Over the last week there's been a tremendous outpouring of opinion among pilots regarding the proposed legislation I wrote about in my last post. The most controversial aspect is (predictably) the proposal to require all airline pilots to possess Airline Transport Pilot (ATP) certificates within three years. A fair amount of the opinion I've heard on the web boards, in person, and in the comments on the blog is negative. The two primary objections to the proposal that I've heard are that it represents an undue burden to newer pilots and that increasing experience won't do anything to improve safety. The first argument is understandable and not entirely without merit, but a close examination of conditions in the industry and a peek at future trends ought to ease concerns. The second argument I take much greater issue with; whether advanced out of ignorance or cynical self-interest, it is the same dangerously flawed trope that's never far from the lips of the most noxious CEOs in the airline business. It deserves a spirited rebuttal.
A lot of the alarm being voiced over requiring an ATP for airline newhires comes from those with significantly less experience, particularly those who've already invested a lot of money in training and are now trying to build flight time. I'm sympathetic to these pilots' concerns; having been in their shoes not so long ago, I'm not inclined to pull up the ladder behind me. There are too many people in aviation who are willing to throw those below them to the wolves; it is the exact attitude that gave birth to the cancer that is destroying our profession from the bottom up.
Times are tough for everyone in aviation right now. The major and regional airlines, fractionals, charter operators, and corporate outfits have all laid off thousands of pilots, including several of my friends. I'm still somewhat doubtful that my own job will survive this downturn; reportedly, WidgetCo and RedCo are collectively overstaffed for this winter by as many as 1200 pilots. For those just starting out, openings for the traditional timebuilding jobs are in short supply and competition is fierce. Even those with one of the coveted instructing jobs might not be building very much time: the sorry state of the airlines has killed career-oriented flight training and the economy isn't encouraging anyone to take up an expensive flying hobby, either. On the face of it, adding more restrictions does seem like kicking a guy when he's already down.
The unfortunate reality is that things are so bad right now that this law, if passed, isn't likely to affect anybody currently in aviation, or at least those well along in their training. The few airlines doing limited hiring (including mine) have extremely high competitive minimums. I don't think it's going to change anytime soon. There isn't any attrition at the regionals, and they're not going to grow any further; some will shrink significantly as major airlines attempt to reduce 50-seat lift. There are already many well-qualified airline pilots on the street, and it will get far, far worse if one or more major airlines goes out of business or is acquired this winter. The bottom line is that if you don't already have significant airline experience, you will not likely be hired at an airline in the United States for at least several years whether this law passes or not.
Things will eventually turn around; I personally think that the economy will recover enough to support airline growth at about the same time retirements resume after five years of stagnation, around 2011-12. Once the majors start hiring in large numbers, it's going to cause regional airline attrition to skyrocket. Initially, competitive hiring minimums will stay high as the regionals work through a large backlog of highly qualified pilots (which includes furloughees and those who've been building flight time steadily from now until then). Those currently finding it so difficult to build time will then find timebuilding jobs much easier to come by (assuming they haven't already thrown in the towel). I suspect that even without the proposed law, competitive minimums will remain at or above 1500 hours by the time most of today's commercial pilots reach the regional airlines.
The change of law will primarily affect those who begin training between now and ~2013, particularly those who jump in at the beginning of the next hiring cycle. Absent any changes to legal requirements, the relative lack of new pilots in the intervening years will cause competitive minimums to fall from 1500+ hours to 250 hours very quickly, just as happened in 2006. I'll get to why that would be a very bad thing in a minute, but now I wish to address whether requiring these future pilots to build 1500 hours represents an undue burden. Firstly, they will have entered aviation and paid for their training knowing the 1500 hour requirement. Secondly, the ability to be hired by any airline with less than 1500 hours is a historical anomaly that has only happened a few times throughout the last fifty years. Finally, it is likely that timebuilding jobs will be much more available than today (and better paid!) to those who build their time during the next shortage.
The suggestion that increasing newhire experience will not improve safety puzzles me. For the most part, I've seen it not from aviation newbies but from moderately experienced pilots who were hired at the airlines with low time during the last five years. I can understand why industry groups would fight against the requirement tooth-and-nail, but what motivation can these pilots have? Pride? A wish to justify the route they took to the airlines? I don't blame anybody for accepting a First Officer position with low time; I surely would have done so if I'd had the opportunity. To subsequently claim that the practice was just as safe as hiring more experienced candidates, however, bespeaks ignorance that hints at some of the limitations of inexperience.
I've heard three primary arguments in favor of this assertion. The first is based on personal experience and goes something like "I hired on at XYZ Airlines with 300 hours and didn't have a problem in training or on the line." Obviously, self-critique isn't the best means of judging these things; I'd prefer the opinions of check airmen and the Captains flying with the low-timers. But let's assume that our debate partner's check airmen and Captains agree that he exhibited superior aeronautical knowledge and skill as a low-time new-hire. There isn't a direct parallel to safety here. How many unusual situations happened in this pilot's early career? How many tough decisions? How many times did he have to challenge an off-the-reservation Captain? How many emergencies? Probably few, if any; I've only had a small handful in 4000 hours of airline flying. Airline flying is pretty uneventful most of the time and real tests of one's worth as a pilot come infrequently. It's very possible, even probable, that a low-time pilot will not be truly tested before he gains some experience. One cannot extrapolate this stroke of luck across the industry, because over thousands of flights per day things do happen, and any system that puts thousands of inexperienced pilots in the right seat is guaranteeing that some of them will be called upon in a dicey situation. I haven't flown with many low-time First Officers but some of my friends have, and they generally agree that most of them are fine in normal situations but many are virtually useless when things go wrong. It's not that they're bad pilots, they just haven't experienced many similar situations in their careers yet.
A frequent corollary to the above argument is "I flight instructed for 300 hours, and I fail to see how another 1000 hours of pattern work would have made me a safer pilot." If those 700 hours were flown in the same pattern with the same perfect weather and the same infallible student in a perfectly trustworthy airplane, that might be a good point. The reality is that one will encounter a wide variety of challenging situations in those 1000 hours which will develop decision-making skills, sound judgment, and practice in keeping one's composure in a bind. I scared myself and learned important lessons many, many more times in 2000 hours of instructing and freight dogging than I have in the 4000 hours since; those lessons could fill an entire post. It's worth noting that those who denigrate the value of timebuilding are generally those who didn't do a great deal of it.
The second common argument is that various organizations have employed 250-hour pilots with great success; the most common examples given are the major airlines back in the 60s, the U.S. military, and major airlines in Europe. All three are really apples-to-oranges comparisons. In the case of the major airlines of yesterday (who, by the way, weren't exactly shining examples of aviation safety), new-hires generally spent several years observing experienced pilots as flight engineers, and then moved to the right seat under the tutelage of experienced Captains. The U.S. Air Force, Navy, and Marines do put pilots with as little as 200 hours in command of high-performance fighter jets, but only after a very intensive,lengthy, and costly screening, selection, and training process that weeds out the majority of candidates and leaves only the cream of the crop. The European airlines have a fairly stringent selection process, many do their own ab-initio training, and all require an ATP. Yes, it's a "frozen ATPL" until the pilot builds enough flight time - but unlike the FAA ATP, the flight time is the easy part of earning a JAA ATP. Their ATP is all about demonstrating a command of aviation knowledge far superior to that of most regional newhires in the US (and actually, many Captains as well).
If the regional airlines in the U.S. screened their 250-hour candidates intensively, put them through a lengthy, costly, and difficult training program, required them to demonstrate a knowledge level equivalent to JAA ATPL standards, had them observe line operations for a while, and then paired them with experienced Captains, the above comparisons would be valid and I wouldn't be writing this post because I wouldn't see a problem with 250 hour First Officers. The regional airlines of 2005-07 did none of the above and industry trends suggest that it will be even worse in the next shortage. If regionals were willing to take essentially anyone with a pulse and a commercial certificate after a three-hour interview process, rush them through a training program designed for much more experienced pilots, and throw them on the line after the minimum legal IOE to fly with 2000-hour Captains who just upgraded, what will they do in a deeper and more prolonged shortage at a time when the regionals aren't making the large guaranteed profits of 2005-07? Many industry players have been pushing for the FAA to adopt the Multi-Crew Pilot certificate (MPL) concept developed by ICAO, which would put "pilots" with less than 120 hours of actual flight time into the right seat of airliners. They wouldn't be legal to act as pilot-in-command of a Cessna 150, yet are somehow expected to pull their weight as part of a well-functioning airline crew. If this law does not pass, you can be sure that the RAA will be pushing hard for MPL during the next shortage.
The final argument I've seen is that the airline accident record does not support the idea that inexperienced pilots pose a significant safety risk. Its supporters are quick to point out that both pilots in Colgan 3407 had flight time exceeding ATP minimums, or that the majority of pilot-error airline accidents involve experienced pilots. First off, airline accidents happen so infrequently that accident data alone is a pretty poor metric of aviation safety trends, particularly those involving fairly short-term phenomenon like the three year span in which widespread hiring of pilots with less than ATP minimums was pervasive. Secondly, low-time pilots made up a fairly small portion of all pilots even at airlines that extensively engaged in the practice of hiring low-timers due to the rapid accumulation of flight time, making statistical analysis on the basis of accident rates all the more problematic. I'd be much more interested in a study involving ASAP, NASA, and FOQA data, but no such study has been done.
As for Colgan 3407, I'd argue that experience did play a role, along with many other factors. True, both CA Renslow and FO Shaw had well above ATP minimums, but CA Renslow was fairly inexperienced for a PIC of a 76-seat airliner. That was a direct consequence of Colgan hiring him direct from Gulfstream with 600 hours, very little of which was prior PIC time. It's impossible to know for sure, but one can't help but wonder if more real-world experience before the airlines would have made a difference. Airline flying is an efficient breeder of complacency if one lets his guard down. I know that in my own case, getting bit by complacency a few times early on made me much more wary of it later in my career. The US Navy cited complacency as a primary culprit in their study of aircraft accidents that found Navy pilots were most dangerous between 700 and 900 hours of total time.
There actually is one argument against the new regulation that I find credible. If the law changes, it's possible that at the height of the next shortage, regional airlines will be so desperate for candidates with 1500 hours that they'll take anyone with the flight time regardless of prior checkride busts, violations, crashes, etc. The fact that the new legislation addresses hiring standards, as well as the fact that the airlines weren't much more selective than that in the last shortage, makes me less swayed.