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 TRANSPORTATION SYSTEMS CENTER

ECONOMIC ANALYSIS DIVISION

OFFICE OF THE ASSISTANT SECRETARY OF TRANSPORTATION 

FOR RESEARCH AND TECHNOLOGY

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

VIII. 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 pilots with operations 

familiarization; and establish Pilot Professional Development Committees. This rulemaking 

applies to part 121 air carriers as well as part 135 operators required to use pilot training and 

qualification programs that comply with part 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 Committees (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 flight 3701 in Jefferson 

City, Missouri, and the February 12, 2009, crash of Colgan Air flight 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 Rule. The recent Pilot Certification final rule ensured technical 

proficiency in those subjects via other means.1These 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.

Executive 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 (onetime 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 Certification 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-requirementsfor-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 savings benefits created by the proposed rule, by 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

(Millions 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 analyzed 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 by 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 analysis 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. Background

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 unprofessionally 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 pilots’ failure to comply with the sterile flight deck rule as factors 

in multiple accidents and incidents including Pinnacle Airlines flight 3701 (October 14, 2004) 

and Colgan Air flight 3407 (February 12, 2009).

The Colgan Air accident2focused 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 deck

rule.3

B. Accident	History	Related	to	the	Proposed	Rule	

The following accidents exemplify the types 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 benefits 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 Flight 

3701) Bombardier CL-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 

destroyed.

The NTSB concluded that the probable causes 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 scenarios; 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 Pinnacle 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 styles. 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, “Loss of Control on Approach, Colgan Air, Inc. Operating as Continental 

Connection Flight 3407 Bombardier DHC-8-400, N200WQ Clarence Center, New York, February 12, 2009.” 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 by 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 CFR part 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 91K 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 91K 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: Develop 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	(Public 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 Rulemaking Committee (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 association 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.

Section 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.
Pilot	Professional	Development	Regulatory	Evaluation 12

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, leadership and command ground training for current PICs

 Mentoring, leadership, and command recurrent training for PICs

 Pilot Professional Development Committees (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 complete 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 required 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 best 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 type 

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 analysis are as follows:
Pilot	Professional	Development	Regulatory	Evaluation 15

 Discount Rates:

8

7% and 3%

 Period of Analysis: 2015-2024

 Monetary values expressed in 2013 dollars

 Discounting calculations use 2013 as the base year

The FAA analyzed the expected costs of the proposed regulatory option over a 10-year 

period. To simplify the computational analysis, we assumed that the final rule would be issued 

on January 1, 2015. Thus, this analysis covers the years 2015 through 2024. The first year (2015)

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 (2016), the current PICs would receive mentoring, leadership, and command 

training so that by the compliance date of January 1, 2017, all PICs receive the required training. 

From 2017 through the rest of the analysis 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 Transport Pilot (ATP) certificate holders from U.S. Civil Airman Statistics.9This data 

 

8 Office of Management 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 60-64. 

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 year since the 

mandatory retirement age is 65. We assume this estimated retirement rate remains constant over 

the analysis 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 part 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 been 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 Type 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 year.

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 In addition, 

part 135 operators conducting commuter operations in airplanes type 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 

Information Subsystem (NVIS) database in August of 2014. There are 66 air carriers that operate 

exclusively part 121 operations and 12 air carriers 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, we 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 by the proposed rule.

The FAA identified three part 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 analysis assumes that all pilots for these three operators 

would be affected by 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 10-year time period of this analysis.

This data, and the changes over time described in Section 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 Category Year Annual 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 Sections

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 pilots 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 of time from an individual who is already employed. Therefore, some employerprovided 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. Employer Costs for Employee Compensation – September 2013. 

http://www.bls.gov/news.release/pdf/ecec.pdf
Pilot	Professional	Development	Regulatory	Evaluation 20

worked by 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 by 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 2012, 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 $31,

14 which is 

approximately $44 after applying the 1.42 benefits multiplier.

The per diem cost allotted for pilot training based on the General Services Administration 

(GSA) Rate is $123.

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 Rates 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 PPDCs 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 Crew Resource Management (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 decisionmaking. 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 of pilots behaving unprofessionally and place the 

airplane at risk, helping 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 by the proposed rule. However, the qualitative benefits 

of each of the proposed provisions are discussed in Section 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 compromise 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 Public 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 Resource 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 would.”
Pilot	Professional	Development	Regulatory	Evaluation 23

substantially different levels and types of experience." The MLP ARC recommended 

amendments to the part 121 training content requirements and 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 by 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 cycles while occupying the flight deck 

observer seat before serving in part 121 operations.

17 In order to achieve the operations 

familiarization goals, the FAA believes that a minimum of two operating cycles are necessary to 

provide the newly employed pilot 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). In addition, two 

operating cycles may allow the newly employed 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 processes 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 by 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 by PICs, 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 upgrade 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	Requirements	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 by § 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 ensure 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 

curriculum (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

Additionally, 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 flight training to develop a robust upgrade curriculum specific to their operations 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, types 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 larger 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 certificate 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 by 

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 by 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 proposed 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 A3 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 specify 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 by 

removing the generic knowledge elements and reducing 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 by § 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 employing 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 subjects 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 practical 

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, 

including instrument approach 

procedures;

 Normal and emergency communication 

procedures;

 Visual cues prior to and during descent 

below DA/DH or MDA;

 Crew 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;

 The 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 complexities, kinds and types 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, 

based 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 believes 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 by 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 based on a class size of 20 pilots per class.

As an example of this calculation, in 2015 an estimated 37,714 SICs will complete 

recurrent ground training and as a result approximately 1,886 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 $83,000 in 2015 (1,886 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 PICs and SICs is 

calculated by 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 $1.980 million for 2015 (37,714 x 1⁄2 x $105 per 

flight hour x 1 hour). The full calculations are shown in Tables 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 type 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 by § 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 procedures) 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 proposed 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;

 Meteorology;

 Air 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;

 Crew resource 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 times 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 types and complexities, kinds and types 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 of training time reduction that will 

result from the revised curriculum. However, based on FAA experience of approving and 

surveilling upgrade training curriculums, the FAA estimates that on average the replacement of 

the current upgrade ground training subjects 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 psychomotor 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 Current § 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; 

 Recovery 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; 

 Recovery from full stall and stick 

pusher activation;

 Seat dependent maneuvers and 

procedures;

 Duty position maneuvers and 

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 

manual 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 each 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. Instead, 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 upgrading 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 because 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 year 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 2,051 upgrading pilots. The cost savings for pilot time is estimated to 

be $1.821 million in 2017 (2,051 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 year. In 2017, the per diem 

costs are estimated to be $0.505 million (2,051 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 year by 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 2,051 upgrading pilots is 

expected to be $0.072 million (2,051 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 Savings (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 $72 million over a 10-year period. When

discounted using a 7 percent discount rate, the proposed rule would result in cost savings of $46

million over a 10-year 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 types 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 year 

as the pilot work force evolves over time and to operate the PPDC.

A. Operations	Familiarization

The proposed rule 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-year 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 also 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 pilot time related to this provision by multiplying the total 

the number of newly hired SICs each year by 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 $0.281 million for 2017. The estimated cost 

of additional per diem payments is calculated by multiplying the number of newly hired SICs 

each year by 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 analysis 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 (2017-2024)*

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 procedures, 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 instructor 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 80 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 estimates 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 compensation 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 by 

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, based 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 pilots 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 type 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 year 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 $913,000 (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 $253,000 (2,057 x $123 per day x 1 day). The 2,057 SICs upgrading to PIC will involve 

approximately 103 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 $36,000 (103 classes x $44 per hour x 8 

hours). The total 2017 cost is approximately $1,203,000 ($913,000 + $253,000 + $36,000).

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 (2015-2024)*

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 by 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. Therefore, 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 

LOFT 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 certain 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 by all current PICs, the FAA used the flight hour cost for average PICs 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 of 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 which 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 does not prescribe a certain number of hours for the recurrent 

training of PICs in mentoring, leadership, and command. However, based 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 by the proposal to be provided every three years. 

Therefore, for the purposes of this analysis, the FAA assesses this cost as one training hour per 

year. 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 flight 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 1,781 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 (1,781 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 (2015-2024)*

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 requirements 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. Meeting 

once a year 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 carriers may opt to have the PPDC meet more frequently 

or for longer duration to maximize the effectiveness of the PPDC. 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 year. 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 year).

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 (2017-2024)

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: Recordkeeping 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 $68 million over the 10-year analysis period. 

When discounted using a seven percent discount rate, the present value of the costs is $47

million.
Pilot	Professional	Development	Regulatory	Evaluation 49

Table 14: Compliance Cost by Proposed Provision (2015-2024)*

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 year. 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-year cycle suggesting that the recurrent training would 

then need to be eight hours per year 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 by 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 after 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-year analysis beginning in 2015, with a base year of 2013 dollars, analyzes 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 by 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-year period based on changes to ground training in this proposal that are 

possible due to changes already implemented in the Pilot Certification 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 discount rate, the proposed 

rule would result in cost saving benefits of $46 million over a 10-year period.

As described in Section V above, the FAA believes the proposed rule would result in 

costs to operators of approximately $68 million over a 10-year period. When discounted using a 

7 percent discount rate, the proposed rule would result in costs of $47 million over a 10-year 

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

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.
Pilot	Professional	Development	Regulatory	Evaluation 53

VIII. Appendix	A:	Supporting	Tables

Table A-1

NUMBERS OF PILOTS BY OPERATOR (August 2014)

 Part 121 Operator Type PICs SICs Total Carrier Count

ABX AIR INC 121 127 127 254 1

AEKO KULA INC 121 15 11 26 1

AERO MICRONESIA INC 121 7 5 12 1

AERODYNAMICS INC 121 5 3 8 1

AIR TRANSPORT INTERNATIONAL INC 121 69 66 135 1

AIR WISCONSIN AIRLINES CORPORATION 121 394 375 769 1

ALASKA AIRLINES INC 121 752 718 1470 1

ALLEGIANT AIR LLC 121 200 200 400 1

AMERICAN AIRLINES INC 121 3559 4201 7760 1

AMERIJET INTERNATIONAL INC 121 26 24 50 1

AMERISTAR AIR CARGO INC 121 18 6 24 1

ATLAS AIR INC 121 375 700 1075 1

AVIATION SERVICES LTD 121/135 3 2 5 1

CARIBBEAN SUN AIRLINES INC 121 17 15 32 1

CENTURION AIR CARGO INC 121 20 34 54 1

CHAMPLAIN ENTERPRISES INC 121 137 120 257 1

CHAUTAUQUA AIRLINES INC 121 292 279 571 1

COMPASS AIRLINES LLC 121 257 281 538 1

DELTA AIR LINES INC 121 4871 5784 10655 1

DYNAMIC AIRWAYS LLC 121 25 15 40 1

ELITE AIRWAYS LLC 121 12 5 17 1

EMPIRE AIRLINES INC 121/135 100 23 123 1

ENDEAVOR AIR 121 892 899 1791 1

ENVOY AIR INC 121 1063 1164 2227 1

ERA AVIATION INC 121 30 27 57 1

EXPRESSJET AIRLINES INC 121 2355 2184 4539 1

FALCON AIR EXPRESS INC 121 27 18 45 1

FEDERAL EXPRESS CORP 121 1884 2120 4004 1

FLORIDA WEST INTERNATIONAL AIRWAYS INC 121 14 19 33 1

FRONTIER AIRLINES INC 121 331 311 642 1

GOJET AIRLINES LLC 121 235 203 438 1

GREAT LAKES AVIATION LTD 121/135 60 17 77 1

GULF AND CARIBBEAN CARGO INC 121 25 23 48 1
Pilot	Professional	Development	Regulatory	Evaluation 54

Table A-1 (Continued)

NUMBERS OF PILOTS BY OPERATOR (August 2014)

 Part 121 Operator Type PICs SICs Total Carrier Count

HAWAII ISLAND AIR INC 121 28 30 58 1

HAWAIIAN AIRLINES INC 121 300 272 572 1

HORIZON AIR INDUSTRIES INC 121 320 301 621 1

HYANNIS AIR SERVICE INC 121/135 269 66 335 1

JETBLUE AIRWAYS CORPORATION 121 979 1000 1979 1

KAISERAIR INC 121/135 20 18 38 1

KALITTA AIR LLC 121 100 150 250 1

KALITTA CHARTERS II LLC 121 22 19 41 1

KEY LIME AIR CORPORATION 121/135 34 5 39 1

LYNDEN AIR CARGO L L C 121 31 29 60 1

MESA AIRLINES INC 121 273 238 511 1

MIAMI AIR INTERNATIONAL INC 121 36 46 82 1

MN AIRLINES LLC 121 121 119 240 1

MOUNTAIN AIR CARGO INC 121/135 98 28 126 1

NATIONAL AIR CARGO GROUP INC 121 43 35 78 1

NORTHERN AIR CARGO INC 121 25 20 45 1

OMNI AIR INTERNATIONAL INC 121 88 83 171 1

ORANGE AIR LLC 121 5 2 7 1

PENINSULA AIRWAYS INC 121/135 43 40 83 1

PIEDMONT AIRLINES INC 121 230 275 505 1

POLAR AIR CARGO WORLDWIDE INC 121 2 0 2 1

PRESCOTT SUPPORT CO 121/135 8 10 18 1

PSA AIRLINES INC 121 283 462 745 1

REPUBLIC AIRLINES INC 121 599 513 1112 1

RHOADES AVIATION INC 121 4 2 6 1

SEABORNE VIRGIN ISLAND INC 121 37 30 67 1

SHUTTLE AMERICA CORPORATION 121 362 326 688 1

SIERRA PACIFIC AIRLINES INC 121 6 3 9 1

SILVER AIRWAYS CORPORATION 121 97 130 227 1

SKY LEASE I INC 121 32 50 82 1

SKYWEST AIRLINES INC 121 1399 1347 2746 1

SOUTHERN AIR INC 121 69 136 205 1

SOUTHWEST AIRLINES CO 121 3952 3680 7632 1
Pilot	Professional	Development	Regulatory	Evaluation 55

Table A-1 (Continued)

NUMBERS OF PILOTS BY OPERATOR (August 2014)

 Part 121 Operator Type PICs SICs Total Carrier Count

SPIRIT AIRLINES INC 121 456 448 904 1

SWIFT AIR L L C 121 12 12 24 1

TATONDUK OUTFITTERS LTD 121/135 25 22 47 1

TEM ENTERPRISES 121 14 8 22 1

TRANS STATES AIRLINES LLC 121 156 148 304 1

UNITED AIRLINES, INC. 121 4378 5743 10121 1

UNITED PARCEL SERVICE CO 121 1350 1340 2690 1

US AIRWAYS INC 121 2175 2392 4567 1

USA JET AIRLINES INC 121/135 38 19 57 1

VIRGIN AMERICA INC 121 320 320 640 1

VISION AIRLINES INC 121/135 26 22 48 1

WESTERN GLOBAL AIRLINES LLC 121 10 5 15 1

Type PICs SICs Total Carrier Count

Exclusive Part 121 totals 121 36,348 39,651 75,999 66

Part 121/135 Totals 121/135 724 272 996 12

Part 121 TOTALS 37,072 39,923 76,995 78

 Other Operators* Type PICs SICs Total Carrier Count

BERING AIR 135 28 4 32 1

HAGELAND AVIATION SERVICES 135 101 12 113 1

TRADEWIND AVIATION LLC 135 27 17 44 1

Other Carrier TOTALS 156 33 189 3

All Carriers 37,228 39,956 77,184 81

* Part 135 commuter carriers who have operations in airplanes type certified for two pilots are

required by the proposed rule to provide operations familiarization flights for new hires, and 

mentoring, leadership, and command training for PICs and upgrading pilots. The FAA identified three 

Part 135 carriers who have commuter operations in airplanes type certified for two pilots. 

Source: National Vital Information Subsystem (NVIS) database, August 2014.
Pilot	Professional	Development	Regulatory	Evaluation 56

Table A-2

Assumptions:

Year 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

Total - 77184 77493 77803 78114 78427 78740 79055 79372 79689 80008 80328

Year 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

Total - - 309 310 311 313 313 315 317 317 319 320

Year 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Total - 1698 1705 1712 1719 1725 1732 1739 1746 1753 1760 1767

Sources:

0.5%

Annual growth rate of 0.4% applied to PICs and SICs equally

Change in pilot count from previous year

Number of Pilots

5

Number of New Pilots Needed Due To Growth

5: 2014 pilots counts from National Vital Information Subsystem (NVIS) database, August 2014. See Table A-1.

NUMBER OF PILOTS (BY CATEGORY) AND GROUND INSTRUCTORS IMPACTED BY COST PROVISIONS (EXCLUDING PPDC PROVISION) 

AND RECURRENT COST RELIEVING PROVISIONS

1: FAA Aerospace Forecasts 2013-2033. Table 30: Active Pilots by Type of Certificate, Airline Transport, 2012-2033.

2: Table A-20.

3: Estimated rate of early medical retirements. Source: Pilot Certification and Qualifciation Final Rule.

4: This is an FAA assumption.

 Pilots Per Ground Instructor4

200

Growth1Retirements2

Attrition due to 

Medical Early 

Retirement3

0.4% 2.2%

Retirements

Annual Retirement of 2.20% (based on total number of pilots)
Pilot	Professional	Development	Regulatory	Evaluation 57

Table A-2 (Continued)

Year 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

Total - 386 387 389 391 392 394 395 397 398 400 402

Year 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

Total - - 4443 4459 4477 4497 4512 4532 4551 4566 4586 4604

Year 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

Total - - 73050 73344 73637 73930 74228 74523 74821 75123 75422 75724

Year 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2014

Total - 386 387 389 391 392 394 395 397 398 400 402

Attrition Rate of 0.5% applied to PICs and SICs equally

Number of Newly Promoted and Newly Hired Pilots

Newly Promoted PICS = Growth in PICs + Total Retirements + Attrition of PICs; SICs = Newly Promoted PICS + Growth in SICS + 

Attrition of SICs

Number of Pilots Receiving Modified Recurrent Training

Pilot Count minus Newly Promoted and Newly Hired Pilots

Number of Ground Instructors Needed

Number of total pilots divided by estimated number of pilots per instructor

Attrition Due to Medical Early Retirement

NUMBER OF PILOTS (BY CATEGORY) AND GROUND INSTRUCTORS IMPACTED BY COST PROVISIONS (EXCLUDING PPDC PROVISION) 

AND RECURRENT COST RELIEVING PROVISIONS
Pilot	Professional	Development	Regulatory	Evaluation 58

Table A-3

Assumptions:

Year 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

Year 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

Year 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Total - 1694 1701 1707 1714 1721 1728 1735 1742 1749 1756 1763

Sources:

200

Number of Pilots 5

Annual growth rate of 0.4% applied to PICs and SICs equally

Number of New Pilots Needed Due To Growth

Change in pilot count from previous year

5: 2014 pilots counts from National Vital Information Subsystem (NVIS) database, August 2014. See Table A-1

NUMBER OF PILOTS (BY CATEGORY) AND GROUND INSTRUCTORS IMPACTED BY PPDC COST PROVISION AND UPGRADE COST RELIEVING

PROVISIONS

1: FAA Aerospace Forecasts 2013-2033. Table 30: Active Pilots by Type of Certificate, Airline Transport, 2012-2033.

2: Table A-20

3: Estimated rate of early medical retirements. Source: Pilot Certification and Qualifciation Final Rule.

4: This is an FAA assumption.

Growth1Retirements2

Attrition due to

Medical Early 

Retirement3

 Pilots Per Ground Instructor4

0.4% 2.2% 0.5%

Retirements

Annual Retirement of 2.20% (based on total number of pilots)
Pilot	Professional	Development	Regulatory	Evaluation 59

Table A-3 (Continued)

Year 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

Year 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

Year 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

Year 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2014

Total - 385 387 388 390 391 393 394 396 397 399 401

Attrition Rate of 0.5% applied to PICs and SICs equally

Number of Newly Promoted and Newly Hired Pilots

Newly Promoted PICS = Growth in PICs + Total Retirements + Attrition of PICs; SICs = Newly Promoted PICS + Growth in SICS + Attrition of SICs

Number of Pilots Receiving Modified Recurrent Training

Pilot Count minus Newly Promoted and Newly Hired Pilots

Number of total pilots divided by estimated number of pilots per instructor

Number of Ground Instructors Needed

Attrition Due to Medical Early Retirement

NUMBER OF PILOTS (BY CATEGORY) AND GROUND INSTRUCTORS IMPACTED BY PPDC COST PROVISION AND UPGRADE COST RELIEVING

PROVISIONS
Pilot	Professional	Development	Regulatory	Evaluation 60

Table A-4

Guarantee NEW-HIRE

AIRLINE

Total

Count % Total

SIC 

Count %of SICs

PIC 

Count %of PICs Aircraft 1 3 5 7 12 7 10 MAX Reserve Monthly

ALASKA AIRLINES 1470 3% 718 2.63% 752 3.09% 737-900 $48 $89 $105 $109 $121 $162 $174 $180 79 $3,792

ALLEGIANT 7760 15% 4201 15.37% 3559 14.64% MD-80 $41 $73 $83 $87 $87 $134 $141 $146 70 $2,870

AMERICAN 400 1% 200 0.73% 200 0.82% 737-800 $35 $92 $97 $102 $113 $159 $163 $166 73 $2,555

AMERIJET 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% A320 $38 $69 $78 $81 $89 $132 $140 $149 75 $2,850

HAWAIIAN 572 1% 272 1.00% 300 1.23% 717 $36 $87 $97 $107 $113 $161 $162 $162 75 $2,700

JETBLUE 1979 4% 1000 3.66% 979 4.03% A320 $47 $81 $92 $98 $108 $149 $155 $159 75 $3,525

MN AIRLINES (formerly SUN COUNTRY) 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% A321 $39 $72 $82 $87 $91 $120 $145 $164 72 $2,808

UNITED 10121 20% 5743 21.01% 4378 18.01% A320 $33 $75 $82 $86 $94 $130 $134 $137 70 $2,310

US AIRWAYS 4567 9% 2392 8.75% 2175 8.95% A-320 $25 $62 $75 $79 $85 $118 $122 $125 76 $1,900

VIRGIN AMERICA 640 1% 320 1.17% 320 1.32% A-320 $44 $75 $82 $88 $95 $132 $141 $150 70 $3,080

Narrowbody Weighted Average $46 $89 $99 $104 $112 $158 $164 $169 $3,348

Sources:

SIC and PIC Count: NVIS, August 2014

Wages: Airline Pilot Pay Snapshot, 2012. hp://www.airlinepilotcentral.com/files/airlinepilotpaysnapshot2012.pdf

CAPTAIN (years of experience)

WEIGHTED AVERAGE WAGES OF NARROWBODY OPERATORS

FIRST OFFICER (years of experience)
Pilot	Professional	Development	Regulatory	Evaluation 61

Table A-5

Guarantee NEW-HIRE

AIRLINE

Total

Count % Total

SIC 

Count %of SICs

PIC 

Count %of PICs Aircraft 1 3 5 7 12 7 10 MAX Reserve Monthly

ABX AIR 254 1% 127 0.55% 127 0.65% 767-200 $48 $103 $120 $126 $143 $194 $200 $204 68 $3,264

AMERICAN 7760 18% 4201 18.09% 3559 18.32% 777 $35 $115 $120 $126 $139 $197 $202 $205 73 $2,555

AMERIJET 50 0% 24 0.10% 26 0.13% 767-200 $46 $49 $52 $57 $57 $84 $88 $103 65 $2,990

ATI 135 0% 66 0.28% 69 0.36% 767-200 $56 $85 $85 $90 $101 $155 $170 $173 61 $3,416

ATLAS 1075 3% 700 3.01% 375 1.93% 747-400 $75 $99 $110 $121 $141 $173 $189 $201 62 $4,650

CENTURION 54 0% 34 0.15% 20 0.10% MD-11 $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

HAWAIIAN 572 1% 272 1.17% 300 1.54% A330 $36 $102 $114 $126 $133 $189 $190 $191 75 $2,700

KALITTA AIR 250 1% 150 0.65% 100 0.51% 747-400 $66 $85 $91 $97 $109 $142 $154 $192 62 $4,092

OMNI 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-11 $55 $60 $67 $69 $72 $113 $125 $125 60 $3,300

SOUTHERN AIR 205 0% 136 0.59% 69 0.36% 747-400 $59 $71 $79 $84 $97 $136 $148 $172 60 $3,540

UNITED 10121 24% 5743 24.73% 4378 22.54% 747-400 $33 $107 $116 $121 $130 $183 $187 $190 70 $2,310

UPS 2690 6% 1340 5.77% 1350 6.95% 747-400 $39 $149 $155 $161 $182 $244 $249 $262 81 $3,159

US AIRWAYS 4567 11% 2392 10.30% 2175 11.20% A-330 $25 $79 $96 $101 $109 $152 $156 $160 76 $1,900

Widebody Weighted Average $44 $116 $124 $131 $142 $199 $204 $209 $3,142

Sources:

SIC and PIC Count: NVIS, August 2014

Wages: Airline Pilot Pay Snapshot, 2012. hp://www.airlinepilotcentral.com/files/airlinepilotpaysnapshot2012.pdf

WEIGHTED AVERAGE WAGES OF WIDEBODY OPERATORS

FIRST OFFICER (years of experience) CAPTAIN (years of experience)
Pilot	Professional	Development	Regulatory	Evaluation 62

Table A-6

Guarantee NEW-HIRE

AIRLINE

Total

Count % Total

SIC 

Count %of SICs

PIC 

Count %of PICs Aircraft 1 3 5 7 10 3 5 7 10 MAX Reserve Monthly

COMPASS 538 2% 281 2.46% 257 2.28% E175 $24 $37 $40 $76 $84 $67 $72 $76 $84 $104 75 $1,800

ENDEAVOR (formerly PINNACLE) 1791 8% 899 7.87% 892 7.92% CRJ900 $26 $38 $41 $44 $45 $69 $74 $78 $85 $106 75 $1,950

ENVOY (formerly AMERICAN EAGLE) 2227 10% 1164 10.19% 1063 9.44% CRJ700 $26 $38 $41 $42 $43 $73 $77 $81 $88 $106 75 $1,950

EXPRESSJET 4539 20% 2184 19.12% 2355 20.91% CRJ900 $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

JETBLUE 1979 9% 1000 8.76% 979 8.69% E190 $47 $73 $82 $89 $93 $128 $131 $134 $139 $143 75 $3,525

MESA1740 3% 370 3.24% 370 3.29% CRJ900 $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

REPUBLIC (including CHAUTAUQUA and 

SHUTTLE AMERICA)12371 10% 1118 9.79% 1253 11.13% E190 $23 $36 $37 $37 $37 $73 $77 $82 $90 $119 75 $1,725

SKYWEST 12746 12% 1347 11.80% 1399 12.42% CRJ900 $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

Small Narrowbody Weighted Average $30 $43 $47 $50 $52 $77 $81 $85 $92 $110 $2,175

Sources:

SIC and PIC Count: NVIS, August 2014

Wages: Airline Pilot Pay Snapshot, 2012. hp://www.airlinepilotcentral.com/files/airlinepilotpaysnapshot2012.pdf

FIRST OFFICER (years of experience)

1: Wage source data included two entries for two different aircraft types for these carriers. Because pilot count data was not available by aircraft, to be conservative, the entry for the larger aircraft and corresponding higher wage 

was selected. 

WEIGHTED AVERAGE WAGES OF SMALL NARROWBODY OPERATORS

CAPTAIN (years of experience)

Table A-7

NUMBER OF AIRPLANES BY TYPE

Year: 2012

Passenger

Number of Narrowbody Aircraft 3148

Number of Widebody Aircraft 524

Number of Regional Jets 1755

Cargo

Number of Narrowbody Aircraft 265

Number of Widebody Aircraft 575

Total 6267

Source: FAA Aerospace Forecast Fiscal Years

2013-2033. Pages 113-4 and 119. Tables 21, 22,

and 27.
Pilot	Professional	Development	Regulatory	Evaluation 63

Table A-8

New SIC

Average

SIC

Upgrading 

SIC

Average

PIC

Senior 

PIC

FIRST OFFICER CAPTAIN

Daily

% of 

Fleet 0 1 3 5 7 10/12 7 10 MAX

Narrowbody Aircraft 54.46% $111.61 $46 $89 $99 $104 $112 $158 $164 $169

Widebody Aircraft 17.54% $104.73 $44 $116 $124 $131 $142 $199 $204 $209

Small Narrowbody Aircraft 28.00% $72.50 $30 $43 $47 $50 $52 $85 $92 $110

Weighted Average $99 $41 $81 $89 $94 $101 $145 $151 $160

Hourly Hourly

2012 WAGES BY YEARS OF EXPERIENCE AND WEIGHTED BY PILOT COUNTS AND PLANE TYPE
Pilot	Professional	Development	Regulatory	Evaluation 64

Table A-9

ANALYSIS OF EMPLOYER PROVIDED BENEFITS

% of Total

Compensation

Does this category of 

benefits vary with 

hours worked?

Wages and salaries 70.3

Total benefits 29.7

Paid leave 6.9 No

Vacation 3.6

Holiday 2.1

Sick 0.8

Personal 0.4

Supplemental pay 2.8 No

Overtime and premium1 0.8

Shift differentials 0.2

Nonproduction bonuses 1.7

Insurance 8.2 No

Life 0.1

Health 7.7

Short-term disability 0.2

Long-term disability 0.1

Retirement and savings 3.7 Yes

Defined benefit 1.6

Defined contribution 2.1

Legally required benefits 8.2 Yes

Social Security and Medicare 5.9

Federal unemployment insurance 0.1

State unemployment insurance 0.8

Workers’ compensation 1.4

Yes 11.9

No 17.9

Total 29.8

Percent that varies with hours worked 11.9

Incremental Hours Wage Multiplier 1.169

Incremental Employee Wage Multiplier 1.42

Source:

http://www.bls.gov/news.release/pdf/ecec.pdf

BLS, Employer costs for Employee compensation - June 2013

Table 5, Private Industry
Pilot	Professional	Development	Regulatory	Evaluation 65

Table A-10

ADJUSTMENT FOR CHANGE OVER TIME

Month:

Mean Annual

Pilot Wage Source

May 2012 $ 128,760 http://www.bls.gov/oes/2012/may/oes532011.htm

May 2013 $ 129,600 http://www.bls.gov/oes/current/oes532011.htm

Annual Wage Growth 

Rate: 0.65%

Table A-11

WAGES USED IN PROPOSAL COST ANALYSIS

Labor Category

Wage

Rate

1

Factor for 

Employer 

Provided 

Benefits

2

Factor for 

Change

Over Time

3

Total

Compensation 

Costs Unit of time

Ground Training Instructor $31 1.42 1 $44 hourly

Senior Management Person

4

$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

Per Diem $123 1 1 $123 day

Clerk

5 $18 1.42 1 $26 hourly

Sources

1: Table A-8. 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).

2: Table A-9.

3: Table A-10.

Note: Per Diem is 2013 standard GSA lodging and per diem rate including meals and incidentals.

5: Table A-8. Ground training instructor wage rate and clerk wage 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)

and Information and Record Clerks (43-4000).

4: The FAA determined that a senior management person would command an average hourly 

compensation equal to that of a senior PIC. 
Pilot	Professional	Development	Regulatory	Evaluation 66

Table A-12

RECURRING COST FOR OPERATIONS FAMILIARIZATION FOR NEW-HIRE PILOTS

2 SIC Familiarization Operating Cycles

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of New-Hire SICs 1- - 2420 2431 2439 2450 2460 2468 2479 2489

New SIC Cost per Day

2

$116 $116 $116 $116 $116 $116 $116 $116 $116 $116

Days Required 30 0 1 1 1 1 1 1 1 1

Familiarization Flight Cost (Millions $)4$0.000 $0.000 $0.281 $0.282 $0.283 $0.284 $0.285 $0.286 $0.288 $0.289 $2.278

Per Diem5$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Required 60 0 1 1 1 1 1 1 1 1

Per Diem Cost (Millions $)7$0.000 $0.000 $0.298 $0.299 $0.300 $0.301 $0.303 $0.304 $0.305 $0.306 $2.415

Total (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 Percent $0.000 $0.000 $0.441 $0.414 $0.388 $0.365 $0.342 $0.321 $0.301 $0.283 $2.855

PV 3 Percent $0.000 $0.000 $0.514 $0.501 $0.488 $0.476 $0.464 $0.452 $0.441 $0.430 $3.766

1: The number of new-hire SICs (Table A-2).

2: Estimated daily training cost for new SICs (Table A-11).

3: Estimated number of training days required.

4: New-hire SIC cost, calculated by multiplying the number of new-hire SICs by the daily cost and the number of days required (footnotes 1, 2, and 3).

5: The per diem rate (Table A-11).

6: Number of travel days for which a per diem would be necessary.

7: Per diem cost, calculated by multiplying the per diem rate by the number of days required (footnotes 5 and 6).

8: Total cost, calculated by summing the new-hire SIC cost and the per diem cost (footnotes 4 and 7).

Note: This information corresponds to section V.A. and Table 9 within the Pilot Professional Development Regulatory Evaluation.
Pilot	Professional	Development	Regulatory	Evaluation 67

Table A-13

START-UP COMPLIANCE COST FOR MENTORING, LEADERSHIP, AND COMMAND

Modify Upgrade Flight and 

Ground Training Curriculum 

(2015)

Create One-Time PIC Training 

and Modify PIC Recurrent 

Training Curricula (2015)

Train Ground Instructors 

(2015)

Number of Carriers 181 81

Number of Ground Instructors

2

387

Ground Instructor Cost per Hour

3

$44 $44 $44

Ground Instructor Hours Required 480 40 8

Total (Millions $)5$0.285 $0.143 $0.136

PV 7 Percent $0.249 $0.125 $0.119

PV 3 Percent $0.269 $0.134 $0.128

*Costs discounted according to year of analysis (2015).

1: Number of part 121, 121/135, and 135 carriers required to modify or create trainings.

2: Number of ground instructors necessary to be trained (Table A-2).

3: Estimated ground instructor cost per hour (Table A-11).

4: Estimated ground instructor hours required to develop or undertake training.

Note: This information corresponds to sections V.B. and V. C. and Tables 10 and 11 within the Pilot Professional Development 

Regulatory Evaluation.

5: Total cost per provision, calculated by multiplying number of carriers or instructors by the corresponding hourly cost and hours 

required.
Pilot	Professional	Development	Regulatory	Evaluation 68

Table A-14

COST OF NEW MENTORING, LEADERSHIP, AND COMMNAD TRAINING REQUIREMENTS FOR SICS UPGRADING TO PIC

Provide 1 Ground Training Day for SICs Upgrading to PICs Covering Mentoring, Leadership, and Command

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

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

Training Hours Required30 0 8 8 8 8 8 8 8 8

Flight Hours Required40 0 4 4 4 4 4 4 4 4

SIC Upgrading Trainee Cost 

(Millions $)5$0.000 $0.000 $0.913 $0.917 $0.920 $0.924 $0.928 $0.932 $0.936 $0.939 $7.410

Per Diem

6

$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Required70 0 1 1 1 1 1 1 1 1

Per Diem Cost (Millions $)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 Ground Classes

9

- - 103 103 104 104 105 105 105 106

Ground Instructor Cost per 

Hour

10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours per Class

11 0 0 8 8 8 8 8 8 8 8

Ground Instructor Cost 

(Millions $)12 $0.000 $0.000 $0.036 $0.036 $0.036 $0.037 $0.037 $0.037 $0.037 $0.037 $0.294

Total (Millions $)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 Percent $0.000 $0.000 $0.917 $0.861 $0.808 $0.758 $0.711 $0.667 $0.626 $0.587 $5.936

PV 3 Percent $0.000 $0.000 $1.068 $1.042 $1.015 $0.990 $0.965 $0.940 $0.917 $0.893 $7.830

1: Estimated number of SICs upgrading to PIC (Table A-2).

2: Estimated senior SIC cost per flight hour (Table A-11).

3: Estimated number of training hours required.

4: Estimated number of flight hours required, equivalent to 1/2 of training hours required (footnote 3).

6: The per diem rate (Table A-11).

7: Number of travel days for which a per diem would be necessary.

8: Per diem cost, calculated by multiplying the per diem rate by the number of days required (footnotes 6 and 7).

10: Estimated ground instructor cost per hour.

11: Estimated ground instructor hours required per class (Table A-11).

5: SIC upgrading trainee cost, calculated by multiplying the number of upgrading pilots by the flight hour cost and the number of flight 

hours required (footnotes 1, 2, and 4).

12: Ground instructor cost, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and 

the number of ground instructor hours required per class (footnotes 9, 10, and 11).

Note: This information corresponds to information presented in section V.B. and Table 10 within the Pilot Professional Development 

Regulatory Evaluation.

9: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 

1).

13: Total cost, calculated by summing the SIC upgrading trainee cost, the per diem cost, and the ground instructor cost (footnotes 5, 8,

and 12).
Pilot	Professional	Development	Regulatory	Evaluation 69

Table A-15

RECURRING TRAINING COSTS FOR 1 ADDITIONAL HOUR FOR RECURRENT PIC TRAINING

PIC Mentoring, Leadership, and Command 1 Hour Recurrent Ground Training

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of PICs Receiving Recurrent Training

1

- - 35620 35762 35906 36049 36193 36339 36484 36630

Average PIC Cost per Flight Hour

2

$171 $171 $171 $171 $171 $171 $171 $171 $171 $171

Training Hours Required 30 0 1 1 1 1 1 1 1 1

Flight Hours Required 40 0 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

PIC Trainee Cost (Millions $)5$0.000 $0.000 $3.046 $3.058 $3.070 $3.082 $3.095 $3.107 $3.119 $3.132 $24.708

Number of Ground Classes

6

- - 1781 1788 1795 1802 1810 1817 1824 1832

Ground Instructor Cost per Hour

7

$44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours per Class

8

0 0 1 1 1 1 1 1 1 1

Ground Instructor Cost (Millions $)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 Percent $0.000 $0.000 $2.383 $2.236 $2.098 $1.969 $1.847 $1.733 $1.627 $1.526 $15.420

PV 3 Percent $0.000 $0.000 $2.776 $2.705 $2.637 $2.571 $2.506 $2.443 $2.381 $2.321 $20.339

1: Estimated number of PICs receiving recurrent training (Table A-2).

2: Estimated average PIC cost per flight hour (Table A-11).

3: Estimated number of training hours required.

4: Estimated number of flight hours required, equivalent to 1/2 of training hours required (footnote 3).

5: PIC trainee cost, calculated by multiplying the number of recurring PICs by the flight hour cost and the number of flight hours required (footnotes 1, 2, and 4).

6: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

7: Estimated ground instructor cost per hour (Table A-11).

8: Estimated ground instructor hours required per class.

10: Total cost, calculated by summing the PIC trainee cost and the ground instructor cost (footnotes 5 and 9).

Note: This information corresponds to information presented in section V.C. and Table 11 within the Pilot Professional Development Regulatory Evaluation.

9: Ground instructor cost, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number of ground 

instructor hours required per class (footnotes 6, 7, and 8).
Pilot	Professional	Development	Regulatory	Evaluation 70

Table A-16

ANNUAL COSTS FOR PPDC MEETING

PPDC Meeting Cost, One Half-Day Meeting Per Year

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Carriers 1- - 78 78 78 78 78 78 78 78

Senior Management Person Cost per Hour

2

$188 $188 $188 $188 $188 $188 $188 $188 $188 $188

Hours Required 30 0 4 4 4 4 4 4 4 4

Senior Management Person Cost (Millions $)4$0.000 $0.000 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.469

Senior PIC Cost per Flight Hour

5

$188 $188 $188 $188 $188 $188 $188 $188 $188 $188

Flight Hours Required 60 0 4 4 4 4 4 4 4 4

Senior PIC Cost (Millions $)7$0.000 $0.000 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.059 $0.469

Total (Millions $)

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 Percent $0.000 $0.000 $0.089 $0.084 $0.078 $0.073 $0.068 $0.064 $0.060 $0.056 $0.572

PV 3 Percent $0.000 $0.000 $0.104 $0.101 $0.098 $0.095 $0.093 $0.090 $0.087 $0.085 $0.754

1: Number of part 121 and 121/135 carriers required to develop a PPDC.

2: Estimated senior management person cost per hour (Table A-11).

3: Estimated senior management person hours required.

4: Senior management person cost, calculated by multiplying the number of carriers by the hourly cost and the number of hours required (footnotes 1, 2, and 3).

5: Estimated senior PIC cost per hour (Table A-11).

6: Estimated number of flight hours required. 

7: Senior PIC cost, calculated by multiplying the number of carriers by the flight hour cost and the number of flight hours required (footnotes 1, 5, and 6).

8: Total cost, calculated by summing the senior management person and senior PIC costs (footnotes 4 and 7).

Note: This information corresponds to information presented in section V.D. and Table 12 within the Pilot Professional Development Regulatory Evaluation.
Pilot	Professional	Development	Regulatory	Evaluation 71

Table A-17

RECURRING COST SAVING FOR COST RELIEVING PROVISIONS RELATED TO SIC RECURRENT TRAINING

Annual Training Cost Savings for 1 Hour Reduction in SIC Recurrent Ground Training

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Recurrent SICs 137714 37866 38017 38168 38322 38474 38628 38784 38938 39094

Average SIC Cost per Flight Hour

2

$105 $105 $105 $105 $105 $105 $105 $105 $105 $105

Training Hours Reduced 31 1 1 1 1 1 1 1 1 1

Flight Hours Reduced 40.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

SIC Trainee Cost Savings (Millions $)5$1.980 $1.988 $1.996 $2.004 $2.012 $2.020 $2.028 $2.036 $2.044 $2.052 $20.160

Number of Ground Classes

6

1886 1893 1901 1908 1916 1924 1931 1939 1947 1955

Ground Instructor Cost per Hour

7

$44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours Reduced per Class

8

1 1 1 1 1 1 1 1 1 1

Ground Instructor Cost (Millions $)9$0.083 $0.083 $0.084 $0.084 $0.084 $0.085 $0.085 $0.085 $0.086 $0.086 $0.845

Total (Millions $)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 Percent $1.802 $1.691 $1.586 $1.489 $1.397 $1.311 $1.230 $1.154 $1.083 $1.016 $13.757

PV 3 Percent $1.945 $1.896 $1.848 $1.801 $1.756 $1.711 $1.668 $1.626 $1.585 $1.545 $17.379

1: Estimated number of SICs receiving recurrent training (Table A-2).

2: Estimated average SIC cost per flight hour (Table A-11).

3: Estimated number of training hours reduced.

4: Estimated number of flight hours reduced, equivalent to 1/2 of training hours reduced (footnote 3).

6: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

7: Estimated ground instructor cost per hour (Table A-11).

8: Estimated ground instructor hours reduced per class.

10: Total cost savings, calculated by summing the SIC trainee and ground instructor cost savings (footnotes 5 and 9).

5: SIC trainee cost savings, calculated by multiplying the number of SICs required by the SIC cost per flight hour and the flight hours reduced (footnotes 1,

2, and 4). 

9: Ground instructor cost savings, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number 

of ground instructor hours reduced per class (footnotes 6, 7, and 8).

Note: This information corresponds to information presented in section IV.G. and Table 4 within the Pilot Professional Development Regulatory 

Evaluation.
Pilot	Professional	Development	Regulatory	Evaluation 72

Table A-18

RECURRING COST SAVING FOR COST RELIEVING PROVISIONS RELATED TO PIC RECURRENT TRAINING

Annual Training Cost Savings for 1 Hour Reduction in PIC Recurrent Ground Training

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of PICs Receiving Recurrent Training

1

35336 35478 35620 35762 35906 36049 36193 36339 36484 36630

Average PIC Cost per Flight Hour

2

$171 $171 $171 $171 $171 $171 $171 $171 $171 $171

Training Hours Reduced 31 1 1 1 1 1 1 1 1 1

Flight Hours Reduced 40.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5

PIC Trainee Cost Savings (Millions $)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 Ground Classes

6

1767 1774 1781 1788 1795 1802 1810 1817 1824 1832

Ground Instructor Cost per Hour

7

$44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours Reduced per Class

8

1 1 1 1 1 1 1 1 1 1

Ground Instructor Cost (Millions $)9$0.078 $0.078 $0.078 $0.079 $0.079 $0.079 $0.080 $0.080 $0.080 $0.081 $0.792

Total (Millions $)

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 Percent $2.707 $2.540 $2.383 $2.236 $2.098 $1.969 $1.847 $1.733 $1.627 $1.526 $20.667

PV 3 Percent $2.921 $2.847 $2.776 $2.705 $2.637 $2.571 $2.506 $2.443 $2.381 $2.321 $26.107

1: Estimated number of PICs receiving recurrent training (Table A-2).

2: Estimated average PIC cost per flight hour (Table A-11).

3: Estimated number of training hours reduced.

4: Estimated number of flight hours reduced, equivalent to 1/2 of training hours reduced (footnote 3).

5: PIC trainee cost savings, calculated by multiplying the number of PICs required by the PIC cost per flight hour and the flight hours reduced (footnotes 1, 2, and 4). 

6: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

7: Estimated ground instructor cost per hour (Table A-11).

8: Estimated ground instructor hours reduced per class.

10: Total cost savings, calculated by summing the PIC trainee and ground instructor cost savings (footnotes 5 and 9).

Note: This information corresponds to information presented in section IV.C. and Table 4 within the Pilot Professional Development Regulatory Evaluation.

9: Ground instructor cost savings, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number of ground 

instructor hours reduced per class (footnotes 6, 7, and 8).
Pilot	Professional	Development	Regulatory	Evaluation 73

Table A-19

RECURRING COST SAVINGS FOR COST RELIEVING PROVISIONS RELATED TO UPGRADE TRAINING

Annual Training Cost Savings for 2 Fewer Upgrade Ground Training Days

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Upgrading SICs 1- - 2051 2059 2068 2076 2085 2092 2101 2110

Senior SIC Cost per Flight Hour2$111 $111 $111 $111 $111 $111 $111 $111 $111 $111

Training Hours Reduced30 0 16 16 16 16 16 16 16 16

Flight Hours Reduced40 0 8 8 8 8 8 8 8 8

SIC Upgrading Trainee Cost Savings (Millions $)5$0.000 $0.000 $1.821 $1.828 $1.836 $1.843 $1.851 $1.858 $1.866 $1.874 $14.778

Per Diem6$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Reduced 70 0 2 2 2 2 2 2 2 2

Per Diem Cost (Millions $)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

Ground Instructor Cost per Hour10 $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 (Millions $)12 $0.000 $0.000 $0.072 $0.072 $0.073 $0.073 $0.073 $0.074 $0.074 $0.074 $0.586

Total (Millions $)

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 Percent $0.000 $0.000 $1.829 $1.716 $1.611 $1.512 $1.419 $1.330 $1.249 $1.172 $11.839

PV 3 Percent $0.000 $0.000 $2.131 $2.077 $2.025 $1.974 $1.924 $1.875 $1.828 $1.782 $15.615

1: Estimated number of SICs upgrading to PIC (Table A-3).

2: Estimated senior SIC cost per flight hour (Table A-11).

3: Estimated number of training hours reduced.

4: Estimated number of flight hours reduced, equivalent to 1/2 of training hours reduced (footnotes 3).

6: The per diem rate (Table A-11).

7: Number of travel days for which a per diem would have been necessary.

8: Per diem cost savings, calculated by multiplying the per diem rate by the number of days reduced (footnotes 6 and 7).

9: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

10: Estimated ground instructor cost per hour (Table A-11).

11: Estimated ground instructor hours reduced per class.

Note: This information corresponds to information presented in section IV.C. and Table 7 within the Pilot Professional Development Regulatory Evaluation.

13: Total cost savings, calculated by summing the SIC upgrading trainee cost savings, the per diem cost savings, and the ground instructor cost savings (footnotes 5, 8,

and 12).

12: Ground instructor cost savings, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number of ground 

instructor hours reduced per class (footnotes 9, 10, and 11).

5: SIC upgrading trainee cost savings, calculated by multiplying the number of upgrading pilots by the flight hour cost and the number of flight hours reduced 

(footnotes 1, 2, and 4).
Pilot	Professional	Development	Regulatory	Evaluation 74

Table A-20

ESTIMATED ACTIVE PILOT CERTIFICATES HELD

BY CATEGORY AND AGE GROUP OF HOLDER

as of December 31, 2013

Age Cohort* Number of Percent of Percent of 

ATP ATP ATP

Certificates Certificates Certificates

in 5-year Age Cohort in 5-year Age Cohort in 1-year Age Cohort

(Average)

[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%

Total 137,658 100%

*Over age 65 omitted from table

Source: US Civil Airmen Statistics

http://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/2013/

Table 12: Estimated Active Pilot Certificates Held by Category and Age Group of Holder
Pilot	Professional	Development	Regulatory	Evaluation 75

Table A-21

RECORD KEEPING AND ADDITIONAL CURRICULUM DEVELOPMENT COSTS

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Approval of Qualification Standards Document for Certificate Holders with AQP (§ 121.909)

Number of AQP Carriers 125

Number of Hours per Carrier 23

Total Hours

3

75 75

Ground Instructor Cost per Hour 4$44

Record Keeping Cost5$3,300 $ 3,300

PV 7 Percent $2,882 $0 $0 $0 $0 $0 $0 $0 $0 $0 $2,882

PV 3 Percent $3,111 $0 $0 $0 $0 $0 $0 $0 $0 $0 $3,111

Mentoring, leadership and command ground training for pilots currently serving as pilot in command (PIC) (§ 121.429)

Number of PICs 637527

Record Keeping Time Burden

7

 38 38

Clerk Cost per Hour 8$26

Record Keeping Cost9$988 $ 988

PV 7 Percent $0 $807 $0 $0 $0 $0 $0 $0 $0 $0 $807

PV 3 Percent $0 $904 $0 $0 $0 $0 $0 $0 $0 $0 $904

1: Number of AQP carriers requiring qualification standards document.

2: Estimated hours required per carrier.

3: Total hours required calculated by multiplying number of carriers by hours per carrier (footnotes 1 and 2).

4: Estimated ground instructor cost per hour (Table A-11).

6: Number of current PICs who will undertake the one-time training in 2016 (Table A-2).

7: Recordkeeping time burden, based on 0.1% for each applicable pilot (footnote 6).

8: Estimated clerk cost per hour (Table A-11).

9: Recordkeeping cost for PIC training, calculated by multiplying the recordkeeping time burden by the clerk cost per hour (footnotes 7 and 8).

5: Cost for approval of qualification standards document, calculated by multiplying total hours required by the ground instructor cost per hour (footnotes 3 

and 4).
Pilot	Professional	Development	Regulatory	Evaluation 76

Table A-21 (Continued)

RECORD KEEPING AND ADDITIONAL CURRICULUM DEVELOPMENT COSTS

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Recurrent PIC mentoring, leadership and command ground training (§121.427)

Number of PICs Receiving Recurrent 

Training (per year) 10 11873 11921 11969 12016 12064 12113 12161 12210 96328

Record Keeping Time Burden

11

 12 12 12 12 12 12 12 12 97

Clerk Cost per Hour 12 $26 $26 $26 $26 $26 $26 $26 $26

Record Keeping Cost13 $309 $310 $311 $312 $314 $315 $316 $317 $2,522

PV 7 Percent $0 $0 $236 $221 $207 $195 $183 $171 $161 $151 $1,524

PV 3 Percent $0 $0 $274 $267 $261 $254 $248 $241 $235 $229 $2,010

Operating familiarization for new-hire pilots (§ 121.432(d))

Number of New-Hire SICs 14 2420 2431 2439 2450 2460 2468 2479 2489 19636

Record Keeping Time Burden

15

 2 2 2 2 2 2 2 2 20

Clerk Cost per Hour 16 $26 $26 $26 $26 $26 $26 $26 $26

Record Keeping Cost17 $63 $63 $63 $64 $64 $64 $64 $65 $520

PV 7 Percent $0 $0 $48 $45 $42 $40 $37 $35 $33 $31 $311

PV 3 Percent $0 $0 $56 $55 $53 $52 $50 $49 $48 $47 $410

Total Burden

Total Time Burden

18 75 38 14 14 14 14 15 15 15 15 229

Total Recordkeeping Cost19 $3,300 $988 $372 $373 $375 $376 $378 $379 $381 $382 $7,303

PV 7 Percent $2,882 $807 $284 $266 $250 $234 $220 $206 $194 $182 $5,523

PV 3 Percent $3,111 $904 $330 $322 $314 $306 $298 $291 $283 $276 $6,434

10: Estimated number of PICs receiving recurrent training (Table A-2).

11: Recordkeeping time burden, based on 0.1% for each applicable pilot (footnote 10).

12: Estimated clerk cost per hour (Table A-11)

13: Recordkeeping cost for recurrent PIC training, calculated by multi[lying the recordkeeping time burden by the clerk cost per hour (footnotes 11 and 12).

14: The number of new-hire SICs (Table A-2).

15: Recordkeeping time burden, based on 0.1% for each applicable pilot (footnote 14).

16: Estimated clerk cost per hour (Table A-11).

18: The total time burden, calculated by summing the recordkeeping time burden for each category (footnotes 3, 7, 11, and 15).

19: The total recordkeeping cost, calculated by summing the recordkeeping cost for each category (footnotes 5, 9, 13, and 17).

Note: This information corresponds to information presented in section V.E. and Table 13 within the Pilot Professional Development Regulatory Evaluation.

17: Recordkeeping cost for new-hire SIC familiarization, calculated by multiplying the recordkeeping time burden by the clerk cost per hour (footnotes 15 

and 16).
Pilot	Professional	Development	Regulatory	Evaluation 77

Table A-22

ONE TIME COST FOR TRAINING CURRENT PICs IN MENTORING, LEADERSHIP, AND COMMAND

Provide 1 Ground Training Day for Current PICs Covering Mentoring, Leadership, and Command

Train Current PICs in

Mentoring, Leadership, and 

Command (2016)

Number of PICs 137527

Average PIC Flight Hours Required 2 4

Average PIC Cost per Flight Hour

3

$171

PIC Total Cost4$25.668

Number of Classes

5

1876

Ground Instructor Cost per Hour

6

$44

Instructor Hours per Class

7

8

Ground Instructor Total Cost8$0.660

Total (Millions $)

9

$26.329

PV 7 Percent $21.492

PV 3 Percent $24.095

*Costs discounted according to year of analysis.

1: Number of current PICs who will undertake the one-time training in 2016 (Table A-2).

2: Estimated number of flight hours required, per standard industry arrangements for new pilot training.

3: Estimated average PIC cost per flight hour (Table A-11).

6: Estimated ground instructor cost per hour (Table A-11).

7: Estimated number of ground instructor hours required per class

8: Ground instructor cost, calculated by multiplying the number of ground classes required by the ground 

instructor cost and the number of ground instructor hours required per class (footnotes 5, 6, and 7).

4: PIC ground training cost, calculated by multiplying the number of current PICs by the flight hour cost 

and the number of flight hours required (footnotes 1,2, and 3)

5: Number of ground classes needed based on an estimated class size of 20 pilots and the number of 

pilots in need of training (footnote 1).

9: Total cost, calculated by summing the PIC ground training cost and the ground instructor cost 

(footnotes 4 and 8).

Note: This information corresponds to sections V. C. and Table 11 within the Pilot Professional 

Development Regulatory Evaluation.
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 

synthesized 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 

analyzed 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 by 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 analyzing the ARC proposal alternative is largely similar to 

methodology used to analyze the FAA proposal. All key elements and assumptions concerning 

time frame of the analysis, 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 

Rate22

Factor for 

Employer 

Provided 

Benefits23

Factor for 

Change 

Over 

Time24

Total 

Compensation 

Costs

Unit of 

time

Senior Management Person25 $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 Instructor26 $31 1.42 1 $44 hourly

Professional Development Position27 $150,000 1.42 1 $213,000 annual

Per Diem28 $123 1 1 $123 day

 

22 Table A-8.

23 Table A-9.

24 Table A-10.

25 The FAA determined that a senior management person would command an average hourly compensation 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 New 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 flight 3701 in Jefferson City, Missouri and the February 12, 2009 crash of Colgan Air 

flight 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 analysis period is calculated by multiplying the salary for the PDP by the number of affected 

operators for each year of the analysis period. This calculation is shown in Table B-3. 

2. Create	a	Professional	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 would 

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. Finally, 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 by 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 analysis 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 by multiplying the total number of PICs by four hours 

and the average PIC flight hour cost. 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 would combine 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 by the PICs would be 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 by multiplying the senior PIC 

hours needed by the corresponding flight hour cost and number of carriers and summed for the 

relevant years 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 

typically 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 comply 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, by multiplying the total 

number of ground training classes by 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 

increased 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, by 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 cost 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 flight hours needed; second, by 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 classroom 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 

year 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 assumes 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, by multiplying the number of PICs taking recurrent 

training by 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

Table B-3

ARC PROPOSAL: COST FOR PDP PERSON

Hire a New Professional Development Position under Part 119

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Carriers Requiring a PDP

1

78 78 78 78 78 78 78 78 78 78

PDP Salary

2

$213,000 $213,000 $213,000 $213,000 $213,000 $213,000 $213,000 $213,000 $213,000 $213,000

Number of PDPs needed 31 1 1 1 1 1 1 1 1 1

PDP Cost (Millions $)4$16.614 $16.614 $16.614 $16.614 $16.614 $16.614 $16.614 $16.614 $16.614 $16.614 $166.140

Total (Millions $)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 Percent $14.511 $13.562 $12.675 $11.846 $11.071 $10.346 $9.669 $9.037 $8.446 $7.893 $109.056

PV 3 Percent $15.660 $15.204 $14.761 $14.331 $13.914 $13.509 $13.115 $12.733 $12.362 $12.002 $137.593

1: Number of part 121 and 121/135 carriers who would be required to hire a PDP.

2: Estimated annual PDP salary (Table B-1).

3: Estimated number of PDPs needed per carrier.

4: PDP cost, calculated by multiplying the number of carriers by the estiamted PDP salary and the estimated number of PDPs per carrier (footnotes 1,2, and 3).

5: The total cost to hire a PDP.
Pilot	Professional	Development	Regulatory	Evaluation 89

Table B-4

ARC PROPOSAL: FIRST-YEAR SENIOR PIC COST TO DEVELOP THE PDSC

Establish PDSC Program

Year = 2015 Cost: 

Number of Carriers Requiring a PDSC 178

Senior PIC Cost per Flight Hour

2

$188

Flight Hours Required 348

Review Time for Committee (Millions $)4$0.704

Total (Millions $)5$0.704

PV 7 Percent $0.615

PV 3 Percent $0.663

2: Estimated senior PIC cost per flight hour (Table B-1).

3: Estimated flight hours required.

5: The total cost to estblish the PDSC.

1: Number of part 121 and 121/135 carriers who would be required to 

establish a PDSC.

4: Review time cost, calculated by multiplying the number of carriers by 

the estimated senior PIC cost and the estimated hours required 

(footnotes 1, 2, and 3).
Pilot	Professional	Development	Regulatory	Evaluation 90

Table B-5

ARC PROPOSAL: MENTORING INSTRUCTION COSTS FOR ALL PICS

Mentoring Training for All PICs

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of PICs 1- 37527 2057 2066 2073 2082 2091 2098 2107 2115

Average PIC Cost per Flight Hour

2

$171 $171 $171 $171 $171 $171 $171 $171 $171 $171

Training Hours Reduced30 8 8 8 8 8 8 8 8 8

Flight Hours Reduced40 4 4 4 4 4 4 4 4 4

PIC Trainee Cost (Millions $)5$0.000 $25.668 $1.407 $1.413 $1.418 $1.424 $1.430 $1.435 $1.441 $1.447 $37.084

Total (Millions $)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 Percent $0.000 $20.953 $1.073 $1.008 $0.945 $0.887 $0.832 $0.781 $0.733 $0.687 $27.899

PV 3 Percent $0.000 $23.490 $1.250 $1.219 $1.187 $1.158 $1.129 $1.100 $1.072 $1.045 $32.651

1: Number of PICs receiving mentoring training (Table A-2).

2: Estimated average PIC cost per flight hour (Table B-1).

3: Estimated training hours required.

4: Estimated flight hours required, equivalent to 1/2 of training hours (footnote 3).

6: The total cost to train PICs in mentoring.

5: PIC trainee cost, calculated by multiplying the number of PICs by the estimated average PIC cost and the estimated flight hours required (footnotes 

1, 2, and 4).
Pilot	Professional	Development	Regulatory	Evaluation 91

Table B-6

ARC PROPOSAL: PDSC MEETING COSTS

PDSC Quarterly Meetings Cost

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Carriers Requiring a PDSC1- 78 78 78 78 78 78 78 78 78

Senior PIC Cost per Flight Hour

2

$188 $188 $188 $188 $188 $188 $188 $188 $188 $188

Flight Hours Required30 96 96 96 96 96 96 96 96 96

PDSC Team Meeting Time Cost (Millions $)4$0.000 $1.408 $1.408 $1.408 $1.408 $1.408 $1.408 $1.408 $1.408 $1.408 $12.670

Total (Millions $)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 Percent $0.000 $1.149 $1.074 $1.004 $0.938 $0.877 $0.819 $0.766 $0.716 $0.669 $8.011

PV 3 Percent $0.000 $1.288 $1.251 $1.214 $1.179 $1.145 $1.111 $1.079 $1.047 $1.017 $10.332

1: Number of part 121 and 121/135 carriers who would be required to establish a PDSC.

2: Estimated senior PIC cost per flight hour (Table B-1).

3: Estimated flight hours required.

5: Total cost for PDSC meeting time.

4: Estimated PDSC team meeting cost, calculated by multiplying the number of carriers by the senior PIC cost per flight hour and the flight hours required

(footnotes 1, 2, and 3).
Pilot	Professional	Development	Regulatory	Evaluation 92

Table B-7

ARC PROPOSAL: RECURRING COSTS FOR THE ADDITIONAL INDOCTRINATION CLASS TIME FOR NEWLY-HIRED PILOTS

Additional Indoctrination Training

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of New -Hire SICs 1- - 2420 2431 2439 2450 2460 2468 2479 2489

New SIC Cost per Day

2

$116 $116 $116 $116 $116 $116 $116 $116 $116 $116

Days Required 30 0 0.25 0.25 0.25 0.25 0.25 0.25 0.25 0.25

SIC Trainee Cost (Millions $)4$0.000 $0.000 $0.070 $0.070 $0.071 $0.071 $0.071 $0.072 $0.072 $0.072 $0.569

Number of Classes

5

- - 121 122 122 123 123 123 124 124

Instructor Cost per Hour

6

$44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours per Class

7

0 0 2 2 2 2 2 2 2 2

SIC Instructor Cost (Millions $)8$0.000 $0.000 $0.011 $0.011 $0.011 $0.011 $0.011 $0.011 $0.011 $0.011 $0.086

Total (Millions $)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 Percent $0.000 $0.000 $0.062 $0.058 $0.054 $0.051 $0.048 $0.045 $0.042 $0.039 $0.399

PV 3 Percent $0.000 $0.000 $0.072 $0.070 $0.068 $0.067 $0.065 $0.063 $0.062 $0.060 $0.526

1: The number of new-hire SICs (Table A-2).

2: Estimated daily training cost for new SICs (Table B-1).

3: Estimated number of training days required.

4: New-hire SIC cost, calculated by multiplying the number of new-hire SICs by the daily cost and the number of days required (footnotes 1, 2, and 3).

5: Number of classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

6: Estimated instructor cost per hour (Table B-1).

7: Estimated instructor hours required per class.

9: The total cost, calculated by suming the SIC trainee cost and instructor cost (footnotes 4 and 8). 

8: Instructor cost, calculated by multiplying the number of classes required by the instructor cost per hour and the number of instructor hours 

required per class (footnotes 6, 7, and 8).
Pilot	Professional	Development	Regulatory	Evaluation 93

Table B-8

ARC PROPOSAL: RECURRING COST FOR 2 FAMILIARIZATION FLIGHTS FOR NEWLY-HIRED PILOTS

2 SIC Familiarization Flights

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of New-Hire SICs 1- - 2420 2431 2439 2450 2460 2468 2479 2489

New SIC Cost per Day

2

$116 $116 $116 $116 $116 $116 $116 $116 $116 $116

Days Required 30 0 1 1 1 1 1 1 1 1

SIC Trainee Cost (Millions $)

4

$0.000 $0.000 $0.281 $0.282 $0.283 $0.284 $0.285 $0.286 $0.288 $0.289 $2.278

Per Diem5$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Required 60 0 1 1 1 1 1 1 1 1

Per Diem Cost (Millions $)7$0.000 $0.000 $0.298 $0.299 $0.300 $0.301 $0.303 $0.304 $0.305 $0.306 $2.415

Total (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 Percent $0.000 $0.000 $0.441 $0.414 $0.388 $0.365 $0.342 $0.321 $0.301 $0.283 $2.855

PV 3 Percent $0.000 $0.000 $0.514 $0.501 $0.488 $0.476 $0.464 $0.452 $0.441 $0.430 $3.766

1: The number of new-hire SICs (Table A-2).

2: Estimated daily training cost for new SICs (Table B-1).

3: Estimated number of training days required.

5: The per diem rate (Table B-1).

6: Number of travel days for which a per diem would be necessary.

7: Per diem cost, calculated by multiplying the per diem rate by the number of days required (footnotes 5 and 6).

8: The total cost, calculated by summing the SIC trainee cost and the per diem cost (footnotes 4 and 7).

4: New-hire SIC cost, calculated by multiplying the number of new-hire SICs by the daily cost and the number of days required (footnotes 1, 2,

and 3).
Pilot	Professional	Development	Regulatory	Evaluation 96

Table B-9

ARC PROPOSAL: RECURRING COSTS FOR 32 HOURS OF COMMAND AND LEADERSHIP TRAINING COSTS FOR SICS BEING PROMOTED TO PIC

Provide 32 Hours Leadership and Command Training to SICs Upgrading to PICs

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of Upgrading SICs 1- - 2057 2066 2073 2082 2091 2098 2107 2115

Senior SIC Cost per Flight Hour2$111 $111 $111 $111 $111 $111 $111 $111 $111 $111

Training Hours Required332 32 32 32 32 32 32 32 32 32

Flight Hours Required416 16 16 16 16 16 16 16 16 16

SIC Upgrading Trainee Cost (Millions $)5$0.000 $0.000 $3.653 $3.669 $3.682 $3.698 $3.714 $3.726 $3.742 $3.756 $29.640

Per Diem6$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Required 70 0 4 4 4 4 4 4 4 4

Per Diem Cost (Millions $)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 Classes

9

- - 103 103 104 104 105 105 105 106

Instructor Cost per Hour

10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours per Class

11 0 0 32 32 32 32 32 32 32 32

SIC Instructor Cost (Millions $)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 Percent $0.000 $0.000 $3.670 $3.445 $3.230 $3.032 $2.846 $2.669 $2.505 $2.350 $23.745

PV 3 Percent $0.000 $0.000 $4.274 $4.167 $4.060 $3.959 $3.860 $3.760 $3.666 $3.573 $31.318

1: Estimated number of SICs upgrading to PIC (Table A-2).

2: Estimated senior SIC cost per flight hour (Table B-1).

3: Estimated number of training hours required.

4: Estimated number of flight hours required, equivalent to 1/2 of training hours required (footnote 3).

6: The per diem rate (Table B-1).

7: Number of travel days for which a per diem would be necessary.

8: Per diem cost, calculated by multiplying the per diem rate by the number of days required (footnotes 6 and 7).

9: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

10: Estimated ground instructor cost per hour (Table B-1).

11: Estimated ground instructor hours required per class.

13: The total cost, calculated by summing the SIC upgrading trainee cost, the per diem cost, and the SIC instructor cost (footnotes 5, 8, and 12).

5: SIC upgrading trainee cost, calculated by multiplying the number of upgrading pilots by the flight hour cost and the number of flight hours required 

(footnotes 1, 2, and 4).

12: Ground instructor cost, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number of 

ground instructor hours required per class (footnotes 9, 10, and 11).
Pilot	Professional	Development	Regulatory	Evaluation 97

Table B-10

ARC PROPOSAL: RECURRING COSTS FOR 8 ADDITIONAL HOURS FOR PIC RECURRENT TRAINING

PIC Leadership and Command 8 Hours Recurrent Training

YEAR 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 TOTAL

Number of PICs Receiving 

Recurrent Training

1

- - 35620 35762 35906 36049 36193 36339 36484 36630

PIC Cost per Flight Hour

2

$171 $171 $171 $171 $171 $171 $171 $171 $171 $171

Training Hours Required30 0 8 8 8 8 8 8 8 8

Flight Hours Required40 0 4 4 4 4 4 4 4 4

PIC Trainee Cost (Millions $)5$0.000 $0.000 $24.364 $24.461 $24.560 $24.658 $24.756 $24.856 $24.955 $25.055 $197.664

Per Diem6$123 $123 $123 $123 $123 $123 $123 $123 $123 $123

Days Required 70 0 1 1 1 1 1 1 1 1

Per Diem Cost (Millions $)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 Classes

9

- - 1781 1788 1795 1802 1810 1817 1824 1832

Instructor Cost per Hour10 $44 $44 $44 $44 $44 $44 $44 $44 $44 $44

Instructor Hours per Class

11 0 0 8 8 8 8 8 8 8 8

PIC Instructor Cost (Millions $)

12 $0.000 $0.000 $0.627 $0.629 $0.632 $0.634 $0.637 $0.640 $0.642 $0.645 $5.086

Total (Millions $)

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 Percent $0.000 $0.000 $22.408 $21.025 $19.729 $18.512 $17.370 $16.299 $15.294 $14.350 $144.987

PV 3 Percent $0.000 $0.000 $26.097 $25.438 $24.796 $24.170 $23.560 $22.966 $22.386 $21.821 $191.233

1: Estimated number of PICs (Table A-2).

2: Estimated PIC cost per flight hour (Table B-1).

3: Estimated number of training hours required.

4: Estimated number of flight hours required, equivalent to 1/2 of training hours required (footnote 3).

6: The per diem rate (Table B-1).

7: Number of travel days for which a per diem would be necessary.

8: Per diem cost, calculated by multiplying the per diem rate by the number of days required (footnotes 6 and 7).

9: Number of ground classes needed based on an estimated class size of 20 pilots and the number of pilots in need of training (footnote 1).

10: Estimated ground instructor cost per hour (Table B-1).

11: Estimated ground instructor hours required per class.

13: The total cost, calculated by summing the PIC trainee cost, the per diem cost, and the PIC instructor cost (footnotes 5, 8, and 12).

5: PIC trainee cost, calculated by multiplying the number of upgrading pilots by the flight hour cost and the number of flight hours required (footnotes 

1, 2, and 4).

12: Ground instructor cost, calculated by multiplying the number of ground classes required by the ground instructor cost per hour and the number of

ground instructor hours required per class (footnotes 9, 10, and 11).