U.S. Department of Transportation 

FEDERAL AVIATION 

ADMINISTRATION

REGULATORY EVALUATION

QUALIFICATION, SERVICE AND USE OF 

CREWMEMBERS AND AIRCRAFT DISPATCHERS 

 

SUPPLEMENTAL NOTICE OF PROPOSED RULEMAKING 

(14 CFR 65, 119, 121, 135, 142) 

Office of Aviation Policy and Plans 

Operations Regulatory Analysis Branch, APO-300 

March 2010 
TABLE OF CONTENTS 

Section Page No.

I. Introduction..............................................................................................................2 

II. Background ...........................................................................................................2 

III. Benefit-Cost Analysis ..............................................................................................5 

 III.A. General Assumptions ....................................................................................5 

 III.B. Benefit Analysis ............................................................................................6 

 III.B.1. Benefit Assumptions .............................................................................6 

 III.B.2. Accident Population and Scoring..........................................................7 

 III.B.3. Quantification of Safety Benefits..........................................................9 

 III.B.3.A. Pilots Training Benefits 

 III.B.3.B. Flight Attendant Training Benefits 

 III.B.3.C. Aircraft dispatcher Training Benefits 

 III.B.3.D. Qualitative Benefit Discussion 

 III.B.3.E. Quantified Accident Prevention Benefit Summary 

 III.C. Costs............................................................................................................25 

 III.C.1. General Cost Assumptions and Data Sources.....................................25 

 III.C.2. Subpart BB Costs ................................................................................26 

 III.C.2.A Pilot, Flight Attendant and Flight Engineer Assumptions 

 III.C.2.B. Number of Pilots, Flight Attendants and Flight Engineers 

Affected 

 III.C.2.C. Subpart BB Pilot and Flight Engineer Cost Estimation 

Methodology 

 III.C.2.D. Subpart BB Flight Attendant Cost Estimation Methodology 

 III.C.3. Subpart CC Costs ................................................................................50 

 III.C.3.A Aircraft dispatcher Assumptions 

 III.C.3.B. Number of Aircraft dispatchers Affected 

 III.C.3.C. Subpart CC Aircraft dispatcher Cost Estimation Methodology 

 III.D. Government Costs.......................................................................................56 

 III.E. Industry Cost Estimate ................................................................................61 

IV. Poisson Distribution Analysis Modeling Accident Probability............................ 64 

V. Benefit Cost Summary...........................................................................................66 

 

VI. Appendices.............................................................................................................70 
2

I. INTRODUCTION 

In January 2009, the FAA published a notice of proposed rulemaking (NPRM) for 

“Qualification, Service, And Use of Crewmembers And Aircraft Dispatchers”. Based on 

industry comments, the FAA has updated the NPRM regulatory evaluation. This preliminary 

regulatory evaluation estimates the costs and benefits of a supplemental notice of proposed 

rulemaking (SNPRM) to amend the regulations for training programs of air carriers that operate 

under parts 121 and 121/135. The proposed changes are intended to increase safety and 

contribute significantly to reducing the frequency of aviation accidents. The proposal also 

reorganizes and revises training and qualification requirements to make them easier to use and 

understand. 

The primary purpose of this proposed rule is to establish new requirements for traditional air 

carrier training programs to ensure that safety-critical training and evaluation is provided for 

crewmembers and aircraft dispatchers. In developing the training and evaluation requirements, 

the FAA reviewed the current standards in subparts N, O and P, as well as the flight training 

tasks listed in Appendix E (flight training requirements), F (proficiency check requirements), and 

H (advanced simulation) of part 121. 

The FAA estimates the total cost of the proposed rule would be approximately $391.9 million in 

nominal dollars, $199.1 million at a seven percent present value, and $290.3 million at a three 

percent present value. The estimated potential quantified safety benefits over the 10-year 

analysis interval is $445.1 million, $222.9 million at a seven percent present value, and $327.5 

million at a three percent present value. 

The FAA estimates the total cost of the proposed rule would be approximately $391.9 million in 

nominal dollars, $199.1 million at a seven percent present value, and $290.3 million at a three 

percent present value. The estimated potential quantified safety benefits over the 10-year 

analysis interval is $445.1 million, $222.9 million at a seven percent present value, and $327.5 

million at a three percent present value. The following table shows these results. 
3

II. BACKGROUND 

The regulations governing pilots, flight engineers, flight attendants and aircraft dispatcher 

qualification and training requirements are in 14 CFR part 121 subparts N and O. Subpart N 

prescribes the requirements for establishing and maintaining a training program for pilots, flight 

engineers, flight attendants, aircraft dispatchers, and other operations personnel and requirements 

for the use of training devices in conducting the program. Subpart O prescribes pilot, flight 

engineer and flight attendant qualifications. Appendix E to part 121 establishes the training tasks 

required for pilot initial, transition, and upgrade flight training. Appendix F to part 121 

establishes the tasks for pilot proficiency checks. Appendix H to part 121 provides guidelines 

and a means for using advanced airplane simulators for flightcrew training and checking. 

The FAA reviewed its crewmember training regulations to identify improvements in training 

program content and application that would reduce human error among crewmembers, 

particularly in hazardous or emergency situations. Based on this review, the FAA identified the 

following proposed changes to the current rules: 

• Train and evaluate flightcrew members in a complete flightcrew environment. 

• Require Line Oriented Flight Training (LOFT) to be administered in a simulator during 

recurrent training. 

• Require training and practice in the use of Crewmember Resource Management (CRM) 

principles integrated with technical skills. 

• Require a qualified Flight Simulation Training Device (FSTD) to be used for training, 

testing, and checking of flightcrew members. 

• Require simulator training for proper pilot reaction to Traffic Alert and Collision Avoidance 

System (TCAS) Resolution Advisories. 
4

• Provide a structured training program based on newly prescribed Qualification Performance 

Standards (QPS), and on programmed hours that may not be reduced below levels prescribed 

by regulation. 

• Maintain individual pilot proficiency test and proficiency check records for five years, in 

accordance with the Pilots Records Improvement Act (PRIA). 

• Require training in the following special hazards: 

 - Unusual attitudes, and 

- Upset/disturbance and loss of control. 

Generally, the proposed reorganization of the training and qualification requirements would 

accomplish the following: 

• Consolidate crewmember requirements in current subparts N and O of part 121 into a 

new subpart BB. 

• Delete obsolete references to flight navigators. 

• Dispatcher requirements in current subparts N and P of part 121 would be consolidated 

into a new subpart CC. 

• Drug and alcohol testing requirements and hazardous materials training requirements to 

remain in subparts N and O. 

• Consolidate practical training and checking standards in appendices E and F of part 121 

into revised QPS appendices for pilots and flight engineers. 
5

III. BENEFIT-COST ANALYSIS 

This section details the derivation of the FAA’s estimation of the benefits and costs. First, we 

discuss the general assumptions used in our estimation of the benefits and costs. Then we 

explain the estimation of the quantified and qualified benefits. Next, we discuss the estimation 

of the quantified costs. We then present the estimation of costs to the Federal Government. 

Airline operators separately estimated their costs and impacts. Their cost estimate is presented 

for information. Lastly, we summarize benefits and costs for this SNPRM. 

III.A. General Assumptions 

The FAA made the following general assumptions to facilitate the benefit and cost analysis for 

this regulatory evaluation: 

• The base year is 2010. 

• All monetary values are expressed in constant 2010 dollars. The present value of the 

potential 10-year benefit stream was calculated by discounting the monetary values using a 

three and seven percent present value rate from 2016 to 2025. 

• This final rule would be published in 2011. 

• This proposed rule would become effective 120 days after publication of the final rule. The 

compliance date for airlines would be in 2016 or five years after the effective date of the final 

rule. 

• The analysis period extends for 10 years from 2016 through 2025. We believe this analysis 

period fully accounts for the expected benefits and costs. 

• It is not the intent of the FAA, for this proposed rule to affect operators with AQP pilot 

training programs beyond adding minimal costs. Therefore, the FAA did not include 

Advanced Qualification Program (AQP) operator costs in the SNPRM’s cost estimate or 

accidents that occurred by operators with AQP pilot training programs in the benefit 

estimate. Based on the FAA’s analysis of six existing AQP operators, on average, this 

proposal could require an AQP operator to be expected to add five to six tasks to their current 

training curriculum, assuming the carrier has not obtained approval of alternative means of 
6

compliance for tasks not currently addressed. Also, based on an estimate that each task may 

take from two to 10 minutes, this may result in anywhere between 10-60 minutes of 

additional training to an operator’s current program. The FAA believes that the cost of these 

additional five to six tasks would be minimal for those operators with AQP pilot training 

programs. 

The FAA requests comments on these assumptions, accompanied by clear documentation. 

III.B. Benefit Analysis 

The FAA estimates the phased-in benefits of this proposed rulemaking are about $445.1 million 

in nominal dollars, $222.9 in seven percent present value, and $327.5 million in three percent 

present value terms. The benefits would accrue from the proposed additional operational and 

training initiatives that are designed to meet the aviation accident reduction goals established in 

the FAA’s safety agenda. The proposed regulations would enhance traditional training programs 

by requiring the NTSB recommended use of flight simulation training devices for pilots and 

flight engineers, and including additional training requirements in areas that are critical to safety. 

Although the FAA believes the methodology employed in the regulatory evaluation (RIA) 

provides an accurate estimate of benefits associated with the provisions of the SNPRM, in 

Appendix 8, we also discuss an alternate methodology that would result in a more conservative 

estimation of benefits. 

III.B.1. Benefit Assumptions 

In addition to the general assumptions at the beginning of the Benefit-Cost analysis section, the 

FAA made the following general assumptions to facilitate the benefit analysis for this regulatory 

evaluation: 

• Past accident history is an accurate reflection of future accidents. 

• Safety benefits are realized after 2016, when programs must be in place. 
7

The FAA requests comments on these benefit assumptions, accompanied by clear 

documentation. 

III.B.2. Accident Population and Scoring 

The FAA expects the major benefit of this proposed rule would be to prevent or mitigate future 

accidents. For the accident avoidance safety benefit analysis, the FAA reviewed accident data 

for U.S. certificate holders required to train under parts 121 and 121/135 over the 22-year 

interval from 1988 through 2009. The FAA Accident Investigation and Prevention Group (AVP) 

provided a listing of all parts 121 and 121/135 accidents that have occurred since 1988. The 

FAA Flight Standards Service (AFS) and AVP reviewed each of these accidents and developed a 

list of accidents potentially related to this rule, including 240 pilot related accidents, 22 flight 

attendant related accidents, and seven dispatcher accidents for a total of 269 accidents. The 

National Transportation Safety Board (NTSB) investigations identified several areas of 

inadequate training that were either the probable cause or contributing factors for many of these 

accidents, such as incomplete manuals, inadequate standards/procedures, unstabilized approach 

below 500 feet, crew resource management, turbulence, thunder storms, wind shear, instrument 

flight rules (IFR) conditions, crosswind, and tailwind. For each of these accidents, AFS 

developed a regulatory change that could have mitigated each accident. 

From the list of 269 accidents, the FAA eliminated duplicate accident listings and accidents by 

operators with an AQP pilot training program since this rulemaking would have only minimal 

impact on these operators. We then eliminated accidents that occurred while the carrier was 

operating under part 135. After the 1995 commuter rule, part 135 operators were merged into 

part 121 creating a higher standard of safety on these operators flightcrew training programs. In 

addition, since the proposal only applies to part 135 operators in commuter scheduled service 

with two pilots, as dictated by the type certificate data sheets, no current part 135 operators meet 

these criteria or would be affected by the proposed rule. 
8

This elimination process resulted in a list of 149 pilot-related accidents, 22 flight attendantrelated accidents, and seven dispatcher-related accidents. Of the 149 pilot-related accidents, 23 

(about 15 percent) involved one or more fatalities and 126 (about 85 percent) had no fatalities. 

The pilot related-accidents resulted in 491 fatalities, 169 serious injuries, and 572 minor injuries. 

The flight attendant-related accidents resulted in one fatality, 24 serious injuries, and 42 minor 

injuries. There were no fatalities, three serious injuries, and one minor injury for the seven 

dispatcher-related accidents. 

The importance of training varies for each of the accidents. Therefore, the FAA Accident 

Investigation and Prevention group (AVP) rated each accident by conducting a Commercial 

Aviation Safety Team (CAST) scoring process. All of the accidents that have had final National 

Transportation Safety Board (NTSB) reports published have been scored against the CAST 

safety enhancements. AVP used the NTSB recommendations along with narratives, probable 

cause, contributing factors and other pertinent data to score the accidents. 

AVP used a Joint Implementation Monitoring Data Analysis Team (JIMDAT)-like method 

because many of the issues in these accidents are not well defined in the probable cause or 

contributing factors statements of the NTSB reports. The JIMDAT-type scoring system is from 

0 to 5, and the score is based upon the likelihood that the rule change would have mitigated that 

accident. The scoring does not consider the effects of AQP, nor does it reflect GPWS-TAWS1

and the virtual elimination of Part 121 CFIT (Controlled Flight Into Terrain) accidents. The 

level and percentage of effectiveness criteria follows: 

5- 95% effectiveness. The proposed requirement directly addresses the NTSB causal factors 

and would prevent the accident in the future. 

4- 75% effectiveness. The proposed requirement directly addresses the majority of the 

NTSB causal factor and would probably prevent or is likely to reduce the risk of the respective 

accident, given the circumstances that prevailed. 

 

1

 (Ground Proximity Warning System)-( Terrain Awareness Warning System) 
9

3- 55 % effectiveness. The proposed requirement directly addresses one of several NTSB 

causal factors and is likely to reduce the risk of the respective accident, given the circumstances 

that prevailed. 

2- 35% effectiveness. The proposed requirement generally addresses the NTSB causal 

factors and is likely reduce the risk of the respective accident, given the circumstances that 

prevailed. 

1- 15% effectiveness. The proposed requirement is likely to have reduced the risk of the 

respective accident, given the circumstances that prevailed. 

0- 0% effectiveness. The proposed requirement would not reduce the risk of this type of 

accident in the future. 

Table 1 shows the distribution of these effectiveness criteria for the pilot, flight attendant and 

dispatcher-related accidents. 

The accident date, operator, aircraft model, accident location, and effectiveness criteria are in 

Appendix 1 for the pilot-related accidents, Appendix 2 for the flight attendant-related accidents 

and Appendix 3 for the dispatcher-related accidents. 

III.B.3. Quantification of Safety Benefits 

This section describes the methodology to quantify the safety benefits for the proposed rule. We 

first discuss the component costs of an averted accident which form the quantitative basis for 
10

future pilot, flight attendant and dispatcher-related benefits. We then present the methodology 

we developed to estimate the safety benefits for the pilot, flight attendant and aircraft dispatcherrelated historical accidents. Lastly, we summarize our quantified safety benefit estimates for 

pilots, flight attendants, and dispatchers. 

The proposed regulations enhance traditional training programs by requiring the use of flight 

simulation training devices for pilot and flight engineers and including additional training 

requirements in areas that are critical to safety. The proposal also reorganizes and revises the 

qualification and training requirements. The proposed changes are intended to contribute 

significantly to reducing aviation accidents. 

The benefit of avoiding an accident includes averted fatalities, injuries, aircraft replacement or 

repair, and accident investigation costs. In estimating benefit values, the FAA uses $6.0 million 

as a base case for an avoided fatality (VSL), $521,000 for a serious injury (assumed to be the 

average of a severe, serious, and moderate injury), and $12,000 for a minor injury.2 The 

additional associated medical and legal costs for a fatality are $265,400, for a serious injury 

(assumed to be the average of a severe, serious, and moderate injury) $93,267, and for a minor 

injury $5,000.3

 The weighted average air carrier accident investigation cost for the NTSB is 

$110,300, for an FAA accident investigation $57,800, and for a private accident investigation 

$280,900.4

 The NTSB accident investigation reports provided the number of fatalities and 

injuries.5 The FAA also conducted a sensitivity analysis on the VSL which is discussed in the 

“Sensitivity Analysis on VSL and Hourly Pilot Simulator Costs” section below. 

Destroyed aircraft were valued at their replacement cost. 6 Aircraft with substantial damage were 

valued at 13 percent of the aircraft value.7 Aircraft with minor damage were not valued in this 

 

2Office of the Secretary of Transportation Memorandum, "Treatment of Value of a Statistical Life in Departmental 

Analysis – 2009 Annual Revision”, March 2009. 

3APO Bulletin APO-2-1, “Treatment of Value of Life and Injury in Economic Analyses”, February 2002, updated in 

2010 and included in Appendix 4. 

4

http://www.faa.gov/regulations_policies/policy_guidance/benefit_cost/media/050404%20Critical%20Values%20D

ec%2031%20Report%2007Jan05.pdf 

5

https://www.ntsb.gov/aviation/aviation.htm 

6Table 5.1 from the “Economic Values for FAA Investment and Regulatory Decisions, A Guide”, updated in 2009 

and included in Appendix 5. 

7

 Ibid. Restoration of repair. 
11

evaluation. The FAA determined the aircraft damage status from NTSB accident investigation 

reports.8

III.B.3.A. Pilot Training Benefits 

This section details the methodology used to estimate future safety benefits estimated from the 

historical pilot-related accidents. 

Using the scoring effectiveness and component costs described above, we computed the safety 

benefits for fatalities, injuries, and inspections for each of the 149 pilot-related accidents. Next,

we estimated the aircraft replacement or repair values based on amount of damage reported in 

the NTSB accident reports for each accident. We then summed the safety benefits for our 

fatality, injury, and inspection estimate with the aircraft replacement or repair estimate for each 

accident. We multiplied that sum by the AVP effectiveness ratio for each accident to obtain a 

final safety benefit value per accident. Lastly, we summed all accidents’ safety benefit values to 

equal an estimated total value of about $964.0 million. 

The pilot-related accidents occurred over the 22-year interval from 1988 to 2009. The most 

recent accident this rule would mitigate is the Colgan Air accident in February 2009. Computing 

the mean of the estimated total value of about $964.0 million over the 22-year historical pilotrelated accident interval resulted in about $43.8 million per year. Assuming an equally likely 

preventable accident average would happen in any year over the 10-year analysis interval results 

in a total benefit of about $438.2 million in nominal terms, $219.4 million for a seven percent 

present value, and $322.4 million for a three percent present value. 

Table 2 shows these results. 

 

8

 https://www.ntsb.gov/aviation/aviation.htm 
12

III.B.3.B. Flight Attendant Training Benefits 

This section presents the methodology used to estimate future safety benefits estimated from the 

historical flight attendant-related accidents. 

Using the component costs described above, we computed the safety benefits for fatalities, 

injuries, and inspections for each of the 22 accidents involving a flight attendant. The losses 

from these accidents were largely due to injuries. Next, we estimated the aircraft replacement or 

repair values based on amount of damage reported in the NTSB accident reports for each 

accident. According to the NTSB accident reports, the accidents involving flight attendants were 

mostly the result of turbulence, which resulted in injuries but little to no airplane damage. One 

accident involved a flight attendant who died, while operating an exit door, by setting off an 

explosive door release when the aircraft was pressurized. We included the airplane damages for 

this accident. 

We then summed the safety benefits for our fatality, injury, and inspection estimate with the 

aircraft replacement or repair estimate for each accident. Next, we multiplied the sum by the 

AVP effectiveness ratio for each accident to obtain a final safety benefit value per accident. 
13

Lastly, we summed each of the safety benefit values to obtain an estimated total value of about 

$10.8 million. 

Flight attendant-related accidents occurred over the 22-year interval from 1988 to 2009. We 

note that all of the flight attendant-related accidents used in this analysis occurred from 1995 to 

2007. There may have been a change in the NTSB record keeping in 1998. We request 

comment on what may be an anomaly causing our benefit estimate to be understated. 

Computing the mean of the estimated total value of about $10.8 million over the 22-year 

historical flight attendant-related accident interval resulted in about $491,000 per year. 

Assuming an equally likely preventable accident average would happen in any year of the 10-

year analysis interval result in about $4.9 million in nominal terms, $2.5 million for a seven 

percent present value, and $3.61 million for a three percent present value. 

Table 3 shows these results. 

III.B.3.C. Aircraft Dispatcher Training Benefits 

This section discusses the methodology used to estimate future safety benefits estimated from the 

historical dispatcher-related accidents. 
14

In six of the seven accidents cited, the NTSB focused on the aircraft dispatcher's failure to 

provide the crew with weather, turbulence, braking, or Notice to Airmen information. The 

SNPRM provides a structured approach to training dispatchers in their operational control 

responsibilities and authority. This training coupled with an effective Dispatcher Resource 

Management (DRM) program could have prevented these accidents with the prompt interaction 

of the aircraft dispatcher and Pilot in Command during abnormal weather events. In the seventh 

accident, the aircraft dispatcher was not cited, because the operator was a supplemental carrier 

operating with a flight following system (i.e. there was no dispatcher). In the SNPRM, we are 

proposing that supplemental carriers be required to have certificated aircraft dispatchers who will 

have equal responsibility with the pilot or flight engineer for the pre-flight planning, including 

weight and balance. 

Using the component costs described above, we computed the safety benefits for fatalities, 

injuries, and inspections for each of the seven dispatcher-related accidents. Next, we estimated 

the aircraft replacement or repair values based on amount of damage reported in the NTSB 

accident reports for each accident. 

For each accident, we then summed the safety benefits for our fatality, injury, and inspection 

estimate with the aircraft replacement or repair estimate for each accident. Next, we multiplied 

the sum by the AVP effectiveness ratio for each accident to obtain a final safety benefit value per 

accident. Lastly, we summed each of the safety benefit values to obtain an estimated total value 

of about $4.34 million. 

Aircraft dispatcher-related accidents occurred over the 22-year interval from 1988 to 2009. We 

note that all of the aircraft dispatcher-related accidents used in this analysis occurred from 1998 

to 2007. There may have been a change in the NTSB record keeping in 1998. Again, we request 

comment as a data anomaly may result in understated benefits. 

Computing the mean of the estimated total value of about $4.34 million over the 22-year 

historical aircraft dispatcher-related accident interval resulted in about $197,500 per year. 
15

Assuming an equally likely preventable accident average would happen in any year of the 10-

year analysis interval results in about $1.97 million in nominal terms, about $0.99 million for a 

seven percent present value, and about $1.45 million for a three percent present value. 

Table 4 shows these results. 

Under current regulations, supplemental operators must always list an alternate airport for 

domestic operations, because flight followers currently do not have the training and qualification 

standards of aircraft dispatchers. The FAA is proposing to offer relief to supplemental operators 

who operate domestically with no alternate airport if certain weather minimums are met and if 

they comply with the new subpart CC prior to the 5 year phase-in period. The benefits of 

offering relief to supplemental operators who operate domestically with no alternate airport are a 

reduction in required fuel for the flight. Reduced fuel means that the carrier could either carry 

more revenue generating cargo or passengers on the flight, or burn less fuel due to lower weight, 

resulting in reduced fuel costs, aircraft emissions, and maintenance cost on engines or airframes 

because of the reduced takeoff and landing weights when no alternate airport is required. The 

FAA did not quantify these benefits because supplemental operators typically operate either nonscheduled or on-demand service, which translates into Revenue Passenger or Ton Miles (RPM or 

RTM) which are difficult to estimate. In addition, weather conditions, the specific aircraft type 
16

and its fuel burn, and the length of the route and alternative would also be difficult to estimate. 

Thus the total benefit calculation for the proposal is somewhat underestimated. 

III.B.3.D. Qualitative Benefit Discussion 

The proposed rule would also generate qualitative benefits for pilots, flight engineers, flight 

attendants, and aircraft dispatchers. Qualitative benefits include enhanced aviation safety with 

increased training and evaluation requirements, and reduced air pollution and fuel costs. 

A major qualitative benefit area is the value of having well-trained crew members to solve minor 

problems before they become accidents. The aviation system and transport category aircraft are 

extremely complex, but extremely safe. When an accident occurs, it is generally the result of a 

long chain of multiple failures. The crew members are generally the last opportunity to break the 

chain and prevent an accident. It is well established that crew members who are insufficiently 

trained are less likely than well-trained crew members to quickly and efficiently diagnose and 

solve problems. Every day, small events and mishaps are dealt with by crew members and they 

never become accidents. The outcome of small events and mishaps is mitigated by the quick 

action of well trained crew members. Flight 1549 that landed safely in the Hudson River is an 

example of how very quick reaction and decision making by a well trained cockpit crew can 

avert a catastrophe. A small number of incidents and accidents caused by things other than 

training or human error could have been prevented or mitigated if crew members had quickly 

behaved differently. While we have documented the likely size of the accident problem with 

training as a factor, it is not possible to estimate the impact of increased problem solving 

capability as the number of insufficiently trained crewmembers is reduced. It is, however, real 

and significant. 

The following qualitative benefit discussion details flightcrew member, flight attendant, and 

aircraft dispatcher training. 

Flightcrew members
17

In developing the rule’s requirements, the FAA proposes to enhance the training and evaluation 

requirements for flightcrew members and to require the use of flight simulation training devices 

(FSTD). The proposed changes seek to make a significant contribution to the FAA’s accident 

reduction goal by directly addressing the safety goals from two recent FAA “Call to Action” 

initiatives, including pilot “upset recovery” training and improvement of runway safety by 

requiring training in critical runway safety issues. 

The existing recurrent qualification and training requirements for PICs and SICs differ in several 

respects. Current regulations require different training tasks and events for PICs and SICs. For 

example, PICs receive more training tasks and more frequent proficiency checks than SICs. In 

addition, PICs are required to complete recurrent training every 6 months while SICs are 

required to complete recurrent training every 12 months. In addition, under current regulations, 

PICs and SICs may train separately. 

The current disparity between the training requirements for PICs and SICs is not consistent with 

actual line operations. During actual operations, pilots must work as a flight crew unit. 

Typically, today’s flight operations involve PICs and SICs sharing both pilot flying and 

monitoring responsibilities on the flight deck. This proposal would streamline the training for 

PICs and SICs to ensure they are provided training that mirrors to the greatest extent possible 

actual line operations. Accordingly, under this proposal, PICs and SICs would complete 

recurrent training on a 9-month basis, complete the same academic subjects and job performance 

tasks listed in the QPS, and demonstrate proficiency in the flying and monitoring duties 

associated with the prescribed tasks and events. These proposed changes facilitate training 

flightcrew members in a complete crewmember environment that simulates actual line 

operations. 

In selecting the proposed 9-month recurrent training cycle, the FAA took into consideration 

recurrent training cycles currently employed by operators training under an Advanced 

Qualification Program (AQP). Training cycles for these operators include 6-month cycles, 9-

month cycles, and 12-month cycles. The FAA also considered requiring PICs and SICs to train 

on the 6-month cycle currently required for PICs, and also considered requiring recurrent 
18

training on the 12-month cycle currently required for SICs. Based on recent industry trends 

such as the prevalence of two-pilot flightcrews and the advent of regional carriers that have 

resulted in opportunities for an SIC to upgrade to a PIC without having accumulated significant 

experience as an SIC in a part 121 operation, the FAA believes a 12-month recurrent training 

cycle is not sufficient to provide adequate training and experience for these less experienced 

SICs. 

The 9-month recurrent training cycle would provide SICs who upgrade to a PIC with more 

training at each training event. The proposal adds an additional simulator period to each 

recurrent training event for all pilots (PICs and SICs). This increases PIC training requirements 

from six simulator periods in three years to eight simulator periods in that same three years. In 

addition, it substantially increases the number of simulator periods for SICs from three simulator 

periods in three years to eight simulator periods in that same three years. Also, while this 

proposal reduces the frequency with which PICs return for training, it increases the frequency 

with which SICs return for training. Extending the interval just three months for PICs (from six 

to nine months) would not adversely affect their skills. This would also enhance their CRM 

skills by virtue of requiring their pairing with SICs for each recurrent training cycle and by 

requiring an additional simulator period. Thus, the FAA believes that the proposed 9-month 

recurrent training interval is the maximum training interval allowable that would ensure the 

necessary safeguards are in place to address recurrent training requirements for all pilots, 

including those who fly with less frequency or in extended or long-haul operations. 

Flight Attendants

By regulation, no certificate holder may operate a passenger carrying flight under part 121 in 

domestic, flag or supplemental operations unless the required number of flight attendants are on 

the airplane. This requirement was established because flight attendants perform numerous 

safety duties that, when performed effectively, can mitigate or prevent injuries and loss of life in 

aircraft accidents. The majority of flight attendant training and evaluation requirements were 

first promulgated over 40 years ago. With the increased complexity of aircraft cabin systems, 

emergency equipment and procedures, and types of aircraft operations, the training and 
19

evaluation requirements for flight attendants must be improved to maintain an equivalent level of 

safety. 

For example, post-9/11 security procedures have greatly changed the scope of flight attendant 

safety responsibilities. With procedures that require flightcrew members to remain on the flight 

deck during a cabin emergency, flight attendants are the sole responders to emergency situations 

in the aircraft cabin. The increased training and evaluation requirements in this proposal provide 

the necessary training and evaluation in the actions that flight attendants must take in an 

emergency to prevent or mitigate the effects of a possibly catastrophic accident. 

In addition, the frequency of turbulence events has increased. From 1980 through 2008, U.S. air 

carriers had 234 turbulence accidents resulting in 298 serious injuries and three fatalities. Of the 

298 serious injuries, 184 involved flight attendants and 114 involved passengers.9

 Increased 

training and evaluation requirements regarding flight attendant response to turbulence may 

mitigate or prevent these accidents in the future. 

Finally, due to improvements in aircraft systems and design, aircraft accidents are becoming 

more survivable. On December 20, 2008, a Continental Airlines Boeing 737-500 veered off a 

runway and slid into a snowy field at the Denver airport.10 The captain and five of the 110 

passengers were seriously injured; the first officer, two flight attendants and 38 passengers 

received minor injuries; and one flight attendant and 67 passengers were uninjured. The airplane 

was substantially damaged. According to post accident interviews, although the flight attendants 

were not able to communicate with the pilots immediately after the airplane came to a stop, they 

promptly ordered an evacuation when they saw fire outside the airplane. Flight attendant 

statements indicated that passengers seemed frightened but were responsive to instructions, and 

the evacuation progressed quickly and smoothly. All airplane occupants had exited and moved 

away from the airplane before the fire entered the airplane cabin. On January 15, 2009, all 155 

people on board a US Airways flight survived a ditching into the Hudson River off New York 

 

9

Turbulence: Staying Safe, available at http://www.faa.gov/passengers/fly_safe/turbulence/. 

10 NTSB/AAR-10/04 (adopted 7/13/2010) 
20

City's west side after both engines lost power from striking a flock of birds.11 Within seconds 

after the ditching, an evacuation of the airplane was initiated via the forward and over wing exits. 

In both cases, flight attendant emergency response was directly responsible for increased 

passenger survivability. 

With the trends toward increased flight attendant responsibility to respond to emergencies in the 

cabin, turbulence events, and survivable accidents, the need for flight attendants to be fully 

trained and prepared to execute their safety duties becomes ever more important. Increasing 

flight attendant proficiency in the use of aircraft systems, emergency equipment, emergency 

procedures, firefighting techniques, response to turbulence, response to passenger interference 

situations or medical events, may prevent or mitigate future accidents and enhance passenger 

safety during flight. 

For example, NTSB investigation of several accidents and incidents determined that flight 

attendants needed more specific training in firefighting procedures and effective crew 

coordination during an in-flight fire (Recommendations A-01-83 through A-01-85). The 

proposed rule contains detailed requirements for firefighting training, including fighting hidden 

fires, and the proper use of a halon fire extinguisher. Other NTSB investigations have 

determined that flight attendants need additional training in emergency evacuation procedures 

(Recommendations A-92-67, A-92-70, A-92-71, A-92-74, and A-92-77). The requirements in 

this proposal respond to those NTSB recommendations. 

Flight attendants must be proficient in preparing an airplane for an evacuation or a ditching, 

extinguishing an in-flight fire, supervising the cabin following a decompression, handling a 

hijack situation, and managing passengers during an emergency evacuation. Emergency 

situations, by their very nature, happen infrequently, so the only way that flight attendants can 

practice skills needed in an emergency is during initial and recurrent training. 

Clearly, flight attendants mitigate accidents. Flight attendants who are better trained and 

qualified are better prepared to execute emergency procedures and may prevent deaths or 

 

11 NTSB/AAR-10/03 (adopted 5/4/2010) 
21

mitigate injuries in an airplane accident. This proposal addresses NTSB recommendations that 

flight attendants need more specific training. Based on the role of flight attendants to mitigate 

accidents and the NTSB recommendations, the FAA believes the benefits from the proposed 

flight attendant training justify the costs. Just as good crew training helped to land the US 

Airways A320 on the Hudson and the flight attendants got everyone out safely. Therefore, the 

training and evaluation requirements in this proposal would result in numerous qualitative 

benefits for flight attendants. 

Aircraft Dispatchers

An aircraft dispatcher is a licensed airman certificated by the FAA. Flightcrew members and 

aircraft dispatchers share a joint responsibility for the safe operation of each flight. Aircraft 

dispatchers perform numerous duties that, when performed effectively, can mitigate risk to 

prevent accidents, fatalities, and injuries. For example, aircraft dispatchers analyze and evaluate 

meteorological information to determine potential hazards to safety of flight; select the most 

desirable route of flight, and compute the amount of fuel required for the safe completion of the 

flight according to type of aircraft, distance of flight, maintenance limitations, weather 

conditions, and minimum fuel requirements prescribed by current federal aviation regulations. 

Aircraft dispatchers also prepare flight plans containing information such as maximum allowable 

takeoff and landing weights, weather reports, and airport field conditions, and perform many 

other tasks required for the safe completion of flight. Aircraft dispatchers also play a critical role

during in-flight emergencies by communicating information to flightcrew members to assist 

them in their decision-making. 

Since the aircraft dispatcher training rules were first adopted, there has been an increase in the 

number and complexity of operations in part 121, as well as changes in technology, such as 

NextGen.12 To maintain an equivalent level of safety, the training and evaluation requirements 

for aircraft dispatchers must keep pace with the increases in airline operational control 

complexities that result from these advances. 

 

12 NextGen, is the evolution from a ground-based system of air traffic control to a satellite-based system of air traffic 

management. 
22

The following is an example of how aircraft dispatchers can mitigate risk to prevent future 

accidents. On December 28, 2001, a Boeing 747 cargo airplane operated by a part 121 

supplemental operator had a tail strike on departure from Anchorage, Alaska. Under current 

regulations, part 121 supplemental operators are not required to have aircraft dispatchers to 

provide a second source of operational review. The NTSB found prior to departure that the crew 

failed to account for the weight of the additional fuel and inadvertently used the same 

performance cards that were used for the previous landing. The NTSB found the probable cause 

of the accident was inadequate preflight planning/preparation and failure to calculate aircraft 

weight and balance by the flight crew (NTSB Event ID ANC02LA008). The FAA believes this 

accident could have been mitigated if the pilots had been required to share joint responsibility 

with a certificated aircraft dispatcher involved in the preflight planning of this operation. The 

FAA recognizes that requiring the shared responsibility of operational control between the PIC 

and the certificated aircraft dispatcher in supplemental operations increases the safety of the 

flight, creates a single level of safety for all part 121 operations, and provides qualitative benefits 

for the proposal regarding aircraft dispatchers. 

Qualitative benefits also include addressing open NTSB safety recommendations related to 

crewmember training. The changes proposed in this SNPRM address the following NTSB 

recommendations: 

• Crewmember Resource Management (CRM) training (Recommendations A-88-71 and 

A-94-96); 

• Flight attendant training (Recommendations A-92-67, A-92-70, A-92-71, A-92-74, and 

A-92-77); 

• TCAS RA training (Recommendation A-93-46); 

• Use of simulators to conduct LOFT (Recommendations A-94-191 through 194); 

• Training of flightcrews to respond to sudden, unusual or unexpected aircraft upsets 

(Recommendation A-96-120); 

• Training of crewmembers to respond to in-flight fires (Recommendations A-01-83 

through A-01-85); 

• Aircraft pressurization on the ground while the ground-based air conditioning is 

supplying conditioned (cooled or heated) air to the cabin (Recommendation A-07-96); 
23

• Monitoring of exit availability on the ground after a significant event to help expedite and 

emergency evacuation (Recommendation A-09-26); 

• Communication and coordination between Flight Crewmembers and Flight Attendants 

regarding emergency and unusual situations (Recommendation A-09-27); 

• Pilot monitoring duties (Recommendation A-10-10); 

• Requirements for flightcrew member academic training regarding leadership 

(Recommendations A-10-13, A-10-14, and A-10-15); 

• Pilot recordkeeping requirements regarding training performance (Recommendations A10-17 and A-10-18); 

• Develop and implement procedures to establish airspeed reference (Recommendation A10-21); and 

• Develop and conduct stall recovery training and provide stick pusher familiarization 

training for pilots of stick-pusher equipped aircraft (Recommendations A-10-22 and A10-23).13

 

III.B.3.E. Quantified Accident Prevention Benefit Summary 

The safety benefits from these initiatives would be derived from flight attendants having a better 

awareness of turbulence hazards, aircraft behavior in turbulence, the need to maintain personal 

safety, as well as the importance of communication and coordination between pilots, flight 

engineers, and flight attendants during turbulence events. 

Pilots and flight engineers would also be better prepared for emergency situations, such as 

upset/disturbance and loss of control, unusual attitudes, and recovery from approach to stall. 

Improvements in aircraft dispatcher training programs enhances safety by including additional 

training requirements to ensure that each aircraft dispatcher is trained and proficient in the 

different aircraft types to which the aircraft dispatcher is assigned. In addition, aircraft 

dispatcher training program improvements also increases safety by including training in 

hazardous weather and Enhanced Weather Information Systems (EWINS) as required areas of 

study. 
24

Table 5 summarizes our safety benefit estimates for pilots, flight attendants and dispatchers. 

The proposed changes seek to make a significant contribution to the FAA’s accident reduction 

goal by directly addressing the safety goals from two recent FAA “Call to Action” initiatives 

including pilot “upset recovery” training and improvement of runway safety by requiring training 

in critical runway safety issues. 

The FAA requests comments, with supporting documentation, on the benefit analysis for this 

proposal. 

 

13 The NTSB Safety Recommendation Letters are available online at http://www.ntsb.gov/Recs/letters/ letters.htm. 
25

III.C. Cost Analysis 

From 2016 to 2025, the FAA estimated the total nominal dollar cost of the proposed rule would 

be about $391.9 million, $199.1 million at a seven percent present value, and $290.3 million at a 

three percent present value. The costs would accrue from additional pilot, flight engineer, flight 

attendant, and aircraft dispatcher training requirements, additional travel costs to and from 

training facilities, and the use of additional simulators or training facilities. Those individuals 

affected by the new training requirements include pilots-in-command (PIC), pilots second-incommand (SIC), flight engineers, flight attendants and aircraft dispatchers. 

III.C.1. General Cost Assumptions and Data Sources

In addition to the general assumptions at the beginning of Section III. Benefit-Cost Analysis, the 

FAA made the following general assumptions to facilitate the cost analysis for estimating the 

proposals costs to pilot, flight engineer, and flight attendant training programs. This section also 

includes an identification of key data sources. 

• No costs would be realized from 2010 through 2015. 

• The number of pilots, flight engineers, flight attendants, and aircraft dispatchers employed by 

parts 121 and 121/135 operators was obtained through the FAA National Vital Information 

Subsystem (NVIS)14 database at the end of December 2009 and represents our estimate of the 

number of employees in 2010. 

• The NVIS database only provides a total number of pilots, flight engineers, flight attendants 

and aircraft dispatchers. Therefore we assume 4.0 percent of the total number of pilots, flight 

engineers, flight attendants and aircraft dispatchers are check pilots, check flight engineers, 

check flight attendants and check aircraft dispatchers. 

• We also assume that 2.0 percent of the total pilots, flight engineers, flight attendants and 

aircraft dispatchers are instructors. 

 

14 The National Vital Information Subsystem (NVIS) is a subsystem of the Flight Standards Automation System 

(FSAS), a comprehensive information system used primarily by inspectors to record and disseminate data associated 

with inspector activity and the aviation environment. NVIS maintains up-to-date information about the aviation 

community within Flight Standards jurisdiction. This database contains the general information about the operator 

including the number of pilots, flight attendants, engineers, and navigators; contractors; exemptions and deviations. 
26

• Using the FAA Aerospace Forecasts, for fiscal years 2009-2025,15 the FAA estimated that the 

affected population of pilots, flight engineers, flight attendants and aircraft dispatchers would 

grow at approximately 0.3 percent per year. These new employees would have to undergo 

initial, new hire, or, for flight attendants, basic qualification training. 

• The average ground school class size for pilots, flight engineers, flight attendants, aircraft 

dispatchers, check pilots, check flight engineers, check flight attendants, check aircraft 

dispatchers and instructors training is 20. 

• Based on the locations of the flight simulators and training centers, and the corresponding per 

diem rates for those locations, the FAA assumes that the weighted averages for lodging and 

meals are $92 and $44, respectively. 16 Per Diem cost (i.e., lodging and meals) rates are

based on rates established annually by the General Services Administration (GSA) for 

travelers on official Government business to use for their lodging, meals, and incidental 

expenses. 

• The FAA determined there would be a cost to certificate holders for employees who travel by 

air because of the additional training times required by this proposed rule. We estimated an 

air travel cost by taking the product of two,17 times the domestic Cost per Available Seat 

Mile (CASM), and the average trip length.18 Therefore, the FAA assumed that the cost for 

employees who travel by air is $126.37. 

• Pilots, flight engineers, flight attendants, and aircraft dispatchers who travel by car would 

travel approximately 40 miles at a cost of $0.54 per mile.19

The FAA requests comments on these cost assumptions, accompanied by clear documentation. 

III.C.2. Subpart BB Costs 

The FAA analyzed the expected costs of subpart BB from 2010 through 2025. A factor driving 

the expected costs were the additional hours the proposed rule would add to the pilots, flight 

 

15 Active Pilots by Type of Certificate, FAA Aerospace Forecasts: Fiscal years, Airline Transport, 2009–2025; 

Airline Transport 2010-2020. 

16 Includes incidental expenses. 

17 Round trip flights from home to training center and return. 

18 Department of Transportation Form 41 database. 
27

engineers, flight attendants, check pilots, check flight engineers, check flight attendants and 

instructor training. Other cost drivers included the capital and operating costs of simulators and 

expanding training facilities. Expected costs for subpart BB would be about $386.3 million. 

These costs would begin to accrue in 2016, five years after the rule is expected to take effect, and 

would continue to 2025. 

Subpart BB would impose either an addition or a reduction of the hours of initial, transition, 

conversion, requalification, upgrade, and recurrent training costs to operator pilot and flight 

engineer training programs. Subpart BB would also impose either an addition or a reduction of 

the hours of basic qualification, requalification, and recurrent training costs to operator flight 

attendant training programs. The incremental costs of training to pilots and flight engineers are 

estimated at about $380.9 million, in nominal dollars, plus $5.5 million for flight attendants. The 

FAA estimates the additional paperwork costs would be about $1.7 million for pilots and flight 

engineers. 

Under the assumption that existing facilities are optimized,20 Subpart BB would also result in 

additional capital and operating expenses to either build or expand training and simulator 

facilities for traditionally-trained pilots, flight engineers and flight attendants. Rather than 

estimate the capital recovery costs over the life cycle of simulators and expansion of facilities, 

we estimated the rent of simulator services with a usage fee per pilot or flight engineer, or an 

inclusive flight attendant instructional usage fee expense for a ground school classroom training 

session. As in the NPRM, and after extensive industry validation, the FAA estimates the average 

cost of simulator session to be $550 an hour. The FAA estimates the weighted average hourly 

training cost for the inclusive flight attendant instructional ground school expense to be $37.43. 

Many of the changes in subpart BB are either editorial or procedural. These types of proposed 

revisions do not add any new requirements or impose costs. Some changes expand or clarify the 

intent of the proposed rule through reorganization, updating terminology, and clarifying 

 

19 According to the 2009 “Your Driving Costs” brochure, a family will spend $54.00 per 100 miles on gas, oil, tires, 

and maintenance. Retrieved from http://www.aaa.com. 

20 The FAA contacted many of the responders to the NPRM and confirmed that their existing training facilities, 

simulators, and ground school classes are optimized. 
28

procedures. These proposed editorial or procedural changes would not impose any new 

requirements or costs. 

III.C.2.A. Pilot, Flight Engineer and Flight Attendant Assumptions 

The FAA made the following general assumptions to facilitate the analysis for estimating the 

costs for the new training requirements to pilots, flight engineers, and flight attendants. 

The following assumptions apply to estimating the pilot and flight engineer training costs for 

operators with traditional training programs: 

• 100 percent of the pilots, check pilots and instructors attend a recurrent training cycle every 9 

months. 

• At the time of this writing, there are 18 operators with AQP pilot training programs that 

employ approximately 62 percent of all part 121 pilots. In addition, there are about a dozen 

operators either developing or considering AQP curriculums for their pilots who employ 

approximately 16 percent of all part 121 pilots. The FAA contacted other operators with 

traditional pilot training programs and they have expressed interest in converting to an AQP 

curriculum. We assume that two percent of the pilots, who work for operators with 

traditional pilot training programs, would convert to an AQP pilot training curriculum 

annually over the 10-year analysis interval. 

• Five percent of the affected pilots and flight engineers would require transition, conversion, 

upgrade, requalification, or upgrade training. 

• For pilots or flight engineers who must complete requalification training, one-third would 

go through Phase I training, one-third would go through Phase II training, and one-third 

would go though Phase III training. 

• Of the affected pilots and flight engineers 32 percent would require transition training, eight 

percent conversion training, five percent requalification, or 55 percent upgrade training. 

• Pilots and flight engineers undergoing transition, requalification, conversion and upgrade 

training would require the same number of simulator tasks required by initial or new hire 

training. 
29

• Training and checking in the simulator occur with both seats filled with persons either in 

training for the respective seat or who are qualified to operate the airplane from that seat. 

The FAA has a requirement for training and checking to be accomplished under a "full crew 

concept," where every seat in the simulator will be filled. When a full crew concept cannot 

be accomplished, the proposed rule language identifies what persons may fill the seat. 

However, if the pilot that is scheduled to receive the training or undergo the check cannot be 

present, and the operator has exhausted the list of persons the FAA provided as acceptable, 

then the operator may put two pilots-in-command (PIC) or two pilots second-in-command 

(SIC) together for training but not checking. For training, this analysis allows any 

combination of PICs and SICs to train together. 

• Currently, due to simulator training scheduling today, it is not unusual to have someone who 

does not actually require the training to occupy one of the seats in the simulator. Although 

the FAA believes there would be a cost savings from this proposal by making both PIC and 

SIC have a nine month recurrent training cycle, we did not attempt to quantify the cost 

savings in this analysis. We request comments on this issue. 

• Two pilots and one instructor would occupy a simulator during training. 

• Pilots and flight engineers undergoing transition, requalification, conversion, upgrade, or 

recurrent training would train on one airplane group per training cycle.21

• 80 percent of the affected pilot population would fly to their training locations, while the 

remaining 20 percent of the affected population would travel by car. 

• 80 percent of the affected pilot and flight engineer population who attend ground school 

would use distance learning, while the remaining 20 percent of the affected population would 

travel. 

• 85 percent of pilots operate turbojet airplanes and 15 percent operate turboprop airplanes. 

• Although a very small number of flight engineers in part 121 operated turbo-propeller or 

reciprocating engine powered aircraft, this analysis assumes that 100 percent of flight 

engineers operate turbojet airplanes. 

• The FAA contacted industry and determined that the average simulator usage fee equals 

$550 per hour. We believe the rental price accurately reflects the cost of capital. 

 

21 The initial, transition, upgrade, conversion, requalification training cycle occurs once while the recurrent training 

cycle occurs every nine months. 
30

The following assumptions apply to estimating the flight attendant training costs: 

• The total number of affected flight attendants at the end of December 2009 is 100,970 and 

will represent the number of employees in 2010.22 

• Five percent of the affected flight attendants, check flight attendants and instructors would 

require requalification training. 

• For flight attendants who must complete requalification training, 80 percent would go 

through Phase I training and 20 percent would go through Phase II training. 

• Flight attendants would train for an average of two equipment groups.23

• Flight attendants would train for both aircraft during the same training cycle. 

• The SNPRM is not establishing a programmed hour training requirement for check flight 

attendant or flight attendant instructor training. However, we assume the SNPRM will cause 

operators to require additional training. The additional training would be four hours of initial 

and two hours of annual recurrent training per check flight attendant and flight attendant 

instructor. 

• 95 percent of flight attendants work in turbojet airplanes and 5 percent work in turboprop 

airplanes. 

• Although there are no emergency training hours specified in the current Federal Aviation 

Regulations, the national norm is 24 hours. 

• In January 2010, the FAA surveyed the Aviation Safety Inspectors (ASI) for five major 

airlines. They stated the percentage of flight attendants who traveled to training ranged 

between zero to 80 percent with an average of 47 percent. Therefore, we assumed that 47 

percent of the affected flight attendant population would fly to their training locations, while 

the remaining 53 percent of the affected population would travel by car. 

• Flight attendants usually receive a minimal stipend amount for initial training. This analysis 

does not include this minimal stipend to offset the costs to flight attendants. 

• The capital and operating expenses of expanding training facilities are estimated using an 

average hourly usage fee for the inclusive flight attendant instructional ground school 

 

22 NVIS. 
31

expense for the additional training hours required by this proposal. Operators provided the 

FAA with average hourly costs for basic qualification, requalification, and recurrent flight 

attendant training. In order to maintain the confidentiality of operator training costs, we 

computed a weighted average and use an average hourly usage fee cost of $37.43, per flight 

attendant, for the inclusive flight attendant instructional ground school expense. 

• 50 percent of the affected flight attendant ground school training program would be done by 

distance learning, while the remaining 50 percent would require travel. This assumption 

implies when flight attendants use distance learning they would not incur travel expenses or 

the inclusive flight attendant instructional ground school expenses. 

The FAA requests comments on these assumptions, accompanied by clear documentation. 

III.C.2.B. Number of Pilots, Flight Engineers and Flight Attendants Affected 

This section discusses the derivation of our estimate of the annual number of pilots, flight 

engineers and flight attendants employed by part 121 and 121/135 operators between 2010 and 

2025. 

The proposed rule would affect pilots of part 121 and 121/135 operators who do not conduct 

pilot training under an Advanced Qualification Program (AQP). Thus we estimate only the 

number of pilots employed by operators in traditional pilot training programs. The proposal will 

affect all flight attendants and flight engineers employed by part 121 and 121/135 operators. 

To estimate the number of pilots, flight engineers and flight attendants employed in the 10-year 

analysis interval we begin with a 2010 base of 79,986 pilots, 1,892 flight engineers, and 100,970 

flight attendants who are employed by part 121 and 121/135 operators. Next, we remove pilots 

who are training under an AQP program. This results in a 2010 base of 30,395 traditionally 

trained pilots. We then assign a conversion, requalification, transition and upgrade training rate 

of five percent and the growth rate of 0.3 percent to the number of affected pilots, flight 

 

23 OAG Fleet Database reports an average of 1.65 equipment groups per operator which we rounded up to two. The 

OAG Fleet Database defines an equipment group as major groupings of aircraft types. For example, B737 would 

include all of the B-737 variants. 
32

attendants, and flight engineers from 2010 to 2025. Lastly, we estimate that two percent of the 

pilots and flight engineers would move from a traditional to an AQP pilot training program 

annually. 

Tables 6, 7, and 8 show the results of these calculations for the estimated number of pilots and 

flight engineers from 2010 through 2025 affected by this proposal. The ‘Initial’ column 

represents the number of pilots or flight engineers who would go through initial or new hire 

training. The ‘5.0%’ column represents the number of pilots or flight engineers who would go 

through conversion, requalification, transition, or upgrade training. The ‘Pilot PIC’, ‘Pilot SIC’, 

‘F/E’, ‘Check PIC’, ‘Check F/E’, ‘Instructor PIC’ and ‘Instructors F/E’ columns represent the 

number of pilots and flight engineers who would go through recurrent training. We note the new 

training requirements would start when the proposal becomes effective in 2016. We also note 

that there are no check or instructor SICs. The total number of pilots declines over time because 

annually, the attrition of pilots to AQP training programs exceeds the number of new pilots to 

traditional operators. 
33

To estimate the number of flight attendants, check flight attendants and instructors employed in 

the 10-year analysis interval, we calculated the product of four percent of 100,970 to obtain 

4,039 check flight attendants. Next, we calculated the number of instructors by taking the 

product of two percent of 100,970 to obtain 2,019 instructors. These calculations resulted in a 

total 94,912 (100,970-4,039-2,019) flight attendants, 4,039 check flight attendants, and 2,019 

instructors employed by part 121 and 121/135 operators in 2010. 
34

Next, we calculated the requalification training rate for flight attendants, check flight attendants 

and instructors by calculating the product of the number of flight attendants, check flight 

attendants and instructors and five percent by year for 2010 through 2025. Lastly we use a 0.3 

percent growth rate by year for 2010 through 2025. 

Table 9 shows the results of these calculations for the estimated number of flight attendants, 

check flight attendants and instructors from 2010 through 2025. The ‘Initial 0.3%’ column 

represents the number of flight attendants, check flight attendants and instructors who would go 

through basic qualification training. The ‘Requal 5.0%’ column represents the number of flight 

attendants, check flight attendants and instructors who would go through requalification training. 

The ‘Flight Attendants’, ‘Check F/A’ and ‘Instructors F/A’ columns represent the number of 

flight attendants, check flight attendants and instructors who would go through recurrent training. 

We note the new training requirements would start when the proposal becomes effective in 2016. 

III.C.2.C Subpart BB Pilot and Flight Engineer Cost Estimation Methodology 

Total pilot and flight engineer training costs constitute over 95 percent of the total FAA 

estimated cost of the proposal. Functionally, pilot and flight engineer training costs include 

simulator usage fees, pilot and flight engineer time and travel, and ground school. While we 

provide an estimate of ground school training savings, we do not include these savings as a result 
35

of the rule. The FAA expects these cost savings could occur with the implementation of the rule. 

However, industry informed us that they consider ground school training costs resulting from the 

proposal to be minimal and thus our expected pilot and flight engineer ground school savings are 

also minimal. We left in the ground school cost savings as part of this discussion to facilitate 

comments. 

This section presents the methodology to estimate the costs of the incremental pilot and flight 

engineer training hours required by this proposal. First, we detail the current required training 

hours versus those proposed in the SNPRM. Then, we discuss the hourly wages and the 

derivation of hourly employee benefits. Next we explain our methodology for estimating the 

incremental pilot and flight engineer training hours costs of the proposed rule. Then, we show 

the cost estimates from this proposed rule as they apply to pilots, flight engineers, check pilots 

and flight engineers, and instructor training. Lastly, we discuss the paperwork costs of revising 

pilot manuals, flight engineer manuals, and the certificate holder’s Continuous Analysis Process 

(CAP) document. 

The FAA sets a minimum required standard for training pilots and flight engineers and we 

believe current industry practices exceed our minimum. This regulatory evaluation will not 

attempt to estimate the existing practice relative to the new requirements. We base our estimate 

on the incremental time this proposal adds to the current regulatory requirements. To the extent 

industry current practices exceed the regulatory requirement, our cost estimate would result in an 

over estimate of the actual compliance costs. 

Pilots and flight engineers must undergo two basic methods of training. The first is simulator 

training and the second is ground school training. We estimate that 80 percent of the pilots and 

flight engineers would undergo distance learning for their ground school training. The costs for 

a pilot or flight engineer to undergo distance learning would be the same for the hours spent in a 

ground school class room but would not include transportation costs such as airfare, automobile 

mileage, hotel, facility usage fees, and per diems.
36

When a pilot enters a simulator for training, the pilot must complete a prescribed number of 

tasks. These tasks, along with an estimate of the time necessary to complete them, are listed in 

the technical report in the federal docket.24

Typically, simulator sessions are scheduled in four hour blocks. However, when a pilot 

completes all of the prescribed tasks before four hours, the simulator training session is 

complete. 

In the NRPM, the FAA estimated the costs based on four-hour simulator sessions. After 

analyzing the tasks prescribed in the technical report, we believe many of the simulator sessions 

would last less than four hours. Therefore, in the SNPRM cost analysis, we will be estimating 

the cost of the average number of hours the pilot spends in the simulator rather than the number 

of four-hour simulator sessions. 

Tables 10 and 11 show the minimum number of pilot and flight engineer simulator and ground 

training hours currently required by the FAA, our estimate of the number of training hours 

required by this proposal, and the average incremental difference and percentage between the 

two. 

The FAA requests comments on these cost estimates based on pilot and flight engineer simulator 

hours and ground training hours, accompanied by clear documentation. 

 

24 http://www.regulations.gov/search/Regs/home.html#docketDetail?R=FAA-2008-0677 
37
38
39

The FAA uses the hourly wages plus benefits for pilot and flight engineer, check pilot and flight 

engineer and instructor as a basis to estimate the additional training costs of this proposal. 

Benefits include health benefits, vacation, life insurance, sick time, etc. In May 2009, the 

Employee Benefit Research Institute, using a Bureau of Labor Statistics Survey of employee 

benefits estimated the total 2009 benefit as a percentage of payroll at 30.2 percent.25 The FAA 

accepts 30.2 percent to estimate the value of benefits for pilots, check pilots, flight engineers, 

check flight engineers and instructors as an additional cost of this proposal. 

Table 12 shows the hourly wage, estimated hourly benefit, and total hourly cost we calculated 

for pilots and flight engineers. 

The FAA estimated the pilot and flight engineer simulator and ground school training costs by 

summing the additional initial or new hire training cost with the transition, upgrade, conversion, 

requalification, and recurrent training costs this proposal mandates. 

The FAA accepts industry’s NPRM comments that the proposed additional training would 

require higher travel for simulator and ground school training for pilots and flight engineers than 

our NPRM estimate. Using the assumptions above, we accounted for travel, hotel and per diem 

costs by pilots or flight engineers who traveled either by airplane or automobile to their simulator 

or ground school training sessions. We note that pilots or flight engineers who opted for ground 

school distance learning did not incur travel costs, but did incur ground school costs based on the 

pilots or flight engineers hourly rate in training. 

 

25 http://www.ebri.org/pdf/publications/books/databook/DB.Chapter%2003.pdf updated May 2009. 
40

We now discuss the FAA’s estimate of this proposal’s additional simulator training costs to 

pilots, flight engineers, check pilots and flight engineers, and instructors. 

The additional simulator training costs consist of the sum of travel; the pilots’, flight engineers’, 

and instructors’ additional hours (computed using hourly wages plus benefits) spent in the 

simulator; and the additional simulator usage fees.

Travel costs include hotel, airfare or automobile mileage, and per diem (meals, etc.) costs. We 

estimated the travel costs by taking the product of the number of pilots and flight engineers per 

additional simulator training cycle26 and the sum of hotel, per diem and either air or automobile 

travel costs. 

We estimated the additional time in the simulator costs by taking the product of the number of 

pilots or flight engineers per additional training cycle, the additional hours mandated by this 

proposal that a pilot must be in simulator training, and the sum of the pilots’ or flight engineers’, 

with the instructors’ hourly wage plus benefits.27 

Lastly, we estimated the cost of the simulator usage fees by taking the product of the number of 

pilots or flight engineers per additional training cycle, the additional hours mandated by this 

proposal that a pilot must be in simulator training, and the $550 average hourly simulator cost, 

while factoring in two pilots per simulator session. 

For the check PICs, flight engineers and instructors

28 we calculated the incremental simulator 

training costs mandated by this proposed rule in a similar manner as we did for the pilots and 

flight engineers. The only exception was that we used check PICs’, flight engineers’ and 

instructors’ wages plus benefits and incremental hours instead of pilots and flight engineers. 

 

26 The initial, transition, upgrade, conversion, requalification training cycle occurs only once while the recurrent 

training cycle occurs every nine months. 

27 There is one instructor for every two pilots in the simulator. 

28 We note that SIC do not have a check or instructor category. 
41

Lastly, we summed the initial, conversion, requalification, transition, upgrade, and recurrent 

simulator training costs to arrive at the FAA estimate for this proposals total pilot and flight 

engineer training costs. 

Table 13 shows the results of our calculation of the estimate of this proposals additional 

simulator training costs to pilots, flight engineers, check pilots and flight engineers and 

instructors. Appendix 7 shows the break out of additional simulator costs for PICs, SICs, and 

flight engineers. 

We note that of the $380.9 million total PIC, SIC and flight engineer simulator training cost, 

travel costs are about 20 percent, additional hours spent in the simulator costs are about 28 

percent, and simulator usage costs are about 52 percent. 

We now discuss the FAA’s estimate of this proposal’s additional ground school training costs to 

pilots, flight engineers, check pilots and flight engineers, and instructors. 

Again, we provide the following discussion to facilitate comments regarding ground school cost 

savings. Originally we expected the SNPRM ground school changes would have resulted in 

substantial cost savings. Industry informed us they consider ground school costs as minimal and 

we accepted their judgment. 
42

The additional ground school costs consist of the sum of the additional (or relieving) travel costs 

and the time pilots and flight engineers, including instructors, are in ground school. 

To estimate the ground school costs incurred by this proposal, we first estimated the number of 

additional (or relieving) days a pilot or flight engineer would be in ground school training per 

training cycle.29

Travel costs include hotel, airfare or automobile mileage, and per diems (meals, etc.) For ground 

school training, the FAA proposes to allow that training be conducted in an environment other 

than a classroom by distance learning. An approved distance learning program ensures the 

training will provide the students with the knowledge and cognitive skills to perform their 

required duties. We estimate that 80 percent of the traditionally trained pilots would take 

advantage of distance learning and would save a part 121 or 121/135 operator travel costs. For 

those traditionally trained pilots who travel to ground school facilities, we estimated the ground 

school travel costs by taking the product of the number of pilots or flight engineers per additional 

training cycle, the number of additional (or relieving) ground school hours this proposal requires 

and the sum of the hotel, per diem and either air or automobile travel costs. 

Next, we calculated the additional (or relieving) time pilots are in ground school training by 

taking the product of the number of pilots and flight engineers, including an instructor, per 

additional training cycle, with the additional (or relieving) ground school hours, and their hourly 

wage. We note that although distance learning is a travel cost savings, we still need to include 

the cost of the pilot’s and flight engineer’s ground school training time regardless of whether the 

pilots and flight engineers are distance learning or in a ground school classroom. 

For the check pilots and flight engineers and instructors, we calculated the incremental ground 

school training costs of this proposed rule in a similar manner as the pilots and flight engineers.30

 

The only exception was that we used instructor wages and incremental hours instead of pilot and 

flight engineer wages. 

 

29 The initial, transition, upgrade, conversion, requalification training cycle occurs only once while the recurrent 

training cycle occurs every nine months. 
43

Lastly, we summed the initial, transition, upgrade, conversion, requalification, and recurrent 

ground school training costs to arrive at a total cost, by pilot and flight engineer, check pilot and 

flight engineer and instructor. 

Table 14 shows the results of our calculations of the estimate of total ground school training 

costs (or savings) to pilots, flight engineers, check pilots and flight engineers and instructors. 

Again, we provide these estimates to facilitate comments. 

Now we discuss the estimation of the paperwork costs to industry for updating the pilot and 

flight engineer manuals and the certificate holder’s Continuous Analysis Process (CAP) 

document. We first discuss the wages and benefits for the industry employees involved. 

For industry wages and benefits, the following computations involving salaries include the 

hourly wage and, as discussed above, employee benefits estimated at 30.2 percent of hourly 

wage. The FAA obtained industry hourly wages for Technical Writer Managers and Technical 

Writers from PayScale.31

Table 15 shows the hourly wage, estimated hourly benefit, and total hourly employee cost the 

FAA calculated for industry employees responsible for updating manuals. 

 

30 We note that SIC do not have a check or instructor category. 
44

The proposed SNPRM changes that deal with manuals for operations in accordance with part 

121 will require revisions to the manual requirements. The manuals must include the 

instructions and information necessary to allow pilots, other pilots and flight engineers to 

perform their required safety related duties and responsibilities. The manual, and any changes, 

must be approved by the Administrator. 

The FAA estimates for a certificate holder operating under part 121 or 121/135 with two 

equipment groups,32 on average, 35 percent of the content of these manuals will require revision. 

On average, we estimate that this constitutes about 86 pages for each equipment group. 

From the FAA National Vital Information Subsystem (NVIS) database, we determined this 

proposal would require 80 operators with traditional pilot training programs to update the content 

of their manuals. 

Table 16 shows the time we estimate for industry to update manuals. 

We estimate the industry paperwork cost of reviewing the updated manuals by calculating the 

product of hourly wage, the average number of equipment groups per operator, the number of 

operators, and the number of hours determined for each category. Then we summed the costs for 

each employee category. 

 

31 http://www.payscale.com/ 
45

The total industry paperwork cost of reviewing the updated manuals is $1.47 million. On 

average, over the 10-year analysis interval, the costs to update the manuals would be $147,000 

annually. 

The Continuous Analysis Process (CAP) requires certificate holders to document the 

effectiveness of their training and qualification programs, or the need to change, to allow for 

continuance. The FAA does not intend for the CAP to meet the detailed data collection 

requirements for operators with AQP training programs. The cost estimates are the time 

estimates to prepare and maintain the actual document that outlines the certificate holder’s CAP 

for FAA approval as part of the approved training program. 

We estimate industry costs for documenting the effectiveness of operators with traditional 

training programs for each category as follows: 

(a) Pilots (includes training programs for pilots, flight engineers, check pilots and check 

flight engineers, and instructors): 

(i) Initial documenting requires eight hours for review by a Technical Writer Manager for 

80 passenger and cargo air carriers. 

(i) Recurrent documenting requires two hours for review by a Technical Writer Manager 

for 80 passenger and cargo air carriers. 

(b) Flight Attendants: 

(i) Initial documenting requires eight hours for review by a Technical Writer Manager for 

66 passenger air carriers. 

(ii) Recurrent documenting requires two hours for review by a Technical Writer Manager 

for 66 passenger air carriers. 

Table 17 summarizes the FAA expected results of the industry paperwork cost of reviewing and 

updated manuals and the CAP. 

 

32 OAG Fleet Database. 
46

III.C.2.D. Subpart BB Flight Attendant Cost Estimation Methodology 

This section presents the methodology to estimate the costs of the incremental flight attendant 

training hours required by this proposal. Unlike the proposed requirements for pilots, which 

would only affect operators with traditional pilot training programs, the proposed requirements 

for flight attendants would affect all part 121 and 121/135 operators. First, we compare the 

current flight attendant training hour requirements versus those proposed in the SNPRM. Then, 

we detail the flight attendant hourly wages and the derivation of hourly employee benefits. Next 

we discuss our estimation of the additional flight attendant training costs for the proposed rule. 

Lastly, we show the additional flight attendant, check flight attendant and instructor training cost 

estimates for the proposed rule. 

The FAA sets a minimum required standard for training flight attendants and we believe industry 

practices exceed our minimum. We base our estimate on the incremental time this proposal adds 

to the current requirements with the expectation that actual industry compliance costs would be 

lower. 
47

The FAA notes that although there are no minimal hour requirements for emergency training, we 

use 24 hours as the national norm.33

Currently, the Federal Regulations do not specify requalification training but does provide 

guidance that industry currently follows. The FAA received information on 39 operator’s 

requalification programs. We computed a current industry weighted average number of hours 

for Phase 1 and Phase 2 requalification training by taking the product of each operator’s number 

of flight attendants employed in 2010 times the number of hours the operators of training 

reported. We then summed the Phase 1 and Phase 2 products and divided that sum by the sum of 

the flight attendants employed by the 39 operators. Our calculations yielded a weighted average 

of 31 hours for Phase 1 training and 54 hours for Phase 2 as the current industry norm for 

requalification training. 

Table 18 shows the minimum flight attendant training hours currently required by the FAA, the 

number of training hours that would be required by this proposal, and the incremental difference. 

The FAA requests comments on these minimum flight attendant training hours, accompanied by 

clear documentation. 

 

33 FAA Order 8900.1 Flight Standards Information Management Systems (FSIMS), Volume 3. General Technical

Administration, Chapter 23 Flight Attendant Training and Qualification Programs, Section 4. Flight Attendant 

General Emergency Training Curriculum Segment, 3-1805, Evaluation of Training Hours. 
48

The FAA uses the hourly wages of a flight attendant, check flight attendant and instructors as a 

basis to estimate flight attendant costs. In addition to hourly wages, an operator also includes 

benefits for each employee. Benefits include health benefits, vacation, life-insurance, sick time, 

etc. In May 2009, the Employee Benefit Research Institute, using a Bureau of Labor Statistics 

Survey of employee benefits estimated the total 2009 benefit as a percentage of payroll, at 30.2 

percent.34 The FAA uses the 30.2 percent to estimate the value of hourly benefits for flight 

attendant, check flight attendant and instructors as an additional cost of this proposal. 

Table 19 shows the hourly wage, estimated hourly benefit, and total hourly cost the FAA 

calculated for flight attendants, check flight attendants, instructors and managers. 

We now discuss the FAA’s estimation of the proposal’s additional training costs to flight 

attendants, check flight attendants, and instructors. 

The additional training costs to flight attendants, check flight attendants, and instructors consists 

of the proposal’s additional training time, transportation, hotel and per diem costs, and the 

inclusive flight attendant instructional ground school expense. 

The FAA estimated the additional basic qualification training costs by taking the product of the 

new flight attendants employed, the incremental basic qualification training hours this proposal 

requires, and the total flight attendant hourly rate. We calculated the requalification and the 

recurrent costs in a similar manner. The only exception was that we used the requalification and 

 

34 http://www.ebri.org/pdf/publications/books/databook/DB.Chapter%2003.pdf updated May 2009. 
49

recurrent hours instead of the basic qualification hours and included the recurrent training 

cycle.35

For the check flight attendants and instructors, we calculated their incremental basic 

qualification, requalification and the recurrent costs in a similar manner as flight attendants. The 

only exception was that we used check flight attendant and instructor wages and incremental 

hours instead of flight attendant wages. 

Lastly, we summed the initial, recurrent and requalification training costs to arrive at a total 

training cost, by flight attendant, check flight attendant and instructor. 

The FAA expects the additional training requirements would result in additional travel for 

training for flight attendants, check flight attendants, and instructors. Using the assumptions 

above, we calculated the travel costs by taking the product of the number of flight attendants, 

check flight attendants and instructors, the transportation costs by travel mode, and the additional 

travel days required. We note that flight attendants who use distance learning will not incur 

additional travel costs. 

Next, we calculated the inclusive flight attendant instructional ground school expense by taking 

the product of the number of flight attendants, check flight attendants and instructors, the 

incremental basic qualification, requalification, and recurrent training hours this proposal 

requires, and the inclusive flight attendant instructional ground school hourly expense of $37.43. 

We note the inclusive flight attendant instructional ground school expense includes the instructor 

costs and flight attendants who use distance learning would not incur this expense. 

Table 20 shows the results of our calculation of the estimate costs of this proposal to flight 

attendants, check flight attendants, and instructors: 

 

35 The basic qualification and requalification training cycles occurs only once while the recurrent training cycles are 

annual. 
50

III.C.3. Subpart CC Costs 

The FAA has analyzed the expected costs of subpart CC proposed requirements from 2016 

through 2025. The assessment of the additional hours required drives the cost estimate for the 

aircraft dispatcher, check aircraft dispatcher and instructor training. Subpart CC would impose 

additional hours of initial, transition, and recurrent training costs, which would increase the costs 

to operators of training aircraft dispatchers, check aircraft dispatchers, and instructors. The 

estimated costs equal the product of the number of aircraft dispatchers, the additional training 

hours proposed, and their wages plus benefits. The incremental costs of training aircraft 

dispatchers are estimated at about $614.6 thousand in nominal dollars, check aircraft dispatchers 

about $404.8 thousand, and instructors about $202.7 thousand. The FAA determined that no 

additional paperwork would occur over current regulation requirements. Thus the expected costs 

for subpart CC would be about $1.2 million, $622.6 thousand at a seven percent present value, 

and $905.6 thousand at a three percent present value. These costs would begin to accrue in 2016, 

five years after the rule is expected to take effect, and continue to 2025. 

Many of the changes in subpart CC are either editorial or procedural in nature. These types of 

proposed revisions do not add any new requirements or impose costs. Some changes expand or 

clarify the intent of the proposed rule through reorganization, updating terminology, and 

clarifying procedures. These proposed changes do not impose any new requirements or costs. 
51

III.C.3.A. Aircraft Dispatcher Assumptions 

The FAA made the following assumptions to facilitate estimating the costs for dispatcher 

training: 

• The total number of affected aircraft dispatchers at the end of December 2009 is 2,285 and 

will represent the number of employees in 2010.36

 

• The average number of equipment groups per part 121 and 121/135 passenger and cargo 

operators is two.37

• In December 2009, the FAA surveyed aircraft dispatcher training schools and determined the 

cost to certificate a flight follower ranges from $1,950 to $2,900, with an average of $2,400. 

• Five percent of the affected aircraft dispatchers would require transition training. 

• 100 percent of the check dispatchers and instructors attend recurrent training every 12 

months. 

The FAA requests comments on these assumptions, accompanied by clear documentation. 

III.C.3.B. Number of Aircraft Dispatchers Affected

This section discusses the derivation of our estimate of the number of aircraft dispatchers, check 

aircraft dispatchers, and instructors employed by part 121 and 121/135 operators between 2010 

and 2025. 

The above assumptions, the turnover rate of five percent, the growth rate of 0.3 percent, the 

2,285 number of 2010 aircraft dispatchers, check aircraft dispatchers, and instructors employed 

by part 121 and 121/135 operators form the quantitative basis for estimating the number of 

affected dispatchers from 2010 to 2025. 

 

36 NVIS. 

37 OAG Fleet Database reports an average of 1.65 equipment groups per operator, which we rounded up to two. The 

OAG Fleet Database defines an equipment group as major groupings of aircraft types. For example, B737 would 

include all of the B-737 variants. 
52

The FAA surveyed the supplemental operators and determined that 278 flight followers were not 

included in the NVIS database. From our survey, we determined that 248 of the 278 flight 

followers are certificated as FAA aircraft dispatchers. The remaining 30 flight followers (278-

248) do not have FAA certificates and will have to go through initial training the year this 

proposal goes into effect. 

Several steps are needed for a 2010 estimate of the total number of parts 121 and 121/135 

dispatchers. First, we added the number of aircraft dispatchers from the NVIS database to the 

number of flight followers to obtain a 2010 total of 2,533 (2,285+248). Since the NVIS database 

only includes a total number for aircraft dispatchers, we estimate the 2010 number of check 

aircraft dispatchers by calculating the product of four percent of 2,533 to obtain 101 check 

aircraft dispatchers. Next, we calculated the number of instructors by taking the product of two 

percent of 2,533 to obtain 51 instructors. Lastly, we subtract the number of check aircraft 

dispatchers and instructors for the 2010 NVIS total number of aircraft dispatchers. These 

calculations resulted in a total 2,381 (2,533-110-51) aircraft dispatchers, 101 check aircraft 

dispatchers, and 51 instructors employed by part 121 and 121/135 operators in 2010. 

Next, we calculated the turnover and growth rate for aircraft dispatchers, check aircraft 

dispatchers, and instructors by calculating the product of the number of aircraft dispatchers, 

check aircraft dispatchers and instructs and five percent for the turnover rate and 0.3 percent 

(5.3) for the growth rate, by year, for 2010 through 2025. 

Table 21 shows the results of these calculations for the estimated number of aircraft dispatchers, 

check aircraft dispatchers and instructors from 2010 through 2025. The ‘Initial’ column 

represents the number of aircraft dispatchers, check aircraft dispatchers and instructors who 

would go through initial training. The ‘Transition’ column represents the number of aircraft 

dispatchers who would go through transition training. The ‘Check Dispatchers’ and ‘Instructor 

Dispatchers’ columns represent the number of check aircraft dispatchers and instructors who 

would go through annual recurrent training. We note these new training requirements would 

start when the proposal becomes effective in 2016. 
53

III.C.3.C. Subpart CC Aircraft Dispatcher Cost Estimation Methodology 

This section presents the methodology to estimate the costs of the incremental training hours 

required by this proposal. We begin by comparing the current requirement of the number of 

training hours to those proposed in the SNPRM. Then, we discuss the aircraft dispatcher’s 

hourly wages and the employee benefits. Next we discuss our estimation of the additional 

aircraft dispatcher training costs for the proposed rule. Lastly, we show our estimate of the 

additional aircraft dispatcher, check aircraft dispatcher and instructor training costs for the 

proposed rule. 

The FAA sets a minimum requirement for training aircraft dispatchers and we believe industry 

practices exceed our minimum requirement. We base our estimate on the incremental time this 

proposal adds to the current requirements with the expectation that actual industry compliance 

costs would be lower. 

Table 22 shows the minimum aircraft dispatcher training hours currently required by the FAA, 

the number of training hours required by this proposal, and the difference between the two. The 

FAA requests comments on these minimum aircraft dispatcher training hours, accompanied by 

clear documentation. 
54

The FAA determined that the incremental training this proposal adds would occur in-house by 

qualified FAA-certificated dispatchers, who are acting as instructors, employed by the operators. 

Therefore, no travel time for aircraft dispatchers, check aircraft dispatchers and instructors would 

be necessary for the additional training requirements of this proposal. The FAA will use the 

hourly wages of aircraft dispatchers, check aircraft dispatchers and instructors as a basis to 

estimate the aircraft dispatcher costs. In addition to hourly wages, we include employee benefits. 

Benefits include health benefits, vacation, life-insurance, sick time, etc. In May 2009, the 

Employee Benefit Research Institute, using a Bureau of Labor Statistics Survey of employee 

benefits estimated the total 2009 benefit as a percentage of payroll, at 30.2 percent.38 The FAA 

will use the 30.2 percent to estimate the value of hourly benefits for aircraft dispatchers, check 

aircraft dispatchers and instructors as an additional cost of this proposal. 

Table 23 shows the hourly wage, estimated hourly benefit, and total hourly cost we calculated 

for aircraft dispatchers, check aircraft dispatchers, instructors, and the Director of Training. 

 

38 http://www.ebri.org/pdf/publications/books/databook/DB.Chapter%2003.pdf updated May 2009. 
55

The FAA estimated the aircraft dispatcher costs by summing the initial training cost to certificate 

the 30 flight followers with the cost of initial training for the newly hired aircraft dispatchers, the 

transition cost, and the recurrent costs of training existing certificated check dispatchers and 

instructors. First, we took the product of 30 flight followers and the average $2,400 certification 

cost. We then calculated the initial training cost by taking the product of the total increase of 

new aircraft dispatchers employed, the incremental training hours required, the total hourly 

aircraft dispatcher rate including the instructor costs, and the average number of equipment 

groups per operator. We calculated the aircraft dispatcher transition costs in a similar manner as 

the initial training costs, with the exception of including the flight followers’ certification costs 

and the average number of equipment groups per operator. 

For the check aircraft dispatchers and instructors, we calculated their incremental costs of this 

proposed rule in a similar manner as aircraft dispatchers except we used check aircraft dispatcher 

and instructor wages and incremental hours instead of aircraft dispatchers and the Director of 

Training conducted the instructor classes. Also, we calculated the recurrent costs by taking the 

product of the number of check aircraft dispatchers and instructors, the incremental hours, their 

total hourly rate including the instructor costs, and the average number of equipment groups per 

operator. Lastly, we summed the initial, recurrent and transition training costs to arrive at a total

training cost, by aircraft dispatcher, check aircraft dispatcher and instructor. 

Table 24 shows the results of our calculation of the estimate costs of this proposal to flight 

followers, aircraft dispatchers, check aircraft dispatchers and instructors. 
56

III.D. Government Costs 

We present the estimation of the government costs for this proposed rule. We start with an 

estimate of the wages and benefits for the FAA employees involved. Next we discuss the 

estimated costs to the FAA for reviewing the updated crewmember manuals. Then we estimate 

the FAA costs to review and approve the crewmember training programs revisions. Lastly, we 

discuss our estimates of the FAA continuous analysis process costs and then summarize the total 

estimated government costs. 

The following computations involving salaries include the hourly wage and, as discussed above, 

employee benefits, which are estimated 30.2 percent of hourly wage. 

Table 25 shows the hourly wage, estimated hourly benefits, and total hourly employee costs we 

calculated for managers, aviation safety inspectors and clerks. 
57

We now discuss the estimated costs to the FAA for reviewing the updated crewmember manuals. 

The proposed SNPRM changes that deal with manuals for operations in accordance with part 

121 and 121/135 would require revisions to the manual requirements. The manuals must include 

the instructions and information necessary to allow the pilots, other pilots and flight engineers to 

perform their required safety related duties and responsibilities. The manual, and any changes, 

must be approved by the FAA Administrator. 

The FAA estimates that, for a certificate holder operating under part 121 and 121/135 with two 

equipment groups, on average 35 percent of the content of these manuals will require revision.39

 

On average, we estimate that this constitutes about 86 pages for each aircraft type. Review of 

the proposed changes will be required by the FAA and will require an Aviation Safety Inspector 

(Cabin Safety) and an Aviation Safety Inspector (Operations). The final review and acceptance 

of these manual revisions will be made by the FAA principal operations inspector and will 

require one day for review. 

From the FAA National Vital Information Subsystem (NVIS) database, we determined that this 

proposal would require 80 operators with traditional pilot training programs to update the content 

of their manuals. 

We determined the time required for each FAA employee to review the updated manuals. Table 

26 shows these times. 

 

39 OAG Fleet Database 
58

We estimate the government cost of reviewing the updated manuals by calculating the product of 

hourly wage, the average number of equipment groups per operator, the number of operators, 

and the number of hours determined for each FAA employee category. Then we summed the 

costs for each employee category. 

Table 27 shows these results. 

We now estimate the FAA costs to review and approve the proposal’s training program 

revisions. 

This proposal would revise the training program requirements for pilots, flight engineers, flight 

attendants, and persons authorized to administer pilot, flight engineer, and flight attendant 

proficiency tests. 

The overall commitment of time to review and approve the appropriate training program or 

program revision impact the FAA through principal operations inspectors, aircrew program 

designees, operations inspectors, cabin safety inspectors, and FAA clerks or secretaries. The 

documents and information reviewed and approved or rejected are addressed here. 

We estimate FAA costs for revising crewmember training programs for each category as 

follows: 

(a) Pilots (includes training programs for PIC, SIC, check and instructor pilots): 
59

(i) Existing module review requires one hour for review by an Aviation Safety InspectorOperations, 15 modules for each equipment group, for 80 passenger and cargo air 

carriers. 

(ii) New module development requires five hours to review by an Aviation Safety 

Inspector-Operations, three new modules per aircraft type for two equipment groups, 

for 80 passenger and cargo air carriers. 

(iii) Review by Principle Operating Inspector (POI) of complete Pilot training program. 

(b) Flight Engineers (includes training programs for flight engineers, check and instructor 

flight engineers): 

(i) Existing module review requires one hour for review of each existing module by an 

Aviation Safety Inspector-Operations, three modules for each equipment group, for 25 

air carriers.40

(ii) New module development requires five hours, by an operations inspector, for each new 

module, two new modules for each equipment group, for 25 air carriers. 

(iii) Review by POI of complete flight engineer training program. 

(c) Flight Attendants: 

(i) For review of the modified existing training modules. 

A. Requires one hour for review by an Aviation Safety Inspector-Cabin Safety for 15 

modules, two equipment groups, and 66 passenger air carriers.41 

B. Requires eight hours for review by an Aviation Safety Inspector-Cabin Safety for 

three emergency training modules, and 66 passenger air carriers. 

C. Requires four hours for review by an Aviation Safety Inspector-Cabin Safety for 

three basic indoctrination modules, and 66 passenger air carriers. 

(ii) For review of the new training modules. 

A. Requires eight hours for review by an Aviation Safety Inspector-Cabin Safety for 

two modules per two equipment groups, and 66 passenger air carriers. 

B. Requires eight hours for review by an Aviation Safety Inspector-Cabin Safety for 

five new emergency training modules, and 66 passenger air carriers. 

 

40 FAA National Vital Information Subsystem (NVIS) database 

41 Ibid. 
60

C. Requires eight hours for review by an Aviation Safety Inspector-Cabin Safety for 

one new basic indoctrination module, and 66 passenger air carriers. 

(iii) Requires two hour review by a principal operations inspector of complete flight 

attendant training program for 66 passenger air carriers. 

(d) Cover, approval letter: Requires 1.5 hour review by a clerk or secretary for 66 passenger 

air carriers. 

Table 28 shows these results: 

We now discuss our estimates of the continuous analysis process (CAP) costs to the FAA and 

then summarize the total estimated government costs. 

Air carriers would be required to document the effectiveness of their training and qualification 

programs, or the need to change, to allow for continuance. The cost of the CAP is divided into 

three parts: pilots, flight engineers, and flight attendants. To estimate the CAP costs we 

calculated an initial and recurrent cost to the FAA. The initial cost was estimated by taking the 

product of a two hour review by an aviation safety inspector for each crewmember category. 

The recurrent costs were estimated by taking the product of a one hour review by an aviation 

safety inspector for each crewmember category. 
61

Table 29 shows these results. 

We then summed the estimated costs to the FAA for reviewing the updated crewmember 

manuals, reviewing and approving the crewmember training program revisions, and the 

continuous analysis process. 

Table 30 shows these results 

On average, over the 10-year analysis interval, the government costs would be about $257,900 

nominal dollars every year. 

III.E. Industry Cost Estimate 

Despite working closely with industry, there still remains a wide variance in the cost estimates 

between the FAA and industry. We tried to reduce our differences by drafting a technical report 

that outlined the tasks that we believe industry would need to accomplish for the NPRM. In this 

report we selected a single airplane type for each of the six operators with AQP pilot training 

programs and the one operator with a traditional pilot training program. We then presented this 
62

report to industry in December 2009 and met to discuss the understanding of the NPRM 

requirements based on our technical report.42 

Discussions with industry after the December 2009 meeting, led us to determine the following 

costs that industry believes the proposal would add that differ from the FAA’s intentions: 

• New definition of check pilot/check captain, 

• Definition of “complete flightcrew”, 

o New definition for the qualification of seat substitutes whenever training 

requirements dictate that crews are not perfectly matched, 

o The correct assignment of crews because of labor agreement requirements that 

flying be awarded based on seniority, 

o Crew pairing, 

o Both seats in the simulator are not able to be filled, 

• Increased line check task requirements, 

• Additional reports and approvals, 

• Operators with AQP pilot training programs would incur substantial costs, 

• Modifications to training assignment software, 

• Modification to Instructor and device scheduling software, 

• Logic changes in crew scheduling software, 

• Logic changes in schedule audit software, and 

• Operators with traditional pilot training programs believe ground school costs are 

minimal. 

The FAA believes that once the SNPRM has been released that some of these differences may be 

resolved. In the meantime, we provide the industry’s cost estimates they believe this proposal 

will add to traditional pilot, flight engineer, flight attendant and aircraft dispatcher training 

programs. Although the FAA expects that this proposal would have a minimal impact on 

operators with an AQP pilot training program, we also include an AQP-increased cost estimate 

based on industry provided costs. Much of the AQP pilot training operator cost estimates from 

 

42 “Comparison of Current Training and Qualification Requirements in Part 121, Subparts N, O, and Y, and

Proposed Training and Qualification Requirements in Subpart BB”, October 31,2009. 
63

industry are based on the absolute requirement for only a PIC and SIC to train together in a 

simulator. As stated in the preamble, the FAA is requiring a complete flight crew for training 

and evaluation, but allows for substitution of flightcrew members in certain circumstances. 

Based on the NPRM comments and following the December 2009 Industry meeting, we obtained 

operator estimates of compliance costs which differ significantly from the FAA’s estimates. In 

order to maintain confidentiality of the operators who provided costs estimates, we first 

calculated an average initial and recurrent cost by taking the quotient of each responder 

operator’s aircraft dispatcher, flight attendant, and pilot costs with their number of aircraft 

dispatchers, flight attendants, and traditionally trained pilots employed in 2010. We then 

averaged each of these costs by operator to determine an average cost per individual aircraft 

dispatcher, flight attendant, and traditionally trained pilots. Next, we took the product of the 

average cost per individual aircraft dispatcher, flight attendant and traditionally trained pilot with

the total number employed by part 121 and 121/135 operators. With only minimal AQP costs, 

the operators estimated the SNPRM would impose $2.3 billion total nominal costs and $1.3 

billion costs at a seven percent present value. 

Table 31 shows these results. 

Although it is the FAA’s intention that this proposal would not have more than a minimal effect 

on operators with AQP pilot training programs, using industry estimates, we estimated 

substantial costs to operators with AQP pilot training programs. Operators with AQP pilot 

training programs estimate they would incur an additional $6.0 billion in compliance costs, $3.2 

billion at a seven percent present value, and $4.6 billion at a three percent present value from this 
64

proposal. These cost estimates are higher than we received from the NPRM because industry 

expects that this proposal’s requirements are more onerous for relief pilot consolidation (crew 

pairing) and an expected FAA approval process for the continuous analysis process. The FAA 

requests specific comments from industry on how to minimize any impact on operators with an 

AQP pilot training program while meeting the intent of this rulemaking. 

For such wide differences in costs, there must be wide differences in the interpretation of 

compliance. One of the most significant differences is crew pairing. Industry estimates appear 

to assume the worst case that only a PIC and SIC can train together in a simulator. We expect 

after industry has read the SNPRM preamble and rule language, such differences would be 

minimized. 

IV. POISSON DISTRIBUTION ANALYSIS MODELING ACCIDENT

PROBABILITY 

Without preventative action accidents attributed to the lack of flight crew training could occur in 

the future. The FAA uses the Poisson distribution to model the accident probability of the lack 

of flight crew training since that distribution has been shown to be appropriate for rare event 

discrete outcomes. The Poisson is a one-parameter distribution whose parameter, λ, is equal to 

the expected number of accidents. 

We estimate λ for the lack of flight crew training accidents by multiplying the total number of 

178 pilot, flight attendant, and aircraft dispatcher accidents by the effectiveness criterion value’s 

percentage43 and dividing the product by 22, which is the number of years in the historical 

analysis interval from 1988 through 2009. The results of our calculations yield 2.31 for λ, the 

average number of expected accidents per year. 

Next, we multiply 2.31, the average number of expected preventable accidents per year, by the 

number of years in analysis period, which extends for 10 years from 2016 through 2025, to 

 

43 Calculated by summing the ASAIS/AIA effectiveness values (267) for each of the 178 accidents and then dividing 

by the total possible effectiveness value (178*5). 
65

obtain 23.1 total preventable accidents. We then divide 23.1 by the nominal base case benefits 

of $445 million. This results in an average benefit value of $19.3 million per accident. 

Based on the Poisson distributions tables with λ = 2.3, there is a 67 percent probability that the 

proposed rule would prevent two or more accidents for each year of the analysis interval. 

The shaded area’s of Table 32 shows the results of this analysis. The P(x or more) column 

represents the cumulative probabilities of x or more accidents, per year, when x = 0,1, ... ,10. 

The Poisson distribution results support the FAA’s concern regarding the need for this proposed 

rule. 

V. BENEFIT COST SUMMARY 

The benefits of this proposal would increase safety and contribute significantly to reducing the 

frequency of future aviation accidents. Phased-in potential quantified benefits would accrue from 

the additional training initiatives and are estimated to be about $445.06 million over the next 10-

year analysis interval, $222.86 million at a seven percent present value, and $327.48 million at a 

three percent present value. 
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Table 33 shows the proposals benefit breakdown by pilot, flight attendant, and aircraft 

dispatcher. 

The proposed rule would also generate qualitative benefits for pilots and flight engineers, flight 

attendants, and aircraft dispatchers. Qualitative benefits include enhanced aviation safety with 

the increased training and evaluation requirements, reduced air pollution and fuel costs. 

Qualitative benefits also include addressing the open NTSB safety recommendations related to 

crewmember training. The changes proposed in this SNPRM address the following NTSB 

recommendations: 

• Crewmember Resource Management (CRM) training (Recommendations A-88-71 and 

A-94-96); 

• Flight attendant training (Recommendations A-92-67, A-92-70, A-92-71, A-92-74, and 

A-92-77); 

• TCAS RA training (Recommendation A-93-46); 

• Use of simulators to conduct LOFT (Recommendations A-94-191 through 194); 

• Training of flightcrews to respond to sudden, unusual or unexpected aircraft upsets 

(Recommendation A-96-120); 

• Training of crewmembers to respond to in-flight fires (Recommendations A-01-83 

through A-01-85); 

• Aircraft pressurization on the ground while the ground-based air conditioning is 

supplying conditioned (cooled or heated) air to the cabin (Recommendation A-07-96); 

• Monitoring of exit availability on the ground after a significant event to help expedite and 

emergency evacuation (Recommendation A-09-26); 

• Communication and coordination between Flight Crewmembers and Flight Attendants 

regarding emergency and unusual situations (Recommendation A-09-27); 

• Pilot monitoring duties (Recommendation A-10-10); 

• Requirements for flightcrew member academic training regarding leadership 

(Recommendations A-10-13, A-10-14, and A-10-15); 
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• Pilot recordkeeping requirements regarding training performance (Recommendations A10-17 and A-10-18); 

• Develop and implement procedures to establish airspeed reference (Recommendation A10-21); and 

• Develop and conduct stall recovery training and provide stick pusher familiarization 

training for pilots of stick-pusher equipped aircraft (Recommendations A-10-22 and A10-23).44

Lastly the Poisson distribution analysis shows there is a 67 percent probability that the proposal 

would prevent two or more accidents for each year of the analysis interval. This high probability 

of airplane accidents is unacceptable for the FAA’s mission of safety. 

From 2010 to 2025, the FAA estimates the total cost of the proposed rule would be 

approximately $391.9 million in nominal dollars, $199.1 million at a seven percent present 

value, and $290.3 million at a three percent present value. The total costs include increased 

training for pilots, flight engineers, flight attendants and aircraft dispatchers along with 

additional costs of more simulators, paperwork for updating manuals, and government costs for 

review and approval of the modified training programs and manuals. 

Table 34 summarizes these results. 

 

44 The NTSB Safety Recommendation Letters are available online at http://www.ntsb.gov/Recs/letters/letters.htm. 
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Table 35 shows the proposal’s cost breakdown by pilot and flight engineer training, flight 

attendant training, aircraft dispatcher training, government and paperwork. 

Table 36 shows benefits, costs, and net benefits broken down by pilots, flight attendants, and 

dispatchers. 

The SNPRM quantitative benefit estimate of $445.1 million exceeds the quantitative cost 

estimate of $391.9 million for pilots, flight attendants and aircraft dispatchers. In addition, the 

proposed rule also has qualitative benefits. The qualitative benefits include our response to the 

FAA “Call to Action” and to the 28 NTSB safety recommendations. 

Thus, the FAA concludes that the benefits of the proposed rule justify the costs. 
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VI. APPENDICES 
70

Appendix 1 – Pilot-Related Accidents 
71
72
73

Appendix 2 – Flight Attendant-Related Accidents 
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Appendix 3 – Aircraft Dispatcher-Related Accidents 

 
75

Appendix 4 
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Appendix 5 

Table 5-1(a) was developed by APO to update the 2003$ values from Table 5-1. The U.S. fleet 

and aircraft values we used were current as of July 2008. 

Replacement values for air carriers were derived from proprietary databases developed by the 

Airliner Price Guide45 and OAG Aviation Solutions46. The Airliner Price Guide provided the 

base and market values for each airplane model by year of manufacture. The OAG Aviation 

Solutions Fleet database provided the number of active airplanes. 

The industry database covering each aircraft and aircraft type in the U.S. fleet was developed by 

creating a custom query from the OAG Aviation Solutions Fleet database. The average value 

was developed using an estimated value for each aircraft delivered in a given year, and then 

aggregating these values into the economic values aircraft categories. 

The updated summary of values for passenger and all cargo air carrier aircraft are shown in 

Table 5-1(a). Detailed data by equipment type are contained on the APO website. The first 

column for each operator group reports the number of aircraft in the OAG Aviation Fleet 

database that were used in developing weighted averages.

47 The second column shows the 

airplane group. The third column shows the year the airplane was manufactured. The fourth 

column shows the current (2008) market value values. The fifth column shows the base values, 

which assumes an orderly market for aircraft transactions. The sixth column shows the number 

of active aircraft as of July 31, 2008. The average base value of a passenger aircraft is about 

$18.1 million. The market value is about $1.5 million less. The range in values among the 

equipment groups is quite large reflecting the different average size and average age of aircraft in 

each group. Similar results hold for all cargo aircraft. 

 

45 Airliner Price Guide, 568 Waterloo Road, Suite 102, Warrenton, VA 20186. 

46 OAG Aviation Solution, 3025 Highland Pkwy, Suite 200, Downers Grove, Il 60515. 

47 This differs from the Form 41 fleet sizes because they consider all aircraft in the U.S. fleet, including aircraft out 

of service, aircraft in non-commercial service and other circumstances. 
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Appendix 6 

Part 121/135 Pilot, Flight Engineer, Flight Attendant and Aircraft Dispatcher Employment 

2010 
78

Appendix 7 

Break out of Simulator Costs by PIC, SIC and Flight Engineer 
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Appendix 8 

Alternate Benefit Analysis 

The FAA believes the methodology employed in the regulatory evaluation (RIA) provides a 

reasonable accurate estimate of benefits associated with the proposed requirements of the 

SNPRM. This belief is based on the fact that we only included accidents where the pilots 

received N&O training and we subjected all accidents to a CAST effectiveness process. 

In Appendix 8, we discuss an alternate methodology that would result in a more conservative 

estimation of benefits because the N&O SNPRM RIA benefit analysis may be biased upwards 

by: 

• including accidents that occurred with pilots trained under N&O who subsequently 

converted to an AQP pilot training program, 

• not accounting for when an operator trains their pilots under N&O is purchased, does the 

pilot’s training process remain uniform, and 

• not including the exit of many of the former N&O operators from the marketplace. 

When we tried to model out the potential upwards bias, we ran into a series of insurmountable 

problems. Ultimately, these problems prevented us from fully modeling more than one alternate 

approach. 

The calculation problems included: 

• AQP training occurs by equipment type. Therefore operators train pilots over a widelyvarying prolonged period of time. 

• When an operator with an N&O pilot training program is purchased by an operator with an 

AQP pilot training program, the new operator may phase out airplanes and the new crews can 

be assigned to fly other airplanes that require N&O training, or the new operator may phase 

the pilots into an AQP training program under timeframe not knowable to FAA. 

• As N&O operators exit the market place, we have no way of determining where their pilots 

went to work next; that is for an operator with an N&O, or AQP pilot training program. 
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FAA believes that the RIA benefit analysis reasonably estimates the benefits associated with this 

proposal, however, we seek comments on this analysis and the alternative benefits analysis 

below. 

The data for the historical review period that are necessary for an analysis based on the number 

of operations are problematic because of the way airlines transitioned from N&O to AQP. 

Therefore, this proposed analytical method is intended to serve as a proxy for this data. 

The alternate benefit analysis APO prepared includes the following steps and results: 

• Step 1. Indentify and calculate the percentage of the accidents used in the RIA that occurred 

while the pilot was training under N&O then the operator later switched to an AQP training 

program. The FAA believes this proposal addresses 149 N&O trained pilot-related accidents. 

Of these 149 accidents, we identified 37 accidents that occurred on airplanes operated by 

pilots who were trained under N&O, whose airlines later converted to an AQP program. The 

remaining 112 accidents occurred on airplanes operated by pilots who were trained under 

N&O and whose airlines continue to train under N&O. We did not include accidents 

involving pilots who trained under an AQP program at the time of the accident. The 

following table shows these results: 

• Step 2. The FAA Accident Investigation and Prevention Group (AVP) rated each of the 149 

accidents by conducting a Commercial Aviation Safety Team (CAST) scoring process. This 

step provided an accident mitigation ratio for each of the 149 accidents. 

• Step 3. For the 112 accidents that occurred on airplanes operated by pilots who trained under 

N&O and whose airlines continue to train under N&O, we then estimated the benefits using 
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the AVP-provided accident mitigation ratio along with the critical values for each accident’s 

number of fatalities, injuries, and accident investigation costs. 

• Step 4. Next, for the 37 accidents that occurred on airplanes operated by pilots who trained 

under N&O and whose airlines later switched to an AQP program we estimated the benefits 

using the AVP score along with the critical values for each accident’s number of fatalities, 

injuries, and accident investigation costs. 

• Step 5. We then calculated the percentage of the 2010 operations that were operated by 

pilots trained under N&O and AQP programs. The following table shows these results: 

• Step 6. Next, we multiplied the results of Step 4 by the percentage of operations in 2010 by 

pilots trained under N&O (57.6%) versus total operations by part 121 operators. We believe 

this step under estimates the expected benefits. 

• Step 7. We then summed the results from Step 3 and Step 6 to obtain the total benefits over 

the 22-year historical analysis interval. 

• Step 8. Next, we divided the results of Step 7 by the 22-year historical analysis interval to 

obtain an annual average historical benefit for the 149 accidents. 

• Step 9. We then assumed the equally likely preventable accident average from Step 8 could 

happen in any year over the future 10-year analysis interval. 

• Step 10. Lastly, we calculated the 3 and 7 percent present value for the equally likely 

preventable accident average from Step 9 over the future 10-year analysis interval. 

The following table shows these results: 
82

Using this benefit modeling method, the SNPRM has a benefit to cost ratio of about 1.02:1. 

We request comment on these assumptions and the methodology from the following alternative 

benefit analysis.