Two data-based critiques of the 1,500 hour rule

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The 1,500 hour rule was set by Congressional fiat

ALPA defended the rule using a chart

RAA and one of the best aviation safety journalist have written hard data critiques of the Union’s numbers

The subject of, nay the heated debate about. the 1,500 hour rule has dominated much of the current aviation trade press. The below list shows its frequency on the JDA Journal site:

Exemption Petition To Create A Restricted ATP Will Republic’s Pilot Pathway Work?shortage factors

Pilot Shortage- Yes Or No – Data Analysis Needed To Find THE Solution

Perception Is Reality- With That Established, There Are Short And Long Term Issues To Be Fixed On Pilot Shortage

Let’s Premise The Experienced Pilots Fly Act On Good Available Data To Support 65 Becoming 67 Retirement Rule

PILOT FATIGUE/OVERSCHEDULING V. PILOT SHORTAGE- There’s An FAA Process To Decide

Ordinarily, the first section of the JJ posts attempts to add insight to the quoted content. The two articles that follow are excellent data based exposition and should speak for themselves!!!

pilots

 


RAA Responds to Inaccurate Data on Pilot Supply Washington, D.C.,

August 11, 2022 –

RAA logo

The Regional Airline Association (RAA), representing the airlines which provide 43% of scheduled passenger flights in the U.S. and offer the only source of air service to most of the country, issued a statement in response to release of misleading comments and graphics seeking to deny the existence of a real and worsening pilot shortage.

Misleading graphs are sometimes deliberately misleading and sometimes it’s just a case of people not understanding the data behind the graph they create. The “classic” types of misleading graphs include cases where:

      • The Vertical scale is too big or too small, or skips numbers, or doesn’t start at zero.
      • The graph isn’t labeled properly.
      • Data is left out.” –

 https://www.statisticshowto.com/probability-and-statistics/descriptive-statistics/misleading-graphs/ [1]

 

“Our reply is technical, because it is important to get the details right” noted RAA President and CEO Faye Malarkey Black.

Faye Malarkey Black

 

In an earlier release, the Air Line Pilots Association (ALPA) alleges that certain airlines “mislead the public about pilot supply to cover up bad business decisions and their attempts to negatively impact aviation safety.” The organization previously identified RAA as the subject of its allegations. The release went on to cite “FAA data” without acknowledging that it had isolated the data from a broader dataset to lend the appearance of an “uptick” in pilot supply. When the omitted data is included, there is no support for the claim of a meaningful pilot “uptick.” Put another way, of course pilot production is resuming and trending up, considering it fell to new lows during the pandemic.

Please read on for the missing data and why it matters.ALPA misleading data chart

 

The chart above shows new pilot qualifications are “up” from April 2021 through July 2022. This is accurate. However, it is important to understand what they are “up” from, which is a global pandemic. Pilot training was disrupted during the pandemic, and qualifications plunged in 2020 into 2021 as a result. As the country reopened, pilots resumed training and qualifications. That a sharp incline would follow a decline is not unusual; FAA is clearing this backlog of certificates.

The charts below use the same data cited in the misleading graphic above but include all the relevant data. The first chart examines year over year original issuance of the relevant certificates through August 1. The number of new certifications issued has averaged 6,335 per year for the past decade and fell to less than 4000 in 2020 and less than 5000 in 2021. Pilots with COVID-disrupted training and qualifications are now resuming their training and the uptick represents the clearing of those backlogged of certifications. This is not a record-breaking increase; we would expect a higher than usual year as paused pilot certificates resume after a dramatic downturn.

ATP chartThe second chart shows the monthly rate of new certificates. This chart shows the clear decline from April to June of 2020, then a slow but steady increase through February 2022. If production continues at the current monthly rate, 2022 is forecast to produce 9,984 new ATP AMEL airmen. This rate is declining, however, even if it held, 2022 would be on track to produce +103% more new pilots than 2021 but still only +4.9% more than 2016. Again, this is consistent with backfilling COVID-paused certifications, as pilots resume their qualifications.

 

The third chart shows the count of qualified pilots that also hold the required medical clearances. This chart shows a decrease in the1st class medical pilots number of ATP AMEL pilots with first class medicals, despite 845 new ATP AMELs issued in the month of July. This is an example of why new ATP AMEL certificates does not necessarily mean growth in the pilot population. This is particularly relevant in June to July. During peak summer demand, nearly all seniority list pilots would be active. Despite hundreds of new ATP AMELs each month, the chart shows the total count is barely growing month over month.

The misleading statement went on to note increased major airline hiring and reduced block hours serves as evidence of strong pilot production. In fact, each of these datapoints are fully consistent with a shortage, which has been additionally exacerbated by pandemic pressures on crew resiliency. Major airline hiring is not the same thing as new pilot production. Moreover, as major airlines hire more pilots than ever, including enough pilots to cover increased sick calls and avoid other disruptions, they draw from regional airlines. In turn, regional airlines find inadequate new pilots being produced to replace those departures. As a result, major airlines are trimming flights operated by their regional partners. These flights are not being replaced — 71% of the country has lost air service with an average loss of one in five flights. Because this shortage is primarily impacting regional airline routes, rural air service is being decimated. Travelers from these communities will spend more time on our nation’s highways as a result, where the accident and traffic fatality rate is soaring. CEOs of nearly every major and regional airline have acknowledged the pilot shortage is grounding aircraft and forcing service cuts to smaller communities. Unfortunately, some collective bargaining units deny the shortage and characterize any efforts to resolve it as anti-safety. This strategy, which puts collective bargaining interests above the interests of the traveling public, is unacceptable. “This is a serious crisis that’s hurting people in smaller communities,” concluded Black. “It deserves a serious response.” Media contact: media@raa.org

airports exclusively served by RA carriers


1500-Hour Rule Continues to Distract from Producing Better Pilots

Aug. 3, 2022

Kathryn Creedy

Kathryn Creedy

It has been 13 years since the Colgan accident in Buffalo, New York. While much has happened in training and safety science in the aviation industry including the addition of Upset Prevention and Recovery Training (UPRT), certain factions – most notably Air Line Pilots Association – and, by extension, Buffalo News – failed to recognize any of it including the fact the rule had serious negative safety implications.

Buffalo News A:PA CO3407 Rep. Higgins

Pilot unions, legislators and Buffalo News writers like to cast airlines as greedy, money-grubbing companies who do not want to do what it takes to deliver safe operations. Their minds are so closed they fail to recognize that there are better ways to train pilots being advocated by the international airline training and safety community.

Their continued agitation over the 1500-hour rule is, in fact, distracting us from developing the technology and standards sought by mainline airline trainers that produce better, safer pilots.

For instance, the Buffalo News charged the industry is trying to eliminate the 1500-hour rule when, in fact, it is on record as opposing any attempt to change the rule. An inconvenient truth for advocates. Efforts by Republic and SkyWest are petitions that are within the rule and deserving of consideration by genuine aviation safety professionals. While ALPA blamed the two airlines for failing to manage the pilot situation, it lodged the same charge against the mainlines as well but it has shirked its own responsibility in building better pilots.Lyft Academy

Advocates oppose Republic Airways petition to gain credit for Lift Training Academy curriculum that incorporates the Airline Safety & FAA Extension Act. Its curriculum adopts the combined wisdom prescribed by the training and safety professionals who crafted the Pilot Certification and Qualification Requirements for Air Carrier Operations and who were members of the Air Carrier Training Aviation Rulemaking Committee (ACT ARC) and the First Officer Qualifications Aviation Rulemaking Committee (FO ARC).

Advocates call it an effort to make an end run around the rule but a thorough analysis shows that is not true. This link provides access to all the relevant information so you can do your own research.Lyft Academy teacher and student

If Republic were a money-grubbing airline not interested in aviation safety, why did it invest $30 million in its curriculum to produce better pilots? Another inconvenient truth ignored by advocates.

Listening to Aviation Safety Experts

flight simulation trainingBut their activity continues to distract from what airline trainers say our goal should be – training better pilots. We know how to produce pilots that are not only proficient but are proven, by data analysis, to be competent, according to airline training professionals who want to see them respond to any situation the right way every time not just when they pass the flight test.

A few questions need to be asked about the efficacy of the 1500-hour rule but before getting to that, I should explain that I do not listen to airlines or labor unions when it comes to safety because they both have agendas.

I listen to the safety and airline training experts who want to see a dramatic change in how pilots are trained. Indeed, I’ve spent the past five years listening to them at World Airline Training Summit, the Royal Aeronautical Society and with many individual airline pilots who decry the policies of their union. These experts, including pilots, have convinced me the way we train pilots is antiquated and counterproductive.

One question we should be asking is why no other aviation authority in the world adopted the 1500-hour rule. Advocates of the rule said, without it, regional aircraft would continue to fall out of the sky. But that has not happened. Indeed, international pilots fly in and out of American airspace with fewer hours than U.S. regional new hires without incident.

As a side note, I was shocked to see Buffalo News quote Mesa CEO Jonathan Ornstein testimony expressing these exact sentiments because I’d not heard him and my discussions with others expressed these questions long ago.

Disingenuous Statistics

Advocates also credit the 1500-hour rule with keeping skies safe but since only the U.S. has that rule how do they explain that, in the rest of the world, planes are not falling from the sky?

“Some 1,186 people were killed in crashes of U.S. commercial planes in the two decades before the Flight 3407, but since the advent of that safety law, only two people have been killed on flights sponsored by U.S. airlines,” intoned the Buffalo News recently.

correlation v. causation

Really? Did that number include 9/11 but more importantly, were all those previous accidents attributable to pilot inexperience? The obvious answer is no because that accounting would include numerous mainline accidents including the United DC 10 at Sioux City, the rudder hard-over of a Northwest flight at Detroit, the American Airlines runway overrun at Little Rock which killed the captain and 10 passengers. The Alaska Airlines Flight 759 aircraft that went down in the Pacific, Southwest 1455 runway overrun at Las Vegas, USAir Flight 1493 which landed on a SkyWest Metro at LAX, Continental Airlines Flight 1404 at Denver, TWA 800 off Long Island, American Airlines Flight 1572 at Hartford, Delta Airlines Flight 1288, an uncontained engine failure, ValueJet 592 in the Everglades, Southwest 548 sliding off the runway at Midway, Northwest 299 in a midair over Detroit, FedEx 14 at Newark, American 587 which crashed in Queens, USAir 405 crashed on takeoff from LaGuardia, USAir 5050 also crashed on takeoff at LaGuardia, USAir 1016 crashed at Charlotte.

Yes, during that time, there were more than a dozen regional accidents BUT, the point is the entire regional airline industry is blackened unlike the mainline industry. Clearly, making such a statement as that of the Buffalo News is disingenuous at best and misleading at worst. To say the problem only exists at regionals is not only wrong but it prevents us from improving safety.

This is especially true since any safety expert will testify the safety record we have today is the result of not one rule but the concerted effort of the entire industry, safety experts and regulators to leverage data to identify safety problems before they conspire to become an accident. That watershed moment came in 1994 after two mainline and two regional accidents.

That is also why it is important to establish all factors in an accident since some of those listed were not pilot error. In the case of Colgan, the role of commuting, a sacred cow in the industry, was glossed over as the 1500-hour rule distracted us. When questioned about commuting at the time, ALPA’s response threw pilots under the bus saying it was their duty to show up rested and fit to fly. That does, of course, rightly call into question airline practices that are as much in question at mainlines as at regionals, as unions have recently pointed out.

The most important rule coming out of Colgan was one that had been in the works since 1994 – requiring the entire record of a pilot’s experience so bad pilots don’t get passed along as happened with the Colgan captain. Sadly, while the rulemaking was completed just this year, the infrastructure to make it useful is still a work in progress.

It’s Not the Hours, It’s the Experience

Airline trainers and safety professionals want to see the of adoption competency/evidence-based training that will extract data throughout training – and indeed the pilot’s career – to ensure pilots are not just proficientpilot performance which is today’s standard. Mainlines are already doing this. They also want to compliment the subjective evaluation of a flight instructor with data that ensures a great pilot every time.

One Captain recently boiled it down to this: We need to teach pilots how to physically fly the aircraft (no computers), how to manage the flight (weather, diversions, maintenance, passengers, etc.), as well as teach the pilot how to manage the computers (FMS, autopilot, auto throttle, etc.) so the aircraft does what the pilot intends.[2] Too often something happens and pilots respond with “why did it do that?” Then, like AF447, they are so busy trying to figure what happened and why, they fail to save the aircraft.

So, what do safety experts say about the 1500-hour rule. The National Transportation Safety Board opposed it when its then Chair Deborah Hersmann stated even pilots with 20,000 hours have accidents. Air France 447 is a great example and very similar to Colgan.

Another question needing to be asked is what happens to aspiring pilots between graduation from flight school or university. We know because the Flight Safety Foundation (FSF) studied this cohort and concluded the 1500-hour rule is counterproductive to safety.

FSF found these pilots lost the discipline and professionalism they learned in flight school and at university by towing banners, traffic reporting and the like. Another truth ignored by rule advocates.

This is especially significant since the National Transportation Safety Board, which pulls no punches when it comes to aviation safetyvalues discipline and professionalism as key to improving aviation safety.

Advocates say aspiring pilots need experience and they say 1500 hours is the right amount of experience. But Colgan proved that wrong. The captain had 3000+ hours of experience and the first officer nearly 2500 hours. So, why did advocates stop at 1500 hours? Why not 4000 which addressed both pilots’ experience?

Another question to be asked is why 1500-hour rule advocates have left these pilots on their own in the face of the FSF report? That is not in the interest of safety.

It begs the question of what kind of experience is valuable and this is why safety experts such as FSF, the NTSB and so many airline pilots privately tell me the rule is wrong. Time-building missions as described above have nothing to do with building the right experience they say, adding aspiring pilots don’t just need experience they need airline-related experience to ensure safety.

But ALPA, incredibly, opposes using simulators to accomplish this despite the fact simulators are key safety tools, invented to improve safety and to give pilots experience at maneuvers that have killed pilots when conducted in the air.

The rule and its advocates told aspiring pilots they were on their own when it came to building experience which could cost – just to build to 1500 hours, not flight school or university costs – $150,000+ and rising given fuel, flight instructor and aircraft costs – knowing full well it would limit the number of new pilots.

Wouldn’t it be better, if you are going to foist questionable requirements on these young people, to provide them relevant time-building opportunities? Wouldn’t it, in the interest of safety, be the responsible thing to do? Wouldn’t it contribute more to safety if these opportunities reinforced professionalism and discipline and provide airline-related experience?

While advocates told aspiring pilots they were on their own, the regional industry, to its credit, realizing there was significant remedial training needed amongst new hires, expanded their training footprint by 50%.

That may sound as if I am an apologist for the regional industry. I’m not. But it must be recognized that while 1500-hour rule advocates are just talking and criticizing, the entire airline industry is investing in aviation safety.

We Must Work Together to Produce Better Pilots

Airlines and labor are to blame for the pilot shortage and the loss of community air service, while tragic, is another distraction. We should not need excuses for improving aviation safety.

Airlines not only kicked the can down the road by keeping their heads in the sand, they exacerbated an already bad situation by using bailout funds designed to curtail layoffs to buy out pilots in an excruciatingly misguided policy.

That means, it is up to the airlines to solve this problem and it will ultimately mean they will pick up the training tab (some already are) just as they did decades ago.

But airlines cannot do it alone and we all must ensure the training that they provide has to be the right training. In solving this problem, we cannot ignore airline training professionals who want to transform training to meet 21st Century requirements and produce the best pilot not on some arbitrary hourly metric that does more harm than good.

Kathryn B. Creedy is a veteran aviation journalist and author who has covered every facet of commercial and business aviation.  Kathryn has written for Forbes Online and is the author of Time Flies – The History of SkyWest Airlines. Her byline has appeared in Air & Space and top aviation publications, including Air Transport World, Aviation Week and Space Technology, Flightglobal and Airline Business. She was the first North American editor/senior analyst for CAPA — Centre for Asia Pacific Aviation. She has also written for Airports, Business Travel Executive, Business Airports International, Airline Fleet Management, Aviation Maintenance, Transportation Security International, Low Fare & Regional Airlines and Inflight. She is currently editor of Future Aviation/Aerospace Workforce News.

 

[1] StatisicsHowTo.com is owned and operated by Independent Media Associates, Inc. Stephanie Glen originally conceived of this site and developed StatisicsHowTo.com’s original content. Stephanie worked as an adjunct professor of mathematics for Jacksonville University and Florida State College at Jacksonville before starting this site. She created the site to help her students in STA2023 to understand elementary statistics. It’s since grown to cover AP Stats and calculus-based statistics. You’ll find help for SPSS, Minitab, Excel and other popular technology for stats. There are more than 1000 articles, videos, calculators and tables. and it’s still growing!

Stephanie earned both an MAT (Mathematics Education) and an MFA in Creative Writing. She’s been teaching mathematics and statistics since 2006. Stephanie is a member of both Pi Mu Epsilon (the mathematics honors society) and Kappa Delta Pi (education honors society). She attended the University of Florida and FSU and took two additional years of coursework in education and mathematics education. Her publishing credits include the Sirius Elementary Statistics textbook published by Houghton Mifflin, which

[2] See safety performance targets by FSF

Pilots talking


 

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