INITIAL REGULATORY EVALUATION

PILOT CERTIFICATION AND QUALIFICATION REQUIREMENTS

FOR AIR CARRIER OPERATIONS

OFFICE OF AVIATION POLICY AND PLANS

AIRCRAFT REGULATORY DIVISION (APO-300)

Daniel F. Leach

February 2, 2012
2

I. ACRONYMS USED IN THIS DOCUMENT

APD—Aircrew Program Designee

ATP—Airline Transport Pilot

AVP—Office of Accident Investigation and Prevention

FAA—Federal Aviation Administration

FOQ—First Officer Qualifications (Short title for Pilot Certification and Qualification 

Requirements for Air Carrier Operations)

FOQ ARC—First Officer Qualifications Aviation Rulemaking Committee

FSTD—Flight Simulation Training Device

ME—Multiengine

NTSB—National Transportation Safety Board

NPRM—Notice of Proposed Rulemaking

APO—Office of Policy and Plans

PIC—Pilot in command (Captain)

SIC—Second in command (First officer, Co-Pilot)

VSL—Value of a Statistical Life

II. EXECUTIVE SUMMARY

The purpose of this proposed rule is to meet pilot certification and qualification requirements 

imposed by Congress in Sections 216 and 217 of the Airline Safety and Federal Aviation 

Extension Act of 2010. The Act had its genesis in the crash of Colgan Air Flight 3407 that 

occurred outside of Buffalo, New York, on February 12, 2009, destroying the airplane, damaging 

residential homes, and resulting in 50 fatalities. Section 216 of the Act specifically requires that 

all pilots in part 121 air carrier operations hold an air transport pilot (ATP) certificate by August 

2, 2013, regardless of any rulemaking. Section 216 also requires sufficient multiengine 

experience as determined by the Administrator. Currently in part 121 operations, only a pilot in 

commant (PIC) is required to hold an ATP certificate.

As directed by Section 217 of the Act, to be qualified to hold an ATP certificate, pilots must 

have received flight training, academic training, or operational experience that will prepare them 

to function effectively in a multi-pilot environment, in an air carrier operational environment, in 

adverse weather conditions, and during high altitude operations. This section also requires the 

training must prepare pilots to adhere to the highest professional standards.
3

Section 217 of the Act also requires that holders of the ATP have sufficient flight hours, as 

determined by the Administrator, to allow them to function effectively in an air carrier 

operational environment. Section 217 specifies that the Administrator shall require at least 1,500 

flight hours (the current requirement) but allows the Administrator to grant credit toward flight 

hours for specific academic training courses. Section 217 further specifies that the total flight 

hours shall include sufficient flight hours in difficult operational conditions that may be 

encountered by an air carrier to enable pilots to operate safely in such conditions.

Consistent with the requirements of the Act and many of the recommendations of the First 

Officer Qualifications (FOQ) ARC, this proposed rule would require the following:

1. An ATP certificate for all pilots operating in part 121. The proposed requirement will 

retain the 1,500 hours total time as a pilot required for an ATP certificate but allow 

an ATP certificate with restricted privileges to be held: (a) by military pilots with 750 

hours of flight experience; and (b) by baccalaureates from an aviation program who

obtained their commercial pilot certificate with instrument rating from an affiliated part 

141 pilot school, and who have 1,000 hours of flight experience. The ATP with restricted 

privileges would allow a pilot to serve in part 121 air carrier operations as a second in 

command (SIC) only. A first class medical certificate will remain the requirement for 

exercising the privileges of an ATP certificate (restricted or unrestricted). The minimum 

age for an ATP certificate with restricted privileges would be reduced to 21 years of age. 

The current requirement for an ATP certificate will remain at 23 years of age.

2. A minimum of 50 hours of multiengine (ME) flight experience. This requirement 

would apply not just to pilots serving in part 121 operations, but for all pilots who apply 

for an ATP certificate with an airplane category multiengine class rating. This would 

include PICs in part 135 air carrier operations that require the PIC to hold an ATP
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certificate, and PICs in part 91, subpart K, Fractional Ownership Programs, which require 

the PIC to hold an ATP certificate. The FOQ ARC also recommended 50 hours of 

multiengine time.

3. An ATP Certification Training Program for applicants for an ATP certificate with 

an airplane category multiengine class rating or type rating. The FOQ ARC made a 

similar proposal. This is a foundational course that the FAA believes should be required 

at the certification level to address the gap in aeronautical knowledge of a commercial 

pilot and the knowledge a pilot should have prior to entering an air carrier environment.

The course would include academic study as well as simulator flight training, including 

training in difficult operational conditions. This requirement will necessitate changes in 

the ATP knowledge and practical tests. In addition to all pilots in part 121 operations, this

requirement would apply to PICs in part 135 air carrier operations that require the PIC to 

hold an ATP certificate, and PICs in part 91, subpart K, Fractional Ownership Operations,

which require the PIC to hold an ATP certificate.

4. An aircraft type rating for all SICs serving in part 121 operations. The FOQ ARC 

made the same recommendation. Currently only PICs are required to hold an aircraft type 

rating. The FAA has determined that this requirement would improve safety in part 121 

operations by further exposing the pilot to an advanced multiengine aircraft and a 

multicrew environment. Also the training and testing for an aircraft type rating requires a 

pilot to be tested to the same standard as the PIC and demonstrate proficiency in difficult 

operational conditions, including adverse weather and high altitude operations. 

5. A minimum of 1,000 hours in air carrier operations to serve as PIC in part 121 

operations. An unintended consequence of the Act’s requirement for all part 121 pilots to 

hold an ATP certificate is that the natural mentoring of SICs may not occur. The 1,000-
5

hour requirement would ensure that a pilot would have at least one full year of relevant 

operational experience before upgrading to PIC. The FAA proposes to allow a pilot to 

count SIC time in part 121 operations as well as PIC time in part 135 operations and in 

part 91, subpart K, Fractional Ownership Operations, that require an ATP certificate per 

the operating rule part.

These are the rule provisions that have cost implications as discussed in greater detail in 

Section III below. The total social cost of the rule provisions identified above is $2,018.5 million, 

with present value cost of $782.4 million. However, since the ATP certificate requirement for

pilots in part 121 operations is a statutory requirement and, therefore, not a cost of the proposed 

rule, we show separately the total cost of the proposed rule, which is $443.3 million, with present 

value cost of $200.4 million. The total social benefit is $896.0 million, with present value benefit

of $384.1 million. 

Overview of Costs and Benefits

Total Cost

($ mil.)

PV Cost

($ mil.)

Annualized 

PV Cost

($ mil.)

Total Social Cost (Pre-statutory baseline) $ 2,018.5 $ 782.4 $ 73.9

Costs Attributable to Proposed Rule

(Post-statutory baseline) $ 443.3 $ 200.4 $ 18.9

Total Benefits

($ mil.)

PV Benefits

($ mil.)

Annualized 

PV Benefits 

Total Social Benefit $ 896.0 $ 384.1 $ 36.3 

Note: Annualized PV Cost/Benefit is the annual cash flow of the 20-year annuity that yields the same 

present value as the cost/benefit item.

.
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III. DISCUSSION OF COSTS AND BENEFITS

A. Total Costs and Benefits of this Proposed Rule

As discussed in more detail below, on a pre-statute basis, the proposed rule has costs that far 

exceed its benefits. However, about 75 percent of these costs (about $ 55 million annualized) are 

the result of the underlying statutory requirement that all pilots operating under part 121 have an 

ATP by August 1, 2013. If the FAA were not to use its authority to allow credit for academic

credit, these projected costs would rise to more than $87 million annualized. The proposed 

rule’s requirements of an ATP certificate and aircraft type rating for part 121 SICs, 1,000 hours 

of flight experience in air carrier operations prior to serving as a part 121 PIC—and 50 hours of 

ME time and a foundational ATP Certification Training Program for pilots seeking an ATP 

certificate with airplane category and multiengine class rating or type rating—would, as a group 

of requirements, enhance the qualifications, experience, and seasoning of pilots. As a 

consequence, the FAA believes that the proposed rule would enhance safety by reducing the 

accident rate in air carrier operations. 

However, we estimate that cost will be minimal for the requirement of 50 hours of ME time 

for applicants for the ATP certificate with an airplane category multiengine class rating or type 

rating. ME hours are typically acquired while engaged in other commercial aviation activities 

such as flight instruction or part 135 air carrier operations on the way to obtaining the ATP

certificate. Airlines currently post minimums for ME time from 50 hours to as much as 1,500 

hours.1

We also estimate as minimal the costs of the requirement that a pilot have 1,000 hours of air 

carrier operating experience prior to serving as a part 121 PIC. According to a survey of 

 1 Kit Darby, President, www.KitDarby.com, Aviation Consulting, LLC, Peachtree City, GA.
7

industry,2 the average number of years for an SIC to upgrade to a PIC is about five years for

operators which use regional jet airplanes and/or turbopropeller airplanes (hereafter referred to as 

regional airlines) and more than ten years for major airlines. Even without air carrier operating 

experience in part 135 or part 91, subpart K operations, at an average number of 750 flight hours 

a year, an SIC will accumulate the required hours in 1 1/3 years.

Accordingly, in Table 1 below we show the expected costs of the proposed rule based on the 

costs of the three remaining requirements—the ATP Certification Training Program, the type 

rating requirement for part 121 SICs, and the part 121 ATP Certificate requirement for SICs.

Table 1 also shows the expected benefits of the proposed rule. Using a pre-statute baseline, the

table shows the total costs of the proposed rule to be $2,018.5 million, with present value cost of 

$782.4 million and annualized present value cost of $73.9 million. The total benefits of the 

proposed rule are $896.0 million, with present value of $384.1 million and annualized present 

value benefits of $36.3 million. However, since the FAA currently requires 1,500 hours for an 

ATP certificate, and the requirement for an SIC to hold an ATP certificate will take effect 

whether or not a regulation is issued, the cost of $1,575.2 million ($582.0 million in present 

value) associated with this provision are attributable to the statute, not this proposed regulation. 

Therefore, using a post-statute baseline, Table 1 shows that the proposed rule is cost beneficial as 

expected costs are $443.3 million ($200.4 million in present value), which are now less than the 

expected benefits of $896.0 million ($384.1 million in present value). In comparing costs and 

benefits, however, we must consider part 121 operators separately since all of the cost drivers 

apply to part 121 operators, while just the cost of the ATP Certification Training Program applies 

to part 135 and part 91, subpart K, operators.

 2 Owing to the expedited nature of this proposed rule, questionnaires were sent to the Air Transport Association 

(ATA) and the Regional Airlines Association (RAA), who, in turn, distributed the questionnaire to selected 

members. Five responses were received from the major airlines and three from the regional airlines.
8

As the table shows, for part 121 operators the proposed rule is cost-beneficial since present 

value benefits, at $225.1 million,3 are greater than present value costs, at 179.0 million. For part 

135 operators present value benefits are $159.0 million, while present value costs are $14.8 

million, so for part 135 operators the proposed rule is overwhelmingly cost-beneficial. Although 

the FAA does not have an estimate of benefits for part 91, subpart K, operators, these operators 

have pilot certification and operating rules similar to part 135 operators. Given the overwhelming 

benefit-cost ratio for part 135 operators, we are confident that the proposed rule is cost-beneficial 

for part 91, subpart K, operators as well.

In addition to Table 1, the table in Appendix 1 presents a different presentation of the cost 

and benefit findings. The table shows the cost and benefits of the proposed rule by rule 

provisions and the corresponding sections of the Act to which the provisions are responsive.

 3 Some of these benefits are presumably attributable to the statute’s ATP requirement, but as noted in the following 

section, we find at most $23.0 million attributable to the statute, with the likely amount much less. As Table 1 shows 

part 121 benefits to be $46.1 million greater than costs, the proposed rule would still be cost-beneficial even if the 

maximum $23.0 million were attributable to the statute.
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Table 1. Summary of Costs and Benefits of Proposed FOQ Rule, 2013-2032

Total Cost

($ mil.) 

PV Cost

($ mil.) 

Annualized 

PV Cost

($ mil.) 

Part 121 ATP Certificate Requirement $ 1,575.2 $ 582.0 $ 54.9 

 ATP Practical Test $ - $ 23.3 $ 2.2 

 ATP 1,500 Hour Requirement $ 2,520.4 $ 901.8 $ 85.1

 Savings from 750-hour ATP Military Credit $ (219.8) $ (78.6) $ (7.4)

 Savings from 500-hour ATP Educational Credit $ (725.5) $ (264.5) $ (25.0)

Type Rating (Part 121 Operators Only) $ - $ 3.4 $ 0.3 

ATP Certification Training Program $ 443.3 $ 196.9 $ 18.6 

 Part 121 Operators $ 396.6 $ 175.6 $ 16.6 

 Part 135 Operators $ 32.5 $ 14.8 $ 1.4 

 Part 91, Subpart K, Operators $ 14.3 $ 6.5 $ 0.6 

Total Social Cost--Part 121 Operators

(Pre-statutory baseline) $ 1,971.7 $ 761.0 $ 71.8 

Total Social Cost (Pre-statutory baseline) $ 2,018.5 $ 782.4 $ 73.9 

Costs Attributable to Proposed Rule--Part 121 Operators

(Post-statutory baseline) $ 396.6 $ 179.0 $ 16.9 

Costs Attributable to Proposed Rule

(Post-statutory baseline) $ 443.3 $ 200.4 $ 18.9 

Total 

Benefits

($ mil.)

PV 

Benefits

($ mil.)

Annualized 

PV 

Benefits 

Part 121 Benefits $ 525.0 $ 225.1 $ 21.2 

Part 135 Benefits $ 371.0 $ 159.0 $ 15.0 

Total Social Benefit $ 896.0 $ 384.1 $ 36.3 

Notes: 1. Although a social cost, the cost of the ATP certificate requirement is not a cost attributable to the proposed 

rule, as the requirement is specifically mandated by the Airline Safety Act of 2010.

2. Although incremental total costs of the ATP practical test and type rating are zero, incremental present value costs 

are positive. See discussion in the text below.

3. The same flight test qualifies a pilot for both the ATP certificate and the type rating. The incremental present value 

cost of the type rating requirement ($3.4 million) occurs because more current pilots have ATP certificates than type 

ratings.

4. Owing to a requirement of a preliminary version of this paper, the incremental cost of the type rating requirement 

includes the cost of the ATP written exam. As this is an extremely small cost, it is not reallocated here to the cost of the 

ATP certification requirement.

5. Annualized PV Cost/Benefit is the annual cash flow of the 20-year annuity that yields the same present value as the 

cost/benefit item.

6. Column sums may be off one or more units from totals owing to rounding.
Costs and Benefits of the ATP Certificate Requirement 

As the ATP certificate requirement for part 121 SICs is mandated by the Airline Safety Act 

of 2010 and is self-executing, we attribute the cost of the requirement to the statute and not the

proposed rule.

The FAA’s Office of Accident Investigation and Prevention (AVP) found little relationship 

between the 1,500-hour requirement and airplane accidents and therefore found little benefit

from that requirement. Only seven of the 31 accidents used for the part 121 benefit analysis had 

SICs with less than 1,500 hours. Moreover, the NTSB reports on these seven accidents have 

other causes and contributing factors which are addressed by the proposed rule. Finally, the 

seven accidents with SICs with less than 1,500 flight hours account for just 10.2% of our

estimated $225.1 million part 121 benefits, or $23.0 million, which, accordingly, is the 

maximum that could be attributable to the statute’s 1,500-hour requirement.

As the 1,500-hour requirement is mandated by statute, we did not further pursue the 

estimation of the requirement’s potential benefits.

B. Who is Potentially Affected by this Rule?

The proposed requirements would most affect any individual seeking an ATP certificate with 

an airplane category multiengine class rating. The proposed requirements would most affect 

individuals wishing to serve as SIC in part 121 air carrier operations, as well as individuals

wishing to serve as PIC in part 91 subpart K operations4

or on-demand part 135 operations

involving turbojets or other airplanes with 10 or more seats, or part 135 commuter operations

(“Scheduled 135”) involving multi-engine airplanes with 9 or less seats.

5 Also affected by the 

proposed rules would be individuals wishing to serve as PIC in part 121 air carrier operations, or, 

 4

§91.1053(a)(2)(i)

5

§135.243(a)(1)
11

more generally, anyone seeking an ATP certificate with an airplane category multiengine class 

rating. Any certificate holders approved under part 121, 135, 141, or 142 would be affected by 

the proposed rule if they choose to offer the proposed ATP Certification Training Program.

C. Principal Assumptions and Sources of Information

• We use a 20-year period of analysis in order to more fully account for costs that will 

accumulate over time as new pilots replace retiring pilots unaffected by the proposed rule. As 

the final rule will become effective on August 2, 2013, we use the 20-year period of analysis, 

2013-2032. In calculating present values, we discount back to 2010.

• Discount rate is 7 percent (Office of Management & Budget, Circular A-4, “Guidelines and 

Discount Rates for Benefit-Cost Analysis of Federal Programs,” October 29, 1992, p. 8, 

www.whitehouse.gov/omb/circulars/index.html).

• VSL ($6 million) and value of prevented injuries: United States Office of the Secretary of 

Transportation. Memorandum: Treatment of the Economic Value of a Statistical Life in 

Departmental Analyses--2009 Annual Revision, March 18, 2009.

• Number of rule-related accidents and associated number of fatalities, number of minor & 

serious injuries, aircraft model, and aircraft damage: FAA, Office of Accident Investigation 

and Prevention (AVP)

• Market value of aircraft and restoration costs: APO update to 2008 of data in Economic 

Values for FAA Investment and Regulatory Decisions, A Guide, Section 5. Office of 

Aviation Policy and Plans, U.S. Federal Aviation Administration, Wash., DC, Dec. 31, 2004.

• Number of part 121 PICs and SICs by airline and part 135 ATP pilots; and part 91, subpart

K, fractional ownership program PICs: FAA, Flight Standards Service, National Vital 

Information Subsystem (NVIS) database (Nov. 22, 2010; Dec. 10, 2010)
12

• Pilot growth rate (0.6%): U.S. DOT, FAA, Aviation Policy & Plans. FAA Aerospace 

Forecast: 2010-2030. Table 29, "Active Pilots by Type of Certificate", Air Transport, Avg 

Annual Growth, 2009-2030

• Cost of ATP Certification Training Program and cost of type rating: Industry survey and 

FAA Flight Standards Service

• Percentage of SICs without ATP (major & cargo airlines and regional airlines): Estimated 

from industry survey

• Percentage of SICs without type rating (major & cargo airlines and regional airlines): 

Estimated from industry survey

• Typical number of years for upgrade from SIC to PIC (Major airlines: 10 years, Regionals: 5 

years): Estimated from industry survey

• Typical number of years after which PIC will move from regional airline to major airline (2 

years): Industry survey

• Pilot salary data by airline (2008): www.airlinepilotcentral.com

• Number of part 121 retiring pilots (minimum): Calculated using www.faa.gov, Data and 

Research, U.S. Civil Airmen Statistics, Annual Statistics, 2009. Table 12, “Estimated Active 

Certificates Held As of December 31, 2009.”6

• Early and medical pilot retirement rate (0.5%): Email from Kit Darby, President, 

www.KitDarby.com, Aviation Consulting, LLC, Peachtree City, GA, dated 12/18/2010

 6 Using the midpoint ages of the five-year age groups, we used the @Risk Excel add-on to estimate a probability 

distribution for “Airline Transport” [ATP] certificates (The program chose the BetaGeneral distribution). Using the 

results of a 10,000 trial simulation of the distribution of the selected BetaGeneral distribution, we calculated a 

frequency distribution by age. To calculate the number of Part 121 ATP certificate holders, we normalized this 

distribution for ages 23 to 64 to sum to 1. We used these estimated numbers of Part 121 ATP certificate holders by 

year, to calculate the minimum number of retiring pilots by year. To this number we added 0.5% of the total number 

of previous-year pilots to account for medical and early retirements.
13

• Flight experience of military pilots leaving the service: FAA Flight Standards Service, Air 

Transportation Division (AFS-200), Air Carrier Training Branch (AFS-210)

• Hiring minimums by airline & airline group and percentage of pilots hired with military 

training: Kit Darby, President, www.KitDarby.com, Aviation Consulting, LLC, Peachtree 

City, GA

• Number of baccalaureates with aviation-related degrees: Aviation Accreditation Board 

International (AABI), Gary W. Kiteley, Executive Director, 3410 Skyway Drive, Auburn, 

AL

• We assume safety benefits will grow at the annual growth rate of air carrier revenue 

passenger miles. Source: U.S. DOT, FAA, Aviation Policy & Plans. FAA Aerospace 

Forecast: 2010-2030. Table 5, "U.S. Commercial Air Carriers' Total Scheduled U.S. 

Passenger Traffic", Revenue Passenger Miles, System [Domestic + Int'l], Avg Annual 

Growth, 2009-2030.

D. Costs of this Proposed Rule

As discussed above in Section A, “Total Costs and Benefits of this Proposed Rule,” we 

estimate costs to be minimal for the requirement that holders of the ATP certificate have 50 

hours of ME time and the requirement that a pilot have 1,000 hours of air carrier experience prior 

to serving as PIC in part 121 operations. As discussed above, we estimate that the three 

remaining provisions of the rule—the ATP Certification Training Program, the type rating 

requirement for part 121 SICs, and the ATP certification requirement--could have cost 

implications, although, as already noted, since the latter requirement is mandated by the Airline 

Safety Act of 2010, we attribute that cost to the statute, not the proposed rule. We estimate the 

costs of each of these three requirements below.
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Cost of ATP Certification Training Program

The requirement for the ATP Certification Training Program applies to all new applicants for

an ATP certificate with an airplane category multiengine class rating or type rating. Accordingly, 

the ATP Certification Training Program would apply to all pilots in part 121 operations, all PICs 

in part 91, subpart K, Fractional Ownership Operations, and all part 135 air carrier operations 

requiring the PIC to hold an ATP certificate. Part 135 operations requiring the PIC to hold an 

ATP certificate with an airplane category multiengine class rating are (1) commuter operations 

using multiengine airplanes with nine or fewer passenger seats (“Scheduled 135”) and (2) ondemand operations using multiengine airplanes with 10 or more passenger seats or turbojets.

The FAA anticipates that the ATP Certification Training Program would be a 7-day course, 

typically conducted by part 142 training center or a part 121 air carrier just prior to initial pilot 

training. The FAA anticipates the course would entail three days of ground school and four days 

of flight training—two days with an FTD and two days with a Level C or D simulator. Typically 

two pilots train concurrently in a simulator and this is reflected in our estimates of simulator cost 

per pilot.

In Table 2 are shown the estimated cost factors for the training program, and in Table 3 are 

shown calculations of total cost per pilot.
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Table 2. Cost Factors for the ATP Certification Training Program

Cost Factor Rate Period

Ground school 

instructor $ 33 per hour

Simulator instructor $ 130 per hour

Level C or D simulator $ 2,000 4-hr simulator event

FSTD $ 400 4-hr simulator event

Training pay $ 1,302 per month

Hotel $ 90 per day

Per diem $ 45 per day

Sources: 1. Pay rates incorporate a benefits factor of 1.302--Employee Benefit Research 

Institute, www.ebri.org (Benefit FAQs)

2. Other cost factors--Industry survey and FAA Flight Standards Service

Table 3. Cost per Pilot of 7-Day ATP Certification Training Program

Item Item Cost

Ground school instructor (3 days) $ 39

Simulator instructor (four 4-hr events) $ 2,083

Level C or D simulator (two 4-hr events, 2 pilots) $ 2,000 

FSTD (two 4-hr events, two pilots) $ 400 

Training pay & benefits (7 days) $ 304 

Hotel (7 days) $ 630

Per diem (7 days) $ 315 

Total Cost per Pilot $ 5,771

Notes. 1. Ground school class sizes are assumed to average 20 pilots.

2. Simulator instructor, simulator, and FTD costs reflect the fact that flight training is typically 

done with two pilots concurrently.

3. As the FAA anticipates that the training would take place just prior to initial pilot training, 

there would be no incremental travel costs.

In Table 4, the cost per pilot from Table 3 is used to estimate total and present value costs for 

new pilots over the 2013-2032 estimation period. (As indicated in the section on type rating costs 

below, current pilots without an ATP certificate will be able to obtain one at no additional cost 

when fulfilling the requirements for an aircraft type rating.) We estimate the number of new part 
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121 pilots, new part 135 PICs requiring an ATP certificate, and new part 91, subpart K, pilots by 

summing the annual change in pilot numbers with the estimated number of retiring pilots for

each of the three categories of pilots. These estimated numbers of new pilots are multiplied by 

the estimated cost per pilot of the ATP Certification Training Program. The resulting numbers 

are summed to obtain the figures in the “Total Cost of ATP Certification Program” column. 

As the table shows, we estimate the total cost of the ATP Certification Training Program 

over the 20-year estimation period, 2013-2032, to be $443.3 million with present value cost 

equal to $196.9 million.
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Table 4. Cost of ATP Certification Training Program, 2013-2032

Assumptions for Table Below

7% Discount rate

78,258 No. of part 121 pilots, 2010

7,295 No. of part 135 pilots, 2010

3,203 No. of part 91, subpart K, pilots, 2010

0.6% Pilot growth rate

3% Estimated retirement rate, part 135 and part 91, subpart K, pilots

$5,771 Estimated cost of ATP Certification Training Program

Year

No. of 

Part 

121 

Pilots

Retiring 

Part 

121 

Pilots

No. of 

New 

Part 

121 

Pilots

Part 121 Cost 

of ATP Cert. 

Program

($ mil.)

No. 

of 

Part 

135 

ATP 

Pilots

Retiring 

Part 

135

Pilots

No. of 

New 

Part 135 

ATP 

Pilots

Part 135 

Cost of ATP 

Cert. 

Program

($ mil.)

No. of 

Part 91, 

subpart

K, 

Pilots

Retiring 

Part 91, 

subpart

K, 

Pilots

No. of 

New 

Part 91, 

subpart

K, 

Pilots

Part 91, 

subpart K, 

Cost of ATP 

Cert. Pgm 

($ mil.)

Total Cost of 

ATP Cert. 

Program

PV 

Factor

PV Cost of 

ATP Cert. 

Program 

2011 78,728 1,751 7,339 219 3,222 96 0.935

2012 79,200 1,906 7,383 220 3,242 97 0.873

2013 79,675 2,052 2,527 $ 14,584,019 7,427 221 266 $ 1,533,837 3,261 97 117 $ 673,459 $ 16,791,315 0.816 $ 13,706,715 

2014 80,153 2,189 2,667 $ 15,394,290 7,472 223 267 $ 1,543,041 3,281 98 117 $ 677,499 $ 17,614,830 0.763 $ 13,438,269 

2015 80,634 2,335 2,816 $ 16,253,498 7,516 224 269 $ 1,552,299 3,300 98 118 $ 681,564 $ 18,487,361 0.713 $ 13,181,233 

2016 81,118 2,465 2,948 $ 17,015,375 7,562 225 271 $ 1,561,613 3,320 99 119 $ 685,654 $ 19,262,642 0.666 $ 12,835,512 

2017 81,605 2,602 3,089 $ 17,826,192 7,607 227 272 $ 1,570,982 3,340 100 120 $ 689,768 $ 20,086,942 0.623 $ 12,509,138 

2018 82,094 2,723 3,213 $ 18,539,681 7,653 228 274 $ 1,580,408 3,360 100 120 $ 693,906 $ 20,813,995 0.582 $ 12,113,935 

2019 82,587 2,844 3,336 $ 19,253,354 7,699 230 275 $ 1,589,891 3,380 101 121 $ 698,070 $ 21,541,315 0.544 $ 11,717,048 

2020 83,082 2,939 3,435 $ 19,820,945 7,745 231 277 $ 1,599,430 3,400 101 122 $ 702,258 $ 22,122,633 0.508 $ 11,246,025 

2021 83,581 3,034 3,533 $ 20,388,723 7,791 232 279 $ 1,609,026 3,421 102 122 $ 706,472 $ 22,704,221 0.475 $ 10,786,612 

2022 84,082 3,121 3,623 $ 20,907,933 7,838 234 280 $ 1,618,681 3,441 103 123 $ 710,711 $ 23,237,325 0.444 $ 10,317,650 

2023 84,587 3,183 3,688 $ 21,281,064 7,885 235 282 $ 1,628,393 3,462 103 124 $ 714,975 $ 23,624,432 0.415 $ 9,803,299 

2024 85,094 3,236 3,744 $ 21,605,629 7,932 237 284 $ 1,638,163 3,483 104 125 $ 719,265 $ 23,963,057 0.388 $ 9,293,287 

2025 85,605 3,281 3,792 $ 21,881,630 7,980 238 286 $ 1,647,992 3,504 104 125 $ 723,580 $ 24,253,203 0.362 $ 8,790,477 

2026 86,118 3,300 3,814 $ 22,011,555 8,028 239 287 $ 1,657,880 3,525 105 126 $ 727,922 $ 24,397,357 0.339 $ 8,264,229 

2027 86,635 3,303 3,820 $ 22,044,161 8,076 241 289 $ 1,667,827 3,546 106 127 $ 732,289 $ 24,444,277 0.317 $ 7,738,432 

2028 87,155 3,289 3,809 $ 21,979,449 8,124 242 291 $ 1,677,834 3,567 106 128 $ 736,683 $ 24,393,967 0.296 $ 7,217,295 

2029 87,678 3,274 3,797 $ 21,914,935 8,173 244 292 $ 1,687,901 3,589 107 128 $ 741,103 $ 24,343,939 0.277 $ 6,731,302 

2030 88,204 3,218 3,744 $ 21,606,836 8,222 245 294 $ 1,698,029 3,610 108 129 $ 745,550 $ 24,050,414 0.258 $ 6,215,084 

2031 88,733 3,170 3,699 $ 21,347,692 8,271 247 296 $ 1,708,217 3,632 108 130 $ 750,023 $ 23,805,932 0.242 $ 5,749,444 

2032 89,266 3,088 3,620 $ 20,893,723 8,321 248 298 $ 1,718,466 3,654 109 131 $ 754,523 $ 23,366,712 0.226 $ 5,274,175 

Total, 2013-

2032 58,648 68,714 $ 396,550,685 4,691 5,630 $32,489,910 2,060 2,472 $14,265,275 $ 443,305,870 $ 196,929,160 

Notes.: 1. For the sources of assumptions and “No. of Retiring Part 121 Pilots”, see the “Principal Assumptions and Sources of Information” section. 2. Retirement rate, part 135 and part 91, subpart K, pilots. We 

estimate that the retirement rate of part 135 ATP and part 91K pilots will be less than the part 121 pilot retirement rate, which we estimate to average 3.5% over the estimation period, 2013-2032. 3. Column sums may be off one or 

more units from totals owing to rounding.
18

Cost of an ATP Certificate/Aircraft Type Rating

The rule proposes that all SICs in part 121 operations hold an aircraft type rating for the 

aircraft flown by August 2, 2013, the same date that the SICs are required to hold an ATP 

certificate by Congressional mandate. The ATP practical test standards are the same standards

used for a type rating practical test. Given the statute’s requirement for an ATP certificate, the 

incremental cost of the proposed rule’s requirement for an aircraft type rating is zero. Some 

current SICs, however, already hold the ATP certificate. For these pilots, there would be an 

incremental cost for the type rating.7 Because of their close relationship, in this section we 

estimate ATP and type rating testing costs concurrently. Far more costly, however, is the 

requirement (retained by the proposed rule) that an applicant for an ATP certificate have a 

minimum of 1,500 hours of flight time. A later section entitled, “Cost of the ATP 1,500-hour 

Requirement”, will show the ATP 1,500-hour requirement to be orders of magnitude more costly 

than ATP testing costs.

Table 5 below shows the cost factors for the ATP and aircraft type rating practical test.

Table 5. Cost Factors for an ATP Certificate/

Aircraft Type Rating

Cost Factor Rate Unit

Ground school instructor $ 33 per hour

Simulator instructor $ 130 per hour

Check Pilot $ 130 per hour

Aircrew Program Designee (APD) $ 143 per hour

Level C or D simulator $ 2,000 4-hr event

New hire training pay $ 1,302 per month

SIC pilot pay $ 78 per hour

Hotel $ 90 per day

Per diem $ 45 per day

ATP written test $ 150 per test

Sources: 1. Pay rates incorporate a benefits factor of 1.302--Employee Benefit Research Institute, www.ebri.org 

(Benefit FAQs)

 2. Other cost factors--Industry survey and FAA Flight Standards Service

 7 Very few pilots hold a type rating without also holding the ATP certificate.
19

These cost factors are now used to estimate the cost per pilot, enabling the cost for all 

affected pilots to be estimated. As cost estimation per pilot, and overall, differs considerably 

between current and new SICs, we estimate overall costs for these groups separately.

Cost of ATP Certificate/Aircraft Type Rating per Pilot—New Pilots

The FAA believes that the ATP practical test/aircraft type rating for new pilots would be 

conducted at the conclusion of initial training, so that the cost of the ATP/aircraft type rating for 

new pilots would be incremental to the initial training costs. Table 6 below shows cost estimates 

per pilot for new pilots:

Table 6. Incremental Cost of an ATP Certificate/Aircraft Type

Rating per Pilot for New Pilots

Item Item Cost

Level C or D simulator for flight training (4-hr event, 2 pilots--two hours each) $ 1,000 

Simulator instructor for flight training (4-hr event, 2 pilots) $ 260

Incremental cost of type rating/ATP "Check ride" (Incremental cost of APD) $ 52 

Training pay & benefits (1 day) $ 43 

Hotel (negotiated rate) (1 day) $ 90 

Per diem (1 day) $ 45 

ATP written test $ 150 

Total $ 1,641

Note: Column sums may be off one or more units from totals owing to rounding.

As summarized in the table, the FAA estimates that after initial training, pilots need two 

additional hours of simulator training to be prepared to take the aircraft type rating check ride

(practical test). The same check ride qualifies as the practical test for the ATP certificate so the 

pilots will qualify for both the aircraft type rating and an ATP certificate simultaneously. Since a 

check ride is already required during initial training, the incremental cost for the aircraft type 

rating/ATP check ride is just the incremental salary and benefits of the Aircrew Program 

Designee (APD) required to conduct an aircraft type rating or ATP practical test, compared to a 
20

check airman. We include the cost of the ATP written test here as it would be required for the 

ATP practical test.

Cost of an ATP Certificate/Aircraft Type Rating per Pilot for Current SICs

The FAA believes that the aircraft type rating for current SICs would be conducted most 

efficiently at the conclusion of recurrent training, so that the cost of type rating current SICs 

would be incremental to the cost of recurrent training. Table 7 below shows our cost estimates 

per pilot for current SICs:

Table 7. Incremental Cost of an ATP Certificate/Aircraft Type Rating

per Pilot for Current Pilots

Item Item Cost

Ground school instructor (2 days) $ 26

Level C or D simulator for flight training (Two 4-hr events, 2 pilots--4 hours each) $ 2,000 

Simulator instructor for flight training (Two 4-hr events, 2 pilots) $ 521

Incremental cost of Level C or D simulator for "Check ride" for type rating/ATP (4-hr event) $ 1,000 

Incremental cost of type rating/ATP "Check ride" (Incremental cost of APD) $ 52 

Pilot pay (four 4-hr negotiated "training days") $ 1,250 

Hotel (4 days) $ 360

Per diem (4 days) $ 180 

Total $ 5,389

Notes: 1. Ground school class sizes are assumed to average 20 pilots.

2. As the FAA anticipates that the aircraft type rating would be conducted at the conclusion of recurrent pilot

training, there would be no incremental travel costs.

As summarized in the table, the FAA estimates that current SICs would need four hours of 

simulator training to be prepared for the aircraft type rating. The check ride for recurrent training 

is typically done with two pilots concurrently, whereas the aircraft type rating/ATP check ride is 

conducted with one pilot, so the incremental cost of a 4-hour simulator event is $2,000 -$1,000 = 

$1,000. The cost estimate does not include a charge for the ATP written exam as we estimate the 

number of current SICs without the ATP written test to be minimal.
21

Cost of an ATP Certificate/Aircraft Type Rating for New Part 121 Pilots, 2013-2032

Using the estimates of cost per pilot for new part 121 pilots, the total cost and present value cost 

for the estimation period, 2013-2032, can be estimated. These estimates are shown in 

Table 8 below:
22

Table 8. Cost of an ATP Certificate/Aircraft Type Rating for New Part 

121 Pilots, 2013-2032

Assumptions

7% Discount rate

78,258 No. of Part 121 Pilots, 2010

0.6% Pilot growth rate

5 Average number of years to upgrade (when ATP certificate is currently required)

$1,641 Estimated incremental cost of an ATP certificate/aircraft type rating for new pilots

5 Yrs Add'l Discounting

Year

No. of 

Part 121 

Pilots

No. of 

Retiring 

Pilots

Gross No. 

of New Part 

121 Pilots

Total Cost of 

ATP Cert./ 

Aircraft 

Type Rating

PV 

Factor

PV Cost of 

ATP Cert./ 

Aircraft Type 

Rating

PV 

Factor

PV Cost of 

ATP Cert./ 

Aircraft Type 

Rating 

Net PV Cost 

of ATP Cert./ 

Aircraft Type 

Rating

2011 78,728 1,751 0.935 0.666

2012 79,200 1,906 0.873 0.623

2013 79,675 2,052 2,527 $ 4,146,660 0.816 $ 3,384,910 0.582 $ 2,413,394 

2014 80,153 2,189 2,667 $ 4,377,044 0.763 $ 3,339,226 0.544 $ 2,380,822 

2015 80,634 2,335 2,816 $ 4,621,342 0.713 $ 3,294,953 0.508 $ 2,349,256 

2016 81,118 2,465 2,948 $ 4,837,966 0.666 $ 3,223,741 0.475 $ 2,298,483 

2017 81,605 2,602 3,089 $ 5,068,504 0.623 $ 3,156,410 0.444 $ 2,250,477 

2018 82,094 2,723 3,213 $ 5,271,370 0.582 $ 3,067,985 0.415 $ 2,187,431 

2019 82,587 2,844 3,336 $ 5,474,288 0.544 $ 2,977,650 0.388 $ 2,123,023 

2020 83,082 2,939 3,435 $ 5,635,670 0.508 $ 2,864,889 0.362 $ 2,042,626 

2021 83,581 3,034 3,533 $ 5,797,106 0.475 $ 2,754,163 0.339 $ 1,963,680 

2022 84,082 3,121 3,623 $ 5,944,733 0.444 $ 2,639,532 0.317 $ 1,881,950 

2023 84,587 3,183 3,688 $ 6,050,825 0.415 $ 2,510,877 0.296 $ 1,790,221 

2024 85,094 3,236 3,744 $ 6,143,108 0.388 $ 2,382,403 0.277 $ 1,698,621 

2025 85,605 3,281 3,792 $ 6,221,583 0.362 $ 2,254,988 0.258 $ 1,607,775 

2026 86,118 3,300 3,814 $ 6,258,524 0.339 $ 2,119,979 0.242 $ 1,511,516 

2027 86,635 3,303 3,820 $ 6,267,795 0.317 $ 1,984,223 0.226 $ 1,414,724 

2028 87,155 3,289 3,809 $ 6,249,396 0.296 $ 1,848,971 0.211 $ 1,318,291 

2029 87,678 3,274 3,797 $ 6,231,053 0.277 $ 1,722,938 0.197 $ 1,228,431 

2030 88,204 3,218 3,744 $ 6,143,451 0.258 $ 1,587,584 0.184 $ 1,131,926 

2031 88,733 3,170 3,699 $ 6,069,769 0.242 $ 1,465,929 0.172 $ 1,045,187 

2032 89,266 3,088 3,620 $ 5,940,692 0.226 $ 1,340,892 0.161 $ 956,038 

Total 58,648 68,714 $112,750,879 $49,922,244 $ 35,593,870 $14,328,374

Notes: 1. For the source of the number of retiring part 121 pilots, see the “Principal Assumptions and Sources of Information” section 

above.

2. Column sums may be off one or more units from totals owing to rounding.
23

Under current rules and practice, virtually all part 121 pilots eventually upgrade to PIC, a 

position for which an aircraft type rating and ATP certificate are required. On average this occurs 

5 years into the pilot’s career, often at a regional airline. Under the proposed rule, a new part 121 

pilot will be required to have an aircraft type rating and an ATP certificate at the beginning of his 

or her career as SIC. Since the undiscounted costs are the same under the proposed rule as under 

the current rule, the incremental undiscounted cost attributable to the proposed rule is zero. 

Nevertheless, there is an incremental present value cost stemming from the fact that the costs of 

the aircraft type rating would be incurred 5 years earlier under the proposed rule.

8 This 

incremental cost may be expressed as follows: C = PV1 – PV2, where C is the incremental

present value cost of the proposed rule; PV1 is the present value cost of the requirement that new 

SICs have an aircraft type rating and an ATP certificate immediately upon entering into revenue 

service; and PV2 is the present value cost of upgrading in year 5 under the existing rule. The 

table shows the total cost of an aircraft type rating over the 20-year estimation period to be 

$112.7 million, but, as indicated, the incremental undiscounted cost is zero. The total cost 

column is discounted with the usual discount factors to calculate the first “PV Cost of Aircraft 

Type Rating/ATP” column, which sums to PV1 = $49.92 million, the present value cost under 

the proposed rule. In the second “PV Cost of Aircraft Type Rating/ATP” column, the total cost 

stream is discounted by an additional 5 years to obtain the present value cost, PV2 = $35.59

million, the present value cost under the current rule. The incremental present value cost of the 

 8 The FAA believes that a small percentage of new SICs (less than 5%) may leave part 121 operations prior to 

upgrading to PIC. By not taking this potential attrition into account, the FAA’s cost estimates for a type rating/ATP

are understated by no more than $1.8 million in present value . A similar underestimation is made in the analysis for 

existing SICs who do not currently hold a type rating.
24

ATP certificate/aircraft type rating requirement for new pilots is calculated as the increase in 

present value cost: $49.92 mil - $35.59 mil. = $14.33 million.9

Cost of an ATP Certificate/Aircraft Type Rating for Current Part 121 Pilots, 2013-2032

First, the cost of an ATP certificate for all current pilots without an ATP certificate is 

calculated and then, independently, the cost of an aircraft type rating for all current pilots without 

one is calculated. As already noted, the latter cost will be higher since there are fewer current 

pilots with a type rating than with an ATP certificate. The difference between the ATP certificate

cost and the type rating cost will be the incremental cost of the proposed rule’s type rating 

requirement for current pilots.

The total cost and present value estimates for current pilots for the estimation period, 2013-

2032, are shown in Table 9 below:

 9 Pilots will need one or more additional aircraft type ratings as they follow a typical career path from a regional 

airline to a major airline. However, the average number of years to upgrade for a major airline is more than 10 years, 

which added to an average 7-year regional airline career, is far into the future. The low cost of the initial aircraft

type rating, combined with heavy discounting, indicates the cost of future additional aircraft type ratings is minimal.
25

Table 9. Cost of an ATP Certificate/Aircraft Type Rating for Current

Part 121 Pilots

Assumptions

7% Discount rate

0.6% Pilot growth rate

$5,389 Estimated incremental cost of an ATP certificate/aircraft type rating for current pilots

9,986 No. of SICs, 2010—regional airlines

29,594 No. of SICs, 2010—majors & cargo airlines

25.2 % of SICs at regional airlines

85 % of SICs without an ATP certificate--regionals

15 % of SICs without an ATP certificate--majors & cargo airlines

90 % of non-type rated SICs--regionals

30 % of non-type rated SICs--majors & cargo airlines

Cost of an ATP Certificate

Year

No. of 

Part 

121 

SICs

No. of 

Current 

Part 121 

Pilots w/o an 

ATP Cert.

Total Cost of 

an ATP Cert.

PV 

Factor

PV Cost of 

an ATP

Certificate

PV 

Factor 

(2.5 Yrs 

Add'l 

Discount)

PV Cost of

ATP (2.5 Yrs

Add'l 

Discount)

Net PV Cost 

of an ATP

2013 40,177 13,161 $ 70,924,078 0.816 $ 57,895,174 0.689

 $ 

48,885,882 $ 12,413,978 

Cost of a Type Rating

Year

No. of 

Part 

121 

SICs

No. of 

Current 

Part 121 

Pilots w/o an 

Aircraft 

Type Rating

Total Cost of 

an Aircraft 

Type Rating

PV 

Factor

PV Cost of 

an Aircraft 

Type Rating

PV 

Factor 

(2.5 Yrs 

Add'l 

Discount)

PV Cost of 

Type Rating 

(2.5 Yrs 

Add'l 

Discount)

Net PV Cost 

of Type 

Rating

2013 40,177 18,189 $ 98,018,226 0.816

 

$80,012,070 0.689

 

$67,560,999 $ 12,451,071

As noted previously, currently only PICs are required to hold an ATP certificate and an 

aircraft type rating for the airplane flown in revenue service. Based on an industry survey, we 

estimate that about 85% of the SICs for regional airlines and approximately 15% of the SICs of 

major and cargo airlines do not have an ATP certificate. The corresponding figures for an aircraft 

type rating are 90% and 30%. With the additional estimate of 25.2% of SICs at regional airlines, 
26

we calculate that more than 13,000 current (2013) SICs do not have aircraft type ratings.10 As 

Table 9 shows, we estimate $70.9 million to be the total cost to upgrade current SICs from 

commercial certificates to ATP certificates. (But, as in the case of new pilots, this is the total cost 

under both the current rule and the proposed rule, so the incremental total cost is zero.) When 

discounted with the usual discount factor, a present value cost of $57.9 million is obtained under 

the proposed rule. As in the case of new part 121 pilots, however, what must be calculated is the 

incremental present value cost owing to the proposed requirement that pilots must have the ATP

certificate immediately when in revenue service. As we have no information on the time in part 

121 service of current SICs without an ATP certificate, it is assumed that, on average, they have 

been in service for 2.5 years and have, on average, 2.5 additional years to serve as SICs before 

they would upgrade and be required, under current rules, to have an ATP certificate (and aircraft

type rating). As the table shows, we discount an additional 2.5 years to obtain the present value 

cost of $48.9 million under the current rule. The incremental PV cost of the earlier requirement 

for the aircraft type rating is then $57.9 - $48.9 = $9.0 million.

The analogous independent calculation for the type rating cost yields an incremental PV cost 

of the earlier requirement for a type rating to be 12.4 million. $12.4 - $9.0 = $3.4 million is then 

the incremental net present value cost of the proposed rule’s requirement for a type rating in 

addition to the statute’s requirement for an ATP certificate.

Cost of an ATP Certificate/Aircraft Type Rating for All Part 121 Pilots, 2013-2032

The table below summarizes the cost of an ATP certificate/aircraft type rating for new and 

current part 121 pilots:

 10 A small percentage of SICs also have not passed the ATP written exam. The estimated total cost for these pilots is

minimal.
27

Table 10. Summary of ATP Certificate/Type Rating

Cost for All Part 121 Pilots, 2013-2032

NPV Cost

ATP Cost--New Pilots $ 14.3 

ATP Cost --Current Pilots w/o ATP Certificate $ 9.0 

Cost of ATP Requirement $ 23.3 

Cost of Type Rating $ 3.4 

All Costs of ATP Certificate/Type Rating $ 26.7 

Notes: 1. “Cost Current Pilots w/o ATP Certificate” is the cost of 

providing an ATP certificate (and type rating) to all current pilots with 

neither.

2. “Cost of Type Rating” is the cost of type rating pilots already holding 

an ATP certificate.

Estimated Cost of ATP Certificate 1,500-Hour Requirement

As previously noted following the Congressional mandate of the Act, the proposed rule 

requires all SICs in part 121 air carrier operations to have an ATP certificate by August 2, 2013. 

The FAA proposes to retain the current requirement that ATP holders have at least 1,500 hours 

of total time as a pilot, except for a newly created restricted privileges ATP certificate under 

which (1) pilots with military training would require only 750 hours of flight time and (2) pilots 

with an aviation-related bachelor degree, who also obtained their commercial pilot certificate 

with instrument rating from an affiliated part 141 pilot school, would require only 1,000 hours of 

flight time. Holders of a restricted privileges ATP certificate would be allowed to operate as 

SICs only in part 121 operations and would be required to be at least 21 years old and hold a first 

class medical certificate.

In this section what is estimated is the cost of the increase in flight time that the ATP 

certificate requirement will entail. Only the cost for new pilots is estimated, as, given the 

depressed hiring environment for pilots in 2009 and 2010, the number of pilots currently with 
28

less than 1,500 hours appears to be small11, with corresponding minimal costs. For the future, the 

effect of the requirement would be to delay the careers of pilots in part 121 operations, so the 

cost of the increased flight hour requirement can be estimated by the reduced salary and benefits 

that the requirement engenders. From a social point of view, the reduced salary and benefits 

reflects the loss of pilot productivity the 1,500-hour restriction brings about by delaying the 

entrance of pilots into part 121 operations and, consequently, delaying their career path.

A common career path of a pilot in part 121 operations is to start out as a SIC (first officer) in 

a regional airline, upgrade to PIC (captain) at that airline and, subsequently, to become an SIC 

and a PIC at a major airline. Based on a survey of industry, we estimate the career path of a 

“typical” pilot in part 121 operations as follows: Upgrade to regional airline PIC after five years, 

move to a position as SIC at a major airline after two years as PIC at the regional airline, and 

upgrade to PIC at the major airline after an additional ten years. Under current regulations, a 

pilot is eligible for part 121 operations with a commercial pilot’s license, which requires just 250 

hours of flight time.

12

There is considerable cross-sectional variation in the hiring minimums of regional airlines, 

but the average total hours minimum appears to be about 750 hours. The number of flight hours 

the FAA assumes pilots can accumulate in one year is also about 750 hours. Accordingly, the 

FAA estimates that the proposed requirement for an ATP certificate with 1,500 hours of flight 

time would, on average, delay a new pilot’s part 121 career approximately one year. As pilots 

with an aviation-related bachelor’s degree, who also received their commercial pilot certificate 

 11 Industry survey. Confirmed by email from Kit Darby, President, www.KitDarby.com, Aviation Consulting, LLC, 

Peachtree City, GA, dated 12/18/2010.

12 A graduate of a part 141 pilot school or a part 142 training centers can obtain a commercial license with as few as 

190 hours of flight time.
29

with instrument rating from an affiliated part 141 pilot school, would be allowed to hold the 

restricted privileges ATP certificate with 1,000 hours, the FAA estimates that their careers will 

be delayed by only one-third of a year. The part 121 careers of Air Force, Navy, and Marine

pilots appear not to be delayed by the proposed rule, as these pilots appear to typically have more 

than 1,500 hours of flight time when leaving the service, so they will be eligible for the 

unrestricted ATP certificate. Army pilots typically have at least 750 hours of flight time when 

leaving the military, so they will be immediately eligible for the restricted privileges ATP 

certificate under the proposed rule.

In order to calculate the cost of the ATP certificate 1,500-hour requirement, we calculate the 

earnings and active benefits of a typical pilot in part 121 operations in a 35-year career and then 

calculate the loss in earnings and active benefits caused by the effect of the hours requirements in 

delaying that career. Regional airline earnings are estimated by averaging salary and active 

benefits data for Colgan Air and Mesa Airlines, as this provides a median estimate for the 

regional airlines included in a recent study.

13 Major airline earnings are estimated using salary 

and active benefits data for Delta Airlines as this was the median airline in the same study.

14

(Retirement benefits were not included as they greatly complicate the analysis with little effect 

on present value.) As pilots’ salaries differ by type of airplane flown (as well as by airline), an 

average salary for each airline was calculated as a weighted average using the number of aircraft 

of each type as weights. Hourly salary data by airline for 2008 were obtained from 

 13 www.KitDarby.com Aviation Consulting. U.S. Airline Pilot Job Market Overview. April 12, 2010. Peachtree 

City, Georgia.

14 The active benefits factor for Colgan Airlines and Mesa Airlines 1.233 and for Delta Airlines it is 1.15. Kit Darby 

Aviation Consulting, pp. 34-37.
30

www.airlinepilotcentral.com and were converted to monthly figures by multiplying hourly salary 

by the airline’s average credit hours per month.

15

Based on a 35-year career, the total cost of a one-year delay in a part 121 pilot’s career is 

estimated to be $130,298, with a present value cost of $67,598.16 Total cost of a one-third year 

delay in a part 121 pilot’s career is estimated to be $43,433, with a present value cost of 

$21,226.17 In order to put these results on a basis comparable to the 20-year estimates of the 

other costs and of the estimated benefits of this proposed rule, the present value costs is 

annualized to $5,221 per year for a one-year delay and $1,639 per year for a one-third year delay. 

Using these estimates the total cost of the ATP certificate 1,500-hour requirement for the 

estimation period 2013-2032 can be calculated, as shown in Table 11 below:

 15 Kit Darby Aviation Consulting, pp. 26-27.

16 Estimating the cost of a one-year delay is straightforward. For the year of delay, it is assumed the pilot is 

accumulating hours at the rate of 750 hours/year as a commercial pilot. And it is assumed the pilot will earn the 

same salary as a commercial pilot as he or she will in their first year as a regional airline SIC.

17 To calculate the cost of a one-third year delay, it is assumed delayed pilots are paid for 1/3 of a year as a 

commercial pilot. All other cash flows are identical to those of the undelayed pilot, with the exception of the last 

year when the pilot retires at age 65 two-thirds of the way through the 35th pay year.
31

Table 11. Cost of ATP 1,500-Hour Requirement, 2013-2032

Assumptions

7% Discount rate

78,258 No. of part 121 pilots, 2010

0.5% Pilot growth rate

25% % of new pilots with military training

1,133 No. of graduates with baccalaureates & aviation-related majors (2008-2009 academic year)

80% Estimated % of graduates with baccalaureates & aviation-related majors from programs with affiliated part 141 school

7% Discount rate

$1,639 Annualized Cost of 1-Year Career Delay for Aviation Degree Pilots

$5,221 Annualized Cost of 1-Year Career Delay for Pilots Subject to Full 1,500-Hour Requirement

Year

No. of 

Part 

121 

SICs

No. of 

Retiring 

Pilots

No. of 

New 

Pilots

No. of 

New 

Pilots 

with 

Military 

Training

No. of Pilots 

w/Bachelor 

Deg. from 

Aviation Pgm 

w/Part 141 

School

Cumulative No. 

of Pilots

w/Bachelor Deg. 

from Aviation 

Pgm w/Part 141 

School

No. of Pilots 

Restricted by 

Full 1,500-

Hour 

Requirement

Cumulative No. 

of Pilots 

Restricted by 

Full 1,500-Hour 

Requirement

Cost of OneThird Year 

Career Delay for 

Aviation Degree 

Pilots

Cost of 1-Year 

Career Delay for 

Pilots Subject to 

Full 1,500-Hr 

Requirement

Total Cost of 

Career Delay

7% 

Discount 

Factor

Present Value 

Cost of Career 

Delay

2011 78,728 1,360 1,830 917 0.935 

2012 79,200 1,512 1,985 923 0.873 

2013 79,675 1,656 2,131 533 928 928 670 670 $ 1,521,909 $ 3,497,838 $ 5,019,747 0.816 $ 4,097,608 

2014 80,153 1,791 2,269 567 934 1862 768 1438 $ 3,052,949 $ 7,507,058 $ 10,560,008 0.763 $ 8,056,179 

2015 80,634 1,935 2,416 604 940 2802 872 2310 $ 4,593,176 $ 12,060,635 $ 16,653,812 0.713 $ 11,873,938 

2016 81,118 2,061 2,545 636 945 3747 964 3274 $ 6,142,644 $ 17,092,299 $ 23,234,943 0.666 $ 15,482,424 

2017 81,605 2,197 2,683 671 951 4698 1,062 4335 $ 7,701,409 $ 22,635,021 $ 30,336,430 0.623 $ 18,892,004 

2018 82,094 2,315 2,805 701 957 5654 1,147 5482 $ 9,269,527 $ 28,622,530 $ 37,892,056 0.582 $ 22,053,522 

2019 82,587 2,433 2,926 731 962 6617 1,232 6714 $ 10,847,053 $ 35,054,715 $ 45,901,768 0.544 $ 24,967,520 

2020 83,082 2,526 3,022 755 968 7585 1,298 8012 $ 12,434,044 $ 41,832,223 $ 54,266,267 0.508 $ 27,586,218 

2021 83,581 2,619 3,118 779 974 8559 1,364 9377 $ 14,030,557 $ 48,954,941 $ 62,985,498 0.475 $ 29,923,957 

2022 84,082 2,704 3,205 801 980 9538 1,424 10801 $ 15,636,650 $ 56,389,677 $ 72,026,326 0.444 $ 31,980,550 

2023 84,587 2,705 3,209 802 986 10524 1,421 12222 $ 17,252,379 $ 63,809,421 $ 81,061,799 0.415 $ 33,637,765 

2024 85,094 2,706 3,213 803 991 11515 1,418 13640 $ 18,877,802 $ 71,214,059 $ 90,091,861 0.388 $ 34,939,177 

2025 85,605 2,707 3,217 804 997 12513 1,415 15056 $ 20,512,978 $ 78,603,478 $ 99,116,456 0.362 $ 35,924,365 

2026 86,118 2,708 3,221 805 1003 13516 1,412 16468 $ 22,157,965 $ 85,977,563 $ 108,135,528 0.339 $ 36,629,245 

2027 86,635 2,709 3,225 806 1009 14526 1,409 17878 $ 23,812,821 $ 93,336,198 $ 117,149,020 0.317 $ 37,086,379 

2028 87,155 2,710 3,229 807 1016 15541 1,406 19284 $ 25,477,607 $ 100,679,268 $ 126,156,875 0.296 $ 37,325,267 

2029 87,678 2,711 3,233 808 1022 16563 1,403 20687 $ 27,152,382 $ 108,006,654 $ 135,159,036 0.277 $ 37,372,600 

2030 88,204 2,712 3,238 809 1028 17590 1,400 22088 $ 28,837,205 $ 115,318,240 $ 144,155,445 0.258 $ 37,252,506 

2031 88,733 2,713 3,242 810 1034 18624 1,397 23485 $ 30,532,137 $ 122,613,907 $ 153,146,044 0.242 $ 36,986,774 

2032 89,266 2,714 3,246 811 1040 19664 1,394 24880 $ 32,237,239 $ 129,893,536 $ 162,130,776 0.226 $ 36,595,051 

Total, 2013-2022 49,326 59,392 14,848 19,664 24,880 $ 332,080,433 $ 1,243,099,261 $ 1,575,179,694 $ 558,663,049 

Notes. 1. Column sums may be off by one or more units from totals owing to rounding.

2. For the sources of assumptions and “No. of Retiring Part 121 Pilots”, see the “Principal Assumptions and Sources of Information” section.
32

As the table shows, from the number of new pilots, subtract the estimated number of new 

pilots with military training. As discussed above, only army pilots typically leave the military 

with less than 1,500 hours, but they typically have at least 750 hours, qualifying them for a 

restricted privileges ATP certificate and so will not be subject to a career delay. For the moment

skipping one column, subtract the estimated number of graduates with baccalaureates from 

aviation programs with an affiliated part 141 school.18 The resulting column shows the number 

of pilots restricted by the full 1,500-hour requirement.

In corresponding columns to the right of the numbers of aviation degree pilots and fullyrestricted pilots, the total number of pilots is calculated. The annual total cost of career delay for 

these pilots is then calculated so as to provide total and present value cost figures on a 20-year 

basis comparable to the other 20-year estimated costs and to the 20-year estimated benefits of 

this proposed rule. For each year, the cumulative number of both aviation degree pilots and fully 

restricted pilots are multiplied by their respective annualized costs ($1,639 and $5,221), so as to 

account for 20 years of annualized costs for new pilots arriving in 2013, 19 years of annualized 

costs for new pilots arriving in 2014, etc., down to 1 year of annualized costs for new pilots 

arriving in 2032.

As the table shows, the total cost of the ATP Certificate 1,500-hour requirement for the 

estimation period, 2013-2032, is about $1.6 billion, with present value cost of $558.7 million.

Since the FAA requires 1,500 hours for an ATP certificate, and the requirement to hold an ATP

certificate will take effect whether or not a regulation is issued, the costs associated with this 

provision are attributable to the statute, not this proposed regulation. The FAA further notes that 

this rulemaking contains a provision that would permit a pilot to obtain a restricted privileges 

 18 We use the projected previous year's figures since students will need at least a year at 750 hours a year to attain 

the 1,000 hours they would need for a restricted privileges ATP certificate.
33

ATP certificate at fewer than 1,500 hours. This allowance for a restricted privileges ATP 

certificate results in a reduction in the costs that would be incurred if the default provision of the 

public law went into effect without action by this Agency. 

E. Benefits of this Proposed Rule

The FAA expects that this proposed rule would reduce the number of future accidents. The 

bulk of the benefits of the proposed rule, particularly with part 121 operations, would be the 

value of the averted fatalities and injuries. The value of averted fatalities and injuries is based on 

the value of a statistical life. These values are shown in the table below along with associated 

medical and legal costs:

Table 12. Value of a Statistical Life (VSL) and Prevented Injuries

AIS 

Code Injury Level

Fraction of 

VSL

Value of 

Prevented 

Injury

Medical & 

Legal Costs Total Value

Cost of 

NTSB 

"Serious" 

Injury

AIS 1 Minor 0.0020 $ 12,000 $ 3,062 $ 15,062 

AIS 2 Moderate 0.0155 $ 93,000 $ 8,696 $ 101,696 

AIS 3 Serious 0.0575 $ 345,000 $ 25,964 $ 370,964 $ 578,113 

AIS 4 Severe 0.1875 $ 1,125,000 $ 136,679 $ 1,261,679 

AIS 5 Critical 0.7625 $ 4,575,000 $ 367,416 $ 4,942,416 

AIS 6 Fatal 1.0000 $ 6,000,000 $ 162,520 $ 6,162,520 

The Office of the Secretary of Transportation currently estimates the VSL to be $6 million. 

Shown in the “Fraction of VSL” column are relative value coefficients for preventing injuries 

associated with the Abbreviated Injury Scale (AIS). These coefficients are multiplied by the VSL 

to determine the value of a prevented injury by AIS code.19 Adding medical and legal costs20, we 

 19 Memorandum: Treatment of the Economic Value of a Statistical Life in Department Analyses--2009 Annual 

Revision, March 18, 2009. United States, Office of the Secretary of Transportation.

20 Economic Values for FAA Investment and Regulatory Decisions, a Guide, p. 2-2 to 2.4. Office of Aviation Policy 

and Plans, U.S. Federal Aviation Administration, Washington, DC, Final Report, Revised October 3, 2007. The 

values in this section are for 2001. We updated these values from 2001 to June, 2010 by the CPI-U price relative for 
34

obtain the total value of avoiding fatalities or injuries by injury level or fatality. As the NTSB 

classifies injuries in just two categories, “Minor” and “Serious”, the FAA Office of Policy and 

Plans calculates NTSB’s “Serious” category as the average of AIS categories, 2-4.

There would be additional benefits from the corresponding avoided destruction or damage to 

aircraft. The value of accident airplanes and the cost of restoring damaged airplanes is shown by 

category of airplane in Appendix 3. 

Effectiveness of the FOQ Rule in Preventing Accidents

For the 10 fiscal years from 2001 to 2010, the FAA’s Office of Accident Investigation and 

Prevention (AVP) compiled a list of all part 121 accidents and part 135 commuter and ondemand accidents over that period, along with the number of fatalities, the number of minor and 

serious injuries, aircraft model, and aircraft damage. From this list they determined the accidents 

that would have been affected by the proposed rule. AVP assessed that the package of 

requirements of the proposed rule would have had a likelihood of preventing some of these 

accidents. Based on NTSB accident reports, AVP assigned each accident a qualitative 

effectiveness rating and corresponding effectiveness score, which represents the likelihood that 

the proposed rule would have prevented the accident.21 All scores were reviewed by a 3-person 

panel. For part 121 operations, the table below shows the categories of qualitative effectiveness 

ratings and corresponding scores and the number of accidents in each category:

 

June, 2010 compared to June, 2001 (218.0/178.0 = 1.2247).

21 Federal Aviation Administration. Office of Accident Investigation and Prevention. “An Assessment of the 

Effectiveness of Public Law 111-216 in Reducing Accident Risk,” November 22, 2010
35

Table 13. FOQ Accident Scoring Summary 

for Part 121 Operations, FY 2001-FY 2010

Qualitative 

Effectiveness 

Score

Quantified 

Effectiveness 

Score

Number of 

Accidents

None 0 323

Low 0.15 17

Moderate 0.35 6

Moderate-to-High 0.55 5

High 0.75 3

Very High 0.90 0

Total 354

As the table indicates, AVP has assessed that 31 of 354 part 121 accidents would have had some 

likelihood of being prevented by the proposed rule. For the 31 accidents the effectiveness scores 

(later referred to as “effectiveness ratings”) range from 0.15 to 0.75, meaning that had the 

proposed rule been in place the likelihood the accidents would have been prevented ranges from 

15% to 75%. In the following section we describe the three accidents that received the highest

scores of 0.75 in this set, along with the most significant accident to receive the next-highest

score of 0.55. In the subsequent section we describe three accidents with the highest cost in terms 

of people killed or injured and in terms of aircraft damage or destruction. The avoidance of such 

high-cost accidents provides most of the benefits of the proposed rule.

Accidents with High Effectiveness Ratings

The three part 121 accidents that received the highest scores of 0.75 are essentially explained by 

crew performance and, consequently, are the accidents in which the benefits of the proposed rule 

are most clearly highlighted. In all three accidents the proposed rule would have affected the 

eligibility of both pilots, as neither the PIC nor the SIC met the proposed minimum experience 
36

for their respective positions. These accidents are described along with the most significant 

accident to receive the next highest score of 0.55.

Great Lakes Aviation Accident at Laramie Regional Airport, June 20, 2007 (Effectiveness 

Rating = 0.75)

On June 20, 2007 at 1620, a Beech 1900D operated by Great Lakes Aviation landed long and 

bounced in visual meteorological conditions (VMC) at Laramie Regional Airport. The crew tried 

to slow the aircraft, but left the runway at high speed where the right propeller struck an 

electrical box. A propeller blade then broke off and struck the right side of the fuselage. The PIC 

later noted that the approach was about 14 knots above the targeted speed and the airplane was 

“one dot high” on the glide slope. No injuries occurred to the 2 pilots and 9 passengers, but the 

aircraft was substantially damaged.

The NTSB determined the probable cause to be the PIC’s improper decision making, his 

misjudgment of speed and distance, and his failure to go around during an unstable approach. 

Factors in the accident were improper crew resource management (CRM) and the SIC's failure to 

intervene. The PIC had 2,250 hours of pilot experience and the SIC had 774 hours. The proposed 

rule would have required more training, experience, and seasoning in an air carrier environment,

which may well have led the PIC to go around upon recognizing an unstable approach or could 

have led the SIC to intervene.

Air Tahoma Crash at Florence, Ky, August 13, 2004 (Effectiveness Rating = 0.75)

On August 13, 2004, at 0049, a Convair 580 on a cargo flight operated by Air Tahoma 

crashed on approach to Cincinnati, Ohio. The PIC was killed and the SIC seriously injured. The 
37

airplane was destroyed. The PIC had exactly 2,500 hours and the SIC had 924 hours as a pilot, 

the majority of which had been in single-engine airplanes. The SIC had just three months of 

experience as an air carrier pilot.

The SIC was the pilot flying and about 20 minutes before the accident, he commented 

multiple times that the aircraft was pulling to the right and stated “I don't know why.... I don't 

know what's going on.” With the runway in sight, the SIC again noted “What is wrong with this 

plane? It’s really funny. I got something all messed up here." The PIC eventually advised the 

SIC that they had a fuel imbalance because the PIC, as the pilot not flying, had erroneously left 

the cross-feed open, which caused a prohibited fuel transfer. The SIC then stated that "we're 

going to flame out," but the PIC responded, "I got the cross-feed open. Just keep power on."

Ultimately, despite adequate fuel, the aircraft lost power due to fuel starvation and crashed one 

mile short of the runway.

Both pilots, especially the SIC, would have benefited from the greater experience and 

training required by the proposed rule. That greater training and experience may well have 

enabled the SIC to identify a lateral center-of-gravity (CG) problem caused by a fuel imbalance. 

It also may well have led the PIC to respond with some urgency when he finally recognized a 

fuel imbalance and the possibility of fuel starvation, owing to his having left the cross-feed open. 

Mesa Airlines Accident at Roanoke Regional Airport, October 16, 2001 (Effectiveness 

Rating = 0.75)

On October 16, 2001 at 2114, an ERJ-145 operated by Mesa Airlines suffered a hard landing

at Roanoke Regional Airport. The PIC had briefed the visual approach to runway 33 for which 

go-around was not an option owing to hills. The SIC later reported a quartering crosswind at 15 
38

mph, gusting to 21 mph. The SIC reported the approach as normal until 300 feet above ground, 

when she called "one dot high" “Ref + 5” (5 mph above “reference speed” for the landing).

Airspeed then dropped abruptly and the stick shaker activated (indicating the airplane was 

stalling). The PIC added power, but the aircraft landed hard before engines could spool up. 

Damage included broken and cracked frames and stringers, popped rivets, skin worn through in 

the lower aft pressure vessel, and scraped skin on the lower aft fuselage. NTSB identified the 

probable cause as the PIC's failure to maintain airspeed. Factors included the failure of both 

pilots to follow company CRM and flight manual procedures, and the PIC's improper approach 

briefing.

Both pilots were hired during a period of rapid expansion for the carrier and moved through 

what the NTSB report described as a “rushed’ upgrade program. The PIC had 2,548 hours, with 

200 in make-model. The commercially-rated SIC had 1,850 hours, with 90 hours in make-model. 

The PIC had been an instructor when the carrier hired her 21 months before the accident. She 

had accrued 600 hours as an SIC in the BE-1900 and, based on seniority, qualified for upgrade to 

PIC in the ERJ. The SIC was hired with 400 flight hours, flew as SIC on the Beech 1900, and, 

based on seniority, then upgraded to the ERJ as an SIC. Neither pilot had any prior experience in 

swept-wing aircraft, nor had the carrier provided any jet training on swept-wing aerodynamics. 

The emphasis of the proposed rule on better preparation of pilots for Part 121 operating 

environments, more training in energy management, stall recognition, aerodynamics, and 

professionalism would have directly affected this accident.
39

USA Jet Crash at Saltillo, Mexico, July 6, 2008 (Effectivness Rating = 0.55)

The most significant accident to receive the next highest score of 0.55 involved a DC-9

operated by USA Jet on a cargo flight, which crashed in heavy fog while on approach in 

mountainous terrain to Saltillo, Mexico. The PIC was killed and the SIC seriously injured. 

Before the crash, the flight data recorder shows the aircraft alternating above and below the glide 

slope and left and right of the localizer throughout the approach. The aircraft ultimately stalled 

and crashed 1,000 feet short and 500 feet to the right of the runway. 

The SIC on the flight was an experienced flight engineer but had just 830 hours as a pilot and

75 hours as a Part 121 pilot. A more experienced SIC likely would have called for a go-around or 

may have been willing to intervene and increase the thrust, either action of which would have 

averted the accident.

Accidents with the Highest Effective Cost

In this section, a description of the three accidents with the highest effective cost is provided. 

The avoidance of high effective cost accidents provides most of the benefits of the proposed rule.

Avjet Crash at Aspen, Colorado, March 29, 2001 (Effectiveness Rating = 0.35)

On March 29, 2001, a Gulfstream III operated as a part 135 charter flight by Avjet 

Corporation, crashed while on final approach to Aspen-Pitkin County Airport (ASE), Aspen, 

Colorado. The airplane crashed about 2,400 feet short of the runway threshold after the flight 

crew continued an unstabilized approach below Minimum Descent Altitude without having 

adequate visual reference. The crew failed to follow company standard operating procedures for 

a proper briefing for the approach, FAA regulations for non-precision approach procedures and 
40

sterile cockpit rules below 10,000 feet.22 The PIC also failed to establish a professional 

atmosphere in the cockpit. The crew failed to implement proper division of duties between the 

flying pilot and the non-flying pilot, as both pilots were looking out the cockpit window for the 

airport so that neither one was monitoring the aircraft’s position vertically. The PIC, SIC, flight 

attendant, and all 15 passengers were killed and the aircraft was destroyed.

Corporate Airlines Crash at Kirksville, Missouri, October 19, 2004 (Effectiveness Rating = 

0.35)

On October 19, 2004, Corporate Airlines flight 5966, a BAE Systems BAE-J3201, struck 

trees on final approach and crashed short of runway at the Kirksville Regional Airport (IRK), 

Kirksville, Missouri. The airplane struck trees short of the runway threshold after the flight crew 

continued an unstabilized approach below Minimum Descent Altitude without adequate visual 

reference. The crew failed to follow FAA regulations for non-precision approach procedures and 

sterile cockpit rules below 10,000 feet. The crew also failed to implement proper division of 

duties between the flying pilot and the non-flying pilot, as both pilots were looking outside the 

cockpit window for the airport so that neither one was monitoring the aircraft’s position 

vertically. The PIC, SIC, and 11 of the 13 passengers were killed. The two surviving passengers 

received serious injuries and the aircraft was destroyed.

Colgan Air Crash at Buffalo, NY, February 12, 2009 (Effectiveness Rating = 0.35)

On February 12, 2009, a Colgan Air, Inc. Bombardier DHC-8-400, operating as Continental 

Connection flight 3407, was on an instrument approach to Buffalo-Niagara International Airport, 

 22 “Sterile cockpit rules” refers to FAA rules forbidding nonessential activities by crewmembers below 10,000 feet, 

such as nonessential conversations within the cockpit and nonessential communications between the cockpit crews 

and the cabin.
41

Buffalo, New York, when it crashed into a residence about five miles short of the runway after 

the PIC lost control of the aircraft. The crew failed to follow FAA regulations for sterile cockpit 

rules below 10,000 feet. The crew also failed to implement proper division of duties between the 

flying pilot and the non-flying pilot, as both pilots had their attention diverted with the 

consequence that neither pilot was monitoring the aircraft’s airspeed or pitch. The PIC

additionally failed to establish a professional atmosphere in the cockpit. The PIC, SIC, two flight 

attendants, and all 45 passengers aboard the airplane were killed. One person on the ground was 

also killed and the airplane was destroyed. 

In each of these accidents SOPs and FAA regulations were not followed owing to lack of 

professional behavior initiated by the PIC, but quickly assimilated by the SIC. Additionally, in 

each case the PIC was the pilot flying and therefore each SIC had the responsibility to monitor 

the aircraft and report deviations but failed to do so. The ATP Certification Training Course of 

the proposed rule has multiple modules to address these causal factors: 

• Operating in a multi-crew environment 

• Introduction to crew resource management

• Aerodynamics

• Knowledge based decisionmaking

• Pilot monitoring responsibilities, including communications, risk management, decision 

making, leadership, emergency operations and difficult operating conditions

• Threat and error management

• Energy management 

• Stall recognition/recovery
42

• Manual Handling Skills

Total Benefits of the Proposed Rule

Table 14 below shows the estimated cost of accidents that would have had some likelihood 

of being prevented had the proposed rule been in effect in the period 2001-2010, taking into 

account 30 part 135 accidents as well as the 31 part 121 accidents:

Table 14. Estimated Cost of FOQ Rule-Related Accidents, FY 2001-2010

Operations

No. of 

Accidents

FatalitiesSerious 

Injuries

Minor 

Injuries

Full Cost 

of 

Fatality/

Injuries

($ mil.) 

Full 

Amt of 

AP 

Dmge

($ mil.) 

Full 

Accident 

Cost

($ mil.) 

Wtd Ave. Rule 

Effectiveness

($ mil.)

Effective 

Accident 

Cost

($ mil.) 

Part 121 31 65 14 37 $ 409.2 $ 77.4 $ 486.6 0.344 $ 167.4 

Part 135 30 42 14 7 $ 267.0 $131.3 $ 398.3 0.297 $ 118.3 

Total 61 107 28 44 $ 676.2 $208.7 $ 884.9 0.323 $ 285.8 

Notes. Column sums may be off by one or more units from totals owing to rounding.

For the 61 accidents partially attributable to pilot qualification issues, over the 10-year 

sample period we the full accident cost is estimated to be $884.9 million. As the table shows, the 

weighted average effectiveness (weighting by full accident cost) for all accidents is 0.323.

Multiplying this figure by the full accident cost yields the effective accident cost of $285.8 that 

the FAA estimates to be attributable to pilot qualification issues. Appendix 4 shows the 

calculations by individual accident.

It is assumed the chance of an accident is equally likely in any year of the 10-year estimation 

period, for an average effective cost of $28.58 million per year. Without the proposed rule, it is 

assumed that effective costs would grow at an annual rate of 3.5%, the average annual growth 
43

rate for air carrier revenue passenger miles forecast by the FAA for the period, 2009-2030.23

With the proposed rule, these projected costs become, as avoided costs, benefits of the proposed 

rule, which are shown for the estimation period, 2013-2032, in Table 15 below.

Table 15. Estimated Benefits of Proposed Rule, 2013-2032

7% Discount rate

3.5% Estimated annual growth rate in benefits

20 Number of years of estimation period

13.880 20-year growing annuity factor

2013 

Benefits

($ mil.) 

Benefits, 

2013-2032

($ mil.)

20-yr 

growing 

annuity 

factor, 

discounted 

2 years

Present 

value 

benefits,

2013-2032

($ mil.)

$ 31.68 $ 896.0 12.12335 $ 384.1

As the table shows, estimated total benefits for the estimation period, 2013-2032 are almost 

$900 million. Multiplying the estimated $31.68 million in benefits for 2013 by the 20-year 

growing annuity factor, discounted 2 years, yields present value benefits of about $384 million.

The Number of Avoided Accidents and Avoided Fatalities

In this section we calculate directly key primary variables underlying the expected 

benefits of the proposed rule--the number of accidents and the number of fatalities we expect the 

proposed rule to prevent. In Table 16, we multiply the sample number of part 121 and part 135 

accidents (from Table 14) by their corresponding weighted average effectiveness rating to obtain 

the expected number of accidents and fatalities that would have been prevented had the proposed

rule been in effect.24

 23 U.S. DOT, FAA, Aviation Policy & Plans. FAA Aerospace Forecast: 2010-2030. Table 5, "U.S. Commercial Air 

Carriers' Total Scheduled U.S. Passenger Traffic", Revenue Passenger Miles, System [Domestic + Int'l], Avg 

Annual Growth, 2009-2030

24 What is calculated here is the “effective” number of accidents and fatalities avoided since the most costly 
44

Table 16. Number of Accidents and Fatalities Preventable by Proposed Rule 

 Using 2001-2010 Sample Period Accidents

Operations

No. of 

Accidents

Fatalities

Wtd 

Ave. 

Effectiveness

Expected 

No. of 

Accidents 

Avoided

Expected 

No. of 

Fatalities 

Avoided

Part 121 31 65 0.344 10.7 22.4

Part 135 30 42 0.297 8.9 12.5

Total 61 107 0.323 19.7 34.6

Note: The sum of part 121 and part 135 accidents and fatalities avoided may not equal the 

“Total” number owing to the weighting scheme and/or rounding error

In Table 17 we use the average number of expected accidents and fatalities avoided per 

year from the Table 16 analysis to project the total number of accidents and fatalities that, with

the proposed rule, would be prevented over the 20-year estimation period, 2013-2032. As with 

benefits, we assume the number of accidents and fatalities would grow at the annual rate of 

3.5%. Table 17 shows that 61.3 is the number of accidents that would be prevented by the 

proposed rule over the 20-year period, 2013-2032 (33.4 for part 121 and 27.9 for part 135). For 

fatalities Table 17 shows that 109.2 is the number that would be prevented (70.1 for part 121 and 

39.1 for part 135).

 

accidents (or, equivalently, the most beneficial avoided accidents) have greater weight in determining weighted 

average effectiveness.
45

Table 17. Number of Accidents and Fatalities Avoided Under the Proposed 

 Rule, Estimation Period, 2013-2032

Year

Part 121 

Accidents 

Avoided

Part 135 

Accidents 

Avoided

Part 121 

Fatalities 

Avoided

Part 135 

Fatalities 

Avoided

2010 1.1 0.9 2.2 1.2

2011 1.1 0.9 2.3 1.3

2012 1.1 1.0 2.4 1.3

2013 1.2 1.0 2.5 1.4

2014 1.2 1.0 2.6 1.4

2015 1.3 1.1 2.7 1.5

2016 1.3 1.1 2.7 1.5

2017 1.4 1.1 2.8 1.6

2018 1.4 1.2 2.9 1.6

2019 1.5 1.2 3.0 1.7

2020 1.5 1.3 3.2 1.8

2021 1.6 1.3 3.3 1.8

2022 1.6 1.3 3.4 1.9

2023 1.7 1.4 3.5 2.0

2024 1.7 1.4 3.6 2.0

2025 1.8 1.5 3.7 2.1

2026 1.8 1.5 3.9 2.2

2027 1.9 1.6 4.0 2.2

2028 2.0 1.7 4.2 2.3

2029 2.1 1.7 4.3 2.4

2030 2.1 1.8 4.5 2.5

2031 2.2 1.8 4.6 2.6

2032 2.3 1.9 4.8 2.7

Subtotal 33.4 27.9 70.1 39.1

Total 61.4 109.2

Note: Sums may not equal “Subtotal” or “Total” owing to rounding error.
46

APPENDIX 1—Costs and Benefits of the Proposed Rule by Rule Provision and Corresponding Public Law Provision

Public Law Provision NPRM Proposal Total 

Cost1

PV 

Cost1

Total 

Benefit1

PV 

Benefit1

Net Total 

Benefit

Net PV 

Benefit

“All flight crewmembers – have obtained an airline transport pilot certificate under part 

61 of title 14, Code of Federal Regulations[.]” (Section 216 of P.L.)

ATP certificate for all part 

121 pilots

Part 121

$ 1,575.2

Part 121

$ 582.0

Part 

1213

At most 

$ 53.8

Part 

1213

At most 

$ 23.0

Part 121

($ 1,521.4)

Part 121

($ 559.0)

ATP practical test

1,500 hour requirement

$ 0.0

$ 1,575.22

$ 23.3

$ 558.72

“ensure that . . . all flight crewmembers – have appropriate multi-engine aircraft flight 

experience, as determined by the Administrator.” (Section 216 of the P.L.)

50 hours aeronautical 

experience in class of 

airplane for ATP

minimal

cost

- - - - -

“ensure that . . . all flight crewmembers – have appropriate multi-engine aircraft flight 

experience, as determined by the Administrator.” (Section 216 of the P.L.)

Aircraft type rating for all 

pilots operating in part 121

Part 121

$ 0.0

Part 121

$ 3.4

Part 

1214

At least 

$ 471.2

Part 

1214

At least 

$ 202.1

Part 

121

At least

$ 74.6

Part 

121

At least

$ 23.1

“The Administrator . . . shall conduct a rulemaking proceeding to amend part 61 of title 

14, Code of Federal Regulations, to modify requirements for the issuance of an airline 

transport pilot certificate.”

“MINIMUM REQUIREMENTS. To be qualified to receive an airline transport pilot 

certificate . . . an individual shall have received flight training, academic training, or 

operational experience that will prepare a pilot, at a minimum, to—

(A) function effectively in a multipilot environment;

(B) function effectively in adverse weather conditions, including icing conditions;

(C) function effectively during high altitude operations;

(D) adhere to the highest professional standards; and 

(E) function effectively in an air carrier operational environment.”

“The total flight hours required by the Administrator . . . shall include sufficient flight 

hours, as determined by the Administrator, in difficult operational conditions that may 

be encountered by an air carrier to enable a pilot to operate safely in such conditions.”

(Section 217 of the P.L.)

ATP certification training 

program for multiengine 

class rating or type rating

Part 121

$ 396.6

Part 121

$ 175.6

Part 

1355

$ 32.5

Part 91

$ 14.3

Part 

1355

$ 14.8

Part 91

$ 6.5

Part 

1355

$ 371.0

Part 916

No 

estimate

Part 

1355

$ 159.0

Part 916

No 

estimate

Part 

1355

$338.5

Part 916

No estimate

Part 

1355

$ 144.2

Part 916

No

estimate

“The Administrator may allow specific academic training courses . . . to be credited 

toward total flight hours[.]” (Section 217 of the P.L.)

ATP w/restricted privileges 

based on academic or military 

training

The reduced cost of obtaining an ATP with fewer than 1,500 hours has been 

accounted for in the $1,575.2 cost of the ATP provision. The proposal reduces total 

cost of the ATP provision by $ 725.5 and PV cost by $ 264.5.

“ensure that . . . all flight crewmembers – have appropriate multi-engine aircraft flight 

experience, as determined by the Administrator.” (Section 216 of the P.L.)

1,000 hours in air carrier 

operations to serve as PIC in 

part 121

minimal

cost

- - - - -

Total Costs and Benefits of the Rule $ 2,018.5 $ 782.4 $ 896.0 $ 384.1 ($ 1,122.5) ($398.3)

Notes:

1 All cost and benefit figures are in millions of dollars.

2 Total cost without the academic crediting provision is $2,520.4. Present value cost is $901.8.

3 Maximum benefits attributable to accidents that involved SICs with fewer than 1,500 hours (assumes no other causes for the accidents).

4 At least 90% of the part 121 benefits come from the type rating and the ATP certification training program.

5 All costs and benefits for part 135 operators are attributable to the ATP certification training program.

6 The FAA does not have an estimate for part 91 operators. Given the overwhelming benefit to part 135, the FAA is confident that the proposed rule is cost-beneficial for 

 91K operators. Accordingly, Net benefits shown in the “Total Costs and Benefits of the Rule” row are calculated using the corresponding cost and benefit figures in that row

 and not by summing column totals.
47

APPENDIX 2

Table 1. Summary of Costs and Benefits of Proposed FOQ Rule, 2013-2032

(3% Discount Rate) 

Total Cost

($ mil.) 

PV Cost

($ mil.) 

Annualized 

PV Cost

($ mil.) 

Part 121 ATP Certificate Requirement $ 1,357.8 $ 869.2 $ 58.4

 ATP Practical Test $ - $ 17.0 $ 1.1

 ATP 1,500 Hour Requirement $ 2,158.2 $ 1,359.1 $ 91.4

 Savings from 750-hour ATP Military Training Credit $ (188.2) $ (118.5) $ (8.0)

 Savings from 500-hour ATP Aviation Degree Credit $ (612.2) $ (388.5) $ (26.1)

Type Rating (Part 121 Operators Only) $ - $ 1.7 $ 0.1

ATP Certification Training Program $ 443.3 $ 305.5 $ 20.5

 Part 121 Operators $ 272.9 $ 18.3

 Part 135 Operators $ 32.5 $ 22.6 $ 1.5

 Part 91, Subpart K, Operators $ 14.3 $ 9.9 $ 0.7

Total Social Cost--Part 121 Operators

(Pre-statutory baseline) $ 1,754.4 $ 1,143.9 $ 76.9

Total Social Cost (Pre-statutory baseline) $ 1,801.1 $ 1,176.5 $ 79.1

Costs Attributable to Proposed Rule--Part 121 Operators

(Post-statutory baseline) $ 396.6 $ 274.7 $ 18.5

Costs Attributable to Proposed Rule

(Post-statutory baseline) $ 443.3 $ 307.3 $ 20.7

Total Benefits

($ mil.)

PV 

Benefits

($ mil.)

Ann. PV 

Benefits

($ mil.)

Part 121 Benefits $ 525.0 $ 355.9 $ 23.9 

Part 135 Benefits $ 371.0 $ 251.5 $ 16.9 

Total Social Benefit $ 896.0 $ 607.4 $ 40.8 

Notes: 1. Although a social cost, the cost of the ATP certificate requirement is not a cost attributable to the proposed rule, as the requirement is 

specifically mandated by the Airline Safety Act of 2010.

2. Although incremental total costs of the ATP practical test and type rating are zero, incremental present value costs are positive. See discussion 

in the text below.

3. The same flight test qualifies a pilot for both the ATP certificate and the type rating. The incremental present value cost of the type rating 

requirement ($3.4 million) occurs because more current pilots have ATP certificates than type ratings.

4. Owing to a requirement of a preliminary version of this paper, the incremental cost of the type rating requirement includes the cost of the ATP 

written exam. As this is an extremely small cost, it was not reallocated here to the cost of the ATP certification requirement.

5. Annualized PV Cost/Benefit is the annual cash flow of the 20-year annuity that yields the same present value as the cost/benefit item.

6. For the ATP 1,500 hour requirement, total cost is lower under 3% discounting compared to 7% discounting since total cost per pilot over the 20-

year estimation period is calculated on the basis of annualizing the pilot’s assumed 35-year career total earnings.

7. Column sums may be off one or more units from totals owing to rounding.
48

APPENDIX 3

Estimated Market Value of Air Carrier Aircraft, 2008

PAX Airplanes Cargo Airplanes

Airplane Category

No. of 

APs

Wt Ave 

2008 Mkt 

Value

($ mil.)

No. 

of 

APs

Wt Ave 

2008 Mkt 

Value

($ mil.)

Two-Engine Narrow Body 3,283 $ 17.28 156 $ 11.11 

Two-Engine Wide Body 476 $ 43.62 272 $ 21.47 

Three-Engine Narrow Body 6 $ 0.54 140 $ 0.94 

Three-Engine Wide Body 18 $ 11.05 208 $ 24.01 

Four-Engine Narrow Body 0 NA 67 $ 2.66 

Four-Engine Wide Body 50 $ 44.19 102 $ 29.35 

Regional Jet under 70 Seats 1,337 $ 8.67 NA NA

Regional Jet 70 to 100 Seats 522 $ 19.56 NA NA

Turboprop under 20 seats (Pt 23) 48 $ 0.88 NA NA

Turboprop under 20 seats (Pt 25) 177 $ 1.35 NA NA

Turboprop with 20 Seats or More 384 $ 4.52 NA NA

Piston Engine (Pt 23) NA NA NA NA

All Airplanes 5,917 $ 16.46 945 $ 16.79 

Sources: 1. Table is an APO update to 2008 of 2003 data in Economic Values for FAA Investment and Regulatory 

Decisions, a Guide, pp. 5-1--5.6. Office of Aviation Policy and Plans, U.S. Federal Aviation Administration, 

Washington, DC, Final Report, Revised October 3, 2007. Online at www.faa.gov, Regulation & Policies, Policy & 

Guidance, Benefit-Cost Analysis, Economics Values for FAA Investment and Regulatory Decisions, Final Report, 

Revised October 3, 2007.

2. Aircraft Numbers: Fleet database, OAG Aviation Solution, 3025 Highland Pkway, Suite 200, Downers Grove, Il 

60515.

3. Aircraft Market Values: Airliner Price Guide, vol. 72, July, 2008. Herndon, Va.

Notes: 1. Restoration costs are estimated as 13% of airplane values for passenger airplanes and 15% for cargo 

airplanes (Economic Values, p. 5-5).

2. Estimated market values for jets used in Part 135 operations are from Economics Values, Table 5-7, p. 5-9,

updated from 2003 to June, 2010 by the CPI-U price relative for June, 2010 compared to June, 2001 (218.0/183.7 = 

1.1867).

3. Restoration costs for jets used in Part 135 operations are estimated as 16% for Part 25 jets weighing < 65,000 lbs 

and 2% for Part 25 jets weighing > 65,000 lbs. (Economic Values, Table 5-10, p. 5-12).
49

APPENDIX 4

Pilot Certification and Qualification Rule-Related Accidents, FY 2001-2010 (Part 121 Operations)

Date

Carrier

Airplane Category

Airplane 

Value

($ mil.) Operations Type

FatalitiesSerious 

Injuries

Minor 

Injuries

Full Cost of 

Fatality/

Injury 

AP 

Dmge 

Code

Full 

Amt 

of AP 

Dmge 

Full 

Accident 

Cost 

Rule 

Effectiveness

Effective 

Accident 

Cost 

04/28/04 Centurion Air Cargo 3-Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $ - 1 $24.01 $ 24.01 0.15 $ 3.60 

08/13/04 Air Tahoma Turboprop <20 Seats (pt 25) $ 1.35 Part 121 Cargo 1 1 0 $ 6.74 1 $ 1.35 $ 8.09 0.75 $ 6.07 

08/30/04 Custom Air Transport 3-Engine Narrow Body $ 0.94 Part 121 Cargo 0 0 0 $ - 0.15 $ 0.14 $ 0.14 0.35 $ 0.05 

09/19/04 FedEx 3-Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $ - 0.15 $ 3.60 $ 3.60 0.15 $ 0.54 

06/07/05 UPS 3-Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $ - 0.15 $ 3.60 $ 3.60 0.15 $ 0.54 

05/16/08 Asia Pacific Airlines 3-Engine Narrow Body $ 0.94 Part 121 Cargo 0 0 0 $ - 0.15 $ 0.14 $ 0.14 0.35 $ 0.05 

07/06/08 USA Jet 2-Engine Narrow Body $ 11.11 Part 121 Cargo 1 1 0 $ 6.74 1 $11.11 $ 17.85 0.55 $ 9.82 

01/27/09 Empire Turboprop <20 Seats (pt 25) $ 1.35 Part 121 Cargo 0 1 1 $ 0.59 1 $ 1.35 $ 1.94 0.15 $ 0.29 

10/22/00 Frontier Flying Ser Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 0 $ - 0.13 $ 0.59 $ 0.59 0.35 $ 0.21 

11/20/00 Atl So East Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 1 0 $ 0.58 0 $ - $ 0.58 0.55 $ 0.32 

02/10/01 Great Lakes (as United Express) Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 7 $ 0.11 0.13 $ 0.59 $ 0.69 0.55 $ 0.38 

10/16/01 Mesa (US Airways Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.75 $ 0.85 

04/18/02 ATA 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 2 10 $ 1.31 0 $ - $ 1.31 0.15 $ 0.20 

06/16/02 Vanguard 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $ - 0.13 $ 2.25 $ 2.25 0.15 $ 0.34 

01/06/03 ExpressJet (Continental Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.55 $ 0.62 

05/24/03 Southwest 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $ - 0.13 $ 2.25 $ 2.25 0.15 $ 0.34 

11/14/03 United 4-Engine Wide Body $ 44.19 Part 121 Pax 0 0 0 $ - 0.13 $ 5.74 $ 5.74 0.15 $ 0.86 

05/09/04 American Eagle Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 13 $ 0.20 0.13 $ 0.59 $ 0.78 0.35 $ 0.27 

10/19/04 Corp. Airlines (American Connection) Turboprop 20+ Seats $ 4.52 Part 121 Pax 13 2 0 $ 81.27 1 $ 4.52 $ 85.79 0.35 $30.03 

04/29/05 Southwest 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 1 0 $ 0.58 0 $ - $ 0.58 0.15 $ 0.09 

05/31/05 Air Wisconsin (as United Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 1 0 $ 0.58 0 $ - $ 0.58 0.15 $ 0.09 

09/18/05 Spirit 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $ - 0.13 $ 2.25 $ 2.25 0.15 $ 0.34 

07/24/06 American Eagle Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.15 $ 0.17 

04/12/07 Pinnacle as NoWest Airline Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.15 $ 0.17 

06/20/07 Great Lakes Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 0 $ - 0.13 $ 0.59 $ 0.59 0.75 $ 0.44 

12/16/07 Air Wisconsin Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.15 $ 0.17 

08/14/08 Trans States as American Connection Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $ - 0.13 $ 1.13 $ 1.13 0.55 $ 0.62 

02/12/09 Colgan Air Turboprop 20+ Seats $ 4.52 Part 121 Pax 50 0 0 $308.13 1 $ 4.52 $312.65 0.35 109.43 

05/06/09 World Airways 3-Engine Wide Body $ 11.05 Part 121 Pax 0 1 3 $ 0.62 0.13 $ 1.44 $ 2.06 0.15 $ 0.31 

08/27/09 Airtran 2-Engine Narrow Body $ 17.28 Part 121 Pax 0 1 0 $ 0.58 0 $ - $ 0.58 0.15 $ 0.09 

06/28/10 American Eagle Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 2 3 $ 1.20 0 $ - $ 1.20 0.15 $ 0.18 
50

APPENDIX 4 (cont.)

Pilot Certification and Qualification Rule-Related Accidents, FY 2001-2010 (Part 135 Operations)

Date Carrier Airplane Category

Airplane 

Value($ 

mil.) Operations Type

FatalitiesSerious 

Injuries

Minor 

Injuries

Full Cost of 

Fatality/Injury 

AP 

Dmge 

Code

Full 

Amt 

of AP 

Dmge 

Full 

Accident 

Cost 

Rule 

Effectiveness

Effective 

Accident 

Cost 

08/28/01 Grand Aire Express Part 25 Jet 65,000 lbs+ $ 26.52 On-Demand Cargo 0 0 0 $ - 0.02 $ 0.53 $ 0.53 0.15 $ 0.08 

04/08/03 Grand Aire Express Part 25 Jet 65,000 lbs+ $ 26.52 On-Demand Cargo 0 2 0 $ 1.16 1 $26.52 $ 27.68 0.15 $ 4.15 

01/09/07 Ameristar Jet Charter Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Cargo 2 0 0 $ 12.33 1 $ 8.51 $ 20.83 0.35 $ 7.29 

01/10/07 Airnet Systems Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Cargo 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.55 $ 0.75 

02/24/09 Bankair Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Cargo 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.15 $ 0.20 

10/26/01 American Jets International Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Med 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.35 $ 0.48 

08/30/02 Care Flight International Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Med 1 4 0 $ 8.47 1 $ 8.51 $ 16.98 0.35 $ 5.94 

07/02/04 Air Trek Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Med 6 0 0 $ 36.98 1 $ 8.51 $ 45.49 0.35 $15.92 

03/17/07 Air Trek Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Med 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.15 $ 0.20 

12/20/00 Million Air Dallas Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.35 $ 0.48 

03/29/01 Avjet Part 25 Jet 65,000 lbs+ $ 26.52 On-Demand Pax 18 0 0 $110.93 1 $26.52 $137.45 0.35 $48.11 

03/25/02 Corporate Flight Management Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.35 $ 0.48 

08/13/02 Corporate Flight International Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 1 $ 8.51 $ 8.51 0.15 $ 1.28 

11/11/03 West Coast Charters Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.35 $ 0.48 

02/20/04 Aztec Capital Corporation Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 1 1 $ 0.59 0.16 $ 1.36 $ 1.95 0.15 $ 0.29 

03/19/04 AirNet Systems Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.35 $ 0.48 

11/28/04 Air Castle Corporation Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 3 3 0 $ 20.22 1 $ 8.51 $ 28.73 0.35 $10.06 

07/15/05 Aspen Base Operations Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 1 3 $ 0.62 0.16 $ 1.36 $ 1.98 0.15 $ 0.30 

01/05/06 Netjets as Executive Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.15 $ 0.20 

06/02/06 International Jet Charter Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 2 0 3 $ 12.37 1 $ 8.51 $ 20.88 0.35 $ 7.31 

08/23/07 Jet Share US Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 0 0 0 $ - 0.16 $ 1.36 $ 1.36 0.15 $ 0.20 

07/31/08 East Coast Jets Part 25 Jet < 65,000 lbs $ 8.51 On-Demand Pax 8 0 0 $ 49.30 1 $ 8.51 $ 57.81 0.15 $ 8.67 

03/13/02 Warbelows Air Ventures TP<20 (pt 23) $ 0.88 Commuter 0 0 0 $ - 0.15 $ 0.13 $ 0.13 0.15 $ 0.02 

08/24/02 Cape Smythe Air Service TP<20 (pt 23) $ 0.88 Commuter 0 0 0 $ - 0.15 $ 0.13 $ 0.13 0.15 $ 0.02 

07/13/03 Air Sunshine TP<20 (pt 23) $ 0.88 Commuter 2 0 0 $ 12.33 0.15 $ 0.13 $ 12.46 0.35 $ 4.36 

04/04/04 Peninsula Airways TP<20 (pt 23) $ 0.88 Commuter 0 0 0 $ - 0.15 $ 0.13 $ 0.13 0.75 $ 0.10 

09/17/04 Everts Air Alaska TP<20 (pt 23) $ 0.88 Commuter 0 0 0 $ - 0.15 $ 0.13 $ 0.13 0.15 $ 0.02 

02/19/09 Frontier Flying Service TP<20 (pt 23) $ 0.88 Commuter 0 1 0 $ 0.58 0.15 $ 0.13 $ 0.71 0.15 $ 0.11 

02/01/10 Cape Air TP<20 (pt 23) $ 0.88 Commuter 0 0 0 $ - 0.15 $ 0.13 $ 0.13 0.35 $ 0.05 

03/15/10 Servant Air TP<20 (pt 23) $ 0.88 Commuter 0 2 0 $ 1.16 1 $ 0.88 $ 2.04 0.15 $ 0.31
51

Appendix 5—Effectiveness Ratings by Airline Safety Act Rule for Seven 

Highlighted FOQ Accidents

 Effectiveness Rating

Date Carrier Location

Ops 

Type Aircraft Type FOQ N&O PR&D SMS

FOQ High Effectiveness Rating Accidents

10/16/01 Mesa Roanoke, VA Part 121 ERJ-145 0.75 0.75

08/13/04 Air Tahoma Florence, KY Part 121 CV-580 0.75 0.20

06/20/07 Great Lakes Laramie, WY Part 121 BE-1900D 0.75 0.55 0.15 0.20

07/06/08 USA Jet Saltillo, Mex Part 121 DC-9-15F 0.55

FOQ High Effective Cost Rules

03/29/01 Avjet Aspen, CO Part 135 Gulfstream III 0.35

10/19/04 Corporate Airlines Kirksville, MO Part 121 BAE-32 0.35 0.35 0.75 0.10

02/12/09 Colgan Air Buffalo, NY Part 121 DHC-8-400 0.35 0.75 0.50 0.10

Table Note: The NTSB and other accident investigation authorities aim to identify all potential hazards 

that contribute to an accident in an effort to establish probable cause and contributing factors. 

Accidents rarely result from a single failure or action; rather they usually result from a chain of 

events. By eliminating, mitigating, or managing the hazards identified in the chain, future accidents 

may be avoided. Each hazard identified in an accident is usually independent of other hazards 

identified in the same accident. For this reason, aviation safety standards organizations around the 

world take steps to address each hazard, often in separate rulemakings. Consequently, for an 

accident with hazards addressed by multiple rules, it is possible for effectiveness ratings to sum to 

greater than 100 percent. 

Sources:

FOQ (First Officer Qualifications): Pilot Certification and Qualification Requirements for Air Carrier 

Operations (Draft proposed rule).

N&O: Qualification, Service, and Use of Crewmember and Aircraft Dispatchers (SNPRM), 76 FR 

29336 (May 20, 2011).

PR&D (Pilot Rest & Duty): Flightcrew Member Duty and Rest Requirements (Final Rule), 77 FR 55852 

(Jan. 4, 2012).

SMS (Safety Management Systems): Safety Management Systems for Part 121 Certificate Holders 

(NPRM), 75 FR 68224 (Nov. 5, 2010).