## FINAL REGULATORY EVALUATION

PILOT CERTIFICATION AND QUALIFICATION REQUIREMENTS

FOR AIR CARRIER OPERATIONS

OFFICE OF AVIATION POLICY AND PLANS

ECONOMIC ANALYSIS DIVISION (APO

- 300)

Daniel F. Leach

June 2013

### 2 

## TABLE OF CONTENTS

TABLE OF CONTENTS

................................ ................................ ....................... 2

I. EXECUTIVE SUMMARY

................................ ................................ ............... 4

II. ACRONYMS USED IN THI S DOCUMENT

................................ ................... 8

III. BACKGROUND

................................ ................................ ............................ 9

IV. DISCUSSION OF COSTS AND BENEFITS

................................ ................ 13

A. Who is Potentially Affected by this Rule?

................................ ................................ ................................ ......... 13

B. Principal Assumptions and Sources of Information

................................ ................................ ......................... 13

C. Overview of Costs and Benefits

................................ ................................ ................................ .......................... 15

Cost and Benefits of the Statute

................................ ................................ ................................ .............................. 17 Benefits of the Final Rule (Cost Savings)

................................ ................................ ................................ ............... 19 Costs and Safety Benefits of the Final Rule

................................ ................................ ................................ ............ 19

D. Costs and Cost Savings of the Final Rule

................................ ................................ ................................ .......... 23 Cost of ATP Certification Training Program

................................ ................................ ................................ .......... 23 Cost of an ATP Certificate/Airplane Type Rating

................................ ................................ ................................ .. 31 Cost of ATP Certificate/Airplane type rating per Pilot

— New Pilots

................................ ................................ . 33 Cost of ATP Certificate/Airplane type rating per Pilot

-- Current SICs

................................ ............................... 35 Cost of ATP Certificate/Airplane type rating for New Part 121 Pilots, 2013

- 2032

................................ ........... 37 Cost of ATP Certificate/Airplane type rating for Current Part 121 Pilots, 2013

................................ ................ 40 Cost of ATP Certificate/Airplane type rating for All Part 121 Pilots, 2013

- 2032

................................ ............. 44

Cost of the ATP Certificate Requirement (Eligibility Restrictions) under the Statute

................................ ............ 45
Cost of the 1,500

- Hour Requirement under the Final Rule and Cost Savings Attributable to the Final Rule

........ 55

E. Safety Benefits of this Rule

................................ ................................ ................................ ................................ .. 60 Probability Scores

................................ ................................ ................................ ................................ .................. 61 Description of Accidents with the Highest Expected Accident Costs

................................ ................................ .... 63 Corporate Airlines Crash at Kirksville, Missouri, October 19, 2004 (Probabil ity Score = 0.15)

....................... 63 Crash of Colgan Air at Buffalo, NY, February 12, 2009 (Probability Score = 0.20)

................................ ......... 64 Avjet Crash at Aspen, Colorado, March 29, 2001 (Probability Score = 0.35)

................................ ................... 65 Estimating the Safety Benefits of the Final Rule

................................ ................................ ................................ .... 66

Cost

- Benefit Sensitivity Analysis using Low and High Values of VSL

................................ ............................ 71



### APPENDIX 1

- DESCRIPTION OF FOQ A CCIDENTS WITH HIGH P ROBABILITY

SCORES

................................ ................................ ................................ ............ 76

Mesa Airlines Accident at Roanoke Regional Airport, October 16, 2001 (Probability Score = 0.75)

................... 76 USA Jet Crash at Saltillo, Mexico, July 6, 2008 (Probability Score = 0.55)

................................ .......................... 77 Great Lakes Aviation Accident at Laramie Regional Airport, June 20, 2007 (Probability Score = 0.55)

.............. 78 Air Tahoma Crash at Florence, KY, August 13, 2004 (Probability Score = 0.55)

................................ ................. 78

### 3 APPENDIX 2

-- ESTIMATED MARKET VAL UE OF AIR CA RRIER AIRCRAFT ($ 20 10)

81

APPENDIX 3

— FOQ ACCIDENTS, FISCA L YEARS 2001

- 2010

...................... 82

APPENDIX 4

— COST PER PILOT OF EL IGIBILITY RESTRICTIO NS

............. 84

APPENDIX 5

— PART 121 FOQ ACCIDEN TS WITH PROBABILITY SCORES

CHANGED IN THE FINAL RULE

................................ ................................ ...... 87

### 4 

## I

. EXECUTIVE SUMMARY

In response to the Airline Safety and Federal Aviation Extension Act of 2010, Pub.L. 111

-

2 16 (the Act), this final rule requires an airline transport pilot (ATP) certificate for all pilots

serving in part 121 operations, including pilots serving as second in command (SIC), who are

currently required to have just a commercial pilot certificate with an instrument rating. The Act

also requires applicants for an ATP certificate to have 1,500 flight hours but gives the Federal

Aviation Administration (FAA) discretion to reduce the flight

- hour requirement based on

specific academic training courses. To this end the final rule establishes a restricted privileges

ATP certificate (R

- ATP) with a 750

- hour flight time requirement for military pilots (a 750

- hour

credit) and a 1,000

- hour and 1,250

- hour flight time requirement for pilots with a 4

- year or 2

- year

aviation degree (a 500

- hour or 250

- hour credit respectively). Th e final rule also provides relief to

the statutory requirements by allowing pilots with 1,500 hours of flight time to be eligible for the

R

- ATP with a minimum age of 21 years rather than the ATP certificate minimum age

requirement of 23 years.

The final ru le also requires all SICs serving in part 121 operations to hold a type rating in the

airplane flown and requires applicants for an ATP certificate with an airplane category

multiengine class rating or an ATP certificate obtained concurrently with an airpl ane type rating

to complete an ATP Certification Training Program (CTP).

In Table 1 , we summarize the costs and benefits of the statute and the rule

. Table 1A shows

the costs of the statute, which result from the Congressionally

- mandated self

- executing

req uirement that all part 121 SICs have an ATP certificate . We estimate the costs of the ATP

certificate requirement to be $6.4 billion ($2.2 billion in present value), almost all of which stems

from the 1,500

- hour requirement. The FAA was unable to find a qu antifiable relationship

### 5 between the 1,500

- hour requirement and airplane accidents and hence no benefit from the

requirement. For most accidents reviewed by the FAA, both pilots had more than 1,500 hours of

flight time and for those SICs that did not, there were other causal factors identified by the

NTSB.

Table 1D shows the cost savings benefits resulting from the rule’s provision for academic

training credits (including credit for military training) toward the 1,500

- hour requirement (by

means of the R

- ATP) and the rule’s provision allowing pilots with a minimum age of 21 also to

be eligible for the R

- ATP. These cost savings are $2.3 billion, with a present value of $0.8

billion. The savings reduce the cost of the statute’s ATP certificate/1,500

- hour require ment to

$4.1 billion, with a present value of $1.4 billion.

Table 1 B shows the costs of the rule and Table 1C shows the benefits. The costs of the rule

stem from the rule’s requirement that all SICs serving in part 121 operations hold a type rating in

the airplane flown and the requirement that an ATP CTP be completed by all applicants for an

ATP certificate with an airplane category multiengine class rating or an ATP certificate obtained

concurrently with an airplane ty pe rating. T he cost of the final rule of $ 312.7 million ($ 138.7

million in present value) is nearly entirely composed of the required training costs. Part 121

operators incur most of the training costs and all of the type rating costs of $1.5 million in

pr esent value. Table 1C shows the expected benefits of the final rule. F or part 121 o perators the

discretionary provisions 1 

### of the final rule are cost

- beneficial because present value benefits, at

$ 127.5 million, exceed present value costs, at $ 124.6 million

. Similarly, f or part 135 operators

the discretionary provisions of the rule are cost beneficial with present value benefits, at $ 124.2

million , greater than present value costs, at $ 9.8 million

. A lthough the FAA does not have a

1 The final rule provisions address the requirements in sections 216 and 217 of the Act. With the exception of the requirement that all pilots in part 121 operations hold an ATP certificate, the ACT gave the FAA discretion in how it would address those statutory requirements

.

### 6 quantitative estimate of benefits for part 91, subpart K, operators, we believe that the ATP CTP

will sufficiently enhance safety for part 91, subpart K, operators to make the discretionary

provisions of the rule cost

- beneficial for these operators as well. Because of the similarity of

their operations, we believe that part 91 subpart K operators are subject to similar risks as part

135 operators. The lack of identifiable rule

- related accidents reflects the significantly smaller

scope of part 91 subpart K operations co mpared to part 135 operations.

### 7 

## Table 1

— Statutory and Rule Costs and Benefits (2013

- 2032 )

Table 1A

-- Statutory Costs and Benefits

Statute Costs Total Cost ($ mil.) PV Cost ($ mil.) Annualized Cost ($ mil.)

ATP Certificate Requirement

-- Practical & Written Tests $ 29.9 $ 31.1 $ 2.9

ATP Certificate Requirement

-- Eligibility Restrictions $ 6,344.5 $ 2,181.9 $ 206.0



### Part 121 ATP Certificate Requirement $ 6,374.4 $ 2,213.0 $ 208.9

Statute Benefits No Identifiable Accident Benefits



### Table 1B

-- Discretionary (Final Rule) Provision

Costs and Benefits

Discretionary Provision Costs Total Cost ($ mil.) PV Cost ($ mil.) Annualized Cost ($ mil.)

Part 121 Operators $ 280.4 $ 124.6 $ 11.8

Part 135 Operators $ 22.4 $ 9.8 $ 0.9

Part 91, Subpart K, Operators $ 9.8 $ 4.3 $ 0.4



### Total Training/Type Rating Costs $ 312.7 $ 138.7 $ 13.1

Discretionary Provision Safety Benefits Total Benefit ($ mil.) PV Benefits ($ mil.) Annualized Benefits ($ mil.)

Part 121 Safety Benefits $ 292.5 $ 127.5 $ 12.0

Part 135 Safety Benefits $ 284.3 $ 124.2 $ 11.7



### All Safety Benefits $ 576.8 $ 251.7 $ 23.8



### Table 1C

-- Cost Savings Benefits of Final Rule

Final Rule Cost Savings Total Cost Savings ($ mil.) PV Cost Savings ($mil.) Annualized Cost Savings ($ mil.)

Military Academic Training Credit (750 hrs) $ 547.1 $ 188.2 $ 17.8

4

- Year Degree Academic Training Credit (500 hrs) $ 972.0 $ 333.0 $ 31.4

2

- Year Degree Academic Training Credit (250 hrs) $ 490.1 $ 165.8 $ 15.7

Pilots with 1,500 Hrs Flight Time Eligible for Restricted ATP Certificate at Age 21 $ 300.1 $ 102.8 $ 9.7



### Cost Savings from Rule Relief $ 2,309.3 $ 789.8 $ 74.6



### Table 1D

-- Total Statutory and Discretionary (Rule) Costs and

Benefits

Statutory and Discretionary Costs & Benefits Total ($ mil.) Present Value ($mil.) Annualized ($ mil.)

Statutory and Discretionary Costs $ 6,687 $ 2,352 $ 222

Discretionary Safety and Cost Saving Benefits $ 2,886 $ 1,042 $ 98

Notes: 1.Part 121 PV cost of $124.6 million includes $123.1 million in ATP CTP costs and $1.5 million in type rating costs. 2. Details may not add up to totals due to rounding

. 3. Discount rate is 7%

.

### 8 

## II. ACRONYMS USED IN THIS DOCUMENT

A4A

— Airlines for America

ATA

— Airline Transport Association

APD

— Aircrew Program Designee

APO

— Office of Policy and Plans

ATP

— Airline Transport Pilot

ATP CTP

— Airline Transport Pilot Certification Training Program

AVP

— Office of Accident Investigation and Prevention

CRM

— Crew Resource Management

FAA

— Federal Aviation Administration
FOQ

— First Officer Qualifications (Short title for Pilot Certification and Qualification Requirements for Air Carrier Operations)
FOQ ARC

— First Officer Qualifications Aviation Rulemaking Committee

FFS

— Full Flig ht Simulator

FSTD

— Flight Simulation Training Device

FTD

— Flight Training Device

MDA

— Minimum Descent Altitude

M.E.

— Multiengine

NTSB

— National Transportation Safety Board

NPRM

— Notice of Proposed Rulemaking

OST

— Office of the Secretary of Transportation

PIC

— Pilot in command (Captain)

PV

— Present Value

RAA

— Regional Airline Association

SIC

— Second in command (First officer, Co

- Pilot)

VSL

— Value of a Statistical Life

### 9 

## III. BACKGROUND

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

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

Extension Act of 2010. These sections of t he Act had their genesis in the crash of Colgan Air

Flight 3407 that occurred outside of Buffalo, New York, on February 12, 2009, destroying the

airplane, damaging residential homes, and resulting in 50 fatalities. Section 216 of the Act

specifically requires that all pilots in part 121 air carrier operations hold an airline transport pilot

(ATP) certificate by August 2, 2013, regardless of any rulemaking. Prior to this final rule, only a

pilot in command (PIC) in part 121 operations and a second in command (SIC) of flag and

supplemental operations requiring three or more pilots were required to hold an ATP certificate.

Section 216 also requires all pilot flight crewmembers to have an appropriate amount of

multiengine (M.E.) experience as determined by the Administrator.

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

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

to function effectively in a multi

- pilot environment, in an air carrier operational environment, in

adver se weather conditions, and during high altitude operations. This section also requires that

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

Section 217 of the Act also requires that holders of an ATP certificate have suff icient flight

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

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

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

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

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

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

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

Officer Qualification Aviation Rulemaking Committee (FOQ ARC ) , this final rule will require

the following:

1. An ATP certificate for all pilots operating in part 121 . This requirement codifies the

Congressionally

- mandated 1 ,500 hours of flight time required for an ATP

certificate

, but allow s a “restricted privileges” ATP certificate to be held by (a ) military

pilots with 750 hours of flight experience and (b) graduates of 4

- year or 2

- year aviation

degree programs who obtain their commercial pilot certificate with instrument rating

from an associated part 141 pilot school . To be eligible for a restric ted

- privileges ATP

certificate, graduates of a 4

- year program will be required to have 1,000 hours of flight

experience (or 1,250 hours with less than 60 hours , but at least 30 hours of aviation

course credits), while graduates of a 2

- year program will be required to have 1,250 hours

of flight experience (with at least 30 hours of aviation course credits)

.

a. The ATP certificate with restricted privileges will allow a pilot to serve in part

121 air carrier operations as a n SIC only. With a restricted

- privileges ATP

certificate, however, part 121 SICs need hold only a second

- class medical

certificate, not the first

- class medical certificate that is the requireme nt for PICs

.

b. The minimum age for an ATP certificate with restricted privileges will be reduced

to 21 years. The current age requirement for an unrestricted ATP certificate will

remain at 23 years

. 2

2 A pilot with 1,500 hours total flight time will also be eligible for an R

- ATP at age 21.

### 11 2. A minimum of 50 hours of multiengine ( M.E. ) flight experi ence

. This requirement will

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

ATP certificate with an airplane category multiengine class rating. 3 

### This will include

PICs in part 135 air carrier operations that requ ire an ATP certificate, and PICs in part 91,

subpart K, Fractional Ownership Programs , which require the PIC to hold an ATP

certificate. The FOQ ARC also recommended 50 hours of M.E. time

.

3. An ATP CTP for ap plicants for an ATP certificate with an airplane category

multiengine class rating or an ATP certificate obtained concurrently with an

airplane type rating. This is a foundational course that will include academic study as

well as flight training in fligh t simulation training devices (FSTD) to meet the Act’s

requirements that pilots have the training and experience to function effectively in an air

carrier environment . The course will provide training necessary to overcome the

knowledge gap between the c omm ercial pilot certificate and the knowledge required for

an air carrier SIC . And the course will instill competenc ies includ ing crew coordination,

checklist/briefing items, low energy states/stal ls, and adverse weather conditions,

including icing, thunderstorms, and crosswinds with gusts. The course topics will be

incorporated into the ATP knowledge test. 4 

### In addition to applying to all pilots in part 121

operations, this requirement will apply to PICs in part 135 air carrier operations that

require an ATP certificate, and PICs in p art 91, subpart K, Fractional Ownership

3 The rule applies to the airplane class, so applicants for an ATP certificate with an airplane cat egory single

- engine class rating will be required to have 50 hours of single

- engine time. This 50 hours is included in the 1,500 hours total time as a pilot requirement

.

4 We assume that costs to revise the ATP knowledge test will be minimal and that any additional test

- taking time needed to cover the additional topics will be minimal as well.

### 12 Operations, which require the PIC to hold an ATP certificate

. The FOQ ARC made a

similar proposal.

4. An airplane type rating for all SICs serving in part 121 operations. Currently only

PICs in part 121 operations, and SICs in flag or supplemental operations requiring three

or more pilots, are required to hold an airplane type rating. The FAA has determined that

requiring airplane type ratings for all pilots in part 121 operations will i mprove safety by

further exposing pilot s to an advanced multiengine aircraft and a multicrew environment.

Also the provision for an airplane type rating requires a pilot who serves as SIC to be

tested to the same standard as the PIC and to demonstrate prof iciency in difficult

operational conditions, including adverse weather and high altitude operations. The FOQ

AR C made the same recommendation.

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

operations

. Under the final rule, SICs must accumulate 1,000 flight hours in air carrier

operations before becoming eligible for upgrade to PIC. Without the 1,000

- hour

requirement, SICs with an unrestricted ATP certificate would be eligible for upgrade to

PIC immediately , regardless of th eir experience. The 1,000

- hour requirement will ensure

that a pilot will have at least one full year of relevant operational experience before

upgrading to PIC. The final rule allow s a pilot to count P IC time in part 1 35 operations

that require an ATP certificate and in part 91, subpart K, o perations, as well as SIC time

in part 121 operations. Pilots with experience as PICs in military multiengine transport

operations will be allowed count up to 500 hours of such experience as well.

### 13 

## IV. DISCUSSION OF COSTS AND BENEFITS

A. Who is Potentially Affected by this Rule?

The requirements will affect any one seeking an ATP certificate with an airplane category

multiengine class rating or an ATP certificate obtained concurrently with a n airplane type rating

.

Any certificate holders (air carriers, operators, pilot schools, and/or training centers) approved

under part s 121, 135, 141, or 142 will also be affected by the rule if they choose to offer the ATP

CTP

. Finally, any institution of h igher education that chooses to apply to the FAA for

recognition for an aviation degree major will be affected by the rule.

B . Principal Assumptions and Sources of Information

• We use a 20

- year period of analysis in order to more fully account for costs that will

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

monetary values are expressed in 2010 dollars. In calculating present values, we d iscount

back to the end of 2010/beginning of 2011.

• All monetary values are expressed in 2010 dollars. Discount rate is 7 percent (Office of

Management & Budget, Circular A

- 4, “Guidelines and Discount Rates for Benefit

- Cost

Analysis of Federal Programs,” Oc tober 29, 1992, p. 8,

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

• Value of statistical life ( VSL ) begins at $ 8.86 million in 2010 , and increases to $10.7 million

in 2032 by an annual growth factor of 1. 0107

. 5 

### Memorandum: Guidance on Treatment of the

Econ omic Value of a Statistical Life in Department Analyses. [February 2013]. United

States, Office of the Secretary of Transportation.

5 Due to a decline in real income in 2011 and 2012, the growth factors for these years are 0.98246 and 0.99702, respectively. Email from OST, 3

- 7

- 2013

.

### 14 • Number of rule

- related accidents and associated number of fatalities, number of minor &

serious injuries, and aircraft damag e: FAA, Office of Accident Investigation and Prevention

(AVP)

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

Values for FAA Investment and Regulator y Decisions, A Guide, Section 5, Office of

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

The 2008 data is updated from 2008 to 2010 by the GDP implicit price deflator

.



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

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

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

.

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

Forecast: 2010

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

Annual Growth, 2009

- 2030

.

• Cost of ATP CTP and cost of type rating: Estimated from a one

- time 2010 FAA industry

survey and FAA Flight Standards Service

.

• Percentage of part 121 SICs without an ATP certificate (regional = 85 percent; major/cargo =

15 percent) : Estimated from 2010 FAA industry survey.

• Percentage of part 121 SICs without a type rating (regional = 90 percent; major/cargo = 30

percent) : Estimated from 2010 FA A industry survey.

• Typical number of years for upgrade from SIC to PIC (Maj or airlines: 10 years, Regional

airlines : 5 years): Estimated from 2010 FAA industry survey.

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

years): Estimated from 2010 FAA industry survey.

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

.

• Early and medical part 121 pilot retirement rate (0.5%): Email from Kit Darby, Preside nt,

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

• Part 121 pilot retirement rate (3 .6%): Email from Kit Darby, President, KitDarby.com

Aviation Consulting, LLC, Peachtree City, GA, 12/18 /2010.

• Part 135 and part 91, subpart K, retirement rate (3.0%): We used this rate in the FOQ Initial

Regulatory Evaluation (p. 17) and received no comments.

• Flight experience of military pilots leaving th e service: FAA Flight Standards Service

.

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

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

.

• Number of baccalaureates with aviation

- related degrees: Aviation Accreditation Board

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

AL

.



## C

. Overview of Costs and Benefits

As noted above, in the Safety Act of 2010 Congress mandates that all part 121 SICs have an

ATP certificate with at least 1,500 flight hours

. This statutory requirement is self

- executing, viz.

it will take effect whether or not the FAA issues a regulation. We estimate the costs of the ATP

certifica te requirement to be $6.4 billion over 20 years ($2.2 billion in present value), almost all

of which stems from the 1,500

- hour flight time requirement. The statute allows the

Administrator to specify academic training as an offset to the 1,500

- hour flight time requirement

provided the training enhances safety . The rule provides cost savings benefits from its provision

of such academic training credits toward the 1,500

- hour requirement (by means of the R

- ATP)

### 16 and also by its provision allowing pilots with a minimum age of 21 to be eligible for the R

- ATP.

Our estimate of these cost savings are $2.3 billion, with a present value of $0.8 billion.

The final rule requires that all SICs serving in part 121 operations hold a type rating in the

airplane flown and re quires that an ATP CTP be completed by all applicants for an ATP

certificate with an airplane category multiengine class rating or an ATP certificate obtained

concurrently with an airplane type rating. T he costs of the final rule training and airplane type

rating requirements total $ 312.7 million ($ 138.7 million in present value). The expected benefits

from the new training requirements are $ 576.8 million

, with a present value of $ 251.7 million.

F or part 121 o perators the discretionary provisions of the final rule are cost

- beneficial as present

value benefits, at $ 127.5 million, exceed present value costs, at $ 124.6 million. F or part 135

operators present value benefits of the discretionary provisions , at $ 124.2 million , exceed present

value costs, at $ 9. 8 million, A lthough the FAA does not have a quantitative estimate of the

discretionary provisions’ benefits for part 91, subpart K, operators, we believe that the ATP CTP

will sufficiently enhance safety for part 91, subpart K, operators to make the discre tionary

provisions of the rule cost

- beneficial for these operators as well. Because of the similarity of

their operations, we believe that part 91 subpart K operators are subject to similar risks as part

135 operators. The lack of identifiable rule

- related accidents reflects the signif icantly smaller

scope of part 91

, subpart K, operations compared to part 135 operations.

The purpose of this overview is to provide additional detail of the costs and benefits of Table

1 presented above. This is a layered anal ysis because of the nature of the statutory and regulatory

requirements. This overview has three major elements. The first two sections focus on how the

costs attributable to the statutory provision s are derived and the basis for estimating the benefits

### 17 of the cost

- mitigating provisions of the rule follows. The third section provides a fuller

discussion of the costs and benefits from the training and type rating requirements.

Cost and B e nefits of the Statute

The statute requires all pilots serving in part 121 operations to hold an ATP certificate by

August 2, 2013. 6 

### C urrently pilots may become part 121 SICs with a commercial pilot certificate

and 250 hours of flight time. 7 

### Under the new rule SICs will be required to have an ATP

certificate, which requires 1,500 hours of flight time

. As a result the statute reduces pilot

earnings by delaying employment and promotion opportunities in part 121 operations, and, in

addition, shortens the total number of employ ment years as part 121 pilots must retire at age 65.

The cost of the 1,500

- hour requirement is the reduced career earnings resulting from the time

needed to meet the requirement. In a similar way the requirement for an ATP certificate also

reduces the care er earnings of pilots with a commercial pilot’s certificate who are under age 23,

since 23 is the minimum age requirement for the ATP certificate.

Table 1A above shows the costs of the statute that result from the statute’s self

- executing

requirement that all part 121 SICs have an ATP certificate by August 2, 2013. While a complete

discussion of the $6.4 billion cost of the ATP certificate requirement is presented later in this

regulatory analysis, readers initially may be surprised by the costs presented i n line 1 of Table

1A. Typically present values represent a future value which is less than the undiscounted value.

In this case, t he undiscounted “Total Cost” of the ATP certificate testing requirement

(knowledge and practical tests), of $ 29.9 million is l ess than the present value cost, $ 31.1

6 The final rule will require compliance by August 1, 2013.

7 A graduate of a part 141 pilot schoo l or a part 142 training center can obtain a commercial license with as few as 190 hours of flight time.

### 18 million. This is because virtually all part 121 pilots eventually upgrade to PIC, which under the

current rule, requires an ATP certificate. For current pilots without an ATP certificate, this

means there is no change in undiscounted “Total Cost” under the rule

— the cost is simply

incurred earlier under the rule when the pilot enters part 121 operations . But since the cost of the

ATP certificate will occur earlier under the rule, the present value cost of the requiremen t is

positive, reflecting the time value of money. With these results, combined with the results for

new pilots, we obtain the figures in Table 1A. For details see section, “Cost of an ATP

Certificate/Type Rating.”

The FAA reviewed the accidents in the National Transportation Safety Board (NTSB)

accident database over the period 2001

- 2010 and, base d on broad search criteria, found 31

accidents where it appeared that the rule’s training and type rating requirements mi ght have

prevented or mitigated the accident. AVP also attempted to quantify the benefits of the 1,500

-

hour requirement

, but AVP found no relationship between the 1,500

- hour requirement and

airplane accidents

. Only 7 of the 31 accidents used for the part 121 benefit analysis had SICs

with l ess than 1,500 hours and the 7 accidents had other contributing factors , several of which

are being addressed by the rule. In addition, a recent journal article discussing the resul ts of the

2012 Pilot Source Study states that flight hours are not a good predictor of performance. 8 

### As the

ATP certificate requirement is mandated by statute and is self

- executing (will become effective

regardless of whether the FAA issues a rule)

, the c osts associated with this requirement are

attributable to the statute, not the rule ’s discretionary provisions

.

8 A summary of the findings of the 2012 Pilot Source Study was submitted to the rulemaking docket and the results were considered by the FAA during developme nt of the final rule

. The journal article can be found in the Journal of Aviation Technology and Engineering, Vol.II, Issue 2 (2013) at: http://docs.lib.purdue.edu/jate/vol2/iss2/2/

.

### 19 Benefits of the Final Rule (Cost Savings)

The statute allows the Administrator to mitigate the ATP certificate requirement by giving

credit towards flight hours for specific academic training courses. These credits are

operationalized in the rule by the restricted privileges ATP certificate (R

- ATP). The R

- ATP

certificate will allow pilots to obtain an ATP certificate with less than 1,500 hours total flight

time. The restricted privileges ATP certificate will be eligible to the following categories of

pilots: (1) military pilots with a minimum of 750 hours of flight time (a reduction of 750 hours

from t he unrestricted ATP certificate 1,500 hour requirement), (2) graduate s of 4

- year aviation

degree program with a minimum of either 1,000 hours (a 500

- hour reduction) or 1,250 hours (a

250

- hour reduction), depending on the coursework that the student complete s, and (3) graduate s

of 2

- year aviation de gree program s with a minimum of 1,250 hours (a 250

- hour reduction). The

final rule will also mitigate the ATP certificate requirement by allowing pilots with 1,500 hours

total flight time to be eligible for the R

- ATP with a minimum age of 21 years.

We esti mate these credits to reduce total compliance cost of the statute’s 1,500

- hour

requirement by $2.3 billion in total cost over 20 years ($0.8 billion in present value).

Costs and Safety Benefits of the Final Rule

In addition to the statute requirements t he final rul e has several provisions, noted above,

required by the FAA. The final rule will require an airplane type rating for part 121 SICs and

completion of the ATP CTP for pilots seeking an ATP certificate with airplane category and

multieng ine class r ating, or an ATP certificate obtained concurrently with an airplane type rating

.

T he FAA believes that these requirements will improve the knowledge, qualifications, and

### 20 experience of pilots , and, as a consequence, enhance safety by reducing the accident r ate in air

carrier operations.

In Section 16 of the act, the statute requires that all pilots “have appropriate multi

- engine

flight experience, as determined by the Administrator.” Consequently, the final rule will require

all part 121 pilots to have a mi nimum of 50 hours of M.E. time. M.E. hours , however, are

typically acquired while engaged in other commercial aviation activities such as flight instruction

or part 135 operations on the way to obtaining the ATP certificate. Moreover, minimums for

M.E. tim e vary among airlines from 50 hours to as much as 1,500 hours. 9 

### Therefore, we estimate

that cost will be minimal for the requirement of 50 hours of M.E. time for applicants for the ATP

certificate

.

The final rule also will require that a pilot have 1,000 h ours of air carrier operating

experience prior to serving as a part 121 PIC. According to a 2010 survey of industry, 10 

### the

average number of years for an SIC to upgrade to a PIC is about five years for operators that use

regional jet airplanes and/or turbo propeller airplanes (hereafter referred to as regional airlines)

and more than ten years for major airlines. Even without air carrier operating experience in part

135 or part 91, subpart K

, operations, at an average rate of 750 flight hours a year as an SI C in

part 121 operations

, a pilot will accumu late the required hours in 1 1/2 years. Therefore, we also

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

operating experience prior to serving as a part 121 PIC. W e received no comments to the NPRM

on this estimate.

9 Kit Darby, President, KitDarby.com Aviation Cons ulting, LLC, Peachtree City, GA.

10 Due to the expedited nature of this rule, questionnaires were sent to the Air Transport Association (ATA) and the Regional Airlines Association (RAA), who, in turn, distributed the questionnaire to selected members. Five responses were received from the major airlines and three from the regional airlines.

### 21 Accordingly, the costs of the discretionary provisions of the final rule are based on the costs

of two requirements

— the airplane type rating requirement for part 121 SICs and the ATP CTP

requirement for applicants for the ATP certificate with an airplane cat egory multiengine class

rating (part 121, part 135, and part 91, subpart K, PICs required to hold an ATP certificate).

Table 1B shows total (undiscounted) costs of these requirements to be $ 312.7 milli on

($ 138.7 million in present value). Table 1C shows the expected safety benefits of the final rule

.

The safety benefits of the rule are greater than the costs, with present value benefits of $ 251.7

million greater than present value costs of $ 138.7 million

.

In comparing costs and benefits, however, we must consider part 121 operations separately

since they differ considerably from part 135 operations and part 91, subpart K, operations.

Moreover, all of the cost drivers apply to part 121 operators, while ju st the cost of the ATP CTP

applies to those PICs required by rule to hold an ATP certificate in part 135 and part 91, subpart

K, operat ion s.

As tables 1B and 1C show , for part 121 o perators the discretionary provisions of the final

rule are cost

- beneficia l since present value safety benefits, at $ 127.5 million, are greater than

present value costs, at $ 124.6 million. For part 135 operators present value benefits are $ 124.2

million, w hile present value costs are just $ 9.8 million.

There have been six part 91

, subpart K

, accidents over the period 2008

- 2012, but only two

were M.E. accidents and neither of these were rule related. Accordingly, we do not have a

quantitative estimate of safety benefits for part 91

, subpart K

, operators as we do for part 121 and

part 135 operators. The FAA believes, however, that the discretionary provisions of the rule are

cost

- beneficial for part 91

, subpart K

, operators for the following reasons.

### 22 Seven of the nine part 91

, subpart K

, operators also have extensive part 135 oper ations that

are significantly integrated with their part 91

, subpart K

, operations, with many of their pilots

and airplanes being used in both types of operations. (Just two small part 91

, subpart K

,

operators with less than 5% of the part 91

, subpart K

, S ICs do not also have part 135 operations.)

Moreover, the part 91

, subpart K

, operational rules were modeled after the part 135 on

- demand

operational rules because of the similarity in operations. We believe this integration and

similarity of operations sho ws part 91

, subpart K

, operations to be subject to risks similar to

those faced by part 135 operations.

Fractional ownership programs were not regulated under part 91

, subpart K

, until 2003 with

management specifications not required until 2005. Therefore , 2005 is likely the first year an

accident would have been coded by the FAA as a part 91

, subpart K

, accident. Moreover, AVP

reports it is possible that the part 91 , subpart K

, coding field for accidents was not used until

2008. Thus it was not possible t o have a part 91

, subpart K

, accident in the two years, 2001

-

2002, but there may well \ have been part 91

, subpart K

, accidents in the five years, 2003

- 2007,

that simply were not coded as such. We should also expect significantly fewer part 91

, subpart

K

, ac cidents relative to part 135 accidents because there are significantly fewer part 91

, subpart

K

, operations than part 135 operations.

For these reasons

, the FAA is confident that the rule will sufficiently enhance safety for part

91

, subpart K

, operators t o make the rule ’s discretionary provisions cost

- beneficial for these

operators, particularly given the provisions’ high benefit

- cost ratio for part 135 operators.

### 23 D. Costs and Cost Savings of the Final Rule

As discussed above, we estimate costs to be minimal for the requirement that holders of the

ATP certificate have 50 hours of M.E. time and the requirement that a pilot have 1,000 hours of

air carrier experience prior to serving as PIC in part 121 operations. In this section, we estimate

the costs of the three remaining provisions of the rule

— the ATP CTP, the type rating

requirement for part 121 SICs, and the ATP certification requirement. As already noted, we

attribute the latter requirement to the statute, not the rule, sinc e the requirement is mandated by

the statute and is self

- executing. However, we estimate those statute costs here in order to

estimate the cost savings benefits from the flight hour credit s for academic training courses

allowed by the rule

, and to provide an estimate of the cost of requiring an ATP certificate for all

pilots in part 121 operations.

.

Cost of ATP Certification Training Program

The requirement for the ATP CTP applies to all applicants for an ATP certificate with an

airplane category multieng ine class rating who take the knowledge test after July 31, 2014

. This

is a one

- year delay in the compliance deadline proposed in the NPRM. Accordingly, the ATP

CTP will apply to all pilots in part 121 operations, as well as those PICs required to hold an ATP

certificate by rule in part 135 air carrier operations and part 91, subpart K, Fractional Ownership

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

category multien gine class rating are (1) commuter operations using multiengine airplanes with

nine or fewer passenger seats (“Scheduled 135”) and (2) on

- demand operations ( using

multiengine airplanes with 10 or more passenger seats or turbojets )

. In part 91, subpart K, P ICs

of M.E. turbine

- powered fixed

- wing airplanes are required to hold an ATP certificate.

### 24 As discussed below in the section, “Cost of the ATP Certificate Requirement (Eligibility

Restrictions) under the Statute,” the typical air carrier pilot starts out at a regional air carrier

before progressing to a major air carrier. Accordingly, t he FAA expects that the ATP CTP will

likely be a 7

- day program , typically conducted by a regional air carrier or at a part 142 training

center just prior to initial pilot trai ning. The FAA expects the course requirements will

necessitate four days of ground school and three days of flight training

— one day with a flight

training device ( FTD ) and two days with a Class C or D full flight simulator (FFS)

. 11

11 Each flight training day consists of one FSTD training period.

### 25 

## Table 2. Cost Factors for ATP Certification Training Program ($ 2010)

Cost Factor Rate Period

Ground school

– Classroom $ 425 per day

Ground school

– Instructor $ 3 2 per hour

Simulator instructor $ 72 per hour

Class C or D FFS $ 5 00 per hour

FTD $ 2 00 per hour

SIC first year pay rate $ 2,544 per month

Travel costs (to part 142 training ctrs) $ 273 per roundtrip

Hotel $ 90 per day

Per diem $ 45 per day

Note: Table figures are rounded to nearest dollar.



### Table 2 shows FAA estimated cost factors for the ATP CTP and Table 3 shows FAA estimates

of total cost per pilot. Instructor and SIC pay rates (to measure the opportunity cost of new hires

below) are for regional air carriers as we assume the ATP CTP will be provided by regional

airlines (or by part 142 training centers with similar costs). Simulator instructor cost reflects

regional airline pilot pay 12 

### (assuming 50% captains, 50% first officers ). G round school instructor

and p ilot pay (simulator instructors and SICs ) includes benefits of 27.4%. 13



### Travel costs require some explanation. Roundtrip airfare to a training center is estimated as

$336.09, the price of an average domestic flight in 2010. 14 

### Car fare is estimated as 40

- mile

roundtrip times an estimated cost per mile for 2010 of 50 cents, 15 

### for a cost of $20. We assume

12 www.airlinep ilotcentral. com, 2008 survey. See section " Cost of ATP Certificate Requirement (Eligibility
Restrictions) under the Statute" for details.

13 See section "Cost of ATP Certificate Requirement (Eligibility Restrictions) under the Statute" for details.

14 w ww.bts.gov, Dropdown menu "Data and Statistics, " Quick Links

— “Air Fares,” “National Level Fares Since

1995.”

15 www.irs.gov/Tax

- Professionals/Standard

- Mileage

- Rates

### 26 80 percent of pilots traveling to part 142 training centers will travel by air and 20 percent by

car, 16 

### so average roundtrip travel c osts to a training center are estimated as 0.80 x $336.09 + 0.20

x $20 = $272.87. (Figures in all tables are round ed to the nearest dollar.) The value of travel time

is accounted for in the Opportunity Costs of Training for New Hires shown in Table 3 becau se

there is sufficient time for the pilot to travel to and from the training site within the 7

- day

training period.

Hotel and per diem costs approximate the corresponding figures ($92, $44) used in the

Regulatory Evaluation: Qualifications, Service and Use of Crewmembers and Aircraft

Dispatchers

-- Supplemental Notice of Public Rulemaking, March, 2010, p. 29. We initially

assumed training would involve 7 hotel nights. It is more likely that the training can be

accomplished such that only 6 overnights are requ ired. For the purposes of this analysis, we have

retained the 7

- night estimate in order to provide a conservative estimate of hotel costs. Even

under this scenario, the rule remains cost beneficial. No comments were received on our NPRM

estimates or on the afore

- mentioned SNPRM estimates.

The assumed cost of $500 per hour to rent a FFS takes into account that the ATP CTP , as it

will cover general subject areas, does not require a pilot to receive the flight training in any

specific FFS, as long as it replicates an aircraft over 40,000 lbs. Therefore there is a greater

available supply of FFSs to provide the training. We received no comments to the NPRM on this

estimate.

In Table 3 we use the data summarized in Table 2 to calculate the cost per pilot of the ATP

CTP. Ground school classroom and instructor costs reflect an assumed class size of 20 pilots.

16 As estimated in the Regulatory Eval ua tion: Qualifications, Service and Use of Crewmembers and Aircraft Dispatchers

-- Supplemental Notice of Public Rulemaking, March, 2010 , p. 29.) No comments were received on our

NPRM estimates or on these SNPRM estimates.

### 27 Classroom cost per pilot is then calculated as (425 x 4)/20 = $85 and similarly for ground school

instructor cost per pilot. Typically two pilots train c oncurrently in a simulator and this is

reflected in our estimates of simulator cost and simulator instructor cost per pilot. The simulator

instructor is paid for one 4

- hour event (FTD training), two 3

- hour events (FFS training), and an

additional brief/deb rief hour per event for a total of 13 hours, the cost of which is split between

two pilots for an amount of (13 x $72.19)/2 = $469.24. The two FFS 3

- hour events are split

between two pilots for an amount of ($500 x 6)/2 = $1,500, and, similarly, for FTD co sts. The

opportunity cost of training time for new hires is the seven day delay in receiving a n SIC ’s pay

(and delay in producing as a n SIC)

. We calculate t his opportunity cost by the first

- year SIC’s

monthly pay prorated by the factor, 7/30, assuming a 30

- day month. As the FAA anticipates that

the ATP CTP will take place just prior to initial pilot training, there will be no incremental travel

costs for pilots trained by air carriers. There will be travel costs for pilots training at part 142

training cent ers. As we assume 50 percent of pilots will train with regional air carriers and 50

percent at part 142 training centers, 17 

### we multiply the travel costs of $272.87 by 0.50 to obtain an

expected average cost per pilot of $136 . Although regional airlines gene rally

17 Estimate based on data from industry and FAA Flight Standards Service

.

.

### 28 

## Table 3. Cost per Pilot for ATP Certification Training Program ($ 2010)

Item Item Cost

Ground school : Classroom (4 days) $ 85

Ground school: I nstructor ( 4 days [30 hours] ) $ 4 8

Simulator instructor ( one 4

- hr event, two 3

- hr events, 1 brief/debrief hr per event ) $ 469

Class C or D FFS (two 3

- hr events, 2 pilots ) $ 1.500

F T D (one 4

- hr event, 2 pilots ) $ 4 00

Opportunity Cost of Training Time for New Hires (7 days) $ 594

Travel costs for travel to part 142 training centers $ 136

Hotel (7 days) $ 630

Per diem (7 days) $ 315

Total Cost per Pilot $ 4,177

Note : Table 3 details may not perfectly reflect Table 2 cost factors due to rounding.



### do not pay per diem for new hires, we include an estimate for per diem, as per diem costs are

social costs whether paid by the airlines or by the pilots themselves.

Using the cost per pilot of the ATP CTP from Table 3, we estimate the program’s cost over

the per iod, 2014

- 2032 for new part 121, part 135 , and part 91, subpart K pilots requiring an ATP

certificate

. Benefits begin to accrue in 2014 because , as already noted, under the final rule t he

requirement for the ATP CTP applies only to applicants for an ATP ce rtificate with an airplane

category multiengine class rating who take the knowledge test after July 31, 2014. 18 

### As shown in

Table 4 below, we estimate t he annual number of new part 121

, part 135, and part 91, subpart K,

by summing the annual change in forec ast pilot numbers with the estimated number of retiring

pilots for each of the three pilot categories

. We estimate the number of part 121, part 135, and

18 Applicants who take the knowledge test on or before July 31, 2014, have until August, 1, 2016, to take the practical test without being required to take the ATP CTP. We are somewhat conservative in overestimating cost in 2014, 2015, and 2016 by not accounting for applicants who avoid the ATP CTP by taking the knowledge test earlier than they otherwise would have.

### 29 part 91, subpart K, pilots to grow at the FAA’s forecast rate of 0.6 percent, 19 

### but with a higher

retire ment rate, 3.6 percent, 20 

### for part 121 pilots than for part 135 and part 91, subpart K, pilots,

which we assume to be 3.0 percent. We assume a higher retirement rate for part 121 pilots as

they are required to retire at age 65. We estimate the number of ret iring part 121, part 135, or

part 91, subpart K, pilots in any year by multiplying the retirement rate by the number of pilots in

the previous year. 21 

### The number of new pilots in any operations category (part 121, part 135, or

part 91, subpart K) in any yea r is then the sum of the change in the number of pilots from the

previous year plus the number of retiring pilots. The annual cost of the ATP CTP for any

category is then the number of new pilots in that category times the $4, 177 program cost per

pilot.

The resulting calculations by year are summed to obtain the figures in the “Total Cost of

ATP Certification Program” column

. As the table shows, we estimate the total cost of the ATP

Certification Training Program over the period, 201 4

- 2032, to be $ 312.7 million ( present value

$ 13 7.2 million ).

19 U.S. DOT, FAA, Aviation Policy & Plans. FAA Aerospac e Forecast: 2010

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

- 20

.

20 Email from Kit Darby, President, KitDarby.com Aviation Consulting, LLC, Peachtree City, GA, dated

12/20/2010.

21 Alternatively, once the number of retiring pilots is calculated for 2011 using the number of pilots for 2010 , the number for subsequent years can be calculated using the 0.6% pilot growth rate.

### 30 Table 4. Cost of ATP Certification Training Program , 2014

- 2032 ($ 2010 )

Year No. of

Part

121

Pilots Retiring

Part

121

Pilots No. of

New

Part

121

Pilots Part 121 Cost

of ATP Cert.

Program ($ mil.) No.

of

Part

135

ATP

Pilots Retiring

Part

135

Pilots No. of

New

Part 135

ATP

Pilots Part 135

Cost of ATP

Cert.
Program ($ mil.) No. of
Part 91,
subpart

K,

Pilots Retiring
Part 91,
subpart

K,

Pilots No. of

New Part 91,
subpart

K,

Pilots Part 91, subpart K,

Cost of ATP Cert. Pgm

($ mil.) Total Cost of

ATP Cert. Program PV Cost of ATP Cert. Program

2011 78,728 2,817 7,339 219 3,222 96

2012 79,200 2,834 7,383 220 3,242 97

2013 79,675 2,851 7,427 221 3,261 97

2014 80,153 2,868 3,346 $ 14.0 7,472 223 267 $ 1.1 3,281 98 117 $ 0.49 $ 15.6 $ 11.9

2015 80,634 2,886 3,366 $ 14.1 7,516 224 269 $ 1.1 3,300 98 118 $ 0.49 $ 15.7 $ 11.2

2016 81,118 2,903 3,387 $ 14.1 7,562 225 271 $ 1.1 3,320 99 119 $ 0.50 $ 15.8 $ 10.5

2017 81,605 2,920 3,407 $ 14.2 7,607 227 272 $ 1.1 3,340 100 120 $ 0.50 $ 15.9 $ 9.9

2018 82,094 2,938 3,427 $ 14.3 7,653 228 274 $ 1.1 3,360 100 120 $ 0.50 $ 16.0 $ 9.3

2019 82,587 2,955 3,448 $ 14.4 7,699 230 275 $ 1.2 3,380 101 121 $ 0.51 $ 16.1 $ 8.7

2020 83,082 2,973 3,469 $ 14.5 7,745 231 277 $ 1.2 3,400 101 122 $ 0.51 $ 16.2 $ 8.2

2021 83,581 2,991 3,489 $ 14.6 7,791 232 279 $ 1.2 3,421 102 122 $ 0.51 $ 16.3 $ 7.7

2022 84,082 3,009 3,510 $ 14.7 7,838 234 280 $ 1.2 3,441 103 123 $ 0.51 $ 16.3 $ 7.3

2023 84,587 3,027 3,531 $ 14.8 7,885 235 282 $ 1.2 3,462 103 124 $ 0.52 $ 16.4 $ 6.8

2024 85,094 3,045 3,553 $ 14.8 7,932 237 284 $ 1.2 3,483 104 125 $ 0.52 $ 16.5 $ 6.4

2025 85,605 3,063 3,574 $ 14.9 7,980 238 286 $ 1.2 3,504 104 125 $ 0.52 $ 16.6 $ 6.0

2026 86,118 3,082 3,595 $ 15.0 8,028 239 287 $ 1.2 3,525 105 126 $ 0.53 $ 16.7 $ 5.7

2027 86,635 3,100 3,617 $ 15.1 8,076 241 289 $ 1.2 3,546 106 127 $ 0.53 $ 16.8 $ 5.3

2028 87,155 3,119 3,639 $ 15.2 8,124 242 291 $ 1.2 3,567 106 128 $ 0.53 $ 16.9 $ 5.0

2029 87,678 3,138 3,661 $ 15.3 8,173 244 292 $ 1.2 3,589 107 128 $ 0.54 $ 17.0 $ 4.7

2030 88,204 3,156 3,682 $ 15.4 8,222 245 294 $ 1.2 3,610 108 129 $ 0.54 $ 17.2 $ 4.4

2031 88,733 3,175 3,705 $ 15.5 8,271 247 296 $ 1.2 3,632 108 130 $ 0.54 $ 17.3 $ 4.2

2032 89,266 3,194 3,727 $ 15.6 8,321 248 298 $ 1.2 3,654 109 131 $ 0.55 $ 17.4 $ 3.9

Total s , 2013

- 2032 57,543 67,134 $ 280.4 4, 470 5,364 $ 22.4 1,963 2, 355 $ 9.8 $ 312.7 $ 1 37.2

Note: Details may not add up to totals due to rounding.

### 31 Cost of an ATP Certificate/Airplane Type Rating

The final rule requires that all pilots hired after July 31, 2013, in part 121 must have an

airplane type rating for the aircraft flown. For those SICs employed in part 121 operations as of

August 1, 2013, the final rule requires they hold an airplane type rating for the aircraft flown by

January 1, 2016, a change from the NPRM’s deadline of August 1, 2013

. For currently employed

pilots, this change will allow air carriers to take advantage of recurrent training cycles (as

assumed in our cost estimates) ins tead of adding additional training events. The ATP practical

test standards are the same standards used for an airplane type rating, meaning a pilot who

completes an ATP certification event in a type

- rated aircraft will receive an ATP certificate with

that airplane type rating. This section details the ATP certificate costs 22 

### by first calculating the

cost per pilot and then using cost per pilot to derive costs for new pilots over the period 2013 to

2032 and for current SICs without an ATP certificate or airp lane type rating.

As will be shown, the estimated ATP certificate cost is $29.5 million, with present value

$30.9 million. While that cost is not insignificant, this cost is attributable to the statute. Lastly,

the type rating present value cost of $1.5 mi llion is discussed.

Given the statute’s requirement for an ATP certificate, the incremental cost of the rule’s

requirement for an airplane type rating is zero for pilots who must obtain an ATP certificate.

Some current SICs, however, already hold the ATP c ertificate but do not hold an airplane type

rating for the aircraft flown. For these pilots, there will be an incremental cost of adding an

airplane type rating to their ATP certificates. 23 

### Because of their close relationship, in this section

we estimate AT P certificate and airplane type rating testing costs together, although we bear in

22 The costs of the ATP eligibility restrictions are discussed in a later section.

23 Very few pilots hold a type rating in the airplane flown without also holding the ATP certificate.

### 32 mind that the costs of the ATP certificate are attributable to the statute. Only the incremental

costs of the airplane type rating are attributable to the ru le ’s discretiona ry requirements

. 24 

### Tab le

5 below shows the cost factors for the ATP certificate and airplane type rating:



## Table 5. Cost Factors for an ATP Certificate/ Airplane type rating ($ 2010)

Cost Factor s for ATP Certificate/Type Rating Rate Unit

Ground school

— Classroom $ 425 per day

Ground school

— I nstructor $ 3 2 per hour

Simulator instructor

— Part 121 regional airlines $ 72 per hour

Check pilot

— Part 121 regional airlines $ 1 09 per hour

Aircrew Program Designee (APD)

— Part 121 regional airlines $ 1 24 per hour

Simulator instructor

— All airlines (Average pilot pay) $ 1 52 per hour

Check pilot

— Part 121 major/cargo airlines $ 204 per hour

Aircrew Program Designee (APD)

— All airlines $ 220 per hour

Class C or D FFS $ 2,000 4

- hr event

Current SIC s, regional airlines

— Estimated average pay, first year $

2,544 per month

Current SIC s, regional airlines

— Estimated average pay, first 5 years $ 39 per hour

Current SIC s, major/cargo airlines

— Estimated average pay, first 5 years $ 113 per hour

Hotel $ 90 per day

Per diem $ 45 per day

ATP written test $ 150 per test

Note: Table figures are rounded to nearest dollar.



### For s imulator instructor and SIC pay estimates we use data from www.airlinepilotcentral.com

,

2008 survey. See section, " Cost of ATP Certificate 1,500

- Hour Requirement, " for details. Based

on industry and FAA Air Carrier Training Branch (AFS

- 210) data, we estimate that 50 percent of

simulator instructors are captains and 50 percent are first officers. Aircrew Program Designees

(APDs) are authorized by the FAA to conduct practical tests for the ATP certificate and airplane

type ratings. APDs are c aptains that are paid at th e rate for the largest airplane for which their

24 Far more costly for the statute, however, is the requirement that an applicant for an ATP certificate have a minimum of 1,500 hours of flight time. A lat er section entitled, “Cost of the ATP 1,500

- hour Requirement”, will
show the ATP 1,500

- hour requirement to be orders of magnitude more costly than ATP certificate and type rating testing costs.

### 33 seniority qualifies them. Based on data obtained from industry, for major/cargo airlines w e

estimate that rate to be the rate for the 767

- 400/A330 for major/cargo airlines (Delta), and, for

the regional airli nes , the CRJ

- 900 and

- 700 (Mesa) and the DH C

- 8

- 300 (Piedmont). See section,

" Cost of ATP Certificate 1,500

- Hour Requirement ." Check pilot and APD pay rates for all

airlines are calculated as weighted averages of part 121 regional airline and major/cargo airline

APD pay rates (regional airlines

— 26.3 percent of pilots, major/cargo airlines

— 73.7 percent of

pilots). As an estimate of the pay of regional and major/cargo airline SICs without an ATP

certificate/type rating, we ca lculate the average pay of regional airline and major/cargo airline

SICs for the first 5 years of employment at an airline. See section, " Cost of ATP Certificate

1,500

- Hour Requirement ." The remaining cost factors are from T able 2 and are straightforward.

The Table 5 cost factors are now used to estimate the cost of the ATP certificate/airplane

type rating per pilot, which will allow us to estimate the cost for all affected pilots. As cost

estimation per pilot and cost overall differ considerably between cu rrent and new SICs, we

separately estimate costs for these groups.

Cost of ATP Certificate/Airplane type rating per Pilot

— New Pilots

The FAA believes that the ATP practical test/airplane type rating for new pilots will be

conducted at the conclusion of in itial training, so that the cost of the ATP certificate/airplane

type rating for new pilots will be incremental to the initial training costs. 25 

### Table 6 below shows

cost estimates per pilot for new pilots:

25 ATP written test

— Industry data reported by email from the F AA Flight Standards Service, 12/11/2010. No

comment was received on this estimate in the NPRM

### 34 

## Table 6. Incremental Cost of an ATP Certificate/Aircraft Type Rating p er Pilot for New Pilots ($ 2010)

Item Item Cost 

### Class C or D FFS (4

- hr event, 2 pilots) $ 1,000
Simulator instructor for flight training (4

- hr event, 1 hr brief/debrief time, 2 pilots) $ 180
Incremental cost of type rating/ATP "Check ride" (Incremental cost
of APD) (1 pilot) $ 73
Opportunity Cost of Training Time (1 day) $ 85
Hotel (negotiated rate) (1 day) $ 90

Per diem $ 45

ATP written test $ 150

Total Cost $ 1,6 2 3

Note: Details may not add to Total Cost due to rounding.



### As the FAA anticipates that the ATP practical test/ airplane type rating for new pilots will be

conducted at the conclusion of initial pilot tra ining, there will be no incremental travel costs. As

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

hours of simulator training to be prepared to take the practical test for the airplane type rating

.

The type rating evaluation event (check ride) qualifies as the practical test for the ATP

certificate

, so the pilots will qualify for both the airplane type rating and an ATP certificate

simultaneously. Since a n evaluation event is already required during init ial training, the

incremental cost for the ATP certificate/type rating evaluation event is just the incremental salary

and benefits of the APD required to conduct an ATP practical test or airplane type rating

,

compared to a check pilot, viz. the estimated Table 5 differential between an APD and a check

pilot: $123.52

- $108.91 = $14.61, multiplied x 5 hours = $73.05. The opportunity cost of one

day’s training time we estimate by a first

- year SIC’s monthly pay prorated by the factor 1/30,

assum ing a 30

- day m onth.

### 35 Cost of ATP Certificate/ Airplane type rating per Pilot

-- Current SICs

The FAA believes that the ATP practical test/airplane type rating for current SICs will be

conducted most efficiently at the conclusion of recurrent training, so that the cost wi ll be

incremental to the cost of recurrent training. Accordingly, there will be no travel costs. Table 7

below shows our cost estimates per pilot for current SICs

.

Table 7. Incremental Cost of an ATP Certificate/ Airplane Type R ating per Pilot for

Current Pilots ($ 2010)

Item Item Cost

Ground school

— Classroom (2 days) $ 42.50

Ground school

-- I nstructor (2 days) $ 2 5

Level C or D simulator for flight training (Two 4

- h r events, 2 pilots ) $ 2,000

Simulato r instructor (Two 4

- hr events, 1 hour brief/debrief time per event, 2 pilots ) $ 762

Incremental cost of Level C or D simulator for "Check ride" for type rating/ATP (4

- hr event) $ 1,000

Incremental cost of type rating/ATP "Check ride" (Incremental cost of APD) $ 80

Hotel (4 days) $ 360

Per diem (4 days) $ 180

Pilot pay (four 4

- hr negotiated "training days")

— ATP Certificate $ 1,030

Pilot pay (four 4

- hr negotiated "training days")

— Type rating $ 1,212

Total

— ATP Certificate $ 5, 48 0

Total

— Type Rating $ 5, 662

Note: Due to rounding, details may not add up to totals and minor inconsistencies may occur between tables

7 and 5.



### As both regional and major/cargo airlines have SICs that will have to obtain ATP certificates and

type ratings, we use the “all airlines” instructor cost from Table 5 for this section. The simulator

instructor is paid for two 4

- hour events and an additional brief/debrief hour per event for a total

of 10 hours, the cost of which is split between two pilots for an amount of (10 x $152.40)/2 =

$762. As noted in the table, the FAA estimates that current SICs will need 16 hours of ground

school training and 4 hours of simulator training to be prepared for the ATP certificate/airplane

typ e rating . The recurrent training evaluation event is typically done with two pilots

concurrently, whereas the ATP certificate/airplane type rating evaluation event is conducted with

### 36 one pilot, so the incremental cost of a 4

- hour simulator is $2,000 (Simula tor cost of ATP

certificate/type rating check ride)

- $1,000 (Simulator cost of recurrent training check ride) =

$1,000. There is an additional incremental cost of the pay for the APD required to conduct the

evaluation for the ATP certificate/airplane type rating , compared to a check pilot, viz. the

estimated Table 5 pay differential between an APD and a check pilot: $220

- $204 = $16,

multiplied x 5 hours = $80.

We estimate average pilot pay for pilots without ATP certificates /type ratings using weighted

averages of regional airline pay rates and major/cargo airline pay rates . About 2 5 percent of SICs

are at regional airlines and 75 percent at major/ cargo airlines. Eighty

- five percent of SICs at

regional airline s do not have an ATP certificate an d 90 percent of these SICs do not have a type

rating, with corresponding figures for major and cargo airlines of 15 percent and 30 percent

. We

received no comments to the NPRM on these estimates of the number of SICs without an ATP

certificate or without a n airplane type rating. Using the appropriate pay rates from Table 5, the

average hourly pilot pay for SICs without an ATP certificate is calculated as follows:

[($38.98 x 0.85 x 0.2523) + ($112.96 x 0.15 x 0.7477)]/[(0.85 x 0.2523) + (0.15 x 0.7477)] =

$6 4.38, which multiplied by 16 “training day” hours equals $1030, as shown in Table 7. A

similar calculation is made for SICs without a type rating to obtain total pilot pay of $1,212.

Other cost estimates have been discussed previously. The cost estimate does not include a

charge for the ATP written exam as we estimate the number of current SICs without the ATP

written test to be minimal. We received no comments to the NPRM on this estimate.

### 37 Cost of ATP Certificate/ Airplane type rating for New Part 121 Pilots, 2013

- 2032

We use the estimates of cost per pilot for new part 121 pilots to calculate the total cost and

present value cost for the estimation period, 2013

- 2032

. These estimates are shown in Table 8

.

### 38 

## Table 8. Cost of an ATP Certi ficate/ Airplane Type R ating for New Part 121 Pilots, 2013

- 2032 ($ 2010)

Year Number

of Part

121

Pilots Number

of Retiring

Pilots Number

of New

Pilots Total Cost of ATP/Type

Rating

Post

- Statute Total Cost

of ATP/Type

Rating

Pre

- Statute Incremental ATP/Type Rating Cost

of Statute PV Cost of ATP/Type

Rating

2011 78,728 2,817

2012 79,200 2,834

2013 79,675 2,851 3,326 $ 5,399,867 $

- $ 5,399,867 $ 4,407,900

2014 80,153 2,868 3,346 $ 5,432,266 $

- $ 5,432,266 $ 4,144,250

2015 80,634 2,886 3,366 $ 5,464,860 $

- $ 5,464,860 $ 3,896,369

2016 81,118 2,903 3,387 $ 5,497,649 $

- $ 5,497,649 $ 3,663,316

2017 81,605 2,920 3,407 $ 5,530,635 $

- $ 5,530,635 $ 3,444,201

2018 82,094 2,938 3,427 $ 5,563,819 $ 5,399,867 $ 163,952 $ 95,421

2019 82,587 2,955 3,448 $ 5,597,201 $ 5,432,266 $ 164,935 $ 89,714

2020 83,082 2,973 3,469 $ 5,630,785 $ 5,464,860 $ 165,925 $ 84,348

2021 83,581 2,991 3,489 $ 5,664,569 $ 5,497,649 $ 166,921 $ 79,303

2022 84,082 3,009 3,510 $ 5,698,557 $ 5,530,635 $ 167,922 $ 74,559

2023 84,587 3,027 3,531 $ 5,732,748 $ 5,563,819 $ 168,930 $ 70,100

2024 85,094 3,045 3,553 $ 5,767,145 $ 5,597,201 $ 169,943 $ 65,907

2025 85,605 3,063 3,574 $ 5,801,747 $ 5,630,785 $ 170,963 $ 61,965

2026 86,118 3,082 3,595 $ 5,836,558 $ 5,664,569 $ 171,989 $ 58,258

2027 86,635 3,100 3,617 $ 5,871,577 $ 5,698,557 $ 173,021 $ 54,774

2028 87,155 3,119 3,639 $ 5,906,807 $ 5,732,748 $ 174,059 $ 51,498

2029 87,678 3,138 3,661 $ 5,942,248 $ 5,767,145 $ 175,103 $ 48,417

2030 88,204 3,156 3,682 $ 5,977,901 $ 5,801,747 $ 176,154 $ 45,521

2031 88,733 3,175 3,705 $ 6,013,769 $ 5,836,558 $ 177,211 $ 42,799

2032 89,266 3,194 3,727 $ 6,049,851 $ 5,871,577 $ 178,274 $ 40,239

Total 60,394 70,460 $ 114,380,558 $ 84,489,982 $ 29,890,575 $ 20,518,859

Note: Due to rounding, details may not add up to totals or multiply to products.



### As in Table 4, the number of part 121 pilots is estimated to grow at the FAA’s forecast rate

of 0.6 percent and the “Number of Retiring Pilots” is calculated by multiplying the number of

previous year pilots by an estimated retirement rate of 3.6 percent. The “Number of New Part

121 Pilots” is then calculated as the annual change in the “Number of Part 121 Pilots” plus the

change in the “Number of Retiring Pilots” (to account for replacement pilots). The “Number of

### 39 New Pilots” is then multiplied by $1,603, the estimated cost of an ATP certificate for new pilots

(from Table 6), to yield the subsequent column, “Total Cost of ATP/Type Rating Post

- Statute.”

However, we need to determine the incremental cost of the statute, which requires us first to

derive the n ext column, “Total Cost of ATP/Type Rating Pre

- Statute.” Under current rules and

practice, virtually all part 121 pilots eventually upgrade to PIC, a position for which an ATP

certificate and an airplane type rating are required. On average upgrade typical ly occurs 5 years

into a pilot’s career at a regional airline. Under the final rule, a new part 121 pilot will be

required to have an ATP certificate (by statute) and an airplane type rating (by rule) at the

beginning of his or her career as SIC. Consequen tly, annual pre

- statute total cost is shown simply

by shifting post

- statute cost backward by five years. 26 

### That results in zero pre

- statute cost for the

years 2013

- 2017. But the 2013 $ 5

. 400 million ATP certificate cost for 3,326 pilots, which will

occur as a result of the statute, under the current rule will occur 5 years later anyway as a

consequence of pilot upgrade. Therefore that $ 5

. 400 million post

- statute cost for 2013 is also the

pre

- statute cost for 2018, the $5

. 432 million post

- statute cost for 2014 is also the pre

- statute cost

for 2019, etc. Because of the zero pre

- statute cost for the years 2013

- 2017, the “Incremental

ATP/Type Rating Cost of Statute” is large for these years, but much smaller from 2018 onwards

when significant type rating costs wou ld occur even in the absence of the statutory requirement.

As Table 8 shows, for new pilots the incremental ATP certificate/type rating costs

attributable to the statute is $29. 9 million, with present value $20. 5 million. 27

26 Alternatively, we can first calculate the pre

- statute cost and then derive the post

- statute cost by shifting pre

- statute cost forward by five years.

27 The FAA believes that a small percentage of new SICs (less than 5%) may leave part 121 operations prior to upgrading to PIC. By not taking this potential attrition into account, the FAA’s cost estimate for a n ATP

certificate/ type rating is minimally understated. A similar under estimation is made in the analysis for existing SICs who do not currently hold a type rating.

### 40 Cost of ATP Certificate/Airplane type rating for Current Part 121 Pilots, 2013

To calculate the cost of an ATP certificate/type rating for current part 121 pilots, we proceed

as follows. First, we calculate the cost of an ATP certificate/airplane type rating for all current

pilots withou t an ATP certificate and then we calculate the cost of an airplane type rating for all

current pilots with an ATP certificate. The first cost is a cost of the statute; the second cost is a

discretionary cost of the rule. The ATP certificate costs for curre nt pilots are shown in the upper

half of Table 9:

### 41 

## Table 9. Cost of an ATP Certificate/ Airplane type rating for Current Part 121 Pilots ($ 2010)

Cost of ATP Certificate/Type Rating for Current (2013) Part 121 SICs

Year Number of

Effected

P art 121

SICs

— Post

Statute Number of

Affected

P art 121

SICs

— Pre

Statute Total Cost

of ATP

Certificate

Post

- Statute Total Cost

of ATP

Certificate

Pre

- Statute Incremental

ATP

Certificate

Cost of

Statute PV Cost of

ATP

Certificate

2013 13,161 $72,125,939 $

- $ 72,125,939 $ 58,876,251

2014 2,632 $

- $14,425,188 $(14,425,188) $(11,004,907)

2015 2,632 $

- $14,425,188 $(14,425,188) $(10,284,960)

2016 2,632 $

- $14,425,188 $(14,425,188) $ (9,612,112)

2017 2,632 $

- $14,425,188 $(14,425,188) $ (8,983,282)

2018 2,632 $

- $14,425,188 $(14,425,188) $ (8,395,591)



### Total $

- $ 10,595,400



### Cost of Type Rating for Current (2013) Part 121 Pilots Already Holding

an ATP Certificate

Year No. of

Affected

Part 121

SICs

-- Post

- Rule No. of

Affected

Part 121

SICs

-- Pre

- Rule Total Cost Type Rating

Post

- Rule Total Cost of Type Rating

Pre

- Rule Incremental Type Rating

Cost of Rule PV Cost of
Type Rating

2013 5,028

2014 1,006 1,006 $ 5,693,420 $ 5,693,420 $

-

2015 4,022 1,006 $22,773,679 $ 5,693,420 $17,080,259 $12,177,989

2016 1,006 $ 5,693,420 $(5,693,420) $(3,793,766)

2017 1,006 $ 5,693,420 $(5,693,420) $(3,545,576)

2018 1,006 $ 5,693,420 $(5,693,420) $(3,313,622)



### Total $

- $ 1,525,025

Note: Due to rounding, details may not add to totals or multiply to products.

### 42 As noted previously, c urrently only PICs (and SICs in flag and supplemental operations

requiring three or more pilots) are required to hold an ATP certificate and an airplane type rating

for the airplane flown in part 121 revenue service. Based on industry data obtained from the

ATA (now A4A) and RAA , we estimate that about 85 percent of the SICs for regional airlines

and about 15 percent of the SICs of major and cargo airlines do not have an ATP certificate.

(The corresponding figures for an air plane type rating are 90 percent and 30 percent

. ) With the

additional estimate of 25.2 percent (= 9,986/29,594) of SICs at regional airlines, we calculate

that (0.85 x 0.2523 + 0.15 x 0.7477) x 40,297 = 13,161 current (2013) SICs do not have ATP

certificate

. 28 

### Multiplying this number, shown for the year 2013 in column 1, “Number of

Affected Part 121 SICs

— Post

- Statute,” times the $5,48 0 cost per pilot of an ATP certificate

(from Table 7) yields the 2013 Total Cost of ATP Certificate Post

- Statute. Po st

- statute cost is

zero for subsequent years as all the statute cost is incurred upfront.

Pre

- statute cost is calculated as follows. As in the case of new part 121 pilots

, the cost that

must be calculated is c ost due to the statute’s requirement that pilot s will be required have the

ATP certificate immediately upon entering revenue service rather than when they upgrade to PIC

( on average in 5 years )

. As we have no information on the time in part 121 service of current

SICs without an ATP certificate

, we ass ume a uniform time distribution so that one

- fifth, or

2,632 (rounded), of the 13,161 SICs without an ATP certificate upgrade in each of the 5 years

from 2014 to 2018. We then calculate the Total Cost of ATP Certificate Pre

- Statute as about

$14.4 million fo r each year 2014

- 2018. Subtracting the pre

- statute total cost column from the

post

- statute total cost column yields the Incremental ATP Certificate Cost of Statute. Multiplying

the incremental cost column by the appropriate present value factors yields the final column, the

28 A small percentage of SICs also have not passed the ATP written exam. We estimate the total cost for these pilots

to be minimal.

### 43 Present Value Cost of the ATP Certificate. Unlike the case of new pilots, total cost is the same

before and after the statute, so the incremental total cost is zero. However, the present value total

cost is positive, at about $ 10.6 milli on. This present value cost represents the time value of

money underlying the requirement that part 121 SICs have the ATP certificate immediately on

entry into revenue service, rather than when they later upgrade to PIC. As previously discussed,

this cost is a cost of the statute, not the discretionary provisions of the rule.

An incremental airplane type rating cost stems from the fact that 90%

- 85% = 5% of

regional airline SICs have an ATP certificate but do not have a type rating for the aircraft flown,

with a corresponding figure for the major and cargo airlines of 30%

- 15% = 15%. The cost of

providing airplane type ratings for these pilots is shown in the lower half of Table 9. The number

of current SICs holding an ATP certificate but without an airpla ne type rating is c alculate d as

(0.05 x 0.2523 + 0.15 x 0.7477) x 40,297 = 5,028.

But a change in the final rule delays the compliance deadline for current part 121 SICs to

have an airplane type rating from August 1, 2013 to January 1, 2016. The effect of this change is

shown in the first column, “No. of Part 121 Pilots

— Post

- Rule,” where the 5,028 figure is shown

for 2013. As with the ATP certificate analysis, we assume a uniform time distribution of pilots so

that one

- fifth, or 1,006 (rounded), of the 5,02 8 pilots with an ATP certificate but without an

airplane type rating will upgrade to PIC each year. So the first column shows 1,006 pilots

upgrading in 2014 at a cost per pilot of $5,662 (from Table 7), for a total cost of about $5.7

million. At the end of 2015 (beginning of 2016), the remaining 4,022 SICs will be required by

the rule to have airplane type ratings. Of these, 1,006 would have obtained the type rating

anyway. In any case, the 4,022 will receive airplane type ratings, at a total cost of about $22.8

million.

### 44 As with the ATP certification analysis, the pre

- rule cost of the airplane type rating is

calculated on the assumption of a uniform time distribution of pilot upgrades, as shown by the

1,006 number of pilots in the “No. of Part 121 Pilots

— Pre

- Rule” annually for 2014

- 2018. As is

clear from the table, the difference between the post

- rule and the pre

- rule costs is that the post

rule costs are upfront at the end of 2014 and 2015 (beginning of 2016), whereas the comparable

pre

- rule costs are distri buted evenly over the 2014

- 2018 period. Thus, as with the ATP

certification costs, the total cost is identical pre

- and post

- rule, so the total incremental cost is

zero. However, as with the ATP certification costs, the present value type rating cost is po sitive,

at about $1.5 million.

Cost of ATP Certificate/ Airplane type rating for All Part 121 Pilots, 2013

- 2032

Table 10 below summarize s the cost of an ATP certificate/airplane type rating for new and

current part 121 pilots:



## Table 10. Summary of ATP Certificate/ Type Rating Cost for
All Part 121 Pilots, 2013

- 2032 ($ 2010)

Total Cost

($ mil.) PV Cost ($ mil.)

ATP Cost

-- New Pilots $ 29,890,575 $20,518,859

ATP Cost

-- Current Pilots w/o ATP Certificate $

- $10,595,400

Cost of ATP Certification Requirement $ 29,890,575 $31,114,259

Cost of Type Rating

— Current Pilots $

- $ 1,525,025

All Costs of ATP Certificate/Type Rating (rows 3+4) $ 29,890,575 $32,639,284

Notes: 1. “ATP Cost

-- Current Pilots w/o ATP Certificate” is the cost of providing an ATP certificate (and type rating) to all current pilots without an ATP certificate. 2. “Cost of Type Rating

— Current Pilots” is the cost of type rating pilots already holding an ATP

certi ficate.

### 45 The ATP certificate cost of $29.5 million, with present value $30.9 million is attributable to

the statute, (see Table 1A, “Statute Costs and Benefits”). The type rating present value cost of

$1.5 million is attributable to the rule. The fact that , for “All Costs of ATP Certificate/Type

Rating” present value cost is greater than total (undiscounted) cost reflects the time value of

money PV cost for current pilots as discussed above.

Cost of the ATP Certificate Requirement (Eligibility Restrictions) under the Statute

As previously noted, the costs attributed to the statute result from the Congressionally

mandated requirement that all part 121 SICs have an ATP certificate , almost all of which stems

from the associated requirement that pil ots have 1,500 hours of flight time to be eligible for an

ATP certificate. The 1,500

- hour requirement results in a pilot’s earnings being deferred by

delays in his or her employment in part 121 service. In a similar way the requirement for an ATP

certifica te also reduces the career earnings of pilots with a commercial pilot’s certificate who are

under age 23, the minimum age requirement for the ATP certificate. In this section we estimate

the total cost of the two eligibility restrictions to be $6.3 billion , with present value cost of $2.2

billion. In the following section we estimate the cost savings that result from the final rule

provisions (by means of the R

- ATP) for academic training credits toward the 1,500

- hour

requirement and the rule provision reduc ing the R

- ATP minimum age requirement for pilots with

1,500 flight hours to 21 years.

We estimate the cost of the 1,500

- hour requirement for new pilots only , as, given the current

depressed hiring environment for pilots, the number of pilots currently serv ing in part 121 with

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

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

### 46 of the increased flight hour requireme nt can be estimated by the reduced salary and benefits that

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

the loss of pilot productivity the 1,500

- hour re quirement brings about by delaying the entrance of

pilots into part 121 operations and, consequently, shortening and, more significantly, delaying

their career path.

Based on information from a 2010 FAA industry survey , we estimate the career path of a

“typical” pilot in part 121 operations as follows: an SIC at a regional airline u pgrade s to regional

airline PIC after five years; after two years as PIC at the regional airline, the pilot move s to a

pos ition as SIC at a major airline; and after an additional ten years, the pilot upgrade s to PIC at

the major airline. Under current regulations, a pilot is eligible to serve as an SIC in part 121

operations with a commercial pilot’s license, which requires just 250 hours of flight time

, 29 

### and

an instrument rating.

There is considerable variation in the hiring mini mums of regional airlines, but the average

total hours minimum is about 750 hours. 30 

### We conservatively assume that pilots with instrument

ratings

— the traditional source of airline pilots

-- can accumulate about 500 hours of flight time a

year. 31 

### Thus, absent r ule relief, the 1,500

- hour requirement for an ATP certificate will delay a

new civilian pilot’s part 121 career , on average, by 750 flight hours (1,500

– 750), or about one

and one

- half year s . Air Force, Navy, and Marine pilots typically have more than 1,5 00 hours of

flight time when leaving the service, so they will not be delayed by the 1,500

- hour requirement.

29 A graduate of a part 141 pilot schoo l or a part 142 training center can obtain a commercial license with as few as 190 hours of flight time.

30 Hiring minimum data supplied by KitDarby.com Aviation Consulting , LLC, Peachtree City , Georgia.

31 Estimate of 450 to 700 flight hours from the FAA Flight Standards Service, email 4 February 2011

.

### 47 Army pilots typically have about 750 hours of flight time when leaving the military, so they will

face a year

- and

- a

- half part 121 career delay like non

- military pilots

.

We estimate the cost of the 1,500

- hour requirement by the loss in earnings

-- salary and

benefits

-- of a typical pilot in part 121 operations, assuming a 35

- year career caused by the effect

of the 1,500

- hour requirement in delaying entry into part 121 service

. Hourly salary and pension

benefits data is from a 2008 airline pilot salary survey by www.airlinepilotcentral.com

. 32 

### Active

benefits are from a recent study by KitDarby.com Aviation Consulting. 33 

### M ajor airline hourly

earnings are estimated using data for Delta Airlines as this was the median major airline in the

Kit Darby study

. Regional airline hourly earnings are esti mated using data for Piedmont Air lines

and Mesa Airlines

. 34 

### As pilots’ hourly rates differ by type of airplane flown (as well as by

airline), an average salary for each airline was calculated as a weighted average using the number

of aircraft of each type ( provided in the same survey) as weights. These hourly earnings were

increased by active benefits factors from the Kit Darby study (Regional airlines: 1.233, Majors:

1.15) 35 

### and by retirement benefits factors from the airlinepilotcentral.com survey (Piedmont :

401k Matching

— 4%; Mesa: 401k Matching

— 3%; Delta: 401k Matching

— 2% and “B Fund”

—

10%). The inclusive benefit factor for Piedmont is then 1.233 x1.04 = 1.282, for Mesa 1.233 x

1.03 = 1.270, and for Delta 1.15 x 1.12 = 1.288. The hourly inclusive earnings da ta were then

32 Pay rates are not adjusted for inflation to 2010

, as they are contractually fixed and, for our airline sample, were

not scheduled to increase until 2011 at the earliest.

33 U.S. Air line Pilot Job Market Overview, April 12, 2010. KitDarby.com Aviation Consulting, LL C, Peachtree City, Georgia, p. 35.

34 In the NPRM Colgan Air and Mesa Airlines were the median airlines on the basis of the KitDarby.com Aviation Consulting study, For that measure we combined Kit Darby’s categories of National Airlines and Commuter

Airlin es into one regional airline category and chose the median airlines based on Darby’s calculations of career pilot earnings. As Colgan Air is no longer in existence, for the final rule we have substituted Piedmont Airlines for Colgan Air. Piedmont Airlines is a turboprop operator, as was Colgan Air, whose 2010 size is close to Colgan

Airline’s 2010 size.

35 KitDarby.com Aviation Consulting, pp. 34

- 37 (1 + ratio of “Active Benefits” to “Career Earnings”)

### 48 converted to monthly figures by multiplying them by the airline’s average credit hours per month

(Regional airlines: 85 hours, Delta: 77 hours), also from the Kit Darby study

. 36 

### Finally, the

monthly earnings figures for Piedmont and Mesa were a veraged to estimate monthly regional

airline earnings using their airplane numbers as weights.

Table 11 shows how we estimate a pilot’s loss of earnings due to a one

- and

- a

- half year part

121 career delay. We begin a 35

- year pilot career, starting at age 30 , and ending with a

regulatory

- required retirement at age 65. Column 3 shows the career path for a typical pre

- statute

part 121 pilot, with 5 years as a first officer (SIC) at a regional airline, 2 years as a regional

airline captain (PIC), 10 years as a m ajor airline first officer, and the remaining 18 years of his or

her career as a major airline captain. Column 4 shows our estimates for the typical pilot’s annual

earnings (including benefits). Column 5 shows the post

- statute pilot’s career path delayed 1 1⁄2

years, while column 6 is the corresponding annual pilot earnings.

For the year

- and

- a

- half

- delay into part 121 service, we assume, as an upper bound estimate,

that pilots will earn the same salary in non

- part 121 operations as they will earn in their firs t year

as a regional airline SIC. 37 

### This accounts for the delayed pilot’s earnings in the first two years.

For all remaining years, the delayed pilot’s earnings are an average of the undelayed pilot’s

earnings for the previous two years. So the delayed pilo t’s earnings at year 4, for example, is the

36 KitDarby.com Aviation Consulting , pp. 26

- 27.

37 The re are many employment opportunities available to pilots who wish to accumulate sufficient hours to qualify for part 121 operations, including part 135 operations or part 91, subpart K operations (first officer), flight
instruction, commercial air tour operations, ferry or training flights, and aerial work operations, such as photography, surveys, banner towing or power line/pipeline patrols. We believe virtually all pilots will be able to accumulate flight hours given these opportunities rather than hav ing to rent airplanes to build flight time

. . Although we do not have data on the salaries paid for these alternative opportunities, we believe that the extent to which pilots in these alternatives will earn less than they would earn in their first year or two as a regional airline SIC is minimal. The reason is that regional airline first officers are willing to accept a relatively low initial salary because of the big jumps in salary that come when they advance sequentially to regional airline captain, majo r airline first officer, and,

finally, major airline captain

. We received no comments on this assumption



### .

### 49 average of the undelayed pilot’s average earnings in years 2 and 3, centered at year 2 1⁄2, thus

creating the 4

– 2 1⁄2 = 1 1⁄2 year earnings delay. Delayed pilot earnings in column (6) subtracted

from undelayed pilot earnings in column (4) yields the net loss in earnings as a result of the year

and

- a

- half delay on entry into part 121 service, shown in column (7).

The loss in earnings takes place in years 2

- 7 and 9

- 19, with no loss in year 1 only because of

our upper bo und estimate of the delayed pilot’s pay in non

- part 121 operations. In year 8 the

delayed pilot has higher earnings than the undelayed pilot because the undelayed pilot is then

taking a pay cut in moving from a position as a regional airline captain to a p osition as a major

airline first officer. The delayed pilot suffers large losses in years 6

- 7, however, because of the

pilot’s delay in becoming a regional airline captain. The delayed pilot also suffers large loses in

years 9

- 10 because of the pilot’s del ay in making the pay jump that a major airline first officer

makes in his or her 2 nd 

### year as a first officer. Finally, the delayed pilot suffers large losses in

years 18

- 19 because of the pilot’s delay in becoming a major airline captain. For the last 16

y ears, years 20

- 35, there is no loss in earnings as the delayed pilot is at the top of the major

airline captain’s pay scale during this period. Summing the annual earnings losses in column (7)

yields a total loss in earnings over the first 20

- year period ( as well as the entire 35

- year period)

of about $258,000. 38 

### Summing the annual present value losses in the column yields a total

present value loss in earnings of about $120,000 as a result of the year

- and

- a

- half delay on entry

into part 121 service.

In Ta ble 12 below we summarize our calculation of the delay loss for all pilots over our

estimation period, 2013

- 2032 using the delay loss per pilot from Table 11. We first calculate the

number of affected pilots per year and then the delay loss for all pilots

— our estimate of the cost

38 The cost of a year

- and

- a

- half delay can also be measured as the sum of a pilot’s earnings over a 35

- year career minus the sum of the earnings forec ast to be received over the same 35

- year per iod, but with a year

- and

- a

- half delay

on entry into part 121 service. A similar statement applies to present value earnings.

### 50 of the 1,500

- hour requirement. The “The No. of Part 121 pilots” column in Table 12 shows the

forecast number of part 121 pilots over the 2013

- 2032 estimation period, using the 2010 number

of part 121 pilots 39 

### as a base and the FAA f orecast rate of 0.6 percent. 40 

### The “No. of New Pilots”

(column 4) is the annual change in the number of part 121 pilots calculated from the forecast

increase in the number of pilots in column 2 and the estimated number of retiring pilots 41 

### from

column 3. As in the NPRM, we next estimate the number of new pilots with military training

,

assuming military pilots to constitute 25 percent of new pilots

. 42 

### U. S. Air Force, Navy, and

Marine pilots typically leave the military with at least 1,500 flight hours, but U.S. Army pilots

typically have only about 750 hours, so, absent rule relief, Army pilots will be subject to the

same year

- and

- a

- half delay as non

- military pilots

. We estimate that U.S. Army pilots are about

28.7 percent of all U.S. military pilots. 43 

### Accor dingly, the “No. of Non

- Army Military Pilots”

(next column) is calculated as the “ Number of New Pilots” times 1

- (0.25 x (1

- 0.287)) . In the

next column we show the number of pilots with 1,500 flight hours, age 21

— pilots restricted by

the ATP certificate mi nimum age requirement using the current (2013) annual estimate of 100

pilots 44 

### and the FAA forecast rate of 0.6 percent. Subtracting the columns of age

- restricted pilots

and Army pilots from the “No. of New Pilots” column yields, in the subsequent column, t he

number of pilots restricted by the 1,500

- hour requirement. In the next column we show the

“ Total Cost of the 1,500

- Hour Requirement.” This column is calculated as follows. We consider

39 FAA Flight Standards Service. National Vital Information Subsystem (NVIS) database, Nov. 22, 2010.

40 U.S. DOT, FAA, Aviation Policy & Plans. FAA Aerospace Forecast: 2010

- 2030. Table 29, "Active Pilots by Type of Certificate", Air Tran sport, Avg Annual Growth, 2010

- 30.

41 See section “Principal Assumptions and Sources of Information. ”

42 KitDarby.com Aviation Consulting, LLC, Peachtree City, GA.

43 2010 military pilot figures from FAA Flight Standards.

44 FAA estimate based on industry sources.

### 51 20 annual cohorts of new pilots, with the first cohort entering the m arket in 2013, the second in

2014, and, so on, until the twentieth cohort in 2032. In order to make the cost of the 1,500

- hour

requirement compatible with other cost and benefit estimates of the statute and rule, we estimate

### 52 

## Table 11. Cost per Pi lot of the 1,500

- Hour Requirement under the Statute (1 1⁄2 Year Delay)

Year Age Typical Part

121 Pilot

Career

(3) Total Earnings Typical (Undelayed)

Pilot
(4) Career Path, Part

121 Service Delayed 1 1/2 Yrs
(5) Total Earnings,

Part 121 Service Delayed 1 1/2 Yrs
(6) Loss in Total Earnings, 1 1/2 Yr Delay
(7) Loss in PV Earnings, 1 1/2 Yr Delay
( 8 )

1 30 FO, Regional $ 30,532 Comm'l Pilot $ 30,532 $

- $

-

2 31 FO, Regional $ 38,131 Comm'l/FO reg. $ 30,532 $ 7,598 $ 6,636

3 32 FO, Regional $ 41,491 FO Reg. $ 34,332 $ 7,160 $ 5,845

4 33 FO, Regional $ 43,667 FO Reg. $ 39,811 $ 3,856 $ 2,942

5 34 FO, Regional $ 44,967 FO Reg. $ 42,579 $ 2,387 $ 1,702

6 35 Capt, Regional $ 82,091 FO Reg. $ 44,317 $ 37,774 $ 25,171

7 36 Capt, Regional $ 84,527 FO Reg.,Capt Reg. $ 63,529 $ 20,998 $ 13,077

8 37 FO, Major $ 64,266 Capt Reg. $ 83,309 $ (19,043) $ (11,083)

9 38 FO, Major $ 99,650 Capt Reg./FO Mjr $ 74,397 $ 25,254 $ 13,736

10 39 FO, Major $ 116,376 FO Mjr $ 81,958 $ 34,418 $ 17,496

11 40 FO, Major $ 119,338 FO Mjr $ 108,013 $ 11,325 $ 5,380

12 41 FO, Major $ 122,230 FO Mjr $ 117,857 $ 4,373 $ 1,942

13 42 FO, Major $ 125,424 FO Mjr $ 120,784 $ 4,640 $ 1,925

14 43 FO, Major $ 128,750 FO Mjr $ 123,827 $ 4,923 $ 1,909

15 44 FO, Major $ 131,692 FO Mjr $ 127,087 $ 4,605 $ 1,669

16 45 FO, Major $ 133,328 FO Mjr $ 130,221 $ 3,108 $ 1,053

17 46 FO, Major $ 135,312 FO Mjr $ 132,510 $ 2,802 $ 887

18 47 Capt, Major $ 200,435 FO Mjr $ 134,320 $ 66,115 $ 19,561

19 48 Capt, Major $ 202,668 FO Mjr/Capt Mjr $ 167,873 $ 34,794 $ 9,621

20 49 Capt, Major $ 202,668 Capt, Major $ 201,551 $ 1,116 $ 288

21 50 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

22 51 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

23 52 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

24 53 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

25 54 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

26 55 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

27 56 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

28 57 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

29 58 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

30 59 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

31 60 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

32 61 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

33 62 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

34 63 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

35 64 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

- 

### Totals $ 5,187,556 $ 4,929,353 $ 258,203 $ 119,757

Note: Details may not add up to totals due to rounding.

### 53 

## Table 12. Cost of the ATP Ce rtificate Requirement (Eligibility Restrictions) under the Statute , 2013

- 2032

Year No. of

Part

121

Pilots No. of Retiring

Pilots No. of

New

Pilots Non

Army Military

Pilots Pilots

w/1500
Hours, Age 21 No. of Pilots

Restricted by 1500

-

Hour Requirement Total Cost of the

1500

- H ou r Requirement Total Cost of

the Minimum

Age Requirement Total Cost of Eligibility

Restrictions PV Cost of Eligibility

Restrictions

2011 78,728 2,817 3,287

2012 79,200 2,834 3,307

2013 79,675 2,851 3,326 593 100 2633 $

- $

- $

- $

- 2014 80,153 2,868 3,346 597 101 2649 $ 20,006,673 $ 759,812 $ 20,766,485 $ 15,842,652

2015 80,634 2,886 3,366 600 101 2665 $ 38,979,698 $ 1,860,273 $ 40,839,971 $ 29,118,335

2016 81,118 2,903 3,387 604 102 2681 $ 49,367,394 $ 2,425,101 $ 51,792,495 $ 34,511,526

2017 81,605 2,920 3,407 608 102 2697 $ 55,949,712 $ 2,787,173 $ 58,736,885 $ 36,578,380

2018 82,094 2,938 3,427 611 103 2713 $ 155,748,994 $ 6,646,288 $ 162,395,281 $ 94,515,532

2019 82,587 2,955 3,448 615 104 2729 $ 211,974,068 $ 10,642,209 $ 222,616,277 $ 121,088,505

2020 83,082 2,973 3,469 619 104 2746 $ 163,103,321 $ 8,923,550 $ 172,026,871 $ 87,449,738

2021 83,581 2,991 3,489 622 105 2762 $ 230,578,213 $ 10,489,426 $ 241,067,639 $ 114,529,499

2022 84,082 3,009 3,510 626 106 2779 $ 322,586,928 $ 15,763,342 $ 338,350,270 $ 150,231,566

2023 84,587 3,027 3,531 630 106 2795 $ 354,341,713 $ 17,826,663 $ 372,168,376 $ 154,436,644

2024 85,094 3,045 3,553 634 107 2812 $ 367,982,558 $ 18,519,033 $ 386,501,591 $ 149,891,981

2025 85,605 3,063 3,574 637 107 2829 $ 382,407,770 $ 19,238,738 $ 401,646,508 $ 145,575,178

2026 86,118 3,082 3,595 641 108 2846 $ 397,665,065 $ 20,006,165 $ 417,671,230 $ 141,479,696

2027 86,635 3,100 3,617 645 109 2863 $ 412,176,204 $ 20,752,995 $ 432,929,199 $ 137,054,297

2028 87,155 3,119 3,639 649 109 2880 $ 422,831,689 $ 21,335,356 $ 444,167,044 $ 131,413,001

2029 87,678 3,138 3,661 653 110 2898 $ 432,746,176 $ 21,825,380 $ 454,571,556 $ 125,692,823

2030 88,204 3,156 3,682 657 111 2915 $ 609,430,704 $ 28,667,008 $ 638,097,712 $ 164,896,574

2031 88,733 3,175 3,705 661 111 2932 $ 704,703,847 $ 35,574,577 $ 740,278,424 $ 178,786,927

2032 89,266 3,194 3,727 665 112 2950 $ 711,871,189 $ 36,011,268 $ 747,882,457 $ 168,806,917

Total, 2013

- 32 60,394 70,460 12,567 2,118 55,775 $ 6,044,451,916 $ 300,054,355 $ 6,344,506,272 $ 2,181,899,773

Note: Due to rounding, details may not add up to totals or multiply to products.

### 54 earnings loss over just this 20

- year period. So the earnings loss of the first (2013) cohort is

estimated over the full 2013

- 2032 20

- year period, the earnings loss of the second (2014) cohort

is estimated over the 19

- year 2014

- 2032, and so on, un til the earnings loss of the 20 th 

### cohort is

estimated for just the year 2032. The column entry for 2013 is zero because there is no earnings

loss (Table 11, Year 1) because we assume pilots earn the same salary in non

- part 121 operations

during their 11⁄2 ye ar delay as they initia lly earn on entry into part 121 service. For 2014 Cohort 1

suffers an earnings loss per pilot of $7,598 (Table 11, Year 2), while Cohort 2 has no first year

earnings loss. Therefore, the cost of the 1,500

- hour requirement for 2014 is the number of Cohort

1 pilots times the second year earnings, or about $20.0 million (=2,633 x $7,598). For 2015 the

cost of the 1,500

- hour requirement is the number of Cohort 1 pilots times the Year 3 cost per

pilot, $7,160 (Table 11, Year 3) plus the nu mber of Cohort 2 pilots times the Year 2 cost per

pilot, or about $39.0 million (= 2,633 x 7,160 + 2,649 x 7,598). As before, the Year 1 cost per

pilot of Cohort 3 is zero. And, so on, up to 2032. We note a large drop in costs in 2020 when the

Cohort 1 pil ots take a large pay cut when they move in Year 8 from a regional airline captain’s

position to a major airline first officer position. Table 12 shows the total (undiscounted) cost of

the 1,500

- hour rule over the years 2013

- 2032 estimation period to be abo ut $6.0 billion.

In the next column we show the cost of the minimum

- age requirement, 45 

### which is calculated

in an analogous way to the calculation of the costs of the 1,500

- hour requirement. For the

minimum

- age requirement, however, we base the costs on a two

- year eligibility delay on entry

into part 121 service, from age 21 to age 23. 46 

### Tab le 12 shows the total (undiscounted) cost of

45 If the Congressionally

- mandated ATP certificate requirement for all pilots serving in part 121 operations were to

go into effect without rulemaking action by the FAA, pilots with 1,500 hours of flight time but who had not yet reached age 23 would be unabl e to serve in part 121 operations, resulting in a delay in their careers.

46 Our estimates are somewhat conservative depending on how many pilots in this category would wish to enter into part 121 service later than their 21 st birthday.

### 55 the minimum

- age requirement over the 2013

- 2032 estimation period to be $300.1 million. 47 

### The

total cost of the two eligibility restrictions together is $6.3 billion, with present value cost of $2.2

billion.

Co st of the 1,500

- Hour Requirement under the Final Rule and Cost Savings Attributable to

the Final Rule

In this section we estimate the cost of the 1,500

- hour requirement under the final rule’s

provisions allowing credit towards the 1,500

- hour requirement f or academic training courses.

We derive the cost savings provided by the rule by subtracting this cost from the full statutory

cost estimated in the previous section. The amount in the figures that previously, under the

statute, represented the cost of the minimum age requirement of 23 years now, under the rule,

represents the cost savings from reducing the minimum age requirement for pilots with 1,500

hours to 21. The cost savings under the rule are simply the reverse of the costs under the statute.

As already noted, the average total hours hiring minimum of regional airlines is about 750

hours, and pilots with commercial pilot certificates are able to accumulate about 500 hours a

year. P ilots with an aviation

- related bachelor’s degree ( who also recei ved their commercial pilot

certificate with instrument rating from an associated part 141 pilot school ) will be allowed to

hold the restricted privileges ATP certificate with a minimum of 1,000 hours if they complete 60

credit hours of aviation and aviatio n

- related coursework. With this relief, the careers of pilots

with aviation

- related bachelor’s degrees will be delayed by 250 hours (1,000

- 750), or just half a

year. Pilots graduating with a bachelor’s degree or an associate’s degree ( who also received th eir

commercial pilot certificate with instrument rating from an associated part 141 pilot school ) will

be allowed to obtain a restricted privileges ATP certificate with a minimum of 1,250 hours if

47 See Appendix 4 for the underlying table that is the basis for these costs (analogous to Table 11 for pilots delayed by the 1,500

- hour requirement).

### 56 they complete at least 30 credit hours of aviation and avia tion

- related coursework. With this

relief, the careers of these pilots will be delayed by 500 hours (1,250

– 750), or one year. 48



### Pilots who graduate from a military pilot training school will be allowed to hold the restricted

privileges ATP certificate wi th a minimum of 750 hours . As previously stated, Air Force, Navy,

and Marine pilots typically have more than 1,500 hours of flight time when leaving the service

and therefore they are immediately eligible for the unrestricted ATP certificate. And since, as

already noted, A rmy pilots typically have about 750 hours of flight time when leaving the

military, with the 750

- hour military credit provided by the rule they experience no delay (750

–

750) as they will be immediately eligible for entry into part 121 se rvice under the rule’s

restricted privileges ATP certificate. Thus, in general, military pilots will not have their careers

delayed as a result of the rule’s requirements.

The cost of a half

- year delay for pilots with an aviation

- related bachelor’s degree and the cost

of a year delay for pilots with an aviation

- related associate’s degree are calculated in an

analogous way to the cost of the year

- and

- a

- half delay we calculated in the previous section. As

in that case, we assume that a pilot, as an upper boun d estimate, will be paid, as a commercial

pilot in non

- part 121 operations, the same salary and benefits the pilot will earn in his or her first

year as a regional airline SIC. As in Table 11 for the full year

- and

- a

- half delay

, we estimate the

annual costs of a half

- year delay in a part 121 pilot’s career over the 2013

- 2032 estimation

period. These undiscounted costs sum to $86,068 (present value $44,792). The analogous annual

costs for a one

- year delay sum to $ 172

, 135, with a present value cost of $87,934. 49 

### For the

remaining pilots subject to the full year

- and

- a

- half delay, from the previous section we already

48 The additional flight time requirements for an ATP certificate will reduce the pool of pilots eligible for part 121

oper ations. The current level of safety will be maintained because pilots must still meet the existing certification and qualification standards before serving in part 121 operations.

49 See Appendix 4 for the half

- year and one

- y ear delay equivalents of Table 11.

### 57 know the annual costs, which sum to $258,203, with present value $119,757

. Allowing for

rounding, the one

- year delay costs are double half

- year delay costs, and year

- and

- a

- half delay

costs are triple half

- year delay costs, with a similar relationship for present value costs. In Table

13 below, we use these cost estimates with estimates of the affected number of pilots in each

category to estimate the f inal rule costs of the 1,500

- hour requirement.

As in Table 12 above, (counting the “Year” column as column zero) columns 1

- 3 of Table 13

show the number of part 121 pilots, the number of retiring part 121 pilots, and the number of

new pilots. The next colu mn shows the number of military pilots. As already noted, the part 121

careers of these pilots will be undelayed as a result of the 750

- hour academic credit towards the

1,500

- hour requirement provided by the rule. The next two columns show the number of pi lots

with bachelor’s degrees and with associate’s degrees. 50

, 51 

### These figures are based the FAA’s

estimate of the percentage of graduates (70 percent) from aviation programs (with professional

pilot majors) that the FAA considers to be associated with a part 141 pilot school. The next

column shows the number of pilots with 1,500 flight hours, age 21. The subsequent residual

column shows the number of pilots fully restricted by the 1,500

- hour requirement, derived by

subtracting the previous four columns

-- the n umber of pilots with military training, the number of

pilots with bachelor’s degrees, the number of pilots with associate’s degree , and the number of

pilots with 1,500 flight hours, age 21

-- from the number of new pilots. In table 12 this group

constituted all the pilots affected by the statute’s 1,500

- hour requirement. In table 13, the number

50 Source: Aviation Accreditation Board International (AABI), Gary W. Kiteley, Executive Director, 3410 Skyway
Drive, Auburn, AL 36830, Tel.: 334

- 844

- 2415.

51 The final rule requires aviation degree baccalaureates to have at least 60 hours of aviation course credits to qualify the restricted privileges ATP certificate with 1,000 flight hours. Otherwise baccalaureates will need the 1,250 flight hours required of associate degree students to qualify for the restricted privileges ATP certificate. The FAA Flight Standards Service estimates that 80% of aviation degree baccalaureates will have the requisite 60 hours of aviation

course credits. For the 20% that do not have the requisite 60 hours, we include the pilot numbers in the figures for associate degree pilots.

### 58 of fully restricted pilots is reduced by the number of pilots allowed academic credit towards the

1,500

- hour requirement.

The next three columns show the cost of delayed entry into part 121 service

— the cost of the

1,500

- hour requirement

— for each of the three affected groups. These costs are calculated in the

same way as in Table 12. The table shows that the net total cost of the 1,500

- hour requirement

for the estimation period, 2013

- 2032, is about $4.0 billion, with present value cost of about $1.4

billion. As shown in the previous section, the full cost self

- executing cost of the ATP certificate

requirement eligibility restrictions will be about $6.3 billion, with present value, about $2.2

billion. We calculate the benefit from cost savings attributable to the final rule as the difference

between the full self

- executing cost of the ATP certificate requirement eligibility restrictions

summarized in Table 12 ($6. 3 billion; $2.2 billion present value) minus the total cost of the

1,500

- hour requirement under the final rule as summarized in Table 13 ($4.0 billion; $1.4 billion

present value). The result is $2.3 billion ($6.3 billion

– $4.0 billion), with a correspond ing

present value cost of $0.8 billion ($2.2 billion

– $1.4 billion). 52

, 53

52 The amount in the figures that previously, under the statute, represented the cost of the minimum age requirement for pilots with 1,500 flight hours of 21 years now represents the cost savings under the rule.

53 The cost savings by category of rule relief

— credits for military, 4

- year degree, and 2

- year degree academic training courses are shown in Table 1.

### 59 

## Table 1 3 . Cost of 1,500

- Hour Requirement under the Final Rule 2013

- 2032 ($ 2010)

Year No. of

Part

121

Pilots Number

of Retiring

Pilots No. of

New

Part

121

Pilots No. of

Pilots

with Military Training No. of Pilots

w/Bachelor Degree from
Pgm

w/

Associated

Part 141

School No. of Pilots

w/Associate Degree from
Pgm

w/

Associated

Part 141

School Pilots

with
1,500 Flight
Hours, Age 21 No. of Pilots

Restricted

by Full
1,500

- Hour Rqmt Cost of 1⁄2

- Year Career

Delay for

Bachelor Degree Pilots Cost of 1 Year Career Delay

for Associate Degree Pilots Cost of 1.5

- Year Career Delay for Pilots Subject to Full
1,500

- Hr Rqmt Cost of 1,500

- Hour Requirement

All Part 121

Pilots PV Cost of
1,500

- Hour Requirement

All Part 121

Pilots

2011 78,728 2,817 3,287 640 687

2012 79,200 2,834 3,307 644 691

2013 79,675 2,851 3,326 832 648 695 100 1,052 $

- $

- $

- $

- $

-
2014 80,153 2,868 3,346 837 652 699 101 1,058 $ 2,461,426 $ 5,282,398 $ 7,990,697 $ 15,734,521 $ 12,003,791

2015 80,634 2,886 3,366 842 656 704 101 1,064 $ 3,564,969 $ 7,650,682 $ 15,568,553 $ 26,784,204 $ 19,096,767

2016 81,118 2,903 3,387 847 660 708 102 1,071 $ 4,291,198 $ 9,209,222 $ 19,717,415 $ 33,217,836 $ 22,134,446

2017 81,605 2,920 3,407 852 664 712 102 1,077 $ 4,737,908 $ 10,167,893 $ 22,346,403 $ 37,252,205 $ 23,198,801

2018 82,094 2,938 3,427 857 668 716 103 1,084 $ 16,792,884 $ 36,038,744 $ 62,206,394 $ 115,038,022 $ 66,953,176

2019 82,587 2,955 3,448 862 672 721 104 1,090 $ 17,682,781 $ 37,948,528 $ 84,662,777 $ 140,294,086 $ 76,310,687

2020 83,082 2,973 3,469 867 676 725 104 1,097 $ 11,225,252 $ 24,090,203 $ 65,143,723 $ 100,459,179 $ 51,068,352

2021 83,581 2,991 3,489 872 680 729 105 1,103 $ 22,755,470 $ 48,834,885 $ 92,093,302 $ 163,683,656 $ 77,764,926

2022 84,082 3,009 3,510 878 684 734 106 1,110 $ 28,310,216 $ 60,755,773 $ 128,841,728 $ 217,907,716 $ 96,753,632

2023 84,587 3,027 3,531 883 688 738 106 1,116 $ 29,439,642 $ 63,179,602 $ 141,524,639 $ 234,143,883 $ 97,161,387

2024 85,094 3,045 3,553 888 692 743 107 1,123 $ 30,553,166 $ 65,569,305 $ 146,972,814 $ 243,095,284 $ 94,276,542

2025 85,605 3,063 3,574 893 696 747 107 1,130 $ 31,771,141 $ 68,183,168 $ 152,734,266 $ 252,688,576 $ 91,585,968

2026 86,118 3,082 3,595 899 700 751 108 1,137 $ 33,039,262 $ 70,904,648 $ 158,828,054 $ 262,771,964 $ 89,009,956

2027 86,635 3,100 3,617 904 705 756 109 1,144 $ 34,190,511 $ 73,375,311 $ 164,623,826 $ 272,189,647 $ 86,168,272

2028 87,155 3,119 3,639 910 709 760 109 1,150 $ 34,925,834 $ 74,953,367 $ 168,879,643 $ 278,758,843 $ 82,474,683

2029 87,678 3,138 3,661 915 713 765 110 1,157 $ 35,777,954 $ 76,782,079 $ 172,839,505 $ 285,399,538 $ 78,915,351

2030 88,204 3,156 3,682 921 717 770 111 1,164 $ 57,089,436 $ 122,518,061 $ 243,407,584 $ 423,015,081 $ 109,315,135

2031 88,733 3,175 3,705 926 722 774 111 1,171 $ 58,155,174 $ 124,805,212 $ 281,459,827 $ 464,420,212 $ 112,163,559

2032 89,266 3,194 3,727 932 726 779 112 1,178 $ 58,504,105 $ 125,554,043 $ 284,322,475 $ 468,380,623 $ 105,719,673

Total, 2013

- 32 60,394 70,460 17,615 13,724 14,726 2,118 22,277 $ 515,268,328 $ 1,105,803,124 $ 2,414,163,624 $4,035,235,075 $ 1,392,075,105

Note s : 1. Details may not add to totals due to rounding. 2. By reducing the R

- ATP minimum age requirement from 23 to 21, the rule eliminates the age restriction on pilots with 1,500 hours and minimum age 21. Therefore is no cost associated with these pilots.

### 60 E. Safety Benefits of this Rule

As a result of the rule’s requirements and the ATP CTP in particular, t he FAA expects that

the rule will reduce the number of future accidents. The quantified benefits of the rule are based

upon the probability that this rule could have prevented identified accidents had the rule been in

place at the time of the accidents and the cost of these accidents in terms of human life and

injuries and airplane damage. The methodolog y begins by identifying previous accidents that this

rule could have prevented, or mitigated. We then assign a probability value to preventing such

accidents in the future. In order to assess the probability that the rule’s requirements will reduce

future accidents

, f or the 10 fiscal years from 2001 to 2010

, AVP reviewed the NTSB accident

reports and structured accident data. That data was supplemented with FAA data as necessary.

For the specified period, AVP reviewed all part 121 accidents

, part 135 commut er accidents, and

part 135 on

- dem and accidents in a turbo jet or in airplanes with a seating capacity of 10 or more.

As noted earlier, AVP found no relationship between the ATP certificate 1

, 500

- hour

requ irement and part 121 accidents because, in short, al l part 121 PICs have an ATP certificate

and 1,500 hours, and in most accident cases, the SIC had at least 1,500 hours. For those seven

accidents that the SIC had less than 1,500 hours, there were other causal factors identified by the

NTSB and the AVP asse ssment. In their assessment AVP found that the requirements of the rule

,

particularly the ATP CTP, would have mitigated the likelihood of such accidents occurring again

in the future.

We also expect only minimal benefits from the requirement that a pilot h ave 1,000 hours of

air carrier operating experience prior to serving as a part 121 PIC. For most operators the 1,000

requirement will not be a factor given that the current actual upgrade times for SICs exceed the

minimum time it would take to acquire 1,0 00 hours set forth in the final rule

.

### 61 The ATP CTP is designed to address the gap in knowledge identified by the FOQ ARC

between a commercial pilot and the knowledge a pilot should have when entering an air carrier

environment. It also addresses the specif ic requirements for modifying the ATP certificate

identified in section 217 of the Act. As well as part 121 operations, the aeronautical knowledge

and flight training requirements established by the ATP CTP are applicable to any operation

requiring a pilot to have an ATP certificate by rule, including PICs in part 91

, subpart K

,

operations, part 135 commuter operations, and part 135 on demand operations using turbojets or

airplanes with a seating capacity of 10 or more. The ATP CTP has a comprehensive topic list to

address these deficiencies that are the underlying causes of many airplane accidents :

• Aerodynamics

o Stall recognition/recovery

o Upset prevention/recovery

o High altitude operations

o Energy management

o Operating in a multicrew environment

• Air Carrier Operations

o Physiology/Fitness for duty

o Communications

o Ground operations

o Aircraft systems and performance

• Crew Resource M anagement

• Knowledge

- based decision

- making

• Leadership and Professional development

• Manual Aircraft H andling S kills

• Pilot M onitoring R esponsibilities

o Communication

o Risk management

o Decision making

o Threat and error management

Probability Scores

Base d on NTSB accident reports, AVP assigned each accident a qualitative rating and a

corresponding probability score, which represents the likel ihood that the rule would have

### 62 prevented the accident. 54 

### All scores were reviewed by a 3

- person panel. For part 121 and part

135 operations

, Table 14 shows the categories of qualitative ratings and corresponding scores

and the number of accidents in each ca tegory.

T 

## able 14. FOQ Accident Scoring Summary for FY 2001

- FY 2010

Qualitative Rating Probability

Score No. of

Part 121

Accidents No. of

Part 135

Accidents

None 0 323 31

Low 0.15 1 8 18

Moderate 0.35 5 8

Moderate

- High 0.55 7 0

High 0.75 1 1

Very High 0.90 0 0

Total 354 58



### As the table indicates, AVP has assessed that 31 of 354 part 121 accidents and 27 of 58 part

135 accidents would have had some likelihood of being prevented by the final rule. For these

accidents, the scores range from 0.15 to 0.75, meaning that had the rule been in place the

probability the accidents would have been prevented ranges from 0.15 to 0.75. 55 

### In the following

section we describe three accidents with the highest cost in terms of fatalities, injuries, aircraft

destru ction, or damage. The avoidance of these accidents provides most of the rule benefits. In

Appendix 1, we describe several accidents that received the highest scores of 0.75 or 0.55

.

54 “An Assessment of the Effectiveness of Public Law 11 1

- 216 in Reducing Accident Risk. ” Federal Aviation Administration. Office of Accident Investigation and Prevention (AVP), November 9, 2012.

55 The FAA will issue multiple rules to address the same accident. In these cases the sum of probabilities wil l not exceed one. To date Pilot Rest & Duty (77 FR 55852, Jan. 4, 2012) and FOQ (Final rule forthcoming) are the only rules both addressing the following accidents: Corporate Airlines, Kirksville, MO, 10/19/04; Colgan Air, Buffalo,
NY, 02/12/09; Great Lake s, Laramie, WY, 06/20/07.The FAA will note the cumulative sum of probabilities across rules with each forthcoming rule.

### 63 Description of Accidents with the Highest Expected Accident Costs

In thi s section

, we provide a description of the three accidents with the highest expected accident

costs. The avoidance of accidents such as these provides most of the benefits of the rule.

Corporate Airlines Crash at Kirksville, Missouri, October 19, 2004 (Pro bability Score = 0. 15 )

On October 19, 2004, a BAE Systems BAE

- J3201 operated by Corporate Airlines struck

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

Kirksville, Missouri. The two pilots and 11 of 13 passengers were killed. The two surviving

passengers received serious injuries and the aircraft was destroyed.

The airplane struck trees short of the runway threshold after the flight crew continued an

un st abiliz ed approach below the minimum d escent a ltitude (MDA) without adequate visual

reference of the runway environment . The crew failed to follow FAA regulations for non

precision approach procedures and failed to implement proper division of duties between the

flying pilot and the pilot mon itoring. The NTSB determined from the cockpit voice recorder

(CVR) that both pilots were looking outside the cockpit window for the runway when they

reached the MDA, which meant that no one was monitoring the airplane’s altitude. The NTSB

also determined t hat the crew engaged in unprofessional, non

- essential conversation during the

approach, which was a violation of sterile cockpit rules that prohibit such activity during flight

below 10,000 feet.

The NTSB determined that the probable cause of the accident was the pilots’ failure to (1)

follow established procedures, (2) properly conduct a non

- precision approach, and (3) adhere to

established division of duties between the flying and non

- flying pilot. Contributing factors to the

accident were the pilots’ fai lure to make standard callouts, failure to establish a professional

demeanor and adhere to sterile cockpit rules, and fatigue. The PIC had 4,234 hours total flight

### 64 time and the SIC 2,856 hours. All the causal and contributing factors of this accident ident ified

by the NTSB are being addressed in the training required by the ATP CTP. Had the flightcrew

been required to complete the ATP CTP and had the SIC been type rated in the airplane, it is

possible that the accident might have been prevented. We believe that the type rating would

have helped because t he type rating raises the bar by requiring an SIC to train to the same level

of aircraft handling proficiency as the PIC. The qualitative assessment that will now be

accomplished by an inspector or designee provides an additional level of oversight to the

checking event performed. Because this is an FAA certification event , there are greater

expectations placed on the SIC ’s performance

.

Crash of Colgan Air at Buffalo, NY, F ebruary 12, 2009 (Probability Score = 0. 20 )

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 about five miles short of the runway after

the PIC lost control of the aircraft, killing the PIC, SIC, two flight attendants, and all passengers.

O ne person on the ground was also killed and the airplane was destroyed.

According to the NTSB final report, the probabl e cause of the accident was the PIC’s

“inappropriate response to activation of the stick shaker, which led to an aerodynamic stall from

which the airplane did not recover.” 56 

### 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 displa ys

56 National Transportation Safety Board. 2010. Accident Report: Loss of Control on Approach, Colgan Air, Inc.
Operating as Continental Connection Flight 3407, Bombard ier DHC

- 8

- 400, N200WQ, Clarence Center, New York, February 12, 2009 , p. x. NTSB : Washington, DC.

### 65 (PFDs) 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 resp onsibilities and workload

management.” 57 

### The PIC’s poor response suggests he was surprised 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

SIC 2,244 hours.

The causal and contributing factors identified by the NTSB and discussed here are all key

focus areas of the training in the ATP CTP. Had the flightcrew been required to complete the

ATP CTP and the SIC been typed rated in the airplane, this accident might have been prevented.

Avjet Crash at Aspen, Colorado, March 29, 2001 (Probability Score = 0.35)

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

Corporat ion, crashed about 2,400 feet short of the runway threshold while on final approach to

Aspen

- Pitkin County Airport (ASE), Aspen, Colorado. The PIC

, SIC , flight attendant, and all 15

passengers were killed and the aircraft was destroyed.

According to the NT SB report, the probable cause of the accident was “the flight crew’s

operation of the airplane below the minimum descent altitude without appropriate visual

reference for the runway.” 58 

### The captain did not arrest the descent at the MDA and the first

office r did not challenge him. Contrary to the company operations manual, the captain did not

brief the instrument approach procedure to the landing runway or the missed approach

procedure. The captain failed to brief despite ATC advising the pilots of deteriora ting weather

57 Colgan A ccident Report, p. 85

58 National Transportation Safety Board. n.d. Aircraft Accident Brief: DCA01MA034, Avjet Corporation, Gulfstream III, N303GA, Aspen Colorado, March 29, 2001, p. 41.

### 66 and that three of the preceding arrivals had conducted missed approaches and despite the fact

that he discussed the possibility that the airplane might have to go to the alternate airport because

of a landing restriction and fuel status. Thus, the flight crew was unprepared to execute the

airport’s instrument and missed approach procedures. The crew also failed to follow FAA

regulations for non

- precision approach procedures and sterile cockpit rules below 10,000 feet.

And the crew failed to imp lement proper division of duties between the flying pilot and the non

flying pilot

, as both pilots were looki ng out the cockpit window for the airport so that n either one

was monitoring the airplane’s pos ition vertically. The NTSB also concluded that the p resence of

a passenger in the flight deck jump seat may have increased the pressure on the captain not to

divert to the alternative airport. The FAA did not require CRM training for part 135 operators

and the training manual did not contain a CRM training module. The PIC had 9,900 hours total

flying time and the SIC 5,500 hours. Despite the considerable flight time and experience that

both pilots had , if they had received training earlier in their careers

, particularly i n the ATP CTP

areas of CRM, energy ma nagement, knowledge

- based decision making, leadership and

professional development, this accident might have been prevented.

Estimating the Safety Benefits of the Final Rule

Calculation of expected safety benefits begins with the calculation of full accide nt costs,

which are based on past accident history, the values of future fatalities and of future injuries

sustained

, and the cost of airplane damage or destruction. Full accident cost is determined by the

number of fatalities and injuries multiplied by th eir respective valuations, and the cost of airplane

damage and destruction. We multiply theses potential costs by the average accident probability

score to obtain the rule

- related “Expected Accident Costs

. ” The expected accident costs are the

### 67 costs that we , on average, expect to avoid with the rule in place, and therefore are an estimate of

the expected benefits of the rule.

The valuation of averted fatalities and injuries is provided in a 2013 Office of the Secretary

of Transportation (OST) memorandum 59 

### . These 2010 values are summarized in Table 15 below

,

along with ass ociated medical and legal costs 60 

### :



## Table 15 . Value of a Statistical Life and Prevented Injuries ($ 2010)

AIS

Code Injury Level Fraction of

VSL Value of

Prevented

Injury Medical & Legal Co sts Total Value Cost of

NTSB

"Serious"

Injury

AIS 1 Minor 0.0030 $ 26,580 $ 3,078 $ 29,658

AIS 2 Moderate 0.0470 $ 416,420 $ 8,742 $ 425,162

AIS 3 Serious 0.1050 $ 930,300 $ 26,103 $ 956,403 $ 1,291,911

AIS 4 Severe 0.2660 $ 2,356,760 $ 137,409 $ 2,494,169

AIS 5 Critical 0.5930 $ 5,253,980 $ 369,378 $ 5,623,358

AIS 6 Fatal 1.0000 $ 8,860,000 $ 163,388 $ 9,023,388



### As the table indicates, OST estimate s the value of a statistical life ( VSL ) to be $ 8.86 million

in 2010 . Shown in the “Fraction of VSL” column are relative value coefficients for preventing

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

the VSL to determine the value of a prevented injury by AIS code. Addin g medical and legal

costs, we obtain the total value of avoiding fatalities or injuries by injury level or fatality. As the

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

and Plans calculates NTSB’s “Seriou s” injury category as the average of AIS categories, 2

- 4.

59 Memorandum: Guidance on Treatment of the Economic Value of a Statistical Life in Department Analyses. [February 2013]. United States, Office of the Secretary of Transportation. We use the VSL stipulated by the OST memorandum for analyses with a base year of 2010 ($8.86 million).

60 Economic Values for FAA Investment and Regulatory Decisions, a Guide , p. 2

- 2 to 2.4. Office of Aviation Policy

and Plans, U.S. Federal Aviation Admin istration, Washington, DC, Final Report, Revised October 3, 2007. The
values in this section are for 2001. We updated these values 2001 to 2010 by the 

### CPI

- U price relative for 2010
compared to 2001 (218.056/177.1 = 1.23126).

### 68 The value of rule

- related accident airplanes and the cost of restoring damaged airplanes are

shown by category of airplane in Appendix 2.

Using the data from Table 15 and Appendix 2, we can estimate accident cost. Table 1 6

summarizes our estimation of the cost of past accidents that would have had som e likelihood of

being prevented had the rule been in effect in the period 2001

- 2010

.



## Table 1 6

. Summary of Estimated Cost of FOQ Rule

- Related Accidents

FY 2001

- 2010 ($ 2010)

Operations No. of

Accidents Fatal

ities Serious Injuries Minor Injuries Full Cost of Fatality/

Injuries ($ mil.) Full Amt

of AP
Dmge ($ mil.) Full

Accident

Cost ($ mil.) Wtd Ave.

Rule

Effect

iveness ($ mil.) Expected

Accident

Cost ($ mil.) Expected

Cost of

Fatalities/ Injuries Expected

Amt of AP

Dmge

Part 121 31 65 14 37 $ 605.7 $ 76.8 $ 682.5 0.2071 $ 141.4 $ 122.3 $ 19.0

Part 135 27 34 14 7 $ 325.1 $ 105.1 $ 430.2 0.3224 $ 138.7 $ 106.3 $ 32.4

Total 58 99 28 44 $ 930.8 $ 181.9 $ 1,112.7 0.2517 $ 280.0 $ 228.6 $ 51.4

Note. Due to rounding, details may not add up to row or column totals or multiply to products



### .

For part 121 and part 135 operations separately, we multiply the number of fatalities, serious

injuries, and minor injuries times their respective valuations (including medical and legal costs)

to obtain the “Full C ost of Fatalities/Injuries.” We obtain the “Full Amount of AP Damage” from

the airplane values given in Appendix 2. The sum of the two calculations is the “Full Accident

Cost” given in the next column. For the 58 accidents partially attributable to pilot q ualification

issues, over the 2001

- 2010 ten

- year sample period we estimate the full accident cost to be

$ 1,112.7 million. This full historical accident cost multiplied by the weighted average probability

score across the 58 accidents equals the likely acci dent costs of $ 280.0 million that the FAA

estimate s to be avoidable were the rule in place when the accidents occurred

. The final two

colum ns show the two components of expected a ccident cos t

-- the expected cost of fatalities and

injuries and the expected amount of airplane damage. These two components will be used to

### 69 calculate the expected benefits of the rule. Appendix 3 shows the calculations by individual

accident.

Without additional informat ion, we use this historical record as our best estimate of what will

happen in the future. Recognizing the random nature of accidents, however, w e assume the

chance of an accident is equally likely in any year of the 10

- year estimation period (uniform

dist ribution), for an average expected societal cost of $ 22.86 million per year from fatalities and

injuries and $5. 14 million from airplane damage

. With the rule in place , these projected rule

related accident costs become, as avoided costs, benefits of the r ule. In additional to providing a

current estimate of the VSL, the 201 3 OST M emorandum provides the additional information

that the benefits of avoided fatalities and injuries should be adjusted for a changing VSL over

time due to changing real income. Usi ng VSL growth factors of 0.98246 and 0.99702 for 2011

and 2012, 61 

### and the OST VSL growth factor thereafter

, we project the benefits of avoided

fatalities and injuries forward to and through the estimation period, 2013

- 2032

. 62



### These results are shown in Table 17 below, along with the corresponding calculations for the

VSL. The value of avoided airplane d amage is constant at $5. 14 million. The sum of the

expected value of avoided fatalities and injuries

, and the expected value of avoided airplane

damage is the total societal value of averted future accidents, or Safety Benefits. Discounting the

safety benefits by the 7% discount factor yields the present value safety benefits. As the table

shows, safety benefits total $ 576.8 milli on with present value safety benefits of $ 251.7 million.

Part 121 safety benefits , not shown in the table, are $ 291.5 million, with present value $ 127.5

million, and part 135 safety benefits are $ 284.3 million, with present value $ 124.2 million, as we

61 http://www.dot.gov/sites/do t.dev/files/docs/VSL%20Guidance%202013.pdf

.

62 Benefits are not calculated for 2013 since the compliance deadline for the final rule’s ATP CTP requirement has

been extended until 2014.

### 70 saw previously in Table 1C. The allocation of safety benefits between part 121 and part 135 is

most easily calculated using the part 121 and part 135 accident cost figures in Table 16

.



## Table 1 7 . Estimated Safety Benefits of Final Rule,

2013

- 2032 ($ 2010)

Year VSL ($
mil.) Value of

Avoided

Fatalities/ Injuries ($ mil.) Value

of

Avoided Airplane
Damage ($ mil.) Safety

Benefits ($ mil.) PV Safety

Benefits ($ mil.)

2010 $ 8.86 $ 22.9 $ 5.14

2011 $ 8.7 $ 22.5

2012 $ 8.7 $ 22.4

2013 $ 8.8

2014 $ 8.9 $ 22.9 $ 5.1 $ 28.0 $ 21.4

2015 $ 9.0 $ 23.1 $ 5.1 $ 28.3 $ 20.2

2016 $ 9.1 $ 23.4 $ 5.1 $ 28.5 $ 19.0

2017 $ 9.2 $ 23.6 $ 5.1 $ 28.8 $ 17.9

2018 $ 9.3 $ 23.9 $ 5.1 $ 29.0 $ 16.9

2019 $ 9.3 $ 24.1 $ 5.1 $ 29.3 $ 15.9

2020 $ 9.4 $ 24.4 $ 5.1 $ 29.5 $ 15.0

2021 $ 9.6 $ 24.6 $ 5.1 $ 29.8 $ 14.2

2022 $ 9.7 $ 24.9 $ 5.1 $ 30.1 $ 13.3

2023 $ 9.8 $ 25.2 $ 5.1 $ 30.3 $ 12.6

2024 $ 9.9 $ 25.4 $ 5.1 $ 30.6 $ 11.9

2025 $ 10.0 $ 25.7 $ 5.1 $ 30.9 $ 11.2

2026 $ 10.1 $ 26.0 $ 5.1 $ 31.1 $ 10.5

2027 $ 10.2 $ 26.3 $ 5.1 $ 31.4 $ 9.9

2028 $ 10.3 $ 26.6 $ 5.1 $ 31.7 $ 9.4

2029 $ 10.4 $ 26.8 $ 5.1 $ 32.0 $ 8.8

2030 $ 10.5 $ 27.1 $ 5.1 $ 32.3 $ 8.3

2031 $ 10.6 $ 27.4 $ 5.1 $ 32.6 $ 7.9

2032 $ 10.7 $ 27.7 $ 5.1 $ 32.8 $ 7.4

Totals

-- 2013

- 2032 $ 479.2 $ 97.7 $ 576.8 $ 251.7

Note: Due to rounding, d etails may not add up to totals and factors may not multiply to products.

### 71 Cost

- Benefit Sensitivity Analysis using Low and High Values of VSL

The Department of Transportation requires a VSL sensitivity analysis with low and high VSL

values. 63 

### For our 2010 base year we use a low value of $5.01 million and a high value of $12.53

million. For part 121 operators we find that the rule is not cost benefici al under the low VSL

value of $5.01 million , with present value safety benefits of $ 82.9 million less than present value

costs of $ 124.6 million

. For part 135 operators, however, the rule remains cost beneficial with

present value safety benefits of $ 83

. 3 million greater than present value costs of $ 9.8 million. For

the high VSL value of $12.53 million, part 121 present value safety benefits are $ 172.3 million

and part 135 present value safety benefits are $164. 0 million.

Discussion of Credit for Academic Courses

Within the limits of the statute the FAA made a safety determination that not meeting the

1,500 hours of flight time could be done based on academic coursework. The cost savings of that

determination are reflected in this regulatory determination. The crediting provisions in the rule

were based on a crediting system recommended by the industry in its ARC report and at the time,

supported by t he best data currently available

, Phase I of the Pilot Source Study, which was

conducted by academic institutions using data from regional airlines. That study indicated that

the most successful candidates in air carrier training were pilots who had 500

- 1, 000 hours of

total flight time

. Phase III of the Pilot Source Study was completed in 2012 and the results of the

study were submitted to the docket for FAA to consider in the final rule stage. This phase of the

study had an independent peer review that con curred with the researcher’s findings. This phase

of the study found that the most successful pilots in training were those with 1,001

- 1,500 hours

63 Memorandum: Guidance on Treatment of the Economic Value of a Statistical Life in Department Analyses. [February 2013]. United States, Office of the Secretary of Transportation. The memorandum gives low and high values of $5.2 million and $12.9 million for the 2012 base year only. The 2010 base year values used here were supplied by OST, http://www.dot.gov/sites/dot.dev/files/docs/VSL%20Guidance%202013.pdf

.

### 72 of total flight time. 64 

### The lack of additional data on the precise relationship/interaction between

flight hou rs and training and safety outcomes and the small number of accidents in the time

period analyzed did not support a further reduction beyond that in the final rule ; therefore

, cost

savings for alternative levels of crediting were not calculated.

Cost an d Benefits Summary of the Final Rule

This final rule implements the mandate of the Airline Safety and Federal Aviation Extension

Act of 2010, Pub.L. 111

- 2 16, provides some mitigation of the cost of the statute’s provisions,

and will implement a training pr ogram in response to Congressional direction

. We estimate $6.4

billion ($2.2 billion in present value) to be the cost of t he Congressionally

- mandated self

executing requirement that all part 121 SICs have an ATP certificate with at least 1,500 flight

hours

. The FAA found no quantifiable relationship between the 1,500

- hour requirement and

airplane accidents because all part 121 PICs have an ATP certificate and 1,500 flight hours, and,

in most accident cases, the SICs had 1,500 flight hours. Very importantly, because the 1,500

-

hour requirement will become law regardless of FAA action, the costs for this requirement do

not require an FAA benefit justification for such costs. Congress allowed, and the final rule

provides, cost

- savings benefits from the rule’s pr ovision for academic training credits (including

credit for military training) toward the 1,500

- hour requirement. The final rule also provides cost

savings by reducing the minimum age requirement for pilots with 1,500 flight hours to 21 years.

The cost sav ings that result from these provisions are $2.3 billion, with a present value of $0.8

billion. This results in a $1.4 billion present value cost of the 1,500

- hour and minimum

- age

requirements over 20 years.

64 www.regulations.gov ; FAA

- 2010

- 0100

- 1801

### 73 T he costs of the final rule training requiremen ts for ATP certificate applicants and the

airplane type rating requirement total $ 312.7 million ($ 138.7 million in present value). The

expected benefits from the new training requirements are $ 576.8 million

, with a present value of

$ 251.7 million. F or part 121 o perators the final rule is cost

- beneficial as present value benefits, at

$ 127.5 million, exceed present value costs, at $ 124.6 million. F or part 135 operators present

value benefits, at $ 124.2 million , exceed present value costs, at $ 9.8 million, A lt hough the FAA

does not have a quantitative estimate of benefits for part 91, subpart K, operators, for the reasons

discussed previously, we believe that the ATP training program will sufficiently enhance safety

for part 91, subpart K operators to make the rule cost

- beneficial for these operators as well.

In summary, t he purpose of this final rule is to meet pilot certification and qualification

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

Aviation Extension Act of 2010. These sections of t he Act had their genesis in the crash of

Colgan Air Flight 3407 that occurred outside of Buffalo, New York, on February 12, 2009,

destroying the airplane, damaging residential homes, and resulting in 50 fatalities. Congress

mandated the ATP certificate requirement

-- the most expensive requirement of this final rule

,

$6.4 billion ($2.2 billion in present value). Congress did allow the FAA to permit academic

training credits (by means of the R

- ATP) towards the total flight time of 1,500 hour, which

results in cost savings of $2.0 billion ($0.7 billion in present value ) that partially offset the 1,500

-

hour requirement. The final rule also partially offsets the requirement by reducing the R

- ATP

minimum age requirement for pilots with 1,500 hours to age 21. This relief provides an

additional cost savings of $0.3 billion ( $0.1 billion in present value). T he costs of the final rule

training requirements for ATP certificate applicants and the airplane type rating requirement total

$ 312.7 million ($ 138.7 million in present value) with expected benefits of $ 576.8 million

### 74 ( $ 251. 7 million in present value)

. The total cost resulting from the statute plus the cost savings

and the present value cost of the rule equal $1.6 billion with benefits of about $250 million. The

FAA action provided discretionary cost savings and met the sa fety intent by issuing a final rule

where the safety benefits exceeded the cost.

### 75 

# Table 18

STATUTORY COSTS AND BENEFITS /

FINAL RULE COST SAVINGS, COSTS, AND BENEFITS

Statute Costs Total Cost ($ mil.) PV Cost ($ mil.)

Part 121 ATP Certificate Requirement $ 6,374.4 $ 2,21 3

. 0

Statute Benefits Total Benefit PV Benefit

Part 121 ATP Certificate Requirement No Identifiable Accident

Benefits



### Discretionary Cost Savings Total Cost Savings ($ mil.) PV Cost Savings ($ mil.)

Academic Training and Experience Credits $ <2,309.3> $ <789.8>

Rule Additional Provision Costs Total Cost ($ mil.) PV Cost ($ mil.)

ATP CTP and Type Rating Total Costs $ 312.7 $ 138.7

Rule Additional Provision Benefits Total Benefit ($ mil.) PV Benefit ($ mil.)

All Safety Benefits $ 576.8 $ 251.7

Total Cost

($ mil.) PV Cost ($ mil.)

Total Cost of Statute Cost + Cost Savings + Rule Cost $ 4,377.8 $ 1,561. 9

Total Benefit ($ mil.) PV Benefit ($ mil.)

Total Benefits from Statute + Rule $ 576.8 $ 251.7

### 76 

## APPENDIX 1

- Description of FOQ Accidents with High Probability Scores

For accidents with the highest sample probability scores of 0.75 or 0.55, the benefits of the rule

should be most clearly highlighted. We now describe one accident with a probability score of

0.75 and three accidents with probability scores of 0.55.

Mesa Airlines Accident at Roanoke Regional Airport, Oc tober 16, 2001 (Probability Score

= 0.75)

On October 16, 2001 at 2114, an ERJ

- 145 operated by Mesa Airlines suffered a hard landing

at Roanoke Regional Airport. The SIC later reported a quartering crosswind at 15 mph, gusting

to 21 mph. On approach to runw ay 33 the PIC briefed that takeoffs were not authorized on 33

during night and IFR operations owing to high terrain and, therefore, go

- around was not an

option. The first officer knew this conclusion was incorrect but did not challenge the captain.

(The ca ptain later described the SIC as passive and quiet.) The SIC reported the approach as

normal until 300 feet above ground, when she called " one dot high " “ Ref + 5 ” (5 mph above

“reference speed” for the landing). The PIC pulled the thrust levers to idle. At 200

- 300 feet the

SIC called Ref

- 5 and Ref

- 10, but stopped when the PIC failed to respond to her callouts.

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

approaching a stall). The PIC added power, but the aircr aft landed hard before engines could

spool up

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

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

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

failure of both pilots to follow company CRM and flight manual procedures, and the PIC's

improper approach briefing.

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

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

200 hours in aircraft type . The commercially

- rated SIC had 1,850 hours, with 90 hours in aircraft

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

She had accrued 600 hours as an SIC in the BE

- 1900 and, based on seniority, qualified for

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

1900, and, based on seniority, then upgraded to the ERJ as an SIC. Neither pilot had any prior

experience in swept

- wing aircraft, nor had the carrier provided any jet traini ng on swept

- wing

aerodynamics.

The Mesa Airlines accident would likely have been prevented by this rule’s emphasis on

additional flight experience to qualify for 121 operations and to upgrade to PIC, as well as the

ATP CTP’s emphasis on foundational training in CRM, multicrew operations, pi lot monitoring

responsibilities, energy management, aerodynamics, and stall recognition and recovery.

USA Jet Crash at Saltillo, Mex ico, July 6, 2008 (Probability Score = 0.55)

On July 6, 2008, a DC

- 9

, operated by USA Jet on a cargo flight

, crashed in he avy fog while

on approach in mountainous terrain to Saltillo, Mexico. The PIC was killed and the SIC seriously

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

the glide slope and left and right of the loca lizer throughout the approach. The aircraft ultimately

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

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

75 hours as a Part 121 pilot. A more experienced SIC who had completed the ATP CTP, with its

focus on CRM, pilot monitoring responsibilities, energy management, and stall recognition may

### 78 well have called for a go

- around or may have been willing to intervene and increase the thrust

,

either action of which would have averted the accident.

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

Score = 0.5 5)

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

bounced in visual meteorological conditions (VMC ) at Laramie Regional Airport. No injuries

occurred to the 2 pilots and 9 passengers, but the a ircraft was substantially damaged. The crew

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

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

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

“one dot high” on the glide slope.

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

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

important factor in the accident was improper cre w resource management (CRM), in particular

the SIC's failure to intervene. The PIC had 2,250 hours of pilot experience and the SIC had 774

hours. Th is rule would hav e required additional experience, seasoning in an air carrier

environment, and the ATP CTP ’s training in leadership, CRM

, energy management and

knowledge

- based decision making . This additional experience and training may have led the PIC

to go around upon recognizing an unstable approach or could have led the SIC to intervene.

Air Tahoma Crash at Florence, KY, August 13, 2004 (Probability Score = 0.5 5)

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

crashed on approach t o the Cincinnati/Northern Kentucky International Airport (CVG)

. The SIC

### 79 was killed, the P IC seriously injured , and the airplane destroyed. The PIC had exactly 2,500

hours and the SIC had 924 hours as a pilot

, 65 

### the majority of which had been in single

- engin e

airplanes. The SIC had just three months of experience as an air carrier pilot.

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

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

. I don't know

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

It’s really funny. I got something all messed up here." Prior to take off the PIC had violated

company procedures and Federal regulations in not l eaving a load manifest at the departure

station. He stated in post

- accident interviews that he had not done so because he had not

completed the airplane’s weight and balance prior to takeoff. The NTSB noted that according to

the captain’s incorrect weight and balance calculations, the airplane was not within takeoff limits

and, therefore, the captain should not have allowed the airplane to take off, although the correct

calculations shown that, in reality the airplane’s weight and balance were within limits . During

the flight the captain became preoccupied with trying to identify the mistake and “did not

respond to the first officer’s first five comments regarding the airplane’s unusual handling

characteristics, which occurred over a period less than 6 minut es” (AVP panel). The PIC

eventually recognized and advised the SIC that they (ironically) had a fuel imbalance because the

PIC, as the nonflying pilot, left the cross

- feed open. This caused a prohibited fuel transfer

because the PIC had not followed compan y procedures in closing the shutoff value for the right

fuel tank . The SIC then stated that "we're going to flame out," but the PIC responded, "I got the

cross

- feed open. Just keep power on." But, despite adequate fuel, the aircraft lost power due to

fuel starvation and crashed one mile short of the runway. As found by the NTSB:

65 

### The SIC was credited with 1424 hours owing to a credit of 500 hours as a result of 1,500 hours experience as a flight engineer.

### 80 “during the airplane’s descent to landing, the fuel in the left fuel tank, which was providing fuel to both engines [because of the cross

- feed] was exhausted because both engine

- dr iven fuel pumps drew air from the left tank into the fuel system instead of fuel from the right tank, resulting in a dual

- engine flameout (p. 33)” 66



### The NTSB found that the probable cause of the accident was “fuel starvation resulting from

the captain’s de cision not to follow approved fuel cross

- feed procedures” (p. 38). The captain’s

distraction with his weight and balance calculations led to his negligence in not responding to the

first officer’s concerns about the airplane’s abnormal handling characteris tics. The NTSB also

found the flight crew’s failure to monitor the fuel gauges as a contributing factor to the accident.

Both pilots would have benefited from the additional flight experience and foundational

training in the ATP CTP required by th is rule. That additional flight experience and foundational

training, especially in risk management, knowledge

- based decision making, and pilot monitoring

responsibilities may have enabled the SIC to identify a lateral center

- of

- gravity (CG) problem

caused by a fue l imbalance. It also may have led the PIC to respond with some urgency when he

finally recognized a fuel imbalance and the possibility of fuel starvation caused by his failure to

follow approved cross

- feed procedures.

66 National Transportation Safety Board. 2006. Aircraft Accident Report: Crash During Approach to Landing, Air Tahoma, Inc., Flight 185, Convair 580, N586P, Covington, Kentucky, August 13, 2004. NTSB: Washington, D.C.

### 81 

## APPENDIX 2

-- Estimated Market Value of Air Carrier Aircraft ($ 2010)

Airplane Category PAX Airplanes Cargo Airplanes

No. of

APs Wtd Ave

2010 Mkt

Value ($ mil.) No.

of

A p s Wtd Ave

2010 Mkt

Value ($ mil.)

Two

- Engine Narrow Body 3,283 $ 17.28 156 $ 11.11

Two

- Engine Wide Body 476 $ 43.62 272 $ 21.47

Three

- Engine Narrow Body 6 $ 0.54 140 $ 0.94

Three

- Engine Wide Body 18 $ 11.05 208 $ 24.01

Four

- Engine Narrow Body 0 NA 67 $ 2.66

Four

- Engine Wide Body 50 $ 44.19 102 $ 29.35

Regional Jet under 70 Seats 1,337 $ 8.67 NA NA

Regional Jet 70 to 100 Seats 522 $ 19.56 NA NA

Turboprop under 20 seats (Pt 23) 48 $ 0.88 NA NA

Turboprop under 20 seats (Pt 25) 177 $ 1.35 NA NA

Turboprop with 20 Seats or More 384 $ 4.52 NA NA

Piston Engine (Pt 23) NA NA NA NA

All Airplanes 6,301 $ 16.46 945 $ 16.79

Sources: 1. Table is an APO update to 2008 of 2003 data in Economic Values for FAA Investment and Regulatory

Decisions, a Guide , pp. 5

- 1

-- 5.6. Office of Aviation Policy and Plans, U.S. Federal Aviation Administration, Washingto n, DC, Final Report, Revised October 3, 2007. Online at www.faa.gov, Regulation & Policies, Policy &
Guidance, Benefit

- Cost Analysis, Economics Values for FAA Investment and Regulatory Decisions, Final Report,
Revised October 3, 2007.

2. Aircraft Numbers: Fleet database, OAG Aviation Solution, 3025 Highland Pkway, Suite 200, Downers Grove, Il

60515.

3. Aircraft Market Values: Airliner Price Guide , vol. 72, July, 2008. Herndon, Va.

4. The 2008 dat a is updated from 2008 to 2010 by the GDP implicit price defla tor for 2010 compared to 2008
(13,063.0/13,161.9) = 0.9925). Source: Bureau of Economic Analysis, www.bea.gov, "National" tab, "Current

Dollar and 'Real' GDP" link, 16 Nov. 2012.

5 . Restoration costs are estimated as 13% of airplane values for passenger airplanes and 15% for cargo airplanes (Economic Values, p. 5

- 5). 6. Estimated market values for jets used in Part 135 operations are from Economics Values, Table 5

- 7, p. 5

- 9, updated from 2003 to 2010 by the GDP implicit price deflator for 2010 compared to 2008 (13,063.0/ /11,836.4) =
1.1036).

7 . Restoration costs for jets used in Part 135 operations are estimated as 16% for Part 25 jets weighing < 65,000 lbs and 2% for Part 25 jets weighing > 65,000 lbs. (Economic Values, Table 5

- 10, p. 5

- 12).

8. Details ma y not add to totals due to rounding.

### 82 

## APPENDIX 3

— FOQ Accidents, Fiscal Year s 2001

- 2010
Part 121 FOQ Acciden ts

Date Carrier Airplane Category Airplane

Value ($ mil.) Operations Type Fatal

ities Serious Injuries Minor Injuries Full Cost of Fatality/ Injury ($ mil.) AP
Dmge

Code Full

Amt of

AP
Dmge ($ mil.) Full

Accident

Cost ($ mil.) Prob

ability

Score Expected

Accident

Cost ($ mil.)

04/28/04 Centurion Air Cargo 3

- Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $

- 1 $23.83 $ 23.83 0.15 $ 3.57

08/13/04 Air Tahoma Turboprop < 20 Seats (pt 25) $ 1.35 Part 121 Cargo 1 1 0 $ 10.32 1 $ 1.34 $ 11.66 0.55 $ 6.41

08/30/04 Custom Air Transport 3

- Engine Narrow Body $ 0.94 Part 121 Cargo 0 0 0 $

- 0.15 $ 0.14 $ 0.14 0.35 $ 0.05

09/19/04 FedEx 3

- Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $

- 0.15 $ 3.57 $ 3.57 0.15 $ 0.54

06/07/05 UPS 3

- Engine Wide Body $ 24.01 Part 121 Cargo 0 0 0 $

- 0.15 $ 3.57 $ 3.57 0.15 $ 0.54

05/16/08 Asia Pacific Airlines 3

- Engine Narrow Body $ 0.94 Part 121 Cargo 0 0 0 $

- 0.15 $ 0.14 $ 0.14 0.35 $ 0.05

07/06/08 USA Jet 2

- Engine Narrow Body $ 11.11 Part 121 Cargo 1 1 0 $ 10.32 1 $11.03 $ 21.34 0.55 $ 11.74

01/27/09 Empire Turboprop <2 0 Seats (pt 25) $ 1.35 Part 121 Cargo 0 1 1 $ 1.32 1 $ 1.34 $ 2.66 0.15 $ 0.40

10/22/00 Frontier Flying Ser Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 0 $

- 0.13 $ 0.58 $ 0.58 0.35 $ 0.20

11/20/00 Atl So East Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 1 0 $ 1.29 0 $

- $ 1.29 0.55 $ 0.71

02/10/01 Great Lakes (as United Express) Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 7 $ 0.21 0.13 $ 0.58 $ 0.79 0.55 $ 0.43

10/16/01 Mesa (US Airways Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.75 $ 0.84

04/18/02 ATA 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 2 10 $ 2.88 0 $

- $ 2.88 0.15 $ 0.43

06/16/02 Vanguard 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $

- 0.13 $ 2.23 $ 2.23 0.15 $ 0.33

01/06/03 ExpressJet (Continental Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.55 $ 0.62

05/24/03 Southwest 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $

- 0.13 $ 2.23 $ 2.23 0.15 $ 0.33

11/14/03 United 4

- Engine Wide Body $ 44.19 Part 121 Pax 0 0 0 $

- 0.13 $ 5.70 $ 5.70 0.15 $ 0.86

05/09/04 American Eagle Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 13 $ 0.39 0.13 $ 0.58 $ 0.97 0.35 $ 0.34

10/19/04 Corp. Airlines (American Connection) Turboprop 20+ Seats $ 4.52 Part 121 Pax 13 2 0 $ 119.89 1 $ 4.49 124.37 0.1 5 $ 18.66

04/29/05 Southwest 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 1 0 $ 1.29 0 $

- $ 1.29 0.15 $ 0.19

05/31/05 Air Wisconsin (as United Express) Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 1 0 $ 1.29 0 $

- $ 1.29 0.15 $ 0.19

09/18/05 Spirit 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 0 0 $

- 0.13 $ 2.23 $ 2.23 0.15 $ 0.33

07/24/06 American Eagle Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.15 $ 0.17

04/12/07 Pinnacle as NoWest Airline Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.15 $ 0.17

06/20/07 Great Lakes Turboprop 20+ Seats $ 4.52 Part 121 Pax 0 0 0 $

- 0.13 $ 0.58 $ 0.58 0.55 $ 0.32

12/16/07 Air Wisconsin Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.15 $ 0.17

08/14/08 Trans States as American Connection Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 0 0 $

- 0.13 $ 1.12 $ 1.12 0.55 $ 0.62

02/12/09 Colgan Air Turboprop 20+ Seats $ 4.52 Part 121 Pax 50 0 0 $ 451.17 1 $ 4.49 $455.66 0.20 $ 91.13

05/06/09 World Airways 3

- Engine Wide Body $ 11.05 Part 121 Pax 0 1 3 $ 1.38 0.13 $ 1.43 $ 2.81 0.15 $ 0.42

08/27/09 Airtran 2

- Engine Narrow Body $ 17.28 Part 121 Pax 0 1 0 $ 1.29 0 $

- $ 1.29 0.15 $ 0.19

06/28/10 American Eagle Regional Jet < 70 Seats $ 8.67 Part 121 Pax 0 2 3 $ 2.67 0 $

- $ 2.67 0.15 $ 0.40

Note: Details may not multiply to products due to rounding.

### 83 

## APPENDIX 3

-- FOQ Accidents Fiscal Years 2001

- 2010 (cont.)
Part 135 FOQ Acciden ts

Date Carrier Airplane Category Airplane

Value ($ mil.) Operations Type Fatal

ities Serious Injuries Minor Injuries Full Cost of Fatality/ Injury ($ mil.) AP
Dmge

Code Full

Amt of

AP
Dmge ($

mil.) Full

Accident

Cost ($ mil.) Prob

ability

Score Expected

Accident

Cost ($ mil.)

08/28/01 Grand Aire Express Part 25 Jet 65,000 lbs+ $ 24.66 On

- Demand Cargo 0 0 0 $

- 0.02 $0.49 $ 0.49 0.35 $ 0.17

04/08/03 Grand Aire Express Part 25 Jet 65,000 lbs+ $ 24.66 On

- Demand Cargo 0 2 0 $ 2.58 1 $24.66 $ 27.25 0.35 $ 9.54

01/10/07 Airnet Systems Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Cargo 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

02/24/09 Bankair Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Cargo 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

08/30/02 Care Flight International Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Med 1 4 0 $ 14.19 1 $ 7.91 $ 22.11 0.15 $ 3.32

07/02/04 Air Trek Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Med 6 0 0 $

- 1 $ 1.27 $ 1.27 0.15 $ 0.19

12/20/00 Million Air Dallas Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

03/29/01 Avjet Part 25 Jet 65,000 lbs+ $ 24.66 On

- Demand Pax 18 0 0 $ 162.42 1 $24.66 187.08 0.35 $ 65.48

03/25/02 Corporate Flight
Management Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

08/13/02 Corporate Flight

International Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 1 $ 7.91 $ 7.91 0.35 $ 2.77

11/11/03 West Coast Charters Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

02/20/04 Aztec Capital Corporation Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 1 1 $ 1.32 0.16 $ 1.27 $ 2.59 0.35 $ 0.91

03/19/04 AirNet Systems Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

11/28/04 Air Castle Corporation Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 3 3 0 $ 30.95 1 $ 2.77 $ 38.86 0.35 $ 13.60

07/15/05 Aspen Base Operations Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 1 3 $ 1.38 0.16 $ 1.27 $ 2.65 0.15 $ 0.40

01/05/06 Netjets as Executive Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

06/02/06 International Jet Charter Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 2 0 3 $ 18.14 1 $ 7.91 $ 26.05 0.35 $ 9.12

08/23/07 Jet Share US Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 0 0 0 $

- 0.16 $ 1.27 $ 1.27 0.15 $ 0.19

07/31/08 East Coast Jets Part 25 Jet < 65,000 lbs $ 7.91 On

- Demand Pax 8 0 0 $ 72.19 1 $ 7.91 $ 80.10 0.35 $ 28.04

03/13/02 Warbelows Air Ventures TP<20 (pt 23) $ 0.87 Commuter 0 0 0 $

- 0.15 $ 0.13 $ 0.13 0.15 $ 0.02

08/24/02 Cape Smythe Air Service TP<20 (pt 23) $ 0.87 Commuter 0 0 0 $

- 0.15 $ 0.13 $ 0.13 0.15 $ 0.02

07/13/03 Air Sunshine TP<20 (pt 23) $ 0.87 Commuter 2 0 0 $ 18.05 0.15 $ 0.13 $ 18.18 0.15 $ 2.73

04/04/04 Peninsula Airways TP<20 (pt 23) $ 0.87 Commuter 0 0 0 $

- 0.15 $ 0.13 $ 0.13 0.75 $ 0.10

09/17/04 Everts Air Alaska TP<20 (pt 23) $ 0.87 Commuter 0 0 0 $

- 0.15 $ 0.13 $ 0.13 0.15 $ 0.02

02/19/09 Frontier Flying Service TP<20 (pt 23) $ 0.87 Commuter 0 1 0 $ 1.29 0.15 $ 0.13 $ 1.42 0.15 $ 0.21

02/01/10 Cape Air TP<20 (pt 23) $ 0.87 Commuter 0 0 0 $

- 0.15 $ 0.13 $ 0.13 0.15 $ 0.02

03/15/10 Servant Air TP<20 (pt 23) $ 0.87 Commuter 0 2 0 $ 2.58 1 $ 0.87 $ 3.46 0.15 $ 0.52

Note: Details may not multiply to products due to rounding.

## APPENDIX 4

— Cost per Pilot of Eligibility Restrictions

Cost Per Pilot of the Minimum

- Age Requirement under the Statute (2 Year Delay)

Year Age Typical Part

121 Pilot

Career

(3) Total Earnings Typical (Undelayed)

Pilot
(4) Career Path, Part

121 Service Delayed 2 Yrs
(5) Total Earnings,

Part 121 Service

Delayed 2 Yrs
(6) Loss in Total Earnings, 2 Yr Delay
(7) Loss in PV Earnings,

2 Y r Delay
(9)

1 30 FO, Regional $ 30,532 Comm'l Pilot $ 30,532 $

- $

-

2 31 FO, Regional $ 38,131 Comm'l Pilot $ 30,532 $ 7,598 $ 6,636

3 32 FO, Regional $ 41,491 FO, Regional $ 30,532 $ 10,959 $ 8,946

4 33 FO, Regional $ 43,667 FO, Regional $ 38,131 $ 5,537 $ 4,224

5 34 FO, Regional $ 44,967 FO, Regional $ 41,491 $ 3,475 $ 2,478

6 35 Capt, Regional $ 82,091 FO, Regional $ 43,667 $ 38,424 $ 25,603

7 36 Capt, Regional $ 84,527 FO, Regional $ 44,967 $ 39,560 $ 24,636

8 37 FO, Major $ 64,266 Capt, Regional $ 82,091 $ (17,825) $ (10,374)

9 38 FO, Major $ 99,650 Capt, Regional $ 84,527 $ 15,123 $ 8,226

10 39 FO, Major $ 116,376 FO, Major $ 64,266 $ 52,110 $ 26,490

11 40 FO, Major $ 119,338 FO, Major $ 99,650 $ 19,687 $ 9,353

12 41 FO, Major $ 122,230 FO, Major $ 116,376 $ 5,854 $ 2,599

13 42 FO, Major $ 125,424 FO, Major $ 119,338 $ 6,086 $ 2,525

14 43 FO, Major $ 128,750 FO, Major $ 122,230 $ 6,520 $ 2,529

15 44 FO, Major $ 131,692 FO, Major $ 125,424 $ 6,268 $ 2,272

16 45 FO, Major $ 133,328 FO, Major $ 128,750 $ 4,578 $ 1,551

17 46 FO, Major $ 135,312 FO, Major $ 131,692 $ 3,620 $ 1,146

18 47 Capt, Major $ 200,435 FO, Major $ 133,328 $ 67,107 $ 19,854

19 48 Capt, Major $ 202,668 FO, Major $ 135,312 $ 67,356 $ 18,624

20 49 Capt, Major $ 202,668 Capt, Major $ 200,435 $ 2,232 $ 577

21 50 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

22 51 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

23 52 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

24 53 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

25 54 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

26 55 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

27 56 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

28 57 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

29 58 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

30 59 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

31 60 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

32 61 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

33 62 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

34 63 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

35 64 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

Totals $ 5,187,556 

### $ 4,843,285 $ 344,270 $ 157,897

Note: Details may not add up to totals due to rounding

## Cost per Pilot of 1,500

- Hour Requirement under the Rule

-- Pilots with Associate’s Degree & Professional Pilot Major (1/2 Year Delay)

Year Age Typical Part

121 Pilot

Career

(3) Total Earnings Typical (Undelayed)

Pilot
(4) Career Path, Part

121 Service Delayed 1/2 Yr
(5) Total Earnings, Part 121 Ops Career Delayed

1/2 Yr

(6) Loss in Total Earnings, 1/2 Yr Delay
(7) Loss in PV Earnings, 1/2 Yr Delay
( 8 )

1 30 FO, Regional $ 30,532 Comm'l/FO Reg. $ 30,532 $

- $

-

2 31 FO, Regional $ 38,131 FO Reg. $ 34,332 $ 3,799 $ 3,318

3 32 FO, Regional $ 41,491 FO Reg. $ 39,811 $ 1,680 $ 1,372

4 33 FO, Regional $ 43,667 FO Reg. $ 42,579 $ 1,088 $ 830

5 34 FO, Regional $ 44,967 FO Reg. $ 44,317 $ 650 $ 463

6 35 Capt, Regional $ 82,091 FO Reg.,Capt Reg. $ 63,529 $ 18,562 $ 12,369

7 36 Capt, Regional $ 84,527 Capt Reg. $ 83,309 $ 1,218 $ 759

8 37 FO, Major $ 64,266 Capt Reg./FO Mjr $ 74,397 $ (10,131) $ (5,896)

9 38 FO, Major $ 99,650 FO Mjr $ 81,958 $ 17,692 $ 9,623

10 39 FO, Major $ 116,376 FO Mjr $ 108,013 $ 8,363 $ 4,251

11 40 FO, Major $ 119,338 FO Mjr $ 117,857 $ 1,481 $ 704

12 41 FO, Major $ 122,230 FO Mjr $ 120,784 $ 1,446 $ 642

13 42 FO, Major $ 125,424 FO Mjr $ 123,827 $ 1,597 $ 663

14 43 FO, Major $ 128,750 FO Mjr $ 127,087 $ 1,663 $ 645

15 44 FO, Major $ 131,692 FO Mjr $ 130,221 $ 1,471 $ 533

16 45 FO, Major $ 133,328 FO Mjr $ 132,510 $ 818 $ 277

17 46 FO, Major $ 135,312 FO Mjr $ 134,320 $ 992 $ 314

18 47 Capt, Major $ 200,435 FO Mjr/Capt Mjr $ 167,873 $ 32,562 $ 9,634

19 48 Capt, Major $ 202,668 Capt, Major $ 201,551 $ 1,116 $ 309

20 49 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

21 50 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

22 51 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

23 52 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

24 53 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

25 54 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

26 55 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

27 56 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

28 57 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

29 58 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

30 59 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

31 60 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

32 61 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

33 62 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

34 63 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

35 64 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

Totals $ 5,187,556 $ 5,101,488 $ 86,068 $ 40,809

Note: Details may not add up to totals due to rounding.

## Cost per Pilot of 1,500

- Hour Requirement under the Rule

-- Pilots with

Bachelor’s Degree & Professional Pilot Major (1 Year Delay)

Year Age Typical Part

121 Pilot

Career

(3) Total Earnings Typical (Undelayed)

Pilot
(4) Career Path, Part

121 Service Delayed 1 Yr
(5) Total Earnings,

Part 121 Service

Delayed 1 Yr
(6) Loss in Total Earnings, 1 Yr Delay
(7) Loss in PV Earnings, 1 Yr Delay
(9)

1 30 FO, Regional $ 30,532 Comm'l Pilot $ 30,532 $

- $

-

2 31 FO, Regional $ 38,131 FO, Regional $ 30,532 $ 7,598 $ 6,636

3 32 FO, Regional $ 41,491 FO, Regional $ 38,131 $ 3,361 $ 2,744

4 33 FO, Regional $ 43,667 FO, Regional $ 41,491 $ 2,176 $ 1,660

5 34 FO, Regional $ 44,967 FO, Regional $ 43,667 $ 1,299 $ 926

6 35 Capt, Regional $ 82,091 FO, Regional $ 44,967 $ 37,124 $ 24,738

7 36 Capt, Regional $ 84,527 Capt, Regional $ 82,091 $ 2,436 $ 1,517

8 37 FO, Major $ 64,266 Capt, Regional $ 84,527 $ (20,261) $ (11,792)

9 38 FO, Major $ 99,650 FO, Major $ 64,266 $ 35,384 $ 19,247

10 39 FO, Major $ 116,376 FO, Major $ 99,650 $ 16,725 $ 8,502

11 40 FO, Major $ 119,338 FO, Major $ 116,376 $ 2,962 $ 1,407

12 41 FO, Major $ 122,230 FO, Major $ 119,338 $ 2,892 $ 1,284

13 42 FO, Major $ 125,424 FO, Major $ 122,230 $ 3,194 $ 1,325

14 43 FO, Major $ 128,750 FO, Major $ 125,424 $ 3,326 $ 1,290

15 44 FO, Major $ 131,692 FO, Major $ 128,750 $ 2,942 $ 1,066

16 45 FO, Major $ 133,328 FO, Major $ 131,692 $ 1,637 $ 554

17 46 FO, Major $ 135,312 FO, Major $ 133,328 $ 1,984 $ 628

18 47 Capt, Major $ 200,435 FO, Major $ 135,312 $ 65,123 $ 19,268

19 48 Capt, Major $ 202,668 Capt, Major $ 200,435 $ 2,232 $ 617

20 49 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

21 50 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

22 51 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

23 52 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

24 53 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

25 54 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

26 55 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

27 56 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

28 57 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

29 58 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

30 59 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

31 60 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

32 61 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

33 62 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

34 63 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

- 35 64 Capt, Major $ 202,668 Capt, Major $ 202,668 $

- $

-

Totals $ 5,187,556 $ 5,015,420 $ 172,135 $ 81,618

Details may not add up to totals due to rounding.

## APPENDIX 5

— Part 121 FOQ Accidents with Probability Scores Changed

in the Final Rul e

NPRM Final Rule

Date Carrier Location Fatalities Probability Score

08/13/04 Air Tahoma Florence, KY 1 0.75 0.55

10/19/04 Corporate Airlines Kirksville, MO 13 0.35 0.15

06/20/07 Great Lakes Laramie, WY 0 0.75 0.55

02/12/09 Colgan Air Buffalo, NY 50 0.35 0.20



## Note: For the NPRM, to determine the probability scores

, AVP evaluated the listed accidents
against the proposed provisions. For the final rule AVP re evaluated the accidents against the final rule provisions and also took into account mitigating actions being taken by other rulemaking projects. As a result, AVP reduced the effect iveness scores for the listed accidents.