### Pilot Professional	Development	Regulatory	Evaluation

U.S. Department of Transportation **FEDERAL AVIATION ADMINISTRATION**  

# NOTICE OF PROPOSED RULEMAKING

**REGULATORY EVALUATION Pilot Professional Development**  **14 CFR Part 121** 
**OFFICE OF AVIATION POLICY AND PLANS**  **ECONOMIC ANALYSIS DIVISION**

**Catherine L. Taylor Gregory Bucci**  VOLPE NATIONAL TRANS PORTATION SYSTEMS CENTER

**ECONOMIC ANALYSIS DI VISION**  

## OFFICE OF THE ASSIST**ANT SECRETARY OF TRA NSPORTATION** 

**FOR RESEARCH AND TEC HNOLOGY** 



# July **2015**

### Pilot	Professional Development	Regulatory	Evaluation i



## Table	of	Contents **List	of	Abbreviations	and	Definitions** ................................ ................................ ................................ ... ii I. Executive Summary ................................ ................................ ................................ ............................... 3 II. Introduction/Background ................................ ................................ ................................ ..................... 7 III. Assumptions and Data Sources ................................ ................................ ................................ ........... 13 IV. Benefits ................................ ................................ ................................ ................................ ............... 21 V. Costs ................................ ................................ ................................ ................................ .................... 39 VI. Discussion of Alternatives ................................ ................................ ................................ ................... 49 VII. Benefit
- Cost Summary ................................ ................................ ................................ ........................ 51 VI II. Appendix A: Supporting Tables ................................ ................................ ................................ ........... 53 IX. Appendix B: ARC Proposal ................................ ................................ ................................ ................... 78

### Pilot	Professional Development	Regulatory	Evaluation ii



## List	of	Abbreviations	and	Definitions

**Acronym Definition**  AQP Advanced Qualification Program ATP Airline Transport Pilot BLS Bureau of Labor Statistics CRM Crew Resource Management FAA Federal Aviation Administration LOFT Line Oriented Flight Training MLP ARC Flight Crewmember Mentoring, Leadership, and Professional

Development Aviation Rulemaking Committee NPRM Notice of Proposed Rulemaking NTSB National Transportation Safety Board NVIS National Vital Information Subsystem PIC Pilot In Command PPDC Pilot Professional Development Committee SIC Second In Command THRR ARC Flightcrew Member Training Hours Requirement Review

Aviation Rulemaking Committee

### Pilot	Professional Development	Regulatory	Evaluation 3



## I. **Executive	Summary** In response to the Airline Safety and Federal Aviation Extension Act of 2010, Public Law 111 - 216, and the recommendations of the Flight Crewmember Mentoring, Leadership, and Professional Development (MLP) Aviation Rulemaking Committee (ARC), this notice of proposed rulemaking (NPRM) would require operators to provide pilots in command (PICs) with mentoring, leadership, and command training ; provide new-hire pil ots with operations familiarization ; and establish Pilot Professional Development Committees. This rulemaking applies to part 121 air carriers as well as p art 13 5 operators required to use pilot training and qualification programs that comply with p art 121 subparts N and O . Specifically, the rule would require :
 Operations familiarization for new -hire pilots;  Revised ground and flight training for upgrading pilots that includes mentoring, leadership, and command training;  Mentoring, leadership, and command ground training for current PICs;  Mentoring, leadership, and command recurrent training for PICs; and  Pilot Professional Development Committee s (PPDC). The new and modified training would be designed to enhance pilot professionalism, communication , and coordination . The benefits of the training in the proposed rule include an increased level of safety from mitigation of unprofessional pilot behavior which will reduce pilot error that can lead to a catastrophic event . The October 14, 2004 , crash of Pinnacle Airlines f light 3701 in Jefferson City, Missouri , and the February 12 , 2009 , crash of Colgan Air f light 3407 near Buffalo, New York, are examples of past accidents where unprofessional pilot behavior contributed to the accident. In addition , the proposed rule responds to National Transportation Safety Board (NTSB ) recommendations and satisfies the statutory requirement for rulemaking in Public Law 111 - 216 .

### Pilot	Professional Development	Regulatory	Evaluation 4

In addition to safety benefits, the NPRM also contains cost saving benefits based on changes to ground training in this proposal that are possible due to changes already implemented in the Pilot Certification R ule. The recent Pilot Certification final rule ensured technical proficiency

in those subjects via other means. 1 

### These changes would lead to a reduction in the time required to complete recurrent and upgrade training and would not compromise safety. The provisions of the proposed rule are summarized in Executive Summary Table 1, below. **Ex ecutive Summary Table**  **1: Summary of Proposed Rule Changes** 

### Provision **Affected Parties Estimated**  **Impact** Operations familiarization for new-hire pilots  New requirement for new-hire pilots to complete two operating cycles while occupying the flight deck observer seat New -hire pilots Additional 1 day of training
Revised upgrade ground training (see Table 5 )  Revised upgrade ground training  Addition of mentoring, leadership, and command training Pilots upgrading from SIC to PIC Removal of 2

days of training Addition of 1 day of training Revised upgrade flight training (see Table 6)  Change tasks covered in upgrade flight training Pilots upgrading from SIC to PIC No change in

training time New mentoring, leadership, and command ground training for pilots currently serving as PIC Current PICs Additional 1 day of training ( one time only) New mentoring, leadership, and command recurrent training for PICs PICs Additional 3 hours of training every 36 months New Pilot Professional Development Committees Carriers Minimum of 1 annual meeting

1 The Pilot Certification rule requires all SIC serving in part 121 operations to hold an airline transport pilot (ATP) certificate with a type rating and requires pilots to complete a minimum of 1,000 hours of relevant operational experience prior to serving as a PIC in part 121 operations. Additionally, the Pilot Certifi cation rule requires pilots, who will serve in part 121 operations, to complete the ATP Certification Training Program prior to ATP certification. Thus, the Pilot Certification rule requirements raise the baseline knowledge and experience level for pilots prior to serving at an air carrier. See Pilot Certification and Qualification Requirements for Air Carrier Operations ; Final Rule , published by the Federal Aviation Administration on July 15, 2013 (78 FR 42324) . https://www.federalregister.gov/articles/2013/07/15/2013 - 16849/pilot- certification- and- qualification-requirements for- air - carrier- operations

### Pilot	Professional Development	Regulatory	Evaluation 5

**Provision Affected Parties**  **Estimated Impact**  Revised Recurrent Ground Training  Change the general operational subjects covered in recurrent ground training (see Table 3 ) All pilots (PICs and SICs) Reduction of 1

hour training per year 

### The estimated cost saving s benefits created b y the proposed rule, b y provision, are shown in Executive Summary

Table 2 below. **Executive Summary Table 2**  **: Cost Saving Benefits of the Proposed Rule by Provision (2015**  **- 2024)** *

**Cost Saving**  **Benefits Total Cost Savings**  **(Millions of 2013 Dollars)**

**Present Value Total**  **7 Percent 3 Percent**  

### Recurrent Ground Training 

### (§ 121.427) $52.559 $34.424 $43.486 Upgrade Ground Training 

### (§ 121.420) $19.458 $11.839 $15.615 **Total** 

### $72.017 **$46.263 $59.101**  ***Table values have been rounded. Totals may not add**  **due to rounding.** 

### The estimated compliance costs of the proposed rule, by provision, are shown in the Executive Summary

Table 3 below. **Executive Summary Table 3**  **: Compliance Costs for the Proposed Rule by Provision**  **(2015 -**  **2024)** ***** **Cost Total Compliance Costs**  **(M illions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  

### New - Hire Pilot Operations Familiarization (§ 121.432(d)) $4.693 $2.855 $3.766 Upgrade Training (§§ 121.420 and 121.426) $10.178 $6.304 $8.227 One -Time and Recurrent PIC Training (§ 121.429, § 121.409(b), and § 121.427) $51.815 $37.037 $44.568 PPDC Annual Meeting (§ 121.17) $0.938 $0.572 $0.754 Recordkeeping $0.007 $0.006 $0.006 **Total** 

### $67.632 **$46.774 $57.321**  ***Table values have been rounded. Totals may not add due to rounding.**  

### The estimated total net benefit for compliance , by provision, for the proposed rule is shown in Executive Summary Table 4 below.

### Pilot	Professional Development	Regulatory	Evaluation 6 **Executive Summary Table 4**  **: Net**  **Benefits by Provision**  **(7% Present Value, Millions of 2013 Dollars, 2015 -**  **2024)** ***** **Provision Cost**  **Saving Benefits**  **Compliance**

**Costs Net** 

**Benefits** Recurrent Ground Training (§ 121.427) $34.424 $0 **$34.424** Upgrade Ground Training (§ 121.420) $11.839 $0 **$11.839** New - Hire SIC Operations Familiarization (§ 121.432(d)) Not Quantified $2.855 **- $2.855**  Upgrade Training (Mentoring, Leadership, and Command) (§§ 121.420 and 121.426) Not Quantified $6.304 **- $6.304**  One -Time and Recurrent PIC Training (Mentoring, Leadership, and Command) (§ 121.409(b), 121.427, and 121.429) Not Quantified $37.037 **- $37.037**  PPDC Annual Meeting (§ 121.17) Not Quantified $0.572 **- $0.572**  Recordkeeping Not Quantified $0.006 **- $0.006**  Total **$46.263 $46.774**  **- $0.511** 

***Table values have been rounded. Totals may not add due to rounding.**  

### In developing this NPRM, the FAA also analyz ed one alternative : a proposal representing the MLP ARC recommendations as presented to the FAA . The MLP ARC recommended several additional requirements that would result in costs significantly greater than the costs of the proposed rule. This regulatory

evaluation begins b y discussing the background leading to the proposed rule, including the relevant accidents and NTSB recommendations. The discussion then presents the key elements and assumptions made to complete the analysis. A qualitative discussion of the safety benefits of each provision of the rule and a quantitative analys is of the cost saving benefits follows. Next , the cost of each provision of the rule is estimated and discussed. Finally, a comparison of the proposed rule’s benefits and costs is presented. Back-up calculations related to the benefit and cost estimates are presented in Appendix A. The analysis of the MLP ARC recommendations, including cost estimation, is presented in Appendix B.

### Pilot	Professional Development	Regulatory	Evaluation 7



## II. **Background and	Need	for	Regulation**  A. Ba ckground Although the overall safety and reliability

of the National Airspace System demonstrates that most pilots conduct operations with a high degree of professionalism, a problem still exists in the aviation industry

with some pilots acting unprofess ionally and not adhering to standard operating procedures, including maintaining a sterile flight deck . The National Transportation Safety Board (NTSB ) has continued to cite inadequate leadership in the flight deck, pilots’ unprofessional behavior, and pil ots’ failure to comply with the sterile flight deck rule as factors in multiple accidents and incidents including Pinnacle Airlines f light 3701 (October 14, 2004) and Colgan Air f

light 3407 (February 12 , 2009). The Colgan Air accident2 

### focused public and Congressional attention on multiple aspects of air carrier training requirements, including issues pertaining to pilot mentoring, leadership , and command . The accident also raised questions about pilot adherence to the sterile flight de ck rule. 3 

## B. Accident	History	Related	to	the	Proposed	Rule The following accidents exemplify the ty pes of accidents that the proposed regulatory options are intended to prevent . We discuss these accidents to provide a qualitative analysis of

2 Some contributing factors to this accident were also mitigated by the following rules: Flightcrew Member Duty and Rest Requirements with a .5 effective mitigation, Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers with a .2 effective mitigation, the Pilot Certification Rule with a .2 effective mitigation, and Safety Management Systems for Domestic, Flag, and Supplemental Operations Certificate Holders with a .05 effective mitigation . 3 14 CFR 121.542, commonly referred to as the sterile cockpit or flight deck rule, prohibits crewmembers from engaging in duties not required for the safe operation of the aircraft, or performing any activity which could distract or interfere with the performance of his or her duties during critical phases of flight.

### Pilot	Professional Development	Regulatory	Evaluation 8

the expected b enefits of the proposed rule . Moreover the proposed requirements respond to Congressional direction and to unresolved NTSB recommendations. 

## 1. **Pinnacle	Airlines	Flight	3701	Jefferson	City,	Missouri** On October 14, 2004, a Pinnacle Airlines (doing business as Northwest Airlink F light 3701) Bombardier C L - 600 - 2B19, crashed into a residential area about 2.5 miles south of Jefferson City, Missouri. During the flight, both engines flamed out after a pilot- induced aerodynamic stall and were unable to be restarted. Both pilots were killed and the airplane was destro ye d. The NTSB concluded that the probable cause s of the accident were : “... (1 ) the pilots’ unprofessional behavior, deviation from standard operating procedures, and poor airmanship, which resulted in an in
- flight emergency from which they were unable to recover, in part because of the pilots’ inadequate training ; (2) the pilots’ failure to prepare for an emergency landing in a timely manner, including communicating with air traffic controllers immediately after the emergency about the loss of both engines and the availability of the landing sites; and (3) the pilots’ improper management of the double engine failure checklist ...” 4 

### The NTSB noted that at the time of the accident, Pinnacle Airlines provided two hours of leadership training during SIC to PIC upgrade training with topics covering leadership authority, responsibility, and leadership styles. The NTSB also noted that after the accident and as a result of a high initial failure rate for pilots upgrading to PIC (the failure rate in July 2004 was 22 percent), Pinnacle revised the leadership training to eight hours with modules on leadership, authority, and responsibility; briefing and debriefing s cenarios; decision-making processes, including those during an emergency; dry run line - oriented flight training scenarios; and risk

4 NTSB Accident Report AAR- 07/01, “Crash of P innacle Airlines Flight 3701 Bombardier CL - 600 - 2B19, N8396A Jefferson City, Missouri October 14,2004.”, p .73 .

### Pilot	Professional Development	Regulatory	Evaluation 9

management and resource utilization. In October 2006, Pinnacle reported to the NTSB that the pass rate for pilots upgrading to PIC had improved to 92 percent for first attempts and 95 percent overall. 

## 2. **Colgan	Air	Flight	3407	Northeast	of	Buffalo,	New	York** On February 12 , 2009, a Colgan Air (doing business as Continental Connection flight 3407) Bombardier DHC - 8 - 400 stalled and crashed into a residence at Clarence Center, New York, while on approach to Buffalo -Niagara Airport. All 45 passengers and the 4 crewmembers in the airplane plus one person on the ground died. The NTSB concluded that the probable cause of this accident “... was the captain’s inappropriate response to the activation of the stick shaker, which led to an aerodynamic stall from which the airplane did not recover
. Contributing to the accident was : (1

) the flightcrew’s failure to monitor airspeed in relation to the rising position of the low
-speed cue; (2) the flightcrew’s failure to adhere to sterile cockpit procedures; (3) the captain’s failure to effectively manage the flight; and (4) Colgan Air’s inadequate procedures for airspeed selection and management during approaches in icing conditions. ”5 

### The NTSB noted that at the time of the accident, although the Colgan Air crew resource management (CRM) training was consistent with Advisory Circular 120 - 51E - Crew Resource Management Training, it only included five slides that addressed command, leadership, and leadership styl es. The NTSB also noted that the Colgan Air SIC to PIC upgrade training included a one - day course on leadership; however, the training focused on the administrative duties associated with becoming a PIC and did not contain significant content applicable to developing 5 NTSB Accident Report AAR- 10/01, “Lo s s of Control on Approach, Colgan Air, Inc. Operating as Continental Connection Flight 3407 Bombardier DHC - 8 -400, N200WQ Clarence Center, New York, February 12, 2009.” p. 155 .

### Pilot	Professional Development	Regulatory	Evaluation 10

leadership skills, management oversight, and command authority . The NTSB concluded that specific leadership training for pilots upgrading to PIC would help standardize and reinforce the critical command authority skills needed b y a PIC during air carrier operations.


## C. NTSB Recommendations In response to those two accidents, the NTSB issued the following recommendations that would be partially addressed by the proposed rule: 1. Recommendation A- 07 - 6 : Require regional air carriers operating under 14 C FR p art 121 to provide specific guidance on expectations for professional conduct to pilots who operate nonrevenue flights. 2. Recommendation A- 10 - 13 : Issue an advisory circular with guidance on leadership training for upgrading captains operating at 14 CFR part 121, 135, and 91 K operators , including methods and techniques for effective leadership; professional standards of conduct; strategies for briefing and debriefing; reinforcement and correction skills; and other knowledge, skills, and abilities critical for air carrier operations . 3. Recommendation A- 10 - 14 : Require all 14 CFR part 121, 135, and 91 K operators to provide a specific course on leadership training to their upgrading captains that is consistent with the advisory circular requested in Safety Recommendation A- 10 - 13 . 4. Recommendation A- 10 - 15 : D evelop and distribute to all pilots multimedia guidance materials on professionalism in aircraft operations that contain standards of performance for professionalism ; best practices in sterile flight deck adherence ; techniques for assessing and correcting pilot deviations ; examples and scenarios ; and a detailed review of accidents involving breakdowns in sterile flight deck and other procedures , including the Colgan Air flight 3407 accident . Obtain the input of operators and air carrier and general aviation pilot groups in the development and distribution of these guidance materials .

### Pilot	Professional Development	Regulatory	Evaluation 11



## D. Airline	Safety	and	Federal	Aviation	Administration	Extension	Act	of 2010	( Pub lic Law 111 -216) On August 1, 2010, the President signed into law the Airline Safety and Federal Aviation Administration Extension Act of 2010 . 6 

### Section 206 of the law directed the FAA to convene an Aviation R

ulemaking C ommittee (ARC) to develop procedures for each part 121 air carrier to: (1) establish a mentoring program for newly employed flightcrew members; (2) establish a flightcrew member professional development committee made up of air carrier management and labor union or professional as sociation representatives to develop, administer, and oversee formal mentoring programs for flightcrew members; (3) establish or modify training programs to accommodate substantially different levels and types of flight experience by newly employed flightcrew members; (4) establish or modify training programs for SIC flightcrew members who are attempting to upgrade to PIC for the first time in a specific aircraft type and ensure that such programs include leadership and command training; and (5) ensure that recurrent training for pilots in command includes leadership and command training . The law specified that leadership and command training include instruction on compliance with flightcrew member duties under § 121.542 . S ection 206 requires the FAA to issue an NPRM and a final rule based on the ARC recommendations . Section 206 also requires the FAA to establish a streamlined review and expedited approval process for part 121 air carriers that have the programs described above in place as of August 1, 2010, the date this law was enacted . Under the streamlined review process, the FAA must expedite approval of programs that it determines meet the requirements in the final rule .

6 Public Law 111 - 216 .

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The Flight Crewmember Mentoring, Leadership, and Professional Development ARC (MLP ARC) presented its report and recommendations to the FAA on November 2, 2010 . 

## E. FAA Response This proposed rule is the culmination of the FAA’s analysis of (1) the rulemaking requirements of § 206 of Public Law . 111 - 216; (2) the recommendations provided by the MLP ARC , the Flightcrew Member Training Hours Requirement Review ARC (THRR ARC) , and the Air Carrier Safety and Pilot Training ARC ; (3) the part 121 pilot qualification and experience requirements provided in the Pilot Certification rule and Qualification, Service and Use of Crewmembers and Aircraft Dispatchers rule ; and (4) the current part 121 PIC role and responsibilities. The proposed rule applies to part 121 air carriers and part 135 operators required to use pilot training and qualification programs that comply with part 121 subparts N and O . 7 

### The proposed rule contains these new requirements:

 Operations familiarization for new -hire pilots

 Revised ground and flight training for upgrading pilots which includes mentoring, leadership, and command training

 Mentoring, l eadership and command ground training for current PICs

 Mentoring, leadership, and command recurrent training for PICs

 Pilot Professional Development Committee s (PPDC)

7 In addition to part 135 operators conducting commuter operations, if authorized by the Administrator, part 91, subpart K (part 91K) operators and other part 135 operators may voluntarily comply with the training program requirements in subparts N and O of part 121 instead of the training program requirements of part 91K or part 135. Given that part 121 compliance is voluntary for part 91K and part 135 operators (other than those conducting commuter operations) and the number of pilots serving in part 91K and part 135 operations who com plete training under part 121 subparts N and O is not known, this pilot segment is not included in this analysis.

### Pilot	Professional Development	Regulatory	Evaluation 13

The proposed rule also contains some cost saving provisions related to revising the topics covered in recurrent ground training and upgrade ground training . These cost saving revisions are possible (with no impact on the level of safety of part 121 operations) due in part to the increased qualifications for pilots require d by the recent Pilot Certification rule (see Section IV .B.6 ) . The rule has some additional conforming and miscellaneous changes that do not impact either the costs or benefits of the proposed rule (see Sections L, M, and N of the NPRM Preamble) . 

## III. **Assumptions	and	Data	Sources** A. Baseline To inform an understanding of baseline conditions, the following section describes the limited information available to the FAA regarding the type and extent of mentoring, leadership, and command training airlines currently provide. The Airline Transport Pilot Certification Training Program (ATP - CTP) includes foundational knowledge of leadership and professional development. The THRR ARC stated that “Crew Resource Management [CRM] training, required for all air carriers, contains some elements of the desired leadership training, but is not designed to aid the PIC in assuming a leadership role in the aircraft and the air carrier as the training envisioned by this ARC would.” Leadership and command training should occur before CRM training so the PIC can use the leadership skills during the team CRM training. The MLP ARC reviewed training programs and reported that some carriers have leadership and command training, but they did not indicate the scope of that training. Even air

### Pilot	Professional Development	Regulatory	Evaluation 14

carriers who may

have leadership and command training most likely do not include it in the FAA approved training program since it is not required by regulations. The Air Carrier Safety

and Pilot Training (ACSPT) ARC Final Report (07 - 31 - 2012) indicated that 15 carriers voluntarily responded to a survey

regarding implementation of the 24 best practices identified in the first ACSPT Report (07 - 31 - 2011). One of the be st practices was “Implement leadership and command training.” The survey results indicate that between 35 and 100 percent of the best practices have been implemented. However, the survey results do not break down the implementation percentage for each best practice. The information above is the extent of the information that the FAA has about the ty pe and extent of leadership training that pilots currently receive. It is not enough information to determine which air carriers may already have training that would meet the requirement of this proposed rule. Therefore, the regulatory evaluation implicitly

assumes that no air carriers provide any leadership and command training in the absence of the rule. To the extent that some air carriers may

already provide compliant leadership and command training, the baseline level of training may

be higher and the incremental cost of the rule may be lower than what is estimated in the RIA. However, lacking information to estimate the amount of baseline training or the incremental requirements, the RIA conservatively estimates the cost of the rule as being higher than it might actually be compared to a baseline where some leadership and command training is already occurring . The FAA welcomes public comment on how many and which airlines already provide mentoring, leadership, and command training that would comply with the proposed rule. 

## B. Key Elements The key elements used in framing this analys is are as follows :

### Pilot	Professional Development	Regulatory	Evaluation 15  Discount Rates : 8 

### 7% and 3%  Period of Analys is : 201 5 - 202 4  Monetary values expressed in 201 3 dollars  Discounting calculations use 2013 as the base year The FAA analyz ed the expected costs of the proposed regulatory option over a 1 0 - ye ar period . To simplify

the computational analysis, we assumed that the final rule would be issued on January

1, 201 5 . Thus, this analysis covers the years 201 5 through 202 4 . The first year (201 5 ) would involve the operators revising and creating various training curriculums as well as the option for operators to reduce their recurrent ground training programmed hours . During the second year (201 6 ) , the current PICs would receive mentoring, leadership , and command training so that b y the compliance date of January 1, 201 7 , all PICs receive the required training. From 201 7 through the rest of the analys is period, new recurrent training related to mentoring, leadership, and command would be provided; new hire pilots would complete operations familiarization ; any

new upgrading PICs would receive the revised upgrade training curriculum, including training in mentoring, leadership, and command ; and the PPDC meetings would occur. 

## C. Key	Assumptions The key assumptions necessary

to conduct this analysis are as follows:

 Pilot Retirement Rate: 2. 2 %  Pilot Attrition Rate Due To Medical Reasons : 0 . 5 %  Pilot Growth Rate: 0.4%  Ground Instructors Needed: 1 instructor for every 200 pilots  Class Size: 20 pilots per class The pilot retirement rate of 2.2 percent is estimated using data on the age profile of Airline Transpor

t Pilot (ATP) certificate holders from U.S. Civil Airman Statistics. 9 

### This data

8 Office of

M anagement and Budget, OMB Circular No. A -4, New Guidelines for the Conduct of Regulatory Analysis , Mar. 2, 2004.

### Pilot	Professional Development	Regulatory	Evaluation 16

shows that in 2013 , 11 percent of ATP pilots under age 65 are in the age bracket 60 - 6 4 . Assuming that ages are uniformly distributed within that cohort suggests that of all ATP pilots under age 65, 2.2 percent are age 64 and will therefore retire during the following ye ar since the mandatory

retirement age is 65. We assume this estimated retirement rate remains constant over the analys is period. Table A- 20 in Appendix A presents the data and calculations underlying this estimate. This analysis also accounts for attrition of the pilot workforce due to medical reasons . As was done in the analysis of the recent Pilot Certification final rule, the FAA estimates that 0.5 percent of p art 121 pilots retire early for medical reasons. We assume this estimated attrition rate due to medical reasons remains constant over the analysis period. For the purposes of this analysis, the FAA assumes that all retirements come from the PIC ranks and that the attrition due to medical reasons comes equally from both PICs and second in command ( SIC ) pilots . Using the FAA Aerospace Forecasts , for fiscal years 2013 - 2033, 10 

### the FAA estimates that the affected population of pilots would grow at approximately 0.4 percent per year. We assume that this 0.4 percent growth would apply equally to PICs and SICs. The FAA also determined that the vast majority

of new-hire pilots would be hired as SICs and that the vast majority of new PICs are former SICs who have be en upgraded from within the air carrier due to seniority and union agreements. Consequently, to simplify the calculations in this analysis, we assume that 100 percent of new-hire pilots would be SICs and 100 percent of all new PICs would be upgraded

9 FAA U.S. Civil Airman Statistics (2013), Table 12 Estimated Active Pilot Certificates Held by Category and Age Group of Holder. http://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/2013/ 10 FAA Aerospace Forecasts 2013 - 2033. Table 30: Active Pilots by T ype of Certificate, Airline Transport, 2012 - 2033. http://www.faa.gov/about/office_org/headquarters_offices/apl/aviation_forecasts/aerospace_forecasts/2013 - 2033/ Accessed March 2013.

### Pilot	Professional Development	Regulatory	Evaluation 17

SICs. In terms of training, this means for each retirement or loss of medical certificate by a PIC, two pilots need to be trained. An SIC needs upgrade training to fill the slot left by the PIC and a new pilot needs indoctrination training to fill the slot left by the SIC upgrading to PIC. The FAA assumes that on average , one ground instructor is needed to train roughly 200 pilots on an annual basis. Further the FAA assumes that on average, class sizes for ground instruction will be 20 pilots. These assumptions are based on the FAA’s experience and observation of the industry . Taken together, these two assumptions imply that the instructor teaches one class of 20 pilots per month for 10 months of each ye ar. 

## D. Data	Sources and	Methodology **1. Number	of	Pilots	Affected	by**  **the	Proposed	Rule** This proposal affects operators that train and qualify pilots in accordance with part 121 and therefore primarily

affects certificate holders conducting part 121 operations. 11 

### Inaddition, part 135 operators conducting commuter operations in airplanes ty pe certificated for two pilots are also required to train and qualify pilots under subparts N and O of part 121. The data used to estimate the number of affected pilots is presented in Table A- 1 of Appendix A and explained more fully

below. Data for the number of pilots and operators was attained from the National Vital In formation Subsystem (NVI S) database in August of 2014 . There are 66 air carriers that operate exclusively

part 121 operations and 12 air car riers that operate a mix of part 121 and part 135 operations . For these 12 air carriers with a mix of part 121 and part 135 operations, the available pilot data do not distinguish between the numbers of those air carriers’ pilots operating under

11 Operators that train in accordance with part 121 include those training under subparts N and O as well as those using the Advanced Qualification Program (AQP) under subpart Y.

### Pilot	Professional Development	Regulatory	Evaluation 18

part 121 and those operating under part 135. As mentioned above, w e made the simplifying assumption for the purposes of estimating the impacts of the proposed rule that all pilots at those 12 air carriers would be impacted b y the proposed rule. The FAA identified three p art 135 operators who conduct commuter operations in airplanes type - certificated for two pilots. These operators also conduct operations which only require one pilot. However, the available pilot data does not differentiate between the numbers of these operators’ pilots that operate airplanes with two pilots and those that operate airplanes with one pilot. As a matter of simplicity, this analys is assumes that all pilots for these three operators would be affected b y this proposed rule. The FAA determined that the numbers of future new operators required to comply with part 121 , subparts N and O would have a minimal impact on the compliance costs because the FAA anticipates that there will be few new operators required to comply with part 121 , subparts N and O . As a result, we use the current numbers of operators to represent this segment of the aviation industry throughout the 1 0 - ye ar time period of this analysis. This data, and the changes over time described in S ection III.C , result in the following number of pilots affected by the rule over the analysis period: **Table 1**  **: Total Numbers of PICs and SICs Impacted by the Proposed Rule** ***** **Pilot C ategory**  

### Year **An nual Growth** 

**2014 2024**  

### PIC 37,228 38,745 0.4% 

### SIC 39,956 41,583 0.4% 

### TOTAL PILOTS **77,184 80,328**  **0.4%** ***Table values have been rounded. Totals may not add due to rounding.** 


### These estimates represent all pilots impacted by the NPRM, including part 121 air carriers and part 135 operators required to comply with part 121 , subparts N and O. All costs and

### Pilot	Professional Development	Regulatory	Evaluation 19

cost savings calculated for the proposed rule are based on these totals with the exception of the PPDC cost and the upgrading training cost savings , which are described accordingly in Section s V.D and IV.C.2 .



## 2. **Employee	Compensation	Costs** The FAA estimated total compensation costs for the various labor categories that would be involved in complying with the proposed rule . These estimates are provided in Table 2 and their derivation is discussed in the following paragraphs. Tables A - 4 through A- 11 in Appendix A provide supporting details of these calculations. Pilots are paid on a flight-hour basis . Airline Pilot Central wage data is used to estimate the relevant wage rates per flight hour for pilots . 12 

### Additionally, since new- hire p ilots in training receive a monthly

salary, the Airline Pilot Central data was used to estimate the monthly salary of new hire pilots in training as follows: the flight hour pay rate for a first officer with one year of experience multiplied by the monthly guarantee flight hours for reserve pilots . The estimated monthly salary for pilots in training is then divided by 30 days to create an estimated daily training wage rate. These hourly and monthly wages need to be adjusted . BLS data shows that wages are 70.3 percent of total compensation costs while benefits are 29.7 percent. 13 

### Therefore , to derive the total compensation costs based on wages , one must factor wages by 1.42 (70.3 + 29.7 / 70.3). However, in this analysis the pilot wage estimates are used to estimate the costs of a few additional hours o f time from an individual who is already employed. Therefore , some emplo yerprovided benefits are not relevant because the costs of those benefits do not vary with hours 12 Airline Pilot Pay Snapshot, 2012. http://www.airlinepilotcentral.com/files/airlinepilotpaysnapshot2012.pdf 13 Bureau of Labor Statistics News Release. Em ployer Costs for Em

ployee Com

pensation

– September 2013. http://www.bls.gov/ne ws.release/pdf/ecec.pdf

### Pilot	Professional Development	Regulatory	Evaluation 20

worked b y the individual. The FAA has determined that retirement and savings benefits and legally required benefits (Social Security and Medicare, federal and state unemployment insurance and workers compensation) increase with hours worked for pilots while paid leave, supplemental pay, and insurance do not. The categories of benefits that vary with hours worked are on average 11.9 percent of total compensation. Therefore , we factor pilots ’ wages b y 1.169 (70.3 + 11. 9 / 70.3) to account for incremental employer-provided benefits. Being that the Airline Pilot Central wage data is from 201 2, an additional adjustment was necessary to bring wages to the base year of 2013. As shown in Table A- 10 of Appendix A , the FAA took the growth in the BLS mean annual pilot wage from 2012 to 2013 and applied it to the weighted average labor category wages calculated in Table A- 8 of Appendix A . This calculation, as well as the application of the benefits multiplier described above , is shown in Table A- 11 of Appendix A . The resulting total pilot cost per flight hour is shown in Table 2 below. The FAA determined that a senior management person would command an average hourly compensation equal to that of a senior PIC. Ground training instructors have an estimated hourly wage of $ 3 1 , 14 

### which is approximately

$ 44 af ter applying the 1.42 benefits multiplier . The per diem cost allotted for pilot training based on the General Services Administration (GSA) Rate is $1 23 . 15

14 Ground training instructor wage rate based on 2013 BLS data for Air Transportation Industry Training and Development Specialists (13 - 1151). http://www.bls.gov/oes/current/naics4_481100.htm 15 Fiscal Year 2013 Per Diem Rate is $77 for lodging and $46 for meals and incidental expenses for a total of $123. This is the standard continental United States rate. http://www.gsa.gov/portal/content/103168

### Pilot	Professional Development	Regulatory	Evaluation 21 **Table 2**  **: Compensation Rat es for Various Labor Categories**  

### Labor Category **Total Compensation Rates** Ground Training Instructor $ 44 per hour Senior Management Person $ 188 per hour Senior PIC $ 188 per flight hour Average PIC $ 171 per flight hour Senior SIC $ 111 per flight hour Average SIC $ 105 per flight hour New SIC $ 116 per day Per Diem $123 per day 

### Many pilot management agreements specify that a pilot who is required to undertake training is guaranteed a minimum of 4 hours of flight time credit when he or she takes training that is not added onto an existing required training class. However, if the additional training is in the form of an add- on to an existing training class, the pilot is generally given half an hour of flight time for each add- on hour to the existing mandatory training class. This pay structure varies among operators, but the FAA assumes it is the average. The FAA also assumes that senior PICs participating in the PPDC s would receive flight hour credit on a one hour to one hour basis. As a result, the FAA estimates pilot labor costs on a flight hour basis.


## IV. **Benefits** A. Introduction This proposed rule is designed to provide training in those soft skills not currently required in part 121 training programs to ensure pilots adhere to these proper procedures under all flight deck circumstances. 16

16 C rew R esource M anagement (CRM) training, currently required of all pilots training under part 121, includes soft skills and practice related to situational awareness, communication skills, teamwork, task allocation, and decision
making. Although leadership is a factor in effective CRM, PICs need more specific training on how to be a leader. Leadership and command training should occur before CRM training so that the PIC can use the leadership skills

### Pilot	Professional Development	Regulatory	Evaluation 22

The FAA believes that the proposed leadership and command training emphasizing sterile flight deck, training PICs to mentor SICs, and the other professional development provisions of the rule would reduce the risk o f pilots behaving unprofessionally and place the airplane at risk, help ing to avoid future situations such as those present in the accidents described in Section II. B . However , the FAA cannot provide estimates of the quantified safety benefits for the rule. The past accidents that involved inappropriate pilot behavior also involved technical flying mistakes . Unprofessional conduct can compromise a pilot’s ability to exercise the technical knowledge and skills required to safely operate the airplane under varying conditions. Therefore, the FAA cannot distinguish the mistakes due to lack of pilot professionalism from the mistakes due to other reasons. As a result, the FAA cannot quantify the number of potential future accidents that could be prevented b y the proposed rule . However, the qualitative benefits of each of the proposed provisions are discussed in Secti on IV.B below. In addition to safety benefits, the rule also contains cost saving benefits based on changes to ground training. These changes lead to a reduction in the time required to complete recurrent and upgrade trainings and do not compromis e safety . This time reduction and corresponding cost savings are described in Section IV.C below. 

## B. Qualitative	Benefits **1. Operations	Familiarization**  Based on § 206(a)(1)(C) of Pub lic Law 111 - 216 , the FAA asked the MLP ARC to consider and address “Methods to establish or modify training programs to accommodate
during the team CRM training. The THRR ARC also stated that “Crew Resourc e Management training, required for all air carriers, contains some elements of the desired leadership training, but is not designed to aid the PIC in assuming a leadership role in the aircraft and the air carrier as the training envisioned by this ARC wou ld.”

### Pilot	Professional Development	Regulatory	Evaluation 23

substantially

different levels and ty

pes of experience." The MLP ARC recommended amendments to the part 121 training content requirements a nd identified observation flights as providing a valuable introduction for new -hire pilots to an air carrier’s operations and company procedures. Currently, a pilot may serve in part 121 operations without first observing actual operations conducted b y the certificate holder. The MLP ARC recommended "All air carriers should be required to provide one or more observation flights." The operations familiarization provision of the proposed rule would require new-hire pilots to complete a minimum of two operating c ycl es while occupying the flight deck observer seat before serving in part 121 operations . 17 

### Inorder to achieve the operations familiarization goals, the FAA believes that a minimum of two operating cycles are necessary to provide the newly employed pil ot with sufficient exposure to an air carrier’s operations and processes. During each operating cycle, the newly employed pilot may observe different operational events, processes and briefings (e.g., types of departures and arrivals, airports, ramp operations, checklist sequences, varying weather, and navigation methods). Inaddition, two operating cycles may

allow the newly emplo yed pilot to observe two different flight crews, as well as a complete round trip. The MLP ARC explained that, “ [t] hese flights should be used as an integral part of the indoctrination training process helping to reinforce information learned during training and ease the transition to line operations.” Further, the FAA is aware that some air carriers already recognize the benefit of these flights and currently require operations familiarization flights for newly employed pilots.

17 Section 121.431(b) defines operating cycle as “a complete flight segment consisting of a takeoff, climb, enroute portion, descent, and a landing.”

### Pilot	Professional Development	Regulatory	Evaluation 24

The benefit of operations familiarization during or soon after the completion of basic indoctrination training is that newly employed pilots will be provided with an opportunity to observe from the flight deck in a real world environment , the unique characteristics of the air carrier ’s operations and the specialized proce sses learned during basic indoctrination training.



## 2. **PIC Mentoring**  **Training** The FAA proposes to require training on mentoring skills for all PICs serving in part 121 operations to establish the mentoring environment recommended b y the MLP ARC. The proposed mentoring training would include techniques for instilling and reinforcing the highest standards of technical performance, airmanship, and professionalism in all SICs . Although the training would be undertaken b y P IC s, the benefit of the mentoring training would be the enhancement of SIC professionalism which may subsequently aid in the prevention of future accidents like those discussed in Section II.B . Each duty day presents an opportunity for a natural mentoring activity through the pairing of an SIC with a more experienced PIC. The benefit of requiring all PICs serving in part 121 operations to complete mentoring training is that it enables every PIC to capitalize on the opportunity to mentor an SIC during each flight , every duty day . Therefore all current PICs need to receive initial training on the subject. The topic will be included in PIC recurrent ground training at least every

36 months to reinforce the principals of effective mentoring, and the topic will be covered during PIC u pgrade ground training so that new PICs can step into a mentoring role when they

upgrade. 

## 3. **PIC	Leadership	and	Command	Training** The FAA proposes to require training on leadership and command skills for all PICs serving in part 121 operations . The purpose of leadership and command training is to provide

### Pilot	Professional Development	Regulatory	Evaluation 25

PICs with the leadership and command skills necessary to manage the crew (including flight attendants, if applicable), communications , workload , and decision-making in a manner that promotes professionalism and adherence to standard operating procedures and subsequently aid in the prevention of future accidents like those discussed in Section II.B . To ensure that the benefits of leadership and command training accrue to all PICs, all current PICs will receive training on the topic during a one -time training prior to the compliance date of the rule and the topics will be reinforced during recurrent ground training at least every 36 months. In addition , recurrent Line - Oriented Flight Training (LOFT) must provide an opportunity

for PICs to demonstrate leadership and command . Leadership and command training will be included in upgrade ground training and incorporated into upgrade flight training through scenario -based training.



## 4. **Revised	Req uirements	for	Upgrade	Training**  In addition to revising the upgrade training requirements to include mentoring, leadership, and command the FAA proposes a performance -based upgrade curriculum. The proposed rule removes the requirement to include all existing upgrade ground training subjects required b y § 121.419(a) and the § 121.424 requirement to include all appendix E maneuvers and procedures during upgrade flight training. Instead , the proposed rule refocuses upgrade ground and flight training to include subjects, maneuvers, and procedures specific to the duties and responsibilities the pilot will have as PIC. The benefit of the revised upgrade training is that the upgrade training will en sure technical knowledge and skills while focusing on the decisionmaking and leadership skills required of a PIC serving in part 121 operations . The revised upgrade flight training is expected to require the same amount as time as the current training cur riculum (or less), while the revised upgrade ground training is expected to replace two days of

### Pilot	Professional Development	Regulatory	Evaluation 26

training time with one day of training time . The cost savings related to the training time reduction is discussed in Section IV.C.2 while the cost of the replacement training is discussed in Section V.B Additional ly, the benefit of replacing the prescriptive list of subjects, maneuvers and procedures with a performance -based requirement is that each carrier can tailor the upgrade ground and f

l ight training to develop a robust upgrade curriculum specific to their op erations and airplane types . 

## 5. **Pilot	Professional	Development	Committee	(PPDC)** The FAA proposes to require each air carrier to establish and maintain a Pilot Professional Development Committee (PPDC ) to develop, administer, and oversee formal pilot mentoring programs. Given that each carrier will have a mentoring training curriculum, the benefit of the PPDC is that it will design the mentoring program to take into consideration many factors specific to each carrier, including the air carrier’s size and scope of operation (e.g., number of pilots, number of aircraft, number of operations, ty pes of operations, locations of operations), unique organizational culture, and unique hiring and advancement practices. For example, the pilots at a smaller certificate holder with few bases of operation may have more frequent opportunities for “in person” mentoring during the course of a duty day than pilots at a larger certificate holder with numerous bases and pilots. Alternatively, pilots at larg er certificate holders may

utilize technology, such as video conferencing , to create mentoring opportunities. These are just two examples of why the FAA believes the parameters for a formal mentoring program must be designed by the PPDC for each carrier in order to maximize the benefits of the program.

### Pilot	Professional Development	Regulatory	Evaluation 27

The PPDC must consist of at least one management representative and one pilot representative and must meet at least annually . The FAA believes that including the perspective and participation of both the cer tificate holder’s management and its pilots in the development of the mentoring programs at each certificate holder will create additional benefits related to promoting professionalism and subsequently aid in the prevention of future accidents like those discussed in Section II.B .



## 6. **Conforming	and	Miscellaneous	Changes** The proposed rule contains a number of conforming changes to the language of various sections of part 121 to make them consistent with other recent rulemakings (see Sections L, M and N of the NPRM Preamble). These conforming changes are expected to benefit air carriers b y facilitating compliance with part 121 by making the regulations easier to understand . The miscellaneous change to allow air carriers to choose to use pictorial means for training and checking of preflight visual inspections is consistent with current exemption 4416P available to all certificate holders conducting part 121 operations (see Section N of the NPRM Preamble). This change is expected to benefit air carriers b y eliminating the need to request an exemption to use this option. 

## C. Quantitative	Benefits /Cost	Saving	Provisions The proposed rulemaking includes some cost saving provisions related to reductions in upgrade and recurrent training requirements that are possible (with no impact on the level of safety of part 121 operations) due in part to the increased qualifications for pilots required by the recent Pilot Certification rule. Now that the Pilot Certification rule has come into effect, it is possible to reassess the training program requirements together with the overall advancement in air carrier training programs .

### Pilot	Professional Development	Regulatory	Evaluation 28

These recurrent training cost saving provisions apply to all part 121 air carriers and those part 135 operators required to comply with part 121 , subparts N and O. The pilot counts used to calculate these savings are shown in Table A - 2 of Appendix A. These changes will take effect at the effective date of the propos ed rule. The upgrade training cost saving provisions apply to part 121 air carriers only. The number of pilots used to calculate these savings are shown in Table A 3 of Appendix A. These changes would take effect at the compliance date of the proposed rule .



## 1. **Pilot	Recurrent	Training** For pilot recurrent training, § 121.427 specifies the minimum content of recurrent ground training. This regulation also specifies the minimum training hours for the entire recurrent ground training curriculum, but does not spe cify the minimum training time for each subject. Among other required items, this regulation requires recurrent ground training to include instruction in the subjects required for initial ground training in § 121.419. The Pilot Certification rule created new prerequisite training requirements that pilots must now complete before completing initial training at an air carrier. In recognition of these new prerequisite requirements, the Pilot Certification rule revised initial ground training b y removing the g eneric knowledge elements and reduc ing the minimum training hours by 10 hours. However, the Pilot Certification rule did not address the minimum training hours required for recurrent ground training. Since the content of recurrent ground training is based in part on the content in initial ground training, recurrent ground training is being modified as part of this proposed rule to remove the generic knowledge elements. Therefore, the minimum training hours for recurrent ground training for all pilots can now also be reduced. Table 3 shows a summary of the general operational subjects from § 121.419 which are required b y § 121.427 to be included in recurrent ground training . The first column shows the

### Pilot	Professional Development	Regulatory	Evaluation 29

general operational subjects required prior to the Pilot Certification rule and the second column shows the general operational subjects required after the Pilot Certification rule. In general, the revised curriculum shifts the focus from general subjects and procedures (because those are covered as a prerequisite before training at the air carrier) to the procedures specific to the certificate holder (the air carrier emplo ying the pilot). **Table 3**  **: Summary of General Operational Subjects Required During Recurrent Ground Training Prior to and After the Pilot Certification Rule**  

### General operational subjects in § 121.419 prior to **Pilot Certification Rule General operational subje**  **cts in § 121.419 after the Pilot Certification Rule**   The certificate holder's dispatch or flight release procedures;  Principles and methods for determining weight and balance, and runway limitations for takeoff and landing;  Enough meteorology to insure a p ractical knowledge of weather phenomena, including the principles of frontal systems, icing, fog, thunderstorms, and high altitude weather situations;  Air traffic control systems, procedures, and phraseology;  Navigation and the use of navigation aids, incl uding instrument approach procedures;  Normal and emergency communication procedures;  Visual cues prior to and during descent below DA/DH or MDA;  C rew resource management training; and  Other instructions as necessary to ensure pilot competence.  The certificate holder’s dispatch or flight release procedures;  The certificate holder’s method for determining weight and balance and runway limitations for takeoff and landing;  Meteorology hazards applicable to the certificate holder's areas of operation;  T he certificate holder’s approved departure, arrival, and approach procedures;  The certificate holder’s normal and emergency communication procedures; and  The certificate holder’s crew resource management training .



### The regulation specifies the minimum training hours for the entire recurrent ground training curriculum, but does not specify the minimum training time for each subject. The time spent on each subject varies based on an air carrier’s operations due to differences such as,

### Pilot	Professional Development	Regulatory	Evaluation 30

airplane types and c omplexities, kinds and ty pes of operations, special operations, navigation methods and systems, and flight deck instrumentation . Therefore it is difficult to estimate the exact amount of training time reduction that will result from the revised curriculum. However, b ased on its experience of approving and surveilling training curriculums and after comparing the general operational subjects required during recurrent ground training prior to and after the Pilot Certification rule , the Agency believe s a one hour reduction in the minimum required training hours for recurrent ground training for recurrent PIC and SIC ground training based on removing the generic knowledge elements is appropriate . This reduction in training times can take place immediately, on the effective date of the proposed rule. The one hour reduction per year in pilot recurrent ground training results in a cost savings for air carriers related to ground instructor time and pilot time. The ground instructor cost saving was calculated b y multiplying the cost per hour for ground instructors ($44 per hour) by the number of classes needed for all recurrent ground training and the one hour reduction in time required. The number of classes needed is estimated b ased on a class size of 20 pilots per c lass . As an example of this calculation, in 2015 an estimated 37, 714 SICs will complete recurrent ground training and as a result approximately 1,8 86 classes (37, 714 / 20) will need 1 hour less of ground instructor time. The cost savings related to ground instructors for SIC recurrent training is then approximately $8 3 ,000 in 2015 (1,8 86 classes x 1 hour x $44 per hour)
. As explained in Section III.D.2 , the cost of one hour of pilot time spent in training is estimated to be one -half the pilot flight hour cost, based on industry practice related to pay

for training. The cost savings related to one hour less spent in training for PIC s and SIC s is calculated b y multiplying one half the cost per flight hour for PICs and SICS by the number of PICs and SICs respectively and the one hour reduction in training time required. The calculation

### Pilot	Professional Development	Regulatory	Evaluation 31

is performed separately for SICs and PICs . For example, in 2015, an estimated 37, 714 SICs will complete recurrent ground training. That total, and the cost per flight hour of $105 was multiplied by

one -half times one hour training time to arrive at the estimated the value of cost savings related to recurrent training for SICs of $ 1 . 9 80 million for 2015 (37, 714 x 1⁄2 x $105 per flight hour x 1 hour) . The full calculations are shown in Table s A- 17 and A - 18 and summarized in Table 4 below. **Table 4**  **: Cost Saving Provisions Related to Modified Pilot Recurrent Ground Training (2015 -**  **2024)** *****



### Cost **Savings Total Cost**  **Savings (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  SIC Recurrent Ground Training (Table A
- 17) $21.005 $13.757 $17.379 PIC Recurrent Ground Training (Table A
- 18) $31.554 $20.667 $26.107

**Total $52.559**  **$34.424 $43.486**  ***Table values have been rounded. Totals may**  **not add due to rounding.** 

## 2. **Upgrade	Training** With the Pilot Certification rule, the FAA elevated the qualifications of all SICs: all part 121 SICs must now hold an Airline Transport Pilot (ATP) certificate and ty pe rating for the airplane in which they

are serving. Additionally, a pilot must have a minimum of 1,000 hours of air carrier experience to serve as a PIC. This means that when they begin upgrade training , SICs will have already demonstrated technical mastery of the airplane at the ATP certificate level. Therefore, the FAA is proposing to replace the current upgrade ground training requirements under § 121.419 with the revised upgrade ground training requirements in proposed § 121.420. Table 5 shows a summary of the upgrade ground training subjects. The first column shows the subjects currently required b y § 121.419 and the second column shows the subjects proposed in new § 121.420 that would replace those in § 121.419 for upgrade ground training

### Pilot	Professional Development	Regulatory	Evaluation 32

after the compliance date of the proposed rule . 18 

### The proposed curriculum would ensure technical knowledge and skills while focusing on the decision-making and leadership skills required of a PIC. Consequently, the first and second bullets in the second column (seat dependent procedures and duty position proced

ures) would include any subjects from the first column involving procedures that change when the pilot upgrades from SIC to PIC. In part those changes relate to different duties and responsibilities that a pilot will have as the PIC rather than the SIC. Although PICs and SICs are currently required to receive ground training in the same subjects, the sub
- elements for each subject may not be the same due to different duties and responsibilities for PICs and SICs. Another source of change is that PIC sits in a different seat than the SIC and some aircraft have different procedures for the pilot in each seat. The requirement for training in crew resource management is present in the both the current curriculum and the proposed curriculum. In addition, this prop osed rulemaking includes requirements of mentoring, leadership, and command .

18 The tasks listed in § 121.419 would remain in place for initial and transition training.

### Pilot	Professional Development	Regulatory	Evaluation 33

**Table 5**  **: Summary of Upgrade Ground Training**  **Subjects in Current § 121.419 and in Proposed § 121.420** 

### Current subjects **for upgrade ground training ( in §**  **121. 419**  **) Proposed subjects**  **for upgrade ground training (**  **in § 121.420*** **)** General operational subjects  The certificate holder's dispatch or flight release procedures;  Principles and methods for determining weight and balance, and runway limitations for takeoff and landing;  M eteorology;  A ir traffic control systems, procedures, and phraseology;  Navigation, including instrument approach procedures;  Normal and emergency communication procedures;  Visual cues prior to and during descent below DA/DH or MDA;  C rew resour ce management ; and  Other instructions as necessary to ensure pilot competence. For each airplane type —  A general description;  Performance characteristics;  Engines and propellers;  Major components;  Major airplane systems ;  Procedures for recognizing, avoiding, and escaping from severe weather situations;  Procedures for operating in or near potentially hazardous meteorological conditions;  Operating limitations;  Fuel consumption and cruise control;  Flight planning;  Each normal and emergency procedure;  Stall prevention and recovery;  Upset prevention and recovery; and  The approved Airplane Flight Manual.  Seat dependent procedures;  Duty position procedures;  Leadership and command;  Crew resource management; and  Mentoring.

*Column includes both general operational and airplane type specific subjects , as applicable .

### Pilot	Professional Development	Regulatory	Evaluation 34

The revised upgrade ground training subjects result in a net reduction in required content. Accordingly, the agency expects that less time will be needed for upgrade ground training and will result in a corresponding cost savings to air carriers. The regulation does not specify minimum training time s for upgrade ground training. When seeking FAA approval of a training curriculum, § 121.403 requires the curriculum to specify the training time for each phase of training (ground training, flight training, indoctrination), not each subject. The time spent on each subject varies based on an air carrier’s operations due to differences such as, airplane typ es and complexities, kinds and ty pes of operations, special operations, navigation methods and systems, and flight deck instrumentation. Therefore the time saved based on revisions to upgrade ground training subjects will also vary by carrier. As such, it is difficult to estimate the exact amount o f training time reduction that will result from the revised curriculum. However, b ased on FAA experience of approving and surveilling upgrade training curriculums , the FAA estimates that on average the replacement of the current upgrade ground training sub jects in § 121.419 with three subjects of seat dependent procedures, duty position procedures, and crew resource management would result in reducing upgrade ground training by two training days. The additional costs from adding mentoring, leadership, and command subjects to the upgrade ground training curriculum are discussed separately in Section V.B . The proposed rule also makes substantial changes to the upgrade flight training requirements. The proposed rule removes the requirement to complete the prescriptive list of approximately

60 tasks in part 121, Appendix E. Instead, the proposed rule includes performance based requirements that will ensure that pilots have attained the knowledge and skills to

### Pilot	Professional Development	Regulatory	Evaluation 35

proficiently operate the airplane as a PIC, including the visual and ps ychomotor acuity necessary to operate the airplane from the seat position occupied by the PIC. Table 6 shows a summary of the upgrade flight training tasks. The left column shows the tasks currently required by § 121.424 and the right column shows the tasks proposed in new §121.426. **Table 6**  **: Summary of Upgrade Flight Training Tasks in Curr ent § 121.424 and in Proposed § 121.426**  

### Current tasks in § 121.424 **Proposed tasks in § 121.426**  Low - altitude windshear;  Manually controlled slow flight;  Manually controlled loss of reliable airspeed;  Manually controlled instrument departure and arrival;  Upset recovery maneuvers;  Recovery from bounced landing;  R ecovery from full stall and stick pusher activation ; and  Approximately 60 tasks listed in part 121 Appendix E  Low altitude windshear;  Manually controlled slow flight;  Manually controlled loss of reliable airspeed;  Manually controlled instrument departure and arrival;  Upset recovery maneuvers;  Recovery from bounced landing;  R ecovery from full stall and stick pusher activation ;  Seat dependent maneuvers and procedures;  Duty position maneuvers an d procedures;  Scenario based training incorporating CRM and leadership and command skills * ; and  Sufficient training to ensure the pilot’s knowledge and skill with respect to the airplane, the Airplane Flight Manual, the certificate holder’s operations man ual and check lists and ATC procedures. * This task can be completed concurrently with other tasks. 

### At first glance it may

appear that the new list of proposed tasks is longer than what is currently required. However note that the first seven bullets in e ach column are the same. The eighth ( and last) bullet of the current tasks list reads "Approximately 60 tasks listed in part 121 Appendix E". The list of proposed tasks in the right column does not specifically require those 60 tasks. In stead, the carrier must identify the tasks necessary

to meet the requirements in eighth,

### Pilot	Professional Development	Regulatory	Evaluation 36

ninth, and eleventh bullets . The FAA believes that the proposed scenario -based training incorporating CRM and leadership and command skills in the tenth bullet can be covered simultaneously

while performing other tasks. Therefore the FAA does not expect the time required to complete upgrade flight training to exceed the amount of time an air carrier currently uses for upgrade flight training. Therefore the Agency estimates no cost increases or decreases associated with revised upgrade flight training. In summary, the revision of the current topics for upgrade ground training are expected to result in a cost savings to carriers related to two fewer days of training for up grading pilots. The additional costs of the mentoring, leaderships, and command topics for upgrade ground training are discussed in Section V.B . The FAA expects that the new upgrade flight training curriculum can be accomplished in the same amount of time as the current upgrade flight training curriculum so there are expected to be no cost increases or decreases associated with revised upgrade flight training. The proposed revision to upgrade ground training will result in cost savings for air carriers related to ground instructor time, pilot time, and per diem travel expenses of pilots traveling to receive upgrade ground training. Per diem expenses are included bec ause it is the FAA’s understanding that most upgrade training occurs at a central location and would require travel for most upgrading pilots. The costs of developing the revised upgrade training curriculum are discussed in Section V. The estimated costs savings related to two fewer days of upgrade ground training is calculated as follows . First, the number of upgrading SICs each ye ar is multiplied by the cost of 16 hours of senior SIC training time (since it is senior SICs as opposed to average or junior SICs

### Pilot	Professional Development	Regulatory	Evaluation 37

who would be upgrading). As explained above in Section III.D.2 , the cost of one hour of pilot training time is estimated to be the cost of one half -hour of pilot flight time. Therefore, the cost associated with 16 hours of training time is the cost of 8 hours of flight time for senior SICS ($111 per hour). When carriers are required to be in compliance with the proposed rule in 2017, there will be an estimated 2, 05 1 upgrading pilots. The cost savings for pilot time is estimated to be $1. 821 million in 2017 (2, 05 1 upgrading pilots x 16 training hours x 1⁄2 x $111 cost per flight hour). Second, the cost savings related to two days of per diem for upgrading pilots is estimated as $123 per day

multiplied by

the number of upgrading pilots each ye ar. In 2017, the per diem costs are estimated to be $0.5 05 million (2,0 5 1 upgrading pilots x 2 days x $123 per day). Finally, the estimated cost savings of the ground instructor time is estimated by dividing the number of upgrading pilots each ye ar b y 20 (the estimated class size) and then multiplying by 16 hours of training time and the hourly ground instructor cost ($44 per hour). In 2017, the cost savings associated with ground instructor time for the estimated 2,0 5 1 upgrading pilots is expected to be $0.07 2 million (2,0 5 1 upgrading pilots x 1/20 x 16 hours training time x $44 per hour). The full calculations for each year of the analysis period are shown in Table A- 19 in Appendix A and the total and present value compliance savings are summarized in Table 7 below.

### Pilot	Professional Development	Regulatory	Evaluation 38 **Table 7**  **: Cost Savings from Modified Upgrade Training (2015 -**  **2024)** *****


### Cost **Savings Total Cost Savings**  **(Millions of 2013 Dollars)**

**Present Value Total**  **7 Percent 3 Percent**  Upgrade Ground Training (Table A
- 19) $19.458 $11.839 $15.615 Upgrade Flight Training $0.000 $0.000 $0.000

**Total $19.458**  **$11.839 $15.615**  ***Table values have been rounded. Totals may not add due to rounding.** 



## 3. **Total	of	Cost Saving**  **Provisions** The total and present value of the cost saving provisions related to pilot recurrent training and upgrade training is presented in Table 8 below. **Table 8**  **: Total and Present Values of Cost Sa vings (2015**  **- 2024)**  *****


### Cost **Savings Total**  **Cost Savings (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  Recurrent Training (Tables A
- 17, A- 18) $52.559 $34.424 $43.486 Upgrade Training (Table A
- 19) $19.458 $11.839 $15.615

**Total $72.017**  **$46.263 $59.101**  ***Table values have been rounded. Totals may not add due to rounding.**  

## D. Conclusion The FAA believes that the proposed rule would generate safety benefits . It would also address NTSB recommendations regarding pilot professionalism and leadership and the statutory requirement for rulemaking in Public Law 111 - 216 . Additionally, the FAA believes the proposed rule would generate cost saving benefits to operators of $ 7 2 million over a 10 - ye ar period. When discounted using a 7 percent discount rate, the proposed rule would result in cost savings of $4 6 million over a 10 - ye ar period.

### Pilot	Professional Development	Regulatory	Evaluation 39



## V. **Costs** The FAA estimates the potential compliance costs with its proposed rule by dividing the proposal into four areas. These areas consist of Operations Familiarization (Section V.A); Revised Upgrade Training (Section V.B ); PIC Mentoring, Leadership, and Command (SectionV . C ); and PPDC (Section V . D ) . This proposed rule would impose two ty pes of compliance costs: (1) start-up costs to develop training curriculums and train the current pilot work force prior to the compliance date ; and (2) recurring costs to conduct the training each ye ar as the pilot work force evolves over time and to operate the PPDC . 

## A. Operations	Familiarization The proposed r

ule would require an operator to have each new-hire pilot training and qualifying under part 121 to observe two operating cycles . For the purposes of this analysis the FAA assumes all new-hire pilots will be first- ye ar SICs. These SICs would observe regularly scheduled flights from the flight deck observer seat with no additional operations cost to the operator . The FAA assumes that one training day will be sufficient for the new hire to observe two operating cycles since a round trip flight ( consisting of two operating cycles ) can easily be accommodated in one day . If the operator does not have sufficient airplanes with flight deck observer seats, the FAA assumes that an alternative authorized in accordance with the proposed deviation authority will als o consist of one training day. The FAA also assumes that the new-hire pilots would receive a per diem for that day because it would likely occur during on- site training . The FAA therefore estimates the cost of the provision to be the cost of one training day and one day of per diem for each new-hire pilot each year . There are no estimated start-up costs. The FAA did not estimate any cost for increased fuel burn due to the weight of the additional passenger on the flights .

### Pilot	Professional Development	Regulatory	Evaluation 40

The FAA estimated the cost of pil ot time related to this provision by multiplying the total the number of newly

hired SICs each year b y the daily compensation cost of new SICs ($116 per day) . In 2017, there will be an estimated 2, 420 new-hire SICs . Multiplying 2, 420 new hire SICs by the $116 daily

cost results in an estimated cost of $0. 28 1 million for 2017. The estimated cost of additional per diem pay ments is calculated by

multiplying the number of newly hired SICs each ye ar b y one day

of per diem ($123 per day). This calculation results in an estimate of $0. 298 million in additional per diem costs due to this provision for 2017. The full calculations for the entire analys is period are shown in Table A - 12 of Appendix A and the total and present value compliance costs are summarized in Table 9 below. **Table 9**  **: Start -**  **Up and Annual Compliance Costs for Familiarization Flights for New -**  **Hire Pilots**  **(20 17**  **- 202**  **4 )**  *****



### Cost **Total Compliance Costs (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  New - Hire Pilot Operations Familiarization (Table A
- 12) $4.693 $2.855 $3.766 **Total $4.693**  **$2.855 $3.766**  ***Table values have been rounded. Totals may not**  **add due to rounding.** 

## B. Revised	Training for	SICs	Upgrading	to	PICs The proposed rule would require part 121 air carriers to modify their training curriculum for senior SICs upgrading to PICs (“upgrade training”) to include mentoring, leadership , and command, seat dependent procedures , duty position procedure s, and crew resource management . 19 

### The proposed rule would also require part 135 operators conducting commuter operations in airplanes type certificated for two pilots to add mentoring, leadership, and command topics to their upgrade training curriculum. The changes would affect both upgrade ground training and upgrade flight training.

19 The revised upgrade training curriculum also removes certain training requirements for part 121 air carriers. This is discussed as a cost saving provision in Section IV.C.2

### Pilot	Professional Development	Regulatory	Evaluation 41

Based on the FAA’s experience and observation of the industry, the FAA estimates it would take one ground instr uctor at each air carrier roughly two weeks or 80 hours to modify the curriculum to include the revised list of subjects . The estimated one -time cost to modify the curriculum is 8 0 hours times the ground instructor hourly compensation cost ($44 per hour) multiplied by

the number of air carriers affected by this provision of the proposed rule (81 carriers ) . The total estimated cost to revised the ground training curriculum is approximately $285,000 ( 81 x 80 hours x $44 per hour). The proposed rule does not place restrictions on distance instruction as long as the training objectives can be satisfied. However it is the FAA ’s understanding that most upgrade ground training does occur in a classroom setting. Therefore , the FAA estimate s the one -time cost to train all ground instructors on the new upgrade training curriculum. The FAA estimates that ground instructors would need one day or eight hours to learn the updated curriculum. As explained in Section III.C , the FAA assumes that one ground instructor is required for every 200 pilots in the workforce . The one time ground instructor training cost is then estimated to be eight hours times the ground instructor hourly comp ensation cost ($44 per hour) multiplied by the total number pilots in the workforce divided by 200 (77,493/200 is approximately equal to 387 ground instructors) . The total estimated cost of training ground instructors is approximately $136,000 ( 8 hours x $ 44 per hour x 387 instructors ). There is assumed to be no additional cost for the training of flight instructors because part 121 Appendix H already requires that flight instructors receive a minimum of four hours of training annually

to become familiar with changes to the training curriculum . One aspect of the revised curriculum for upgrading pilots is expected to result in reduced training time while another aspect is expected in increase training time. As explained in Section

### Pilot	Professional Development	Regulatory	Evaluation 42

IV .C.2 , the FAA estimates that replacing the current subjects required for upgrade ground training (listed in § 121.419 ) with the three subjects of seat dependent procedures, duty position procedures, and crew resource management would result in reducing upgrade ground training b y two training days and is therefore a cost saving provision of the proposed rule. The addition of mentoring, leadership, and command to the upgrade ground training will result in additional costs related to pilot time spent in that ground training. The proposed rule does not specify a certain number of hours for the new upgrade ground training curriculum . However, b ased on FAA experience of approving and surveilling upgrade training curriculums , the FAA estimates it would take one additional training day to complete. Since it is the FAA’s understanding that upgrade ground training generally occurs in a classroom setting (which would likely be away from the pilot’s home) upgrading p ilots would be entitled to one additional day of per diem. As previously

discussed, many

pilot management agreements specify that a pilot who is required to undertake training is generally given half an hour of flight time for each add- on hour to the existing mandatory

training class . The FAA therefore estimates the additional cost of the revised upgrade ground training for both part 121 air carriers and part 135 operators conducting commuter operations in airplanes ty pe certificated for two pilots is the cost of eight senior SIC training hours (equal to the cost of four flight hours for senior SICs) and one day of per diem for each SIC upgrading to PIC each ye ar and the cost of 8 hours of ground instructor training time for each class of 20 SICs upgrading to PIC . When carriers are required to be in compliance with the proposed rule in 2017, an estimated 2, 057 SICs will be upgrading to PIC . The cost of four senior SIC flight hours at $111 per flight hour results in an upgrading trainee cost of approximately $9 13 ,000 (2, 057 x $111 per flight hour x 4 flight hours ). The per diem rate of $123 for one day results in a 2017 per diem

### Pilot	Professional Development	Regulatory	Evaluation 43

cost of $2 53 ,000 (2, 057 x $1 23 per day x 1 day). The 2, 057 SICs upgrading to PIC will involve approximately

10 3 classes assuming a class size of 20 pilots (2, 057/20). The total cost of ground instructor time for teaching those classes in 2017 is then $3 6 ,000 (10 3 clas s es x $44 per hour x 8 hours). The total 2017 cost is approximately $1,2 03 ,000 ($9 13 ,000 + $2 53 ,000 + $3 6 ,000) . The FAA estimates that the revised upgrade flight training requirements would be woven into the existing requirements with no additional time required to complete the upgrade flight training portion the curriculum. The calculations discussed above are shown fully in Tables A- 13 and A- 14 of Appendix A and the total and present value compliance costs are summarized in Table 10 below. **Table 10**  **: Start -**  **Up and Annual Compliance Costs for Upgrade Training Curriculum Requirements (201 5**  **- 202**  **4 )**  ***** 

### Cost **Total Compliance Costs (Millions of 2013 Dollars)** 

**Present Value**  **Total 7 Percent**  **3 Percent** Modify Upgrade Flight and Ground Training Curriculum (Table A
- 13) $0.285 $0.249 $0.269 Train Ground Instructors (Table A
- 13) $0.136 $0.119 $0.128 Train Flight Instructors $0.000 $0.000 $0.000 Train Upgrading Pilots (Table A
- 14) $9.756 $5.936 $7.830 **Total** 

### $10.178 **$6.304 $8.227**  ***Table values have been rounded. Totals may not add due to rounding.**  

## C. Mentoring,	Leadership,	and	Command for PICs The proposed rule calls for new training in the area of mentoring along with leadership and command for PICs . As a practical matter, since both training requirements apply to the same group of pilots and have the same compliance dates, the FAA believes that the subject matter for both topics will be combined into one curriculum and training session . Therefore , the FAA does not estimate costs separately for those provisions. The proposed rule would require operators to create a one -time ground training curriculum for current PICs and modify its recurrent PIC ground training curriculum . The FAA

### Pilot	Professional Development	Regulatory	Evaluation 44

estimates it would take one ground instructor at each air carrier roughly one week or 40 hours to create and modify

these curricula. The one -time cost of curriculum development is estimated to be 40 times the hourly

compensation cost of a ground instructor ($44 per hour) multiplied by the number of air carriers affected b y the provision , resulting in a total cost of approximately $143,000 (40 hours x $44 per hour x 81 operators ). The proposed rule does not place restrictions on distance instruction as long as the training objectives can be satisfied. The agency believes that the MLP ARC recommendation for a facilitated discussion during leadership and command training can be accomplished either inperson or with existing technology . There fore , the cost estimation assumes that ground instructors would be involved in the training but that no per diem expenses for pilots would be incurred by carriers. Because the mentoring, leadership, and command curricula for PICs will be consistent with the mentoring, leadership, and command curriculum developed for upgrading pilots, the FAA estimates that no additional training of ground instructors will be necessary . The proposed rule also requires that leadership and command be included in recurrent LOF T for PICs. However, there is no estimated cost for the training of flight instructors because , as noted previously, part 121 Appendix H already requires that flight instructors receive a minimum of four hours of training annually to become familiar with changes to the training curriculum. The proposed rule does not prescribe a cer tain number of hours for the one -time training of current PICs in mentoring, leadership, and command. However, as previously discussed in Section III.D.2 , many pilot management agreements specify that a pilot who is required to undertake training is guaranteed a minimum of four hours of flight time credit when he or she

### Pilot	Professional Development	Regulatory	Evaluation 45

takes training that is not added onto an existing required training class . Since the one -time mentoring, leadership, and command training will be a new training class, the FAA estimates that the one -time cost will be the cost of four flight hours for each current PIC . Because the training will be taken b y all current PICs, the FAA used the flight hour cost for average PIC s to estimate this one -time cost. This one -time cost is estimated to be four times the average PIC flight hour cost ($171) times the estimated number o f PICs in 2016 (37,527) which is equal to approximately

$25.7 million (37,527 x 4 hours x $171)
. Assuming a class size of 20, the 37,527 PICs requiring the training will result in 1 , 876 classes. Each class will require 8 hours of ground instructor time whi ch is valued at $44 per hour. The estimated cost of the ground instructor time for the mentoring, leadership, and command training for all current PICs is then approximately $0.66 million (1,876 x 8 hours x $44 per hour). Similarly, the proposed rule doe s not prescribe a certain number of hours for the recurrent training of PICs in mentoring, leadership, and command. However, b ased on FAA experience of approving and surveilling recurrent training curriculums the FAA estimates that the recurrent ground training on mentoring, leadership, and command requirements would take an average of three hours total. This training is required b y the proposal to be provided every three years. Therefore, f

or the purposes of this anal ys is, the FAA assesses this cost as one training hour per ye ar. The cost of the recurrent mentoring, leadership, and command training for PICs is estimated to be 0.5 flight hours times the average PIC flight hour cost ($171 per flight hour) times the number PICs taking recurrent training each year . For 2017 (the first year operators are expected to be in compliance) there are estimated to be 35, 620 PICs. The total cost of the new recurrent PIC training in mentoring, leadership and command is estimated to be $3.0 million in 2017 ( 35, 620 x 0.5 fli ght hours x $171 per flight hour). Assuming a class size of 20, the 35, 620

### Pilot	Professional Development	Regulatory	Evaluation 46

PICs in 2017 would require 1,7 81 classes, each requiring 1 hour of ground instructor time with an hourly ground instructor cost of $44 per hour
. In 2017, the ground instructor cost for this requirement is estimated to be $78,000 ( 1,7 81 x 1 hour x $44 per hour). The requirement for air carriers to include in recurrent LOFT, an opportunity for PICs to demonstrate leadership and command, may be incorporated into the LOFT scenario without adding additional time to the scenario The calculations discussed above are shown fully in Tables A- 13 , A - 15 , and A- 22 of Appendix A and the total and present value compliance costs are summarized in Table 11 below. **Table 11**  **: Compliance Costs for**  **PIC Mentoring, Leadership, and Command Requirements (201**  **5 -**  **202 4**  **)** *****



### Cost **Total Compliance Costs (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent**  **3 Percent** Create Curriculum for One
-Time Training of Current PICs and Recurrent Training of PICs (Table A
- 13) $0.143 $0.125 $0.134 Train Ground Instructors A A A Train Flight Instructors $0.000 $0.000 $0.000 Train Current PICs (Table A
- 22) $26.329 $21.492 $24.095 Recurrent PIC Training (Table A
- 15) $25.344 $15.420 $20.339

**Total** 

### $51.815 **$37.037 $44.568**  A : Costs to train ground instructors accounted for in upgrade training costs ***Table values have been rounded. Totals may not add due to**  **rounding.** 

## D. Pilot	Professional	Development	Committee	(PPDC) The proposed rule would require part 121 air carriers to establish and maintain a PPDC. This committee must consist of at least one management representative who satisfies certain qualification req

uirements and one pilot representative. The agency assumes that these representatives would be in a position of seniority with the operator (e.g., a senior management official or a senior PIC). The proposed rule requires the PPDC to meet at least annually . M eeting once a ye ar for half a day (four hours) would likely be a practical minimum requirement of

### Pilot	Professional Development	Regulatory	Evaluation 47

complying with the proposed rule. Air c arriers may opt to have the PPDC meet more frequently or for longer duration to maximize the effectiveness of the PPD C. The estimated cost of each PPDC meeting is the cost of four hours for the senior management representative and four flight hours for the senior PIC. The FAA believes that the PPDC members are likely to be based in the same location, and therefore would not require per diem. The FAA does not anticipate there to be any start-up costs to create the PPDC. This requirement applies only to the 78 air carriers that operate under part 121 or have a mix of operations under part 121 and part 135. It does not apply to those additional part 135 operators that are required comply with part 121 , subparts N and O because the PPDC is not a subpart N or O requirement . Therefore , the cost of this provision is estimated to be four times the estimated hourly

compensation cost for a senior management representative ($188 per hour) plus four times the estimated flight hour cost of a senior PIC ($188 per hour) times 78 carriers times one meeting per ye ar . Thus the estimated cost per year of the PPDC is of $117,000 ( [ 4 hours x $188 for a senior management representative + 4 hours x $188 for a senior PIC ] x 78 operators x 1 meeting per ye ar) . The full calculations are shown in Table A- 16 of Appendix A and the total and present value compliance costs are summarized in Table 12 below. **Table 12**  **: Compliance Costs for the PPDC Meetings (201**  **7 -**  **202 4**  **)** 

### Cost **Total Compliance Costs (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  PPDC Meeting (Table A
- 16) $0.938 $0.572 $0.754

**Total** 

### $0.938 **$0.572 $0.754**  ***Table values have been rounded. Totals may not add due to rounding.** 

### Pilot	Professional Development	Regulatory	Evaluation 48



## E. Recordkeeping	and	Additional	Curriculum	Development	Costs These proposed amendments to part 121 result in some additional paperwork costs related to curriculum development and approval and recordkeeping. These additional costs are explained in the Paperwork Reduction Act section of the Preamble to the proposed rule. The additional costs are estimated in Table A - 21 of Appendix A and are summarized in Table 13 , below. **Table 13**  **: Recordkeep**  **ing and Additional Curriculum Development Costs (2015**  **- 2024)**  *****


### Cost **Total Compliance Costs (2013 Dollars)**  **Present Value Total**  **7**

**Percent 3** 

**Percent** Recordkeeping and Additional Curriculum Development Costs (Table A
- 21) $7,303 $5,523 $6,434 **Total** 

### $7,303 **$5,523 $6,434**  ***Table values have been rounded. Totals may not add due to rounding.**  

## F. Conforming and	Miscellaneous Changes As discussed in Section I.A, the proposed rule contains a number of conforming and miscellaneous changes which the FAA believes will impose no new costs on carriers. 

## G. Total	Compliance	Costs The total compliance costs for the proposed rule, including the costs of Operations Familiarization (Section V.A) , Revised Upgrade Training (Section V.B ), PIC Mentoring, Leadership, and Command (Section V . C ) , and the PPDC (Section V . D ) , are presented in Table 14 below. The proposed rule results in costs of $ 6 8 million over the 10 - ye ar analys is period. When discounted using a seven percent discount rate, the present value of the costs is $ 4 7 million.

### Pilot	Professional Development	Regulatory	Evaluation 49 **Table 14**  **: Compliance Cost**  **by Proposed Provision**  **(201 5**  **- 202**  **4 )**  ***** 

### Cost **Total Compliance Costs (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent 3 Percent**  New - Hire Pilot Operations Familiarization ( Table 9 ) $4.693 $2.855 $3.766 Upgrade Training ( Table 10 ) $10.178 $6.304 $8.227 One -Time and Recurrent PIC Training ( Table 11 ) $51.815 $37.037 $44.568 PPDC Meeting ( Table 12 ) $0.938 $0.572 $0.754 Recordkeeping ( Table 13 ) $0.007 $0.006 $0.006

**TOTAL $67.632**  **$46.774 $57.321**  ***Table values have been rounded. Totals may not add due to rounding.**  

## VI. **Discussion	of	Alternatives** The FAA considered one alternative to the proposed rulemaking : a proposal representing the MLP ARC recommendations as presented to the FAA . A discussion of the MLP ARC proposed provisions and the corresponding costs associated with them can be found in Appendix B . A summary of the estimated costs of incorporating the MLP ARC recommendations into title 14 of the Code of Federal Regulations is presented in Table 15 below .

### Pilot	Professional Development	Regulatory	Evaluation 50 **Table 15**  **: Estimated Costs of MLP ARC Recommendations (2015**  **– 2024)**  ***** 

### Proposed Provision **Total Costs (Millions of 2013 Dollars)** 

**Present Value Total**  **7 Percent**  **3 Percent** Create a Professional Development Position (Table B
- 3) $166.140 $109.056 $137.593 Create a PDSC Program (Table B
- 4) $0.704 $0.615 $0.663 Mentor Training for All PICs (Table B
- 5) $37.084 $27.899 $32.651 Hold Quarterly PDSC Meetings (Table B
- 6) $12.670 $8.011 $10.332 Additional Indoctrination Training for New
- Hire Pilots (Table B
- 7) $0.656 $0.399 $0.526 1 or More Familiarization Flights for New
- Hire Pilots ** (Table B
- 8) $4.693 $2.855 $3.766 32 Hours of Training for SICs Upgrading to PIC (Table B
- 9) $39.026 $23.745 $31.318 Recurrent PIC Training (Table B
- 10) $238.295 $144.987 $191.233 **TOTAL $499.267**  **$317.567 $408.083**  ***Table values have been rounded. Totals may not add due to rounding.** 

***** ***FAA estimate is for 2 operating cycles**  **.** 

### The cost of the MLP ARC recommendations is substantially greater than the cost of the proposed rule. The main drivers of the cost differences between the MLP ARC recommendations and the proposed rule are the full -time professional development position and the additional amount of time required for leadership and command training during upgrade training and during PIC recurrent training . The FAA carefully considered the MLP ARC recommendations when developing the proposed rule and many of the recommendations are incorporated into the proposed rule albeit with less prescriptive requirements . Specifically, the MLP ARC recommended that the committee to oversee pilot professional development meet quarterly ; the NPRM specifies only that it should meet at least once per ye ar. Further, the MLP ARC recommended a 32 -hour program in leadership and command for upgrading pilots. The proposed rule requires leadership and command training for upgrading pilots but does not specify a minimum number of hours for that training. Relatedly, the MLP ARC recommends that the leadership and command topics be

### Pilot	Professional Development	Regulatory	Evaluation 51

included in recurrent training over a four- ye ar cycle suggesting that the recurrent training would then need to be eight hours per ye ar to cover the same material that is included in the upgrade training. The proposed rule also includes a requirement to include leadership and command training in recurrent training but does not specify a minimum number of hours for that training. The FAA does not have enough information to quantify the benefits related to incremental hours spent in leadership and command training or additional committee meetings and therefore leaves the requirements flexible so that each air carrier can make a determination based on its own circumstances. Additional requirements recommended b y the MLP ARC are not included in the proposed rule for a number of reasons . These reasons include redundancy with existing requirements, redundancy in light of regulatory changes put in place af

ter the MLP ARC issued its recommendations, and identification of alternate (less costly) means to achieve desired benefit. A full discussion of the MLP ARC proposal and dissenting views, and the FAA response can be found in the preamble to the proposed rule.


## VII. **Benefit -**  **Cost	Summary** This 10 - ye ar analys is beginning in 2015 , with a base year of 201 3 dollars , analyz es the benefits and costs that would result from the proposed rule. This was done by determining the number of pilots and their corresponding labor hour costs that would be impacted b y the rule, and then assessing the degree of the impact. The FAA estimated approximate time commitments based on the proposed changes, and calculated the resulting dollar amount using the inputs described. As described in Section IV above, the FAA believes the proposed rule would generate safety benefits and address both the NTSB recommendations and the statutory requirement for

### Pilot	Professional Development	Regulatory	Evaluation 52

rulemaking . Additionally, the proposed rule contains cost saving benefits to operators of $72 million over a 10 - ye ar period based on changes to ground training in this proposal that are possible due to changes already implemented in the Pilot C ertification Rule. These changes would lead to a reduction in the time required to complete recurrent and upgrade training and would not compromise safety. When discounted using a 7 percent di scount rate, the proposed rule would result in cost saving benef its of $4 6 million over a 10 - ye ar period. As described in Section V above, the FAA believes the proposed rule would result in costs to operators of approximately $ 6 8 million over a 10 - ye ar period . When discounted using a 7 percent discount rate, the proposed rule would result in costs of $ 4 7 million over a 10 - ye ar period. The benefits and costs , by provision, of the proposed rule are seen in Table 16 below . **Table 16**  **:** 

### Net **Benefits by Provision**  ***** 

### (7% Present Value, Millions of 2013 Dollars, 2015 **- 2024)**  **Provision Cost Saving**  **Benefits Co**  **mpliance**

**Costs Net** 

**Benefits** Recurrent Ground Training 

### (§ 121.427) $34.424 $0 **$34.424** Upgrade Ground Training 

### (§ 121.420) $11.839 $0 **$11.839** New - Hire SIC Operations Familiarization (§ 121.432(d)) Not Quantified $2.855 **- $2.855**  Upgrade Training (Mentoring, Leadership, and Command) (§§ 121.420 and 121.426) Not Quantified $6.304 **- $6.304**  One -Time and Recurrent PIC Training (Mentoring, Leadership, and Command) (§§ 121.409(b), 121.427, and 121.429) Not Quantified $37.037 **- $37.037**  PPDC Annual Meeting (§ 121.17) Not Quantified $0.572 **- $0.572**  Recordkeeping Not Quantified $0.006 **- $0.006**  Total **$46.263 $46.774**  **- $0.511** 

***Table values have been rounded. Totals may not add due to rounding.** 

### Pilot	Professional Development	Regulatory	Evaluation 53



## VIII. **Appendix	A :	Supporting	Tables**  **Tab le**  **A- 1**  NU MB ERSOF P ILOTS BY O PE RA TOR (Aug ust 2014)

**P art 121 O**  **pe rato**  **r Type**  **PICs SICs**  **Total Ca**  **rri er**  **C ount**  AB X AIRI NC 121 127 127 254 1 AE KO KU LAI NC 121 15 11 26 1 AE RO MI CRON ES IA INC 121 7 5 12 1 AE RODYN AM ICS INC 121 5 3 8 1 AIRTR ANSPORT I NT ERN AT IONAL I NC 121 69 66 135 1 AIRWI SCONSIN AIR LI NE S CORPORATION 121 394 375 769 1 ALASKA AIR LI NE S INC 121 752 718 1470 1 AL LEGI ANT

A IRLLC 121 200 200 400 1 AM ERI CA N AIR LI NE S INC 121 3559 4201 7760 1 AM ERI JET I NT ERN AT IONAL I NC 121 26 24 50 1 AM ERI STARA IR CA RGO I NC 121 18 6 24 1 AT LA S AIRI NC 121 375 700 1075 1 AVIAT ION SE RV ICE S LTD 121/ 135 3 2 5 1 CARIBBEAN SU N AIR LI NE S INC 121 17 15 32 1 CEN TU RI ON AIRC AR GO I NC 121 20 34 54 1 CH AM PLAIN EN TERP RISE S INC 121 137 120 257 1 CH AUTA UQ UAA IR LI NE S INC 121 292 279 571 1 COM PASS AIR LI NE S LLC 121 257 281 538 1 DELTAA IR LIN ESI NC 121 4871 5784 10655 1 DYN AM IC AIRWAYS LLC 121 25 15 40 1 ELI TE A IR WA YSLLC 121 12 5 17 1 EM PIREA IRL INE S INC 121/ 135 100 23 123 1 EN DEAVO R AIR 121 892 899 1791 1 EN VO Y A IRI NC 121 1063 1164 2227 1 ERAAVI AT ION INC 121 30 27 57 1 EX PR ESSJET A IRL INE S INC 121 2355 2184 4539 1 FALCON A IREX PRE SS INC 121 27 18 45 1 FE DERA L EX PR ESS CORP 121 1884 2120 4004 1 FLORI DAWEST I NT ERN AT IONAL A IR WA YSI NC 121 14 19 33 1 FRONT IE R A IR LI NE S INC 121 331 311 642 1 GO JET A IRLI NE S LLC 121 235 203 438 1 GR EA T LA KE S AV IAT ION LTD 121/ 135 60 17 77 1 GULFA NDCA RI BBEA N CARG O INC 121 25 23 48 1

### Pilot	Professional Development	Regulatory	Evaluation 54

**Tab le**  **A- 1 (**  **Continue d)**  NU MB ERSOF P ILOTS BY O PE RA TOR (Aug ust 2014)

**P art 121 O**  **pe rato**  **r Type**  **PICs SICs**  **Total Ca**  **rri er**  **C ount**  HA WA II ISLANDA IR INC 121 28 30 58 1 HA WA IIAN AIR LI NE S INC 121 300 272 572 1 HO RIZON A IR IND USTRIES I NC 121 320 301 621 1 HYA NNIS AIRS ERV ICEI NC 121/ 135 269 66 335 1 JETBLU E A IR WA YSC ORPORAT ION 121 979 1000 1979 1 KAISE RA IR INC 121/ 135 20 18 38 1 KAL IT TAA IRLLC 121 100 150 250 1 KAL IT TAC HA RTERS II LLC 121 22 19 41 1 KEY LI MEA IRC ORPORAT ION 121/ 135 34 5 39 1 LYN DEN A IRCA RG O L L C 121 31 29 60 1 ME SA AIR LI NE S INC 121 273 238 511 1 MI AM I AIRI NT ERN AT IONAL I NC 121 36 46 82 1 MN A IR LI NE S LLC 121 121 119 240 1 MO UN TA IN AIR CA RGO I NC 121/ 135 98 28 126 1 NAT IONAL

A IR CA RGO GRO UP I NC 121 43 35 78 1 NORTHERN A IRCA RG O INC 121 25 20 45 1 OM NI AIRI NT ERN AT IONAL I NC 121 88 83 171 1 ORA NG E A IRLLC 121 5 2 7 1 PE NINSU LAA IRWAYS INC 121/ 135 43 40 83 1 PIE DM ONT

A IR LI NE S INC 121 230 275 505 1 POLARA IRC AR GOWO RLDWI DE I NC 121 2 0 2 1 PR ES COT T S UP PORT C O 121/ 135 8 10 18 1 PSA AIR LI NE S INC 121 283 462 745 1 REP UB LI C AIRL INE S INC 121 599 513 1112 1 RHO AD ESA VIAT ION INC 121 4 2 6 1 SEAB ORN E V IR GI N ISLANDI NC 121 37 30 67 1 SH UTTLE A ME RI CA CORPORATI ON 121 362 326 688 1 SIE RRAP AC IFIC AIR LI NE S INC 121 6 3 9 1 SILVE R A IR WAYS CORP ORATI ON 121 97 130 227 1 SKY LEA SEI I NC 121 32 50 82 1 SKYWEST A IR LI NE S INC 121 1399 1347 2746 1 SOU THER N AIRI NC 121 69 136 205 1 SOU THWES T A IRLI NE S CO 121 3952 3680 7632 1

### Pilot	Professional Development	Regulatory	Evaluation 55

**Tab le**  **A- 1 (**  **Continue d)**  NU MB ERSOF P ILOTS BY O PE RA TOR (Aug ust 2014)

**P art 121 O**  **pe rato**  **r Type**  **PICs SICs**  **Total Ca**  **rri er**  **C ount**  SPIR IT AIR LI NE S INC 121 456 448 904 1 SW IFT AIRL L C 121 12 12 24 1 TATO ND UKO UT FIT

TERS LTD 121/ 135 25 22 47 1 TEMEN TERP RI SE S 121 14 8 22 1 TRA NS STAT ES A IR LI NE S LLC 121 156 148 304 1 UN IT ED A IRL INE S, INC. 121 4378 5743 10121 1 UN IT ED P AR CE L S ERV ICECO 121 1350 1340 2690 1 USA IR WAYS INC 121 2175 2392 4567 1 US A JET A IR LI NE S INC 121/ 135 38 19 57 1 VIR GI N AM ERICA INC 121 320 320 640 1 VISION AIR LI NE S INC 121/ 135 26 22 48 1 WESTERN GLO BAL

A IR LI NE S LLC 121 10 5 15 1 **Type PICs**  **SICs Total**  **Ca rri**  **er C**  **ount Ex**  **cl usive**  **P art 121 total**  **s 121**  **36, 348**  **39, 651**  **75, 999**  **66 Pa**  **rt 121/135 To tal**  **s 121/135**  **724 272**  **996 12**  **Pa rt 121 TO** **TALS 37,**  **072 39,**  **923 76,**  **995 78** 

**O the**  **r Ope rators** * **Type PICs**  **SICs Total**  **Ca rri**  **er C**  **ount** BERI NGA IR 135 **28 4**  **32 1**  HA GELA NDAVI AT ION SE RV ICE S 135 **101 12**  **113 1**  TRA DEWI NDA VIAT ION LLC 135 **27 17**  **44 1**  **Othe r Carri**  **er**

**TOTALS 156**  **33 189**  **3 Al**  **l Ca**  **rri er** **s 37,**  **228 39,**  **956 77,**  **184 81**  * P art 1 35 co mmute r carri ers who have o perati ons in ai rpl ane s type ce rti fied fo r t wo pi lo ts are re qui re d by the p ro pose d rul e to p ro vide ope rati ons fa mi lia ri zati on flig hts fo r n ew hires , an d me ntori ng, lea de rs hip, and command trai ningf or P ICs an d upgradi ng pi lo ts. Th e FAA id en ti fied t hre e Pa rt 135 carri ers who ha ve co mmute r o pe rati ons in ai rpl ane s ty pe ce rti fied f or two pi lo ts. Sourc e: N ati ona l Vit al I nf ormati on Subsyste m (NVIS) database , August 2014.

### Pilot	Professional Development	Regulatory	Evaluation 56

**Tabl e**  **A-2**
Assumptions:

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - 37228 37377 37527 37677 37828 37979 38131 38284 38437 38591 38745 SICs - 39956 40116 40276 40437 40599 40761 40924 41088 41252 41417 41583 To tal
- 77184 77493 77803 78114 78427 78740 79055 79372 79689 80008 80328

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - 149 150 150 151 151 152 153 153 154 154 SICs - - 160 160 161 162 162 163 164 164 165 166 To tal
- - 309 310 311 313 313 315 317 317 319 320

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 To tal
- 1698 1705 1712 1719 1725 1732 1739 1746 1753 1760 1767 Source s: 0. 5%

An nual g ro wth rate o f 0. 4% ap pl ied to PICs and SICs eq ual ly

Change i n pilot count f rom previous yea r **Number of**  **Pilot**

**s 5** 

**Number of**  **Ne w P** **ilot**

**s Ne** **ed ed**  **Due To G rowth** 

5: 2014 p ilo ts counts from Nati ona l Vit al I nfor mati on Subsystem (NVIS) da tabase , Aug ust 2014. Se e Tabl e A-1 . NU MB ER OF PILOTS ( BY CATEGORY) A NDGROUN D I NSTRU CTORS I MP ACT ED BY COST P ROV ISIONS (E XCL UDI NG P PD C PR OVISION) ANDRECU RREN T C OST RELI EV INGP ROV ISIONS

1: FA A Aerospace Fore cas ts 2013- 2033. Tabl e 30: A ct iv e Pilot s by Ty pe o f Certi ficate , Ai rl ine Transport, 2 012- 2033. 2: Tab le A-2 0. 3: Es ti mate d rate ofe arl y medic al re ti re me nts. Source : PilotC erti ficati on and Qual ifc ia ti on Fi nal R ul e. 4: Th is isan FAAas sumpti on. P ilot s Pe r Grou nd Instructor 4 200 Gro wth 1 Re ti re ments 2 Attri ti on due t o Me di cal Earl y Re ti re me nt 3 0. 4% 2. 2%

**Reti rements**  An nual R et irement of 2. 20% ( based on total n umbe r o f pilo ts)

### Pilot	Professional Development	Regulatory	Evaluation 57

**Tabl e**  **A-2 (**  **Continue d)** 

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - 186 187 188 188 189 190 191 191 192 193 194 SICs - 200 201 201 202 203 204 205 205 206 207 208 To tal
- 386 387 389 391 392 394 395 397 398 400 402

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - 2041 2049 2057 2066 2073 2082 2091 2098 2107 2115 SICs - - 2402 2410 2420 2431 2439 2450 2460 2468 2479 2489 To tal
- - 4443 4459 4477 4497 4512 4532 4551 4566 4586 4604

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - 35336 35478 35620 35762 35906 36049 36193 36339 36484 36630 SICs - - 37714 37866 38017 38168 38322 38474 38628 38784 38938 39094 To tal
- - 73050 73344 73637 73930 74228 74523 74821 75123 75422 75724

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2014 To tal
- 386 387 389 391 392 394 395 397 398 400 402 Attri ti on Rate of0 .5% ap pl ied to PICs and SICs equal ly

**Number of**  **Ne wl** **y Pr** 

**omoted and Ne wl** **y Hi red Pi** **lo ts**  Newly Promote d PICS = Gro wth i n PICs + Total Re ti re ments + A ttri ti on ofP ICs; SICs =N ewly Promoted PICS + Grow th in SICS + Attri ti on ofSI Cs

**Number of**  **Pilot**

**s Recei vi** **ng Modi** 

**fie d**  **Recu rrent Tra**  **ining** PilotC ount mi nus Newly Promoted and Newly Hi re d Pi lots

**Number of**  **Gr**

**ound Instructors Ne** **eded** Nu mbe r o f total pi lo ts di vided by es ti mate d numbe r ofpi lo ts peri nstructor **Attri ti** **on D ue to Medi** **cal Earl** **y Reti remen**  **t** NU MB ER OF PILOTS ( BY CATEGORY) A NDGROUN D I NSTRU CTORS I MP ACT ED BY COST P ROV ISIONS (E XCL UDI NG P PD C PR OVISION) ANDRECU RREN T C OST RELI EV INGP ROV ISIONS

### Pilot	Professional Development	Regulatory	Evaluation 58

**Tabl e**  **A- 3** 

Assumpti ons:

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - 37072 37220 37369 37518 37668 37819 37970 38122 38274 38427 38581 SICs - 39923 40083 40243 40404 40566 40728 40891 41055 41219 41384 41550 Total
- 76995 77303 77612 77922 78234 78547 78861 79177 79493 79811 80131

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - 148 149 149 150 151 151 152 152 153 154 SICs - - 160 160 161 162 162 163 164 164 165 166 Total
- - 308 309 310 312 313 314 316 316 318 320

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 Total
- 1694 1701 1707 1714 1721 1728 1735 1742 1749 1756 1763 Source s: 200 **Number of**

**Pi lots**  **5** Annual grow th rate of0. 4% appl ied t o P ICs and SICs equal ly

**Number of**

**N ew P** **ilot**

**s Ne** **ed ed Du**  **e To G rowth**  Change i n pi lot c ount fr om pre vio us yea r

5: 2014 p ilot s counts from Nati onal Vi tal I nfor mati on Subsyste m ( NVIS) database , Aug ust 2014. S ee Tab le A-1 NU MBER OFP ILOTS ( BY

CAT EGO RY) ANDGROU NDINSTRU CTORS IM PACT EDBY P PDC COST P ROV ISION ANDUP GR AD E C OST RELI EV ING PR OVISIONS

1: F AA Aerospa ce F orec asts 2 013- 2033. Tab le 30: A cti ve Pi lo ts by Ty pe of Certi fic ate , Air line Tran sport, 2012- 2033. 2: Tab le A-2 0 3: Es ti mate d rate o f ea rl y me di cal re ti re me nts. Source : Pi lo t Ce rti fic ati on and Qua lifc ia tion Fi nal Rul e. 4: Thi s isan FA A assumpti on. Grow th 1 Re ti re me nts 2 Attri ti on due to Me dic al Earl y Re ti re me nt 3 P ilo ts PerGro und Instructor 4 0. 4% 2. 2% 0. 5%

**Reti remen**  **ts** Annual Re ti re me nt of2. 20% ( based on total n umbe r o f pilot s)

### Pilot	Professional Development	Regulatory	Evaluation 59

**Tabl e**  **A- 3 (**  **Conti nued)** 

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - 185 186 187 188 188 189 190 191 191 192 193 SICs - 200 200 201 202 203 204 204 205 206 207 208 Total
- 385 387 388 390 391 393 394 396 397 399 401

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - 2035 2043 2051 2059 2068 2076 2085 2092 2101 2110 SICs - - 2395 2404 2414 2424 2434 2443 2454 2462 2473 2484 Total
- - 4430 4447 4465 4483 4502 4519 4539 4554 4574 4594

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 PICs - - - 35326 35467 35609 35751 35894 36037 36182 36326 36471 SICs - - - 37839 37990 38142 38294 38448 38601 38757 38911 39066 Total
- - - 73165 73457 73751 74045 74342 74638 74939 75237 75537

Ye ar 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2014 Total
- 385 387 388 390 391 393 394 396 397 399 401 Attriti on Rate o f 0. 5%ap pl ied to PICs and SICs equal ly

**Number of**

**N ewl** **y Promoted and Newl y Hi** **red Pi** **lots** Newly Promoted PICS = Gro wth in PICs + Total Re ti re me nts + Attri ti on of PICs; SICs = Ne wly Promote d P ICS + Grow th in S ICS + Attri ti on ofS ICs

**Number of**

**Pi lots**  **Recei ving**  **Modifie d R**  **ecu rren**  **t Trai ning**  PilotC ount mi nus Newly Promoted and Newly Hi re d P ilot s

Numbe r o f total pi lo ts divided by es ti mate d number ofpi lo ts peri nstr uctor **Number of**

**G ro**  **und Instructors Needed**  **Attriti on**  **Du e to** **Med ic** **al Ea** **rl y Reti** **rement** NU MBER OFP ILOTS ( BY

CAT EGO RY) ANDGROU NDINSTRU CTORS IM PACT EDBY P PDC COST P ROV ISION ANDUP GR AD E C OST RELI EV ING PR OVISIONS

### Pilot	Professional Development	Regulatory	Evaluation 60

**Tabl e**  **A- 4**  Gu arante e NEW- HIRE AIRL INE To tal Count % Total SIC

Count %of SICs PIC

Count %ofP ICs Aircraft 1 3 5 7 12 7 10 MA X Re se rv e Mo nthl y AL AS KA AIRLINES 1470 3% 718 2. 63% 752 3. 09% 737- 900 $48 $89 $105 $109 $121 $162 $174 $180 79 $3, 792 AL LEGI ANT 7760 15% 4201 15. 37% 3559 14. 64% MD -80 $41 $73 $83 $87 $87 $134 $141 $146 70 $2, 870 AM ERI CAN 400 1% 200 0. 73% 200 0. 82% 737- 800 $35 $92 $97 $102 $113 $159 $163 $166 73 $2, 555 AM ERI JET 57 0% 24 0. 09% 33 0. 14% 727- 200 $45 $48 $50 $55 $55 $82 $85 $100 65 $2, 925 DELTA 10655 21% 5784 21. 16% 4871 20. 04% 737- 800 $59 $105 $111 $117 $124 $175 $179 $182 70 $4, 130 FEDEX 4004 8% 2120 7. 76% 1884 7. 75% 727- 200 $61 $123 $128 $134 $155 $202 $206 $218 74 $4, 514 FRONTIER 642 1% 311 1. 14% 331 1. 36% A3 20 $38 $69 $78 $81 $89 $132 $140 $149 75 $2, 850 HA WA IIAN 572 1% 272 1. 00% 300 1. 23% 717 $36 $87 $97 $107 $113 $161 $162 $162 75 $2, 700 JETBLU E 1979 4% 1000 3. 66% 979 4. 03% A3 20 $47 $81 $92 $98 $108 $149 $155 $159 75 $3, 525 MN A IRLIN ES( for me rl y SU N COU NT RY) 240 0% 119 0. 44% 121 0. 50% 737- 800 $31 $65 $63 $71 $83 $107 $119 $127 70 $2, 170 SOUTHWEST 7632 15% 3680 13. 46% 3952 16. 26% 737- 700 $57 $107 $130 $139 $151 $205 $212 $216 79 $4, 503 SPIRIT 904 2% 448 1. 64% 456 1. 88% A3 21 $39 $72 $82 $87 $91 $120 $145 $164 72 $2, 808 UN ITED 10121 20% 5743 21. 01% 4378 18. 01% A3 20 $33 $75 $82 $86 $94 $130 $134 $137 70 $2, 310 USA IRWAYS 4567 9% 2392 8. 75% 2175 8. 95% A-3 20 $25 $62 $75 $79 $85 $118 $122 $125 76 $1, 900 VIRG IN AM ERICA 640 1% 320 1. 17% 320 1. 32% A-3 20 $44 $75 $82 $88 $95 $132 $141 $150 70 $3, 080 **Narrowbody W eighted Avera** **ge $46**  **$89 $99**  **$104 $112**  **$158 $164**  **$169** $3, 348 **Source s:**  SIC and PIC Count: NVIS, August 2014 Wa ge s: Ai rl ine Pilot Pa y Snapshot, 2 012.h p ://www.ai rl inepilotcentral .com/files/air linepilotpaysna pshot2012. pdf CAPT AIN (yea rs ofe xper ience) WEI GHTED A VE RAG E WA GESO F N ARROWBODY OPERATORS FIRST OFFICER (ye ars ofe xper ience)

### Pilot	Professional Development	Regulatory	Evaluation 61

**Tabl e**  **A- 5**  Gu arante e NEW- HIRE AIRL INE To tal Count % Total SIC

Count %of SICs PIC

Count %ofP ICs Aircraft 1 3 5 7 12 7 10 MA X Re se rv e Mo nthl y ABX AIR 254 1% 127 0. 55% 127 0. 65% 767- 200 $48 $103 $120 $126 $143 $194 $200 $204 68 $3, 264 AM ERI CAN 7760 18% 4201 18. 09% 3559 18. 32% 777 $35 $115 $120 $126 $139 $197 $202 $205 73 $2, 555 AM ERI JET 50 0% 24 0. 10% 26 0. 13% 767- 200 $46 $49 $52 $57 $57 $84 $88 $103 65 $2, 990 AT I 135 0% 66 0. 28% 69 0. 36% 767- 200 $56 $85 $85 $90 $101 $155 $170 $173 61 $3, 416 AT LA S 1075 3% 700 3. 01% 375 1. 93% 747- 400 $75 $99 $110 $121 $141 $173 $189 $201 62 $4, 650 CE NT URI ON 54 0% 34 0. 15% 20 0. 10% MD -1 1 $59 $75 $79 $83 $92 $122 $130 $140 65 $3, 835 DELTA 10655 25% 5784 24. 91% 4871 25. 08% 747- 400 $59 $131 $137 $145 $154 $217 $222 $226 70 $4, 130 FEDEX 4004 9% 2120 9. 13% 1884 9. 70% 777 $63 $144 $150 $156 $176 $236 $241 $253 74 $4, 662 HA WA IIAN 572 1% 272 1. 17% 300 1. 54% A3 30 $36 $102 $114 $126 $133 $189 $190 $191 75 $2, 700 KAL ITTA AIR 250 1% 150 0. 65% 100 0. 51% 747- 400 $66 $85 $91 $97 $109 $142 $154 $192 62 $4, 092 OM NI AIR 171 0% 83 0. 36% 88 0. 45% 777 $70 $78 $84 $89 $95 $145 $159 $170 60 $4, 200 SKYLEASE 82 0% 50 0. 22% 32 0. 16% MD -1 1 $55 $60 $67 $69 $72 $113 $125 $125 60 $3, 300 SOUTHERN A IR 205 0% 136 0. 59% 69 0. 36% 747- 400 $59 $71 $79 $84 $97 $136 $148 $172 60 $3, 540 UN ITED 10121 24% 5743 24. 73% 4378 22. 54% 747- 400 $33 $107 $116 $121 $130 $183 $187 $190 70 $2, 310 UP S 2690 6% 1340 5. 77% 1350 6. 95% 747- 400 $39 $149 $155 $161 $182 $244 $249 $262 81 $3, 159 USA IRWAYS 4567 11% 2392 10. 30% 2175 11. 20% A-3 30 $25 $79 $96 $101 $109 $152 $156 $160 76 $1, 900 **Widebody Weighted Avera ge**  **$44 $116**  **$124 $131**  **$142 $199**  **$204 $209**  $3, 142 **Source s:**  SIC and PIC Count: NVIS, August 2014 Wa ge s: Ai rl ine Pilot Pa y Snapshot, 2 012.h p ://www.ai rl inepilotcentral .com/files/air linepilotpaysna pshot2012. pdf WEI GHTED AVE RAG E WA GESO F WI DEBODY OPERATORS FIRST OFFICER (ye ars ofe xper ience) CAPT AIN (yea rs ofe xper ience)

### Pilot	Professional Development	Regulatory	Evaluation 62 **Table A-**  **6** Gu arante e NEW- HI RE AIR LINE Total Count % Total SIC

Count %of SICs PIC

Count %of PICs Aircraft 1 3 5 7 10 3 5 7 10 MA X Re se rve Mo nthly COM PASS 538 2% 281 2. 46% 257 2. 28% E175 $24 $37 $40 $76 $84 $67 $72 $76 $84 $104 75 $1, 800 EN DEAVOR (for merly PINNACL E) 1791 8% 899 7. 87% 892 7. 92% CRJ9 00 $26 $38 $41 $44 $45 $69 $74 $78 $85 $106 75 $1, 950 EN VOY (for merly AM ERICAN EAGLE) 2227 10% 1164 10. 19% 1063 9. 44% CRJ700 $26 $38 $41 $42 $43 $73 $77 $81 $88 $106 75 $1, 950 EX PRESSJET 4539 20% 2184 19. 12% 2355 20. 91% CRJ9 00 $23 $40 $42 $45 $47 $67 $71 $75 $84 $107 75 $1, 725 GOJET 438 2% 203 1. 78% 235 2. 09% CRJ700 $25 $37 $38 $38 $38 $68 $71 $76 $83 $97 70 $1, 750 JETBLU E 1979 9% 1000 8. 76% 979 8. 69% E190 $47 $73 $82 $89 $93 $128 $131 $134 $139 $143 75 $3, 525 MESA 1 740 3% 370 3. 24% 370 3. 29% CRJ9 00 $22 $32 $34 $36 $37 $65 $69 $73 $80 $104 76 $1, 672 PSA 745 3% 462 4. 05% 283 2. 51% CRJ700 $24 $33 $38 $40 $40 $64 $70 $74 $81 $96 72 $1, 728 REPU BLI C ( inc ludingCHA UTA UQ UA and SH UTTLE A MER ICA) 1 2371 10% 1118 9. 79% 1253 11. 13% E190 $23 $36 $37 $37 $37 $73 $77 $82 $90 $119 75 $1, 725 SKYWES T 1 2746 12% 1347 11. 80% 1399 12. 42% CRJ9 00 $22 $41 $44 $47 $48 $69 $73 $78 $86 $112 75 $1, 650 US AIRWAYS 4567 20% 2392 20. 95% 2175 19. 31% E190 $42 $47 $52 $54 $58 $84 $88 $91 $97 $101 72 $3, 024 **Smal l**  **Narrowbody Weighted Average $30**  **$43 $47**  **$50 $52**  **$77 $81**  **$85 $92**  **$110** $2, 175
**Sources:** SIC and PIC Count: NVIS, August 2014 Wa ge s: Air line Pilot Pa y Snapshot, 2012. h p://www .a ir lin ep ilo tce ntral .com/file s/airli nepilotpaysna pshot2012. pdf FIRST OFFICE R ( years of exper ien ce )

1: Wage s ource data i ncl ude d two e ntri es fortw o di fferent ai rcraf t types for these carri ers. Be cau se p ilot count data was not avai la ble by ai rcraft, to be conse rvati ve, the e ntry for the l arger ai rcraft and corre sponding higher wage was selected. WEIGHTED AVE RAG E WA GES OF SMALL NA RROWBODY OPERA TO RS CAPT AIN (years of exper ien ce )



### Tab **le A-**  **7** NU MB ER OF A IR PL

ANE S BY TYP E Ye ar: 2012 **Pa sse**  **nge r**  Numbe r o f Na rrowbody Aircraft 3148 Numbe r o f Wi de body Aircraft 524 Numbe r o f Re gi onal J et s 1755 **Ca rgo**  Numbe r o f Na rrowbody Aircraft 265 Numbe r o f Wi de body Aircraft 575 **To ta**  **l** 6267 Source: F AA Aerospace F orec as t F iscal Ye ars 2013- 2033. P age s 113- 4 an d 1 19. Tab les 2 1, 2 2, an d 27.

### Pilot	Professional Development	Regulatory	Evaluation 63

**Tab le**  **A- 8** 
Ne w SIC Average SIC Up gradi ng

SIC Average

PIC Se ni or

PIC FIR ST O FFICE R CAPTAIN Dai ly % of Fl eet 0 1 3 5 7 10/ 12 7 10 MA X Na rrowbody Air craft 54. 46% $111. 61 $46 $89 $99 $104 $112 $158 $164 $169 Wi de body Aircraft 17. 54% $104. 73 $44 $116 $124 $131 $142 $199 $204 $209 Sma ll Na rrow body Aircraft 28. 00% $72. 50 $30 $43 $47 $50 $52 $85 $92 $110 We ig hte d Average $99 $41 $81 $89 $94 $101 $145 $151 $160 Hourl y Hourl y 2012 WA GESBY YEA RS OF EX PE RI EN CEA NDWEI GHTED BY P ILOT C OU NTS ANDP LA NETYP E

### Pilot	Professional Development	Regulatory	Evaluation 64

**Tab le**  **A- 9**  ANALYS IS OF EM PLOYER P ROV ID ED BEN EF ITS % of Total Compe nsa tion Doe s thi s cate go ryo f

be ne fit s va ry with hours wor ked? **Wa ge**  **s an**  **d sa la**  **ri es**  70. 3 **Total b**  **en ef**  **its** 29. 7

Pai d lea ve 6. 9 No

Va cat ion 3. 6 Ho lid ay 2. 1 Sic k 0. 8 Pe rs ona l 0. 4 Suppleme ntal p ay 2. 8 No

Ove rti me and pre mi um1 0. 8 Shi ftd ifferen ti al s 0. 2 Nonproducti on bonuse s 1. 7 Insura nc e 8. 2 No

Li fe 0. 1 He al th 7. 7 Short-te rm di sa bility 0. 2 Lon g- te rm d isa bi lity 0. 1 Re ti re me nt an d savi ngs 3. 7 Ye s

De fined b en efit 1. 6 De fined co ntr ib uti on 2. 1 Le gal lyre quired b en efit s 8. 2 Ye s

Soc ia l Sec uri tyan d Me di care 5. 9 Fede ral u nempl oyme nt in suran ce 0. 1 State u ne mpl oyme nt in surance 0. 8 Work ers’ co mpe nsati on 1. 4
Ye s 11. 9 No 17. 9 To ta l 29. 8 Perce nt tha t vari es wi th hours wo rk ed 11. 9 Inc re me nta l Ho urs Wage M ul tiplier 1. 169 Inc re me nta l Emp loye e Wage M ul ti pl ier 1. 42 Sourc e: http://www.bl s.g ov/ne ws.relea se/pdf/ec ec .pdf BLS , Em pl oyer

co sts for Em pl oyee co mpe nsati on - June 2013 Tab le 5, P ri va te I ndustry

### Pilot	Professional Development	Regulatory	Evaluation 65

**Tabl e**  **A- 10**  ADJU ST ME NT

F OR CH ANG E O VE R TI ME **Month: Me**  **an Annual Pi**  **lo t W**  **age Sour** **ce** Ma y 2012 128, 760 $ http://www.bl s.gov/oes/2 012/ may/oe s5 32011. htm Ma y 2013 129, 600 $ http://www.bl s.gov/oes/c ur re nt/oe s5 32011. htm **Annual W**  **ag e**  **Gr owth**  **Rate :**  **0. 65%** 



### Tab **le A-**  **11** WA GESUS ED I N PR OPOSA L COST A NALYS IS

**Lab or Cate**  **gor**

**y Wa**  **ge Rat**  **e 1**  

### Fa **ctor f or**  **Empl oye**  **r Pr** **ovide d**  **Be ne**  **fit s**  **2** 

### Fa **cto r f** **or**

**Cha nge**  **Ove r Ti**  **me 3**  

### Total

**Compe nsa** **ti on**  **Costs Unit** **of ti**  **me** Gro und Trai ning Instructor $31 1. 42 1 $44 hourl y Se ni or Ma na ge me ntP erson 4 

### $160 1. 169 1. 0065 $188 hourl y Se ni or PIC $160 1. 169 1. 0065 $188 flig hth our Average P IC $145 1. 169 1. 0065 $171 flig hth our Se ni or SIC $94 1. 169 1. 0065 $111 flig hth our Average S IC $89 1. 169 1. 0065 $105 flig hth our New SIC $99 1. 169 1. 0065 $116 da y PerDi em $123 1 1 $123 da y Cl er k 5 

### $18 1. 42 1 $26 hourl y Sources 1: Tab le A-8 . Gro und trai ni ngi nstructor w age rat e base d on 2013 B LSO ccu pati onal Em pl oyme nt Stati st ics forA irTran sportati on Industry ( http://www.bls.gov/oe s/c urre nt/na ics4 _481100. ht m): Trai ni ng and De velo pme ntS pe ci al is ts (1 3- 1151) . 2: Tab le A-9 . 3: Tab le A-10.

Note : P erD iem i s 2013 s tandard G SA lo dg in g and pe r di em rate i nc lu di ng me al s an d in ci de ntal s. 5: Tab le A-8 . Gro und trai ni ngi nstructor w age rat e and cl er k wa ge b ase d on 2013 B LS Occup ati onal Em pl oyme nt Stati sti cs f or AirTran sportati on Industry (http://www.bl s.gov/oe s/c ur re nt/nai cs4 _481100. htm) : Trai ni ng and De velopment Spe ci al ist s (1 3- 1151) and I nfor mati on and Re co rd Cl er ks (43- 4000) . 4: Th e FAA de te rm in ed t hat a s en io r m anage me nt pe rs on would command an av erage h ourl y co mpe nsa ti on eq ual to that ofa s en io r PIC.

### Pilot	Professional Development	Regulatory	Evaluation 66

**Tab le**  **A- 12**  RECU RRIN G C OST FOR OPERATIONS FAM IL IAR IZAT ION FOR NE W- HI RE P ILOTS **2 SI C**  **Fa mi**  **lia ri**  **za tion**  **Ope rati**  **ng Cycl es**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number o f New-Hire S ICs 1

- - 2420 2431 2439 2450 2460 2468 2479 2489 Ne w SIC Cost per Da y 2 $116 $116 $116 $116 $116 $116 $116 $116 $116 $116 Da ys Req ui

red 3 0 0 1 1 1 1 1 1 1 1 Fa mi lia ri za tion Fl ig ht Cost (M illion s $) 4 $0. 000 $0. 000 $0. 281 $0. 282 $0. 283 $0. 284 $0. 285 $0. 286 $0. 288 $0. 289 $2. 278 Per Diem 5 $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Da ys Req ui

red 6 0 0 1 1 1 1 1 1 1 1 Pe r Di em Cost ( Mi llio ns $) 7 $0. 000 $0. 000 $0. 298 $0. 299 $0. 300 $0. 301 $0. 303 $0. 304 $0. 305 $0. 306 $2. 415 **Total (**  **Mi llio**  **ns $ )**  **8 $0.**  **000 $0.**  **000 $0.**  **578 $0.**  **581 $0.**  **583 $0.**  **586 $0.**  **588 $0.**  **590 $0.**  **592 $0.**  **595 $4.**  **693** PV 7 P er ce nt $0. 000 $0. 000 $0. 441 $0. 414 $0. 388 $0. 365 $0. 342 $0. 321 $0. 301 $0. 283 $2. 855 PV 3 P er ce nt $0. 000 $0. 000 $0. 514 $0. 501 $0. 488 $0. 476 $0. 464 $0. 452 $0. 441 $0. 430 $3. 766 1: Th e numbe r ofn ew-hir e SICs (Tabl e A-2 ). 2: Es ti mate d dai ly trai ni ng co st for n ew SICs (Tabl e A-1 1) . 3: Es ti mate d numbe r o f trai ni ng da ys re qui re d. 4: N ew-hire SIC co st, cal cu la te d by mul ti pl yi ng the n umbe r o f ne w-hire SICs by the d ai ly co st an d the n umbe r ofd ay s re qui re d (fo otnote s 1, 2, and 3 ). 5: Th e per

d iem rat e (Tab le A-1 1) . 6: N umbe r o f trave l days for w hi ch a p er

d iem w oul d be n ec essa ry . 7: P er d iem co st, cal cu la te d by mul tiplyingt he p er d iem rate b y the n umbe r ofd ay s re quir ed ( fo otnote s 5 a nd 6) . 8: To tal co st, cal cu la te d by summi ng the n ew-hire SIC co st and the p er d iem co st (fo otnote s 4 a nd 7) . Note : Thi s in fo rmati on co rre sponds to secti on V. A. an d Tabl e 9 w it hi n the P ilo t P rof es si ona l De velo pme nt Re gul atoryEv al ua tion.

### Pilot	Professional Development	Regulatory	Evaluation 67

**Tab le**  **A- 13**  ST ART- UP C OM PL IANCEC OST F OR M EN TORI NG , LEA DERS HI P, ANDC OM MA ND

Mo dify Up grade F lig ht and Gro und Trai ni ng Cur ri cu lu m

(2 015) Cre ate O ne -T im e PIC Trai ni ng

and Mo di fy PIC Re cu rre nt Trai ni ng Cur ri cu la ( 2015) Trai n Gro und Instr uctors (2 015) Number o f Car riers 1 

### 81 81 Number o f Gro und Instructo rs 2 

### 387 Gro und Instructo r Cost per Ho ur 3 

### $44 $44 $44 Gro und Instructo r Ho ur

s Req ui red 4 

### 80 40 8 **Total (**  **Millions $)**  **5** 

### $0. **285 $0.**  **143 $0.**  **136** PV 7 Perce nt $0. 249 $0. 125 $0. 119 PV 3 Perce nt $0. 269 $0. 134 $0. 128 *Co sts di scounte d acco rd in g to yea r o f an al ysi s (2 015) . 1: N umbe r o f part 121, 121/ 135, an d 135 car ri ers re qui re d to modi fy or cre at e trai ni ngs. 2: N umbe r o f ground in str uctors ne ce ssaryto be trai ne d (Tabl e A-2 ). 3: Es ti ma te d ground in str uctor co st pe r hour ( Tab le A-1 1) . 4: Es ti ma te d ground in str uctor hours re qui re d to de ve lo p or u nde rtak e trai ni ng.
Note : Th isi nfor mati on co rre sponds to se ct io ns V.B . an d V. C. and Tab les10 an d 11 w it hi n the P ilo t P ro fess io nal De ve lo pme nt Re gul atory Ev al uati on. 5: To tal co st perp rovi si on, cal cu la te d by mul ti pl yingn umbe r ofcarri ers or in str uctors by the co rre spondi ng hourl y co st and hours re qui re d.

### Pilot	Professional Development	Regulatory	Evaluation 68

**Tabl e**  **A- 14**  COST OF NE W MEN TORI NG , LEADERSHI P, ANDCOM MN AD TRAININGREQUIREM EN TS FOR SI CS U PG RA DIN G TO P IC **Provi de**  **1 G round Trai**  **ni ng Day f** **or SIC s U**  **pgradi ng to PICs Cove**  **ri ng Me**  **ntoring, Le ade**  **rshi p, and Command**  **YEAR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L Number of Upgradi

ng SICS 1

- - 2057 2066 2073 2082 2091 2098 2107 2115 Seni or S IC Cost per Flig ht Ho ur 2 $111 $111 $111 $111 $111 $111 $111 $111 $111 $111 Trai ni ng Ho ur s Requi red 3 0 0 8 8 8 8 8 8 8 8 Flig ht Ho ur s Req ui red 4 0 0 4 4 4 4 4 4 4 4 SIC Up gradi ng Trai nee Cost (M illio ns $) 5 $0. 000 $0. 000 $0. 913 $0. 917 $0. 920 $0. 924 $0. 928 $0. 932 $0. 936 $0. 939 $7. 410 Per Di em 6 $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Da ys Requi

red 7 0 0 1 1 1 1 1 1 1 1 Per Di em Cost (M illio ns $) 8 $0. 000 $0. 000 $0. 253 $0. 254 $0. 255 $0. 256 $0. 257 $0. 258 $0. 259 $0. 260 $2. 053 Number of Gro und Cl

asses 9

- - 103 103 104 104 105 105 105 106 Gro und Instructor Cost per Ho ur 10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Ho urs per Cla ss 11 0 0 8 8 8 8 8 8 8 8 Ground Instructor Cost (M illio ns $) 12 $0. 000 $0. 000 $0. 036 $0. 036 $0. 036 $0. 037 $0. 037 $0. 037 $0. 037 $0. 037 $0. 294 **To tal**  **( Mi**  **llions $)**  **13 $0.**  **000 $0.**  **000 $1.**  **203 $1.**  **208 $1.**  **212 $1.**  **217 $1.**  **222 $1.**  **226 $1.**  **232 $1.**  **236 $9.**  **756** PV 7 P er ce nt $0. 000 $0. 000 $0. 917 $0. 861 $0. 808 $0. 758 $0. 711 $0. 667 $0. 626 $0. 587 $5. 936 PV 3 P er ce nt $0. 000 $0. 000 $1. 068 $1. 042 $1. 015 $0. 990 $0. 965 $0. 940 $0. 917 $0. 893 $7. 830 1: Es tima te d number

o f SICs upgradi ngto PIC ( Tabl e A-2 ). 2: Es tima te d senior SIC cost pe r f lig ht hour ( Tabl e A-1 1) . 3: Es tima te d number

o f trai ningh ours re qui re d. 4: Es tima te d number

o f flig ht hours re qui re d, equivale nt to 1/2 oftrai ning hours re quired (footnote 3) . 6: Th e per

d iem r ate ( Tabl e A-1 1) . 7: N um ber of trave l days for w hi ch a pe r di em w ould be ne ce ssary. 8: P er d iem cost, cal cul at ed by mul ti plying the p erd iem rate b y the n umber o f days re qui re d (footnote s 6 and 7) . 10: Es ti mate d ground i nstructor cost pe r hour. 11: Es ti mate d ground i nstructor hours re quired per cl as s (Tabl e A-1 1) . 5: SI C upgradi ng trai ne e co st, cal cul ate d by multipl yi ng the number o f upgradi ng pi lo ts by the f lig ht hour cost and the n um ber of flig ht hours re qui re d (footnotes 1, 2, and 4).

12: Gro und instr uctor cost, cal cul ate d by mu lt ip ly in g th e number o f ground cl as ses re quired by the g round i nstructor cost pe r h our an d the n umbe r ofground i nstructor hours re quired per cl ass (fo otnote s 9, 10, and 1 1) . Note: Thi s i nformati on corre sponds to infor mati on pre se nte d in s ecti on V.B . and Tabl e 10 w ithin the Pilot Professiona l De velopment Re gulatory Ev al uati on. 9: N um ber of ground cl asses needed base d on an e stimated cl ass si ze of 20 p ilo ts and the n umber o f pi lots in need of trai ning (footnote 1) .

13: To tal cost, cal cul ate d by summi ng th e SIC upgradi ng trai nee cost, the p erd iem cost, and the grou nd instr uctor cost ( fo otnote s 5, 8, an d 12) .

### Pilot	Professional Development	Regulatory	Evaluation 69

**Tab le**  **A- 15**  RECU RRI NGTRA ININGC OSTS FOR 1 A DDI TI ON AL HO URF OR RECU RRENT P IC TRA INING **PIC Me**  **ntori ng,**  **Le ade**  **rshi p,**  **an d**  **Comma nd**  **1 Hou r Re**  **curre nt G**  **round T rai**  **ning YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L Number o f PICs Receivin g Recu rren t Tra in in g 1

- - 35620 35762 35906 36049 36193 36339 36484 36630 Avera geP IC Cost pe r Flig ht Ho ur 2 $171 $171 $171 $171 $171 $171 $171 $171 $171 $171 Tra in in g Ho ur

s Req ui red 3 0 0 1 1 1 1 1 1 1 1 Fl ig ht Ho ur s Requi red 4 0 0 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 PIC Trai ne e Cost (M illio ns $) 5 $0. 000 $0. 000 $3. 046 $3. 058 $3. 070 $3. 082 $3. 095 $3. 107 $3. 119 $3. 132 $24. 708 Number o f Ground Cl

asses 6

- - 1781 1788 1795 1802 1810 1817 1824 1832 Ground Instructor Cost per Ho ur 7 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instru cto r Ho urs pe r Class 8 0 0 1 1 1 1 1 1 1 1 Gro und Instructor Cost (M illio ns $) 9 $0. 000 $0. 000 $0. 078 $0. 079 $0. 079 $0. 079 $0. 080 $0. 080 $0. 080 $0. 081 $0. 636 **Total (**  **Millions $)**  **10 $0.**  **000 $0.**  **000 $3.**  **124 $3.**  **136 $3.**  **149 $3.**  **161 $3.**  **174 $3.**  **187 $3.**  **200 $3.**  **212 $25.**  **344** PV 7 P erce nt $0. 000 $0. 000 $2. 383 $2. 236 $2. 098 $1. 969 $1. 847 $1. 733 $1. 627 $1. 526 $15. 420 PV 3 P erce nt $0. 000 $0. 000 $2. 776 $2. 705 $2. 637 $2. 571 $2. 506 $2. 443 $2. 381 $2. 321 $20. 339 1: Es ti mate d numbe r o f PICs re ce iv in g re cu rre nt trai ni ng (Tabl e A-2 ). 2: Es ti mate d ave rage P IC co st pe r f lig ht hour (Tab le A-1 1) . 3: Es ti mate d numbe r o f trai ning hours re qui re d. 4: Es ti mate d numbe r o f flig ht hours re qui re d, equi va len t to 1/ 2 o f trai ni ng hours re quired ( fo otnote 3) . 5: P IC trai nee cost, cal cu la ted by mul ti pl yi ng the numbe r o f re curri ng PICs by the f lig ht hour co st and the n umbe r off lig ht hours re quired ( fo otnote s 1, 2, an d 4) . 6: N umber of ground cl asse s ne ed ed base d on an e sti mate d cl as s size of 20 p ilo ts and the n umbe r o f pi lots in n eed o f trai ning (footnote 1) . 7: Es ti mate d ground instr uctor cos t p erh our ( Tab le A-1 1) . 8: Es ti mate d ground instr uctor h ours re qui re d pe r cl ass.
10: To tal co st, cal cu la te d by summi ng the P IC trai ne e co st and the ground instr uctor cost ( footnotes 5 a nd 9 ). Not e: Th is infor ma ti on co rre sponds to infor mati on pre se nte d in s ecti on V.C. an d Tab le 11 w it hin the P ilo t Professiona l De ve lo pment Re gul atory Eval ua ti on. 9: Gro und i nstructor co st, cal cul ate d by mul ti plying the n umbe r o f ground cl as se s re quired b y the ground i nstr uctor co st pe r h our an d the n umber of ground in st ructor hours re qui re d pe r cl ass (foot note s 6, 7, an d 8) .

### Pilot	Professional Development	Regulatory	Evaluation 70

**Tab le**  **A-1 6**  ANNU AL COSTS FOR PPDC MEETI NG **PPD C**  **Me et**  **ing Cost, One**  **Hal f-D** **ay Me**  **et ing**  **Pe r Y**  **ea r**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number of Car

riers 1

- - 78 78 78 78 78 78 78 78 Seni or Management Person Cost per Ho ur 2 $188 $188 $188 $188 $188 $188 $188 $188 $188 $188 Ho ur s Req ui red 3 0 0 4 4 4 4 4 4 4 4 Senior M anage ment Person Cost ( Mi llio ns $) 4 $0. 000 $0. 000 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 469 Seni or PIC Cost per Flig ht Ho ur 5 $188 $188 $188 $188 $188 $188 $188 $188 $188 $188 Fl ig ht Ho ur s Req ui red 6 0 0 4 4 4 4 4 4 4 4 Senior P IC Cost (M illio ns $) 7 $0. 000 $0. 000 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 059 $0. 469 **Total (**  **Mi llio**  **ns $ )**  **8 $0.**  **000 $0.**  **000 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **117 $0.**  **938** PV 7 P erce nt $0. 000 $0. 000 $0. 089 $0. 084 $0. 078 $0. 073 $0. 068 $0. 064 $0. 060 $0. 056 $0. 572 PV 3 P erce nt $0. 000 $0. 000 $0. 104 $0. 101 $0. 098 $0. 095 $0. 093 $0. 090 $0. 087 $0. 085 $0. 754 1: N umbe r o f part 1 21 an d 121/ 135 carri ers re quired to de velop a PPDC. 2: Es ti mate d senior

manage ment pe rs on co st pe r h our ( Tabl e A-1 1) . 3: Es ti mate d senior

manage ment pe rs on hours re qui re d. 4: S en io r ma nage me nt pe rson cost, cal cu la te d by mul ti pl ying the n umbe r of carri ers by the h ourl y cost and the n umbe r of hours re qui re d (fo otnote s 1, 2, and 3 ). 5: Es ti mate d senior

P IC co st pe r h our (Tabl e A-1 1) . 6: Es ti mate d numbe r of flig ht hours re qui re d. 7: S en io r PIC cost, cal cu la te d by mul ti pl yingth e numbe r o f carri ers by the f lig ht hour co st and the n umbe r o f flig ht hours re qui re d (footnote s 1, 5, and 6). 8: To ta l cost, cal cu la te d by summi ng the se ni or manage me nt pe rson and se ni or PIC costs ( fo otnote s 4 a nd 7) . Note : Th is in for ma ti on co rre sponds to i nformati on present ed i n se cti on V.D . an d Tabl e 12 w it hi n the P ilo t P rof essiona l De ve lopment Re gul atory Eval uati on.

### Pilot	Professional Development	Regulatory	Evaluation 71

**Tab le**  **A-1 7**  RECU RRI NGCO ST

S AVINGF OR COST RELIEV INGP ROV ISIONS RELATED TO SI C RECU RREN T TRA INING **Annua l**  **Trai ni**  **ng Cost Savi ngs for**  **1 Hou r Re**  **ducti on i**  **n SIC**  **Re curre**  **nt G round Trai**  **ni ng**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L Number o f Recu rren t S ICs 1 37714 37866 38017 38168 38322 38474 38628 38784 38938 39094 Avera geS IC Cost

p er Flig ht Ho ur 2 $105 $105 $105 $105 $105 $105 $105 $105 $105 $105 Tra in in g Ho urs Red uced 3 1 1 1 1 1 1 1 1 1 1 Fl ig ht Ho ur s Red uced 4 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 SIC Trai ne e Cost Sav ing s (M illio ns $) 5 $1. 980 $1. 988 $1. 996 $2. 004 $2. 012 $2. 020 $2. 028 $2. 036 $2. 044 $2. 052 $20. 160 Number o f Gro und Cl

asses 6 1886 1893 1901 1908 1916 1924 1931 1939 1947 1955 Gro und Instructor Cost per Ho ur 7 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Ho urs Redu cedp er Class 8 1 1 1 1 1 1 1 1 1 1 Gro und Instructor Cost ( Mi llions $) 9 $0. 083 $0. 083 $0. 084 $0. 084 $0. 084 $0. 085 $0. 085 $0. 085 $0. 086 $0. 086 $0. 845 **To tal**  **( Mi**  **llio ns**  **$) 10**  **$2. 063**  **$2. 071**  **$2. 080**  **$2. 088**  **$2. 096**  **$2. 105**  **$2. 113**  **$2. 121**  **$2. 130**  **$2. 138**  **$21. 005**  PV 7 P erce nt $1. 802 $1. 691 $1. 586 $1. 489 $1. 397 $1. 311 $1. 230 $1. 154 $1. 083 $1. 016 $13. 757 PV 3 P erce nt $1. 945 $1. 896 $1. 848 $1. 801 $1. 756 $1. 711 $1. 668 $1. 626 $1. 585 $1. 545 $17. 379 1: E sti mate d numbe r o f SICs re ce ivingre curre nt trai ning( Tab le A-2 ). 2: E sti mate d ave rage S ICco st pe r f lig ht hour (Tab le A-1 1) . 3: E sti mate d numbe r o f trai ningh ours re duc ed . 4: E sti mate d numbe r o f flig ht hours re duc ed, eq uivalent to 1/ 2 o f trai ningh ours re duc ed ( fo otnote 3) . 6: N umber ofgro und cl asses need ed b as ed o n an e sti mate d cl as s size of20 p ilots and the n umbe r o f pi lo ts in ne ed of trai ning (fo otnote 1) . 7: E sti mate d ground in structor cost pe r hour ( Tab le A-1 1) . 8: E sti mate d ground in structor hours re duced p er cl as s.
10: To tal cos t sa ving s, ca lc ula te d by summi ng the S IC trai ne e and ground inst ructor cost sav in gs (fo otnote s 5 an d 9) . 5: S IC trai ne e co st sa vin gs, cal cu la te d by mul ti pl yingth e numbe r o f SICs re qui re d by the S IC co st pe r f lig ht hour and the f lig ht hours re duc ed (fo otnote s 1, 2, a nd 4) .

9: Gro und in str uctor cost savi ngs, cal cul ate d by mul ti plyi ng the n umber ofgro und cl asses re qui re d by the ground i nstr uctor cost pe r h our and the n umbe r of ground in str uctor hours re duc ed p ercl ass (fo otnote s 6, 7, and 8) . Note : Th is in fo rmati on co rre sponds to infor mati on pre se nte d in se ct ion IV.G . an d Tab le 4 w it hin the P ilot Prof es si onal De ve lopme nt Re gul atory Ev al ua ti on.

### Pilot	Professional Development	Regulatory	Evaluation 72

**Tab le**  **A-1 8**  RECU RRIN G C OST SAV INGF OR COST RELI EV INGP ROV ISIONS RELA TED TO P ICR ECURREN T TRA INING **Annual Trai**  **ning Cost Savi**  **ngs for 1 Hour Re**  **ducti on i**  **n PIC Re curre**  **nt Gr** **ound Trai**  **ning YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number of PICs Receivin g Recu rren t Tra in in g 1 35336 35478 35620 35762 35906 36049 36193 36339 36484 36630 Avera geP IC Cost per Flig ht Ho ur 2 $171 $171 $171 $171 $171 $171 $171 $171 $171 $171 Tra in in g Ho ur

s Red uced 3 1 1 1 1 1 1 1 1 1 1 Fl ig ht Ho ur s Red uced 4 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 0. 5 PIC Trai ne e Cost Savi ngs (M illio ns $) 5 $3. 021 $3. 033 $3. 046 $3. 058 $3. 070 $3. 082 $3. 095 $3. 107 $3. 119 $3. 132 $30. 763 Number of Gro und Classes 6 1767 1774 1781 1788 1795 1802 1810 1817 1824 1832 Gro und Instructo r Cost per Ho ur 7 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Ho urs Red ucedp er Cla ss 8 1 1 1 1 1 1 1 1 1 1 Gro und Instructor Cost (M illio ns $) 9 $0. 078 $0. 078 $0. 078 $0. 079 $0. 079 $0. 079 $0. 080 $0. 080 $0. 080 $0. 081 $0. 792 **Total (**  **Mi llio**  **ns $ )**  **10 $3.**  **099 $3.**  **111 $3.**  **124 $3.**  **136 $3.**  **149 $3.**  **161 $3.**  **174 $3.**  **187 $3.**  **200 $3.**  **212 $31.**  **554** PV 7 P erce nt $2. 707 $2. 540 $2. 383 $2. 236 $2. 098 $1. 969 $1. 847 $1. 733 $1. 627 $1. 526 $20. 667 PV 3 P erce nt $2. 921 $2. 847 $2. 776 $2. 705 $2. 637 $2. 571 $2. 506 $2. 443 $2. 381 $2. 321 $26. 107 1: Es ti mate d numbe r of PICs re ce ivingr ec urre nt trai ni ng ( Tab le A-2 ). 2: Es ti mate d av erage P IC cost pe r f lig ht hour ( Tab le A-1 1) . 3: Es ti mate d numbe r of trai ni ng hours re duced . 4: Es ti mate d numbe r of flig ht hours re duce d, eq ui val en t to 1/ 2 o f trai ni ng hours re duce d (fo otnote 3 ). 5: P IC trai ne e co st savi ngs, cal cu la te d by mul ti pl ying the n umbe r ofP ICs re qui re d by the P IC cost per f lig ht hour and the f lig ht hours re duce d (footnote s 1, 2, and 4) . 6: N umbe r o f gro und cl asse s ne eded base d on an e sti mate d cl ass siz e of20 p ilo ts an d the n umbe r o f pi lo ts in n eed o f trai ni ng (footnote 1) . 7: Es ti mate d ground i nstructor cost pe r h our ( Tabl e A-1 1) . 8: Es ti mate d ground i nstructor hours re duced p er cl ass.
10: To tal co st savi ngs, cal cu la te d by summi ng the P IC trai ne e and ground i nstructor cost savi ngs (fo otnote s 5and 9) . Note : Th is in for ma ti on co rre sponds to i nformati on present ed i n se cti on IV .C. and Tabl e 4 wit hi n the P ilotP rof essiona l De ve lo pment Re gul atory Eval uati on. 9: Gro und in structor cost savi ngs, cal cul ate d by mul ti pl ying the n umbe r o f ground cl as ses re qui re d by the g rou nd ins tructor cost pe r h our and the n umbe r of ground in structor hours re duce d pe r cl ass (fo otnote s 6, 7, and 8).

### Pilot	Professional Development	Regulatory	Evaluation 73 **Table A-19** RECURRING COST SAV INGS FOR COST RELIEVING PROV ISIONS RELATED TO U PG RADE TRA INING **Annua l**  **Trai ning Cost Savings for 2 Fe**  **wer Upgrade Ground Traini ng Days**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L Number of Upgradi

ng SICs 1

- - 2051 2059 2068 2076 2085 2092 2101 2110 Seni or S IC Cost per Fl

ight Hour 2 $111 $111 $111 $111 $111 $111 $111 $111 $111 $111 Tra in in g Ho ur

s Red uced 3 0 0 16 16 16 16 16 16 16 16 Flig ht Ho urs Red uced 4 0 0 8 8 8 8 8 8 8 8 SIC U pgrading Trai ne e Cost Savings (M illions $) 5 $0. 000 $0. 000 $1. 821 $1. 828 $1. 836 $1. 843 $1. 851 $1. 858 $1. 866 $1. 874 $14. 778 Per Diem 6 $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Days Reduced 7 0 0 2 2 2 2 2 2 2 2 Per Di em Cost (M illio ns $) 8 $0. 000 $0. 000 $0. 505 $0. 507 $0. 509 $0. 511 $0. 513 $0. 515 $0. 517 $0. 519 $4. 094 Number of Ground Classes 9

- - 103 103 103 104 104 105 105 106 Gro und Instructor Cost per Hour 10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Hours Reduced per Class 11 0 0 16 16 16 16 16 16 16 16 Ground Instructor Cost (M illions $) 12 $0. 000 $0. 000 $0. 072 $0. 072 $0. 073 $0. 073 $0. 073 $0. 074 $0. 074 $0. 074 $0. 586 **Total ( Mi**  **llions $ )**  **13 $0.000**  **$0. 000**  **$2.398 $2.407**  **$2. 418**  **$2.427 $2.**  **438 $2.**  **446 $2.456**  **$2. 467**  **$19. 458**  PV 7 P erce nt $0. 000 $0. 000 $1. 829 $1. 716 $1. 611 $1. 512 $1. 419 $1. 330 $1. 249 $1. 172 $11. 839 PV 3 P erce nt $0. 000 $0. 000 $2. 131 $2. 077 $2. 025 $1. 974 $1. 924 $1. 875 $1. 828 $1. 782 $15. 615 1: Es ti mated numbe r o f SICs upgrading to PIC (Table A-3 ). 2: Es ti mated senior SIC co st perf lig ht hour (Table A -1 1) . 3: Es ti mated numbe r o f trai ni ng hours reduce d. 4: Es ti mated numbe r o f flig ht hours re duce d, e quivalent to 1/2oftrai ninghours re duced (fo otnote s 3) . 6: The p er

d iem rate ( Tabl e A-1 1) . 7: N umbe r o f trave l days forw hic h a pe r d iem woul d have be en ne ce ssary. 8: P er di em cost savings, cal cu la te d by multi plying the p er di em rate by the n umber ofd ay s reduce d (footnotes 6 and 7) . 9: N umbe r o f ground cl asse s needed ba sed on an estimated class size o f 20 p ilots a nd the numbe r o f pilots in need of trai ning (footnote 1 ). 10: Esti mated ground instructor cost pe r h our (Table A -1 1) . 11: Esti mated ground instructor hours re duced percl ass.

No te : Thi s i nformation co rre sponds to in for mation pre sented in section IV.C. and Tabl e 7 within the P ilot Professiona l Development Re gulatory Ev al uati on. 13: Total cost savi ngs, cal cu la te d by summing the SIC upgrading trai ne e cost savi ngs, the p er diem cost savi ngs, and the ground in structor cost savi ngs (footnotes 5, 8, and 12 ). 12: Gro und instructor cost savi ngs, cal cul ate d by mul ti pl ying the n umbe r o f ground cl asses require d by the ground i nstructor cost pe r h our and the number of ground in structor hours reduce d per cl ass (footnotes 9, 10, an d 11 ). 5: S IC upgradi ng trai ne e co st savings, calcul ate d by mul ti plyingthe numbe r o f upgrading pilots by the flight hour cost and the numbe r off light hours reduce d (fo otnote s 1, 2, and 4).

### Pilot	Professional Development	Regulatory	Evaluation 74

**Tab le**  **A- 20**  ESTI MATED A CTI VEP ILOT C ERTI FICAT ES HELD BY CA TEGO RY A NDA GE GRO UP O F HOLDER as ofDe ce mbe r 31, 2013 Ag e Cohort* Num ber o f Pe rc entof Pe rc entof AT P ATP ATP Cert if ic at es Cert if ic at es Cert if ic at es in5-y ear Ag e Cohort in 5-y ear Ag e Cohort in 1-y ear Ag e Cohort (Ave rage) **[a ]**  **[b ]**  [c] [d ] = [c] / 5 14-15 0 0% 0. 0% 16-19 0 0% 0. 0% 20-24 297 0% 0. 0% 25-29 4, 863 4% 0. 7% 30-34 11, 314 8% 1. 6% 35-39 14, 614 11% 2. 1% 40-44 19, 359 14% 2. 8% 45-49 23, 606 17% 3. 4% 50-54 25, 780 19% 3. 7% 55-59 22, 523 16% 3. 3% 60-64 15, 302 11% 2. 2% **Tot al**  **137, 658**  **100%** *Ov er age 65 om itte d from ta bl e So urc e: U S C iv

il Airmen Statistics 

### http://www.faa.gov/da ta_re se arch /avi at io n_data_stati sti cs /c iv il_ai rme n_stati sti cs /2 013/ Tab le 12: Es ti mate d Acti ve Pilo t Ce rti fic ate s He ld b y Cate gory and Age Gro up of Ho ld er

### Pilot	Professional Development	Regulatory	Evaluation 75 **Tabl e**  **A- 21**  RECORD KEEPING AND ADDITIONA L CURRICULUMDEV ELO PM EN T COSTS **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L **Approval of Qualification Standards Docume nt for Ce**  **rti fic** **ate Hol**  **der s wi**  **th AQP (§ 121.909)** Number of AQP Carriers 1 25 Number of Ho urs per Carrier 2 3 To tal Ho urs 3 75 75 Gro und Instructor Cost per Hour 4 $44 Re cord Ke ep ing Cost 5 $3, 300 3, 300 $ PV 7 P erce nt $2, 882 $0 $0 $0 $0 $0 $0 $0 $0 $0 $2, 882 PV 3 P erce nt $3, 111 $0 $0 $0 $0 $0 $0 $0 $0 $0 $3, 111
**Me ntoring, leadership and command ground training for pilots curre**  **ntly se rvi**  **ng as pilot in command (PIC) (§ 1 21.**  **429)** Num be r of

PICs 6 37527 Reco rd Ke ep in g Time Burde n 7 38 38 Cler k Cost pe r Hour 8 $26 Reco rd Keeping Co st9 $988 988 $ PV 7 P erce nt $0 $807 $0 $0 $0 $0 $0 $0 $0 $0 $807 PV 3 P erce nt $0 $904 $0 $0 $0 $0 $0 $0 $0 $0 $904 1: N umber of AQP carri ers re quiri ng qual ific ati on standards docume nt. 2: Esti mate d hours re quired percarri er . 3: Total h ours re quired cal cul ate d by mul ti plying numbe r ofcarri ers by hours pe r carri er( footnotes 1 a nd 2) . 4: Esti mate d ground i nstructor cost pe r hour ( Tabl e A-1 1) . 6: N umber of curre nt PICs who wi ll undertake the one-ti me trai ning in 2016 ( Tabl e A-2 ). 7: Re cordke eping ti me b urde n, based on 0 .1% for e ach appl ic abl e pilot (footnote 6) . 8: Esti mate d cl er k cost pe r hour ( Tabl e A-1 1) . 9: Re cordke eping cost f or PIC trai ning, cal cul ate d by mul ti plying the re cordke eping ti me b urde n by the cl er k cost pe r hour ( fo otnotes 7 an d 8) . 5: Cost f or approval ofq ual ific ati on standards docume nt, cal cul ate d by mul ti plying total h ours re quire d by the ground i nstructor cost pe r hour ( footnotes 3 and 4).

### Pilot	Professional Development	Regulatory	Evaluation 76 **Tabl e**  **A- 21 (**  **Continued)** RECORD KEEPING AND ADDITIONA L CURRICULUMDEV ELO PM EN T COSTS **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTA L **Re curre**  **nt PIC me ntoring, leadership and command ground training (§1**  **21. 427)**  Number of PICs Receivin g Recurren t Tra in in g (per year) 10 11873 11921 11969 12016 12064 12113 12161 12210 96328 Reco rd Ke ep in g Time Burde n 11 12 12 12 12 12 12 12 12 97 Cler k Cost pe r Hour 12 $26 $26 $26 $26 $26 $26 $26 $26 Reco rd Keeping Co st 13 $309 $310 $311 $312 $314 $315 $316 $317 $2, 522 PV 7 P erce nt $0 $0 $236 $221 $207 $195 $183 $171 $161 $151 $1, 524 PV 3 P erce nt $0 $0 $274 $267 $261 $254 $248 $241 $235 $229 $2, 010 **Ope rati**  **ng f ami**  **lia ri**  **zati on for ne**  **w-hir e**  **pilots (§ 121.**  **432( d))**  Number of New-Hire SICs 14 2420 2431 2439 2450 2460 2468 2479 2489 19636 Reco rd Ke ep in g Time Burde n 15 2 2 2 2 2 2 2 2 20 Cler k Cost pe r Hour 16 $26 $26 $26 $26 $26 $26 $26 $26 Reco rd Keeping Co st 17 $63 $63 $63 $64 $64 $64 $64 $65 $520 PV 7 P erce nt $0 $0 $48 $45 $42 $40 $37 $35 $33 $31 $311 PV 3 P erce nt $0 $0 $56 $55 $53 $52 $50 $49 $48 $47 $410 **Total Burde**  **n** Total Ti me Burde n 18 75 38 14 14 14 14 15 15 15 15 229 Total Re cordke eping Cost 19 $3, 300 $988 $372 $373 $375 $376 $378 $379 $381 $382 $7, 303 PV 7 P erce nt $2, 882 $807 $284 $266 $250 $234 $220 $206 $194 $182 $5, 523 PV 3 P erce nt $3, 111 $904 $330 $322 $314 $306 $298 $291 $283 $276 $6, 434 10: Esti mate d number of PICs re ce iving re curre nt trai ning (Tabl e A-2 ). 11: Re cordk eeping ti me b urde n, ba sed on 0 .1% for e ach appl ic abl e pilot (footnote 10) . 12: Esti mate d cl er k cost pe r hour ( Tabl e A-1 1) 13: Re cordk eeping cost f or re curre nt PIC trai ning, cal cul ate d by mul ti [lying the recordkeeping ti me b urden by the cl er k cost pe r hour ( footnotes 11 and 12) . 14: The n umber of new-hire SICs (Tabl e A-2 ). 15: Re cordk eeping ti me b urde n, ba sed on 0 .1% for e ach appl ic abl e pilot (footnote 14) . 16: Esti mate d cl er k cost pe r hour ( Tabl e A-1 1) . 18: The total ti me b urde n, cal cul ate d by summing the re cordke eping ti me b urden for e ach cate gory ( fo otnotes 3, 7, 11, and 15) . 19: The total re cordke eping cost, cal cul ate d by summing the re cordke eping cos t f or e ach cate gory ( footnotes 5, 9, 13, and 17) . Note: Thi s i nformati on corre sponds to i nformati on pre se nted in secti on V .E . an d Tabl e 13 w it hin the Pilot Professional De ve lopment Re gul atory Ev al uati on. 17: Re cordk eeping cost f or ne w-hire SIC fami lia ri zati on, cal cul ate d by mul ti plyi ng the re cordke eping time burde n by the cl er k cost pe r hour ( footnotes 15 and 1 6) .

### Pilot	Professional Development	Regulatory	Evaluation 77

**Tabl e**  **A-2 2**  ONETI MEC OST FOR TRA ININGC UR REN T P ICs IN ME NTORING , LEA DERSHI P, ANDCO MMA ND **Pr ovi**  **de 1 G**  **round Trai ni**  **ng Day f or C**  **urre nt PICs Cove**  **ri ng Me**  **ntor in**  **g, Le**  **ad er** **ship, an**  **d Comma**  **nd** Trai n Curren t PICs in Me ntori ng, Le ade rshi p, an d Comma nd (2 016) Number of PICs 1 

### 37527 Avera geP IC Fl

ig ht Ho ur s Req ui red 2 

### 4 Avera geP IC Cost per Flig ht Ho ur 3 

### $171 PICTo tal C ost 4 

### $25. 668 Number of Cl

asses 5 

### 1876 Gro und Instructor Cost per Ho ur 6 

### $44 Instructor Ho urs per Cla ss 7 

### 8 Grou nd Instructor Total Co st 8 

### $0. 660 **To tal**  **( Mi**  **llio ns $**  **) 9**  

### $26. **329** PV 7 P erce nt $21. 492 PV 3 P erce nt $24. 095 *C osts di sc ounte d acco rdi ng to yea r of anal ysi s. 1: N umbe r o f cu rre nt PICs who will unde rtak e the o ne-time trai ni ng in 2016 ( Tab le A-2 ). 2: Es ti ma te d numbero f flig ht hours re qui re d, pers tandard i ndustry arran ge me nts forn ew pilot trai ni ng . 3: Es ti ma te d av erage P IC co st pe r f lig ht hour (Tab le A-1 1) .

6: Es ti ma te d ground in str uctor co st pe r h our (Tab le A-1 1) . 7: Es ti ma te d numbero f ground in structor hours re quired p ercl ass 8: Gro und in structor

co st, cal cul ate d by mul ti pl yi ng the n umbe r ofg round cl asse s re quired b y the gro und in structor cost and the n umbe r o f ground instr uctor hours re qui re d percl ass (foot note s 5, 6, a nd 7) . 4: P IC ground trai ni ng co st, cal cu la te d by mul ti pl yingth e numbe r o f curre nt PICs by the flig ht hour co st and the n umbe r o f flig ht hours re quired ( footnote s 1, 2, an d 3) 5: N umbe r o f ground cl asse s needed b ase d on an e stimated cl ass si ze o f 20 p ilo ts and the n umbe r of pi lo ts in n eed o f trai ni ng (footnote 1 ).

9: To tal co st, cal cu la te d by summi ng the P IC ground trai ni ngco st and the g round instr uctor cos t (fo otnote s 4 an d 8) . No te : Thi s in fo rmati on corre sponds to se ct io ns V. C. an d Tab le 11 w it hi n the Pilo t P rof essiona l De velo pme nt Re gul atory Ev al uati on.

### Pilot	Professional Development	Regulatory	Evaluation 78



## IX. **Appendix	B:	ARC	Proposal** A. Introduction The Flight Crewmember Mentoring, Leadership, and Professional Development Aviation Rulemaking Committee (MLP ARC) was convened as a result of Section 206 of the Airline Safety and Federal Aviation Administration Extension Act of 2010 . 20 

### The MLP ARC presented its report and recommendations to the FAA on November 2, 2010 . The recommendations sy nthesized into the ARC alternative proposal consist of the following actions to be undertaken by operators:

 Create a professional development position  Create a Professional Development Steering Committee (PDSC) program  Provide mentoring training for all PICs  Hold quarterly PDSC meetings  Provide additional indoctrination training for new - hire pilots  Provide one or more familiarization flights for new-hire pilots  Provide 32 hours of leadership and command training for SICs upgrading to PIC  Include leadership and command training in recurrent PIC training This set of recommendations represents an alternative to the FAA proposal and is analyz ed within this Appendix. Additional recommendations within the MLP ARC report relating to the dynamics of the mentor-protégé relationship and other training requirements were not quantified as a part of this alternative proposal. Of these not quantified provisions, the recommendations that were considered to enhance flight crewmember professional development consist of:

 Creation and implementation of a career mentoring program for new-hire pilots, SICs upgrading to PIC, and other specific situations deemed necessary by the PDSC  Conduct recurrent PIC training related to mentoring

20 Public Law 111 - 216

### Pilot	Professional Development	Regulatory	Evaluation 79  Determine through the PDSC whether current flightcrew members have a level of knowledge equivalent to the new indoctrination course and to provide gap training so that all flightcrew members have a common level of knowledge The recommendations that were considered to possibly enhance flightcrew member professional development consist of:

 Include leadership and command principles in the knowledge and Commercial Pilot, Certified Flight Instructor, and Airline Transport Pilot practical test  Require new part 121 pilots to have a bachelor’s degree or equivalent military flight training These additional recommendations would require various assumptions and clarifications not specified b y the MLP ARC and, in addition, it is unclear how effective they would be at enhancing professional development. As explained in the preamble to this proposed rule, in some cases the recommendations of the MLP ARC were outside the scope of the mandate in Public Law 111 - 216 or were addressed by other recent FAA final rules. The inclusion of these additional recommendations would increase costs with an unknown impact on benefits. The methodology, benefits, and costs of the ARC alternative proposal are detailed below. 

## B. Methodology The methodology

for analy zing the ARC proposal alternative is largely similar to methodology

used to analy

ze the FAA proposal. All key elements and assumptions concerning time frame of the analys is, number of pilots affected, 21 

### employee compensation costs, etc. are applicable both to the FAA proposal and the ARC proposal. One addition to the list of assumptions used in analyzing the proposed rule is a new wage category based on the ARC recommendation of creating a Professional Development Position (PDP) to be held by

a full -time employee to monitor professional development. Based on the

21 The number of PICs and SICs impacted by the proposed rule can be found in Table A- 1 of Appendix A.

### Pilot	Professional Development	Regulatory	Evaluation 80

qualifications that the ARC recommended for an individual to hold the PDP , the FAA estimated that such an individual would command an annual salary of $150,000. This wage rate would require the full benefits multiplier of 1.42 described within the Pilot Professional Development Regulatory

Evaluation. The methodology for this labor cost estimate, and the other labor cost estimates used both in the ARC proposal and the FAA proposal can be seen in Table B - 1 below and are described in further detail within the Pilot Professional Development Regulatory Evaluation. **Table B -**  **1: Labor Cost Estimates**  **Used in ARC Cost Analysis**
**Labor Category Wage**  **Rate 22**  

### Fa **ctor for**

**Employer Provided**  **Benefits 23**  

### Factor for

**Change Over**  **Time 24**  

### Total

**Compensation Costs**  **Unit of**

**time** Senior Management Person 25 

### $160 1.169 1.0065 $188 hourly Senior PIC $160 1.169 1.0065 $188 flight hour Average PIC $145 1.169 1.0065 $171 flight hour Senior SIC $94 1.169 1.0065 $111 flight hour Average SIC $89 1.169 1.0065 $105 flight hour New SIC $99 1.169 1.0065 $116 day Ground Training Instructor 26 

### $31 1.42 1 $44 hourly Professional Development Position 27 

### $150,000 1.42 1 $213,000 annual Per Diem 28 

### $123 1 1 $123 day

22 Ta ble A- 8. 23 Table A- 9. 24 Table A- 10. 25 The FAA determined that a senior management person would command an average hourly com pensation equal to that of a senior PIC. 26 Ground training instructor wage rate based on 2013 BLS Occupational Employment Statistics for Air Transportation Industry (http://www.bls.gov/oes/current/naics4_481100.htm): Training and Development Specialists (13 - 1151). 27 N ew wage category based on the ARC recommendations. 28 Fiscal Year 2013 Per Diem Rate is $77 for lodging and $46 for meals and incidental expenses for a total of $123. This is the standard continental United States rate. http://www.gsa.gov/portal/content/103168

### Pilot	Professional Development	Regulatory	Evaluation 81



## C. Benefits As with the proposed rule, the benefits of the training in the MLP ARC recommendations include an increased level of safety from mitigation of unprofessional pilot behavior which will reduce pilot error that can lead to a catastrophic event. The October 14 , 2004 crash of Pinnacle Airlines f light 3701 in Jefferson City, Missouri and the February 12 , 2009 crash of Colgan Air f light 3407 near Buffalo, New York are examples of past accidents where unprofessional pilot behavior contributed to the accident. Those particular accidents also involved technical flying mistakes. Unprofessional conduct can compromise a pilot’s ability to exercise the technical knowledge and skills required to safely operate the airplane under varying conditions. Therefore, the FAA cannot distinguish the mistakes due to lack of pilot professionalism from the mistakes due to other reasons. Further, the FAA cannot estimate relative effectiveness between the proposed rule and the ARC proposal. 

## D. Costs This cost analysis shows that the cost of the ARC proposal is substantially greater than the cost of the FAA proposal. The primary drivers of this cost difference are the full -time PDP for each operator and the longer amount of time required for leadership and command training for upgrading pilots and during PIC recurrent training. A provision by provision analysis of the costs of the ARC proposal is below.



## 1. **Create	a	Professional	Development	Position	(PDP)** The ARC recommended that every part 121 air carrier establish a full -time Professional Develop Position (PDP). An individual would need to have a bachelor’s degree and three years of part 121 experience as a pilot to qualify for the position. Responsibilities of the PDP would include modifying and developing all of the recommended training programs and managing the

### Pilot	Professional Development	Regulatory	Evaluation 82

PDSC. Consequently, hiring a person to fill the PDP would be among the first compliance costs to meet the ARC recommendations. This requirement would apply to the 78 carriers who operate under part 121. The cost for each operator to employ an individual in the PDP for the duration of the analys is period is calculated b y multiplying the salary for the PDP by

the number of affected operators for each ye ar of the analys is period. This calculation is shown in Table B - 3.



## 2. **Create	a	Professio nal	Development	Steering	Committee**  **(PDSC)	Program** The ARC recommended that each operator create a Professional Development Steering Committee (PDSC) for all pilots to help them reach their maximum potential as safe, seasoned, and proficient pilots. Although the ARC did not explicitly determine a number of committee members, the FAA believes that the PDSC would have four members (the PDP and 3 senior PICs). The FAA estimates that it would take the committee two days to establish a PDSC program (or 16 total hours for the individual serving in the PDP and 48 total senior PIC hours). This committee work would be part of the standard duties of the PDP and there would be no additional cost for his or her time. The FAA estimates that the part 121 air carriers woul d compensate the Senior PICs time on the PDSC as equivalent to the scheduled flight hours on a one -to - one basis. We assume that all of the members of the PDSC would be based where the committee would meet and, therefore, would receive no travel per diem. F inally, we assume the PDSC program would require minimal annual review and updating. This requirement would apply to the 78 carriers who operate under part 121. The cost to establish the PDSC is calculated by multiplying the senior PIC hours needed b y the senior PIC flight hour cost and number of carriers. This calculation is shown in Table B - 4.

### Pilot	Professional Development	Regulatory	Evaluation 83 

## 3. **Mentor	Training	for	All	PICs** The ARC recommended that all PICs be given mentoring training. The FAA assumed that the ARC recommendation was for the PICs to mentor both new-hire pilots and pilots taking a major step in their air carrier careers (e.g., promotion from SIC to PIC). On that basis, the FAA estimates that the mentor training program needed to satisfy this requirement would be a four hour computer program that would not require direct instructor-mentor involvement. 29 

### As previously

discussed, many

pilot management agreements specify that a pilot who is required to undertake training is guaranteed a minimum of four hours of flight time credit when he or she takes training that is not added onto an existing required training. The FAA therefore estimates the cost to be the cost of four flight hours for an average PIC. This cost would occur for all current PICs in the second year of analys is and for all new PICs in years three through ten. The cost to provide mentoring training to all PICs who use pilot training and qualification programs that comply

with part 121 is calculated b y multiplying the total number of PICs by four hours and the average PIC flight hour co st. This calculation is shown in Table B - 5.



## 4. **Hold	Quarterly	PDSC	Meetings** The ARC recommended the creation of a PDSC that would meet quarterly and would be under the leadership of the individual serving in the PDP. The FAA also assumes that the ARC intended that each meeting would take one day (or 32 total hours for the individual serving in the PDP and 96 total senior PIC hours). As noted, the participation of the individual serving in the PDP would be part of his or her standard duties and his or her time would not be an incremental compliance cost. All other participants would be paid on the basis of a one flight hour for one meeting hour.

29 The 4 hour mentor training wo uld com bine the mentoring training to mentor new-hire pilots and the mentoring training to mentor SICs becoming PICs.

### Pilot	Professional Development	Regulatory	Evaluation 84

Thus, a PDSC would meet for a total of 128 labor hours a year, but only the 96 of them accrued b y the PICs would b e an incremental cost of the ARC proposal. We also assume that all of the members of the PDSC would be based where the committee would meet and would receive no travel per diem. This requirement would apply to the 78 carriers who operate under part 121. The cost for the quarterly PDSC meetings is calculated b y multiplying the senior PIC hours needed b y the corresponding flight hour cost and number of carriers and summed for the relevant ye ars of the analysis period. This calculation is shown in Table B - 6.



## 5. **Additional	Indoctrination	Training	for	New -**  **Hire	Pilots** The ARC recommended that an operator provide new-hire pilots with additional indoctrination training specific to that operator that would ensure that the indoctrination training accommodates different levels and types of flight experiences of the new-hire pilots. The FAA estimates that this recommended training would be a two hour add- on to the current indoctrination training class time. The costs of this requirement would be the instructor and SIC trainee compensation . The instructor would be paid for the two hours of classroom time for each class. SIC trainees are ty pically paid a monthly

salary . To estimate the value of the two hours of SIC training time we divide the monthly

salary by 30 to estimate a daily cost for an SIC’s trainee’s time. These additional two hours of training time are then estimated to cost one - fourth of that daily cost estimate. There would be no additional travel per diem for this two hour extra segment because they are already at the site receiving other training. The FAA assumes that there would be 20 trainees in the average indoctrination class. The annual cost for the additional indoctrination training for all SICs who use pilot training and qualification programs that comp ly with part 121 is calculated in two parts: first, by multiplying the total number of new pilots by the

### Pilot	Professional Development	Regulatory	Evaluation 85

corresponding daily

cost and one - quarter day of training and second, b y multiplying the total number of ground training classes b y the hourly cost of ground instructor time and two hours of classroom time. This calculation is shown in Table B - 7.



## 6. **Familiarization	Flights	for	New -**  **Hire	Pilots** The ARC recommended that an operator provide at least one familiarization flight to each new-hire pilot to observe operations and company procedure from the flight deck observer seat. This recommendation is adopted in the proposed rule. The new-hire pilot would receive compensation for one training day and a single day

of per diem . We do not estimate any cost for incre ased fuel burn due to the SICs weight. The cost for the familiarization flights for all SICs who use pilot training and qualification programs that comply with part 121 is calculated in two parts. First, b y multiplying the total number of new pilots by the corresponding daily training wage rate and one training day and second, by

multiplying the total number of new pilots by the per diem rate for one day. This calculation is shown in Table B - 8. The estimated cost for this provision is the same as the cost reported for it under the proposed rule.



## 7. **32	Hours	of	Leadership	and	Command	Training	for	SICs Upgrading	to	PIC**  The ARC recommended that an operator provide 32 additional hours of leadership and command training to SICs being promoted to PIC. The costs of this requirement would be the compensation for the PICs and the instructors. In general, the currently employed SICs would receive one hour of flight hour credit for every two hours spent in training. Thus, each trainee would receive 16 hours of flight time credit for the 32 hours of training. Each trainee would also receive four days of per diem .

### Pilot	Professional Development	Regulatory	Evaluation 86

The instructor would require 32 hours of compensation for each class . The FAA assumed that there are 20 students in the average SIC upgrading to PIC class . The c ost for this training for all upgrading pilots who use pilot training and qualification programs that comply with part 121 is calculated in three parts. First, by multiplying the number of upgrading SICs by their corresponding flight hour cost and the 16 f light hours needed; second, b y multiplying the number of upgrading SICs by

the per diem rate for four days; and third, by multiplying the number of ground training classes (assuming a class size of 20) by the ground instructor hourly cost and 32 hours of c lassroom time. This calculation is shown in Table B - 9.



## 8. **Include	Leadership	and	Command	in	Recurrent	PIC	Training** The ARC recommended that an operator include leadership and command in PIC recurrent training classes and that the topic should be covered in a four year cycle. The ARC did not specify

the number of training hours for the leadership and command training but the FAA assumes that it would be the same 32 hour curriculum developed for upgrading pilots. The ARC did specify

that each element of the curriculum should be presented at least once during a four ye ar cycle. To simplify

the calculations, the FAA assesses the requirement to be eight hours every year for each PIC taking recurrent training. The costs of this requirement would be the compensation of the PICs and the instructors and one day of per diem for each PIC. Pilots are, on average, given one hour of flight hour credit for every two hours in training. The instructor would receive eight hours of compensation for each class . The FAA assume s that there are 20 students in the average PIC recurrent training class . The cost for the additional recurrent training for PICs who use pilot training and qualification programs that comply with part 121 is calculated in three parts. First, b y multiplying the number of PICs taking recurrent training b y their corresponding flight hour cost and four flight hours; second, by multiplying the

### Pilot	Professional Development	Regulatory	Evaluation 87

number of PICs by

the per diem rate for one day ; and third, by multiplying the number of ground training classes needed by the ground instructor hourly cost and 8 hours of classroom time. This calculation is shown in Table B - 10.



## 9. **Total	Cost	of	ARC	Proposal** Based on the above provisions, the total cost of the ARC proposal, as derived in Tables B - 3 through B - 11 is presented in Table B - 2 below. **Table B -**  **2: Total and Present Value Compliance Costs for the ARC Proposal by Provision (2015 -**  **2024)***

**Cost Total Compliance Costs**  **(Millions of 2013 Dollars)**

**Present Value Proposed Provision**  **Total 7 Percent**  **3 Percent** Create a Professional Development Position (Table B - 3) $166.140 $109.056 $137.593 Create a PDSC Program (Table B
- 4) $0.704 $0.615 $0.663 Mentor Training for All PICs (Table B
- 5) $37.084 $27.899 $32.651 Hold Quarterly PDSC Meetings (Table B
- 6) $12.670 $8.011 $10.332 Additional Indoctrination Training for New
- Hire Pilots (Table B
- 7) $0.656 $0.399 $0.526 1 or More Familiarization Flights for New
- Hire Pilots **(Table B
- 8) $4.693 $2.855 $3.766 32 Hours of Training for SICs Upgrading to PIC (Table B
- 9) $39.026 $23.745 $31.318 Recurrent PIC Training (Table B
- 10) $238.295 $144.987 $191.233

**Total $499.267**  **$317.567 $408.083**  ***Table values have been rounded. Totals may not add due to rounding.**  ***** ***** **FAA estimate is for 2 operating cycles**  **.**



## 10. **Appendix	B	Supporting	Tables** The following tables support the above discussion and calculations:

### Pilot	Professional Development	Regulatory	Evaluation 88

**Tab le**  **B- 3**  ARC PROPOSAL: COST FOR PDP PE RSON **Hi re**  **a N ew** **P rof** **es siona**  **l De**  **ve lopment**  **Position unde r P**  **art 119 YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TAL Number o f Carri ers Req ui ri ng a PDP 1 78 78 78 78 78 78 78 78 78 78 PDP Sal ar y 2 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 $213, 000 Number o f PDPs needed 3 1 1 1 1 1 1 1 1 1 1 PDP Cost ( Mi llion s $) 4 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $16. 614 $166. 140 **Total (**  **Millio ns**  **$) 5**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$16. 614**  **$166. 140**  PV 7 P erce nt $14. 511 $13. 562 $12. 675 $11. 846 $11. 071 $10. 346 $9. 669 $9. 037 $8. 446 $7. 893 $109. 056 PV 3 P erce nt $15. 660 $15. 204 $14. 761 $14. 331 $13. 914 $13. 509 $13. 115 $12. 733 $12. 362 $12. 002 $137. 593 1: N umberofpart 1 21 an d 121/ 135 ca rri ers who wo uld be re quired to hire a PD P. 2: Es ti ma te d an nual P DP sal ary( Tabl e B- 1) . 3: Es ti ma te d numbe r ofP DP s need ed p ercarri er . 4: P DP cost, cal cu la te d by multi plyingthe numbe r ofcarri ers by the es ti amte d PDP sal ary and the es ti ma te d numbe r ofP DPs percarri er( fo otnotes 1, 2, an d 3 ). 5: The t otal cost to hi re a P DP .

### Pilot	Professional Development	Regulatory	Evaluation 89 **Tab le**  **B- 4**  AR C PR OPOSAL : FIR ST-Y EA R S EN IOR PIC COST TO DEV ELO P THE P DS C **Es tabl**  **is h PD** **SC Progra**  **m Yea**  **r = 2 015**  **Cost:** Number o f Car riers Req ui

rin g a PDSC 1 

### 78 Seni or P IC Cost per Fl

ig ht Ho ur 2 

### $188 Fl ig ht Ho ur s Req ui red 3 

### 48 Re vi ew Ti me f or

C ommi tte e (M illio ns $) 4 

### $0. 704 **To ta**  **l (M**  **illio ns**  **$) 5**  

### $0. 704 PV 7 Perce nt $0. 615 PV 3 Perce nt $0. 663

2: Es ti mate d seniorP IC co st pe r f lig ht hour ( Tab le B- 1) . 3: Es ti mate d flig ht hours re qui re d.

5: Th e total co st to es tbl is h the P DSC. 1: N umbe r ofp art 1 21 a nd 121/ 135 ca rri ers who woul d be re qui re d to es tabl is h a P DSC.
4: Re view ti me co st, cal cu la te d by mul ti pl yingt he n umbe r o f carri ers by the e sti mate d se ni or

P IC co st and the e sti mate d hours re qui re d (footnote s 1, 2, a nd 3) .

### Pilot	Professional Development	Regulatory	Evaluation 90

**Tabl e**  **B- 5**  AR C PR OPOSAL : ME NTORI NGI NST RU CTI ON C OSTS FOR A LL P ICS **Me ntori**  **ng Trai**  **ning fo**  **r Al l**  **PICs YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number o f PICs 1



### - 37527 2057 2066 2073 2082 2091 2098 2107 2115 Avera ge PIC Cost per Fl

ig ht Ho ur 2 

### $171 $171 $171 $171 $171 $171 $171 $171 $171 $171 Tra in in g Ho ur

s Red uced 3 

### 0 8 8 8 8 8 8 8 8 8 Fl ig ht Ho ur s Red uced 4 

### 0 4 4 4 4 4 4 4 4 4 PIC Trai ne e Cost (M illio ns $) 5 

### $0. 000 $25. 668 $1. 407 $1. 413 $1. 418 $1. 424 $1. 430 $1. 435 $1. 441 $1. 447 $37. 084 **To tal**  **( Millio**  **ns $)**  **6** 

### $0. 000 $25. 668 $1. 407 $1. 413 $1. 418 $1. 424 $1. 430 $1. 435 $1. 441 $1. 447 $37. 084 PV 7 Pe rce nt $0. 000 $20. 953 $1. 073 $1. 008 $0. 945 $0. 887 $0. 832 $0. 781 $0. 733 $0. 687 $27. 899 PV 3 Pe rce nt $0. 000 $23. 490 $1. 250 $1. 219 $1. 187 $1. 158 $1. 129 $1. 100 $1. 072 $1. 045 $32. 651 1: N umbe r ofP ICs re ce ivingm ent ori ng trai ning (Tabl e A-2 ). 2: Esti mate d av er age P ICco st per f lig ht hour ( Tab le B- 1) . 3: Esti mate d trai ni ng hours re qui re d. 4: Esti mate d f lig ht hours re qui re d, e qui va len t to 1/ 2 oftrai ni ng hours ( fo otnote 3) . 6: The total cos t to trai n PICs in me ntori ng. 5: P ICt rai ne e co st, cal cu la te d by mul ti plyingthe n umbe r o f PICs by the e sti mate d av erage P IC co st and the e sti mate d flig ht hours re qui re d ( fo otnote s 1, 2, and 4) .

### Pilot	Professional Development	Regulatory	Evaluation 91

**Tab le**  **B- 6**  AR C PR OPOSAL: PD SC ME ETI NG C OSTS **PD SC**  **Qua rte**  **rl y**  **Meet in**  **gs Cost YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number o f Carri ers Req ui rin g a PDSC 1

- 78 78 78 78 78 78 78 78 78 Seni or P IC Cost per Flig ht Ho ur 2 $188 $188 $188 $188 $188 $188 $188 $188 $188 $188 Fl ig ht Ho ur s Required 3 0 96 96 96 96 96 96 96 96 96 PD SC Te am M eet ing Ti me C ost (M illio ns $) 4 $0. 000 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $12. 670 **Total (**  **Mi llions**  **$) 5**  $0. 000 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $1. 408 $12. 670 PV 7 P erce nt $0. 000 $1. 149 $1. 074 $1. 004 $0. 938 $0. 877 $0. 819 $0. 766 $0. 716 $0. 669 $8. 011 PV 3 P erce nt $0. 000 $1. 288 $1. 251 $1. 214 $1. 179 $1. 145 $1. 111 $1. 079 $1. 047 $1. 017 $10. 332 1: N umbe r o f pa rt 12 1 an d 1 21/ 135 ca rri ers who woul d be re qui re d to e st abl is h a P DS C. 2: Es ti ma te d se ni or

PI C co st pe r f lig ht hour (Tabl e B- 1) . 3: Es ti ma te d flig ht hours re quir ed . 5: To tal co st forP DS C me et ing ti me . 4: Es ti ma te d PD SC te am me et ing co st, cal cu la te d by mul ti plying the n umbe r ofcarri ers by the s en iorP IC co st pe r f lig ht hour an d the f lig ht hours re quir ed (footnote s 1, 2, an d 3) .

### Pilot	Professional Development	Regulatory	Evaluation 92

**Tab le**  **B- 7**  ARC PR OPOSAL : RECU RRI NGC OSTS FOR THE A DDITIONA L I ND OCT RI NAT ION CLASS TI MEF OR N EWLY- HI RED P ILOTS **Additi onal**  **I ndoctri**  **na ti**  **on Trai ning**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number o f Ne w -Hire S ICs 1



### - - 2420 2431 2439 2450 2460 2468 2479 2489 Ne w SIC Cost per Da y 2 

### $116 $116 $116 $116 $116 $116 $116 $116 $116 $116 Da ys Req ui

red 3 

### 0 0 0. 25 0. 25 0. 25 0. 25 0. 25 0. 25 0. 25 0. 25 SIC Trai nee Cost (M illio ns $) 4 

### $0. 000 $0. 000 $0. 070 $0. 070 $0. 071 $0. 071 $0. 071 $0. 072 $0. 072 $0. 072 $0. 569 Number o f Classes 5



### - - 121 122 122 123 123 123 124 124 Instructor Cost per Ho ur 6 

### $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Ho urs per Cla ss 7 

### 0 0 2 2 2 2 2 2 2 2 SIC Instr uctor Cost (M illio ns $) 8 

### $0. 000 $0. 000 $0. 011 $0. 011 $0. 011 $0. 011 $0. 011 $0. 011 $0. 011 $0. 011 $0. 086 **Total (**  **Mi llions**  **$) 9**  

### $0. 000 $0. 000 $0. 081 $0. 081 $0. 081 $0. 082 $0. 082 $0. 082 $0. 083 $0. 083 $0. 656 PV 7 P erce nt $0. 000 $0. 000 $0. 062 $0. 058 $0. 054 $0. 051 $0. 048 $0. 045 $0. 042 $0. 039 $0. 399 PV 3 P erce nt $0. 000 $0. 000 $0. 072 $0. 070 $0. 068 $0. 067 $0. 065 $0. 063 $0. 062 $0. 060 $0. 526 1: Th e numbe r o f ne w-h ire SIC s (Tabl e A-2 ). 2: Es ti mate d dai ly trai ni ngco st f or ne w SICs (Tabl e B- 1) . 3: Es ti mate d numbe r o f trai ning days re quired . 4: N ew -hi re S IC co st, cal cul ate d by mul ti pl ying the numbe r o f ne w-h ire SIC s by the d ai ly co st and the n umber of days re quired ( footnote s 1, 2, an d 3) . 5: N umbe r o f cl asses ne eded base d on an e sti mate d cl ass si ze of 20 pilo ts and the numbe r o f pi lo ts i n ne ed o f trai ni ng (fo otnote 1) . 6: Es ti mate d instr uctor co st pe r h our( Tabl e B- 1) . 7: Es ti mate d instr uctor hours re qui re d pe r cl ass.
9: Th e total co st, cal cu la te d by sumi ng the S IC trai ne e co st and i nstructor co st (fo otnote s 4 a nd 8) . 8: I nstructor cost, cal cu la te d by mul ti pl ying the n umbe r o f cl asse s re qui re d by the i nstructor co st pe r h ourand the n umber of instructor h ours re qui re d pe r cl ass ( footnote s 6, 7, an d 8) .

### Pilot	Professional Development	Regulatory	Evaluation 93

**Tabl e**  **B- 8**  AR C PR OPOSAL : REC UR RI NGC OST FOR 2 FAM IL IAR IZAT IO N FL IG HTSF ORN EWLY- HI RE D P ILOTS **2 SIC Fa**  **mi lia**  **ri zati**  **on Flig**  **hts YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number o f Ne w-Hire S ICs 1



### - - 2420 2431 2439 2450 2460 2468 2479 2489 Ne w SIC Cost per Da y 2 

### $116 $116 $116 $116 $116 $116 $116 $116 $116 $116 Da ys Req ui

red 3 

### 0 0 1 1 1 1 1 1 1 1 SIC Trai nee Cost (M illio ns $ ) 4 

### $0. 000 $0. 000 $0. 281 $0. 282 $0. 283 $0. 284 $0. 285 $0. 286 $0. 288 $0. 289 $2. 278 Per Diem 5 

### $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Da ys Req ui

red 6 

### 0 0 1 1 1 1 1 1 1 1 Per Di em C ost (M illio ns $) 7 

### $0. 000 $0. 000 $0. 298 $0. 299 $0. 300 $0. 301 $0. 303 $0. 304 $0. 305 $0. 306 $2. 415 **To tal**  **( Millions**  **$) 8**  

### $0. 000 $0. 000 $0. 578 $0. 581 $0. 583 $0. 586 $0. 588 $0. 590 $0. 592 $0. 595 $4. 693 PV 7 Perce nt $0. 000 $0. 000 $0. 441 $0. 414 $0. 388 $0. 365 $0. 342 $0. 321 $0. 301 $0. 283 $2. 855 PV 3 Perce nt $0. 000 $0. 000 $0. 514 $0. 501 $0. 488 $0. 476 $0. 464 $0. 452 $0. 441 $0. 430 $3. 766 1: Th e numbe r o f ne w- hi re S ICs (Tabl e A-2 ). 2: Es ti mate d dai lyt rai ning co st for n ewS ICs ( Tab le B- 1) . 3: Es ti mate d numbe r o f trai ni ngd ay s re qui re d.
5: Th e pe r d iem rate ( Tabl e B- 1) . 6: N umbe r o f trave l day s for w hi ch a p er

di em w oul d be n ec essa ry . 7: P er d iem co st, cal cu la te d by mul ti plyingt he per d iem rate b y the n umbe r ofd ay s re qui re d (fo otnote s 5 an d 6) . 8: Th e total co st, cal cu la te d by summi ng the S IC trai ne e co st an d the p er di em co st (fo otnote s 4 an d 7) . 4: N ew -hire SIC co st, cal cu la te d by mul ti plyi ng the n umbe r o f ne w-hi re S ICs by the dai lyco st and the n umbe r o f day s re qui re d (footnote s 1, 2, an d 3) .

### Pilot	Professional Development	Regulatory	Evaluation 96 **Tabl e**  **B- 9**  AR C PROPOSAL : RECU RRINGC OSTS FOR 32HOURS OF COM MA NDA ND LEADERSHI P TRAININGCOSTS FOR SICS BEING PROM OT ED TO P IC **Pr ovide**  **32 Ho urs Le**  **ade rship and Command Training to SICs Upgrading to PICs**  **YE AR**  2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number of Upgrading SICs 1

- - 2057 2066 2073 2082 2091 2098 2107 2115 Senior SIC Cost per Flight Hour 2 $111 $111 $111 $111 $111 $111 $111 $111 $111 $111 Train in g Hours Requi

red 3 32 32 32 32 32 32 32 32 32 32 Fl ig ht Ho ur s Requi red 4 16 16 16 16 16 16 16 16 16 16 SIC Up gradi ng Trai nee Cost (M illio ns $) 5 $0. 000 $0. 000 $3. 653 $3. 669 $3. 682 $3. 698 $3. 714 $3. 726 $3. 742 $3. 756 $29. 640 Per Diem 6 $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Days Requi

red 7 0 0 4 4 4 4 4 4 4 4 Per Di em C ost (M illio ns $) 8 $0. 000 $0. 000 $1. 012 $1. 016 $1. 020 $1. 024 $1. 029 $1. 032 $1. 037 $1. 041 $8. 211 Number of Cl

asses 9

- - 103 103 104 104 105 105 105 106 Instructor Cost per Hou r 10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Hour

s per Cla ss 11 0 0 32 32 32 32 32 32 32 32 SIC Instructor Cost ( Mi llio ns $) 12 $0. 000 $0. 000 $0. 145 $0. 145 $0. 146 $0. 147 $0. 147 $0. 148 $0. 148 $0. 149 $1. 175 **Total (**  **Millions $)**  **13** $0. 000 $0. 000 $4. 810 $4. 831 $4. 848 $4. 869 $4. 890 $4. 906 $4. 927 $4. 946 $39. 026 PV 7 P erce nt $0. 000 $0. 000 $3. 670 $3. 445 $3. 230 $3. 032 $2. 846 $2. 669 $2. 505 $2. 350 $23. 745 PV 3 P erce nt $0. 000 $0. 000 $4. 274 $4. 167 $4. 060 $3. 959 $3. 860 $3. 760 $3. 666 $3. 573 $31. 318 1: Es ti mate d numbe r o f SICs upgradi ng to PIC (Tabl e A-2 ). 2: Es ti mate d s enior

SIC cost per fl ight hour (Tabl e B-1 ). 3: Es ti mate d numbe r o f trai ning hours re quired. 4: Es ti mate d numbe r o f flig ht hours re qui re d, eq ui val ent to 1/ 2 oftrai ni ng hours re quired (footnote 3) . 6: Th e per

di em rate ( Tabl e B-1 ). 7: N umber oftrave l days f or w hic h a pe r d iem would be necessary. 8: Pe r d iem co st, cal cul ate d by mul ti pl ying the per diem rate byth e numbe r ofdays re quired (footnote s 6 an d 7) . 9: N umber ofgro und cl asses nee de d base d on an e sti mate d cl ass si ze of20 p ilo ts an d the numbe r o f pi lo ts in ne ed of trai ning (fo otnote 1 ). 10: Esti mated ground i nstructor cost per hour (Tabl e B-1 ). 11: Esti mated ground i nstructor hours requi red per cl ass.
13: The total cost, cal cu la ted by summing the SI C u pgradi ng trai ne e co st, the per d iem cost, and the SIC i nstructor cost (footnote s 5, 8, an d 12) . 5: SI C u pgradi ng trai ne e co st, cal cul ate d by mul ti pl ying the numbe r o f upgradi ng pi lots by the f light hour cost and the n umbe r o f flig ht hours re quired (fo otnotes 1, 2, and 4) .

12: Grou nd instructor cost, cal cu la te d by mul ti plying the number of ground cl asse s re quired b y the ground i nstructor cost pe r hour and the n umbe r o f ground i nstructor hours re quired p er cl as s ( fo otnotes 9, 10, and 1 1) .

### Pilot	Professional Development	Regulatory	Evaluation 97

**Tabl e**  **B- 10**  ARC PROPOSAL: RECU RRINGCOSTS FOR 8 ADDITIONAL HOU RS FOR P IC RECU RREN T TRA INING **PIC Le**  **ade rshi**  **p and Command 8 Hours Re curre**  **nt Training YE** **AR** 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TO TA L Number of PICs Receivin g Recurrent Tra in in g 1

- - 35620 35762 35906 36049 36193 36339 36484 36630 PIC Cost per Fl

ig ht Hou r 2 $171 $171 $171 $171 $171 $171 $171 $171 $171 $171 Tra in in g Hours Required 3 0 0 8 8 8 8 8 8 8 8 Fl ig ht Hour s Requ ired 4 0 0 4 4 4 4 4 4 4 4 PIC Trai ne e Cost (M illions $) 5 $0. 000 $0. 000 $24. 364 $24. 461 $24. 560 $24. 658 $24. 756 $24. 856 $24. 955 $25. 055 $197. 664 Per Diem 6 $123 $123 $123 $123 $123 $123 $123 $123 $123 $123 Da ys Req ui

red 7 0 0 1 1 1 1 1 1 1 1 PerDi em Co st (M illions $) 8 $0. 000 $0. 000 $4. 381 $4. 399 $4. 416 $4. 434 $4. 452 $4. 470 $4. 488 $4. 505 $35. 545 Number of Cl

asses 9

- - 1781 1788 1795 1802 1810 1817 1824 1832 Instructor Cost per Hour 10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44 Instructor Hours per Cl

ass 11 0 0 8 8 8 8 8 8 8 8 PIC Instructor Cost (M illio ns $ ) 12 $0. 000 $0. 000 $0. 627 $0. 629 $0. 632 $0. 634 $0. 637 $0. 640 $0. 642 $0. 645 $5. 086 **Total (**  **Mi llions $** **) 13**  $0. 000 $0. 000 $29. 372 $29. 489 $29. 608 $29. 726 $29. 845 $29. 965 $30. 085 $30. 205 $238. 295 PV 7 P erce nt $0. 000 $0. 000 $22. 408 $21. 025 $19. 729 $18. 512 $17. 370 $16. 299 $15. 294 $14. 350 $144. 987 PV 3 P erce nt $0. 000 $0. 000 $26. 097 $25. 438 $24. 796 $24. 170 $23. 560 $22. 966 $22. 386 $21. 821 $191. 233 1: Es timated number of PICs (Tabl e A-2 ). 2: Es timated PIC cost perf light hour (Tab le B- 1) . 3: Es timated number of trai ni ng hours re qui re d. 4: Es timated number of flig ht hours re quire d, e quiva len t to 1/2oft rai ning hours re qui re d (footnote 3 ).
6: The pe r di em rate ( Tabl e B- 1) . 7: N umber of trave l da ys for which a pe r di em would be n ec essary. 8: P erdi em co st, cal cul ate d by mul tiplying the per di em rate by the numbe r ofdays re qui re d ( footnotes 6 a nd 7 ). 9: N umber of ground classe s ne eded ba sed on an e stimate d cl ass si ze of 20 p ilo ts an d the number of pilots in ne ed o f trai ning (footnote 1) . 10: Es timate d ground i nstr uctor cost pe r h our (Tabl e B-1 ). 11: Es timate d ground i nstr uctor hours re quired p ercl ass. 13: The t otal co st, cal cul ate d by summi ng the P IC trai nee cost, the pe r di em co st, and the PIC in structor cost ( footnote s 5, 8, and 1 2) . 5: P IC trai nee cost, cal cul ate d by mul tiplying the number of upgrading pi lo ts by the f lig hthour cost and the numbe r off lig ht hours re qui re d (footnotes 1, 2, and 4) .

12: Grou nd instr uctor cost, cal cul ate d by mul ti pl ying the numbe r ofg ro und cl asses re quir ed by the ground i nstr uctor cost pe r h our and the numbe r of gro und in structor hours re quir ed per cl ass (footnotes 9, 10, an d 1 1) .