Part of the sweeping regulatory changes in the aftermath of the tragic accident near Buffalo, New York, involving a Colgan Air Bombardier Q400, are requirements for the new Airline Transport Pilot (ATP) certification. The FAA released the final rule for pilot certification and qualification requirements for air carrier operations, commonly referred to as the “1,500-hour rule,” in July 2013. First and foremost, to be eligible to serve as a crew member in a Part 121 Air Carrier (airline) operation, every pilot must now possess an ATP. While the experience and certification requirement for the ATP is vastly different on paper from the Commercial certificate and 250 hours previously required to be a first officer, it does NOT represent nearly as dramatic a change in practice.
Pilot hiring has always been market driven, and historically, pilots have been required to possess minimum experience at least close to the ATP requirements to be competitive for pilot positions. While exceptions exist for every rule, pilots generally have been expected to possess anywhere from 1,000 to 1,500 hours of total time and 50 to 100 hours of multiengine time to be marketable to the airlines. This requirement has not changed essentially in the new rule. The more dramatic changes in the new rule are the additional requirements that first officers possess a type rating for their aircraft and that captains have at least 1,000 hours of airline experience.
The new rule also creates the Restricted ATP (R-ATP) qualification, allowing a pilot to serve as an airline first officer before reaching the necessary 1,500 hours for a full, unrestricted ATP. The R-ATP requires that the pilot be 21 years of age and successfully complete a checkride; in lieu of the minimum hours, it offers credit for specified education and training, thereby acknowledging that specialized, quality training can be an effective substitute for total experience. The options for R-ATP minimum experience are:
- 750 hours of total pilot time for military pilots
- 1,000 hours for graduates holding a bachelor’s degree with an aviation major from an approved school
- 1,250 hours for graduates holding an associate degree with an aviation major from an approved school
For each of these R-ATP options, the majority of total flight experience must have been obtained while enrolled in the specified programs. It is worth noting that simply graduating from a two-year or four-year aviation program does not automatically grant eligibility for the R-ATP. Each school that desires to certify its graduates for the R-ATP must apply for and receive approval from the FAA and must meet criteria outlined in Advisory Circular 61-139.
A separate category of pilots includes those who may possess the 1,500 hours of total pilot time required for a full ATP but fall short of the requisite 500 hours of cross-country experience (e.g. flight instructors). These pilots, who also have at least 200 hours of cross-country time and otherwise meet ATP experience requirements, are also eligible to apply for the R-ATP.
When transitioning to an unrestricted ATP, an FAA inspector can remove R-ATP limitations and issue a full ATP with paperwork only. The applicant must present evidence that he has met the ATP age requirement (23) and the aeronautical experience requirements of § 61.155. The applicant then must complete section III – Record of Pilot Time, on FAA Form 8710-1, Airman Certificate and/or Rating Application Supplemental Information and Instructions, to be issued the unrestricted ATP.
FAA only recently began granting institutional authority to certify for R-ATP. A complete list of approved schools is available at https://www.faa.gov/pilots/training/atp/media/Institutional_Authority_List.pdf. Given the recency of the rule and approval of schools, there exists a population of pilots who have graduated from programs prior to FAA approval and the ability to certify for R-ATP. Unless the school takes steps to include this group in its approval or by other means, it’s conceivable some may not technically meet eligibility requirements – even if having graduated and followed the exact curriculum.
Also included in new ATP certification rules is the requirement to complete an FAA-approved Airline Transport Pilot Certification Training Program (ATP-CTP) prior to taking the FAA written exam for multiengine ATP. ATP-CTP is a 40 hour course – 30 hours of ground school and 10 hours of simulator training – intended to prepare the applicant to operate safely in those operations which require an ATP. Of the 10 hours of simulator training, six (6) hours must be completed in a Level C or higher full flight simulator that represents a multiengine, turbine airplane with a maximum takeoff weight of at least 40,000 pounds, rendering many corporate aircraft ineligible.
The ATP CTP serves as a prerequisite for the multiengine ATP written exam and includes training in:
- Adverse weather conditions,
- Air carrier operations,
- Transport airplane performance,
- Professionalism, and
- Leadership and development.
As of August 1, 2014, all persons applying for the ATP knowledge test are required to present a graduation certificate certifying the completion of an ATP-CTP before taking the written test. For written tests taken before August 1, 2014, those test results still remain valid for 24 calendar months. Written tests for multiengine ATP taken after July 31, 2014 are valid for 60 calendar months. The ATP-CTP graduation certificate itself does not expire so there is no penalty and no harm in taking the ATP-CTP anytime that is convenient.
Single-engine ATP does NOT require the ATP-CTP course, but does require a separate single-engine ATP written exam. Previously held exceptions for taking the ATP practical exam with expired written test results still hold true as provided in § 61.39(b) and (c) which relate to crewmembers of Part 121, 125 or 135 operators or certain foreign pilot license holders.
To date, very few approvals for ATP-CTP have been issued. Sporty’s training partner, ABX Air, in Wilmington, Ohio, was one of the first outside of Embry Riddle Aeronautical University. A list of eligible providers is available at https://www.faa.gov/pilots/training/atp/media/ATP_CTP_Providers.pdf.
The movement in the industry appears to be that many regional airline training departments will be creating ATP-CTP courses and seeking FAA approval indicating that completion of the ATP-CTP requirement may be accomplished in large part, as part of the hiring or on-boarding process of some regional airlines.
As you can see, there have been some dramatic changes in certification and the cost of the ATP written for multiengine has essentially gone from $150 to something north of $4,500 factoring in the costs of ATP-CTP. But practical experience requirements to fly as an airline pilot remain nearly the same. It’s much too early to see what effects the changes in certification may have on safety, but if you are in the category of having passed the ATP written exam prior to the ATP-CTP mandate, keep a close eye on those written test results and make sure you’ve earned the ATP before expiration. And if you’re a collegiate aviation program graduate, ensure your institution had received institutional approval for R-ATP and if not, engage your school to determine where they may be in the process.
For additional information, FAA resources are available at https://www.faa.gov/pilots/training/atp/.