The previous post on the new ATP rule spells out the requirements for Part 121 and other operations but how does this actually affect the pipeline? The following is a brief attempt to begin to quantify the training pipeline.

In the last 10 years we have seen an anomaly regarding pilot hiring flight time requirements at the regional airlines. Talk to most pilots who have been at the regional airlines longer than ten years and you will hear countless examples of how they were hired with multiple thousands of hours of flight time from a variety of sources. It was only in the last ten years as the regional airlines exploded in size (doubling every 2-3 years) where the demand for pilots drove down minimum and competitive flight experience requirements. This phenomenon was also coupled with an increase in the cost of General Aviation and pilot training that created a unique environment where we saw pilots being hired with less than a 1,000 hours at the Regional airlines.

From multiple reports we can show with a good level of certainty that the regional airlines will no longer see that kind of growth, even though attrition to mainline/destination carriers will create what I would call healthy movement.

The first question we need to ask is what kind of flying jobs can be used be “up and coming” pilots to build the necessary time to finally arrive at the airlines? Since this new regulation makes airline pilot positions operating high performance jets no longer entry level pilot positions, we need to explore what the entry level pilot positions will now be.

According to the new ATP rule only certain pilot positions will not need the new ATP.

  • Flight Instructors (not instructing for the ATP certification)
  • Part 135 First Officers
  • Part 135 Charter propeller operations with less than 10 people
  • Part 91 non Subpart K flight operations (this would be non fractional) (pipeline patrol, banner tow, etc)
  • Part 91 Subpart K (fractional/corporate) First Officers
  • Military Flight Operations
Lets first explore the number of Part 135 positions and Part 91 Subpart K positions available.
I used data gleaned from to compile this initial estimate. I realize this does not contain all of the Part 135 or Part 91 Subpart K positions that are out there.
Table 1. (Part 135 and Part 91 Subpart K Pilots)
Cape Air 247
Era 86
Great Lakes 307
Key Lime 40
Airnet 94
Ameriflight 183
Empire 92
Flight Express 39
Mountain Air Cargo 120
Air Cargo 70
Avantair 220
Citation air 228
PlaneSense 110
Total Pilots             1836
Previous Total 1836
NetJets 2570
FlexJet 318
XO Jet 215
Total Pilots 4939

You will notice I separated these numbers into two groups. The first group will easily incorporate new pilots into the right seat, however the second group may take longer to adjust to the new paradigm. The second group will be motivated financially to seek out new pilots looking to build time, as a way to reduce cost. The main driver is pilots in the right seat at these fractional operators will be legally require to have less flight experience and training than the regional airlines. This will be a dynamic shift, that will prove interesting to watch.

The operations totaled in this list require ATP certified PIC’s but according to the FAA do not require ATP certificated First Officers. For now I will assume retirements at the PIC level in these jobs will be negligible for the foreseeable future. It is also possible that some due to insurance purposes will require ATP certified SIC’s. I’ve separated the list into two categories so that the reader can see the possible breakdowns.

We can safely assume that 50% of the previous list will be First Officers. As an extension of the ATP rule this is also the number of pilot positions that will not require an ATP.

Table 2. (First Officers not requiring an ATP)

First Officers 2469

We can further break this down by assuming most incoming pilots who take this route will need two years to develop the required flight time by the airlines to obtain an ATP. This would make the number available to Part 121 carriers each year roughly the following.

Table 3. Number of First Officers available for Part 121 and Part 135 PIC and Part 91 PIC positions.(assumes average 2 years necessary to build required time)

Half every year 1234

The next question we need to ask, what number of pilots can we estimate will be coming from the Military? I’ve done a good deal of research on this and the answer is hard to define, however I think we can make some reasonable guess’s.

The following document/link is research done by Rand group some years back. It is very interesting and if your interested will actually show the previous hiring wave from the 80’s and 90’s. It also shows the amount of military pilots who left the military for the airlines each year. The report goes one step further and shows the breakdown of attrition to the airlines between military groups. Even though the Data is old it gives a interesting starting point.

Quickly lets summarize some of the changes that have occurred since 1997.

  • First – during the last decade the military required pilots to sign up for ten year commitments which naturally extended the military career of an aviator, thus reducing the window of attrition and the number of pilots available for airline careers.
  • Second – UAV use, it is difficult to know what percentage of military operations now are UAV but we can assume it is significant.

The report states the military lost 1,500 pilots to the Airlines in 1997. If we take only 20% of this number and use it as a quick estimate to the number of military pilots who may be leaving the military our number is about 300 pilots per year. It should be noted that the report does state the number fluctuates based upon how good the jobs are in the airlines, and what opportunities are available. For the last ten years where most military pilots could choose between the military or a regional, I would venture many remained at the military. However, with mainline jobs opening up that could make leaving more tempting. Regardless, I think 300 a year is a conservative estimate.

Lets recap-

The Part 135/Part 91 SubPart K operations can provide roughly

1,234 pilots per year

This number may be low due to us ignoring pilots provided by other operations such as banner towing, pipeline patrol, bush flying, traffic watch, etc. This number may also be high if some of the fractional operators choose not to hire low time right seat pilots. However if they do this it will make it more difficult for them to compete with new operators that may hire younger less experienced pilots who will make substantially less.


The Military can provide

300 pilots per year


So the next question is how many Flight Instructors can the industry support?

Remember if there’s not enough students Flight Instructors can’t build the necessary time. This brings us to a question we need to answer first though, how many students does an average flight instructor need to reach the necessary time to go to the airlines?

To answer this and simplify the model lets make some more assumptions!

First, lets identify how much instruction an Instructor needs to give to obtain enough time to apply for an ATP.

Lets assume a Part 61 Instructor will have obtained about 300 hours of flight time before receiving all of their certificates necessary to Instruct students.

With the new/old ATP requirements of 1500 hours for this particular track, this Instructor will need to teach roughly 1200 hours of flight time.

Lets assume an approved Part 141 Instructor will have obtained about 250 hours of flight time before obtaining the necessary certificates to instruct. With the new (restricted) ATP requirement of 1000 hours, they will need to teach roughly 750 hours of flight time.

Now we will determine how many students this is equivalent too. To simplify things we will use a student that goes all the way through training as a unit of measurement.

We will assume a Part 61 student through the course of all their training will receive approx~ 100 hours of instruction.

We will assume a Part 141 student through the course of all their training will receive approx~160 hours of instruction. I use the following resource to justify the part 141 numbers.

We can now apply a quick calculation to determine the number of “full” students (students who run to completion) needed for the Part 61 and approved part 141 track instructors to obtain enough flight time to qualify for their respective ATP’s.

Part 61 = 1200 hours / 100 hours = 12 “Full” Students

Part 141 = 750 hours / 160 hours = 4.7 “Full” Students

Obviously if all these students want to go the Instruction route in order to achieve the necessary flight time that would produce a serious problem. There would need to be a 12 to 4 fold increase in the numbers of students each cycle to supply sufficient time building opportunities for Instructors. Most pyramid or ponzi schemes only last so long until they no longer work. If we assumed Instruction was the only time building opportunity it would quickly turn into a pyramid scheme.

The following charts should illustrate how this looks.

Part 61-Pyramid



Approved Part 141- Pyramid








If you were to compound this among the following generations of students we could begin to see what a problem there would be.

We can make a couple of more assumptions to see where all these students will go if they can’t all be flight instructors.

We know that each cycle will need to train replacement Instructors.

For part 61 I have guessed that number to be roughly 1.5. This number seems sufficient to replace an out-going instructor while still leaving some room for the instructors that may never move on into a full time professional position.

For part 141 I have guessed that number to be roughly 1.2. Lower than the Part 61 assumption, as part 141 track pilots may be more career minded towards reaching an ATP. So close to a pure replacement seemed appropriate, even though there may be some attrition and this number may actually need to be higher.

The following is a breakdown of potential teaching opportunities for Instructors as to what the industry could reasonably support. I’ve create them to add up to the required total of 12 “full” students for Part 61 and 4.7 “full” students for approved Part 141.

Table 4. (Student Source Breakdown for a Sustainable Flight Instructor Development)

Part 61 Instructor Breakdown Approved Part 141 Instructor Breakdown
Quite/GA 4.2 Quite/GA 0.94
Replacement 1.5 Replacment 1.2
Part 135/Part 91 Subpart K 4.3 Part 135/Part 91 Subpart K 1
International 2 Interational 1.55
Total 12 Total 4.69

(I’ve included a link towards the end to a spreadsheet where anyone can change these numbers and see what happens)

With this chart lets see how many instructors the system we have outline could support per year. (for those curious about the International and GA students we look at that in a minute) We know that the amount of Part 135 or Part 91 Subpart K right seat opportunities is limited to approx 1,234 pilots per year. There could be more but this is the number obtained at the beginning of the article.

With this “limitation” we can determine how many Instructors the industry could support each year. First, lets assume that half of the 135/91 track pilots will come from the Approved Part 141 schools and the other half from Part 61 schools.

If we divide 1,234 pilots by half we get about 617 from each source. If we divide this number by each breakdown (4.3 for Part 61 and 1 for Part 141) the Part 135/Part 91 industry could support approx –

Table 5. (Number of ATP applicants the industry could produce from the Flight Instructor pool)

School Instructors
Part 61 144
Approved Part 141 617

For those reading carefully i’m sure they are wondering if the other parts of the breakdown (GA/ or Quit), (International Students) are sustainable.

If the Part 135/Part 91 Subpart K could support the previous numbers of instructors with the breakdown from Table 4, these schools or the industry will need to train the following numbers of GA or washouts and International Students per year. They need to train this many students in order to provide enough teaching hours for Flight Instructors to reach the ATP requirements. We are assuming these Flight Instructors don’t use Part 135 /Part 91 as time building opportunities.

Table 6. Number of General Aviation Students and International students needed to sustain the previous numbers


School GA/Washout International
Part 61 603 223
Approved Part 141 579 1235
Total 1182 1457

It should be noted that not all students will complete all their training and then washout. In this calculation it is best to think of it as a measurement of training given. For example, its possible in one case 8 students might get halfway through their training and then move on to become recreational GA pilots or washout altogether, in these numbers that scenario would be represented as 4 “full” students.

I’ve included a link in this post to a spreadsheet where you can play with the breakdown and the sources to see how they affect the numbers regarding pilot supply. – Spreadsheet

PilotPipeline (1)

As we wrap this brief analysis up, we can look at the total supply. The following adds up our estimated number of Military pilots entering the Part 121 world, the number of pilots who will gain the required time in the right seat at Part 135 or Part 91 Subpart K per year, and the number of pilots who will be needed to train these pilots.

Table 7. ATP Source Total per year

Source Number of Pilots
Military 300
Part 61 Instructors 144
Part 141 Instructors 617
Part 135/Part 91 Subpart K 1235
Total 2296

With these initial numbers and with the pilot demand numbers this site includes this will be enough to support Pilot Demand through 2019. Beyond that the demand will go up and something will need to change to support the additional need for pilots.

Conclusions and Observations:

For these numbers to work there are many assumptions made, most of which I believe err on the conservative side. This is in the spirit of AudriesAircraftAnalysis where we use conservative assumptions, to build realistic models.

(note- if the Fractional Operators do not hire new pilots that would significantly change how many pilots the industry would be able to produce at the same cost)

A couple important points to note include-

  • Training International students for overseas demand could be an important resource for obtaining the required number of students necessary to train and equip our “up and coming” pilots with invaluable experience. It is rarely disputed that internationally there will be a crunch of experienced, qualified and well trained pilots. This is an opportunity for the US to ensure we have the best as we gain experience and seasoning by training others.
  • A vibrant General Aviation community is essential to providing students and experience for Instructors. In the previous breakdown it is assumed 1 “full” student for every instructor will move on to General Aviation flying as an outlet for learned skills. This is counter to the 4.2 General Aviation or students that washout or move onto GA at the 61 level. Part 61 inherently has less career minded students, as most students who fly for pleasure will pass through the Part 61 program. Hopefully, as the FAA opens up new regulations in Aircraft Certification and Liability, costs of aircraft ownership will return to a level a larger percentage of the population can enjoy. One of many side benefits will be increased teaching opportunities for professionally minded pilots.
  • Part 141 and possibly some Part 61 certification programs will need to be rewritten to encourage more cross-country flying. Contrary to some opinions it is possible to give significant instruction to students on small cross-country flights while giving them invaluable cross-country experience. Without the opportunity for the Instructors in the previous numbers to gain the necessary cross-country flight experience it may not matter how much total time they have.



Subscribe To Our Newsletter

Join our mailing list to receive the latest news and updates from our team.

You have Successfully Subscribed!