The new ATP regulations that will most likely be implemented later this year have become a source of confusion and concern among many in the industry. The following is an attempt to simplify what is a fairly complicated regulation. For the full NPRM please see here. It should be noted since the FAA hasn’t released the final details we will just assume the current rule goes into affect as written.

Its easiest to distill the FAA’s new ATP rule down into three parts. First, standard track for someone who wishes to get an unrestricted ATP. Second, an educational track for someone who obtains an aviation degree from an approved University and goes through a part 141 training program at that University. Third, a military pilot looking to leave the military and enter the civilian world as an Airline Pilot.

Before we go any further we need to identify a couple of definitions:

ATP Certificate – Unrestricted allows the operator to exercise the privileges of an ATP, and to teach ATP applicants if they Part 121 experience. Must be 23 to have this no matter what background or track a pilot may go through. Must have standard ATP flight minimums, except for in the case of a military pilot where the total time is reduced to 750 hours.

(restricted) ATP Certificate – Restricted in that this is Multi Engine only, and the pilot cannot act as PIC, no matter how much experience they have. It allows a Pilot 21 years and older to be an SIC, provided they have gone through a Part 141 program that is tied to a Bachelor degree from an approved school, and has 1000 hours of experience with an Aviation degree. This pilot cannot operate as PIC and be awarded full privileges of the ATP certificate until 23.

ATP Certification Program – A 7 day course in high performance training outlined by the FAA, required to be completed by a pilot before taking the Knowledge portion of the ATP test. Very specific in regards to what kind of FTD and simulation devices can be used. Some parts of the training will require a full motion simulator and instructors with Part 121 experience. Only approved Part 121, 135, 142 and 141 training programs will be authorized to give these. Part 142 schools would be schools like Flight Safety. Estimated cost 5,771 dollars, according to the FAA’s NPRM.

The following is how they breakdown the ATP Certification Program. This is Table 2 and 3 from the NPRM document.


Cost factor Rate Period
Ground school instructor $33 per hour
Simulator instructor 130 per hour
Level C or D simulator 2000 4-hr simulator event
FSTD 400 4-hr simulator event
Training pay 1302 per month
Hotel 90 per day
Per diem 45 per day


Ground school instructor (3 days) $39
Simulator instructor (four 4-hr events) 2,083
Level C or D simulator (two 4-hr events, 2 pilots) 2,000
FSTD (two 4-hr events, two pilots) 400
Training pay & benefits (7 days) 304
Hotel (7 days) 630
Per diem (7 days) 315
Total Cost per Pilot 5,771


1. Ground school class sizes are assumed to average 20 pilots.
2. Simulator instructor, simulator, and FTD costs reflect the fact that flight training is typically done with two pilots concurrently.
3. As the FAA anticipates that the training would take place just prior to initial pilot training, there would be no incremental travel costs.


 Who needs this?

We also need to outline who will need an ATP. The simplest way to say this is any pilot that is an Airline Pilot is required to have an Airline Transport Pilot Certificate( restricted or unrestricted). This would be any Part 121 PIC, or SIC. Also any part 135 PIC will need the ATP, unless they are flying “On-demand” (charter) passengers in prop airplanes with less than ten passengers. All part 91 Sub-part K (fractional) PIC’s will be required to comply with this as well. Any SIC’s in Part 135 and part 91 Sub-part K will not be required to have an ATP, we will explore this and career progression in a later post.

Part 61 or Part 141 non (approved) Aviation Bachelor Degree – Track

Standard ATP Track

























From the previous track an ATP will not be required for hiring at a regional. Obviously without the ATP certificate an employee will not be able to exercise privileges of SIC or PIC, until that certificate is obtained.

Part 141 with an (approved) Aviation Bachelor Degree

Part 141 training with an approved 4 year degree




























It should be noted I do not have and cannot find a list defining what schools are approved under this exemption. To be safe assume 1500 hour requirements as the standard until schools are officially approved.

Military Pilot

– The FAA’s reasoning to justify the low total times needed  for military pilots, relies on the fact that military pilots undergo a selective screening process to become pilots while non military pilots have little screening.

Military Pilot Career Flow




























Note- Most Military routes will include a 1-2 year training period followed by a ten year commitment period. It is possible that a Military pilot for some operations could fly for the airlines while simultaneously fulfilling their commitment to the FAA.


It is likely most students will receive there ATP (restricted or unrestricted) through their first Part 121 flying job. This may become the natural solution due to the similarity of current Part 121 training programs at airlines and the previously defined ATP training course. These training programs are already equipped with the required instructors, simulators, and standardized training environment in place. Most of these airlines have experienced sizable stagnation and should have the facilities and instructors in place to accommodate a 7 day training period in addition to other introductory training. What is even more likely is that ATP and Type training received prior to receiving the ATP, should streamline the currently taught company indoctrination and type training now received at most airlines. The ATP certification program would be a reasonable extension of this training environment.

One positive result from this added investment by airlines could be greater loyalty to current pilots as training replacements becomes more expensive. This may also result in airlines investing more in pre-screening, pilot cultivation, and career development.

Problems :

Even though the Part 141 pilots will have a lower benchmark of 1000 hours for a Restricted ATP, they will have a more difficult time obtaining their 325 hours of required cross country time. This is the natural result of the Part 141’s more structured and formal approach to training, which naturally shy’s away from cross-country experience.

Solution: This cross country time problem for the Part 141 students could be partially remedied by a redesign in the Part 141 syllabus to include more cross-country training.

Part 61 pilots will have a higher benchmark of 1500 hours for an Unrestricted ATP, but may have an easier time obtaining the 500 hours cross country time required. This is inherently a result of the nature of Part 61 training that allows a more tailored training structure for students, and often times more exposure to real world circumstances on Cross Country flying useful in this type of training environment.

The challenges posed to Part 61 or Part 141 students from non approved schools is there inability to access a “restricted” ATP at 1000 hours.

Solution: It would be wise to allow Part 61 equal access to “restricted” ATP certificates instead of only “unrestricted” certificates. Also there is little evidence that states part 141 schools will produce better pilots than part 61 schools where a more customized training approach is used.


Look to the next post for a breakdown on pipeline progression.


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