenn.

Ala.

Fla.

Ga.

S.C.

N.C.

Ore.

Idaho

Mont.

Wyo.

Utah

Colo.

Wash.

Nev.

Ariz.

Calif.

Hawaii

Pa.

Va.

N.H.

Mass.

N.Y.

Maine

Vt.

W.Va.

R.I.

Conn.

N.J.

Del.

Md.

D.C.

1

2

N.Dak.

S.Dak.

Minn.

Ill. Ind.

Wis. Mich.

Ohio

5

6

7

Alaska

3

Alaskan

Region

Central

Region

Eastern

Region

Great Lakes

Region

Northwest Mountain

Region

Southern

Southwest Region

Region

Western-Pacific

Region

4

8

6 Southwest Region

Instructor schools:

College schools:

359

20

Vocational schools: 57

7 Southern Region

Instructor schools:

College schools:

576

25

Vocational schools: 106

8 Eastern Region

Instructor schools:

College schools:

505

21

Vocational schools: 76

Total

Instructor schools:

College schools:

Overall nationwide:

2,873

159

3,477

Vocational schools: 445

5 Central Region

Instructor schools:

College schools:

236

9

Vocational schools: 11

1 Northwest Mountain

Region

Instructor schools:

College schools:

293

23

Vocational schools: 58

2 Western-Pacific

Region

Instructor schools:

College schools:

352

25

Vocational schools: 87

3 Alaskan Region

Instructor schools:

College schools:

14

1

Vocational schools: 5

4 Great Lakes Region

Instructor schools:

College schools:

538

35

Vocational schools: 45
 

Page 14 GAO-12-117 Pilot Training 

Note: The total number of schools is approximate because a comprehensive list for the various types 

of schools does not exist. The total number of schools was provided by the Aircraft Owners and Pilots 

Association (AOPA) as of June 2010. Association officials noted that information is entered into the 

listing database by the schools and could not guarantee accuracy and the currency of the data. FAA 

maintains only a current list of the pilot schools with a Part 141 operating certificate. Since most of the 

pilot schools are not directly tracked by FAA, the AOPA listing is considered the best available. We 

reconciled the AOPA total list of schools with FAA’s current list of pilot schools with a Part 141 

operating certificate as of June 2011. We eliminated the duplicate schools and added schools from 

the FAA list to the total number of schools. 

For the most part, all pilot schools must provide training that includes both 

classroom and flight training.24 Classroom training, or ground school, 

provides students with the required aeronautical knowledge and cognitive 

skills necessary to perform the tasks required to become a pilot. Flight 

training focuses on learning how to manipulate the controls of an airplane 

and make it perform certain maneuvers. Regardless of the type of school, 

flight instructors must teach students by demonstrating and explaining, on 

the ground and in the air, the basic principles of flight (e.g., airspace, 

aerodynamics, weather factors, and Federal Aviation Regulations). The 

number of training flight hours required for pilot certification varies by the 

aviation regulations being used to provide pilot training. Because training 

under Part 141 regulations requires a school to use an FAA-approved 

curriculum, fewer hours of actual flight training are required than under 

Part 61.25 Figure 4 shows the differences in general characteristics of the 

types of U.S. pilot schools. 

 

24Training under Part 61 regulations for the private and commercial pilot certificates can 

accomplish the ground school training requirements through instruction from a flight 

instructor or through an approved home-study course. 

25For the airline transport pilot certificate, the same number of total hours is required 

whether pilot training is being conducted under Part 61 or Part 141 regulations. 
 

Page 15 GAO-12-117 Pilot Training 

Figure 4: Differences in Regulatory Requirements and General Characteristics of U.S. Pilot Schools 

Note: Although a training curriculum does not require FAA approval under Part 61, flight instructors 

must cover the minimum knowledge subject areas outlined in the regulations. 

a

Not all collegiate aviation schools have a Part 141 certificate. Therefore, for collegiate schools that 

provide training under Part 61, no FAA approval is needed for the training curriculum used for 

training. 

FAA regulations do not prescribe the entry requirements, selection 

criteria, and screening procedures for students seeking entry into U.S. 

pilot schools, and as a result, they could vary considerably among 

schools. In general, pilot schools admit those students who can pay for 

the training; however, FAA sets a minimum age requirement for each pilot 

certification and requires a current FAA medical certificate and that every 

pilot student is able to read, speak, write, and understand the English 

language.26 FAA’s long-standing requirement for English proficiency 

complies with the 2008 ICAO standard that all private, commercial, or 

airline transport pilots who operate internationally have a pilot certificate 

with the level of English language proficiency. If a person is determined to 

be proficient during the FAA practical test for pilot certification, FAA 

issues pilot certificates with an “English Proficient” endorsement to attest 

that the pilot meets the ICAO standard. 

One of the distinctive characteristics of collegiate schools is that they are 

generally accredited academic programs, which recognizes a level of 

 

26Additionally, the Transportation Security Administration requires pilot schools to verify a 

student’s proof of U.S. citizenship. 

Type of pilot school Knowledge

test

Ground school

and flight training

Practical

test

FAA-approved

curriculum

Degree

granted

Accreditation

Flight instructorbased (part 61)

Vocational

(part 141)

Collegiate

(part 61 or 141)

Source: GAO.

a
 

Page 16 GAO-12-117 Pilot Training 

program quality.27 However, a recently-created organization, the Flight 

School Association of North America, implemented an accreditation 

program in August 2011 for non-collegiate pilot schools intended to 

establish an educational quality standard.28 According to association 

officials, accrediting non-collegiate pilot schools will help to level the 

playing field with the collegiate schools and assist consumers in 

comparing pilot schools. 

Regardless of the type of pilot schools that students attend, once training 

has been completed pilot candidates must pass the same knowledge and 

practical tests to obtain a pilot certificate.29 FAA uses a multiple-choice, 

knowledge test to measure the extent to which applicants for FAA pilot 

certificates have mastered the required aeronautical knowledge areas 

provided in ground school. To pass, applicants must achieve an overall 

score of 70 percent or higher. However, concerns have been voiced by 

some aviation stakeholders related to whether the current knowledge test 

actually requires students to learn the material, as opposed to simply 

studying sample test questions from publicly available sources. Literature 

related to pilot certification and training issues and some aviation 

stakeholders have pointed out that FAA testing is generally based on rote 

memorization. They stated that this encourages instructors and students 

to focus on memorizing test questions to pass the required FAA 

knowledge test, rather than developing a true understanding of the 

material. In 2004, the National Aeronautics and Space Administration 

(NASA) published a study on FAA’s pilot knowledge tests.30 NASA found 

 

27Institutional accreditors review and accredit entire educational institutions. Program 

accreditors review and accredit specific programs or subject area offerings within an 

educational institution, such as the Aviation Accreditation Board International (AABI). AABI 

is an independent body that advances aviation education through accreditation and is the 

only program accreditor for collegiate, non-engineering aviation education for both 2-year 

and 4-year programs. 

28The Flight School Association of North America is a membership-based association that 

represents pilot schools and firms that provide products or services to the pilot training or 

aviation industry. 

29Some vocational and collegiate aviation schools with a Part 141 certificate are granted 

examining authority by FAA, as a privilege of their Part 141 certificate, which allows them 

to recommend their graduates for some of the initial pilot certificates and ratings (except 

flight instructor certificates, airline transport pilot certificates and ratings, and jet type 

ratings) without the pilot candidates having to take the FAA knowledge or practical tests or 

both. 

30NASA, “FAA Pilot Knowledge Tests: Learning or Rote Memorization?” Ames Research 

Center, Moffett Field, California, January 2004. 
 

Page 17 GAO-12-117 Pilot Training 

that many applicants completed the test in far less time than would be 

required for the average human to even read the questions and answers 

on the test—indicating that students had memorized the questions and 

answers—which raises concerns about the extent to which students 

actually mastered the material. 

There is little empirical research that has been conducted comparing the 

extent to which different types of pilot schools prepare pilots for the 

commercial airline industry. We reviewed a pilot source study, published 

in 2010, authored by professors from several accredited collegiate 

aviation schools that researched the impact of collegiate aviation training 

on preparing students to be regional airline first officers.31 The 

researchers analyzed data on how 2,156 new-hire pilots performed in the 

training programs of six regional airlines from 2005 through 2009. The 

study found that the new-hire first officer pilots with the highest rate of 

success—in terms of the amount of extra training needed to complete 

training tasks and fewer number of times tasks were not completed—in 

the airline training: (1) were graduates of accredited college flight degree 

programs, (2) had experience as flight instructors, and (3) had accrued 

between 500 and 1,000 flight hours. We reviewed the study and 

determined that, while statistically significant, the results of this research 

showed small differences in the correlations that supported these three 

conclusions. Phase II of the study, completed in early 2011, expanded the 

research to include testing of multiple variables with the same dataset, 

but the researchers did not report the results of the tests they conducted 

of their data. Phase III is currently underway and is expanding the current 

dataset to include more than six regional airlines. Phase IV will include 

more detailed background data on the newly hired pilots to determine 

relationship factors. 

 

31FAA, International Journal of Applied Aviation Studies, Pilot Source Study: An Analysis 

of Pilot Backgrounds and Subsequent Success in US Regional Airline Training Programs

(Oklahoma City: August 2010). The study was conducted by a consortium of aviation 

university researchers in response to FAA’s Advance Notice of Proposed Rulemaking for 

soliciting comments and recommendations on whether FAA should consider crediting 

specific academic study in lieu of flight hour requirements. 75 Fed. Reg. 6164 (Feb. 8, 

2010). FAA was subsequently required by law to consider allowing specific academic 

training courses to count toward the 1,500 flight hour requirement. Pub. L. No. 111-216, § 

217(d), 124 Stat. 2348, 2368 (2010). 

Little Information Exists 

for Examining and 

Comparing How the 

Different Types of Pilot 

Schools Prepare Pilots for 

Airline Operations 
 

Page 18 GAO-12-117 Pilot Training 

Other than the 2010 pilot source study, our literature review found that 

little other academic study exists and there is no consensus about how 

well the different types of pilot schools prepare commercial pilots for 

airline operations. We received a variety of perspectives from industry 

representatives and some anecdotal information that suggested that one 

major benefit to completing a structured training program that is the 

training provides better aeronautical knowledge (ground school) than an 

unstructured learning environment. Officials from two regional airlines, 

two collegiate aviation schools, and four industry associations with whom 

we spoke generally agreed with the results of the initial phase of the pilot 

source study. Officials from the Regional Airline Association (RAA) told us 

that the broad-based curriculum used by vocational and collegiate 

aviation schools is the better method for preparing a person for a 

professional airline career.32 Furthermore, officials from 6 of the 12 

industry associations and one mainline airline we interviewed considered 

the quality of education at many of the collegiate aviation schools to be 

the highest level of civil aviation pilot training because collegiate schools 

are designed to produce professional pilots for airlines, rather than for 

other aviation jobs. 

Collegiate curriculums also cover a broad range of areas above FAA 

minimum training requirements. In addition, representatives from all but 

one of the regional airlines we interviewed generally told us they strongly 

preferred, but do not require, first officer candidates trained in collegiate 

aviation schools because they perform better in their airline’s training 

program when hired.33 Due to limited screening, training structure, and 

variability of educational content, according to some of the regional airline 

officials, flight instructor-based schools are less likely to produce first 

officers that are prepared immediately upon completing the training to 

enter the workforce and succeed in an airline environment. On the other 

hand, stakeholders from 4 of the 12 industry associations pointed out the 

large number of pilots that matriculate through flight instructor-based 

schools and many are hired by regional airlines without any performance 

issues. Representatives from two of the regional airlines indicated that the 

 

32The Regional Airline Association, founded in 1975, represents regional airlines and 

provides technical, educational, and promotional support to the 32 members and their 

supply company partners. 

33U.S. mainline airlines generally require pilot candidates to have a college degree, but not 

necessarily an aviation-related degree. 
 

Page 19 GAO-12-117 Pilot Training 

professional pilot experience gained through commercial aviation 

positions after completing pilot training is more important than the type of 

pilot school attended. 

Several industry stakeholders have stated that current training 

requirements for commercial pilots are not aligned with today’s 

commercial airline environment. FAA requires the same initial training for 

a pilot hired as a first officer of a regional airline carrying passengers as it 

does for a pilot hired to fly for a commercial non-airline operation, for 

example crop dusting.34 The Air Line Pilots Association (ALPA) has 

suggested that FAA revise the regulations to make a clear distinction 

between training and certification requirements for airline operations and 

those for other types of commercial operations. ALPA contends the 

regulations were developed in an era in which commercial pilots were 

hired by airlines in small, slow, propeller-driven aircraft or as flight 

engineers on jet-powered aircraft. It would traditionally take several years 

and thousands of flight hours before these pilots were given an 

opportunity as a first officer of jet transports.35 However, according to 

ALPA, it is not uncommon today for newly hired pilots to be hired directly 

into airline training programs to become first officers of high-altitude, 

complex aircraft carrying 50 or more passengers, the type of aircraft that 

warrants pilots with more knowledge and greater skills than the new-hire 

airline pilots of the past. Officials from two industry associations and eight 

regional airlines advocated for a separate pilot certification track with 

additional training requirements specific to being an airline pilot. Because 

airline pilots are responsible for the safety of the flying public, according 

to ALPA, it is reasonable that they should be held to a higher standard of 

competency, knowledge, and training than pilots in other flight operations. 

 

34In practice, regional airlines do typically require newly hired first officers to have a 

certain level of experience above the regulatory flight hour minimums required to obtain a 

commercial pilot certificate, typically hiring pilots that have spent several years working up 

through commercial non-airline jobs, i.e., on-demand and cargo operations. However, the 

extent that they do this may vary based on the cyclical dynamics of the supply of and 

demand for pilots. 

35A flight engineer is the third crewmember on an aircraft that requires a three-person 

flight crew, but this position is seen less often as airlines replace older planes with newer 

aircraft that require only two-person crews. 

Pilot Training 

Requirements for a 

Commercial Pilot 

Certificate Are Not Aligned 

with Airline Operations 
 

Page 20 GAO-12-117 Pilot Training 

Additionally, requirements for a commercial pilot certificate do not 

emphasize training in some areas—like decision-making and using 

modern technologies—that are directly related to the airline pilot 

profession. 

 According to FAA and other stakeholders, the regulations regarding 

ground school and flight training, as well as the test standards for a 

commercial pilot certificate, generally emphasize the mastery of 

maneuvers and individual tasks to determine competence. The 

emphasis is on development of motor skills to satisfactorily 

accomplish individual maneuvers—whereas only limited emphasis is 

placed on decision-making—unlike in scenario-based training that 

emphasizes improving operational experience.36

 In addition to traditional skills of flying, navigating, and 

communicating, pilots in today’s newer aircraft have to manage 

automation, information displays, and other new technologies. 

According to the FAA Industry Training Standards’ guidance material 

for the commercial pilot certificate, a growing number of pilots are 

being hired by regional airlines as first officers to operate aircraft with 

these advanced avionics and systems.37 While these pilots may gain 

flying experience and spend years building flight time in commercial 

non-airline jobs or as flight instructors, this experience may be 

accumulated in smaller, slower, and less advanced aircraft. Modern 

aircraft offer advanced avionics and performance capabilities and 

many of these new aircraft travel faster and further than older 

generation commercial aircraft. While generally considered 

enhancements, these modern technologies require increased 

technical knowledge of newer systems and avionics and new skills for 

 

36According to literature we reviewed, scenario-based training uses real-world situation 

that introduces situations and circumstances that pilots face in routine flight operations as 

learning experiences. This training method emphasizes the development of critical 

thinking and flight management skills, rather than solely on traditional maneuvers-based 

training skills. Maneuvers-based training emphasizes the mastery of individual tasks or 

elements, such as the development of competency and motor skills to satisfactorily 

accomplish individual piloting maneuvers. 

37The FAA Industry Training Standards program (referred to as FITS) is a partnership 

between FAA, industry, and academia to create scenario-based training materials to help 

pilot schools train pilots for practical application of knowledge and skills of technicallyadvanced aircraft. The FITS commercial pilot syllabus, developed in 2007, is the accepted 

training method to use in developing a specific FITS curriculum. 
 

Page 21 GAO-12-117 Pilot Training 

managing automation and computerized flight and navigation 

systems. 

According to literature, as airspace complexity and air traffic density 

increase, airline pilots must have increased situational awareness, 

understand risk assessment, and have a complete understanding of 

managing the automation of the aircraft.38 The current training 

requirements and testing for a commercial pilot certificate do not 

emphasize the development of these skills. 

Representatives from 10 regional airlines, 4 pilot schools, and 2 industry 

associations we interviewed said the current training regulations for 

commercial pilots should be revised to incorporate additional training 

requirements that would improve the performance capabilities of the first 

officer applicants that seek employment at airlines, such as exposure to 

advanced jet concepts and simulation,39 aircraft unusual attitude (i.e., 

upset and stall recovery),40 flight crew coordination and environment,41

and scenario-based training. However, when pilots are hired by airlines, 

these types of training are provided by the airline to ensure that pilots are 

adequately competent in these and other advanced training areas—some 

required by FAA for airline operations. For example, FAA regulations for 

 

38However, recent concerns have been raised by industry stakeholders that federal 

regulations and airline operating procedures require airline pilots to have a greater 

reliance on the computerized flight management and automation of today’s aircraft. As a 

result, the implications of decreased opportunities for pilots to manually fly an aircraft 

could potentially result in an increase in accidents and incidents for pilots who are 

suddenly confronted with a loss of computerized controls or emergency situations but 

unprepared to respond immediately or make errors in doing so. 

39Advanced jet training is designed to give instruction in airline flight crew operations in a 

multiengine aircraft, emphasizing the transition of the professionally qualified pilot to a 

highly skilled member of an airline flight management team. Course topics include crew 

resource management, flight crew training techniques, high speed and high altitude 

programming of automatic flight control systems, transport aircraft flight techniques, 

turbojet operations in all flight regimes and in difficult operating conditions, and use of 

advanced avionics. 

40Aircraft upset is a dangerous condition that occurs when an airplane encounters an 

unexpected event that threatens loss of control of the aircraft and may result in an 

accident. Upset recovery training aims at improving a pilot’s ability to maneuver and 

recover an actual airplane from a serious upset to a normal operating condition. 

41Crew (or cockpit) resource management training is designed to improve pilots’ team 

management, situational awareness, communications, task allocation, and decisionmaking skills in an airline crew environment. 
 

Page 22 GAO-12-117 Pilot Training 

airline operations require that all pilots are provided crew resource 

management training as part of the airline’s new hire and recurrent 

training programs. According to ALPA, the lack of specific training 

requirements to be a commercial airline pilot results in a wide range of 

initial training experiences, not all of which are well suited for the 

commercial airline industry. To compensate, some regional airlines, such 

as SkyWest Airlines, use various flight training devices to screen pilots 

during the hiring process to gauge their piloting skills (see fig. 5). 

However, if additional training is required by FAA for pilots prior to being 

hired by an airline, the students would likely be responsible for the extra 

costs involved and would add to the total costs of pilot training borne by 

the student. (For more information on the costs associated with pilot 

schools, see app. II.) 

Figure 5: SkyWest Airlines’ Flight Training Device Used to Test Pilot Applicants 

The industry concerns about current training regulations for commercial 

pilots and incorporating additional initial training requirements to improve 

Source: GAO.
 

Page 23 GAO-12-117 Pilot Training 

first officer applicants’ performance capabilities could be addressed by 

the Airline Safety and Federal Aviation Administration Extension Act of 

2010 for all airline pilots.42 Currently, while a captain for a commercial 

airline is required to hold an airline transport pilot certificate—the highest 

level of pilot certification and requiring the highest number of total flight 

hours—a first officer is required to hold only a commercial pilot certificate, 

i.e., requiring a minimum of 250 flight hours.43 However, the recent law 

will require that each pilot (captain and first officer) must have an airline 

transport pilot certificate, which currently requires a minimum of 1,500 

total flight hours.44 Individuals interested in becoming a first officer for a 

regional airline generally complete training from pilot schools with a 

commercial pilot certificate and possess about 300 to 500 flight hours. 

The 2010 law directs FAA to conduct a rulemaking and effect the 

changes no later than August 2013.45 According to FAA, it will issue a 

notice of proposed rulemaking regarding the increased requirements in 

the fall of 2011. Representatives of the regional airlines we interviewed 

were concerned this legislation will reduce airlines’ hiring flexibility and 

make it harder to find qualified first officers that possess an airline 

transport pilot certificate. 

As another potentially relevant factor, the law stated that the FAA 

Administrator may allow specific academic training courses—beyond the 

additional courses required by the legislation to raise the minimum 

requirements for the airline transport pilot certificate—to be credited in 

lieu of flight hours needed to obtain an airline transport pilot certificate. 

According to FAA’s First Officer Qualifications Aviation Rulemaking 

Committee Report,46 well-structured training programs that feature 

integrated academic content and flight experience optimize the pilot 

 

42Pub. L. No. 111-216, §217 (c) (1), 124 Stat. 2348, 2368 (2010). 

4314 C.F.R. § 61.129(b). 

44Pub. L. No. 111-216, §217(c)(1),124 Stat. 2348,2368 (2010). 

45Pub. L. No. 111-216, §217(f), 124 Stat. 2348, 2368 (2010). 

46FAA, The First Officer Qualifications Aviation Rulemaking Committee Report: 

Recommendations Regarding Rulemaking on Flight Experience, Training, and Academic 

Requirements Prior to Operating as a First Officer in Part 121 Air Carrier Operations, 

September 10, 2010. The committee was composed of representatives of AABI, ALPA, Air 

Transport Association, AOPA, Coalition of Airline Pilots Associations, National Air Disaster 

Alliance-Foundation, National Business Aviation Association, Pilot Career Initiative, 

Regional Air Cargo Carriers Association, and RAA. 
 

Page 24 GAO-12-117 Pilot Training 

learning process, and the committee supported new, higher-level 

minimum certification requirement for first officers. To support the concept 

that academic training courses should be credited for some of the 

additional total flight hours, the report outlined a system for crediting 

academic training courses based on the sources of pilot training, e.g., 

vocational pilot schools, collegiate aviation schools, or military. The 

Coalition of Airline Pilots Associations (CAPA) and National Air Disaster 

Alliance-Foundation presented dissenting opinions to this approach in the 

report and suggested that academic courses, while necessary, should not 

replace an increase in total flight hours required in the law.47

Many of the collegiate aviation schools provide specialized training in a 

flight simulation training device using realistic scenarios, including some 

coursework and advanced flight training in jet aircraft systems and airline 

operational procedures. For example, Embry-Riddle Aeronautical 

University’s Aeronautical Science degree program is designed to prepare 

graduates for a career as a professional pilot in multi-crewmember, jet 

aircraft. Courses include communication theory and skills, aircraft turbine 

engines, crew resource management, aviation weather, jet transport 

systems, and optional upset recovery training. Officials who represented 

10 of the 24 regional airlines we interviewed listed some of these types of 

courses as examples that FAA could require as part of pilot schools’ 

training curriculums that would improve the skill level and competency of 

applicants seeking to be hired as first officers. 

Some collegiate aviation schools—and some large flight instructor-based 

and vocational pilot schools—have developed relationships with the 

training departments of some regional airlines, referred to as bridge 

programs, in order to qualify their students with advanced training 

procedures involving regional jet simulators.48 Students enrolled in a 

 

47CAPA is a trade association, established in 1997, comprised of over 28,000 professional 

pilots to address safety, security, legislative and regulatory issues affecting the individual 

member unions. The National Air Disaster Alliance-Foundation was founded by air crash 

survivors and victims’ family members in 1995, to raise the standard of safety, security, 

and survivability for aviation passengers, and to support victims’ families. 

48A bridge agreement is a formal signed document between an aviation program and a 

regional airline that generally reduces the minimum flight time experience required by the 

airline for students to be considered for hire. Typical conditions of the agreement stipulate 

a specific grade point average, minimum number of flight hours, and other desirable 

academic qualifications for the students. 

Some Pilot Schools 

Provide Training That Is 

More Relevant to Airline 

Operations 
 

Page 25 GAO-12-117 Pilot Training 

bridge program will train on flight simulators and other flight training 

devices, become familiar with regional jets, and often learn airline-specific 

operational procedures in a multi-crew environment. The airlines, in turn, 

will offer interviews to students from those programs that successfully 

complete the school’s curriculum and earn all of the pilot certification 

credentials. A bridge program is designed to bridge the gap between the 

general aviation training experience in small single- and multiengine 

aircraft and a professional airline career. For example, Arizona State 

University’s aviation degree program has established a bridge agreement 

with a regional airline, Mesa Airlines, which allows the students to train in 

full-motion simulators of the regional jets that Mesa operates (see fig. 7). 

Figure 6: Full-Motion Flight Simulator at Arizona State University 

FAA has initiated several efforts to address issues related to pilot 

certification testing and training. In 2010, FAA began revising the 

repository set of questions that it uses to create its knowledge tests for 

pilot certification. FAA found that a significant percentage of applicants 

tested on the new questions failed the test compared to those that took 

the test with the previous questions. FAA plans to cooperate with industry 

representatives on future changes to the knowledge test questions and 

would likely implement any further changes over the next 2 years. 

Additionally, according to FAA officials, FAA has developed other plans 

FAA and Industry Efforts 

to Address Issues 

Associated with Pilot 

Training 

Source: GAO.
 

Page 26 GAO-12-117 Pilot Training 

related to improving pilot training to be implemented during fiscal year 

2012. 

 FAA plans to establish a government and industry working group 

during fiscal year 2012 to address issues related to pilot certification 

testing standards and training. The group will make recommendations 

to FAA on a variety of issues, including knowledge content, technical 

information related to pilot knowledge and practical tests, computer 

testing supplements, knowledge test guides, and practical test 

standards. 

 FAA is currently updating its national guidance and associated 

handbook for FAA inspectors on the recurrent training for flight 

instructors that is conducted by the aviation industry by providing 

refresher training courses. As stated earlier, part of the oversight for 

flight instructor-based schools is the subsequent renewal of the flight 

instructor’s certificate every 24 months. The refresher training is 

designed to keep flight instructors informed of changes to flight 

training and is one of several methods by which a flight instructor may 

renew a flight instructor certificate.49

 FAA is also updating its guidance on the review process for the 24-

month certification renewal for pilots and flight instructors. According 

to FAA, the current guidance is outdated and the revised version will 

provide more detailed guidance for the renewal review process, 

updated terminology and references, and reorganized review content. 

 FAA plans to make changes to the practical test standards (i.e., 

guidance used for conducting the flight test portion of a practical test) 

to incorporate required testing for runway incursions. FAA’s goal with 

the revised standards is to reduce runway incursions by 2 percent 

annually from the current level.50 Currently, the part of the practical 

test standards for evaluating a student’s knowledge of runway 

 

49Renewal of a flight instructor certificate can be completed in three ways: (1) passing a 

practical test for renewal of the flight instructor certificate, (2) meeting required FAA 

minimum of flight activity conducted as an instructor, or (3) completing a flight instructor 

refresher course consisting of ground training or flight training or both. 

50Runway incursions, which are precursors to aviation accidents, are instances where 

collisions are narrowly avoided on an airport’s runways or taxiways. For more information 

on runway incursions, see GAO, Aviation Safety: FAA Has Increased Efforts to Address 

Runway Incursions, GAO-08-1169T (Washington, D.C.: September 2008). 
 

Page 27 GAO-12-117 Pilot Training 

incursions is not required or specifically outlined. However, changes 

to the practical test standards include labeling runway incursions as a 

required testing task that includes specific procedures to be 

conducted during the test. 

 FAA has also recently initiated efforts to partner with the aviation 

academic community through a 5-year plan initiative, working through 

AABI and the University Aviation Association (UAA), to leverage 

academic expertise and develop best practices for improving all pilot 

training.51 The goal is to identify specific non-regulatory measures that 

can be used to improve training and reduce accidents. 

Other efforts to improve pilot training have generally focused on 

advanced training for pilots already employed at airlines—not on initial 

pilot training for students at pilot schools. Over time, U.S. pilot schools 

have become the primary source for producing pilots for the airline 

industry. In May 2011, in response to comments to a January 2009 notice 

of proposed rulemaking and requirements in the Airline Safety and 

Federal Aviation Administration Extension Act of 2010, FAA issued a 

supplemental notice of proposed rulemaking that would require existing 

airline pilots to train as a complete flight crew and coordinate their actions 

through crew resource management and scenario-based training, among 

other things.52 The rule would require airlines to provide ground and flight 

training to all existing airline pilots in the recognition and avoidance of 

stalls, recovery from stalls, recognition and avoidance of aircraft upset, 

and the proper techniques to recover from upset—all related factors 

evidenced in the Colgan Air crash in 2009—as required in the act.53

Additionally in May 2011, NTSB issued a series of recommendations to 

FAA related to first officer leadership and communications training. One 

recommendation to FAA, to which FAA has not yet formally responded, 

was that role-playing or simulator-based exercises that teach first officers 

to assertively voice concerns and that teach captains to develop a 

leadership style that supports first officer assertiveness be included as 

part of the already required crew resource management training for airline 

 

51UAA is the representative voice of college aviation education to the aviation industry, 

government agencies, and the general public. 

5276 Fed. Reg. 29336 (May 20, 2011). The original notice of proposed rulemaking was 

published in January 2009. 74 Fed. Reg. 1280 (Jan. 12, 2009). 

53Pub. L. No. 111-216, § 208, 124 Stat. 2348, 2360 (2010). 
 

Page 28 GAO-12-117 Pilot Training 

operations. These proposals are designed to enhance the training 

programs of airlines rather than the training requirements for pilot 

students, however, some of these ideas could be applied to the initial 

training for students seeking commercial airline careers. 

In addition, other aviation industry efforts are being developed that focus 

on improving all pilot training. For instance, one aviation organization has 

proposed the development of a global professional pilot certification to 

bridge the competency gap between pilot certification and being 

employed. The professional pilot certification would be based on a set of 

standards to ensure a newly-certified pilot has the knowledge required by 

the standards to enter the pilot profession. A not-for-profit association of 

pilot training professionals has proposed the development of an 

independent, international clearinghouse for pilot training best practices. 

International Air Transport Association (IATA) launched the Training and 

Qualification Initiative in 2007 to update and modernize the training of 

existing and future pilots. The initiative’s goal is to make pilot training 

more accurately reflective of the needs of flight deck operational 

procedures. Aviation stakeholders, such as Boeing and Flight Safety 

International, are offering a first officer’s course to bridge the skill and 

competency gap between training received at pilot schools and being 

employed as a commercial airline pilot.54

 

54Flight Safety International is a global professional aviation training company that 

operates the world’s largest fleet of advanced full flight simulators and supplier of flight 

simulators, visual systems, and displays. 
 

Page 29 GAO-12-117 Pilot Training 

Similar to FAA, EASA provides the regulatory framework for oversight of 

European countries’ national aviation authorities, which carry out the 

requirements for pilot licensing and training.55 Creation of EASA is the 

centerpiece of the European Union’s strategy for developing one level of 

aviation safety across Europe. EASA establishes common safety and 

environmental regulations and standards, and monitors the 

implementation of standards through inspections in its member states 

under authorization of the European Union. The United States and 

Europe provide a good comparison for aviation licensing as they offer 

equivalent pilot certificates, but they provide training for these certificates 

in different ways, as we describe below. 

Both FAA and EASA meet the ICAO standards for pilot certification and 

offer the private pilot, commercial pilot, and the airline transport pilot 

certifications (see table 2). An FAA pilot certificate is the equivalent of an 

EASA pilot license (we will only refer to a certificate—not license—for the 

simplicity of reporting). 

 

55EASA is the European aviation regulatory authority and FAA counterpart. EASA became 

operational in September 2003 on the basis of European Parliament and Council 

regulation 1592/2002. The agency is an independent European Union body under 

European law accountable to the Member States and the European Union institutions. In 

February 2008, Regulation 216/2008 was passed repealing Regulation 1592/2002 and 

included the scope of oversight for flight crew licensing. 

European Pilot 

Training Differs from 

the U.S. System, in 

Part Due to Varying 

Philosophies and 

Circumstances 

The European Pilot 

Training System 

Emphasizes Aeronautical 

Knowledge (Ground 

School) Instruction and 

Testing While the U.S. 

System Focuses More on 

Training in Practical Skills 
 

Page 30 GAO-12-117 Pilot Training 

Table 2: Comparison of Pilot Certifications and Training Standards of ICAO, FAA, and EASA 

Private Pilot Certificate 

ICAO FAA EASA 

Minimum Age 17 17 17 

Ground school No specified minimum number of 

hours 

- No specified minimum number 

of hours for Part 61 

- 35 hours for Part 141 

No specified minimum number of 

hours 

Written test No reference to a test, just 

demonstrate knowledge 

Pass an examination and score 

at least 70 percent overall 

Pass examination and score at 

least 75 percent for each subject 

tested 

Flight training 40 hours total time; 35 hours total 

time if completed during a course 

of approved training 

- 40 hours (Part 61) or 35 hours 

(Part 141) total time 

45 hours total time; 5 hours may be 

completed in a Basic Instrument 

Training Device or a flight simulator 

Practical test Demonstrate ability as pilot-incommand of an aircraft within the 

appropriate category of aircraft 

Required in aircraft Required in aircraft 

Commercial Pilot Certificate

Minimum age 18 18 18 

Ground school No specified minimum number of 

hours 

- No specified minimum number 

of hours for Part 61 

- 35 hours for Part 141 

- 250 hours (modular)a

- 350 hours (integrated)b

Written test No reference to a test, just 

demonstrate knowledge 

Pass an examination and score 

at least 70 percent overall 

Pass examination and score at 

least 75 percent for each subject 

tested 

Flight training 200 hours or 150 hours total time if 

completed during an approved 

training course 

250 (Part 61) or 190 hours 

(Part 141) total time 

200 (modular) or 150 hours 

(integrated) total time 

Practical test Demonstrate ability as pilot-incommand of an aircraft within the 

appropriate category of aircraft 

Required in aircraftc Required in aircraft 

Airline Transport Pilot Certificate

Minimum age 21 23 21 

Ground school No minimum number of ground 

school hours 

- No specified minimum number 

of hours for Part 61 

- 40 hours for Part 141 

- 650 hours (modular) 

- 750 hours (integrated) 

Written test No reference to a test, just 

demonstrate knowledge 

Pass an examination and score 

at least 70 percent overall 

Pass examination and score at 

least 75 percent for each subject 

tested 

Flight training 1,500 hours total time 1,500 hours total time 1,500 hours total time 

Practical test Demonstrate ability as pilot-incommand of an aircraft within the 

appropriate category required to be 

operated with a copilot 

Required in aircraft or flight 

simulator 

Required in aircraft or full flight 

simulator of a multi-pilot aircraft 

under instrument flight rules as a 

pilot-in-command 

Source: GAO presentation of ICAO standards, and FAA and EASA regulations. 
 

Page 31 GAO-12-117 Pilot Training 

a

Modular training is similar to the training model practiced in the United States under Part 61 where 

students are trained through a building block approach of modular segments of ground school and 

flight training at their own pace. 

b

Integrated training is similar to the training model practiced in the United States under Part 141 

where students attend an approved flight training organization (school) and train through an approved 

full-time course of ground school and flight training. 

c

An FAA-qualified and approved flight simulator or flight training device can be authorized to be used 

to complete certain flight task requirements listed in the practical test standards for the commercial 

pilot certification. 

In particular, for commercial pilots who may be hired as airline pilots, FAA 

has less exhaustive ground school requirements and practical testing 

requirements for pilot certification than EASA. Pilot certification in the 

United States emphasizes piloting skills and, thus, concentrates more on 

flight training. While FAA pilot certification regulations require some 

ground school instruction, the regulations do not emphasize the need for 

formalized training. As previously stated, FAA’s pilot training regulations 

require that a person applying for a private and commercial certificate 

must receive and log ground training from a flight instructor or complete a 

home-study course on the applicable ground school areas. Part 61 

regulations do not specify a required number of training hours for ground 

school for any pilot certificate—although, they require that minimum 

knowledge subject areas are covered during training—but do specify a 

minimum number of actual flight hours. On the other hand, the European 

system emphasizes and requires ground school training hours along with 

actual flight training hours for pilot certification. EASA has no minimum 

number of training hours for ground school for a private certificate similar 

to FAA, but requires a minimum of 350 hours of instruction for the 

commercial certificate and 750 hours for the airline transport certificate. 

The United States and Europe also have differing approaches to the pilot 

certification knowledge and practical testing. While FAA uses one 

multiple-choice knowledge test and requires an overall score of 70 

percent or higher to pass, EASA uses multiple tests for each certificate 

while utilizing multiple-choice and open-ended questions. Pilot test 

applicants must pass with at least a 75 percent pass score for all 

questions related to each ground school area being tested. European 

officials told us that the quantity and variety of tests given ensure students 

have a true understanding and application of the aeronautical knowledge 

provided in ground school necessary for being a skilled pilot. Also, FAA’s 

pilot certification system places greater emphasis on practical testing on 

various types of equipment. In addition to the required number of hours of 

ground instruction and tests, the United States and Europe differ on the 

type of aircraft on which pilots are trained and tested. As stated earlier, 

much of U.S. pilot training takes place only in a single-pilot, single-engine 
 

Page 32 GAO-12-117 Pilot Training 

airplane, which is not reflective of today’s modern jet aircraft and the 

training needs of an airline pilot, according to aviation stakeholders. FAA 

does not require airline transport pilot applicants to show proficiency in a 

multi-pilot airplane, either as a captain or first officer. However, FAA 

officials stated that airlines are required to provide that training to their 

pilots after being hired and before transporting passengers. EASA, 

however, requires airline transport pilot applicants to show proficiency in 

operating as a first officer on multi-pilot, multi-engine planes and there is 

greater emphasis in Europe for training in a multi-crew environment. 

The U.S. pilot training system is based on the traditional aviation 

philosophy, which relies on a modular (building block) approach. This 

model requires pilots to obtain different certifications through building the 

competencies and experience by accruing a certain level of aeronautical 

knowledge (ground school training) and minimum number of flight hours. 

In a modular training approach, students are provided different training 

modules that are independent of each other. Pilot certification in the 

United States is based on these building blocks whereby each level of 

pilot certificate builds upon the knowledge and experience gained at the 

previous level. Thus, commercial airline pilots are trained through various 

levels of pilot certification by meeting ground school and flight training 

requirements at each level, and then must gain actual flying experience 

through various aviation jobs to build the necessary hours to be hired by a 

regional airline. 

Europe has two training systems for acquiring pilot certificates and 

ratings—the step-by-step modular training approach and an integrated 

training program approach (ab initio). 56 Similar to the United States, the 

modular training programs train students through modular courses and inflight training at their own pace. This approach is usually pursued parttime or on a non-continuous basis, normally focusing on flying solo, and 

starts with a private pilot certificate. The integrated training approach 

requires student pilots to attend an approved flight training organization 

for an approved full-time course and emphasizes a multi-crew 

 

56Ab initio is a Latin term meaning “from the beginning.” Ab initio pilot training 

programs trains students with little to no pilot experience to become 

commercial airline pilots through a continuous training program. 

Differences in Training 

Philosophy and 

Circumstances Have Led 

to Contrasting Pilot 

Training Methods 
 

Page 33 GAO-12-117 Pilot Training 

environment.57 European officials we spoke with explained that the 

integrated approach is specifically directed towards individuals interested 

in becoming an airline pilot. The fundamental philosophy of ab initio

training—which is also the traditional approach by which U.S. military 

pilots are trained—is the belief that a competent, proficient airline pilot 

can be trained to airline standards with as little as 350 hours of flight time, 

provided the student is immersed in a properly designed aviation 

curriculum from the outset.58 In other words, the training approach is not 

based on the quantity of hours of training, but rather on the quality of the 

training to better enable an individual to achieve competency. A few U.S. 

pilot schools offer an ab initio training program; however, they are 

generally provided by universities and require the student to take part in a 

4-year program, generally a longer timeframe than it takes to complete a 

European ab initio program administered by an airline sponsored school. 

U.S. ab initio programs train pilots for positions with regional or commuter 

airlines, whereas in Europe, ab initio training is more specifically for pilots 

being training for mainline airlines. 

Another major difference between the United States and European 

countries is the implementation by EASA of regulations to support the 

multi-crew pilot license—an ICAO-approved, alternative pilot-training and 

certification concept specifically geared toward training commercial airline 

pilots.59 According to ICAO, a total of 32 ICAO member states have 

regulations in place for the multi-crew pilot license. However, currently 

only 13 of the 190 ICAO members (7 percent) have approved training 

organizations to conduct training for the multi-crew pilot license, with 

different training schemes in progress. The training is designed to focus 

on mastering the competencies specific for becoming an airline first 

officer. The multi-crew pilot license, established by ICAO, requires at least 

240 hours of total flight training and is comprised of actual flight time and 

simulation time for meeting competency milestones. However, the license 

 

57Approved flight training organizations are required to meet certain qualifying standards 

of personnel licensing. 

58Competency-based training and assessment is defined as performance orientation with 

an emphasis on standards of performance and their measurement, and the development 

of training to the specified performance standards. 

59In November 2006, ICAO enabled the implementation for the multi-crew pilot license by 

amending ICAO personnel licensing standards to include a new pilot certificate and 

adopting new standards for this ab initio airline pilot training method. 
 

Page 34 GAO-12-117 Pilot Training 

is not a general pilot certificate and must be granted to an individual for a 

specific aircraft type and limits an individual as a first officer for a specific 

airline. FAA has not developed regulations for a multi-crew pilot 

certification, and there are differing views on its usefulness and necessity 

in the United States. FAA officials said they have been studying the 

feasibility of implementing the necessary regulations for U.S.-based 

commercial airlines, but they also indicated that U.S. airlines have not 

publicly shown interest in a multi-crew pilot certification due to the 

availability of a broad pool of commercial and airline transport pilots in the 

United States. Representatives from three regional airlines and one 

industry association told us that, with the number of furloughed pilots as a 

result of the economic downturn in 2008, application of the multi-crew 

pilot certification is not needed in the United States and would be too 

restrictive in nature. The certification would limit pilots to being first 

officers, limit them to a specific aircraft type, and not allow them to 

transfer to other airlines. Traditional pilot certificates require more training 

hours, but do not include such restrictions. 

Part of the reason European countries and airlines have adopted the ab 

initio approach is to address a shortage of qualified airline pilots. 

Historically, U.S. airlines have recruited experienced pilots from the 

robust U.S. general aviation community and the U.S. military. The United 

States also has significantly more pilot schools than Europe. Conversely, 

Europe has not benefited from a steady stream of military pilots or a 

thriving general aviation sector. As a result, European schools are mostly 

focused on producing commercial airline pilots. European countries and 

airlines have used the ab initio training model and multi-crew pilot license 

to increase the number of available airline pilots. 

At times, in response to pilot shortages, European airlines have funded 

the training for their pilot candidates. After the screening process, many 

student pilots in the European countries we visited are provided training 

by airline sponsorship or an agreement for employment with an airline. 

Examples of airlines that follow this practice include Lufthansa and Air 

France, where students are offered the training as part of a partial 

sponsorship program, wherein candidates are required to pay a small 

portion of the training costs upfront (Lufthansa provides loans to students 

to cover this cost). Once training is completed, Lufthansa and Air France 

enter into an employment contract with the candidate, and he or she 

repays the loans via a lower initial salary. Similarly, while British Airways 

does not sponsor students as fully as it has in the past, when it does, the 

students pay for their training through their salary once they begin 

working for the airline. On the other hand, KLM airline does not sponsor 
 

Page 35 GAO-12-117 Pilot Training 

candidates; however, it does partially fund an insurance policy to help 

cover the default risks for the banks that loan the money to the students 

for training as a result of early termination due to poor performance, failed 

medical examination, and other unforeseen circumstances. If the 

insurance policy is executed, students are contractually obligated to 

cease pursuit of a pilot career. U.S. airlines do not sponsor students for 

initial pilot training. As mentioned previously, pilot training in the United 

States is provided to individuals based on the self-sponsored concept—if 

they can pay, they can train. Students do not need to meet certain 

qualifications to train. However, once hired, all U.S. commercial airlines 

are required to provide the advanced training for their pilots. Several 

officials stated that most pilot students in the United States are not 

interested in becoming commercial airline pilots and pursue training to fly 

recreationally. 

According to literature, most pilot schools in the United States conduct 

little screening of students that apply, whereas European schools 

routinely use comprehensive mechanisms to identify the most qualified 

students as to provide the best pilot candidates to their sponsoring 

airlines. The candidate screening process is generally the same across 

Europe and includes several interviews, various psychological tests, and 

scenario-based testing. According to some European officials, pilot 

schools in Europe focus on selection procedures and aptitude screening. 

According to officials at European airlines, basing selection on fixed 

standards instead of selecting candidates influenced by commercial 

pressure assures airlines that they are training a qualified pilot. Officials at 

these European airlines and the pilot schools they sponsor noted that 

pilot training in Europe is very expensive, and selecting the right pilot 

candidates is important because of safety reasons and the upfront 

investment for the company. In the United States, however, the most 

intensive screening process occurs when pilots seek employment with 

airlines. The airlines independently assess candidates’ work experience, 

technical, and non-technical skills before hiring. (For more information on 

the demand for and supply of pilots, see app. II.) According to some 

aviation stakeholders, U.S. pilot schools would lose revenue if they 

screened or selected students as is done in Europe and would be 

challenged under privacy and anti-discrimination laws. 
 

Page 36 GAO-12-117 Pilot Training 

For fiscal year 2010, our analysis of FAA’s PTRS data found that FAA 

completed about 78 percent of the required inspections for the 545 pilot 

schools with a Part 141 certificate (vocational schools and most collegiate 

aviation schools). As part of its oversight role, FAA monitors pilot schools 

with a Part 141 certificate to ensure that they meet the required safety 

and training regulations. To fulfill NPG requirements, FAA requires its 

inspectors to conduct on-site inspections of each of these schools at least 

once a year. The inspections focus on five areas related to pilot school 

operations and the airworthiness of training aircraft. Under operations, an 

inspection must cover the school’s facility and student records. Under 

airworthiness, an inspection must cover the pilot school facility, 

compliance with FAA’s airworthiness directives, and a Part 141 ramp 

check.60 Inspectors enter the details and results of their monitoring in 

FAA’s PTRS data system. In reviewing PTRS data for fiscal year 2010, 

we found that FAA completed the majority of the required inspections of 

schools with a Part 141 certificate—that is, the inspections covered all 

five inspection areas during the year. However, we found that for 118 of 

the 545 schools that were inspected during the fiscal year, all of the five 

inspection areas were not covered (see table 3). An annual inspection 

covering all of the inspection areas is important for overseeing these 

schools because it provides some assurance to FAA that they are 

meeting the regulatory requirements for providing adequate training to 

pilot students. 

 

60A ramp check for a pilot school with a 141 certificate typically involves an inspection of 

the paperwork and exterior of the aircraft used by the school for training to ensure each 

meets all regulatory requirements. FAA inspectors conduct various types of ramp checks 

to ensure that aviation activities are being conducted safely and in compliance with the 

Federal Aviation Regulations. 

FAA Completed Most 

Required Inspections 

of Pilot Schools, but 

Oversight of 

Examiners and 

Instructors Is Difficult 

to Assess 

The Majority of Required 

Inspections of Pilot 

Schools Were Completed 

from Fiscal Years 2006 

through 2010 
 

Page 37 GAO-12-117 Pilot Training 

Table 3: Completion Percentage of Required Inspections for Pilot Schools with Part 

141 Certificates for Fiscal Year 2010 

2010 

Required NPG inspection areas completed Number Percent

Cumulative 

percent

0 of 5 20 3.7 3.7

1 of 5 17 3.1 6.8

2 of 5 58 10.6 17.4

3 of 5 16 2.9 20.3

4 of 5 7 1.3 21.6

5 of 5 427 78.3 100.0

Total 545 100.0

Source: GAO analysis of FAA data. 

We were unable to determine whether the data were missing because 

they were entered incorrectly into PTRS, or because the inspections did 

not take place as required. We were also unable to determine the extent 

inspections were completed in fiscal years prior to 2010 due to limitations 

in tracking the number of pilot schools that existed in each fiscal year. 

FAA does not maintain a historical listing of the active pilot schools with a 

Part 141 certificate for a given fiscal year and, thus, we could not define 

the universe of pilot schools that was required to be inspected during 

fiscal years 2006 through 2009. As a result, we could not determine the 

identity and number of schools that needed to be inspected. While FAA 

officials recognized that all required NPG inspections are expected to be 

completed within each fiscal year time frame, they provided several 

reasons to potentially explain why some of the required inspections are 

not recorded in PTRS. FAA officials said that inspectors may have 

conducted the required inspections for some schools but incorrectly 

entered the details in PTRS. For example, some FAA inspectors may 

conduct full inspections of schools that cover the five inspection areas, 

but may enter only two of the five inspection numbers into PTRS. The 

officials also said that inspectors had additional duties—such as following 

up on previously identified issues or addressing the need for additional 

oversight for certain inspection areas—in conducting inspections for some 

schools, which can make covering all five inspection areas difficult. 

In addition, many of the part 141 pilot school inspections required by NPG 

are incorrectly recorded as discretionary inspections in PTRS making it 

difficult to use PTRS to determine if FAA had conducted all of the 

required inspections of part 141 pilot schools for a given year. 
 

Page 38 GAO-12-117 Pilot Training 

Specifically, 35 percent of the 4,551 part 141 pilot school inspections 

required by NPG in fiscal year 2010 were listed incorrectly in PTRS as 

discretionary inspections. Also, 32 percent of the required inspections 

were listed as discretionary from fiscal year 2006 through 2010. As a 

result, those inspections would not show up in a list generated in PTRS of 

required inspections for fiscal year 2010. FAA officials said that this 

problem is likely caused by the program that populates PTRS with the 

NPG requirements. 

When inspections or other sources revealed compliance issues or 

violations, FAA uses a variety of actions to enforce safety standards and 

regulatory compliance, such as oral or written counseling, administrative 

action, legal enforcement action, and referral for criminal prosecution. 

When an FAA inspector identifies a potential violation, he or she initiates 

an investigation and if FAA determines that a violation has occurred, FAA 

has a wide range of options available for addressing it. From fiscal years 

2006 through 2010, our analysis of FAA’s EIS data found that FAA 

initiated 230 enforcement cases against pilot schools with a Part 141 

certificate. The majority of these cases resulted from an inspection of a 

school, but others may have resulted from other sources. During fiscal 

years 2006 through 2010, FAA used a wide range of enforcement actions 

against pilot schools with a Part 141 certificate (see fig. 7). 

 No action: FAA can determine that no action is warranted. In 26 of 

the 230 cases (about 11 percent), enforcement cases were initiated, 

but no enforcement action was taken. 

 Administrative Actions: In 186 cases (about 81 percent), FAA used 

administrative actions to address violations. These actions refer not 

only to warning notices and letters of correction but also informal 

actions, such as oral or written counseling, which can also be used by 

inspectors to address an apparent violation, provided that certain 

criteria are satisfied and the apparent violation is a low safety risk. 

 Enforcement actions: We found that FAA rarely used punitive means 

such as revoking licenses and assessing penalties against pilot 

schools with a Part 141 certificate. FAA assessed monetary civil 

penalties in 12 cases (about 5 percent) for pilot schools with a Part 

141 certificate and the sanctions ranged from $500 to $20,000. FAA 

revoked the operating certificates of schools in 3 cases, or slightly 

more than one percent. To illustrate the severity of an action that 

leads to revoking operating certificates, these include knowingly 

permitting school training aircraft to be used to carry illegal controlled 
 

Page 39 GAO-12-117 Pilot Training 

substances or an intentional action to improperly credit training to or 

graduate students. 

Figure 7: The 230 Enforcement Cases for Pilot Schools with Part 141 Certificates 

from Fiscal Years 2006 through 2010 

Note: Numbers do not add up to 100 percent due to rounding. 

From fiscal years 2006 through 2010, our analysis of FAA’s PTRS data 

found that FAA completed 9,016 inspections of pilot examiners, but it is 

unclear whether FAA met all of its oversight requirements in this area 

(see fig. 8). FAA uses private individuals or organizations to supplement 

its workforce and to provide certification activities such as examining and 

testing of pilot applicants for a fee paid for by the applicant.61 Known as 

designees, pilot examiners are generally appointed by FAA’s local district 

personnel for either 3 years (for an individual) or 5 years (for an 

 

61FAA uses a broad pool of designated personnel nationwide to act as representatives of 

the agency to conduct many safety certification activities, such as administering practical 

tests to pilots and many other activities. 

It Is Unclear Whether 

Required Inspections for 

Pilot Examiners Were 

Completed Because FAA 

Data System Lack 

Historical Information 

Source: GAO analysis of FAA data.

81% Administrative

11% No action

1%

Other action

Sanction: civil penalty

5%

1%

Sanction: revocation
 

Page 40 GAO-12-117 Pilot Training 

organization).62 As part of its oversight role, FAA requires each pilot 

examiner to be inspected by FAA inspectors at least once annually and 

high activity pilot examiners must be inspected at least twice annually, as 

outlined in the agency’s oversight policy and NPG directives.63

Additionally, several other circumstances may require an FAA inspector 

to inspect a pilot examiner, such as noncompliance with the applicable 

certification policies, an excessively high certification passing rate, or 

involvement in an accident, incident, or other violation.64 Although we 

know the number of inspections conducted for each fiscal year, we could 

not determine the completion percentage of the required inspections for 

either the routine annual or additional inspections for high activity or 

special circumstances for each fiscal year due to limitations in available 

data for the population of pilot examiners. 

 

62Part 61 provides the regulatory basis for the conduct of practical tests for pilot 

certification. Section 183.23 of title 14 (subpart C) provides the regulatory basis for the 

designation of pilot examiners. FAA Order 8900.2 contains procedures for the selection, 

appointment, oversight, training, renewal, termination, and appeal of designees. 

63High activity pilot examiners are defined as conducting 50 or more practical tests per 

quarter. 

64These circumstances may include a designee: (1) who does not comply with the 

applicable certification policies; (2) whose certification passing rate is excessively high; (3) 

who exceeds the allowable amount of certification activity on a given day; (4) who 

conducts any certification activity that requires prior permission from the managing FAA 

office without obtaining that permission in advance; (5) whose certification file error rate is 

excessively high; (6) who is the subject of a valid public complaint; or (7) who has been 

involved in an accident, incident, or violation of federal aviation regulations. 
 

Page 41 GAO-12-117 Pilot Training 

Figure 8: The 9,016 Inspections of Pilot Examiners from Fiscal Years 2006 through 

2010 

Although we could not determine the completion percentage of the 

required inspections for pilot examiners, our analysis of PTRS inspection 

data showed 1- and 2-year gaps in the oversight of some pilot examiners. 

For instance, we found 114 pilot examiners with a 1-year gap between 

inspections, and 11 pilot examiners with a gap of 2 years. This may 

indicate that required inspections of pilot examiners were not completed 

by FAA in a given fiscal year or that inspections were unnecessary due to 

inactivity of the examiners during that year. FAA officials told us that, until 

recently, FAA had not analyzed the extent to which it has conducted all 

required pilot examiner inspections on a national level. 

FAA has previously taken steps to improve oversight of pilot examiners, 

but still faces issues in this area. In 2005, FAA developed 14 

recommendations to improve pilot examiner compliance, 11 of which 

were implemented. FAA officials told us that the implementation of these 

recommendations has resulted in improvements in pilot examiner 

oversight guidance and in the information technology used to oversee 

pilot examiners for local district offices. They also said that, as a direct 

result of the recommendations, more of the pilot examiners with poor 

performance issues have been terminated and oversight of pilot 

examiners has improved. Nevertheless, FAA officials acknowledged they 
 

Page 42 GAO-12-117 Pilot Training 

still face some issues in oversight of pilot examiners, due, in part, to the 

FAA’s current data systems’ difficulty compiling inspection data at the 

regional or national level. In September 2010, FAA began developing 

quarterly assessment reports covering 12-month periods on the oversight 

of its designees, including pilot examiners, to assist in identifying 

oversight gaps and potential areas of concerns. We reviewed the 

quarterly reports that covered July 2009 through March 2011 and found 

they identified a number of areas of concern regarding the oversight of 

pilot examiners. For example, some pilot examiners with the highest 

activity had not been inspected over the previous 12 months. FAA began 

creating the quarterly assessment reports to better inform management 

officials at the national office level. For example, in the most recent report 

provided by FAA officials, five high-activity pilot examiners were identified 

that performed a total of 1,623 pilot practical tests, but no inspections 

were conducted for these pilot examiners for the previous 12 months. 

Conversely, the report found that FAA conducted 218 inspections of the 

171 pilot examiners with the lowest testing activity during the same 

period.65 Based on this report, FAA’s inspection record is not consistent 

with the pilot examiners that are responsible for conducting the largest 

numbers of practical tests, and conducting more oversight on the 

examiners conducting significantly fewer tests. 

FAA officials said that the quarterly assessment reports are a temporary 

way of assessing the extent to which it is conducting all required 

inspections, but FAA is in the process of developing a new designee 

management system that it expects to be operational by July 2012. FAA 

officials told us that the new system is being designed to provide more 

comprehensive data on designees, including pilot examiners, by 

combining data that FAA currently maintains in various data systems. 

Thus, the new system will consolidate the management and oversight 

functions for designees to allow for more readily available data. The 

officials also told us that they are in the process of revising oversight 

policy for designees and improving tools for selecting which pilot 

examiners to inspect. 

 

65Low-activity pilot examiners were those with seven or less activities between the third 

quarter of 2010 and the second quarter of 2011. 
 

Page 43 GAO-12-117 Pilot Training 

Unlike oversight of pilot schools with Part 141 certificates and pilot 

examiners, annual inspections of individual flight instructors (i.e., under 

Part 61 regulations) are not required by FAA. From fiscal years 2006 

through 2010, our analysis of FAA’s PTRS data found that FAA 

completed 1,761 inspections of flight instructors. Oversight for flight 

instructors is generally limited to initial and subsequent certification 

renewal, but additional oversight of flight instructors is conducted as an 

optional work activity by FAA. However, despite being optional, FAA 

officials from one local district office told us that their inspectors make this 

area a priority in their planned work activities for a given fiscal year. 

According to FAA policy, flight instructor certificates are renewed every 24 

months. However, inspections of flight instructors and their training 

activities should take place on a random basis in the interim, but should 

be prioritized as a result of, for instance, observations of noncompliance 

actions made during a pilot school inspection, an instructor or student is 

involved in an accident or incident, or when an instructor has a student 

failure rate of 30 percent or greater on FAA’s certification tests. The 

oversight of flight instructors is important because, like the examiners, this 

population serves as a gatekeeper for ensuring that pilot students are 

being properly trained as they seek certification. However, similar to pilot 

examiners, we could not determine the extent of oversight that FAA 

provided for the entire flight instructor population or the specific reasons 

that inspections were conducted during the 5 fiscal years. 

Similar to pilot schools, when inspections or other sources revealed 

compliance issues or violations, FAA uses a variety of actions to enforce 

safety standards and regulatory compliance. For fiscal years 2006 

through 2010, our analysis of FAA’s EIS data found 178 cases against 

flight instructors (see fig. 9). 

 No action: FAA can determine that no action is warranted. In 38 of 

the 178 cases (about 21 percent), enforcement cases were initiated 

but no enforcement action was taken. 

 Administrative Actions: In 109 cases (about 61 percent), FAA used 

administrative actions to address violations. These actions refer not 

only to warning notices and letters of correction but also informal 

actions, such as oral or written counseling, which can also be used by 

inspectors to address an apparent violation. 

 Enforcement actions: We found that FAA rarely used punitive means 

such as suspending or revoking licenses and assessing penalties 

against flight instructors. FAA suspended licenses in 9 cases (about 

5 percent) and revoked licenses in 16 cases (about 9 percent). FAA 

While Not Required, FAA 

Conducts Optional 

Oversight Inspections for 

Flight Instructors, but to 

What Extent Is Unclear 
 

Page 44 GAO-12-117 Pilot Training 

also assessed monetary civil penalties in three cases (about 2 

percent) for flight instructors. 

Figure 9: The 178 Enforcement Cases for Flight Instructors from Fiscal Years 2006 

through 2010 

In addition to using PTRS and EIS, FAA inspectors develop their work 

plan using another somewhat limited oversight tool—the Safety 

Performance Analysis System (SPAS)—which provides data access and 

analysis on pilot schools, pilot examiners, and flight instructors.66 The 

SPAS system is a data analysis application that monitors performance 

measures and calls attention to trends. SPAS builds on inspection results 

and other data and is intended to assist FAA’s local district offices in 

applying their limited inspection resources to those entities and areas that 

pose the greatest risk to aviation safety. For example, when particular 

inspection tasks warrant attention, SPAS will “flag” an advisory 

notification to a FAA inspector and prompt the inspector to look into the 

 

66SPAS relies on over 25 databases within FAA and other government agencies, including 

PTRS, EIS, and the Vital Information Subsystem, which maintains a current list and the 

status of pilot school certificates. 

Inspectors also Use the 

Safety Performance 

Analysis System to Plan 

Their Work 

Source: GAO analysis of FAA data.

Administrative

61%

Certification revoked

No action

9%

21%

Certification suspended

5%

2%

Other action

2%

Fine assessed
 

Page 45 GAO-12-117 Pilot Training 

situation, e.g., a flight instructor with a high rate of student failure on 

practical tests. While SPAS may be useful at the local level, it does not 

have the capability to perform national level rollup analysis. Thus, FAA 

does not have the ability to measure FAA’s annual performance in 

meeting the NPG inspection requirements for pilot schools and pilot 

examiners based on PTRS inspection data, or to make risk-based, datadriven decisions about the scope of its discretionary, planned work 

activities that include flight instructors. As a result, FAA’s national office 

cannot readily access comprehensive inspection completion data and 

determine the level of oversight its field staff is providing for pilot schools 

and pilot examiners. 

Public and media concerns about aviation safety escalated as a result of 

the Colgan crash in early 2009, and Congress and FAA have taken steps 

to improve aviation safety by making revisions to the training 

requirements that airlines must provide for commercial airline pilots. Our 

analysis indicates that FAA has an opportunity to ensure that the initial 

pilot training process for producing pilots’ commercial certificates is still 

relevant for the necessary knowledge and skills for airline positions. 

Although many of the improvements to training being considered are for 

existing airline pilots—such as those related to decision making and 

operating in a crew environment—they may also apply to initial pilot 

training. We are not making recommendations in this area, because FAA 

has initiated some efforts and has plans for other efforts to address pilot 

training issues. For example, FAA plans to establish a government and 

industry working group during fiscal year 2012 to address issues related 

to pilot certification testing standards and training. Therefore, we 

encourage FAA to continue its efforts, with industry and academia 

collaboration, in reviewing the initial pilot training process, including 

ground school content, training hour requirements, and knowledge testing 

for commercial pilot certification under the Part 61 regulations. 

FAA’s oversight of key functions for the initial pilot training process in the 

United States by which commercial pilots become certificated is 

reasonably sound. We found that FAA completed most required 

inspections of vocational pilot schools (Part 141), but the agency’s data 

sources did not provide certainty that the level of oversight is consistently 

being performed in accordance with the agency’s guidelines and policies, 

including oversight requirements for pilot examiners. FAA’s national office 

does not monitor the annual completion of the requirements outlined in 

the annual NPGs related to monitoring pilot schools and pilot examiners. 

Therefore, the national office cannot readily determine the level of 

Conclusions 
 

Page 46 GAO-12-117 Pilot Training 

oversight its field staff is providing for these key stakeholders and has 

been unable to produce this information. Better internal control 

mechanisms, such as creating and reviewing agencywide reports using 

PTRS data periodically, would improve FAA oversight by providing 

assurance that all required inspections were completed. Additionally, FAA 

could establish standard procedures for entering PTRS data for 

inspectors at the local level of the completed inspection areas to avoid the 

uncertainty of whether or not they were completed as required. This 

would not only help FAA better measure its performance in meeting the 

annual NPG inspection requirements, but would also enable the agency 

to make more informed decisions about the scope of its discretionary, 

planned work activities for flight instructors. Further, the steps taken by 

FAA to develop a quarterly assessment report on the oversight and 

performance of pilot examiners is promising, but FAA should also 

consider developing a similar process for oversight of flight instructors 

because it could identify potential areas of concerns. 

We are making two recommendations to improve FAA’s oversight of pilot 

certification and training. The Secretary of Transportation should direct 

the Administrator of the Federal Aviation Administration to develop a 

comprehensive system that may include modifying or improving existing 

data systems to 

 measure performance for meeting the annual National Program 

Guidelines’ inspection requirements for pilot schools with a Part 141 

certificate and pilot examiners and 

 better understand the nature and scope of the discretionary, planned 

inspections for flight instructors. 

We provided a draft of this report to DOT for review and comment. In 

responding to our recommendations, FAA officials said that they agreed 

that improvements in oversight data were needed but indicated that the 

quarterly assessment reports already measure the level of oversight of 

pilot examiners and summary data is being provided to the national office 

and regional division managers. Additionally, the designee management 

system currently under development will address the recommendation for 

pilot examiner designees in a more permanent way. We retained the 

recommendation; our report notes the oversight improvements underway 

for pilot examiners, and we will assess the effectiveness of the designee 

Recommendations for 

Executive Action 

Agency Comments 

and Our Evaluation 
 

Page 47 GAO-12-117 Pilot Training 

management system once it is implemented. FAA also provided technical 

comments that we incorporated as appropriate. 

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 7 days from the 

report date. At that time, we will send copies of this report to the 

Secretary of Transportation and appropriate congressional committees. 

The report is also available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or by e-mail at dillinghamg@gao.gov. Contact 

points for our Offices of Congressional Relations and Public Affairs may 

be found on the last page of this report. GAO staff who made major 

contributions to this report are listed in appendix III. 

Gerald L. Dillingham, Ph.D. 

Director, Physical Infrastructure Issues 
 

Page 48 GAO-12-117 Pilot Training 

List of Requesters 

The Honorable John L. Mica 

Chairman 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Thomas E. Petri 

Chairman 

The Honorable Jerry F. Costello 

Ranking Member 

Subcommittee on Aviation 

Committee on Transportation and Infrastructure 

House of Representatives 

The Honorable Brian Higgins 

The Honorable Louise McIntosh Slaughter 

House of Representatives 
Appendix I: Scope and Methodology 

Page 49 GAO-12-117 Pilot Training 

To address our objectives and the pilot supply appendix, we reviewed 

and synthesized literature on pilot training and certification in the United 

States. Specifically, we reviewed a range of reports from GAO, Federal 

Aviation Administration (FAA), Congressional Research Service, 

International Civil Aviation Organization, National Transportation Safety 

Board, and Bureau of Labor Statistics that included general background 

information on a variety of related issues on U.S. pilot training, such as 

pilot certification and training issues in the U. S.; historical trends, current 

supply and demand, and forecasts for commercial airline pilots; types and 

requirements of pilot training schools; FAA regulatory training 

requirements for different levels of pilot certification; FAA oversight of 

U.S. pilot training system; and comparable international pilot training 

systems. We conducted a literature review search from databases, such 

as ProQuest, TRIS, and Lexis, as well as well as trade publications and 

literature from aviation stakeholders. Furthermore, we reviewed the 

Federal Aviation Regulations related to training and certification for pilots 

under Part 61, Part 141, and Part 142. We also reviewed FAA 

regulations, policy, and oversight documentation related to pilot training, 

management guidance for overseeing pilot schools, designated pilot 

examiners (pilot examiner), and certified flight instructors (flight 

instructor). Additionally, we reviewed FAA’s national program guidelines 

for fiscal years 2006 through 2010 regarding the required and planned 

oversight activities as well as FAA’s practical test standards used to 

certificate pilots as private, commercial, and airline transport. We also 

reviewed provisions of the Airline Safety and Federal Aviation 

Administration Extension Act of 2010 (Pub. L. No. 111-216) related to 

“Flight Crewmember Screening and Qualifications” and “Airline Transport 

Pilot Certification.” 

To review FAA’s inspection and enforcement activities related to pilot 

schools, pilot examiners, and flight instructors, we obtained FAA’s 

inspection and enforcement policies and analyzed raw data from FAA’s 

inspection and enforcement databases. We analyzed data from the 

Program Tracking Reporting System (PTRS) for inspections that closed 

(had a closing date) in fiscal years 2006 through 2010 and data from the 

Enforcement Information System (EIS) for enforcement actions with a 

date of final action in those fiscal years. To assess the reliability of the 

inspection and enforcement data that we received from FAA, we 

performed electronic testing of the data elements that we used, obtained 

and reviewed documentation about the data and the systems that 

produced them, and interviewed knowledgeable FAA officials. We used 

these data to determine the extent to which FAA had completed all 

required inspections of pilot schools and pilot examiners, and planned 

Appendix I: Scope and Methodology 
Appendix I: Scope and Methodology 

Page 50 GAO-12-117 Pilot Training 

inspections of flight instructors. For pilot schools with a Part 141 

certificate, we analyzed data from PTRS on the numbers of required 

inspections that FAA completed, and whether all five inspection areas 

were covered, and compared to the requirements set in FAA’s National 

Program Guidelines (NPG). The NPG for each fiscal year indicated that 

an inspection was required for each school within each region and to 

include under operations: (1) air agency facility inspection (PTRS activity 

number 1640) and (2) student records (PTRS activity number 1649). The 

NPG for each fiscal year also indicated that an inspection was required 

for each school within each region and to include under airworthiness: (1) 

pilot school facility (PTRS activity number 3650), (2) airworthiness 

directive compliance (PTRS activity number 3667 or 5667), and (3) part 

141 ramp (PTRS activity number 3664 or 5664). To determine the nature 

and scope of the enforcement actions that FAA closed against pilot 

schools with a Part 141 certificate, we analyzed data on these actions 

from EIS, including whether the actions were administrative, fines, or 

suspensions or revocations of schools’ Part 141 operating certificates. 

We also analyzed data to determine the minimum, median, and maximum 

dollar amounts of fines and durations of suspensions. We tested the 

reliability of the PTRS and EIS data that we received from FAA with 

electronic testing of the data elements that we used, obtained and 

reviewed documentation about the data and the systems that produced 

them, and interviewed knowledgeable FAA officials. We found the data to 

be sufficiently reliable for our purposes. 

For pilot examiners, we analyzed data from PTRS on the numbers of 

required inspections that FAA completed and compared to the 

requirements set in the NPG. The NPG for each fiscal year indicated that 

an inspection was required for each pilot examiner within each region 

under: pilot examiner—large-turbojet (PTRS activity number 1664) and 

pilot examiner—other (PTRS activity number 1665). We also obtained 

and reviewed summary data from FAA contained in quarterly assessment 

reports on the oversight of its designated representatives, including pilot 

examiners. The quarterly reports contained data from July 2009 through 

March 2011. 

For flight instructors, the PTRS activity number 1662 is used to record 

CFI inspections in PTRS. The NPG for fiscal years 2009 through 2010 did 

not indicate inspections for certificated flight instructors as a planned work 

activity. To determine the nature and scope of the enforcement actions 

that FAA closed against flight instructors, we analyzed data on these 

actions from EIS, including whether the actions were administrative, fines, 

or suspensions or revocations of flight instructors’ certificates. We also 
Appendix I: Scope and Methodology 

Page 51 GAO-12-117 Pilot Training 

analyzed data to determine the minimum, median, and maximum dollar 

amounts of fines and durations of suspensions. 

We interviewed government officials at the Federal Aviation 

Administration and National Transportation Safety Board. We conducted 

semistructured interviews with representatives from a range of aviation 

stakeholder organizations (see below). We also interviewed researchers 

involved in the pilot source study. We visited pilot training stakeholders in 

six states included in FAA regions that had higher number of pilot 

schools, higher number of pilot certificates issued in 2009, while taking 

into consideration the presence of FAA regional and district offices and 

regional airlines’ offices in some locations. Thus, in our visits to Arizona, 

Florida, Georgia, Indiana, Maryland, and Utah, we interviewed officials at 

FAA regional and district offices, regional airlines, pilot schools, and 

college aviation schools. However, because we selected these six states 

as part of a nonprobability sample, our findings cannot be generalized to 

all pilot training stakeholders in the United States. Through the 

combination of site visits and semistructured telephone interviews, we 

interviewed representatives of 24 regional airlines that transported about 

97 percent of regional passengers in 2009, according to the Regional 

Airlines Association’s 2010 annual report. (See table 5.) 

Table 4: Agencies, Organizations, Associations, Schools, and Airline Interviewed 

U.S. federal agencies 

Department of Transportation Office of Inspector General 

Federal Aviation Administration 

FAA Civil Aerospace Medical Institute 

National Transportation Safety Board 

International organizations 

International Civil Aviation Organization 

International Air Transport Association 

Industry associations 

Air Line Pilots Association 

Air Transport Association 

Aviation Accreditation Board International 

Coalition of Airline Pilots Association 

Flight Safety Foundation 

Flight School Association of North America 

National Association of Flight Instructors 
Appendix I: Scope and Methodology 

Page 52 GAO-12-117 Pilot Training 

Professional Aviation Board of Certification 

Professional Aviation Safety Specialists 

Regional Airline Association 

Society of Aviation and Flight Educators 

University Aviation Association 

Industry organizations 

Airline Apps, Incorporated 

FltOps.com 

Pearson Education, Incorporated 

SIM Services 

Pilot schools 

Aerosim Flight Academy 

Airline Transport Professionals 

Arizona State University College of Technology and Innovation 

Aviation Flight Academy, Incorporated 

Dowling College School of Aviation 

Embry-Riddle Aeronautical University 

Phoenix East Aviation 

Purdue University Department of Aviation Technology 

University of North Dakota Department of Aviation 

Airlines 

Air Wisconsin Airline Corporation 

American Eagle 

Atlantic Southeast Airlines 

Comair 

CommutAir 

Delta Air Lines 

ExpressJet 

Horizon Air 

Kenmore Air Harbor 

Mesa Air Group, Inc. (Mesa Airlines and Freedom Airlines) 

Piedmont Airlines 

Pinnacle Airlines Corp. (Pinnacle Airlines, Colgan Air, and Mesaba Airlines) 

PSA Airlines 

Republic Airways Holdings (Republic Airlines, Chautauqua Airlines, Frontier Airlines, 

Shuttle America Corp.) 

SkyWest Airlines 

Trans States Holdings, Inc. (Trans States Airlines, GoJet Airlines, Compass Airlines) 

Source: GAO. 
Appendix I: Scope and Methodology 

Page 53 GAO-12-117 Pilot Training 

In addition, we conducted site visits to the France, Germany, 

Netherlands, and United Kingdom. We focused on these European 

countries’ pilot certification and training requirements because they offer a 

different model than the United States. The site visits allowed us to obtain 

information on European countries’ pilot standards, as well as their efforts 

to revise their training requirements from traditional training objectives 

and methodology to competency-based training models. However, 

because we selected these four countries as part of a nonprobability 

sample, our findings cannot be generalized to all European countries. 

During these site visits, we interviewed officials at the European Aviation 

Safety Agency (Europe’s aviation regulator), civil aviation authority 

officials, representatives from international and European aviation 

stakeholder groups, representatives from airlines, and flight training 

organizations (schools). However, because these four countries were 

selected as part of a nonprobability sample, the findings from our 

interviews cannot be generalized to all European countries. (See table 6.) 

Table 5: Organizations Contacted by Country 

France 

Directorate General of Civil Aviation 

Ecole de Pilotage Amaury de la Grange 

Air France Airlines 

Corsairfly (regional airline) 

International Civil Aviation Organization (ICAO) European Regional Office 

Aircraft Owners and Pilots Association (AOPA) France 

Germany 

European Aviation Safety Agency (EASA) 

Lufthansa Flight Training Pilot School 

Netherlands 

Ministry of Transport, Public Works and Water Management 

Joint Aviation Authorities Training Organization (JAA TO) 

KLM Airlines 

KLM Flight Academy 

Nationale Luchtvaart School (training organization) 

United Kingdom 

United Kingdom Civil Aviation Authority 

Oxford Aviation Academy 

Cabair College of Air Training (Cranfield) 

British Airways 
Appendix I: Scope and Methodology 

Page 54 GAO-12-117 Pilot Training 

Virgin Atlantic 

Willowair (training organization) 

Aircraft Owners and Pilots Association United Kingdom 

General Aviation Safety Council 

Royal Aeronautical Society 

Flight Safety Committee 

Peter Metcalfe (flight instructor) 

Source: GAO. 

We conducted this performance audit from March 2010 through 

November 2011 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives. 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 55 GAO-12-117 Pilot Training 

For several years now, the issue of whether the United States will 

maintain an adequate supply of qualified pilots has emerged in literature, 

media sources, and aviation industry discussions, but the scope of the 

supply of and demand for U.S. airline pilots is unknown and difficult to 

determine. The number of pilot certificates held in the United States has 

been declining and is expected to continue to decline in the near future. 

Demand, which has historically fluctuated, is projected to significantly 

increase over the next 20 years. Nevertheless, the International Civil 

Aviation Organization (ICAO) is predicting a surplus of pilots in North 

America, based, in part, on the regional capacity to provide pilot training, 

level of current and projected pilot population, and the slow growth rate of 

the aircraft fleet requiring additional pilots to operate them. However, 

certain factors could affect that projected surplus, including the 2007 

legislation extending the mandatory retirement age for airline pilots and 

the sharp curtailment of military pilots as a hiring resource. Particularly 

given the decrease in the number of military pilots available to be hired by 

airlines, the number of students who enroll in and complete training in 

pilot schools will also affect the supply of commercial pilots, as the 

availability of pilots for entry-level regional airline jobs can be directly 

linked to the number of pilot certificates issued. Student enrollment in pilot 

schools is purported to be declining and the dropout rate for completing 

pilot training is high. Furthermore, others factors present potential 

challenges to the pilot training industry, such as available financial 

sources to fund pilot training and the impact of the 2010 legislation 

requiring additional pilot certification requirements for airline first officers. 

The safety and economic contribution of the air transportation system not 

only relies on having well-trained airline pilots but also on having enough 

of them to meet demand. The demand for commercial pilots is a function 

of the size the commercial airline fleet and the number of pilots needed to 

operate that fleet size. Demand for professional pilots in the United States 

has historically fluctuated, driven by a number of factors including 

consumer demand for air travel and the general state of the economy, 

fuel prices, regulatory changes, and aircraft fleet changes. For example, 

since 2008, the economic recession has significantly affected the U.S. 

airline industry. Several airlines have filed for bankruptcy and ceased 

operations, while other airlines have merged. It is still unknown when and 

to what extent the U.S. airline industry will fully recover, but demand for 

air travel is highly cyclical and largely reflective of the state of the 

economy, and expected to increase significantly over the next 20 years. 

The total number of pilot certificates held in the United States has been 

fluctuating downward over the last 10 years. The number of active 

Appendix II: Nature and Scope of the Supply 

of and Demand for Airline Pilots 

The Economy and 

Demographics Affect 

Airline Pilot Supply and 

Demand 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 56 GAO-12-117 Pilot Training 

student, private, commercial, and airline transport pilot certificates held in 

the United States decreased from 608,079 in 2000 to 554,237 in 2009, or 

9 percent. The Aircraft Owners and Pilots Association (AOPA) predicts 

that, by 2014, the number of pilots in the United States will decline to 

500,000.1

In late 2010, Boeing projected the commercial aviation industry in North 

America will require over 97,000 new pilots over the next 20 years (over 

466,000 new pilots globally) to accommodate the strong demand for new 

and replacement aircraft, but noted that emerging markets in Asia, 

especially in China, will experience the greatest need for pilots. As 

demand for air travel continues to increase internationally, the demand for 

qualified pilots will likely continue to grow in many parts of the world, 

particularly in Asia and the Middle East and possibly attract qualified 

commercial pilots from the U.S. market. For instance, Boeing forecasts 

that China will need over 70,000 new pilots by 2029 for new commercial 

aircraft. In order to deal with the lack of available pilots today, some 

foreign airlines have started training their pilots through established flight 

training organizations or sending their students to pilot schools in English 

speaking countries, such as the United States. However, if industry 

projections are realized and commercial airlines, both mainline and 

regional, need large numbers of pilots, it is uncertain whether an 

adequate supply of qualified pilots will be available. 

However, despite these projections, ICAO is reporting a likely surplus of 

pilots in North America. ICAO noted in its 2011 report on the 20-year 

global and regional forecast on civil aviation personnel that the United 

States, with close to 270,000 professional pilots (i.e., commercial or 

airline transport), accounts for approximately 58 percent of the global pilot 

population. Furthermore, the United States has an annual training 

capacity for producing about 27,000 professional pilots annually. Based 

on the projected annual need for new pilots and considering several 

factors, ICAO determined that the United States will likely have a surplus 

of pilots under all of the scenarios it considered for the North American 

region (i.e., the United States and Canada). This may seem surprising 

considering the general perception that a pilot shortage in the United 

States is inevitable, but was supported by ICAO based on the following 

 

1

The Aircraft Owners and Pilots Association is the largest not-for-profit general aviation 

association in the world and serves more than 415,000 members. 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 57 GAO-12-117 Pilot Training 

reasons. First, the annual training capacity in the United States 

represents 60 percent of the worldwide training capacity; thus, the ICAO 

calculations indicate that North America has more than enough training 

capacity to train the number of new pilots needed in this region. Second, 

fleet growth rates—i.e., the number of aircraft needing pilots—for the 

North American region for which the United States is the dominant player, 

are relatively low. Third, the current number of licensed professional pilots 

in the United States represents 58 percent of the global pilot population. 

Although these factors do point to a surplus, other economic and 

demographic factors that can be difficult to determine could affect the 

projected surplus. 

The temporary impact of recent legislation could affect the availability of 

commercial pilots in the future and other measures may be required to 

address related long-term issues. When recent concerns arose about a 

potential pilot shortage, the Fair Treatment for Experienced Pilots Act was 

enacted (age 65 law) in 2007 and allowed pilots to fly domestic routes 

until age 65 instead of the prior mandatory retirement age of 60.2

 For 

international flights, one pilot may be up to age 65 provided the other pilot 

is under age 60, consistent with the November 2006 ICAO standard. This 

effort attempted to ensure there would not be a large group of highly 

skilled pilots retiring at the same time, but according to ICAO data, 

pending age-related retirements will begin to reemerge in 2012. The 2011 

ICAO report also indicated that approximately 85,000 professional pilots 

(31 percent of the total pilot population) are aged 55 or more; among this 

age group, 34,000 (13 percent of the total pilot population) will be eligible 

for retirement by 2015. Another 34,000 will be eligible for retirement by 

2020. The report also asserted that it is likely, considering the age 

structure of pilots in North America, that retirements will take place at an 

accelerating rate, thereby contributing to a potential increase in future 

pilot demand. However, all of the pilots holding commercial or airline 

transport pilot certificates in the United States may not be automatically 

hired by airlines due to performance and skills deficiencies. Therefore, 

despite a projected surplus of professional pilots, having only a potentially 

limited supply of pilots that airlines determine to be qualified to hire could 

still affect the air transportation industry in the United States. 

 

2

Pub. L. No. 110-135, §2, 121 Stat. 1450 (2010). 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 58 GAO-12-117 Pilot Training 

In addition, one of the traditional, preferred sources of airline pilots has 

been severely curtailed, which will likely continue to affect the availability 

of pilots in the future. U.S. commercial airlines are no longer hiring as 

many pilots from the U.S. military as they had in the past, which has 

historically provided airlines with a steady supply of highly qualified pilots. 

According to literature sources, until the 1990s, roughly 90 percent of the 

pilots hired by mainline airlines came from the U.S. military, with the 

remaining source being from civilian aviation. In 2008, about 30 percent 

of pilots hired by commercial airlines had military training backgrounds. 

Moreover, the military is training fewer pilots and retaining more of them 

with better pay and other financial incentives. In addition, many 

commercial airline pilots from Vietnam era are reaching retirement age. 

Particularly given the decrease in military pilots as a source of potential 

civilian pilots, the number of students who enroll in and graduate from 

pilot schools also affects the supply of pilots, and could affect the ICAO 

projected surplus of pilots for the North America region, specifically in the 

United States. The availability of pilots for entry-level regional airline jobs 

can be directly linked to the number of student pilot starts and the number 

of pilot certificates issued. In the past few years, the Federal Aviation 

Administration (FAA) has revised its forecast to reflect an uncertain 

number of student pilots. In 2008, FAA predicted 100,200 student pilots in 

the year 2025, but lowered that estimate in its 2009 through 2025 forecast 

report to 86,600. However, in FAA’s 2011 through 2031 forecast report, 

FAA predicted the number of student pilots increasing to 113,500 in 2025 

(120,600 in 2031), due to a rule change by FAA that makes student pilot 

certificates valid longer for pilots under the age of 40.3

 Also, from 1999 

through 2009, the number of private certificates issued decreased about 

26 percent, but commercial certificates slightly increased about 10 

percent. Representatives of the pilot training industry that we interviewed 

told us that the overall trend reflects a lower number of domestic students 

starting pilot training, a trend which continued into 2011. Representatives 

from a few pilot schools told us that pilot schools across the United States 

experienced large declines in enrollments in 2010. For example, the 

University of Illinois decided to eliminate its 65-year-old aviation school 

 

3

In August 2009, FAA issued a final rule that increased the duration of validity for student 

pilot certificates for pilots under the age of 40 from 36 to 60 months. 74 Fed. Reg. 42500 

(Aug. 21, 2009). This resulted in the increase in active student pilots to 119,119 from 

72,280 at the end of 2009. 

Domestic Student 

Enrollments in U.S. Pilot 

School Is Declining and 

the Dropout Rate of 

Student Pilots Is High 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 59 GAO-12-117 Pilot Training 

after a decade of declining enrollment. The collegiate aviation school 

produced fewer degrees and served fewer students than any other 

program on the campus during the previous school year and no aviation 

students had been accepted for the coming semester. 

The decline of student pilot certificates and student dropout rate are 

concerns to AOPA. According to AOPA, the number of current student 

pilot certificates is the best indicator of the supply of future pilots. 

Representatives of several pilot schools with whom we spoke told us that 

they were becoming more and more dependent on foreign students to 

maintain their pilot training operations. Also, according to FAA officials, 

representatives of AOPA, four pilot schools, and several European 

organizations we interviewed said that some European and Asian airlines 

and pilot training organizations send students to the United States for pilot 

training to take advantage of the relatively inexpensive fuel and the yearround weather conditions for training in states such as Florida and 

Arizona. In addition, the dropout rate of student pilots could affect the 

supply of pilots. According to a 2010 AOPA study, almost 80 percent of 

student pilots drop out of training for four key reasons: (1) lack of 

educational quality, (2) lack of customer focus (not a good value or pricing 

not competitive), (3) insufficient sense of community (lacks an 

atmosphere that makes students feel welcome in the aviation 

community), and (4) lack of information sharing (school does not provide 

realistic estimate of time and costs required for a pilot certificate and 

statistics on student success rates at schools).4

 The study indicated that 

while cost of training was a factor, it was less significant than the other 

four reasons people did not complete training—even though some 

literature suggests otherwise as discussed below. 

AOPA, as a result of this information regarding the dropout rate, has 

initiated efforts with close coordination with the pilot training industry to 

work on solutions to stop the outflow of students and to increase the pilot 

population. AOPA has begun an initiative focused on student retention in 

pilot training that will consist of a series of regional meetings across the 

United States to collect perspectives and industry input on potential 

improvements that can be made in providing pilot training. AOPA has met 

with representatives from the aviation community, including pilots, student 

 

4

AOPA, The Flight Training Experience: A Survey of Students, Pilots, and Instructors, 

October 2010. 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 60 GAO-12-117 Pilot Training 

pilots, aviation businesses, pilot schools, and flight instructors who are 

currently involved in conducting pilot training. In addition, the association 

has launched a Let’s Go Flying Web site (www.aopa.org/letsgoflying) and 

created various publications to inspire more people to become interested 

in learning to fly by providing an introduction to and information about 

becoming a pilot. 

Aviation stakeholders from 4 of the 9 pilot schools, two industry 

associations, and one industry organization we interviewed told us that 

one of most important challenges for maintaining an adequate supply of 

students for pilot schools is the availability of financial support for pilot 

training. Pilot training costs vary amongst the pilot schools. According to 

AOPA and other sources, the cost of training from the beginning of 

training through a commercial pilot certificate and a multiengine rating 

could be in excess of $40,000 but varies across the country. According to 

AOPA, pilot training can cost about $100,000 or more at most collegiate 

aviation schools for a 4-year degree and the flight training provided. The 

University Aviation Association (UAA) indicated that there is no single 

comprehensive information source regarding the cost of pilot training 

across the United States, but AOPA officials told us costs vary between 

$40,000 and $100,000 for the training needed to obtain a commercial 

pilot certificate and a multiengine rating. Furthermore, as previously 

stated, pilots would likely be responsible for any increased costs if 

additional training requirements were developed by FAA. The costs are 

high compared to the low starting salaries. According to a 2009 survey by 

the Regional Airline Association (RAA) of member airlines based on 2008 

salary data, the salaries for regional pilots generally averaged between 

$28,000 and $43,000 for regional airline first officers and $62,000 to 

$102,000 for regional airline captains. RAA estimated that salaries have 

increased 2 to 5 percent since but it does not have more current data. 

Some stakeholders we interviewed said that these realities could 

potentially prevent prospective students from enrolling in a pilot school or 

reduce the desire to become a pilot. However, it is important to note that 

the previously mentioned AOPA study reported that that training costs 

were not a statistically significant reason individuals dropped out of 

training. 

A range of tuition resources is available, but some of these sources are 

drying up. To pay for pilot training, AOPA officials said that students 

typically use personal funds, personal credit (credit cards and personal 

loans), scholarships, grants, parent or student loans, other educational 

loans, and the Veterans Administration’s (VA) Montgomery GI Bill 

Challenges to Financing 

Pilot Training Could Affect 

Enrollment 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 61 GAO-12-117 Pilot Training 

benefits. For example, AOPA offers loans for pilot training up to $25,000 

and allows flexible funding options for students since AOPA does not limit 

the use of funds to certain types of schools or training. One benefit of 

collegiate schools and some vocational schools is that they are generally 

eligible to receive VA benefits and federal financial aid (such as federal 

education loans or grants). However, flight instructor-based schools do 

not generally qualify for federal financial aid or VA benefits. VA benefits 

allow a qualified student to be reimbursed up to 60 percent for ground 

and pilot training costs to the maximum allowable limit, but do not fund 

training for a private pilot certificate. Many financial institutions have 

provided financing for pilot training through educational loan programs, 

such as the Federal Family Education Loan program, and personal 

loans.5

 According to literature we reviewed and representatives of four 

pilot schools and three industry associations we interviewed indicated that 

many of the private banks have been tightening restrictions on financing 

available to potential new pilot students, and others have left the pilot 

training loan market. The National Association of Flight Instructors 

reported that Sallie Mae took a $1 billion loss in 2009 for educational 

loans, which explains, in part, the reason it has become increasingly 

difficult to obtain funding.6

 We reported in November 2009 that many 

lenders offering student loans have exited the market in response to 

limited access to capital resulting from the credit crisis.7

 Thus, lenders 

have begun to give pilot training a higher risk profile than in the past and 

have been slowly exiting this loan market. 

Representatives of the regional airlines we interviewed and stakeholder 

associations have voiced a significant level of concern regarding the 

legislative mandate to increase the number of flight hours needed for first 

officers to be hired by commercial airlines. As discussed earlier in the 

report, the Airline Safety and Federal Aviation Administration Extension 

 

5

The Federal Family Education Loan program allowed private financial institutions to 

provide students with loans, but the federal government assumed the risk of default, and 

paid the financial fees while the student attended college. As of July 2010, federal 

education loans are now made directly by the U.S. Department of Education under the 

Federal Direct Loan Program. 

6

Sallie Mae is the largest servicer of federally guaranteed student loans and the largest 

originator and servicer of private student loans. 

7

GAO, Higher Education: Factors Lenders Consider in Making Lending Decisions for 

Private Education Loans, GAO-10-86R (Washington, D.C.: November 2009). 

Recent Efforts to Improve 

Airline Safety and Pilot 

Training Could Impact 

Pilot Availability 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 62 GAO-12-117 Pilot Training 

Act requires that FAA develop regulations requiring all airline pilots, 

including the first officers, to hold an airline transport pilot certificate—the 

highest level of pilot certification and requiring the highest number of total 

flight hours—instead of the commercial pilot certificate that is required 

today.8

 Aviation stakeholders have voiced significant concerns that 

requiring first officers for regional airlines to possess an airline transport 

pilot certificate will likely result in the inability to fill some positions due to 

the lack of qualified pilots. The overall decreasing trends in pilot 

certificates being issued is illustrated in table 4 with the general decline in 

the number of airline transport pilot certifications issued from 1999 

through 2009 from pilot schools operating under Part 61, Part 141, and 

Part 142 regulations. The number of airline transport certificates issued 

decreased about 60 percent. 

Table 6: Airline Transport Pilot Certifications Issued from 1999 through 2009 from 

Pilot Schools Operating under Part 61, Part 141, and Part 142 

Year Part 61 Part 141 Part 142 Total

1999 6,666 4 503 7,173

2000 6,652 5 1,039 7,696

2001 5,735 2 957 6,694

2002 3,670 3 904 4,577

2003 3,087 10 844 3,941

2004 3,490 2 987 4,479

2005 3,579 6 1,130 4,715

2006 3,542 4 1,191 4,737

2007 4,873 4 1,123 6,000

2008 3,845 6 1,022 4,873

2009 2,078 2 815 2,895

Source: FAA. 

Note: Training for the airline transport pilot certificate is generally provided by pilot schools that train 

students under Part 61 and Part 142 regulations. 

Aviation stakeholders such as AOPA and RAA have both also voiced 

concerns that increasing pilot certification requirements to become an 

airline pilot could significantly discourage potential pilots from entering 

aviation due to the increased time and expense required to meet the new 

 

8

Pub. L. No. 111-216, §217(a), 124 Stat. 2348, 2367. 
Appendix II: Nature and Scope of the Supply of 

and Demand for Airline Pilots 

Page 63 GAO-12-117 Pilot Training 

hiring minimums of airlines. For example, regional airline officials we 

interviewed said the new requirement will create a gap in experience for 

new pilots seeking entry level airline jobs that could take several years to 

fill. Furthermore, AOPA said the cost of obtaining the additional 1,250 

flight hours needed to meet the total time for an airline transport pilot 

certificate could deter many new pilots into pursuing other professional 

careers by increasing the number of flight hours to obtain employment as 

an airline pilot. Additionally, the 2011 ICAO report mentioned earlier 

stated that even though the United States has sufficient training 

capacities, the requirement that all commercial airlines’ first officers have 

an airline transport pilot certificate could drastically limit the availability of 

first officers to support existing delivery schedules for new aircraft at 

many airlines. 

The majority of officials representing the regional airlines we interviewed 

also indicated that the proposed FAA rules to revise pilot duty and rest 

requirements will potentially create a need for more pilots.9

 Provisions in 

the Airline Safety and Federal Aviation Administration Extension Act of 

2010 directed FAA to issue a regulation to specify limitations on the hours 

of pilot flight and duty time to address problems relating to pilot fatigue.10

NTSB has long been concerned about the possible safety effects of 

fatigue in the aviation industry—specifically pilots—and have issued 

several safety recommendations to FAA after identifying it as a 

contributing factor in several aviation accidents. FAA identified the issue 

of pilot fatigue as a top priority following the Colgan Air crash, and the 

NTSB accident report stated the pilots’ performance was likely impaired 

because of fatigue, but the degree to which it contributed could not be 

conclusively determined. The proposed changes to the duty and rest 

requirements of pilots will likely mean airlines need more pilots to comply 

with the new rules. The officials said the industry will likely see a greater 

demand for these additional pilots over the next few years, but this will 

depend on each airline’s staffing ratios for its aircraft and flight operations. 

However, the general response was that the rule changes would require 

more qualified pilots in order to maintain the same level of service. 

 

9

75 Fed. Reg. 55852 (Sept. 14, 2010). FAA’s proposed rule (1) sets a 9-hour minimum for 

rest prior to flying-related duty (a 1-hour increase over the current rules), (2) establishes a 

new method for calculating a pilot’s weekly, monthly, and yearly flight time limits so that 

pilots can receive at least 8 hours of sleep during that rest period, and (3) sets a daily 

flight duty period to 13-hours (currently it is a 16-hour duty period between rest periods). 

10Pub. L. No. 111-216, §212, 124 Stat. 2348, 2362. 
Appendix III: GAO Contact and Staff 

Acknowledgments 

Page 64 GAO-12-117 Pilot Training 

Gerald L. Dillingham, Ph.D., (202) 512-2834 or dillinghamg@gao.gov

In addition to the contact named above, the following individuals made 

important contributions to this report, Keith Cunningham, Assistant 

Director; Richard Brown; Owen Bruce; Vashun Cole; Cindy Gilbert; Brian 

Hackney; Bob Homan; David Hooper; Amber Keyser; Nitin Rao; Amy 

Rosewarne; and Michael Silver. 

Appendix III: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(540212)
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