Market Intelligence: -General Aviation

The House Transportation and Infrastructure Committee released the text of their bill to reauthorize the Federal Aviation Administration (FAA).

The Air Line Pilots Association (ALPA) issued the following statement citing serious concerns about safety impacts of House FAA Reauthorization Proposal:

“ALPA continues to review the House Transportation and Infrastructure Committee’s bill, however we have serious concerns about its commitment to maintaining the highest levels of aviation safety and protecting the rights of pilots.”

On June 12, 2023, ALPA sent the below letter to the House of Representatives:

“As you move to mark up the FAA reauthorization legislation, we write to reiterate labor’s interest in moving a bipartisan bill that is safety-focused. Finalizing a reauthorization bill before the current authorization expires is critical to continued aviation operations, and ensuring that the legislation affirms the U.S. as the gold standard of aviation safety should be a shared goal. We appreciate the Committee’s commitment to moving the bill expeditiously.

Any provisions dealing with raising the pilot retirement age, flight deck video recordings or proposals to reduce flight crew operations in FAR 121 airliners or weaken pilot training regulations must be rejected. These proposals undermine the safety of the national air space and run counter to the shared bipartisan commitment of collaboration to pass a final FAA reauthorization measure into law before the deadline.

Raising the retirement age for airline pilots will not appreciably increase the number of pilots and will exacerbate operational and scheduling complexity because pilots over age 65 will be limited to flying domestic routes resulting in even more challenges and stresses on the system. The International Civil Aviation Organization (ICAO) limits pilots to age 65 for any international flying. Therefore, senior pilots on international routes would have to return to domestic-only flying. This would require retraining on different equipment and would bump less-senior pilots to different aircraft or flight deck positions. This will have unintended consequences on airline operations that will complicate the return to travel post-COVID resulting in more delays and cancellations. It would also introduce unnecessary risk to the system.

Similarly, introducing video recorders on the flight deck is a solution in search of a problem. There are countless needs in our aviation system that are deserving of resources which could be much better utilized than adding extraneous, unproven recording devices to the flight deck. Ensuring all airports have Airport Surface Detection Equipment, for example, so the near-miss that took place at Austin, TX., will not happen again.

At least two well-trained, qualified professional airline pilots on the flight deck of every airliner are critical to safe operations. Congress acted decisively to require robust improvements in airline pilot training in 2010 after decades of tragic airline accidents. Since then, fatalities rates have gone down by 99.8 percent. Reductions or changes to first officer qualifications and training should have no place in a safety-focused FAA reauthorization bill. Neither, too, should proposals that seek to remove pilots from the cockpit or introduce single-pilot airliner operations.

As representatives of America’s aviation workforce, the safety of our system is core to everything we do. We urge you to reject any proposal that introduces risk into our U.S. air transportation system.”

Moreover, on June 14, 2023, ALPA sent the House Transportation & Infrastructure Committee the below letter opposing its Securing Growth and Robust Leadership in American Aviation Act:

“On behalf of the 74,000 pilots represented by the Air Line Pilots Association, International (ALPA) at 42 air carriers, we regretfully write to oppose the Securing Growth and Robust Leadership in American Aviation Act.

ALPA prides itself in working in a bipartisan matter to advance aviation safety and the rights of workers. However, the decision to move forward with changing the statutory pilot retirement age is an anti-union poison pill. The rash decision to move an amendment on changing the statutory pilot retirement age, without consulting agencies responsible for safety, or studying potential impacts of such a change as has been done elsewhere is a politically driven choice that betrays a fundamental understanding of airline industry operations, the pilot profession, and safety.

The International Civil Aviation Organization – a specialized agency of the United Nations – mandates that pilots in multi-crew operations must retire at age 65. The Committee’s decision to change the retirement age puts the U.S. in non-compliance with the international standard and will have substantial negative effects on air travel, air carrier operations, and pilots. Pilots who are age 65 and older will be unable to fly outside the U.S. borders. These pilots, frequently captains of widebody aircraft that fly internationally, will be forced to retrain on other aircraft and displace junior pilots from their aircraft. Given the pilot profession is seniority based, this will create a cascading training backlog that is expensive as pilots must retrain and requalify on aircraft or into a different seat position. This costly endeavor will reduce the amount of flying airlines can do, restrict flights, and pilot availability. Further, many U.S. airlines use narrowbody aircraft to fly international routes and do not segregate the aircraft based on operation type. As such, pilots age 65-67 would have to be further restricted by management flight operations as to where they can fly.

Pilots bid on routes based on seniority and are entitled to a bid based on seniority alone. An age 67 change would require unions and management to reopen collectively bargained agreements and seek new contractual arrangements that restrict pilots from bidding on routes and deal with attendant compensation issues to protect against age discrimination lawsuits since pilots are entitled, by contract, to flying opportunities based on seniority. The bill would expose both carriers and unions to litigation, as the current immunity language in law since 2007 will not cover the retroactive return of retired pilots contemplated by the provision. Pilot labor unions and management have been through a lengthy and difficult process to secure agreements, and this proposal would upend the results of collective bargaining.

It has been argued that changing the retirement age will increase the supply of pilots. Rather, it will likely increase the cost of pilots for air carriers, as pilot utilization for older pilots is relatively low. Proponents of this change suggest that ICAO would be forced to raise its retirement age based on a statutory change in U.S. law. This is false. The European safety regulator – EASA – has already expressed opposition to changing its retirement age based on detailed safety analysis.

Most importantly, the current international limit is based on safety. According to numerous studies, including a 2017 study by EASA, there is an increased risk of cardiovascular issues, diabetes, and cognitive decline with increasing age. It is imprudent for Congress to impose its own view on safety based on ideology rather than proven analysis and data and place the U.S. in non-compliance with international standards.

While the underlying bill includes some important provisions on workforce development, safety, and improvements for workers, the decision to impose an ill-conceived poison pill in the bill without consideration of safety, the airline industry, and the pilot profession, renders such advancements moot. We ask that the Committee reconsider its path, remove this provision, and focus on safety, improving airline travel, and upholding the rights of U.S. airline workers.”

Source: ALPA