On February 12, 2009 Colgan Air Flight 3407, operating as Continental Connection Flight 3407, crashed on an instrument approach to Buffalo – Niagara International Airport.  All 45 passengers and four flight crew died, along with one person on the ground.

One year later the NTSB issued its investigation report.  It concluded that the cause of the accident was the captain’s inappropriate control response to stick shaker activation which resulted in an accelerated stall.  Contributing factors identified by the NTSB included the Captain’s failure to effectively manage the flight, failure to adhere to sterile cockpit procedures, inadequate airmanship on the part of both pilots, and Colgan’s inadequate procedures.  At the time of the accident the Captain held an airline transport pilot (ATP) certificate, and had accumulated a total of 3,379 hours of total flight time.  The first officer held a commercial rating and had total flight time of 2,244 hours.

Soon after the crash, survivors began lobbying Congress for legislative action.  Congress responded by passing the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public Law 111-216) requiring the FAA to draw up new rules on pilot experience, training and rest, which mandated that co-pilots as well as pilots possess an ATP certificate requiring a minimum of 1,500 flight hours.  The FAA responded by issuing rules promulgating new flight crew qualification and certification standards, including the 1,500 hour and ATP requirements for copilots, in July, 2013, effective August 1, 2013.

No effort is made here to explore the details of these rules. Rather, the purpose is to discuss the practical impact of these rules on safety and the airline industry.

The impact of the ATP and 1,500 hour requirement falls mainly on regional carriers whose role in airline operations blossomed as trunk carriers struggled to cut costs in response to deregulation. The trunks outsourced many operations to regional carriers who employed cockpit crew with minimum experience—as little as 250 hours for co-pilots—for minimum wages to fly turboprop and regional jets under agreements with major carriers.

Regional carriers are resisting these requirements, asserting a shortage of pilots and possible unpopular service reductions. “All of our members, large and small, are having trouble finding qualified 1,500-hour pilots,” says Roger Cohen, president of the Regional Airline Association. “Every community, large and small, if you’re not concerned about losing some or all of your air service, you should be.”  “Are we going to see some changes in that 1,500-hour rule – the flight duty rule,” Sen. Deb Fischer, R-Neb., asked Federal Aviation Administration Administrator Michael Huerta at a recent hearing. “Are you going to be flexible and accommodating with us?”  Secretary Huerta responded by reminding the Senator that Congress imposed the requirement.  The Air Line Pilots Association – which represents major carrier aircrew, and has members on layoff – denies that any shortage exists.

The real question is whether the new requirements will enhance air safety.  It is worth considering that the Colgan 3407 captain probably would have satisfied the new rules, and that its copilot had well over 1,500 hours.  The crew of Asiana flight 214 had logged many thousands of hours, but may have not been adequately familiar with their aircraft and systems for a visual landing, and apparently failed to appropriately monitor their final approach airspeed and flight path.   And the NTSB found that the Colgan captain’s improper control inputs stalled the aircraft.

Professor Daniel Rust of the Center for Transportation Studies at the University of Missouri-St. Louis questions the 1,500 hour rule.  “Logging more time in the cockpit does not automatically translate into pilots with significantly more knowledge and skills,” he says.  “Over reliance upon automation is the real issue.  Nothing replaces learning and maintaining good ‘stick and rudder’ skills combined with vigilant situational awareness.” The principal effect of the “1,500 hour rule” and the new aircrew certification requirements may be to decrease the role of regional carriers as farm teams for pilots seeking airline careers in the big leagues.  Additionally, the new rules may accelerate the trend toward rising airline fares and fees and corresponding airline service reductions.