Will reducing flying hour requirements alleviate the pilot shortage?

Is the reduction of mandatory flight hours the silver bullet to solve the pilot shortage?
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Concerns of a pilot shortage have been circulating since the onset of COVID-19. However, the global pandemic only exacerbated the issue rather than served as the catalyst. In 2019 Oliver Wyman, a United States (US) management consulting firm, conducted a poll of flight operations leaders and found that “62 percent listed a shortage of qualified pilots as a key risk” for the industry. 

The abrupt halt to air travel resulted in some pilots retiring or taking up other professions and, according to a statement from US-based National Air Carrier Association (NACA) issued in March 2023, more than 3,000 pilots took “early retirement packages during the COVID-19 pandemic” and an additional 12,000 pilots “are expected to retire over the next five years”. 

The NACA warned that due to the “robust demand for domestic and international air travel, and an expected shortfall of 28,000 pilots by the end of the decade, Congress should take significant steps to boost the pipeline of commercial pilots”. 

While the analysis conducted by Oliver Wyman showed that in Europe the supply-demand pendulum would be balanced in the near-term future, it also noted that the situation could deteriorate in the long-term. The consultancy firm added that this was further intensified by some airlines recommending to pilots in training “that they abandon the profession altogether”. 

The pandemic has clearly had an impact on projections. In its Commercial Market Outlook (CMO) 2022 Boeing estimated that aviation would need 602,000 new pilots globally by 2041, a reduction from the planemaker’s 2019 forecast of 645,000. 

Various stakeholders have attempted to tackle the potential pilot shortage problem, including the US House Committee on Transport & Infrastructure (T&I). The committee held a hearing on the topic on April 19, 2023, with the chairman of T&I, Sam Graves, a Republican from Missouri, noting in his opening remarks that “now is the time to examine the challenges the aviation industry faces so we can build and fly the advanced aircraft of the future”. 

The 1,500-hour rule 

The hearing focused on looking at the current and future challenges the aerospace workforce is faced with. 

While members of Congress addressed challenges that the industry will face across many professions, Garret Graves, a Republican from Louisiana, a member of the T&I, and the Chairman of the Aviation Subcommittee said that aviation is “going off a cliff” in terms of its workforce projections.  

Sam Graves noted: “As a professional pilot, I think about how pilot training has remained static over the years, except for the adoption of the 1,500 flight-hour rule.”  

The 1,500 flight-hour rule was established in the US following the Colgan Air accident in February 2009, which claimed the lives of 50 people, including one fatality on the ground. The airline’s Bombardier (now De Havilland Canada) DHC Dash 8 Q400, registered as N200WQ, operating on behalf of Continental Airlines as Continental Connection flight 3407, crashed into a residential neighborhood while it was on approach to Buffalo Niagara International Airport (BUF) in New York. The National Safety Transportation Board (NTSB) determined that four possible causes contributed to the crash, including the pilots’ failure to monitor the aircraft’s airspeed, the failure to adhere to sterile cockpit procedures, and the captain’s failure to effectively manage the flight. Lastly, the NTSB noted that Colgan Air had “inadequate procedures for airspeed selection and management during approaches in icing conditions”. 

In response to the incident, the US Federal Aviation Administration (FAA) stated that the “accident raised questions about whether SICs [Second-In-Command or First Officer – ed. note] should be held to the same training and flight hour requirements as PICs [Pilot-In-Command or Captain – ed. note], and whether a pilot’s overall academic training and quality of flight training were as important as the total number of flight hours”.  

Additionally, the FAA claimed that the crash also brought to light “pilot professionalism and whether pilots receive sufficient experience in a multicrew environment”. 

In 2010, the FAA began to move forward with making changes to changes to the US aviation system, issuing an advance notice of proposed rulemaking (ANPRM). In the ANPRM, the regulator sought feedback about “eligibility, training, and qualification requirements for SICs”. The ANPRM resulted in the FAA creating the First Officer Qualification Aviation Rulemaking Committee (FOQ ARC). However, before the committee could submit its conclusions, then-President Barrack Obama signed the Airline Safety and Federal Aviation Administration Extension Act of 2010 in August 2010. 

In its summary of the changes to the pilot certification requirements, the FAA noted that the act included “several specific provisions for modifying ATP certification requirements to prepare air carrier pilots to operate more safely”, adding that by August 2, 2013, all Part 121 pilots had to hold an Airline Transport Pilot (ATP) Certificate. The FAA stated that the new provisions included, among other things, that for ATP holders, the “minimum number of flight hours shall be at least 1,500 flight hours”.  

Impeccable safety record 

Few could argue that the rule has not had a positive impact on the aviation system in the US. The Colgan Air flight 3407 was the last fatal accident to involve a passenger-carrying Part 121 operator. 

However, there have been fatalities in the US since the accident, including the crash of Atlas Air (on behalf of Amazon’s Prime Air) flight 3591 which claimed the lives of the three pilots in Trinity Bay, Texas, and a fatality that occurred due to an engine failure on Southwest Airlines flight 1380, for example.

“We heard at our first hearing how we’ve established the gold standard here in the United States, but it’s also true that many other countries have very safe systems. And none of them have achieved their safety record by matching our 1,500 flight-hour first officer requirement,” Sam Graves said in his opening remarks during the April 2023 hearing.  

The chairman of the T&I Committee argued that allowing pilots to come out of flight school with just 250 flight hours and asking them to bridge the gap to accumulate 1,500 hours is not an adequate structure to ensure flight safety. 

“I’m not convinced that taking kids out of flight school and telling them to tow banners, train students, or bore holes in the sky while racking up debt produces the best pilots,” he continued, noting that the Colgan Air captain had “3,379 hours and the first officer had 2,244 hours”. 

In contrast, the European Union Aviation Safety Agency (EASA) permits airlines to employ First/Second Officers straight out of flight schools where pilots accumulate 250 hours and pass exams in more than a dozen subjects during their initial training. The license they acquire is considered a ‘frozen’ Airline Transport Pilot License (ATPL). It is ‘unfrozen’ once a pilot successfully passes the 1,500-flight hour mark, allowing a First/Second Officer to become a Senior First Officer or begin their journey toward becoming a Captain. 

Perhaps this is why research from Oliver Wyman has so far been positive about Europe’s prospect of managing to ensure an adequate supply of pilots. 

However, Captain Jason Ambrosi, the President of The Air Line Pilots Association, International (ALPA), a pilot union based in the United States, has disputed the firm’s findings that the US has not got enough pilots. 

Disproportionate impact 

According to Ambrosi, there are more than enough pilots in the US, with the projections of current and future pilot numbers based on “misleading data, or a failure to account for a multitude of industry dynamics at play”.

The President of ALPA stated that “there are more than enough pilots to meet U.S. airline hiring demand”.  

Ambrosi also highlighted that the decision made by carriers to leave certain regional communities were “market-driven business choices and should not be conflated with pilot supply”. He added that “training capacity has been the dominant pilot-related constraint on air travel”. 

“The good news is that the system is resilient—and is working to correct this current, short-term situation. All while maintaining the United States’ enviable position of having the golden standard when it comes to the safety of our aviation system,” Ambrosi said, adding that responding to short-term challenges with “permanent changes to pilot training and qualification requirements” is “ill-considered and dangerous”. 

But Regional Airline Association (RAA) President and Chief Executive Officer (CEO) Faye Malarkey Black proposed another angle of discussion during the hearing on April 19, 2023, stating that “a worsening pilot shortage has hindered the regional airline industry’s recovery from the pandemic and is decimating small community air service.” 

She said: “The impacts of the pilot shortage are real. Currently, more than 500 regional aircraft are parked, and those aircraft remaining in service are underutilized.” 

According to ch-aviation.com data, out of all the Mitsubishi (ex-Bombardier) CRJ100/200/700/900/1000 and Embraer E145/E170/E190 aircraft in the United States, 496 are marked as stored or in maintenance, while 1,532 are currently active. 

Black added: “Currently, the pilot shortage is further complicated by an acute captain shortage. Twelve large carriers alone hired 13,128 pilots in 2022, sourcing nearly all these pilots from regional airlines.”  

Questionable employment practices 

But the situation in Europe is hardly perfect, with the European Cockpit Association (ECA) calling on the European Commission (EC) to make changes to the Air Services Regulation 1008/2008. 

In an open letter to Adina Vălean, the European Commissioner for Transport, published on February 6, 2023, the ECA said: “Since at least February 2015 […] it has been clear that Europe’s Single Aviation Market has failed to maintain a level playing field, provide healthy competition free of social dumping, and deliver decent social standards for the people working in the aviation sector”. 

“It needs fixing to stop aircrews’ social standards to worsen even further, to ensure legal certainty for crews and authorities, and to end social dumping by unscrupulous airlines,” the pilot union added.  

In another website post published the same day, ECA President Otjan de Bruijn pointed out that the outdated legislation enabled “atypical employment such as bogus self-employment and zero-hour contracts, and legal uncertainty for aircrews due to the lack of an ‘operational base’ definition”. 

The organization has long fought the practice of pay-to-fly (P2F), whereby pilots pay to fly commercial aircraft for a set number of flight hours in order to unfreeze their licenses. In October 2022, the ECA called the practice a “hidden evil” as pilots whose ATPLs are still frozen can opt to unfreeze their licenses by paying airlines anywhere from €20,000 ($22,037) to €80,000 ($88,153) to increase their hours from 250 to the required 1,500. 

“It is not acceptable to ask a young 20–22-year-old to pay such sums after they already paid significant sums for their flight school to obtain their license,” the ECA continued. “P2F cannot be considered as training since it is not performed under the continuous supervision of a trainer and the cost of training on a specific course used by the employer to perform its services should therefore be borne by the employer.”  

“Ironically, those airlines that have turned the cost of training cadets into a source of revenue are the same ones complaining about pilot shortage. If they genuinely wish to find sufficient pilots, they should first consider offering them the training and a decent contract instead of making them pay to fly,” the ECA concluded. 

Meanwhile, according to Mircea Constantin, the Head of Representation of the Flight Personnel Union (FPU) Romania, the fact that P2F continues to exist “is unacceptable”. 

“European pilots’ organizations have already started counseling the upcoming generations of cadets and young wannabe pilots, explaining the significant fees required to enter the industry nowadays,” Constantin said in a statement issued to AeroTime.  

“But we must also push for an urgent revision of the current Air Services Regulation, outdated since 2008, and this is crucial to end exploitative practices such as pay-to-fly schemes,” he added. 

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