Maintaining the Current Minimum First Officer Qualifications

The best and most important safety feature of any airline operation is a well-trained, highly experienced, and qualified professional pilot. With a solid foundation of training and experience, pilots are essential in maintaining the safety of our system and ensuring that aviation safety continues to advance. Several regional airline accidents from 2004 to 2009 identified numerous training and qualification deficiencies that ultimately led to Congressional action (P.L. 111-216) and regulatory changes that significantly improved aviation safety. The last of these accidents occurred February 12, 2009, near Buffalo, N.Y. Fifty lives were lost—49 in the aircraft and one on the ground. This accident is now viewed as a watershed event for the airline industry and aviation safety.

The U.S. Congress acted decisively and forcefully on the identified safety deficiencies by sending legislation to the president that addressed the documented shortcomings. P.L. 111-216, the “Airline Safety and Federal Aviation Administration Extension Act of 2010,” was signed into law on August 1, 2010.

Following the establishment of the law, and based on industry recommendations on how best to implement it, the Federal Aviation Administration (FAA), citing 31 accidents over a nine-year period, issued regulations to establish minimum first officer training and qualification requirements. The regulations became effective August 1, 2013.

The regulations require that all airline pilots flying under 14 Code of Federal Regulations (CFR) Part 121 must hold the air transport pilot (ATP) certificate, instead of only the commercial pilot certificate, and it created a new restricted ATP (R-ATP), which could be gained with fewer flight hours than the ATP if the pilot applicant receives aviation and flight training from the military or an accredited aviation college or university.

The new rules also emphasize significantly greater focus on academics and instruction, areas of knowledge, and flight experience in various weather and operational situations and also required a type rating in the aircraft to be flown for the airline employer, among other numerous safety improvements.

Some industry representatives who had initially been very supportive of the new regulations have since become critical of the new rules, arguing that they have created a pilot shortage. There is no reliable data to support this position. In fact, there is an adequate supply of qualified pilots and a robust pipeline of pilots to meet the needs of commercial aviation. In 2015, the FAA issued 6,430 ATP certificates, and in the first eight months of 2016, the FAA reported that they had issued 6,530 ATP certificates, including 599 R-ATP certificates. Regional airlines that report a shortage of pilots typically offer lower salaries, poor work-life balance, and fewer opportunities for career progression. Qualified pilots have many employment opportunities and some regional airlines have realized that to attract qualified candidates, they have to make competitive offers and invest in their pilots. Safety regulations should not be driven by the economic decisions of airlines.

Some are urging Congress to take action that would weaken, or eliminate altogether, many of the key components of the first officer qualification and training rules issued in 2013—reverting back to the environment that contributed to the 31 airline accidents cited by FAA. That is not in the public’s interest.


  • Maintain both P.L. 111-216 and the associated FAA regulations. The regulations establishing minimum first officer qualifications were based on safety and risk analysis and have proven to have significant safety benefits.
  • Do not modify or alter either the law or the regulations. This includes any attempts to weaken or roll back minimum first officer qualification requirements.

Download ALPA's position paper, "We Keep America Flying" (PDF)