FEDERAL AVIATION ADMINISTRATION

EXECUTIVE SUMMARY

TITLE: Pilot Certification and Qualification Requirements for Air Carrier Operations

ACTION: This action would create new certification and qualification requirements for pilots 

in air carrier operations. The proposal would require a second in command (SIC) in part 121 

operations to hold an airline transport pilot (ATP) certificate and a type rating for the aircraft to 

be flown. The FAA proposes to allow pilots with an aviation degree or military pilot experience 

to obtain an ATP certificate with restricted privileges with fewer than 1,500 hours total time as a 

pilot. The proposal also would require at least 1,000 flight hours in air carrier operations in order 

for a pilot to serve as a pilot in command (PIC) in part 121 air carrier operations. Finally, the 

FAA is proposing to modify the requirements for an ATP certificate with an airplane category 

multiengine class rating or type rating to include 50 hours of multiengine flight experience and 

completion of a new FAA-approved ATP Certification Training Program. The training would 

include academic training and training in a flight simulation training device. These proposed 

requirements would ensure that pilots have proper qualifications and experience in difficult 

operating conditions and in a multicrew environment prior to serving as flightcrew members in 

air carrier operations.

STATEMENT OF THE PROBLEM: The Federal Aviation Administration is initiating this 

rulemaking project to address some of the factors that may have influenced the Colgan Air (dba 

Continental Airlines Express) accident that occurred on February 12, 2009, outside of Buffalo, New York. 

Additionally, this proposed rule responds to a Congressional mandate in Public Law 111-216, which 

requires the FAA to revise the eligibility, training, and qualification requirements for pilots engaged in air 

carrier operations.

EFFECT OF THIS ACTION: Pilots preparing to enter air carrier operations would have a stronger 

foundation of aeronautical knowledge and experience as a result of the increased flight time and training

requirements for obtaining an ATP certificate. Requiring an aircraft type rating for all SICs in part 121 

operations will ensure all part 121 pilots are trained and tested to the same standard with respect to the 

aircraft to be flown. Requiring pilots to have air carrier experience prior to serving as PIC in part 121 

operations would assist in their professional development and develop the competencies necessary to

assume the greater responsibilities of a PIC.

EFFECT ON FAA: The Air Transportation Division of the Flight Standards Service would be 

responsible for approving the curriculum of all part 141 pilot schools, part 142 training centers, and part 

121 or part 135 certificate holders who would elect to offer the proposed ATP Certification Training 

Program. Additionally, FAA inspectors or designees would be needed to administer the proposed aircraft 

type rating test for SICs in part 121 operations. Finally, the FAA would need to revise the ATP 

knowledge test and practical test standards.
“SIGNIFICANCE”: This notice of proposed rulemaking is a “significant regulatory action” as 

defined in section 3(f) of E.O. 12866, and is “significant” as defined in DOT’s Regulatory Policies and 

Procedures due to the Congressional mandate.

CONTROVERSIAL ISSUES: Pilots seeking an ATP certificate with airplane category multiengine 

class rating or type rating would be required to complete the proposed ATP Certification Training 

Program, which could impose additional time and financial burdens on individual pilots. Requiring all 

part 121 SICs to have an aircraft type rating could impose a financial burden on some operators. 

Requiring a pilot to have air carrier experience prior to serving as a PIC in part 121 operations may delay 

his or her career advancement. Finally, although an applicant for an ATP certificate with restricted 

privileges would be required to pass the same written and practical tests, the proposed reduced-hour

requirement for an ATP certificate may be controversial.

COSTS AND BENEFITS: We estimate that the cost will be minimal for the requirement of 50 hours 

of multiengine time for an ATP certificate with airplane category multiengine class rating or type rating. 

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

operating experience before serving as PIC in part 121 operations. 

As a result of our provision allowing pilots with an aviation degree or military pilot experience to 

hold a restricted-privileges ATP certificate with less than 1,500 flight hours, we have reduced by 

$945 million the costs of the statutory requirement that all pilots in part 121 operations have an 

ATP certificate by August 2, 2013. Nevertheless, on a pre-statute baseline, about 75% of the rule’s 

costs are the result of this requirement, making the proposed rule not cost-beneficial. The requirement

will take effect, however, whether or not a regulation is issued. We believe that a post-statute baseline is 

appropriate and, therefore, the costs associated with this provision are attributable to the statute, not this 

proposed regulation. On a post-statute baseline, the proposed rule is cost-beneficial.

The remaining costs of the rule are associated with the aircraft type rating requirement for part 121 SICs 

and the ATP Certification Training Program.

Along with the benefits, the table below summarizes the costs of the proposed rule:

Total Cost

($ mil.)

PV Cost

($ mil.)

Part 121 ATP Certificate Requirement $ 1,575.2 $ 582.0 

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

ATP Certification Training Program $ 443.3 $ 196.9

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

Costs Attributable to Proposed Rule

(Post-statute baseline) $ 443.3 $ 200.4

Total

Benefits

($ mil.)

PV 

Benefits

($ mil.)

Total Social Benefits $ 896.0 $ 439.8 

Note: Column sums may be off one or more units from totals owing to rounding.
INFORMATION REQUESTED: Throughout the NPRM the FAA invites commenters to 

address specific questions pertaining to the proposed requirements. The information requested 

includes: 

• The adequacy of the minimum hour requirements for an ATP certificate;

• The requirement for additional multiengine experience for pilots applying for an ATP 

certificate;

• The requirement for SICs in part 121 operations to hold an aircraft type rating;

• The appropriateness of permitting applicants with specific military and academic training 

to apply for an ATP with fewer than 1,500 hours of flight time;

• The appropriate combination of academic training and training in a flight simulation 

training device for the ATP Certification Training Program; and

• Consideration for an alternative licensing structure, such as a multicrew pilot license.

The FAA also added additional questions at the request of OMB. Those questions pertain to the 

rule’s impact on pilot supply and potential areas in air carrier training programs that could be 

removed as a result of the ATP Certification Training Program. OMB also asked the FAA to 

seek comment on accident effectiveness ratios.