The 1500-Hour Rule - Is America at a Disadvantage?

     On a bleak winter evening, on February 12, 2009 at about 10:17 p.m., Continental Connection Flight 3407 (operated by Colgan Air, Inc.) crashed while on final approach into Buffalo, New York.  The repercussions from this crash had a transformative impact on pilot experience requirements for air carriers as well as on aviation training.  The end result was a requirement that any pilot operating as a first officer with an air carrier would need to have a minimum of 1500 hours of total flight experience, significantly increasing the prior required flight hours from 250 hours.  The International Civil Aviation Organization (ICAO) has not adopted this model, and has instead supported a Multi-Crew Pilot License (MPL) program which leads to certification in 240 hours, ab initio (meaning without any previous flight experience).  The program requires specific types of flight training and quickly transitions the student to the multi-engine (ME) and multi-crew environment.  The obvious advantage for foreign pilots and flight schools is the reduction in costs associated with becoming a professional airline pilot.  Why travel to the United States to study aviation when such programs (and future employment) are available overseas?  Most U.S. civilian pilots will meet this requirement by teaching in simple single-engine (SE) propeller trainers with antiquated gages, as opposed to building flight hours in multi-engine jets with sophisticated state-of-the-art glass cockpits.  Both pilots in the Colgan crash well exceeded the 1500 flight hour experience requirements.  This article will explore this different approach to training.  

     Let’s begin with a brief review of the Colgan accident, beginning with the crew’s flight experience.  The captain had accumulated 3,379 hours of total flying time, including 3,051 hours in turbine airplanes, 1,030 hours as a pilot-in-command (PIC), and 111 hours on the Q400.  The first officer held a commercial pilot certificate and had accumulated 2,244 hours of total flying time, including 774 hours in turbine airplanes and on the Q400.  Thus, both pilots had in excess of the 1500 hour total flight experience, which was mandated by the Federal Aviation Administration (FAA) as a result of the crash.[1]

     Turning to the activities of the captain and the first officer prior to their duty on this flight, it is to be noted that both pilots suffered from significant fatigue.  According to the National Transportation Safety Board (NTSB) Accident Report, the captain spent the night before the accident sleeping in the company crew room, where he obtained, at best, eight (8) hours of uninterrupted sleep as evidenced by multiple logins to the CrewTrac computer system (a scheduling system). The Chairman of the NTSB, Deborah A.P. Hersman, noted that, “conservatively, the captain in this accident obtained 2 fewer hours sleep than his usual sleep and perhaps, significantly less based on his quality of sleep.”  In addition to sleep loss, it was also noted that the captain had a cumulative sleep debt of between six and twelve hours, which reflected the two to four hours of sleep that he accumulated over the course of each of the preceding three nights, two of which were also spent in a crew lounge.  At the time of the accident, he had been awake for at least fifteen hours – three hours more than the levels at which a 1994 NTSB study identified performance degradation in accident flight crews.  Id.   

     The first officer was similarly not properly rested. The night before the accident she commuted from Seattle, Washington to Newark, New Jersey, changing planes shortly after midnight in Memphis, Tennessee and arriving at Newark at 6:30 a.m., which was 3:00 a.m. Seattle time.  In the preceding thirty-four hours before the crash, she had only gotten a maximum of 8 ½ hours of total sleep – three to five hours of which were while traveling overnight cross-country ( 1 ½ hours from Seattle and 2 hours from Memphis to Newark), and the remaining 5 hours while resting in the company crew room.  Id.

     Against this background, let us examine the crash itself.  Continental Connection Flight 3407, a Bombardier DHC-8-400 (Q400), was flying from Newark, New Jersey to Buffalo-Niagara International Airport in Buffalo, New York.  The flight was routine until its final approach into Buffalo.  The activities of the crew in the ten minutes leading up to the incident are noteworthy.  Eleven minutes before the approach, the captain began the standard approach briefing for an instrument approach landing system (ILS) approach to runway 23.  The flight cockpit data recorder showed that the airplane descended to 10,000 feet at about 2206:37 (roughly 10 ½ minutes before the accident).  From that point on, the flight crew was required to observe the sterile cockpit rule (meaning conversations should be limited only to matters directly pertaining to the flight).  They did not.  The cockpit voice recorder discloses that the crew was maintaining casual and extraneous conversations.  Id.  

     Five minutes before the crash, the approach controller cleared the flight to descend and maintain 2,300 feet and subsequently directed the plane to make turns for the ILS runway 23 intercept.  As the airplane was approaching the preselected altitude of 2,300 feet, the airspeed was about 180 knots (and completely normal).  Id.  

     Two minutes before the crash, the captain called for the flaps to be moved to the 5° position.  Afterward, the approach controller cleared the flight crew to turn left onto a heading of 260° and maintain 2,300 feet until established on the localizer for the ILS approach to runway 23.  The captain then began to slow the airplane down less than three miles from the outer marker (an approach point) to establish the appropriate air speed before landing.  According to the flight data recorder, the engine power levers were reduced to 42° (flight idle was 35°) and both engines’ torque values were at minimum thrust.  The approach controller then instructed the flight crew to contact Buffalo air traffic control tower, which was acknowledged by the first officer.  Id.

     One minute before the crash, the first officer told the captain that the gear was down and that the airspeed was about 145 knots.  Later, the flight data recorder showed that additional pitch trim in the airplane-nose-up direction had been applied by the autopilot and that an “ice detected” message appeared on the engine display in the cockpit.  At about the same time, the captain called for the flaps to be set to 15° and for the before landing checklist to be completed. The cockpit voice recorder recorded a sound similar to a flap handle movement, and the flight data recorder showed that the flaps had been selected to 10°.  The flight data recorder also showed that the airspeed at this time was about 135 knots.  Id.

     Roughly thirty seconds before the crash, the cockpit voice recorder recorded a sound similar to the stick shaker.  The stick shaker warns a pilot of an impending wing aerodynamic stall through vibrations on the control column, providing tactual and aural cues.  The cockpit voice recorder also recorded a sound similar to the autopilot disconnect horn, which repeated until the end of the recording.  Data indicates that the airplane was at an airspeed of 131 knots when the autopilot was disengaged.  The cockpit voice recorder recorded a sound similar to an increase of engine power, and the flight data recorder showed that engine power increased to about 75% torque.  Id.

     At this point the flight data recorder showed that while the engine power was increasing, the airplane was pitching up; rolled to the left, reaching a roll angle of 45° left wing down; and then rolled to the right.  As the airplane rolled to the right through wings level, the stick pusher activated and flaps 0 was selected.  At about 2216:37, the first officer told the captain that she had put the flaps up.  The flight data recorder confirmed that the flaps had begun to retract by 2216:38; at that time, the airplane’s airspeed was at about 100 knots.  The aircraft’s pitch and roll angles were erratic and the aircraft reached 25° nose down, and a 100° right wing down, respectively, when the airplane entered the steep descent ending in the crash.  Id.

     Stall recovery conventionally requires the application of forward elevator pressure to move the nose down to regain airspeed with the additional application of power.  The action in pulling back on the control column (rearward elevator pressure) to raise the nose and the retraction of the flaps by the crew in the stall recovery scenario was fatal.  Flaps add additional lift, but increase induced drag.  By lifting the flaps back into retracted positon, the additional lift provided by the flaps, at a critically low air speed, was negated.

     The NTSB faulted the captain for inappropriately reacting to the aerodynamic stall as the primary cause of the accident, with contributing factors being: (1) the flight crew’s failure to monitor airspeed in relation to the rising position of the low-speed cue; (2) the flight crew’s failure to adhere to the sterile cockpit rule; (3) the captain’s failure to effectively manage the flight; and (4) Colgan’s inadequate procedure for airspeed selection and management during approach in icing conditions.  Despite the history of crew fatigue prior to the accident, fatigue was not cited as an official cause of the accident, much to the dismay of the Chairman of the NTSB, Deborah A.P. Hersman.[2]  Id.

     As a result of the accident, the NTSB recommended better stall recovery techniques, theorizing that the training the crew received for stall recovery was inadequate - existing protocols required that the stall recovery occur with minimal loss of altitude.  The new stall recovery training would emphasize full recovery with less emphasis on minimal loss of altitude. 

     The other change to come from this crash was the 1500-Hour Rule.   According to its press release, the FAA states, “[t]he rule requires first officers – also known as co-pilots – to hold an Airline Transport Pilot (ATP) certificate, requiring 1500 hours total time as a pilot.  Previously, first officers were required to have only a commercial pilot certificate, which requires 250 hours of flight time.”  The new Secretary of Transportation at the time, Anthony Foxx, further commented that, “I am especially pleased to mark my first week by announcing a rule that will help us maintain our unparalleled safety record.” [3]  FAA Administrator Michael Huerta stated:

"The rule gives first officers a stronger foundation of aeronautical knowledge and experience before they fly for an air carrier," said FAA Administrator Michael Huerta. "With this rule and our efforts to address pilot fatigue — both initiatives championed by the families of Colgan flight 3407 — we're making a safe system even safer." 

Id.

     Other highlights of the rule include:

  • A requirement for a pilot to have a minimum of 1,000 flight hours as a co-pilot in air carrier operations prior to serving as a captain for a U.S. airline;
  • Enhanced training requirements for an ATP certificate, including 50 hours of multi-engine flight experience and completion of a new FAA-approved training program; and
  • An allowance for pilots with fewer than 1,500 hours of flight time or who have not reached the minimum age of 23 to obtain a "restricted privileges" ATP certificate. A restricted privileges ATP certificate allows a pilot to serve as a co-pilot until he or she obtains the necessary 1,500 hours. The options are:
  1. Military pilots with 750 hours total time as a pilot;
  2. Graduates holding a Bachelor's degree with an aviation major with 1,000 hours total time as a pilot;
  3. Graduates holding an Associate's degree with an aviation major with 1,250 hours; and
  4. Pilots who are at least 21 years old with 1,500 flight hours.

     Exactly how a pilot is supposed to meet the minimum 1,500 flight hour requirement is complicated.  One option is to become a flight instructor and build time, however, not everyone who is a good pilot is also is good teacher – they are two separate skill sets.  There is some potential opportunity to work under Part 135 Operators (charters) and the military is another option for some.  Though the graduates of college level flight programs are given a reduction in the number of required hours (1,250), on average they will be far from even meeting the reduced requirements at graduation (after incurring massive tuition bills).

     Overseas, ICAO has supported a Multi-Crew Pilot License (MPL) program which leads to certification in 240 hours, ab initio (meaning without any previous flight experience).  The program is generally broken into four segments:  (1) Core Flying Skills; (2) Basic; (3) Intermediate; and (4) Advanced. [4]  Some important distinctions between U.S. flight training and this training are worth mentioning.  First, upset training (in an acrobatic airplane) is introduced in the Basic component of the training.  Typically, a U.S. pilot candidate will not be introduced to any form of significant acrobatics in pursuing a commercial pilot’s license.  The student may undertake such training at his or her option, but it is not required.  Spin training is conducted for the flight instructor rating.  Multi-crew training in multi-engine airplanes is also introduced much earlier in the Intermediate component.  Typically a U.S. pilot candidate will obtain a private pilot’s license, instrument rating and commercial single-engine license with a goal to complete that training near the minimum required 250 hours.  The U.S. single engine pilot’s license is not good for much – banner towing (with additional training), local sightseeing flights, and fish spotting along the coast come to mind.  The U.S. pilot candidate will then pursue the flight instructor rating (to make money) and add on multi-engine ratings.  Multi-crew training does not typically occur until employment with a charter or a carrier.

     Typical training MPL scheme:

       Notes:  FSTD (Flight Simulator Training Device) Id.

     The U.S. does not currently offer a Multi-Crew Pilot License, which is now recognized in many countries throughout the world.  Thus, foreign students have less incentive to come to the United States for training. 

     Should the U.S. take another look at ICAO’s ab initio training?  Does the quantity of hours matter or is it the type of training that counts?  Consider U.S. Navy pilots who become carrier qualified with just several hundred hours.  Clearly, the answer lies somewhere in between.  It is time for the FAA to rethink its flight hour requirements.

Fly safe!

[1]  National Transportation Safety Board, Loss of Control on Approach, Colgan Air, Inc., Operating as Continental Connection Flight 3407, Bombardier DHC-8-400, N200W, Clarence Center, New York, February 12, 2009,  Aircraft Accident Report NTSB/AAR-10/1 (Washington, DC: NTSB, 2010).

[2] The FAA did, however, increase the crew rest requirements, in part as a result of this incident.

[3] “Press Release – FAA Boosts Aviation Safety with new Pilot Qualification Standards,” Federal Aviation Administration, 10 July 2013, https://www.faa.gov/news/press_releases/news_story.cfm?newsId=14838 [last accessed 2/29/16].

[4] “Guidance Material and Best Practices for MPL Implementation, 2nd Edition,” International Air Transportation Association, July 2015.