Exemption Petition to create a Restricted ATP Will Republic’s Pilot Pathway work?

R-ATP pilot
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Collateral consequence of 1,500 hrs. ATP = Pilot Shortage

Republic files Exemption Petition for a Restricted ATP

Well designed, many safety strictures, but will this Pathway be granted?

Republic Airways, on April 15,2022, filed a petition for AN EXEMPTION from 14 CFR § 61.160(a)- Aeronautical Experience.   Specifically, Senior Vice President and Chief Operating Officer, Paul Kinstedt  requested that the FAA enable the carrier to implement a innovative, but highly safety justified,   Restricted Air Transport Pilot (R-ATP) Program. [see below for details].

1st page of Republic Petition

Nothing in recent memory equates to the dysfunctional debate about increasing the number of hours required as a predicate to hiring a First Officer for a Part 121 carrier. Congress, on a less than substantively factual record, enacted the Airline Safety and FAA Extension Act of 2010 (ASFE) which increased the minimum hour from 250 hours to 1,500 hours. To add to the differences of opinion,  FAA Air Carrier Training Aviation Rulemaking Committee (ACT-ARC) published numerous recommendations to improve and develop pilot safety, including alternative methods to develop professional pilots for part 121 operations.

exemption docketA Petition for Exemption is a procedural tool for seeking relief from an existing rule; in some ways, it is very similar to a Petition for Rulemaking—the parameters for both are laid out in 14 CFR Part 11. Exemptions are defined in 14 CFR § 11.15, what must be included in this document is at §11.81 . The Republic Petition covers all of the essentials so defined.

Exemptions have been used by the CAB and FAA to test a new concept, i.e., 14 CFR Part 298 was initially issued as an exemption and a Court of Appeals commended the Board for its use of this statutory authority and the Small Aircraft exemption 7897F,from 14 CFR §91.501. Given this history the 1,500 hour history, some limitation might help move this petition from filing to finish.




Some comments from another article on this Petition—

Lots of hours as such doesn’t make someone a good pilot, but rather it comes down to the training that they’ve received

If these flight academies have good programs and a rigorous process for certifying people to get into the cockpit of a jet with passengers, then I’m all for it, regardless of whether a pilot has 750 hours or 1,500 hours

If the FAA believes it’s safe for pilots from the military to fly with 750 hours, then there should be a similar pathway for civilians to do this, in my opinion

Becoming a pilot is expensive, and that excludes a lot of people who may potentially be interested in this as a career path; if becoming a pilot can be made more affordable without compromising safety, I’d consider that to be a great thingRepublic Plane





Republic Airways Petitions FAA to Lower Pilot Minimums For Company’s First Officers

If successful, the airline would be allowed to hire pilots with just 750 hours, half of the current requirement.

By Michael Wildes

exempt cockpit

Regional carrier Republic Airways has petitioned the FAA to lower the required pilot minimums for its “Restricted Air Transport Pilot”  (R-ATP) program from 1,500 hours to 750.


Republic is headquartered in Indianapolis and flies on behalf of Delta Air Lines (NYSE: DAL), American Airlines (NASDAQ: AAL), and United Airlines (NASDAQ: UAL). The company applied on April 15 to the Department of Transportation (DOT) to lobby{sic}[1] for its version of the restricted ATP.republic exempt petition

“The requested exemption would allow selected civilian pilots who complete the rigorous Republic R-ATP program to apply for an airline transport pilot certificate concurrently with a multiengine airplane type rating with a minimum of 750 hours of total flight time as a pilot,” the airline explained in its letter.

Moreover, the airline said its Republic R-ATP would resemble the military-based training pathway more closely but would be even safer than the military’s version with a revised civilian approach.

Presently, qualified military pilots who want to transition to a commercial environment may earn an R-ATP with 750 hours of total flight time to qualify for an airline job.

Congress drafted the Airline Safety and Federal Aviation Administration Extension Act of 2010. The act directed the FAA to require that commercial pilots seeking an airline transport pilot (ATP) certificate acquire at least 1,000 hours to get a restricted ATP or 1,500 hours to qualify for a total ATP—something casually known as “the 1,500-hour rule.”

In its proposal, Republic argues that its R-ATP program would make “airline pilot career opportunities more accessible for qualified individuals from underrepresented groups who meet the selection criteria but may not have the financial means or academic support to pursue an aviation career path while providing a higher level of safety.”

How It Would Work

lift academy

Republic’s proposed  R-ATP program would be a closed-loop system that the airline would operate within its subsidiary training program known as the LIFT Academy. The airline said the benefit of the closed-loop system is that pilots selected to participate are trained entirely in house, in keeping with Part 141 training standards specific to ATP requirements. Furthermore, with the integration of performance data collection, analyses, and programs like AQP (the FAA’s advanced qualification program), Republic says it can adjust and improve the training content through data-informed and data-driven analysis.

Moreover, the airline estimates that it could reduce the flight training and tuition cost that pilots pay in four-year degree programs from $200,000 to $75,000. Republic says this would lower the economic barrier of entry to many under-represented minority groups.

The airline notes that the high cost of training has caused 40 percent of students in its LIFT Academy to withdraw altogether while trying to satisfy the minimums in place today. In its proposition, the cost of the Republic R-ATP Program would include all training costs required to become a Republic pilot, though there are some caveats for when they would be eligible for that.

Ultimately, upon completing the Republic R-ATP Program, pilots would be able to use their R-ATP privilege only at Republic—in keeping with the terms of the broader exemption—until the pilot requirements for an unrestricted ATP are met.


Prospective pilots who want to enroll in the program would undergo a selective aptitude test, as with the military R-ATP version. Upon selection, they would enroll in the program as full-time airline employees. They would earn all the required piloted certificates but receive specific training to work in a Part 121 airline environment. On the ground, “students will complete courses in Advanced Airline Academics, complete Command Experience, receive a Republic mentor, and complete Supplemental Advanced Aviation Training to help them better prepare for a career as an airline pilot,” the company said.

To maintain a high standard, the program would have a series of “knowledge and skill validation gates” that if students failed to pass through, they would be removed from the program and have to earn their R-ATP the standard way.

Industry Clamoring for Pilots


While the DOT has yet to respond, airlines have increasingly tried various things to offset pilot shortages that have forced them to cancel routes, especially through their regional partnerships. Delta Air Lines recently eliminated its four-year degree requirement for pilots, while United Airlines launched its Aviate Academy to create a more direct pipeline from flight school to a career.

Michael Wildes

Michael Wildes covers Business News for FLYING and appreciates all things aviation, media, business, and philanthropy. He holds aWildes master’s degree in Logistics & Supply Chain Management, and a bachelor’s degree in Aeronautical Science, both from Embry-Riddle Aeronautical University. Previously, he worked at the university’s flight department as a Flight Check Airman, Assistant Training Manager, and Quality Assurance Mentor. He holds MEI, CFI & CFII ratings.

[1] Filing a document in a public document is not “lobbying” which is prohibited


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