Sec. Chao expresses willingness to discuss the 1,500 hour rule, hopefully facts will be considered

Share this article: FacebooktwitterlinkedinFacebooktwitterlinkedin

Congress urged to water down Flight 3407 pilot training rules

Families of CO 3407 deserve much credit for expediting the NTSB recommendations

the 1,500 rule was established with no statistical evidence

there are several technical criticism of the mandated hours requirement

The opening paragraph of an article in The Buffalo News

The Families of Continental 3407 deserve a lot of credit for advocating for the enactment of PL 111-216 ; by so doing all of the NTSB’s probable cause findings for that accident were mandated as actions for the FAA to remedy:

“The National Transportation Safety Board determines that the probable cause of this accident was the captain’s inappropriate response to the activation of the stick shaker, which led to an aerodynamic stall from which the airplane did not recover. Contributing to the accident were

(1) the flight crew’s failure to monitor airspeed in relation to the rising position of the lowspeed cue,

(2) the flight crew’s failure to adhere to sterile cockpit procedures, (3) the captain’s failure to effectively manage the flight,


(4) Colgan Air’s inadequate procedures for airspeed selection and management during approaches in icing conditions.”

Most of the 17 sections (§§202-217) attributed the Families of Continental 3407’s efforts find some basis in the NTSB report or some reasonable extrapolation thereof—except one, the 1,500 hour minimum experience pilot requirement.

The quote from Secretary Chao’s comments at a Washington Post forum on FAA matters has not been posted by that paper. According to The Buffalo News report:

“Chao was asked if she would be open to seeing the minimum number of flight hours for new pilots reduced below the 1,500-hour standard set by that 2010 aviation safety law.

“You know, I think there needs to be a robust discussion, because obviously we hold the memories of those who are lost in our hearts, and we don’t ever want to see an accident like that again or any accident ever occur,” Chao responded. “But there is this side effect, unanticipated, corollary impact of reducing the number of pilots, pilots who can very safely fly in our sky. So I think Congress needs to have this discussion, and we will abide by the wishes of Congress.”

This debate would be benefitted by a few important points:

  1. The NTSB report on Continental 3407 did not include a recommendation to increase the minimum from 250 hours to 1,500 hours. It is fair to say that the primary findings attributed the tragedy to pilot fitness and fatigue.
  2. The Washington Post and The Hill both trace the political clout for passage, if not the origin of the concept for, the 1,500 hour rule to the Air Line Pilots Association, consistently ranked as one of Washington’s most effective lobbying organization. .
  3. FAA Air Carrier Training Aviation Rulemaking Committee, a panel composed of industry, academic, professional training and federal experts, carefully reviewed the literature and research on identifying pilot attributes which enhance safety. The 50 page analysis made many recommendations citing the scientific, quantitative evidence, BUT did not endorse the 1,500 hour rule.

4. Roger Cox, the NTSB’s operational factors group chairman during the Colgan 3407 investigation, issued a very thoughtful retrospective on the crash and the subsequent implementation of the recommendations.

Colgan 3407 Eight Years Later – Making a Difference in Aviation Safety is his 20 page long review and he endorses all of the actions taken over those years with one exception. His paragraph on the 1,500 rule acknowledges that it was the “most controversial element of the new airline regulations.” Unlike all of the other points of his paper, he neither endorses nor opposes it.


  1. Flight Hours and Flight Crew Performance in Commercial Aviation by  Melanie A Todd ,and Matthew J. W. Thomas,. appeared in  Aviation, Space, and Environmental Medicine, Volume 83, Number 8, August 2012, pp. 776-782(7), peer-reviewed monthly journal published by Aerospace Medical Association. The authors, after extensive research, they found

There were no statistically significant differences between experience groups for First Officers or Captains against the set of technical measures; however, there were minor differences with regard to nontechnical measures as a function of crew composition. There was also a difference in automation use, with First Officers with less than 1500 h keeping the autopilot engaged until a significantly lower altitude. Discussion: Despite on-going debate that low-hour First Officers are not as capable as their more experienced colleagues, we found no evidence of this in our study.

This is a definitive quantitative conclusion by two highly qualified academics.

Flight Safety Foundation, whose reputation reflects its tagline– an independent, international, and impartial non-profit that exists to champion the cause of aviation safety, published an article supporting the Australian study– says. Specifically, it recited and reinforced the study’s major points:

  • Methods
  • Results
  • Little Variation
  • No Less Able

Nevertheless, the report said that the study provides “concrete evidence to inform legislators, regulators, safety groups, pilots and the industry in the ongoing debate surrounding pilot hours and inferred performance. There is a continued need for scientific rigor, rather than political commentary, to inform the debate on commercial pilot training and licensing, in particular the individual differences that make up the competence of a pilot instead of adherence to an arbitrary threshold that might somehow ensure performance, and, therefore, safety.”


Let the debate begin and facts should be the basis for a decision.











Share this article: FacebooktwitterlinkedinFacebooktwitterlinkedin

2 Comments on "Sec. Chao expresses willingness to discuss the 1,500 hour rule, hopefully facts will be considered"

  1. They are right, the number is wrong .. it should be 3,000 hours of experience before you can be responsible for all those lives.. but airlines dont want to pay for that kind of experience from new hires. Greed has them still paying regional pilots 25 grand a year!

  2. It is not about flight time, it is all about training and judgement, it takes an ATP 1500 hrs to be a captain increase the ATP to 5000 to be able to be a captain

Leave a comment

Your email address will not be published.