The 1,500 Hour ATP Rule

Below is a summary I wrote for a family friend who was doing a debate project on the 1,500 hour rule for ATP certification. In this article I summarize where to find the regulations regarding the rule, decode and clarify the regulations themselves, and then give some thoughts on how the rule could be theoretically changed to reduce total hours while still requiring a breadth and depth of experience. I personally am opposed to reducing the total number of hours to be eligible for an ATP. However, times change and inflation only keeps happening so I will just posit a guess here in 2023 that we will see some change on this rule from congress in the next decade or two.

All aviation regulations in the U.S. are contained in the Code of Federal Regulations or CFRs for short. Specifically they are contained within the 14th Title of the CFRs. Each Title is then subdivided into Parts. All regulations in regard to pilot certifications are contained within the 61st Part of Title 14 or 14 CFR Part 61 for short. From there we can find all regulations in regard to the certification of Airline Transport Pilots. Since we are only concerned about airline flying we will further limit our search to those regulations which only concern airplanes and disregard rotorcraft (helicopters), lighter than air (balloons) and the like. Since all major airlines only fly multi engine (more than one engine) land (airplanes that can't land on water) we have finally arrived at the query of our search. 14 CFR Part 61 ATP Airplane Multiengine Land Certifications. 

All of my comments and clarifications of the regulations below are highlighted in green.

§ 61.159 Aeronautical experience: Airplane category rating.

(a) Except as provided in paragraphs (b), (c), and (d) of this section, a person who is applying for an airline transport pilot certificate with an airplane category and class rating must have at least 1,500 hours of total time (total time is any flying time including airplanes, rotorcraft, and lighter than air) as a pilot (you can't just fly along as a passenger, you actually have to be flying the airplane) that includes at least:

(1) 500 hours of cross-country flight time. (This is time flying between two destinations which are at least fifty nautical miles apart)

(2) 100 hours of night flight time. (Defined as thirty minutes after sunset to thirty minutes before sunrise.)

(3) 50 hours of flight time in the class of airplane for the rating sought. (This means you have to have 50 hours of multi engine time specifically before getting your ATP. This is very difficult as multiengine time normally costs somewhere between $400 and $1000 per hour if you are renting an airplane. I only had eight hours of multiengine time after getting my multiengine commercial certificate and thankfully my company let me fly as a copilot to build the rest of these fifty hours.) A maximum of 25 hours of training in a full flight simulator representing the class of airplane for the rating sought may be credited toward the flight time requirement of this paragraph if the training was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter. (Flight simulators are multi million dollar system certified by the FAA to look and feel just like the real airplane. This isn't something you get from playing a video game. Simulators can cost even more to rent per hour than a "cheap" multiengine airplane mentioned above.) A flight training device or aviation training device may not be used to satisfy this requirement. (Flight training and aviation training devices are basically the fancy video game version of a simulator and the FAA doesn't want to count this time towards the ATP because it is very unrealistic. Most flight training devices cost about $100 per hour to rent.)

(4) 75 hours of instrument flight time, in actual or simulated instrument conditions, subject to the following: (Instrument flight time is the time you spend flying without looking outside and only looking at the instruments in the instrument panel. This is very challenging flying but is at the core of what airline flying is all about. Actual instrument time is time you are actually in an airplane flying in the clouds. Simulated instrument time is time when you are flying but with a hood over your head so that you can't see outside. You must have an instructor or safety pilot with you to fly simulated instrument time. If you didn't have someone else you could run into something accidentally.)

(i) Except as provided in paragraph (a)(4)(ii) of this section, an applicant may not receive credit for more than a total of 25 hours of simulated instrument time in a full flight simulator or flight training device. (Basically they want to make sure that you have experience flying on instruments in a real airplane and not just in a simulator.)

(ii) A maximum of 50 hours of training in a full flight simulator or flight training device may be credited toward the instrument flight time requirements of paragraph (a)(4) of this section if the training was accomplished in a course conducted by a training center certificated under part 142 of this chapter. ( A part 142 training center is a highly structured and FAA approved simulator flight school. This is not goofing around on a simulator somewhere without much supervision or structure.)

(iii) Training in a full flight simulator or flight training device must be accomplished in a full flight simulator or flight training device, representing an airplane. (You can't count simulator time from a rotorcraft or lighter than air aircraft. They want it in something that simulates how an airplane flies.)

(5) 250 hours of flight time in an airplane as a pilot in command, or as second in command performing the duties of pilot in command while under the supervision of a pilot in command, or any combination thereof, subject to the following: (They want to make sure that you haven't flown off all your hours as a copilot without a lot of responsibility with someone else making all the decisions)

(i) The flight time requirement must include at least— (Additional restrictions on the above 250 hours)

(A) 100 hours of cross-country flight time; and

(B) 25 hours of night flight time.

(ii) Except for a person who has been removed from flying status for lack of proficiency or because of a disciplinary action involving aircraft operations, a U.S. military pilot or former U.S. military pilot who meets the requirements of § 61.73(b)(1), or a military pilot in the Armed Forces of a foreign contracting State to the Convention on International Civil Aviation who meets the requirements of § 61.73(c)(1), may credit flight time in a powered-lift aircraft operated in horizontal flight toward the flight time requirement. (This subsection basically allows military helicopter pilots to count their experience towards the above requirement. Military helicopter pilots are highly skilled pilots and before this exception was put into the regulations they had to go fly an airplane a lot more before they could get their ATP and go to the airplanes.)

(6) Not more than 100 hours of the total aeronautical experience requirements of paragraph (a) of this section or § 61.160 may be obtained in a full flight simulator or flight training device provided the device represents an airplane and the aeronautical experience was accomplished as part of an approved training course in parts 121, 135, 141, or 142 of this chapter. (Further limit on the 1,500 hour rule from the very beginning to make sure that not too much time is counted from simulators towards actually flying. All of the approved training courses listed, 121, 135, 141, and 142 are all highly structured.)

(b) A person who has performed at least 20 night takeoffs and landings to a full stop may substitute each additional night takeoff and landing to a full stop for 1 hour of night flight time to satisfy the requirements of paragraph (a)(2) of this section; however, not more than 25 hours of night flight time may be credited in this manner. (This allows you to substitute night landings for night hours. Tgis is interesting. I hadn't heard of this until now. Kind of goes along with the reasoning for lowering hours but increasing landings.)

(c) A commercial pilot may log second-in-command pilot time toward the aeronautical experience requirements of paragraph (a) of this section and the aeronautical experience requirements in § 61.160, provided the pilot is employed by a part 119 certificate holder authorized to conduct operations under part 135 of this chapter and the second-in-command pilot time is obtained in operations conducted for the certificate holder under part 91 or 135 of this chapter when a second pilot is not required under the type certification of the aircraft or the regulations under which the flight is being conducted, and the following requirements are met— (This whole section allows copilots at small charter airline companies, like my company, to log time toward their ATP but yet not be considered a necessary crewmember in the airplane they are flying. This applies to airplanes that only require one pilot, yet the company has permission for a second pilot to fly along as a copilot in the interest of safety. This would otherwise not be allowed as the number of pilots must match the number of pilots the manufacturer said the airplane needs to have.)

(1) The experience must be accomplished as part of a second-in-command professional development program approved by the Administrator under § 135.99 of this chapter;

(2) The flight operation must be conducted in accordance with the certificate holder's operations specification for the second-in-command professional development program;

(3) The pilot in command of the operation must certify in the pilot's logbook that the second-in-command pilot time was accomplished under this section; and

(4) The pilot time may not be logged as pilot-in-command time even when the pilot is the sole manipulator of the controls and may not be used to meet the aeronautical experience requirements in paragraph (a)(5) of this section.

(d) A commercial pilot may log the following flight engineer flight time toward the 1,500 hours of total time as a pilot required by paragraph (a) of this section and the total time as a pilot required by § 61.160: (This section allows pilots who worked previously as flight engineers to count some of their flight engineer time towards pilot time. Flight engineers do not actually fly the airplane however on big old airplanes they manage the operation of the fuel, electrical systems, landing gear, and engines. I have heard mixed results regarding pilots who substitute flight engineer time in this way. They are so close yet so far from actually flying and commanding an airplane when acting as a flight engineer.)

(1) Flight-engineer time, provided the time—

(i) Is acquired in an airplane required to have a flight engineer by the airplane's flight manual or type certificate;

(ii) Is acquired while engaged in operations under part 121 of this chapter for which a flight engineer is required;

(iii) Is acquired while the person is participating in a pilot training program approved under part 121 of this chapter; and

(iv) Does not exceed more than 1 hour for each 3 hours of flight engineer flight time for a total credited time of no more than 500 hours.

(2) Flight-engineer time, provided the flight time—

(i) Is acquired as a U.S. Armed Forces' flight engineer crewmember in an airplane that requires a flight engineer crewmember by the flight manual;

(ii) Is acquired while the person is participating in a flight engineer crewmember training program for the U.S. Armed Forces; and

(iii) Does not exceed 1 hour for each 3 hours of flight engineer flight time for a total credited time of no more than 500 hours.

(e) An applicant who credits time under paragraphs (b), (c), and (d) of this section is issued an airline transport pilot certificate with the limitation, “Holder does not meet the pilot in command aeronautical experience requirements of ICAO,” as prescribed under Article 39 of the Convention on International Civil Aviation. (This limits pilots who have used the above exemptions to not be able to fly internationally until they reach the full standards. This isn't really a problem because only highly experienced and more senior crews get to fly the long international flights. This in my opinion should say something about what the rest of the world would think about American exceptions to the rules and what is considered the gold standard for pilot certification of professional pilots.)

(f) An applicant is entitled to an airline transport pilot certificate without the ICAO limitation specified under paragraph (e) of this section when the applicant presents satisfactory evidence of having met the ICAO requirements under paragraph (e) of this section and otherwise meets the aeronautical experience requirements of this section.

Cutting hours from an already gold standard requirement is tricky business. Here are some initial thoughts to consider as prerequisites when weighing how to cut and adjust hours. Most pilots require about 250 hours of flight time just to get through the basic certifications needed just to start heading towards the ATP. They will come out of this with about 25 hours of instrument time, 100 hours cross country, 30 night hours, and 300 or so landings. The requirement in the past for copilots at the airlines was 250 hours before they upped it to 1500. I have taught MANY 250 hour pilots and I would frankly be scared to death riding in the back of an airliner if I knew one of them was up front. This is not an insult in the least and the vast majority of those pilots were average or well above average. They problem was they didn't know what they didn't know yet. Also, what they had experienced up to that point was only a fraction of what a typical professional pilot experiences in a year of flying. Most pilots I know really start to mature in their flying at about 1,000 hours total time and really blossom into confidence and good judgement at about 2000 to 3000 hours. After that many hours the average pilot has learned 90% of what they will learn in a 40 year career and most will actually go through a period of complacency and lack of motivation after a few years of professional flying before they either decide to really up their game and be a safe and conscientious pilot or just get by on the minimum standards. 

If it were up to me and total hours had to be reduced I would add landing requirements of say one landing for every hour of flight time you take away. So if you want total time to be 750 hours you would also need to have 750 landings for the 750 hours you took away. If you wanted it to be 500 hours total time you would need to have 1,000 landings. I would also up the cross country, night, and PIC hour requirements somewhat to make up for the loss of total hours. No more than 25% max. 

The problem with all of the requirements given in the regulations above is that they can almost all be accomplished in what I call the "training bubble". You can go get almost all of your cross country, night, and instrument time within a hundred or two hundred mile radius of your home airport and only ever land at the same five airports. When I taught at Council Bluffs most everybody who flew there had only ever flown within a one hundred mile radius east of the airport. They were afraid of the control zone over Eppley, Offutt, and Lincoln so most only went east from Council Bluffs. This control zone is no big deal once you know how to get in and out of it and all of them had but without even realizing it, they avoided it. If it were me I would add extra distance requirements to the cross country requirements to visit at least ten states or something like that to get them out of the next. You get into problems though for pilots who train in Alaska and Hawaii and also pilots who only have enough money for relatively short flights. If you went on say a one thousand mile trip to the east coast and back in a little single engine rental airplane in two days the bill would probably be close to three thousand dollars. 

Instructor time is also something you could consider using to offset reduced total time from 1500 hours. Most new instructors hone their skills to a much higher level if they instruct for several hundred hours versus a person who doesn't instruct. The average pilot will probably not gain much experience in this way after about 500 hours of instructing. After that point they have mastered the airplane to a greater extent and can get the average student through a training program to achieve the early certifications. An industry problem with instructing, however, is what we call "blind leading the blind". In short, a pilot is trained by an instructor who was recently a student. He trains a few students, gets a few hundred hours and then leaves for better job.  This cycle repeats over and over again and results in a lack of experienced instructors. Bad habits are passed from one instructor to the next because the instructor is still learning himself and hasn't reached a point where they really understand what they are doing and can self critique themselves. Most flight schools pay flight instructors what equates to about double or triple the minimum wage so there's very little motivation to hang around and keep teaching unless you just really enjoy doing it. This is a problem because the average instructor will work their brains out to only fly about four or five hours in a full ten to twelve hour work day. If it rains or snows, there's no flying, and therefore no pay.

I hope you enjoyed this brief analysis of the 1,500 hour rule issue. The problem, as it stands in 2023, is a highly contentious issue and we will likely see a lot more lobbying and maneuvering before anything actually happens in the hallowed halls of congress. 

Blue skies and tailwinds.