AINsight: The 1,500-hour Rule is Ridiculous

 - September 22, 2022, 7:49 PM
Pipistrel Alpha (Photo: Pipistrel)
Mesa is buying a fleet of Pipistrel Alpha's to help pilot candidates accrue time. (Photo: Pipistrel)

Mesa Airlines is buying a fleet of two-seat Pipistrel Alpha light sport aircraft to help career pilot candidates log hours toward the FAA’s minimum 1,500-hour requirement for airline operations. That’s great news for Textron, which bought Pipistrel in August; the Alpha is a fun airplane, relatively inexpensive to operate, and fairly modern, as light airplanes go.

But the idea that future airline pilots will gain the necessary experience by flying around in the Alpha with another pilot to keep per-pilot costs down is ridiculous.

First of all, this is a VFR airplane. Airlines fly IFR. Granted, the FAA says nothing about the kind of hours pilots log to reach the 1,500 needed to qualify for the airline transport pilot (ATP) license, but it makes me wonder how the hours in the Alpha are going to be beneficial.

Second, the Alpha has almost zero opportunity for pilots to work together as a two-pilot crew. I’m sure someone could come up with a division of duties, pilot flying, pilot monitoring, “you do the radios,” etc., but is that truly a positive transfer of learning for an airline flight deck?

Third, this effort just highlights the stupidity of the 1,500-hour rule and the lengths that we as an industry are stretching to comply with the wording of the rule but certainly not the intent. The 1,500-hour rule came about because the families of the victims of the Colgan Air Flight 3407 crash near Buffalo, New York, in 2009 made a concerted effort to lobby congress to force the FAA to implement the rule. (Never mind that both pilots had more than 1,500 hours.)

The real intent of the 1,500-hour rule is to impose a higher level of qualification for Part 121 airline pilots. (And if it’s so important for 121 pilots to be so good, why shouldn’t this apply to Part 135, one might wonder. I do.) We all understand the desire to set a new minimum standard for airline pilots, but in fact, there have always been adequate minimum standards. Colgan Air and the previous airlines that employed the captain of Flight 3407 failed in their duty to eliminate him from the ranks because of his below-grade skills, and that is the real cause of the accident. The 1,500-hour rule would not have prevented the deaths of the two Colgan pilots, two flight attendants, 45 passengers, and one person on the ground.

Prior to the imposition of the 1,500-hour rule, airlines were allowed to hire commercial pilots with just 250 hours (or fewer for pilots who learned in Part 141 flight schools) to fly as first officers, and they would normally graduate to captain qualifications after a few years of work. The system worked as long as everyone followed the rules, provided good training, and weeded out the unqualified.

Because Colgan Air failed to weed out a clearly unqualified pilot, we have the 1,500-hour rule. And it is a burden. Thousands of pilots get their commercial pilot license in the U.S. every year, but they are not available to work for airlines so they have to figure out a way to log flight hours. Some become flight instructors, some find work towing banners, lofting parachutists, or other odd jobs, and some even buy an airplane in which to log flight time. The value of these fight hours is just as questionable as the value of logging unstructured time in a light sport aircraft.

So all this raises a big question: was the 1,500-hour rule a mistake? Not according to the Air Line Pilots Association, which stringently defends it on safety grounds. The FAA doesn’t seem to want to budge on the rule either; witness the recent rejection of a petition for exemption by Republic Airways, which offered to replace 750 of the 1,500 hours with a structured training program oriented towards airline operations.

This is not a bad idea, and it turns out, airlines in Europe, Australia, China, Oman, Philippines, Singapore, Thailand, United Arab Emirates, and the UK have been operating for many years under the multi-crew pilot license (MPL) scheme. The MPL was created by the International Civil Aviation Organization in 2006, and ICAO member countries are free to adopt it, and many did with great success.

Under MPL, pilots with around 200 hours but undergoing a formal competency-based training program are eligible to fly as first officers in their country’s equivalent of Part 121 airline operations. The key here is the training. These pilots are not trained to the commercial level and then turned loose to accumulate another thousand or so hours of unstructured experience, but rather they learn important concepts in safety and multi-crew operations from the beginning.

I haven’t seen a comparison of airline accident statistics between MPL-using countries and those that don’t have such a system, but I suspect they aren’t all that different. If there were a clear safety drawback with MPL, I’m sure the regulators would have clamped down, and they haven’t.

It’s a mystery to me why the FAA doesn’t acknowledge the benefits of structured training, although the FAA does allow the issuance of a restricted ATP for qualified graduates of certain colleges and universities. In this case, a pilot with a restricted ATP can fly as a first officer for a Part 121 carrier before reaching 1,500 hours.

But that doesn’t make room for airlines like Republic Airways, which developed a program it felt was every bit as good as those used for restricted ATPs.

Bottom line: if the facts show there is no degradation of safety for the equivalent of an MPL-type program, the FAA should allow organizations an exemption from the 1,500-hour rule or else just rewrite the rules and join much of the rest of the world and adopt ICAO’s MPL program.

The opinions expressed in this column are those of the author and not necessarily endorsed by AIN Media Group.