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U.S. Department of Transportation

FEDERAL AVIATION ADMINISTRATION

REGULATORY EVALUATION

QUALIFICATION, SERVICE AND USE OF CREWMEMBERS 

AND AIRCRAFT DISPATCHERS

FINAL RULEMAKING

(14 CFR PART 121)

Office of Aviation Policy and Plans 

Regulatory Analysis Division

Volpe National Transportation System Center

George Thurston

October 2013
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TABLE OF CONTENTS

I. INTRODUCTION.......................................................................................3

II. BACKGROUND........................................................................................5

III. GENERAL BENEFIT-COST ANALYSIS ASSUMPTIONS...............................10

IV. BENEFIT ANALYSIS..............................................................................11

V. COST ANALYSIS....................................................................................35

VI. BENEFIT COST SUMMARY.......................................................................66

VII. APPENDICES.........................................................................................69
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I. INTRODUCTION

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

“Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers”. Based on a public

meeting and comments, along with an increase in the NPRM scope, the FAA updated the NPRM 

and the regulatory evaluation. We then published a supplemental notice of proposed rulemaking 

(SNPRM) in May 2011. After reviewing the changes proposed in the NPRM and the SNPRM, 

the agency has decided to move forward with a final rule that increases safety benefit by 

including certain provisions that enhance pilot training for rare, but high risk scenarios. This 

focus reduces the overall requirements as proposed in the NPRM and SNPRM.

The final rule adds safety-critical tasks to pilot training such as recovery from stall and upset 

with an emphasis on manual handling skills. In addition, the final rule requires enhanced runway 

safety training, training on pilot monitoring duties for the pilot not flying to be incorporated into 

existing requirements for scenario-based flight training, and requires air carriers to implement 

remedial training programs for pilots. The FAA expects these changes to contribute to a 

reduction in aviation accidents. Additionally, the final rule revises recordkeeping requirements 

for communications between the flightcrew and dispatch; ensures that personnel identified as 

flight attendants have completed flight attendant training and qualification requirements; 

provides civil enforcement authority against those making fraudulent statements; and, provides a 

number of conforming and technical changes to existing air carrier crewmember training and

qualification requirements. The final rule also includes provisions that codify current processes 

that provide training efficiencies for certificate holders who operate multiple aircraft types with 

similar design and flight handling characteristics. 

In developing the training and evaluation requirements, the FAA reviewed the current 

requirements in subparts A, M, N, O, P, T, V and Y as well as the flight training tasks listed in 

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

Appendix H (advanced simulation) of part 121.
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Table 1 shows the FAA’s estimate for the base case costs, including the low and high cost range, 

in 2012 dollars. Table 1 also shows our estimated potential quantified safety benefits using a 22-

year historical accident analysis period.

Table 1

Total Benefits and Costs (2012 $ Millions) From 2019 to 2028
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II. BACKGROUND

The regulations governing training and qualification requirements for crewmembers engaged in 

operations under part 121 are found in 14 CFR part 121 subparts N and O1

. Subpart N 

prescribes the requirements for establishing and maintaining a training program for 

crewmembers, aircraft dispatchers, and other operations personnel and requirements for the use 

of training devices in conducting the program. Subpart O prescribes crewmember qualifications

related to the final rule. Appendix E to part 121 establishes the training tasks required for initial, 

transition, and upgrade pilot flight training. Appendix F to part 121 establishes the tasks for pilot 

proficiency checks. Appendix H to part 121 provides guidelines and a means for using advanced

airplane simulators for flightcrew training and checking. 

This rule is necessary to address several National Transportation Safety Board (NTSB) 

recommendations and addresses the requirements in the Airline Safety and Federal Aviation 

Administration Extension Act of 2010 (the 2010 Act).

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 Under the 2010 Act, Congress directed 

the FAA to conduct rulemaking to ensure that all flightcrew members receive ground training 

and flight training in recognizing and avoiding stalls, recovering from stalls, and recognizing and 

avoiding upset of an aircraft, as well as the proper techniques to recover from upset. The 2010 

Act also directed the FAA to ensure air carriers develop remedial training programs for flight 

crew members who have demonstrated performance deficiencies or experienced failures in the 

training environment. 

The FAA reviewed the crewmember and aircraft dispatcher training regulations to identify 

improvements in training program content and application. Although the agency’s review is 

ongoing, we have identified the following areas where changes were necessary to the current 

rules:

• Fraud and falsification,

• Personnel identified as flight attendants,

 1 Further references to part 121 operators include both part 121 and part 121/135 operators listed in the FAA 

National Vital Information Subsystem (NVIS) database. 2 Public Law 111-216. 
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• Proficiency checks for pilots in command (PIC),

• Related aircraft differences training, 

• Training equipment other than Flight Simulation Training Device (FSTD) approved under 

part 60,

• Approval of FSTDs, 

• Pilot monitoring, 

• Remedial training,

• Communication record for domestic and flag operations,

• Training for instructors and check airmen who serve in FSTDs,

• Extended envelope flight training maneuvers and procedures,

• Extended envelope ground training subjects,

• Runway safety maneuvers and procedures, and

• Crosswinds maneuvers with gusts.

On May 20, 2011, the FAA published the Supplemental Notice of Proposed Rulemaking 

(SNPRM). Following a four month comment period ending on September 19, 2011, the FAA 

received 134 comments on the SNPRM and regulatory evaluation.3 These comments came from 

air carriers, trade associations, labor unions, the National Transportation Safety Board (NTSB), 

the Families of Continental Flight 3407, and many individual commenters. The FAA fully 

considered these comments in developing the final rule and regulatory evaluation.

One of the commenters’ major concerns was the proposal would cause additional training, and 

therefore costs, to operators who train their pilots under the Advanced Qualification Program 

(AQP). Based upon further review of the final rule requirements and AQP curriculums, the FAA 

has concluded that the final rule contains training tasks that are not currently included in existing 

pilot AQPs. Therefore, the final rule will increase the training costs for all pilots who operate in 

part 121 service, including those who train under an AQP.

 3 http://www.regulations.gov/#!docketDetail;dct=PS+O+SR+FR;rpp=10;so=ASC;sb=postedDate;po=280;D=FAA2008-0677 . Accessed March 22, 2013.
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Based on public comments and further agency review of the proposal, the FAA made the 

following changes to the regulatory evaluation for the final rule:

• Re-estimated costs and benefits to correspond directly to the provisions of this final rule. 

The final rule focuses on safety-critical enhancements to pilot training for rare, but highrisk scenarios.

• Assumed that the final rule will affect all AQP and non-AQP trained pilots in command, 

second in command pilots, check pilots, and flight instructors by adding simulator and 

ground school time to their current training curriculum. 

• Accounted for paperwork costs documenting the required revisions to part 121 operators

pilot training programs.

• Updated the value of averted fatalities, injuries, accident investigation and medical costs 

based on current U.S. Department of Transportation (DOT) guidance.4

• Updated the hourly wages and benefits for aircraft crew members with current hourly 

wages from the Bureau of Labor Statistics (BLS).

• Removed airfare, hotel, and per diem travel costs from the cost estimates because the 

FAA believes operators will be able to complete the new final rule training requirements 

within their current initial, upgrade, transition, or recurrent simulator and ground school 

training days. The FAA conducted a sensitivity analysis on the costs of the final rule 

adding an additional day of travel. The results of the sensitivity analysis are shown in 

Appendix 10. Even with the cost of an extra day of travel, the benefits of the final rule 

still exceed the costs.

• Conducted a new accident analysis that took into account the mitigations of other final 

rulemakings for the same accidents in determining the probability of effectiveness for this

final rule. 

• Assumes that the “Flight Simulation Training Devices Qualification Standards For 

Extended Envelope and Adverse Weather Event Training Tasks” rulemaking (RIN 2120-

AK08) rulemaking is in place by the time compliance is required with the new pilot 

training requirements because amendments to FSTD qualification and evaluation 

 4 “Revised Departmental Guidance 2013: Treatment of the Value of Preventing Fatalities and Injuries in Preparing 

Economic Analysis.” available at http://www.dot.gov/regulations/economic-values-used-in-analysis
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standards in part 60 are needed to support the new full flight simulator training 

requirements in this final rule. In addition, the agency recognizes that the final rule on 

Pilot Certification and Qualification Requirements for Air Carrier Operations will be in 

place at the time that compliance is required with the pilot training requirements in this 

final rule. 

• Included a table in Appendix 13 comparing the probability of effectiveness ratings of the 

overlapping accidents from the Flightcrew Member Duty and Rest Requirements final 

rule, the Pilot Certification and Qualification Requirements final rule and this final rule.

• Updated employment growth rates for pilots based on current FAA forecasts and actual 

February 2013 employment statistics for part 121 operators.

• Updated the hourly simulator costs from the $550 estimate used in the SNPRM to $500 

for the final rule based on updated FAA Flight Standards Service (AFS) data. This 

revised cost maintains consistency with analysis from the “Pilot Certification and 

Qualification Requirements for Air Carrier Operations” final rule published on July 15, 

2013 (78 FR 42324). 

• Conducted a sensitivity analysis on the hourly simulator rental rate using the $550 rate 

from the SNPRM. We estimated $323.1 million for the total costs using the $550 hourly 

rate. The total benefits, as shown in Table 22, exceed the costs for the $550 hourly 

simulator rental rate.

• Initiated the “Flight Simulation Training Device Qualification Standards for Extended 

Envelope and Adverse Weather Event Training Tasks” rulemaking to amend 14 CFR Part 

60 to require the additional programming and upgrades to simulators, which will be 

needed to comply with extended envelope training required by the final rule. The FAA 

estimates that the $500 hourly simulator rental rate assumed in this analysis includes all 

upgrades expected to be required by the Flight Simulation Training Device rulemaking.

As an alternative, we also conducted a sensitivity analysis using $600 for an hourly 

simulator rental rate. We estimated $332.4 million for the total costs with the $600 

hourly rate. The total benefits as shown in Table 22 also exceed the costs for $600 hourly 

simulator rental rate.

• Conducted a sensitivity analysis to explore the effect of reducing the historical analysis 

period from the 22 year period to 10 years in response to comments disputing the use of a 
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22-year time frame for accidents. Appendix 14 shows that using the 10-year period, the

estimated benefits of this final rule increase by approximately 17 percent.

• Changed the pilot ground school distance learning5 percentage from the 80 percent 

estimate used in the SNPRM to 100 percent, because the FAA allows 100 percent of nonhands on pilot ground training to be accomplished via distance learning.6

 Therefore, the 

FAA assumes that 100% of the non-hands on pilot ground training required by the final 

rule can be done via distance learning.

 5 Distance learning allows pilots to train out of the classroom (such as at home). 6 FAA Order 8900.1, Vol.3, Ch. 19, Sec. 5, Para. 3-1209 (July 15, 2013). The FAA notes pilot ground school 

training requirements include hands-on emergency equipment training (current §121.417(c) requires that every 24 

months, pilots must perform hands-on drills on aircraft emergency equipment) that may not be accomplished via 

distance learning. The costs for those hands-on drills are not included in this cost analysis because they are 

currently required.
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III. GENERAL BENEFIT-COST ANALYSIS ASSUMPTIONS

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

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

the estimation of the quantified benefits and discuss the qualitative benefits. Next, we discuss 

the estimation of the quantified costs. Lastly, we summarize the estimated benefits and costs for 

the final rule. 

The benefit and cost analysis for the regulatory evaluation is based on the following 

factors/assumptions:

• The analysis is conducted in constant dollars with 2012 as the base year.

• The estimates of costs and benefits reported in this evaluation include both 2012 dollar 

values and present values. Benefits and costs are calculated in present values using both 3

percent and 7 percent discount rates as prescribed by OMB in Circular A-4. 

• This final rule will be published in late 2013.

• This final rule will become effective in 2014, 120 days after its publication. Compliance is 

required on the effective date (120 days) for a few of the provisions, including for example 

all technical amendments, §§ 121.9 (falsification), 121.392 (identification of personnel as 

flight attendants), and 121.711 (communication records). Compliance with the provisions

related to training is required within 5 years after the effective date. We note, however, that 

individual air carriers may submit proposed training program revisions for approval at any 

point after the effective date. The agency will work with each air carrier to meet their 

implementation needs. 

• Although some incidental costs are expected to occur prior to 2019, the primary analysis 

period for costs and benefits extends for 10 years, from 2019 through 2028. This period was 

selected because annual costs and benefits will have reached a steady state by 2019.
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IV. BENEFIT ANALYSIS

The FAA contracted Volpe National Transportation System Center to assist the FAA with the 

estimation of the final rule’s benefits and the forecast of future accidents, fatalities and injuries. 

The FAA estimates of the phased-in benefits of this final rule over the analysis interval are 

shown in Table 1. These benefits are anticipated to result from the additional operational and 

training requirements of the final rule. The FAA estimates that these requirements will reduce 

the probability of aviation accidents. Reducing the probability of their recurrence generates 

benefits in the form of reductions in the expected fatalities, injuries, and other costs resulting 

from such accidents. The regulations will enhance traditional pilot training programs by 

requiring training in areas that NTSB and FAA have identified as critical to preventing the 

recurrence of certain types of accidents.

Benefit Assumptions

In addition to the general assumptions identified at the beginning of this section, the FAA made 

the following specific assumptions to facilitate the benefit analysis for this regulatory evaluation:

• Safety benefits will be realized beginning in 2019, when compliance is required with the 

new training provisions in the final rule. 

• Past accident history from 1988 to 2009 (22 years) is an appropriate basis on which to 

forecast the likely future occurrence of the types of accidents that the training and other 

provisions of this rule will help to prevent. The Accident Population and Scoring section 

provides the reasons for a 22-year benefit period.

Accident Population and Scoring

The FAA expects that the major benefit of the final rule will be to prevent or reduce the 

probability of certain types of aircraft accidents in the future. For the benefits analysis, the FAA 

analyzed the causal factors, as determined by the NTSB, for past accidents that occurred in part 

121 operations. The objective of the analysis was to determine if an accident could have been 

prevented or mitigated by the training provisions in the final rule. In 1988, Delta flight 1141

crashed shortly after lifting off from the runway at the Dallas-Fort Worth International Airport 
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(DCA88MA072). In its final report, the NTSB determined that one causal factor for the accident 

was “The captain and first officer’s inadequate cockpit discipline which resulted in the 

flightcrew’s attempt to take off without wing flaps and slats properly configured.” 

As a result of the accident investigation, the NTSB made recommendations to the FAA that 

emphasized the importance of training and manual procedures regarding “the roles of each flight 

crewmember in visually confirming the accomplishment of all operating checklist items,” as well 

as the “verification of flap position during stall recognition and recovery procedures.”

The FAA determined that the pilot monitoring training and operational provisions may have 

prevented or mitigated this accident. The pilot monitoring training will provide pilots an 

opportunity to practice monitoring skills in an environment that closely simulates real line 

operations. The operational requirements will require flightcrew members to follow air carrier 

procedures regarding pilot monitoring. Together, these provisions establish an active 

requirement for the pilot not flying the aircraft to remain engaged throughout the flight by 

monitoring the pilot flying, as well as the position of the aircraft, the flight instruments, the 

configuration of the aircraft, etc. The provisions will ensure that the pilot monitoring is prepared 

to notify the pilot flying of any anomalies or to assume the flying responsibilities if necessary. If 

these requirements had been in place at the time of this accident, the pilot monitoring may have 

identified the incorrect configuration and notified the pilot flying prior to takeoff.

Therefore, the FAA initiated the historical accident interval for the benefits analysis with this 

accident in 1988. The FAA concluded the accident interval in 2009 with the Colgan accident 

because, at this time, the NTSB still has not finalized its reports on the major accidents (that may 

be pertinent to this training rule) that occurred in 2010 and 2011. This is why the FAA uses the 

same 22 year accident interval (1988-2009) for the benefits analysis in the final rule as in the 

SNPRM. 

The FAA identified 10 additional major accidents with casual factors identified by the NTSB 

that are addressed by the provisions in the final rule that occurred during this 22 year accident 

interval. The FAA cited these accidents in the benefits analysis based on pertinent accident 
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causal factors, regardless of whether or not there were open NTSB recommendations associated 

with those accidents. 

In response to comments questioning the use of a 22-year period, however, the FAA conducted a 

sensitivity analysis to explore the effect of reducing the historical analysis period from 22 years 

to 10 years. As indicated in Appendix 14, using the 10-year historical accident analysis period 

increases the estimated benefits of the final rule by approximately 17 percent.

The analysis conducted for the Regulatory Evaluation accompanying the SNPRM identified 149 

pilot-related accidents during the 22 year historical analysis period covering 1988 to 2009 for 

which the proposed rule would reduce the probability of their recurrence. The FAA Accident 

Investigation and Prevention Group (AVP) and FAA’s Flight Standards Service (AFS) 

subsequently determined that the more limited set of regulatory changes in this final rule address 

the causal factors (as determined by the NTSB) involved in nine of those 149 historical pilotrelated accidents. For further explanation regarding the limited set of regulatory changes, please 

see Section I of the final rule preamble, “Overview of Final Rule.”

For example, 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, Buffalo, New York, when it crashed into a residence in Clarence Center, 

New York, about five nautical miles northeast of the airport resulting in the death of everyone 

aboard and one person on the ground. The NTSB determined that the probable cause of this 

accident was the pilot in command’s (PIC) inappropriate response to the activation of the stick 

shaker, which led to an aerodynamic stall from which the airplane did not recover. The PIC’s 

response was inappropriate because he pulled back on the control column rather than pushing it 

forward to reduce the angle of attack. As a result, the airplane’s pitch increased and its airspeed 

decreased, resulting in the stall. A contributing factor was both pilots’ failure to monitor 

airspeed via their primary flight display and thus their failure to recognize the impending stick 

shaker onset as airspeed fell and pitch increased. The NTSB noted that the “failure of both pilots 

to detect this situation was the result of a significant breakdown in their monitoring 

responsibilities and workload management.” The PIC’s poor response suggests he was surprised 
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by activation of the stick shaker. Another contributing factor was the crew’s lack of 

professionalism in failing to follow FAA sterile cockpit rules below 10,000 feet. The PIC had 

3,379 hours total flying time and the second in command (SIC) 2,244 hours. Had the flightcrew 

been required to complete the extended envelope training provisions required by this final rule, 

this accident would likely have been mitigated. 

Also, on September 8, 1994 a USAir (now US Airways) Boeing 737-300, flight 427, crashed 

while maneuvering to land at Pittsburgh International Airport, Pittsburgh, Pennsylvania. Flight 

427 was operating as a scheduled domestic passenger flight from Chicago-O'Hare International 

Airport, Chicago, Illinois, to Pittsburgh. The flight crew did not report any problems with the 

airplane and radar data indicates that the closest other traffic was about 4.5 miles and 1,500 feet 

vertically separated from flight 427 at the time of the accident. About 6 miles northwest of the 

destination airport, the airplane entered an uncontrolled descent and crashed near Aliquippa, 

Pennsylvania. All 132 people on board were killed, and the airplane was destroyed by impact 

forces and fire. The NTSB determined that the probable cause of the accident was a loss of 

control of the airplane resulting from the movement of the rudder surface to its limit. The rudder 

surface most likely deflected to its limit in a direction opposite to that commanded by the pilots 

as a result of a failed main rudder power control unit (PCU). The FAA has determined that the 

provisions regarding upset prevention and recovery training in this final rule may have prevented 

or mitigated this accident. 

In addition, given the changes adopted in the final rule and the impact the training provisions 

will have on air carriers who provide training under an Advanced Qualification Program, the 

FAA has determined that two additional accidents, American 587 and Continental 1404, 

involved contributing factors that are addressed by the final rule. 

On November 12, 2001 an American Airlines A300-600, flight 587, crashed in a residential area 

of Belle Harbor, New York. The airplane accident occurred shortly after takeoff from John F. 

Kennedy International Airport, Jamaica, New York. All 260 people aboard the airplane and 5 

people on the ground were killed, and the airplane was destroyed by impact forces and a postcrash fire. The NTSB found the probable cause of this accident to be the in-flight separation of 
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the vertical stabilizer as a result of the loads beyond ultimate design caused by the SIC’s

unnecessary and excessive rudder pedal inputs. The rudder input was a reaction to wake 

turbulence. Characteristics of the Airbus A300-600 rudder system design and elements of the 

American Airlines Advanced Aircraft Maneuvering Program also contributed to the incorrect 

rudder pedal inputs. The NTSB found that the American Airlines Advanced Aircraft 

Maneuvering Program excessive bank angle simulator exercise could have caused the SIC to 

have an unrealistic and exaggerated view of the effects of wake turbulence; erroneously associate 

wake turbulence encounters with the need for aggressive roll upset recovery techniques; and 

develop control strategies that would produce a much different, and potentially surprising and 

confusing, response if performed during flight. The provisions adding upset prevention and 

recovery training in this final rule may have mitigated this accident because the training delivers 

recovery strategies which focus on primary control inputs and early intervention strategies.

7

 

Further, the provisions that require pilots to complete upset prevention and recovery training in a 

full flight simulator (FFS) with an instructor who has been trained on the specific motion and 

data limitations of the FFS, would mitigate the possibility of delivering negative training in 

simulation.8 

On December 20, 2008, a Continental Airlines Boeing 737-500, flight 1404, departed the left 

side of runway 34R during takeoff from Denver International Airport, Denver, Colorado. At the 

time of the accident, visual meteorological conditions prevailed, with strong and gusty winds out 

of the west. The NTSB reported that, as the airplane crossed the uneven terrain before coming to 

a stop; the airplane became airborne, resulting in a jarring impact when it regained contact with 

the ground. A post-crash fire ensued and the airplane was substantially damaged. The PIC and 5 

of the 110 passengers were seriously injured; the SIC, 2 cabin crewmembers, and 38 passengers 

sustained minor injuries. The NTSB accident report revealed that before starting the takeoff roll 

the PIC verbally repeated the wind speed and direction; however, during the takeoff roll the PIC

inconsistently applied cross wind correction. The NTSB found that the probable cause of the 

 7 All pilots have received training on wake turbulence from the early stages of flight training. Since wake 

turbulence can lead to an upset condition, the enhanced training required in this rule will reinforce earlier training by 

teaching pilots appropriate upset prevention and recovery techniques. 8 Appendix 15 provides a sensitivity analysis to determine the impact of removing the catastrophic American 587 

accident from the benefits analysis for the 10 and 22 year historical accident analysis intervals.
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accident was the PIC’s ceased rudder input, which was needed to maintain directional control of 

the airplane, about 4 seconds before the excursion, when the airplane encountered a strong and 

gusty crosswind that exceeded the PIC’s training and experience. The FAA has determined that 

the expansion of existing requirements for training on crosswind maneuvers to include wind 

gusts in this final rule may have prevented or mitigated this accident. 

American 587 and Continental 1404 were excluded from the benefits estimates reported in the 

SNPRM because the SNPRM analysis assumed that the proposed rule would have no impact on 

the safety of flights operated by pilots trained using an Advanced Qualification Program (AQP).

Following further review of existing AQP curriculums and the pilot training requirements

retained for the final rule, the agency has determined that the majority of the rule’s new pilot 

training maneuvers and procedures are not incorporated into existing AQPs used to train pilots; 

therefore, it is appropriate to include those two additional accidents in this analysis. For these 11 

accidents, the NTSB investigations identified several specific areas of inadequate training that 

were either the probable cause or a contributing factor for many of these accidents. Of the 11 

pilot-related accidents, nine accidents involved one or more fatalities and two had no fatalities.

To determine the likely probability of effectiveness of the final rule in preventing the recurrence 

of accidents similar to the 11 accidents identified in the historic period, AVP undertook a 

multiple-step process. The FAA recognizes that there are multiple rulemakings occurring in 

parallel with this final rule and there is some degree of overlap among them regarding the 

historical accidents used to estimate benefits.9 Therefore, to account for the relationship of these 

new rules, AVP first rated the effectiveness of the entire suite of these rules in reducing the 

probability of the future recurrence of these accidents, using the scoring process of the 

Commercial Aviation Safety Team (CAST).10 AVP used the NTSB recommendations along 

 9 Specifically, these parallel rulemakings are: Flightcrew Member Duty and Rest Rule (FDR); Pilot Certification and 

Qualification Requirements for Air Carrier Operations Rule (FOQ); Flight Simulation Training Device Qualification 

Standards for Extended Envelope and Adverse Weather Event Training (part 60) and Safety Management Systems 

for part 121 Certificate Holders (SMS). 10 The FAA evaluated these historical accidents in the context of the other rulemakings such that the sum of the 

probabilities for each accident across all these rules will not exceed one. Appendix 13 details the overlap of the 

probability for each accident in the parallel rules that are published as a final rule.
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with its narrative descriptions, probable cause findings, identification of contributing factors, and 

other pertinent data to assign scores reflecting the likelihood that the collection of these rules 

could have prevented each accident in the final rule analysis interval. 

AVP developed these scores using a Joint Implementation Monitoring Data Analysis Team 

(JIMDAT)-like method because many of the issues surrounding these accidents are not clearly 

defined in the probable cause or contributing factors statements of the NTSB reports. The 

JIMDAT-like score, as applied to a specific historical accident, is based upon the likelihood that 

the training, operational, and other changes these rules collectively require would have prevented 

the occurrence of that accident if they had been in place at the time it occurred. AVP used a 

sliding percentage scale of zero to 0.9 to describe the score assigned to each accident. 

The second step of the process was to allocate the overall probability of effectiveness for the 

suite of new rules to each individual rule, so that the safety-related benefits of each individual 

rule – which arise from the projected effectiveness of that specific rule in reducing the 

probability of future accidents – could be estimated. AVP used the same zero to 0.9 sliding scale 

noted above to arrive at the final effectiveness ratings. In some cases, this effort to allocate the 

composite probability of effectiveness among individual rules is complicated by their

interrelatedness. For instance, this final rule requires additional simulator training for pilots, 

while the upcoming part 60 rulemaking would establish the requirements that simulators be 

capable of providing the enhanced training capabilities required under this final rule. In that case,

the combined probability of effectiveness of these two rules was allocated roughly evenly 

between this final rule and the part 60 rulemaking.

Table 2 shows probability of effectiveness for this final rule for the 11 historical accidents that 

were used as the basis for estimating its benefits, and also reports important summary 

information regarding these accidents. Appendix 1 and Appendix 2 provide additional details of 

the historical accidents.
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Table 2

Selected Characteristics of 11 Historic Accidents (1988-2009)

Quantification of Safety Benefits

This section describes the methodology the FAA used to quantify the safety benefits for the final 

rule. Appendix 3 identifies the specific provisions of this final rule that respond to the probable 

causes and contributing factors that the NTSB identified for each historic accident. Because 

many accidents were the result of multiple contributing factors, and the provisions of this final 

rule were developed to respond to these contributing factors, there are several cases where the 

rule’s probability of effectiveness for an historical accident is the result of the expected impacts 

of multiple provisions of the rule. For that reason, the FAA has not attempted to develop separate 

benefit estimates for each individual provision of this rule, and our quantitative estimates of the 

rule’s benefits will be derived only for all of its provisions taken together. In addition, there are 

other provisions of the rule for which anticipated benefits can be described only in qualitative 

terms; these provisions will be discussed separately in a later section of this document. 

The following provisions of the final rule are expected to have quantifiable safety benefits:

• Pilot monitoring (§§ 121.544, 121.409, Appendix H),

• Remedial training (§§ 121.415(h) and § 121.415(i)),

• Extended envelope flight training maneuvers and procedures (§§ 121.423, 121.407(e), 

121.424, 121.427(d)(1)(i), 121.433(e), Appendix E),

• Extended envelope ground training subjects (§§ 121.419(a)(2) and 121.427),

• Runway safety maneuvers and procedures (Appendices E and F), and
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• Crosswind maneuvers including wind gusts (Appendices E and F).

The benefits of avoiding the recurrence of an accident potentially include avoided fatalities, 

injuries, aircraft replacement or repair, loss of cargo for cargo plane accidents, property damage 

on the ground, and accident investigation costs.11

In estimating the value of an averted future accident, we take the characteristics of the historic 

accidents as a starting point. No future accident is expected to have exactly the same causes or 

consequences as the historical accidents included in this analysis. Rather, this analysis uses these 

historical accidents to indicate the prevalence of accidents due to insufficient training in the past, 

and uses this information as an indication of how frequently these same types of accidents might 

occur in the future in the absence of this final rule. 

The accident history is also used to inform our estimates of the likely severity of these types of 

potential future accidents, which is measured by the percent of passengers aboard the aircraft that 

were injured (fatal, serious, minor), the extent of physical damage to the aircraft involved, and 

the extent of any physical damage on the ground. This analysis then applies forward-looking 

estimates of the value of preventing the recurrence of accidents of that same severity. For 

instance, the projected value of avoiding a hull loss during the future analysis period is not the 

actual economic value of the aircraft hull that was lost in an historical accident, but is instead the 

estimated value of an aircraft that would be likely to be in use in the future.

In estimating benefit values for avoided fatalities and injuries, the FAA follows the Department 

of Transportation’s (DOT) recently-issued document “Revised Departmental Guidance 2013: 

Treatment of the Value of Preventing Fatalities and Injuries in Preparing Economic Analysis.”12

That document estimates the value for preventing a fatality at $9.1 million (in 2012 dollars), 

while preventing a serious injury is valued at $1,264,900 (assumed to be the average of 

economic costs for severe, serious, and moderate injuries), and preventing a minor injury is 

 11 Avoided emergency response and environmental clean-up costs might be included as other categories of benefits 

but at this time FAA does not have access to estimates of these cost categories. The FAA believes the magnitude of 

the benefit categories to be relatively small in comparison to the other categories of benefits analyzed here.

12 Available at http://www.dot.gov/regulations/economic-values-used-in-analysis
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estimated to have an economic value of $27,300. As recommended in the recent DOT guidance 

document identified above, these values are then escalated at 1.07 percent per year to reflect the 

effect of growth in real income levels on the value that society collectively places on avoiding 

accidental fatalities and injuries. See Appendix 4 for more details.

In estimating the number of fatalities and injuries avoided by preventing the occurrence of future 

accidents, we calculate the number of fatalities and serious and minor injuries as percentages of 

the number of people on board the aircraft involved in each historic accident. Table 3 shows this 

information for each historical accident. We then apply those percentages to the expected 

passenger count on a typical future flight. The average number of passengers per flight for part 

121 passenger operations during 2012 was 84 persons, and the average seating capacity of the 

aircraft they operated was 106 seats.13 After allowing for three flight attendants (one for every 50 

seats) and two flightcrew members, this procedure assumes there would have been 89 people 

aboard a typical flight during 2012. For the single cargo plane accident (FedEx Flight 647), this 

analysis includes the benefits of avoiding the two minor injuries that occurred in the actual 

historical accident. Any additional fatalities or injuries on the ground that occurred in a historical 

accident are also included in the estimates, without adjustment. 

 13 Bureau of Transportation Statistics, Air Carrier Statistics, T-100 Segment Data (U.S. Carriers) for Jan – Oct 2012. 

The listing of part 121 carriers can be found in Appendix 8.
21

Table 3

Fatalities and Injuries as Percentages of People Onboard

* Details may not add to row or column totals due to rounding.

Table 4 shows the forecasted number of fatalities and injuries that would be expected to result if 

an accident of the same severity as the historical accident recurred in 2012, and involved the 

typical airplane carrying 89 people. The 11 historical accidents resulted in a total of 601 

fatalities, 48 serious injuries, and 137 minor injuries. In contrast, the method described above 

results in estimates of 44 fewer fatalities, 16 additional serious injuries, and 16 additional minor 

injuries from an identical number of similarly severe potential future accidents. This discrepancy 

results because although the average number of people on board the aircraft involved in the 

historical accidents (90) is in line with the average future passenger load projected for this 

analysis (89), two of the historical accidents (American 587 and USAir 427) occurred on larger 

than average aircraft and were catastrophic. This means that the actual accident history shows 

higher fatalities than we assume would occur in the future without the final rule. The decision to 

use expected future values for aircraft size and passenger counts is made because the FAA 

believes that the risk of a catastrophic accident is not specific to a certain size of aircraft. All 

FAA regulations require the same level of pilot training and qualifications for all part 121 

operations, regardless of the size of aircraft they typically operate, so that improving pilot 

training is expected to uniformly reduce the probability that aircraft of all sizes will be involved 

in future accidents.

Carrier Flt# Fatalities

Serious 

Injuries

Minor 

Injuries

Total 

People 

Onboard

Colgan 3407 100% 0% 0% 49

American 587 100% 0% 0% 260

American Eagle 4184 100% 0% 0% 68

USAir 427 100% 0% 0% 132

COMAIR 5191 98% 2% 0% 50

Northwest 1482 18% 23% 59% 44

Continental 1404 0% 5% 36% 115

FedEx 647 0% 0% 29% 7

Delta 1141 13% 24% 46% 108

Corporate 5966 87% 13% 0% 15

USAir 5050 3% 5% 29% 63

Total 65% 5% 15% 911

Onboard
22

Our estimate of future benefits incorporates information related to the rule’s expected impacts on 

the aviation system looking forward in order to appropriately value the reduction in future risks. 

However, as a test of the sensitivity of our benefits estimates using this approach, we also 

include an analysis assuming that the exact number of fatalities and injuries as actually occurred 

in each historical accident would occur in a potential future accident. The details and results of 

those calculations are in Appendix 5. 

Table 4

Forecasted Fatalities and Injuries for Accidents

Table 5 below shows the estimated benefits from preventing the forecasted fatalities and injuries 

associated with the potential future recurrence of each of the 11 historical accidents. These 

estimated benefits have not yet been adjusted for the projected probability of effectiveness of the 

rule in preventing the recurrence of similar accidents in the future. Those adjustments are made 

in a later section. In addition, the benefits are projected to grow throughout the future analysis 

period, in order to account for projected growth in the airline industry.
23

Table 5

Valuation of Forecasted Fatalities and Injuries for Accidents (2012 $)

An additional benefit from preventing future accidents is avoiding damage to the aircraft itself. 

Again, we take the approach of estimating benefits based on the replacement value of a “typical” 

aircraft expected to be in the future fleet. As indicated previously, the average seating capacity 

per passenger flight operating under part 121 in 2012 was 106 seats.14 The FAA forecasts that 

seats per flight will grow by approximately 0.5 percent annually over the analysis period, which 

implies that the average seating capacity of part 121 passenger aircraft is expected to average 

112 by 2023, the midpoint of the benefits analysis period.15 With a capacity of 117 seats, the 

Boeing B717-200 is the aircraft model in the current US fleet which is the closest in size to 

average forecast size of 112 seats.16 We therefore estimate the value of a passenger aircraft of 

average size, and of average age to be $10.5 million based on the current market value of a nine 

year old Boeing B717-200. We estimate the value of a “typical” cargo aircraft to be $27.7 

million, based on the market values of average-aged Boeing B757-200, Airbus A300-600, and 

McDonnell Douglas MD-11, the most frequently used cargo airplanes used in part 121 

operations.17 Appendix 6 reports the details of these estimates. 

In all eleven historical accidents used as the basis for this benefit analysis, the primary aircraft 

was destroyed. In one case (Northwest 1482 on December 3, 1990), a second aircraft was 

 14 Bureau of Transportation Statistics, Air Carrier Statistics, T-100 Segment Data (U.S. Carriers) for Jan – Oct 

2012.

15 See Appendix 6, Table 1 for sources and methods. 16 Bureau of Transportation Statistics, Form 41, Schedule B-43, 2011. 17 Bureau of Transportation Statistics, Air Carrier Statistics, T-100 Segment Data (U.S. Carriers) for Jan – Oct 2012.
24

involved and also sustained substantial damage, but was later repaired and placed back in 

service. For that accident, the damage to the second aircraft was valued at 13 percent of the 

average replacement value.18 

In the case of the single cargo plane accident used in the benefits analysis (FedEx Flight 647), 

preventing the destruction of the cargo and the resulting loss of its value is an additional benefit 

category. While the FAA is unaware of published estimates for the value of air cargo, we derived 

the average value per ton of air cargo by assessing the commodity flow value and commodity 

flow weight of goods transported by air using the U.S. Department of Transportation’s 2007 

Freight Analysis Framework (FAF) Survey.19 Because both weight and value of commodities 

typically shipped by air vary by shipment origin and destination, the average value of all 

shipments by air was used. An average cargo value per ton of $89 thousand (in 2012 dollars) was 

calculated by dividing the average value of commodities shipped by air over all origins and 

destinations by the corresponding average weight of an air freight shipment, and then adjusted to 

2012 dollars using the change in the Gross Domestic Product deflator. The average amount of 

freight on a part 121 cargo-only aircraft operation is approximately 25 tons.20 Thus the value of 

the complete loss of the aircraft’s cargo on a typical flight is estimated to be $2.225 million in 

2012 dollars. 

In nine of the historical accidents, property damage on the ground was minimal because the 

aircraft accident occurred on or near the airport runway, in an undeveloped area such as a field, 

or in the water.21 However, the Colgan 3407 accident (February 12, 2009) destroyed one home 

on the ground, while the American 587 accident (November 12, 2001) destroyed four homes, 

severely or substantially damaged four other homes and one boat (parked in a driveway), and 

also resulted in minor damage to a retail gasoline station and three additional homes. To estimate 

 18 “Economic Values for FAA Investment and Regulatory Decisions, A Guide,” Oct. 3, 2007 by GRA, Incorporated, 

Table 5-4.

19 Freight Analysis Framework 2007, a joint survey conducted by the Census Bureau and BTS and updated every 5 

years. (http://www.bts.gov/publications/commodity_flow_survey/2007/state_summaries/) 20 Bureau of Transportation Statistics, Air Carrier Statistics, T-100 Segment Data (U.S. Carriers) for Jan - Oct 2012. 21 It is worth noting that where the accident actually occurs and subsequently how much damage occurs on the 

ground for any future possible accident that this final rule prevents cannot be known with any level of certainty. In 

the absence of data or forecasts on where these types of crashes are likely to occur, we use the information on the 

actual ground damage experienced in the historical accidents. 
25

the value of avoiding similar damage to ground property by preventing the recurrence of such an 

accident, the FAA used the 2012 median home value of $175,400.22 Roughly 25 percent of a 

typical home’s value is associated with the land and would not be destroyed by an accident, so 

the value for a destroyed house structure used in this analysis is $131,600 (75 percent of 

$175,400).23 The economic benefit from preventing severe or substantial damage to homes is in 

turn valued at 75 percent of this average structure value ($98,700); preventing minor damage (of 

homes and gas station) is estimated to result in benefits equal to 25 percent of structure value 

($32,900). For completeness, we have also included an estimate of the value of a pre-owned 

recreational boat to be $14,600.24

FAA estimates a value of $10.7 million for the accident investigation costs associated with a 

catastrophic accident, and $0.6 million for the accident investigation costs associated with a noncatastrophic accident.25 These values are derived from estimates of costs to NTSB, FAA, and 

private parties associated with historical accident investigations, adjusted to 2012 dollars using 

the GDP deflator.

Table 6 below shows these benefit calculations for preventing damage or destruction of aircraft 

hull values (primary and secondary aircraft), cargo value, property damage, and accident 

investigation costs applied to the 11 historic accidents. Again, note that these benefits estimates 

are not yet adjusted to reflect the rule’s probability of effectiveness in preventing similar future 

accidents. 

 22 Average of monthly U.S. Existing Home Median Sales Price from National Association of Realtors accessed at 

http://ycharts.com/indicators/sales_price_of_existing_homes on April 4, 2013. 23 Davis, Morris A. and Jonathan Heathcote, 2007, "The Price and Quantity of Residential Land in the United 

States," Journal of Monetary Economics, vol. 54 (8), p. 2595-2620; data located at Land and Property Values in the 

U.S., Lincoln Institute of Land Policy http://www.lincolninst.edu/resources/ accessed on April 4, 2013. Estimate is 

based on average aggregate U.S. quarterly values for Q4 2011 through Q3 2012 for both CWS and FHFA sources. 24 Average price of a pre-owned powerboat (with engine) in 2010 was $14,039 according to "Recreation Boating 

Stakeholders Growth Summit Industry Overview 2011" accessed at http://consensus.fsu.edu/BoatSummit/pdfs/Recreational%20Boating%20Growth%20Summit%20Industry%20Overview.pdf on April 4, 2013. 

This value has been adjusted to 2012 value using the GDP deflator. 25 The estimated accident investigation costs are the estimated costs of “Major” and “Air Carrier Weighted Average” 

investigations from “Economic Values for FAA Investment and Regulatory Decisions, A Guide,” Oct. 3, 2007 by 

GRA for the FAA, Table 8-2.
26

Table 6

Additional Categories of Benefits from Preventing Historic Accident (2012 $)

The next steps in estimating the benefits of the final rule are to adjust the estimated benefits from 

preventing each accident by the probability of effectiveness of this rule in preventing the 

recurrence of that specific accident, and then to project those annualized benefit values forward 

through the future analysis period. Table 7 displays the probability of effectiveness for each 

accident, along with the adjusted fatality and injury-related benefits estimates, and other 

categories of benefits derived using the forecasting methods discussed above. Each of the entries 

in the two columns containing these adjusted benefits estimates is equal to the entry in Table 5 

(fatalities and injuries) or Table 6 (other benefit categories) corresponding to a specific historical 

accident, multiplied by the estimated probability of effectiveness of the rule in preventing that 

accident shown in Table 7. The bottom two rows of Table 7 show the total estimated benefits of 

the rule if it had been in place during the full 22 years of the accident history, and the estimated 

average annual benefit of the rule.

Carrier Flt# Primary Secondary Total

Colgan 3407 $10,500,000 $131,600 $10,700,000 $21,331,600

American 587 $10,500,000 $1,067,400 $10,700,000 $22,267,400

American Eagle 4184 $10,500,000 $10,700,000 $21,200,000

USAir 427 $10,500,000 $10,700,000 $21,200,000

COMAIR 5191 $10,500,000 $10,700,000 $21,200,000

Northwest 1482 $10,500,000 $1,365,000 $600,000 $12,465,000

Continental 1404 $10,500,000 $600,000 $11,100,000

FedEx 647 $27,700,000 $2,225,000 $600,000 $30,525,000

Delta 1141 $10,500,000 $600,000 $11,100,000

Corporate 5966 $10,500,000 $10,700,000 $21,200,000

USAir 5050 $10,500,000 $600,000 $11,100,000

Total $132,700,000 $1,365,000 $1,199,000 $2,225,000 $67,200,000 $204,689,000

Accident 

Investigation 

Costs

Hull Damage Property 

Damage on 

Ground Cargo Value
27

Table 7

Single Year Benefits of Final Rule (2012 $)

The US airline industry has grown over time, and the FAA forecasts that the airline industry will 

continue to grow throughout the forecast period. This projected increase in traffic is 

accompanied by an increase in the risk of future accidents under the baseline scenario, where this 

rule would not be adopted. To incorporate the effect of forecasted growth on the number of 

future accidents prevented by the rule and the resulting economic benefits, we apply the FAA 

forecast of 2.1 percent annual growth in passenger enplanements to the estimates of benefits 

from avoided fatalities and injuries.26 This accounts for the effects of projected increases in both 

overall flight activity and the typical number of passengers aboard each flight on the reduction in 

future fatalities expected to result from adopting this rule. Table 8 below shows the resulting 

growth in the estimated number of annual fatalities and injuries avoided due to the final rule.27

We apply the 1.6 percent anticipated annual growth in commercial aircraft operations to the 

estimates of the other categories of benefits (avoided property damage and accident investigation 

costs), as these categories of benefits are more closely related to the number of flights rather than 

 26 FAA Aerospace Forecasts 2013 - 2033, Table 10, U.S. Mainline Air Carriers Schedules Passenger Traffic, 

Average Annual Growth Rate (2013-2033) for Revenue Passenger Enplanements (System). 27 Due to rounding, using the information in Table 8 to calculate the benefits from avoided fatalities and injuries will 

result in a slightly different total than is presented below.

Carrier Flt#

Effectiveness 

Rating

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

Colgan 3407 20% $163,800,000 $4,266,320

American 587 25% $213,850,000 $5,566,850

American Eagle 4184 20% $161,980,000 $4,240,000

USAir 427 20% $161,980,000 $4,240,000

COMAIR 5191 15% $119,135,370 $3,180,000

Northwest 1482 50% $86,202,450 $6,232,500

Continental 1404 25% $1,803,275 $2,775,000

FedEx 647 35% $19,110 $10,683,750

Delta 1141 35% $47,930,820 $3,885,000

Corporate 5966 5% $35,795,740 $1,060,000

USAir 5050 50% $16,527,050 $5,550,000

$1,009,023,815 $51,679,420

$45,864,719 $2,349,065

Total benefit over 22 year history

Per year benefit
28

the number of people on a flight.28 The projected future growth rates in passenger enplanements 

and the number of flights differ because the industry is moving toward larger aircraft with higher 

load factors; therefore an increase in passenger demand can be met with a less than proportionate 

increase in the number of flights. 

Table 8

Forecasted Growth in Fatalities and Injuries Avoided Due to Final Rule (2012 $)

As indicated previously, the unit values for fatalities and injuries avoided are escalated at 1.07 

percent per year to account for growth in real incomes, in accordance with DOT guidance.29 In 

the absence of information on how unit values for the other categories of benefits (aircraft hull 

damage, property damage on the ground, etc.) are likely to change in real terms over the future, 

the 2012 estimates of unit values for each other category of benefits are used throughout the 

future analysis period. Table 9 shows the results of these forecasting assumptions for each year 

of the 10-year benefit period for this rule, which extends from 2019 through 2028. To 

summarize, the annual benefits from avoided fatalities and injuries from the last row of Table 9 

are escalated by two factors: 1.07 percent per year to account for real income growth, and 2.1 

 28 FAA Aerospace Forecasts 2013 - 2033, p. 62.

29 “Revised Departmental Guidance 2013: Treatment of the Value of Preventing Fatalities and Injuries in Preparing 

Economic Analysis” available at http://www.dot.gov/regulations/economic-values-used-in-analysis
29

percent per year to reflect growth in passenger enplanements. The other categories of benefits 

from the last row of Table 9 are escalated at 1.6 percent per year, to account for future growth in 

the number of flights and the associated increase in accident risk exposure. In addition, Table 9 

displays the present value of the benefits over the future analysis period when discounted at both 

the seven percent and three percent rates recommended in OMB Circular A-4. 

Appendix 5 presents calculations that parallel this analysis, but instead use the actual fatalities 

and injuries resulting from each historical accident as the basis for an alternative estimate of the 

rule’s benefits. The calculations in Appendix 5 use the same 2012 estimates of property damage 

and accident investigation estimates as the central analysis, but do not incorporate any forecasted 

growth in industry-wide flight activity.

Table 9

Total Benefits of Final Rule (2012 $)

* Details may not add to row or column totals due to rounding.

The total estimated benefit of the final rule over the analysis period is $689.2 million in 2012 

dollars. This stream of benefits has a present value of $317.1 million when discounted at seven 

percent and $488.7 million when discounted at three percent. 
30

These benefits estimates differ from those presented as part of the SNPRM for several reasons. 

On one hand, certain changes in the benefits estimation methodology acted to lower the 

estimated benefits of the final rule. The final rule has fewer training requirements and other 

provisions than the previously-proposed version of the rule analyzed in the SNPRM; this results 

in lower benefits, because fewer accidents are judged to be prevented by the final rule. Further, 

the effectiveness ratings used in the SNPRM represented the impact of this rule when considered 

in isolation, while the probability of effectiveness used here take into account the reductions in 

accident risk expected to result from other contemporaneous rulemakings that FAA is 

undertaking. Thus for the most part, the probability of effectiveness ratings assigned to the 

accidents that could have been mitigated by this final rule are lower than those used in the 

SNPRM. 

The probability of effectiveness for USAir 427, which had an effectiveness rating of zero in the 

SNPRM, is the exception. USAir 427 crashed while maneuvering to land at Pittsburgh 

International Airport, Pittsburgh, Pennsylvania.30 As part of the analysis for the final rule, AVP 

re-evaluated the accidents to be included as the basis for the benefits estimates for the final rule. 

In doing so, AVP determined that the upset recovery and prevention training provisions in the 

final rule, together with the enhancements to simulators from the new part 60 rulemaking, may 

have prevented or mitigated the accident in such a way that the revised 20 percent probability of 

effectiveness was appropriate. Further, two additional accidents, American 587 and Continental 

1404, were added to the list of accidents used to develop the benefits estimates for the final rule 

when it was determined that the final rule would indeed improve the safety of flights operated by 

pilots trained using AQP. Finally, there have also been modifications to the unit values used to 

estimate the various benefit categories. The most significant change is that DOT guidance now 

specifies that benefit cost analyses use an estimate of $9.1 million for the value of preventing a 

fatality, whereas at the time of the SNPRM, the DOT guidance specified $6.0 million as the 

Value of Statistical Life (VSL) to use in benefit cost analyses.

 30 Appendix 1 and Appendix 2 provide additional details of the historical accidents.
31

On net, the methodology changes that acted to increase the estimated benefits outweighed the 

methodology changes that acted to reduce estimated benefits. As a result, the projected benefits 

for this final rule are higher than those estimated and reported in the SNPRM.

Qualitative Benefit Discussion

This section discusses the benefits of the remaining provisions of the final rule in qualitative 

terms:

• Fraud and falsification(§ 121.9),

• Personnel identified as flight attendants (§ 121.392),

• Proficiency checks for PICs (§ 121.441(a)(1)(ii)),

• Related aircraft differences training (§§ 121.400, 121.418, 121.434, 121.439, 121.441),

• Training equipment other than FSTDs approved under part 60 (§§ 121.408, 

121.403(b)(2)),

• Approval of FSTDs (§ 121.407),

• Communication records for domestic and flag operations (§ 121.711), and

• Training for instructors and check airmen who serve in FSTDs (§§ 121.413 and 121.414).

Fraud and falsification (§ 121.9)

Although fraud is currently prohibited by criminal statute, the FAA has added language 

prohibiting fraud and falsification to part 121 to emphasize the importance of truthful statements.

This provision prohibits fraudulent or intentionally false statements in, or a known omission 

from, any record or report that is kept, made, or used to show compliance with this part, or to 

exercise any privileges under this chapter. This provision enhances FAA enforcement options by

allowing the agency to take certificate action or assess a civil penalty against a person for making 

a fraudulent or intentional false statement. This provision may contribute to safety of the aviation 

system although it is not possible to quantify or value that improvement.

Personnel identified as flight attendants (§ 121.392)
32

This provision prohibits operators from identifying any person as a flight attendant if that person 

has not completed all flight attendant training and qualification. Individuals who have not 

completed all flight attendant training and qualification requirements must be clearly identified 

(e.g. via an announcement, by wearing civilian clothes, or not wearing a uniform). This 

provision may reduce confusion of passengers during an emergency situation on a flight who 

might otherwise presume that these individuals are fully qualified flight attendants. However 

FAA does not have access to any information that would allow for quantifying the safety benefit 

of this provision.

Proficiency checks for PICs (§ 121.441(a)(1)(ii))

Currently, in accordance with §§ 121.433(d) and 121.441(a)(1), a PIC who serves on more than 

one aircraft type must complete either recurrent flight training or a proficiency check on each 

aircraft type every 12 months. The final rule amends § 121.441(a)(1) to require PICs who fly 

more than one aircraft type to receive a proficiency check in each aircraft type flown every 12 

months. This amendment ensures PICs operating multiple aircraft types maintain proficiency on 

each aircraft type flown. However, the FAA does not have access to any information that would 

allow for quantifying the safety benefits of this provision. 

Related aircraft differences training (§§ 121.400, 121.418, 121.434, 121.439, 121.441)

This provision formalizes the current practice of allowing carriers and their pilots to take credit 

for training or qualification events on one type of aircraft, and apply that same credit to other 

aircraft types that have similar flight handling characteristics. This type of training credit is 

currently allowed in practice for some aircraft types, most notably the Boeing 757 and Boeing 

767. New advances in fly-by-wire technology allow aircraft manufacturers to design aircraft with 

different models and aerodynamic airframes that are operated in the same way. The ability to 

transfer credit for previous training and qualification on existing aircraft types to different but 

related aircraft types that have similar flight handling characteristics could offer a significant cost 

savings to carriers when they add new aircraft types to their fleets. In this scenario, they will not 

need to develop completely new training programs or completely retrain the pilots flying the new 
33

aircraft types. In addition, there are long term training and qualification efficiencies for pilots 

who are qualified on more than one related aircraft type, in the form of recurrent simulator 

training and qualification, as well as recency of experience requirements, operating experience 

requirements, and consolidation. Lowering the training costs for air carriers to adopt new aircraft 

types will speed up the entry of newer aircraft types into the fleet, which will also bring about 

social benefits from the reduced noise, emissions, and fuel usage that the newer aircraft types 

provide.

Training equipment other than FSTDs approved under part 60 (§§ 121.408, 

121.403(b)(2))

Current regulations do not provide specific requirements for training equipment other than 

FSTDs, but the regulations generally require training equipment to be adequate. Section 121.408

states that the FAA must approve training equipment (e.g. cockpit procedures trainers, door/exit 

trainers, water survival equipment, etc.) used to functionally replicate aircraft equipment required 

to be used as part of the approved training program. As such, this provision enables the safety 

benefits from the regulations governing training on equipment other than FSTDs. It is not 

feasible to separately estimate the benefits of this specific provision. 

Approval of FSTDs (§ 121.407)

This provision conforms the requirements for evaluation, qualification, and maintenance of 

FSTDs used in part 121 to existing part 60 requirements, by providing a reference to part 60 in 

part 121 and adding a new paragraph consistent with the § 121.423 requirement to use an FSTD 

for extended envelope training. This provision therefore provides clarification regarding part 60 

requirements that currently apply to part 121 training. Compliance with new paragraph (e) of 

this provision is required 5 years and 120 days after the date of publication of the final rule in the 

Federal Register because the new extended envelope training required by § 121.423 is not 

required until such time. 

Communication records for domestic and flag operations (§ 121.711)
34

This provision clarifies the information that must be included in the record of communications

between the pilot and aircraft dispatcher based on a legal interpretation of the current 

requirement in § 121.711. This provision also clarifies the recordkeeping requirement by 

defining “en route” for purposes of this section and applies the requirement to all 

flightcrew/dispatch communications made using a two-way communication system required in 

accordance with § 121.99.

Training for instructors and check airmen who serve in FSTDs (§§ 121.413, 

121.414)

These final rule provisions will add some additional check airman (simulator) and flight 

instructor (simulator) initial, transition and recurrent training curriculum items to current 

requirements in existing §§ 121.413 and 121.414 to ensure comprehensive check airman and 

flight instructor understanding of new training tasks in the final rule and the limitations of 

simulation. When the FAA introduced the extended envelope requirements, we felt it was 

important to train simulator instructors how to train pilots for these events. Instructors need to 

understand the simulator control and possess the knowledge to be able to handle these new 

training requirements. This provision enables the safety benefits from the FSTD training 

program by ensuring that the check airmen and flight instructors can adequately operate the 

FSTDs to achieve positive training outcomes. It is not possible to separately quantify the benefits 

of this individual provision.
35

V. COST ANALYSIS

The final rule costs will accrue from additional training requirements, a low and high range for 

the use of simulator time, ground school training facilities, and paperwork. Those individuals 

affected by the new requirements include crew members (pilots and flight attendants) and 

aircraft dispatchers. The constant 2012 dollars and discounted 3 and 7 percent present value 

costs are summarized in the Cost Summary section below.

General Cost Assumptions and Data Sources

The assumptions and identification of key data sources to estimate costs are: 

• The number of part 121 and 121/135 operators, and their pilots were obtained through the 

FAA National Vital Information Subsystem (NVIS) database in February 2013.

31

• NVIS only provides a total number for pilots and does not break out total pilots into pilots, 

check pilots and flight instructors. We use the same assumptions as in the SNPRM that 4.0 

percent of the total number of pilots are check pilots, and 2.0 percent of the total number of 

pilots are instructors.

• Using the FAA Aerospace Forecasts, for fiscal years 2013-2033, the FAA estimated that the 

affected population of pilots would grow at approximately 0.4 percent per year. 32

• In estimating simulator costs, we assume a full simulator; therefore, two pilots and one 

instructor will occupy a simulator during training. We assume operators will assign pilots for

training in the simulator based on availability and current training schedules.

• Flight crewmembers undergoing initial, transition, upgrade, or recurrent training will train on 

one airplane group per training cycle.

• As in the SNRPM, the turnover rate of 5 percent covers pilot retirements and other pilot 

attrition.33

 31 The National Vital Information Subsystem (NVIS) is a comprehensive Flight Standards Services (AFS) 

information system containing up-to-date information about operators including the number of pilots. 32 FAA Aerospace Forecasts 2013-2033. Table 30: Active Pilots by Type of Certificate, Airline Transport, 2012-

2033.

http://www.faa.gov/about/office_org/headquarters_offices/apl/aviation_forecasts/aerospace_forecasts/2013-2033/

Accessed March 2013.
36

• The FAA conducted a survey of eight part 121 operators and estimated that annually 2.6 

percent of the affected pilots will require upgrade training and annually 5.7 percent will 

require transition training.

• For part 121 operators, there is an average of two major groupings of aircraft types 

(equipment groups) per operator.

34

• As in the SNPRM, we assume that check pilots and flight instructors earn 10 percent more 

than line pilots.

Cost Estimate

The FAA analyzed the expected costs of the final rule over the 2013 through 2028 analysis 

interval. The major factor driving the expected costs is the additional training tasks in 

sophisticated simulators. The final rule adds training tasks, and therefore costs, to initial, 

transition, upgrade, and recurrent pilot training programs. Other cost driving factors include the 

high value of pilot’s time, ground school training, and additional paperwork. 

Some paperwork costs will begin on the effective date in 2014 while other paperwork costs will 

begin one year before the 2019 compliance date. The rest of the new paperwork costs start on 

the compliance date in 2019, and will continue to 2028, the end of the analysis interval. These 

start dates are listed in the Estimated Paperwork Costs section. 

This cost analysis estimates the final rule costs by the objective group.35 The cost model was 

computed annually as follows: 

(the number of pilots * fully burdened pilot wage * training hours) + (the number of 

pilots * (simulator costs36 +ground school costs)) + paperwork cost. 

 33http://www.faa.gov/news/conferences_events/aviation_forecast_2010/agenda/media/GAF%20Jim%20Higgins%20

and%20Kent%20Love.pdf The University of North Dakota estimates that 2.12% of pilots have retired annually 

along with forecasting 2.94% pilot attrition (loss of medical, loss of certificate, career transfer) from 2009 to 2024. 

We rounded to three digits.

34 As of March 2013, the OAG Fleet Database reports an average of 1.85 equipment groups per operator which we 

rounded up to two. The OAG Fleet Database defines an equipment group as major groupings of aircraft types. For 

example, B737 would include all of the B-737 variants. 35 An objective group is a grouping of related final rule sections. 36 Includes flight instructor’s fully burdened wages.
37

Table 10 details the final rule provisions by objective grouping and provides the basis for the 

cost analysis.

Table 10

Summary of Final Rule Requirements and When FAA Expects Costs to Accrue

The final rule will add paperwork costs to most of the objective groups listed in the Table 10. 

Additionally, the final rule will add simulator and ground school costs to both extended envelope 

training objective groups. However, the FAA has determined that the training and evaluation 

time required to complete the taxi and pre-takeoff procedures would not take any longer than the 

time currently required to complete those maneuvers because, the procedures are incorporated 

into the existing taxi and pre-takeoff maneuver requirements. Moreover, since crosswind takeoff 

and landing are already required training tasks, and gusty winds are merely one variable of these

current requirements, the agency does not believe any additional time is necessary to train and 

evaluate crosswind takeoffs and landings with gusts. Finally, the amended proficiency check 

requirement for PICs does not add simulator time during recurrent training because under 

existing regulations PICs who fly multiple aircraft types must complete either a recurrent 

training or checking event on each aircraft type flown. Therefore, the recurrent training 
38

framework in place today contemplates that a PIC could fulfill the recurrent training program 

requirements by completing a proficiency check on each aircraft type in which the PIC is 

qualified to serve.

The following sections will discuss the development of parameters that form the basis for the 

final rule cost estimate. First, we will discuss our forecast of the annual number of pilots who

will go through the additional initial, transition, upgrade and recurrent training required by the 

final rule. Next, we present the pilot’s hourly wages and the derivation of hourly employee 

benefits. Then we list the part 121 operators affected by the final rule. Next, we discuss the 

increase in time and cost the final rule adds to simulator and ground school training programs for 

the extended envelope objective groupings. We then estimate the paperwork costs of revising 

pilot manuals, air carrier training courseware, and air carrier training programs for each of the 

objective groupings.

37 Lastly, we present a summary of the total costs.

There are other changes in the final rule that are either editorial or procedural. Some changes 

expand or clarify the intent of the final rule through reorganization, updating terminology, and 

clarifying procedures. These editorial or procedural changes will not impose any new 

requirements or costs. 

Number of Pilots and Operators Affected by the Final Rule

In this section, we first estimate the number of pilots affected by the final rule. Then we discuss 

the source and number of part 121 operators affected.

To estimate the number of flightcrew members in the analysis interval we begin with a 2013 base 

of 76,039 pilots who are employed by part 121 operators. As stated in the General Cost 

Assumptions and Data Sources section, we obtain the number of pilots from National Vital 

Information Subsystem (NVIS). Appendix 9 lists the part 121 operators, their pilots employed, 

and if the operator trains their pilots under AQP.

 37 The Training Program is the document that is submitted to the FAA for approval. It contains all the training 

requirements for that air carrier's crewmembers. Training courseware is the document that instructors teach from—

or the speaker's notes. This document is not FAA approved, although the FAA can review the document at any time 

and require changes to be made. 
39

We apply the same estimate of check pilots and flight instructor, used in the SNPRM, to 

calculate the adjusted pilot base. First, we estimate the number of check pilots by multiplying 

the 2013 base of 76,039 pilots by 4.0 percent to arrive at 3,042 check pilots in 2013. Next we 

estimate the number of flight instructors by multiplying the 76,039 pilots by 2.0 percent to arrive 

at 1,521 flight instructors in 2013. We then subtracted the number of check pilots and instructor 

pilots from the 76,039 pilots to arrive at 71,476 pilots.

We then estimate the number of pilots, check pilots and flight instructors who will undergo 

initial, upgrade, transition, and recurrent training in 2013. Next, we estimated the number of 

pilots who will have to go through initial training. 

Pilots who undergo initial training consist of newly hired pilots who replace pilots lost to 

attrition (loss of medical certificate, loss of airman certificate, career transfer, or retirement). We 

estimate five percent of the total number of pilots would leave an operator through attrition. 

Pilots who undergo initial training are also newly hired pilots due to operator growth (fleet and 

route expansion and traffic growth). Based on the FAA forecast, we expect the total number of 

part 121 pilots to increase by 0.4 percent annually. 

We then estimated the number of newly hired pilots by multiplying the 2013 base of pilots, 

check pilots, and flight instructors by 0.4 percent for growth and five percent for attrition. These 

calculations are displayed in the Table 11 below.

In addition, we expect that annually 2.6 percent of the total pilots will go through upgrade 

training and annually 5.7 percent through transition training.

38 Pilots who go through upgrade 

training do so because they are upgrading from a flight engineer to a first officer (second in 

command) or a first officer to a captain (pilot in command). Pilots who go through transition 

training do so because they are transitioning to another aircraft in an operator’s fleet. We 

estimated the number of pilots who would complete upgrade and transition training by 

 38 This expectation is based on a survey of 8 part 121 operators, and the FAA believes this data is representative of 

all part 121 operators.
40

multiplying the 2013 base of pilots, check pilots, and flight instructors by 2.6 percent for upgrade 

training and 5.7 percent for transition training. These two calculations are displayed in the Table

11 below in the column labeled “Upgrade” and “Transition”. 

Next, we calculated the remaining number of pilots by subtracting the pilots who left due to

attrition, who completed upgrade training, and who completed transition training from the 2013 

base of pilots, check pilots, and flight instructors. The remaining pilots take recurrent training. 

Lastly, we estimated the number of pilots in 2014 by adding the 2013 base of pilots, check pilots, 

and flight instructors to the number of pilots that would be added by growth.

We repeated this process to estimate the number of pilots in the rest of the analysis interval 

(2014-2028) for pilots, check pilots, and flight instructors. The FAA notes that the final rule 

requires pilots to go through extended envelope simulator training every 24 months and extended 

envelope ground school training every 12 months and therefore must forecast pilots annually 

throughout the analysis interval. Table 11 shows these results:

Table 11

Pilot, Check Pilot and Flight Instructor Forecast
41

* Details may not add to row or column totals due to rounding.

In order to estimate the paperwork costs for each part 121 operator affected by the final rule, the 

number of operators are necessary. We also needed to determine which operators train their 

pilots under AQP and which ones train their pilots under the traditional training rules. This

estimate is necessary because operators who train under AQP are required under § 121.909, to 

complete an evaluation of their existing training program against the new requirements set forth 

in this final rule to ensure these requirements are being met. Thus, operators training under AQP 

will have an additional paperwork burden that operators who train under traditional training rules 

will not have.

The numbers of part 121 operators were obtained through the FAA National Vital Information 

Subsystem (NVIS) database and are current as of February 2013. The determination of the 
42

operators who train their pilots under AQP versus non-AQP was provided the AFS-230, the 

Voluntary Safety Programs Branch of the FAA.39

Appendix 9 shows that there are 83 operators currently affected by the final rule; 22 of the 83 

operators train their pilots under AQP, while the remaining 61 operators train their pilots under 

subparts N and O.

Annual and Hourly Wages and Benefits

In this section, we discuss the pilot wages the FAA used in the SNPRM, the reason for using 

those wages, and their source. We then discuss the wages the FAA uses in the final rule, the 

reason for using these wages, and their source. 

The proposed requirements of the SNPRM contained provisions, with different requirements, for 

pilots in command (captains), second in command pilots (first officers), check pilots, flight 

engineers, and flight instructors. In addition, the SNPRM resulted in different training time 

increases for pilots who operate turbojet airplanes and pilots who operate turboprop airplanes. 

Therefore the SNPRM costs analysis required hourly wages for each of these pilot categories. 

For the SNPRM, the Flight Standards Services (AFS) of the FAA provided the average hourly 

wages for each of these pilot categories. As stated in the General Cost Assumptions and Data 

Sources section, for the SNPRM check pilots and flight instructors earn 10 percent more than 

pilots. For the SNPRM, the FAA multiplied the hourly pilot wages, for each category of pilots, 

by a total 2009 benefit as a percentage of payroll from the Bureau of Labor Statistics (BLS) 

survey of employee benefits to arrive at a fully burdened hourly wage. Table 12 shows the pilot 

hourly wages, the estimated hourly benefits, and total hourly costs, by pilot category, used in the 

SNPRM. 

 39 The FAA makes the determination that an operators can start training their pilots under AQP when the operator 

receives an FAA-approved Phase IV Qualification letter.
43

Table 12

SNPRM Pilot, Flight Engineer Hourly Wage & Benefit (2009 $)

The final rule does not contain different requirements for each of the pilot categories or turbojet 

or turboprop equipment types. The final rule requirements add the same amount of simulator 

and ground school training time to captains and first officers regardless of the aircraft they 

operate. 

In May 2012, BLS published the National Industry-Specific Occupational Employment and 

Wage Estimates for Scheduled Air Transportation. The North American Industry Classification 

System (NAICS) code for Scheduled Air Transportation pilots is 481100.40 The major group for 

pilots under the 481100 NAICS code is 53-2011. The FAA believes that the 53-2011 pilot 

survey is the appropriate wage to estimate the salary of the part 121 pilots, check pilots, and 

flight instructors affected by the final rule.41 The BLS survey lists $128,760 as the annual mean 

salary for a pilot. The cost analysis will use the annual mean salary of $128,760 for a pilot to 

estimate the additional costs the final rule adds for simulator and ground school training tasks. 

The FAA notes that the survey lists the annual mean salary range for pilots, by area in the 

continental United States, from $72,580 to $184,320. 

BLS website for Scheduled Air Transportation pilots states “Wages for some occupations that do 

not generally work year-round, full time, are reported either as hourly wages or annual salaries 

 40 The NAICS code is the standard used by Federal statistical agencies in classifying business establishments for the 

purpose of collecting, analyzing, and publishing statistical data related to the U.S. business economy. 

41 BLS describes this survey as “Pilot and navigate the flight of fixed-wing, multi-engine aircraft, usually on 

scheduled air carrier routes, for the transport of passengers and cargo. Requires Federal Air Transport certificate 

and rating for specific aircraft type used. Includes regional, National, and international airline pilots and flight 

instructors of airline pilots.” http://www.bls.gov/oes/current/oes532011.htm Accessed April 2013.
44

depending on how they are typically paid”;

42 BLS reports pilot wages as annual salaries because 

pilots do not work a 40 hour work week. Therefore, the FAA used the Pro Pilot Compensation 

Salary Study – 2012 compiled by ABCO Data Systems in Vienna, VA and estimated that pilots, 

who work for part 121 airlines, typically have their annual pay based on 80 hours per month.43 

The FAA divided the BLS annual mean salary by 80 hours per month to estimate the average 

hourly wage for a pilot operating in part 121 service. 

In addition, pilot benefits (such as health benefits, vacation, sick time, etc.) must be added to 

estimate the costs for this analysis. In March 2013, BLS published their “Employer Costs for 

Employee Compensation” study of employee benefits. In Table A of the BLS study, they 

estimated the total 2012 benefits, as a percentage of total compensation, at 29.7 percent for 

private industry.

44 The FAA accepts the BLS 29.7 percentage of total compensation to estimate 

the value of benefits for pilots, check pilots, and flight instructors as an additional cost of this 

final rule.

Technical writers and flight instructors are also necessary to complete the paperwork 

requirements of the final rule. In May 2012, BLS published the National Industry-Specific 

Occupational Employment and Wage Estimates for Scheduled Air Transportation. The NAICS 

code for Scheduled Air Transportation technical writers is 27-3042. The FAA believes that the 

27-3042 technical writer survey is the appropriate wage to estimate the salary of the part 121 

technical writers affected by the final rule.45 The BLS survey lists the mean hourly wage for a 

technical writer is $32.65. The cost analysis will use the annual mean hourly wage of $32.65 for 

a technical writer to estimate the additional costs along with the total 2012 benefits of 29.7

percent discussed above. The survey lists the annual mean salary range, by area in the 

continental United States, for technical writers from $33,570 to $97,050. 

Table 13 shows these results for pilots, check pilots, flight instructors and technical writers.

 42 http://www.bls.gov/oes/current/oes532011.htm#(4) 43 http://www.safetystanddown.com/wp-content/uploads/2012/06/Salary-study-6-12-lyt_June.pdf Accessed April 

2013.

44 http://www.bls.gov/news.release/pdf/ecec.pdf Accessed April 2013. 45 http://www.bls.gov/oes/current/oes273042.htm Accessed April 2013.
45

Table 13

 Mean Hourly Wages Plus Benefits (2012 $)

* Details may not add to row or column totals due to rounding.

Final Rule Simulator and Ground School Additional Time for Pilots

Pilots must undergo two basic methods of training. This training includes flight training and 

ground school. In this section, we first discuss the method the FAA used to estimate the 

simulator training time this final rule adds to current pilot flight training requirements. We then 

discuss the additional ground school training time the final rule adds. 

 

This regulatory evaluation will not attempt to estimate the existing practice relative to the new 

requirements. We base our estimate on the incremental time this final rule adds to the current 

regulatory requirements for captains and first officers who operate in part 121 service. To the 

extent industry current practices exceed the regulatory requirements, we believe that the cost 

estimate will result in an over estimate of the actual compliance costs.

Under the assumption that existing facilities are optimized,46 the final rule could result in 

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

facilities for flight crewmembers. Rather than estimate the capital recovery costs over the life 

cycle of simulators and expansion of facilities, we estimated the rent of simulator services with a 

usage fee per pilot. As mentioned in the Background section, the FAA estimates the average 

cost of simulator session to be $500 an hour plus the cost of an instructor with two pilots in the 

simulator.

 46 Responders to the NPRM and SNPRM confirmed that their existing training facilities, simulators, and ground 

school classes are optimized.
46

Typically, simulator sessions are scheduled in four hour blocks. In the NRPM, the FAA 

estimated the costs based on four-hour simulator sessions. After analyzing the tasks prescribed 

in the technical report accompanying the SNPRM,

47 we believe many of the simulator sessions 

will last less than four hours. Therefore, in the SNPRM and final rule cost analysis, we estimate

the cost of the additional tasks the final rule requires for pilots in the simulator rather than the 

number of four hour simulator sessions.

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

tasks. On October 26, 2009 the FAA conducted a simulator trial to determine the time necessary

to perform the proposed recurrent proficiency check requirements. The agency collected data on 

the time it took to complete the recurrent proficiency check tasks proposed in the NPRM and 

then used this data to estimate the time required to complete the proficiency check requirements 

proposed in the SNPRM.

For the final rule, the FAA conducted a second simulator trial to determine the time required to 

complete the additional final rule maneuvers and procedures in each curriculum. During the 

second simulator trial, two FAA pilots performed the extended envelope flight training 

requirements. The FAA pilots serving as the pilot in command (PIC) and second in command 

pilot (SIC) both held ATP certificates and were current and qualified to operate the Airbus 330. 

The PIC was type rated. The SIC was not type rated. The Instructor Operating Station (IOS) 

operator had experience operating the Airbus 330 Level D simulator. All required checklists and 

procedures were completed in their entirety for each maneuver/procedure. All required Air 

Traffic Control (ATC) instructions and clearances were provided. The FAA expects task times 

to be comparable throughout the various aircraft fleets used in part 121 operations because we do 

not expect the differences in aircraft design to have an impact on task times. 

The training time listed below represent the data collected during the second simulator trial and 

provides the estimated simulator time required to meet the extended envelope flight training 

 47 The Flightcrew Member Training and Qualification Review and Analysis Technical Report can be found in the 

docket for this rulemaking. The URL for the docket is 

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=FAA-2008-0677.
47

requirements in the final rule. The FAA has reviewed both simulator trials and revised the cost 

estimates for the training tasks required by the final rule. The full discussion of the additional 

tasks the final rule adds to pilot training, along with an estimate of the time necessary to 

complete them, are listed in the preamble and technical report in the federal docket.48

The final rule adds simulator time for pilots to complete extended envelope training maneuvers

and procedures. As noted previously, we determined the training and evaluation time required to 

complete the taxi and pre-takeoff procedures, as well as crosswind maneuver with gusts, will not 

take any longer than the time required under existing regulations for completion. Also, the final 

rule requirement to include pilot monitoring during Line Oriented Flight Training (LOFT) does 

not place any additional burden on operators who use advanced simulation training programs to 

train their pilots or substitute LOFT for recurrent proficiency check requirements because the 

requirement can be met during the ordinary course of any LOFT that is currently part of a part 

121 operator’s training program. 

The final rule requires extended envelope training maneuvers and procedures for all pilots during 

initial, transition, and upgrade flight training and at least once every 24 months during recurrent 

flight training. At a minimum, all extended envelope training must take place in a Level C full 

flight simulator.49 To account for these variables, the agency estimates the following ranges of 

simulator time are required to meet the extended envelope training requirements. For the base 

case cost estimate, we compute the average simulator time, for initial, upgrade, transition, and 

recurrent training, with the range of minutes listed in Table 14.

 48 These reports may be found in the docket for this rulemaking. The URL for the docket is 

http://www.regulations.gov/search/Regs/home.html#docketDetail?R=FAA-2008-0677. 49 The FAA notes that the final rule provides deviation authority in those instances in which a Level C or higher full 

flight simulator is unavailable.
48

Table 14

Additional Simulator Time from Final Rule (Minutes)

As stated in the Background section, the FAA did not include travel expenses in the final rule 

cost analysis for the additional simulator training time because the FAA believes operators can 

complete the new training requirements within the same amount of days as their current initial, 

upgrade, transition, or recurrent simulator and ground school training sessions. With regard to 

simulator training, we are assuming an additional 90-135 minutes for the initial extended 

envelope simulator training. If an operator uses 4 hour simulator sessions (which is not required), 

it would take 6 days of training to get 24 hours. The operator could add 15-25 minutes to each 

simulator session and still finish in the same number of days. For transition, upgrade, and 

recurrent simulator training we are assuming even less time for the extended envelope training, 

so again the same rationale applies. It is not efficient for the operator to use an extra day of 

training just for the additional simulator training time the final rule requires.

50 

In addition, the final rule extended envelope ground training will be required for all pilots during 

initial, transition, and upgrade training and at least once every 12 months during recurrent ground 

school training. To account for these variables, the agency estimates the following amount of 

ground school time is required to meet the extended envelope training requirements.

 50 Although industry informed us that simulators are typically rented in four-hour blocks, simulator rental varies 

depending on the contract that the carrier has with the simulator owner. We assume that air carriers will be able to 

rent only the time needed to complete the training required by the rule. In addition, many large operators have their 

own simulators and do not need to rent.
49

Table 15

Additional Ground School Time from Final Rule

From the General Cost Assumptions and Data Sources section, 100 percent of the pilots will 

undergo distance learning for their ground school training. The costs for a pilot to undergo 

distance learning will be the same for the hours spent in a ground school class room but will not 

include transportation costs such as airfare, automobile mileage, hotel, facility usage fees, and 

per diems because of distance learning.

The FAA believes that the additional simulator and ground school time this final rule requires 

can be conducted in an operator’s current training schedule without adding any additional travel 

time. In the interest of performing a robust cost benefit analysis, the FAA conducted a 

sensitivity analysis on the cost of pilots having to spend an extra day in simulator for the 

additional training tasks added by the final rule and determined that the benefits still exceed the 

costs. The results of this sensitivity analysis can be found in Appendix 10.

Costs and Methodology for Final Rule Estimated Simulator Training Costs

We now discuss the methodology used to estimate the final rule costs for the additional simulator 

training tasks required by the final rule. Additional simulator training costs are estimated by 

summing the cost of the additional time the final rule requires pilots to spend in the simulator 

plus the cost of the additional time simulators are used. The additional final rule cost for pilots 

in the simulator is estimated using fully burdened pilot wages from BLS. The cost for the 

additional time simulators are being used is estimated using hourly simulator costs based on 

FAA data.
50

The FAA estimates the additional time pilots spend in the simulator by multiplying the number 

of pilots by the additional time the final rule will require. We then multiply the additional 

simulator time by the fully burdened pilot’s hourly wage. An instructor will be needed for each 

additional simulator session with two pilots. The additional instructor time is multiplied by the 

flight instructors’ fully burdened wage. As mentioned in the General Cost Assumptions and 

Data Sources section, there are two pilots being trained for each simulator session. This 

calculation is repeated for pilots who go through initial, upgrade, transition or recurrent training

while taking into consideration that there is one instructor for every two pilots in the simulator.

The FAA notes that pilots who go through initial, upgrade, or transition training would go 

through recurrent training in the following years of the analysis interval. 

The FAA estimates the cost of the simulator usage fees by multiplying the additional hours the 

final rule requires for pilots to be in the simulator, with the $500 average hourly simulator cost.

51 

We perform these calculations for the additional time the final rule adds for pilots training in the 

simulator and the additional time the simulator is being operated for both the low and high range 

of simulator times the FAA estimated for initial, upgrade, transition, or recurrent simulator

training. 

For the check pilots and flight instructors we calculate the incremental costs the final rule adds in 

a similar manner as we did for the pilots. 

We then sum the initial (attrition or growth) training costs for pilots, check pilots, and flight 

instructors with the transition, upgrade, and recurrent training costs to arrive at the total cost the 

final rule adds to part 121 operators for simulator training. We perform this calculation for the 

both low and high range of simulator times. Lastly, we multiply the total costs, by year, by the 

three and seven percent present value series.

 51 Hourly simulator costs provided by the FAA Flight Standards Service (AFS).
51

Table 16 shows these results for the low and high range of time the FAA estimates the final rule 

adds to the time pilots are in the simulator.52 Appendix 11 shows the details by pilot, check 

pilot, and flight instructors in 2012 dollars.

Table 16

Simulator Training Costs – Pilot Wages Plus Simulator Usage Time (2012 $)

* Details may not add to row or column totals due to rounding.

Estimated Costs and Methodology for Final Rule Ground School Training Tasks

We now discuss the FAA’s estimate of the final rule’s additional ground school training costs to 

pilots, check pilots, and flight instructors. 

For the final rule, the FAA re-estimated the ground school cost analysis based on updated data 

and analysis that reflect the final rule requirements.

The ground school costs consists of the sum of the additional time the final rule requires for 

pilots, check pilots, and flight instructors to be in initial, transition, upgrade, and recurrent

ground school training. The initial, transition, and upgrade training occurs only once while the 

recurrent training occurs annually.

For ground school training, the FAA continues to allow training to be conducted in an 

environment other than a classroom by distance learning. An approved distance learning 

 52 See Table 14, Additional Simulator Time from Final Rule (Minutes).
52

program ensures the training will provide the students with the knowledge and cognitive skills to 

perform their required duties. As mentioned in the Background section, the agency assumes 100

percent of pilots will take advantage of distance learning and will not incur travel costs for the 

final rule ground school training. 

We calculate the additional time pilots are in ground school training by multiplying the number 

of pilots, with the additional ground school time, and then their hourly wage. We note that 

although operators do not incur travel costs from distance learning, we still need to include the 

cost of the additional time the final rule adds to pilots’ ground school training regardless of 

whether the pilots are distance learning or learning in a classroom.

We then sum the initial, transition, upgrade, and recurrent ground school training costs to arrive 

at a total cost. Next, we sum the pilot, check pilot, and flight instructor final rule ground school 

training costs. We calculate the final rule ground school training costs for check pilots and flight 

instructors in a similar manner as for pilots. 

Table 17 shows the results of our calculations for the estimate of total ground school training 

costs. Appendix 11 shows the details by pilot, check pilot, and flight instructors in 2012 dollars.

Table 17

Ground School Costs (2012 $)

* Details may not add to row or column totals due to rounding.
53

Estimated Paperwork Costs

The final rule adds paperwork in the curriculums for part 121 operator training programs,

training courseware, and operating manuals. This section discusses the estimated costs, by 

objective groups of provisions, for the additional hours it takes to create the paperwork, along 

with the number of pages the final rule adds. The FAA notes that there is only a one-time 

paperwork cost to respondents for each of the groups of provisions.

The FAA estimates no paperwork costs for the following groups of provisions:

• Fraud and falsification (§ 121.9),

• Related aircraft differences training (§§ 121.400, 121.418, 121.434, 121.439, 121.441),

• Proficiency checks for PICs (§ 121.441(a)(1)(ii)), and

• Approval of FSTDs (§ 121.407).

The FAA assumed that air carriers will incur costs related to the paperwork burden for the 

following groups of provisions on the effective date of the final rule, which is 120 days after the 

publication of the rule:

• Personnel identified as flight attendants (§ 121.392), 

• Communication records for domestic and flag operations (§ 121.711), and

• Approval of Advanced Qualification Program (§ 121.909).

Although compliance with the provisions on qualification and training for instructors and check 

airmen who serve in FSTDs (§§ 121.411, 121.412, 121.413, 121.414) is required 5 years after 

the effective date, the FAA believes that air carriers will start to accrue paperwork costs 4 years 

after the effective date.

Air carriers will incur paperwork costs for the following groups of provisions five years and 120 

days after the publication of the rule:

• Training equipment other than FSTDs approved under part 60 (§§ 121.403(b)(2), 

121.408),

• Pilot monitoring (§§121.409,121.544, Appendix H),
54

• Remedial training (§§ 121.415(h) and § 121.415(i)), and

• Extended envelope flight training maneuvers and procedures (§§121.407(e),121.423, 

121.424, 121.427(d)(1)(i), 121.433(e)), Extended envelope ground training subjects (§§ 

121.419(a)(2), 121.427), Runway safety maneuvers and procedures (Appendices E and F) 

and Crosswind maneuvers including wind gusts (Appendices E and F).

The FAA estimated the paperwork costs for these provisions by multiplying the number of hours 

the FAA estimates to update the training program, training courseware, or operating manual by 

the hourly rate of the person responsible for the update, by the number of part 121 operators 

affected by the provision. The Flight Standards Service (AFS) of the FAA provided average 

hourly times and the number of additional pages of paperwork the final rule will add. Table 18 

summarizes the FAA’s cost estimate of the total paperwork requirement for each of the 

following groups of provisions. 

The FAA estimates the total paperwork costs for the final rule will be about $8.2 million. The 

following sections discuss each objective group of provisions, when the provisions will become 

effective, and their paperwork costs. 

Fraud and falsification (§ 121.9) 

Although fraud is currently prohibited by criminal statute, the FAA has added language 

prohibiting fraud and falsification to part 121 to emphasize the importance of truthful statements. 

This provision prohibits fraudulent or intentionally false statements in, or a known omission 

from, any record or report that is kept, made, or used to show compliance with this part, or to 

exercise any privileges under this chapter.53 This provision enhances FAA enforcement options

by allowing the agency to take certificate action or assess a civil penalty against a person for 

making a fraudulent or intentional false statement. Compliance with this provision is required

 53 18 USC 1001is a criminal statute prohibiting fraud and intentional falsification in matters within the jurisdiction 

of the executive branch. This regulation will allow the agency to pursue civil enforcement in instances in which a

person has committed fraud or falsification.
55

120 days after the date of publication of the final rule in the Federal Register. The FAA 

estimates that there are no costs for this provision.

Personnel identified as flight attendants (§ 121.392) 

This provision prohibits operators from identifying any person as a flight attendant if that person 

has not completed all flight attendant training and qualification. Individuals who have not 

completed all flight attendant training and qualification requirements must be clearly identified 

(e.g. via an announcement, by wearing civilian clothes, or not wearing a uniform). This 

provision may reduce confusion of passengers during an emergency situation on a flight who 

might otherwise presume that these individuals are fully qualified flight attendants. 

Operators must revise flight attendant manuals to reflect the new procedures. Compliance with 

this provision is required on the effective date of the final rule, 120 days after the date of 

publication in the Federal Register. The FAA estimates that, for a certificate holder operating 

under part 121, one page of the content of the flight attendant operating manual will require 

revision for each affected operator. 

Proficiency checks for PICs (§ 121.441(a)(1)(ii))

Currently, in accordance with §§ 121.433(d) and 121.441(a)(1), a PIC who serves on more than 

one aircraft type must complete either recurrent flight training or a proficiency check on each 

aircraft type every 12 months. To ensure PICs operating multiple aircraft types maintain 

proficiency on each aircraft type, the final rule amends § 121.441(a)(1) by requiring PICs who 

fly more than one aircraft type to receive a proficiency check in each aircraft type flown at the 

existing 12-month recurrent training interval. The FAA expects that any recurrent training 

program updates needed to reflect this change are minimal and are subsumed in the paperwork 

costs for the collective amendments made to the recurrent training provisions in this final rule. 

Compliance with new paragraph (a)(1)(ii) of this provision is required 5 years and 120 days after 

the date of publication of the final rule in the Federal Register, consistent with the SNPRM. The 

FAA estimates that there are no costs for this provision.
56

Related aircraft differences training (§§ 121.400, 121.418, 121.434, 121.439, 121.441)

Section 121.400 discusses the applicability and terms used in the final rule and adds no costs.

The remaining cost relieving provisions allow pilots, who train in aircraft types that do not have 

a common type certificate, to take credit for common tasks that pilots are already trained in. An 

example of this would be the Airbus airplanes that have cockpit commonality, and through 

related aircraft difference training, these provisions could provide cost savings to operators. 

Although air carriers are not required to seek a related aircraft designation as permitted by 

§ 121.418(b), if they seek the designation and receive it, it may provide relief from the training, 

checking, and experience requirements in §§ 121.419, 121.424, 121.425, 121.427, 121.434, 

121.439 and 121.441. Lowering the cost for air carriers to adopt new aircraft types could speed 

up the entry of the newer aircraft types into the fleet. However, the magnitude of any cost 

savings would be based on operator’s future actions and therefore we do not attempt to quantify 

the savings.

These provisions are effective 120 days after the date of publication of the final rule in the 

Federal Register. The FAA estimates that there are no costs for these provisions.

Training equipment other than FSTDs approved under part 60 (§§

121.403(b)(2),121.408) 

Current regulations do not provide specific requirements for training equipment other than 

FSTDs, but the regulations generally require training equipment to be adequate. Section 121.408 

states that the FAA must approve training equipment (e.g. cockpit procedures trainers, door/exit 

trainers, water survival equipment, etc.) used to functionally replicate aircraft equipment required 

to be used as part of the approved training program. Compliance with this provision is required 

5 years and 120 days after date of publication of the final rule in the Federal Register. This 

provision will require an additional 5 pages in each air carrier’s General Operating manual. 

Section 121.403(b)(2) requires that operators provide the FAA with a list of all training devices 

or training aids that the certificate holder will use. Compliance with this provision is required 5 
57

years and 120 days after date of publication of the final rule in the Federal Register. The FAA 

estimates that, for a certificate holder operating under part 121, one page of the content of the air 

carrier’s approved training program will require revision for each affected operator. 

Approval of FSTDs (§ 121.407) 

This provision conforms the requirements for evaluation, qualification, and maintenance of 

FSTDs used in part 121 to existing part 60 requirements, by providing a reference to part 60 in 

part 121 and adding a new paragraph consistent with the requirement in § 121.423 to use an 

FSTD for extended envelope training. This provision therefore provides clarification regarding 

part 60 requirements that currently apply to part 121 training. Compliance with new paragraph 

(e) of this provision is required 5 years and 120 days after date of publication of the final rule in 

the Federal Register, because the new extended envelope training required by § 121.423 is not 

required until such time. The FAA estimates that there are no compliance or paperwork costs for 

this provision.

Pilot monitoring (§§121.409,121.544, Appendix H) 

Section 121.409 and Appendix H require training on pilot monitoring to be incorporated into 

existing requirement for scenario based training. Section 121.544 also establishes an operational 

requirement for pilots to follow air carrier procedures regarding pilot monitoring. 

These provisions reinforce active monitoring skills to the pilot not flying by requiring the 

inclusion of active pilot monitoring skills during line oriented flight training (LOFT). Appendix 

H currently requires all part 121 pilots in training to complete a four hour LOFT in a simulator. 

The FAA believes that the active monitoring skills of this provision can be accomplished in the 

current four hour LOFT requirements.54

 54 Appendix H requires all pilots trained using advanced simulation to complete a qualification LOFT upon 

completion of initial, transition, or upgrade training. Under existing regulations, LOFT may be substituted for 

recurrent flight training on an alternating basis, but it is not required.
58

Compliance with pilot monitoring is required 5 years and 120 days after date of publication of 

the final rule in the Federal Register. The FAA estimates that §§ 121.544 and 121.409 will add 

20 pages to each air carrier’s training courseware and one page to each air carrier’s approved 

training program. 

Remedial training (§§ 121.415(h) and § 121.415(i)) 

These provisions require certificate holders to incorporate methods for remedial training and 

tracking for pilots who have experienced multiple failures or demonstrated performance 

deficiencies in the training or checking environment into approved training programs. Although 

the FAA expects that industry already addresses deficiencies in pilot performance in accordance 

with existing agency guidance, these final rule provisions create a requirement for compliance. 

Examples of tracking include extra line checks, extra procedures, etc. to make sure the pilot 

trains to his deficiencies. 

In August 2010, Congress directed the FAA to ensure air carriers develop remedial training 

programs for flight crew members who have demonstrated performance deficiencies or 

experienced failures in the training environment. The final rule remedial training requirements 

are intended to reflect the congressional direction and existing agency guidance.55 We assume 

air carriers training under subparts N and O are already implementing the recommendations in 

the agency’s guidance material based on information received during FAA inspections in 2009 

as part of the Call to Action to Enhance Airline Safety. Also, since subpart Y already requires an 

AQP to include such a system, we assume no additional cost to carriers training under AQP. 

Therefore, we only estimate the paperwork costs for documenting this guidance.

Compliance with these provisions is required 5 years and 120 days after the final rule is 

published. The FAA estimates that, for a certificate holder operating under part 121, 20 pages 

will be added to each air carrier’s courseware and one page to each air carrier’s training program. 

Communication records for domestic and flag operations (§ 121.711) 

 55 SAFO 06015, Remedial Training for part 121 Pilots.
59

This provision clarifies the information that must be included in the record of communications

between the pilot and aircraft dispatcher based on a legal interpretation of the current 

requirement in § 121.711. This provision also clarifies the recordkeeping requirement by 

defining “en route” for purposes of this section and applies the requirement to all flight

crew/dispatch communications made using a two-way communication system required in 

accordance with § 121.99. It is current industry practice to record all en route communications 

as defined by the final rule. Compliance with this provision is required 120 days after date of 

publication of the final rule in the Federal Register. 

The FAA estimates that, for a certificate holder operating under part 121, one page will be added 

to each air carrier’s pilot operating manual and one page to each air carrier’s aircraft dispatcher 

operating manual. 

Qualifications and Training for instructors and check airmen who serve in FSTDs 

(§§ 121.411, 121.412, 121.413, 121.414) 

Sections 121.411 and 121.412 add simple technical changes, such as the deletion of obsolete 

dates, deletion of obsolete duty positions (such as flight navigator), and correction of 

terminology. These modifications do not affect costs.

Appendix H currently includes robust requirements for simulator training for check airmen and 

instructors. These final rule provisions will add some additional check airman (simulator) and 

flight instructor (simulator) initial, transition and recurrent training curriculum items to current 

requirements in existing §§ 121.413 and 121.414 training to ensure comprehensive check airman 

and flight instructor understanding of new training tasks in the final rule and the limitations of 

simulation. When the FAA introduced the extended envelope requirements, we felt it was 

important to train simulator instructors on how to train pilots for these events. Although this 

requirement adds recurrent training subjects to instructor training, the FAA believes the 

additional time can be incorporated into the time currently required to train check pilots and 

instructors. The addition of these minimal curriculum requirements will not require additional

program hour requirements and therefore have minimal to no costs. 
60

Although compliance with this provision is required at 5 years and 120 days, the FAA believes 

that operators will start accruing paperwork costs 4 years after date of publication of the final 

rule in the Federal Register. The FAA estimates for a certificate holder operating under part 121, 

§§ 121.413 and 121.414, these provisions will each add 40 pages to each air carrier’s training 

courseware and two pages to each air carrier’s approved training program. 

Extended envelope flight training maneuvers and procedures (§§121.407(e),121.423, 

121.424, 121.427(d)(1)(i), 121.433(e)), Extended envelope ground training subjects 

(§§ 121.419(a)(2), 121.427), Runway safety maneuvers and procedures (Appendices 

E and F) and Crosswind maneuvers including wind gusts (Appendices E and F).

Amendments to §121.407 provide a reference in part 121 to part 60 and the new extended 

envelope training requirement in § 121.423, but does not add requirements; therefore there is no 

paperwork cost. 

Sections 121.419 and 121.427 revise current initial, transition, upgrade or recurrent ground 

training to include training for extended envelope flight training maneuvers and procedures, as 

well as additional training regarding runway safety and crosswind takeoffs and landings with 

gusts. The FAA estimates that, for a certificate holder operating under part 121, §§ 121.419 and 

121.427 will add 20 pages to each air carrier's training courseware and one page, for each 

provision (two pages total) to each air carrier's approved training program. 

Section 121.423 details new extended envelope flight training and provides the interval for 

recurrent training. The FAA estimates that, for a certificate holder operating under part 121, 20 

pages will be added to each air carrier’s training courseware, one page to each air carrier’s 

approved training program, and 20 pages to each air carrier’s flightcrew operating manual. 

Section 121.424 revises revise current initial, transition and upgrade flight training 

curriculum/courseware to include flight training and evaluation, as appropriate. The FAA 

estimates that, for a certificate holder operating under part 121, 20 pages will be added to each 
61

air carrier’s training courseware, one page to each air carrier’s approved training program, and 

20 pages to each air carrier’s pilots operating manual. 

Section 121.433 has paperwork included in the § 121.423 cost estimate.

Compliance with the extended envelope training maneuvers and procedures as well as the 

crosswind maneuvers with gusts and runway safety procedures, is required 5 years and 120 days 

after date of publication of the final rule in the Federal Register.

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

Although the final rule does not make any changes to § 121.909, when the new N and O training 

requirements are published, operators that use AQP will have to review their training programs 

to make sure they address the new N and O requirements (recovery from stall, upset recovery, 

etc.) and possibly revise their Qualifications Standards Document during this process.

This is a cost that only applies to operators that use AQP for pilot training because they are the 

only ones who must meet the § 121.909 requirements. This provision does not apply to 

operators who train their pilots under a traditional N and O training program.

The FAA estimates that, for a certificate using AQP to conduct training, this provision will add 5 

pages to each air carrier’s Qualification Standards Document. For each of the 22 operators, it 

will take an instructor 9.6 hours and a tech writer 40.0 hours to complete the 5 pages required for

this provision.

Summary of Estimated Paperwork Costs by Objective Grouping 

The FAA estimates the total paperwork costs for the final rule will be about $8.2 million in 2012 

dollars. Table 18 shows the details of the number of pages required for each objective grouping 

of final rule provisions, the estimated date that the FAA believes paperwork costs will start to 
62

accrue, the number hours required for each provision, the person conducting the paperwork 

review, their salary, and the total costs for each provision.56 For some of these provisions, 

technical writers and instructors will both be needed to complete the paperwork requirements. 

We have reflected the labor costs of the technical writers and instructors for these provisions in 

separate rows for the objective groupings in Table 18.

 56 In most cases, because the actual implementation will vary by operator, the FAA used the date on which 

compliance is required to estimate paperwork costs. 
63

1

2 Table 18

3 Summary of Paperwork Requirements and Costs (2012 $)

4

5 * Details may not add to row or column totals due to rounding.
64

Cost Summary

From 2013 to 2028, the FAA estimates the base case costs to air carriers for complying with the 

provisions of this final rule are $313.9 million in constant 2012 dollars. The present value of the 

base case is $149.8 million when discounted at a 7 percent annual rate and $226.1 million when 

discounted at 3 percent. As mentioned earlier, we estimate the base case costs using the average 

of the range of simulator training times required by the final rule.

Table 19 summarizes the FAA estimate of the final rule low range costs.

Table 19

Total Costs – Low (2012 $)

* Details may not add to row or column totals due to rounding.

Table 20 summarizes the FAA estimate of the final rule base case costs.
65

Table 20

Total Costs – Base Case (2012 $)

Table 21 summarizes the FAA estimate of the final rule high range costs.

Table 21

Total Costs – High (2012 $)

* Details may not add to row or column totals due to rounding.
66

VI. BENEFIT COST SUMMARY

This final rule will increase safety and contribute significantly to reducing the frequency of 

future aviation accidents. Phased-in potential quantified benefits will accrue from the additional 

training initiatives and shown in Table 23 below. 

The final rule will also generate qualitative benefits, by addressing NTSB safety 

recommendations related to crewmember training, and requirements in the Airline Safety and 

Federal Aviation Administration Extension Act of 2010 (the 2010 Act).

57 

Under the 2010 Act, Congress directed the FAA to conduct rulemaking to ensure that all 

flightcrew members receive ground training and flight training in recognizing and avoiding 

stalls, recovering from stalls, recognizing and avoiding upset of an aircraft, and the proper 

techniques to recover from upset. The 2010 Act also directed the FAA to ensure air carriers 

develop remedial training programs for flight crew members who have demonstrated 

performance deficiencies or experienced failures in the training environment. 

The changes in this final rule address the following NTSB recommendations:

• A-96-120. Require 14 CFR part 121 and 135 operators to provide training to flightcrews

in the recognition of and recovery from unusual attitudes and upset maneuvers, including 

upsets that occur while the aircraft is being controlled by automatic flight control 

systems, and unusual attitudes that result from flight control malfunctions and 

uncommanded flight control surface movements.

• A-05-14. Require all 14 Code of Federal Regulations part 121 air carrier operators to 

establish programs for flight crewmembers who have demonstrated performance 

deficiencies or experienced failures in the training environment that would require a 

review of their whole performance history at the company and administer additional 

oversight and training to ensure that performance deficiencies are addressed and 

corrected

• A-05-30. Require all 14 Code of Federal Regulations part 121 and 135 air carriers to 

incorporate bounced landing recovery techniques in their flight manuals and to teach 

these techniques during initial and recurrent training

 57 Public Law 111-216.
67

• A-07-44. Require that all 14 Code of Federal Regulations parts 91K, 121, and 135 

operators establish procedures requiring all crewmembers on the flight deck to positively 

confirm and cross-check the airplane’s location at the assigned departure runway before 

crossing the hold short line for takeoff. This required guidance should be consistent with 

the guidance in Advisory Circular 120-74A and Safety Alert for Operators 06013 and 

07003.

• A-10-22. Require 14 Code of Federal Regulations (CFR) part 121,135, and 91K 

operators and 14 CFR Part 142 training centers to develop and conduct training that 

incorporates stalls that are fully developed; are unexpected; involve autopilot 

disengagement; and include airplane-specific features, such as a reference speeds switch.

• A-10-23. Require all 14 Code of Federal Regulations part 121, 135, and 91K operators 

of stick pusher-equipped aircraft to provide their pilots with pusher familiarization 

Simulator training.

• A-10-111. Require 14 Code of Federal Regulations parts 121, 135, and 91 K operators to 

incorporate the realistic, gusty crosswind profiles developed as a result of Safety 

Recommendation A-10-110 into their pilot simulator training programs.

Table 22 shows a summary of the costs in 2012 dollars, 7 and 3 percent present value. The total 

costs include increased training for pilots, check pilots and flight instructors along with 

additional costs of more simulator time and paperwork for updating curriculums and operating 

manuals. 

Table 22

Range of Total Costs (2012 $ Millions) From 2019 to 2028

Table 23 shows the final rule’s present value (using a 7% discount rate) quantitative benefit 

estimate of $317.1 million exceeds the present value quantitative base case cost estimate of 

$149.8 million to operators training their pilots under part 121. 
68

Table 23

Summary of Benefits and Costs (2012 $ Millions) From 2019 to 2028

Thus, the FAA concludes that the benefits of the final rule justify the costs.
69

VII. APPENDICES
70

Appendix 1 –Accident Descriptions

Colgan 3407

(1) Accident Information2-12-2009

NTSB Report Number: DCA09MA027

COLGAN 3407

Part 121 Scheduled Domestic Flight

Bombardier DHC-8-402

Fatalites-50

(2) Summary of NTSB accident narrative related to rulemaking.

On February 12, 2009, about 2217 eastern standard time, a Colgan Air, Inc., Bombardier

DHC-8-400, N200WQ, operating as Continental Connection flight 3407, was on an instrument 

approach to Buffalo-Niagara International Airport, Buffalo, New York, when it crashed into a 

residence in Clarence Center, New York, about 5 nautical miles northeast of the airport. The 2 

pilots, 2 flight attendants, and 45 passengers aboard the airplane were killed, one person on the 

ground was killed, and the airplane was destroyed by impact forces and a post-crash fire. The 

flight was operating under the provisions of 14 Code of Federal Regulations Part 121. Night 

visual meteorological conditions prevailed at the time of the accident.

(3) NTSB causal factors. The NTSB determined that the probable cause of the accident was 

the captain’s inappropriate response to the activation of the stick shaker, which led to an 

aerodynamic stall from which the airplane did not recover. 

Other contributing factors are:

1. The flight crew’s failure to monitor airspeed in relation to the rising position of the low 

speed cue.

2. The flight crew’s failure to adhere to sterile cockpit procedures.

3. The captain’s failure to effectively manage the flight.

4. Colgan Air’s inadequate procedures for airspeed selection and management during 

approaches in icing conditions.
71

American Airlines 587

(1) Accident Information11/12/2001

NTSB Report Number: DCA02MA001

American Airlines 587

Part 121 Scheduled International Flight

Airbus A-300

Fatalites-265

(2) Summary of NTSB accident narrative related to rulemaking.

On November 12, 2001, about 0916:15 eastern standard time, American Airlines flight 587, an 

Airbus Industrie A300-605R, N14053, crashed into a residential area of Belle Harbor, New 

York, shortly after takeoff from John F. Kennedy International Airport, Jamaica, New York. 

Flight 587 was a regularly scheduled passenger flight to Las Americas International Airport, 

Santo Domingo, Dominican Republic, with 2 flight crewmembers, 7 flight attendants, and 251 

passengers aboard the airplane. The airplane's vertical stabilizer and rudder separated in flight 

and were found in Jamaica Bay, about 1 mile north of the main wreckage site. The airplane's 

engines subsequently separated in flight and were found several blocks north and east of the 

main wreckage site. All 260 people aboard the airplane and 5 people on the ground were killed, 

and the airplane was destroyed by impact forces and a post-crash fire. In the immediate vicinity 

of the impact area, four homes were destroyed, three homes received substantial damage, and 

three homes received minor damage. In addition, the in-flight separation of the engines resulted 

in property damage where the engines came to rest. A gas station received minor damage as a 

result of the impact of the left engine, and a home and a boat (parked in the driveway) received 

severe damage as a result of the impact of the right engine.

Flight 587 was operating under the provisions of 14 Code of Federal Regulations Part 121 on an 

instrument flight rules flight plan. Visual meteorological conditions prevailed at the time of the 

accident.

(3) NTSB causal factors. The National Transportation Safety Board determines that the 

probable cause of this accident was the in-flight separation of the vertical stabilizer as a result of 

the loads beyond ultimate design that were created by the first officer’s unnecessary and 

excessive rudder pedal inputs. Contributing to these rudder pedal inputs were characteristics of 

the Airbus A300-600 rudder system design and elements of the American Airlines Advanced

Aircraft Maneuvering Program.
72

American Eagle 4184

(1) Accident Information10/31/1994

NTSB Report Number: DCA95MA001

American Eagle Airlines 4184

Part 121 Scheduled Domestic Flight

ATR 72

68-Fatalities

(2) Summary of NTSB accident narrative related to rulemaking.

On October 31, 1994, American Eagle flight 4184 Chicago's O'Hare International Airport (ORD) 

to Indianapolis, Indiana (IND) at 1559 crashed at 41o 5' 40" north latitude and 87o 19' 20" west 

longitude (near Roselawn, IN) during a rapid descent after an uncommanded roll excursion. The 

airplane was in a holding pattern and was descending to a newly assigned altitude of 8,000 feet 

when the initial roll excursion occurred. The airplane was destroyed by impact forces; and the 

captain, first officer, 2 flight attendants and 64 passengers received fatal injuries. Flight 4184 

was a regularly scheduled passenger flight being conducted under 14 Code of Federal

Regulations, Part 121; and an instrument flight rules flight plan had been filed.

(3) NTSB causal factors. 

The NTSB determined that the probable cause was the loss of control, attributed to a sudden and 

unexpected aileron hinge moment reversal that occurred after a ridge of ice accreted beyond the 

deice boots while the airplane was in a holding pattern during which it intermittently 

encountered supercooled cloud and drizzle/rain drops, the size and water content of which 

exceeded those described in the icing certification envelope. The airplane was susceptible to this 

loss of control, and the crew was unable to recover.

Other contributing factors are:

1. The French Directorate General for Civil Aviation's (DGAC's) inadequate oversight of 

the ATR 42 and 72, and its failure to take the necessary corrective action to ensure 

continued airworthiness in icing conditions.

2. The DGAC's failure to provide the FAA with timely airworthiness information developed 

from previous ATR incidents and accidents in icing conditions.

3. the Federal Aviation Administration's (FAA's) failure to ensure that aircraft icing 

certification requirements, operational requirements for flight into icing conditions, and 

FAA published aircraft icing information adequately accounted for the hazards that can 

result from flight in freezing rain.

4. The FAA's inadequate oversight of the ATR 42 and 72 to ensure continued airworthiness 

in icing conditions.

5. ATR's inadequate response to the continued occurrence of ATR 42 icing/roll upsets 

which, in conjunction with information learned about aileron control difficulties during 

the certification and development of the ATR 42 and 72, should have prompted 

additional research, and the creation of updated airplane flight manuals, flightcrew 

operating manuals and training programs related to operation of the ATR 42 and 72 in 

such icing conditions.
73

USAir 427

(1) Accident Information09/08/1994

NTSB Report Number: DCA94MA076

USAir 427

Part 121 Scheduled Domestic Flight

Boeing B-737-300

Fatalites-132

(2) Summary of NTSB accident narrative related to rulemaking.

On September 8, 1994, about 1903:23 eastern daylight time, USAir (now US Airways) flight 

427, a Boeing 737-3B7 (737-300), N513AU, crashed while maneuvering to land at Pittsburgh 

International Airport, Pittsburgh, Pennsylvania. Flight 427 was operating under the provisions of 

14 Code of Federal Regulations Part 121 as a scheduled domestic passenger flight from 

Chicago-O'Hare International Airport, Chicago, Illinois, to Pittsburgh. The flight departed about 

1810, with 2 pilots, 3 flight attendants, and 127 passengers on board. The airplane entered an 

uncontrolled descent and impacted terrain near Aliquippa, Pennsylvania, about 6 miles northwest 

of the destination airport. All 132 people on board were killed, and the airplane was destroyed by 

impact forces and fire.

Visual meteorological conditions prevailed for the flight, which operated on an instrument flight 

rules flight plan.

(3) NTSB causal factors. 

The National Transportation Safety Board determines that the probable cause of the USAir flight 

427 accident was a loss of control of the airplane resulting from the movement of the rudder 

surface to its blow-down limit. The rudder surface most likely deflected in a direction opposite 

to that commanded by the pilots as a result of a jam of the main rudder power control unit servo 

valve secondary slide to the servo valve housing offset from its neutral position and over-travel 

of the primary slide.
74

Comair 5191

(1) Accident Information08/27/2006

NTSB Report Number: DCA06MA064

COMAIR 5191

Part 121 Scheduled Domestic Flight

Bombardier CL-600-2B19

Fatalites-49

(2) Summary of NTSB accident narrative related to rulemaking.

On August 27, 2006, about 0606:35 eastern daylight time, Comair flight 5191, a Bombardier 

CL-600-2B19, N431CA, crashed during takeoff from Blue Grass Airport,

Lexington, Kentucky. The flight crew was instructed to take off from runway 22 but instead 

lined up the airplane on runway 26 and began the takeoff roll. The airplane ran off the end of the 

runway and impacted the airport perimeter fence, trees, and terrain.

The captain, flight attendant, and 47 passengers were killed, and the first officer received serious 

injuries. The airplane was destroyed by impact forces and postcrash fire. The flight was 

operating under the provisions of 14 Code of Federal Regulations Part 121 and was en route to 

Hartsfield-Jackson Atlanta International Airport, Atlanta, Georgia. Night visual meteorological 

conditions prevailed at the time of the accident.

(3) NTSB causal factors. 

The National Transportation Safety Board determines that the probable cause of this accident 

was the flight crewmembers’ failure to use available cues and aids to identify the airplane’s 

location on the airport surface during taxi and their failure to cross-check and verify that the 

airplane was on the correct runway before takeoff. Contributing to the

accident were the flight crew’s non-pertinent conversation during taxi, which resulted in a loss of 

positional awareness, and the Federal Aviation Administration’s (FAA) failure to require that all 

runway crossings be authorized only by specific air traffic control (ATC) clearances.
75

Northwest 1482

(1) Accident Information12/03/1990

NTSB Report Number: DCA91MA010A

NORTHWEST AIRLINES 1482

Part 121 Scheduled Domestic Flight

DC-9

Fatalites-8

(2) Summary of NTSB accident narrative related to rulemaking.

On December 3, 1990, at 1345 EST, Northwest Flight1482, a DC-9 (N3313L) a regular schedule 

flight to Pittsburg Pa, and Northwest Flight 299, a Boeing 727 (N278US) a regular schedule 

flight to Memphis, collided near the intersection of runway 09/27 and 03C/21C in dense fog at 

Detroit Metropolitan/Wayne County Airport, Romulus, MI. At the time of the collision, theB727 was on its takeoff roll, and the DC-9 had just taxied onto the active runway. The B-727 was 

substantially damaged, and DC-9 was destroyed. Seven of the 40 passengers and 1 crewmember 

aboard the DC-9 received fatal injuries. 

(3) NTSB causal factors. 

The NTSB found the probable cause of the accident was the lack of proper crew coordination, 

including virtual reversal of roles by the DC-9 pilots, which led to their failure to stop taxiing & 

alert ground controller of their positional uncertainty in a timely manner before & after intruding 

onto the active runway.

Other contributing factors include:

1. Deficiencies in ATC services provided by Detroit tower, including failure of ground 

controller to take timely action to alert local controller to possible runway incursion, 

inadequate visual observation, failure to use progressive taxi instructions in low-vis 

conditions, & issuance of inappropriate & confusing taxi instructions compounded by 

inadequate backup supervision for level of experience of staff on duty.

2. Deficiencies in surface markings, signage & lighting at airport & failure of FAA 

surveillance to detect or correct any of these deficiencies;

3. Failure of northwest airlines to provide adequate cockpit resource management training 

to line aircrews. 

4. Contributing to fatalities was inoperability of DC-9 internal tailcone release mechanism.

5. Contributing to number & severity of injuries was failure of crew of DC-9 to properly 

execute the passenger evacuation.
76

Continental 1404

(1) Accident Information12-20-2008

NTSB Report Number: DCA09MA021

Continental 1404

Part 121 Scheduled Domestic Flight

Boeing B-737-500

Fatalites-0

(2) Summary of NTSB accident narrative related to rulemaking.

On December 20, 2008, about 1818 mountain standard time, Continental Airlines flight 1404, a 

Boeing 737-500, N18611, departed the left side of runway 34R during takeoff from Denver 

International Airport (DEN), Denver, Colorado. A postcrash fire ensued. The captain and 5 of 

the 110 passengers were seriously injured; the first officer, 2 cabin crewmembers, and 38 

passengers received minor injuries; and 1 cabin crewmember and 67 passengers (3 of whom 

were lap-held children) were uninjured. The airplane was substantially damaged. The scheduled, 

domestic passenger flight, operated under the provisions of 14 Code of Federal Regulations Part 

121, was departing DEN and was destined for George Bush Intercontinental Airport, Houston, 

Texas. At the time of the accident, visual meteorological conditions prevailed, with strong and 

gusty winds out of the west. The flight operated on an instrument flight rules flight plan.

(3) NTSB causal factors. 

The NTSB found that the probable cause of the accident was the captain’s ceased rudder input, 

which was needed to maintain directional control of the airplane, about 4 seconds before the 

excursion, when the airplane encountered a strong and gusty crosswind that exceeded the 

captain’s training and experience.

Other contributing factors include:

1. An air traffic control system that did not require or facilitate the dissemination of key, 

available wind information to the air traffic controllers and pilots

2. 'Inadequate crosswind training in the airline industry due to deficient simulator wind gust 

modeling
77

FedEx 647

(1) Accident Information12-18-2003

NTSB Report Number: DCA04MA011

FEDEX 647

Part 121 Scheduled Domestic Flight

Boeing MD-10-10F 

Fatalites-0

(2) Summary of NTSB accident narrative related to rulemaking.

On December 18, 2003, about 1226 central standard time, Federal Express Corporation (FedEx) 

flight 647, a Boeing MD-10-10F (MD-10), N364FE, crashed while landing at Memphis 

International Airport (MEM), Memphis, Tennessee. The right main landing gear collapsed after 

touchdown on runway 36R, and the airplane veered off the right side of the runway. After the 

gear collapsed, a fire developed on the right side of the airplane. Of the two flight crewmembers 

and five nonrevenue FedEx pilots on board the airplane, the first officer and one nonrevenue 

pilot received minor injuries during the evacuation. The post-crash fire destroyed the airplane’s 

right wing and portions of the right side of the fuselage. Flight 647 departed from Metropolitan 

Oakland International Airport (OAK), Oakland, California, about 0832 (0632 Pacific standard 

time) and was operating under the provisions of 14 Code of Federal Regulations (CFR) Part 121 

on an instrument flight rules flight plan.

(3) NTSB causal factors. 

The NTSB probable cause findings: 1) The first officer failed to properly apply crosswind 

landing techniques to align the airplane with the runway centerline and to properly arrest the

airplane’s descent rate (flare) before the airplane touched down; and 2) the captain failed to 

adequately monitor the first officer’s performance and command or initiate corrective action 

during the final approach and landing.
78

Delta 1141

(1) Accident Information08-31-1988

NTSB Report Number: DCA88MA072

DELTA 1141

Part 121 Scheduled Domestic Flight

Boeing B-727-232

Fatalites-14

(2) Summary of NTSB accident narrative related to rulemaking.

About 0901 central daylight time on August 31, 1988, Delta Air Lines, Inc., flight 1141, crashed 

shortly after lifting off from runway 18L at the Dallas-Fort Worth International Airport, Texas. 

The airplane, a Boeing 727-232, U.S. Registry N473DA, was a regularly scheduled passenger 

flight and was en route to Salt Lake City, Utah, with 101 passengers and 7 crewmembers. The 

flightcrew reported that the takeoff roll appeared to be normal in all respects, with no warning 

lights, audible warnings, or unusual engine instrument conditions. The captain stated that the 

rotation was initially normal, but as the main gear wheels left the ground he heard "two

explosions." He said it felt as though the airplane was experiencing "reverse thrust." The captain 

stated that the airplane began to "roll violently." The airplane struck the instrument landing 

system (ILS) localizer antenna array approximately 1,000 feet beyond the end of runway 18L, 

and came to rest about 3,200 feet beyond the departure end of the runway. The flight was 

airborne approximately 22 seconds from liftoff to the first ground impact near the ILS localizer 

antenna. The airplane was destroyed by impact forces and the post-crash fire.

(3) NTSB causal factors. 

The NTSB probable cause findings: (1) The Captain and First Officer's inadequate cockpit 

discipline which resulted in the flightcrew's attempt to takeoff without the wing flaps and slats 

properly configured; and (2) the failure of the takeoff configuration warning system to alert the 

crew that the airplane was not properly configured for the takeoff.

Other contributing factors include:

1. Delta's slow implementation of necessary modifications to its operating procedures, 

manual's, checklists, training, and crew checking programs which were necessitated by 

significant changes in the airline following rapid growth and merger.

2. 'The lack of sufficiently aggressive action by the FAA to have known deficiencies 

corrected by Delta and the lack of sufficient accountability within the FAA's air carrier 

inspection process.
79

Corporate 5966

(1) Accident Information10/19/2004

NTSB Report Number: DCA05MA004

CORPORATE 5966

Part 121 Scheduled Domestic Flight

British Aerospace BAE-J3201

Fatalites-13

(2) Summary of NTSB accident narrative related to rulemaking.

On October 19, 2004, about 1937 central daylight time, Corporate Airlines (doing business as 

American Connection) flight 5966, a BAE Systems BAE-J3201, N875JX, struck trees on final 

approach and crashed short of runway 36 at Kirksville Regional Airport (IRK), Kirksville, 

Missouri. The flight was operating under the provisions of 14 Code of Federal Regulations 

(CFR) Part 121 as a scheduled passenger flight from Lambert-St. Louis International Airport 

(STL), in St. Louis, Missouri, to IRK. The captain, first officer, and 11 of the 13 passengers were 

fatally injured, and 2 passengers received serious injuries. The airplane was destroyed by impact 

and a post-impact fire. Night instrument meteorological conditions (IMC) prevailed for the 

flight, which operated on an instrument flight rules (IFR) flight plan.

(3) NTSB causal factors. 

The pilots' failure to follow established procedures and properly conduct a non-precision 

instrument approach at night in IMC, including their descent below the minimum descent 

altitude (MDA) before required visual cues were available (which continued un-moderated until 

the airplane struck the trees) and their failure to adhere to the established division of duties 

between the flying and nonflying (monitoring) pilot. Contributing to the accident was (1) the 

pilots' failure to make standard callouts and the current Federal Aviation Regulations that allow 

pilots to descend below the MDA into a region in which safe obstacle clearance is not assured 

based upon seeing only the airport approach lights, (2) the pilots' failure to establish and 

maintain a professional demeanor during the flight, and (3) the pilots’ fatigue likely contributed 

to their degraded performance.
80

USAir 5050

(1) Accident Information09-20-1989

NTSB Report Number: DCA89MA074

USAir 5050

Part 121 Scheduled Domestic Flight

BOEING B-737-400

Fatalites-2

(2) Summary of NTSB accident narrative related to rulemaking.

On September 20, 1989, USAir, Inc. flight 5050 was departing New York City's LaGuardia 

Airport, Flushing, New York, for Charlotte Douglas International Airport, Charlotte, North 

Carolina. As the first officer began the takeoff on runway 31, he felt the airplane drift left. The 

captain noticed the left drift also and used the nosewheel tiller to help steer. As the takeoff run 

progressed, the aircrew heard a "bang" and a continual rumbling noise. The captain then took 

over and rejected the takeoff but did not stop the airplane before running off the end of the 

runway into Bowery Bay. Instrument flight conditions prevailed at the time and the runway was

wet.

(3) NTSB causal factors. 

The captain's failure to exercise his command authority in a timely manner to reject the takeoff 

or take sufficient control to continue the takeoff, which was initiated with a mistrimmed rudder. 

Also causal was the captain's failure to detect the mistrimmed rudder before the takeoff was 

attempted.
81

Appendix 2 – Historical Accidents
82

Appendix 3 

Historical Accidents Probable Cause(s), Contributing Factors, and Relevant Provisions of 

Final Rule
83
84
85

Appendix 4 – Value of Statistical Life (VSL)

Appendix 4, Table 1

Estimated Value of Preventing Fatalities and Injuries (2012 $)

Appendix 4, Table 2

Estimated Value of Preventing Fatalities and Injuries 

(2012 $)
86

Appendix 5 – Fatalities, Injuries, and Quantified Benefit - Sensitivity Analysis

Our estimate of future benefits incorporates information related to the rule’s expected impacts on 

the aviation system looking forward in order to appropriately value the reduction in future risks. 

However, as a test of the sensitivity of our benefits estimates using this approach, we also 

include an analysis assuming that the exact number of fatalities and injuries as actually occurred

in each historical accident would occur in a potential future accident. The details and results of 

the calculations for the sensitivity follow.

Appendix 5, Table 1

Actual Fatalities and Injuries from Historical Accidents - Sensitivity Analysis

Appendix 5, Table 2

Valuation of Actual Fatalities and Injuries for Historical Accidents (2012 $)

Sensitivity Analysis
87

* Details may not add to row or column totals due to rounding.
88

Appendix 5, Table 3

Single Year Benefits of Final Rule (Actual Fatalities and Injuries) (2012 $)

Sensitivity Analysis

* Details may not add to row or column totals due to rounding.

Appendix 5, Table 4

Total Benefits of Final Rule (Actual Fatalities and Injuries) (2012 $) - Sensitivity Analysis

* Details may not add to row or column totals due to rounding.
89
90

Appendix 6

Table 1: Expected Value of a Typical Part 121 Passenger Aircraft During Benefits Period
91

Appendix 6

Table 2: Average Value of Most Frequently Used Cargo Aircraft

(Jan-Oct 2012 T-100 Segment Data for Part 121 Cargo Only Operations)
92

Appendix 7

Unit Values for Benefit Analysis
93

Appendix 8

Part 121 Carriers in T-100 Segment Data (US Carriers) (Jan 2012 - Oct 2012)
94

Appendix 9

Part 121 and 121/135 Pilot Employment 

February 2013
95

Appendix 10

Sensitivity Analysis on Pilots Spending an Extra Day in Training

As a sensitivity analysis, the FAA estimated the travel costs of pilots spending an extra day in 

simulator training for the additional tasks added by the final rule. Since travel costs include 

hotel, airfare or automobile mileage, and per diems (meals, etc.), the airfare or automobile 

mileage has already occurred. Therefore, the only remaining travels costs are for the final rule 

are for hotel and per diem costs. The FAA notes that the pilots’ salary has already been 

estimated and included in the costs above.

We used the same hotel and per diem costs we used in the SNPRM regulatory evaluation. The 

FAA notes that no comments were received on our SNPRM estimates for hotel and per diem 

costs.

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

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

meals are $92 and $44, respectively. 58 Per Diem cost (i.e., lodging and meals) rates are based on 

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

Government business to use for their lodging, meals, and incidental expenses. 

We estimated the additional day of travel costs by taking the product of the number of pilots in 

simulator training with the sum of hotel and per diem. We perform this calculation for pilots in 

initial, upgrade, transition, and recurrent training and then sum the results.

The following table shows our cost estimate for an additional day in simulator training.

 58 Includes incidental expenses.
96

Appendix 10

Table 1: Cost of an Additional Day in Pilot Simulator Training

The FAA estimates the total travel cost for an extra day would be about $61.4 million in 2012 

dollars ($29.4 million at a seven percent present value and $44.3 million at a three percent 

present value). 

Even if pilots would have to travel an extra day for in order to complete the additional simulator 

training tasks the final rule adds, the final rule would be cost beneficial.
97

Appendix 11

Low and High Estimated Simulator Costs by Pilot, Check Pilot, and Flight Instructor

(2012 $)

* Details may not add to row or column totals due to rounding.
98

Appendix 12

Estimated Ground School Costs by Pilot, Check Pilot, and Flight Instructor

(2012 $)

* Details may not add to row or column totals due to rounding.
99

Appendix 13

The Probability of Effectiveness Ratings of Overlapping Accidents For the Following Final Rules:

Flightcrew Member Duty and Rest Requirements,

The Pilot Certification and Qualification Requirements, and

Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers

The FAA notes that for future related final rules, the total probability of effectiveness will not exceed 100% for any accident.
100

Appendix 14

Sensitivity Analysis on 10 Year Historical Accident Analysis Period for Benefits Estimation

The FAA reviewed accident data for U.S. certificate holders required to train under part 121 over 

the 22-year interval from 1988 through 2009. The objective of the analysis was to determine if 

an accident could have been prevented or mitigated by the training provisions in the final rule. 

In 1988, Delta flight 1141, crashed shortly after lifting off from the runway at the Dallas-Fort 

Worth International Airport (DCA88MA072). In their final report, the NTSB determined that 

one causal factor for the accident was “The captain and first officer’s inadequate cockpit 

discipline which resulted in the flightcrew’s attempt to takeoff without wing flaps and slats 

properly configured.” The FAA determined that the pilot monitoring training provisions in the 

final rule may have prevented or mitigated this accident. The FAA initiated the historical 

accident interval for the benefits analysis with this accident.

Over the next 22 year historical accident interval, the FAA identified accidents with casual 

factors identified by the NTSB that are addressed by the provisions in the final rule. The FAA 

cited these accidents based on pertinent accident causal factors, regardless of whether there were 

open NTSB recommendations associated with those accidents.

We have explored the effect of reducing the historical analysis period from 22 years to 10 years 

here in response to comments disputing the use of a 22-year time frame for accidents. These 

comments state the accident rate has declined over time so using older accidents is not 

appropriate. As a result of reducing the historical analysis period to 10 years from 2000 to 2009, 

the number of relevant accidents is reduced from eleven to six. The 22-year historical period had 

an accident rate of 0.5 accidents per year, while the 10 year historical period had a slightly higher 

rate of 0.6 accidents per year.
101

Table 1

Accidents During 10 Year Period (2000-2009)

Table 2, below, is adapted from Table 7 of this regulatory evaluation to cover just those 

accidents that occurred during the 10 year historical period. Table 3 is similar to Table 9 of this 

regulatory evaluation and shows those single year benefits grown to account for industry growth 

and also displays the present value of the benefits over the future analysis period when 

discounted at both the seven percent and three percent rates as recommended in OMB Circular 

A-4. Using a 10-year historical analysis period rather than the 22-year period increases the 

estimated benefits by approximately 17 percent. The total estimated benefit of the final rule 

using the 10-year historical analysis period is $803 million in 2012 dollars, compared to $689 

million when using the 22-year historical analysis period. The stream of benefits estimated using 

the 10-year historical analysis period has a present value of $370 million when discounted at 

seven percent and $570 million when discounted at three percent, compared to $317 million and 

$489 million respectively when estimated using the 22-year historical analysis period.

Carrier Flt# Date

State of 

Accident Aircraft Fatalities

Serious 

Injury

Minor 

Injury

People 

on Board

Effectiveness 

Rating for 

Final Rule

American 587 11/12/2001 NY A300B4-605R 265 0 0 260 0.25

FedEx 647 12/18/2003 TN MD-10-10F 0 0 2 7 0.35

Corporate 5966 10/19/2004 MO Jetstream 32 13 2 0 15 0.05

COMAIR 5191 8/27/2006 KY CRJ-100ER 49 1 0 50 0.15

Continental 1404 12/20/2008 CO B737-500 0 6 41 115 0.25

Colgan 3407 2/12/2009 NY DHC-8-402 50 0 0 49 0.20

10 Year Total 377 9 43 496
102

Table 2

Single Year Benefits of Final Rule for 10 Year Period (2012 $)

Table 3

Total Benefits of Final Rule for 10 Year Period (2012 $)

Carrier Flt#

Effectiveness 

Rating

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

American 587 25% $213,850,000 $5,566,850

FedEx 647 35% $19,110 $10,683,750

Corporate 5966 5% $35,795,740 $1,060,000

COMAIR 5191 15% $119,135,370 $3,180,000

Continental 1404 25% $1,803,275 $2,775,000

Colgan 3407 20% $163,800,000 $4,266,320

$534,403,495 $27,531,920

$53,440,350 $2,753,192

Total benefit over 10 year history

Per year benefit

Total Benefits

Total 

Discounted at 

7%

Total 

Discounted 

at 3%

0 2012

1 2013

2 2014

3 2015

4 2016

5 2017

6 2018

7 2019 $66,586,953 $3,076,692 $69,663,645 $43,379,552 $56,643,510

8 2020 $68,717,985 $3,125,974 $71,843,959 $41,813,184 $56,713,621

9 2021 $70,908,550 $3,176,082 $74,084,632 $40,294,631 $56,778,462

10 2022 $73,172,734 $3,226,741 $76,399,475 $38,833,853 $56,848,849

11 2023 $75,505,580 $3,278,501 $78,784,081 $37,430,317 $56,913,620

12 2024 $77,914,525 $3,330,812 $81,245,337 $36,072,930 $56,985,479

13 2025 $80,408,150 $3,384,224 $83,792,374 $34,773,835 $57,062,607

14 2026 $82,975,142 $3,438,461 $86,413,603 $33,511,195 $57,128,033

15 2027 $85,623,197 $3,493,250 $89,116,447 $32,295,800 $57,203,847

16 2028 $88,353,957 $3,549,140 $91,903,097 $31,127,579 $57,274,010

Total $770,166,773 $33,079,877 $803,246,650 $369,532,876 $569,552,038

Year

Calendar 

Year

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

Total Benefits
103

Appendix 15

Sensitivity Analysis on Inclusion of AA 587 Accident in Historical Accident Analysis for 

Benefits Estimation

As explained in the “Accident Population and Scoring” section of the RIA benefits and the 

“Background” section of the Preamble, the accident involving American Airlines 587 was added 

to analysis of historical accidents subsequent to the NPRM. The AA 587 accident resulted in the 

deaths of all 260 people on board and an additional 5 people on the ground. The FAA Accident 

Investigation and Prevention Group (AVP) assigned an effectiveness rating of 0.25 to this 

accident.

Because this catastrophic accident was added to the benefits analysis for the final rule, the FAA 

feels it is worthwhile to present a sensitivity analysis exploring the impact on the benefits 

estimates of not including that accident. 

Table 1, below, is adapted from Table 7 of this regulatory evaluation but removes AA 587 from 

the calculations. Table 2 is similar to Table 9 of this regulatory evaluation and shows those 

single year benefits grown to account for industry growth and also displays the present value of 

the benefits over the future analysis period when discounted at both the seven percent and three 

percent rates as recommended in OMB Circular A-4. 

Removing AA 587 from the benefits analysis decreases the estimated benefits by approximately 

26 percent. However, the benefits estimate without AA 587 still exceeds the costs of the final 

rule by a significant margin. 
104

Table 1

Single Year Benefits of Final Rule, Omitting AA 587 (2012 $)

Table 2

Total Benefits of Final Rule, Omitting AA 587 (2012 $)

Carrier Flt#

Effectiveness 

Rating

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

Colgan 3407 20% $163,800,000 $4,266,320

American Eagle 4184 20% $161,980,000 $4,240,000

USAir 427 20% $161,980,000 $4,240,000

COMAIR 5191 15% $119,135,370 $3,180,000

Northwest 1482 50% $86,202,450 $6,232,500

Continental 1404 25% $1,803,275 $2,775,000

FedEx 647 35% $19,110 $10,683,750

Delta 1141 35% $47,930,820 $3,885,000

Corporate 5966 5% $35,795,740 $1,060,000

USAir 5050 50% $16,527,050 $5,550,000

$795,173,815 $46,112,570

$36,144,264 $2,096,026

Total benefit over 22 year history

Per year benefit

Total

Present Value at 

7%

Present Value at 

3%

0 2012

1 2013

2 2014

3 2015

4 2016

5 2017

6 2018

7 2019 $45,035,940 $2,342,309 $47,378,249 $29,502,436 $38,523,254

8 2020 $46,477,259 $2,379,828 $48,857,087 $28,434,825 $38,567,784

9 2021 $47,958,843 $2,417,976 $50,376,819 $27,399,952 $38,608,794

10 2022 $49,490,219 $2,456,542 $51,946,761 $26,404,539 $38,653,585

11 2023 $51,068,034 $2,495,948 $53,563,982 $25,448,248 $38,694,621

12 2024 $52,697,319 $2,535,772 $55,233,091 $24,523,492 $38,740,490

13 2025 $54,383,877 $2,576,435 $56,960,312 $23,638,529 $38,789,972

14 2026 $56,120,056 $2,617,727 $58,737,783 $22,778,512 $38,831,548

15 2027 $57,911,062 $2,659,438 $60,570,500 $21,950,749 $38,880,204

16 2028 $59,758,006 $2,701,987 $62,459,993 $21,155,200 $38,925,068

Total $520,900,615 $25,183,962 $546,084,577 $251,236,482 $387,215,320

Other Benefits

Total Benefits

Year

Calendar 

Year

Benefits from 

Avoided 

Fatalities and 

Injuries
105

As shown in Table 3 and 4 below, omitting AA 587 from the 10 year benefits history explored in 

Appendix 14 also does not impact the central conclusion that the estimated benefits of the final 

rule exceed the costs by a wide margin.

Table 3

Single Year Benefits of Final Rule for 10 Year Period, Omitting AA 587 (2012 $)

Table 4

Total Benefits of Final Rule for 10 Year Period, Omitting AA 587 (2012 $)

Carrier Flt#

Effectiveness 

Rating

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

FedEx 647 35% $19,110 $10,683,750

Corporate 5966 5% $35,795,740 $1,060,000

COMAIR 5191 15% $119,135,370 $3,180,000

Continental 1404 25% $1,803,275 $2,775,000

Colgan 3407 20% $163,800,000 $4,266,320

$320,553,495 $21,965,070

$32,055,350 $2,196,507

Total benefit over 10 year history

Per year benefit

Total Benefits

Total 

Discounted at 

7%

Total 

Discounted 

at 3%

0 2012

1 2013

2 2014

3 2015

4 2016

5 2017

6 2018

7 2019 $39,941,132 $2,454,597 $42,395,729 $26,399,820 $34,471,967

8 2020 $41,219,398 $2,493,914 $43,713,312 $25,441,148 $34,507,288

9 2021 $42,533,374 $2,533,890 $45,067,264 $24,512,085 $34,539,551

10 2022 $43,891,509 $2,574,306 $46,465,815 $23,618,574 $34,575,213

11 2023 $45,290,830 $2,615,601 $47,906,431 $22,760,345 $34,607,606

12 2024 $46,735,798 $2,657,334 $49,393,132 $21,930,551 $34,644,343

13 2025 $48,231,559 $2,699,946 $50,931,505 $21,136,575 $34,684,355

14 2026 $49,771,329 $2,743,218 $52,514,547 $20,365,141 $34,717,367

15 2027 $51,359,722 $2,786,928 $54,146,650 $19,622,746 $34,756,735

16 2028 $52,997,726 $2,831,517 $55,829,243 $18,909,365 $34,792,784

Total $461,972,377 $26,391,251 $488,363,628 $224,696,350 $346,297,209

Year

Calendar 

Year

Benefits from 

Avoided 

Fatalities and 

Injuries

Other 

Benefits

Total Benefits