The R-ATP Comes with Rules

The college or university curriculum has to be approved by the FAA and the school approved for the restricted ATP (R-ATP), which will lead to fewer hours needing to be acquired.

Per FAR 61.160, pilot applicants who hold a bachelor's degree in an aviation major from a four-year institution that is approved for the R-ATP and a commercial pilot certificate can qualify for the certificate at 1,000 hours total time, and those holding a commercial pilot certificate and an associate's degree from an approved two-year institution can qualify with 1,250 hours total time.

Per the FARs, the required flight training must be completed as part of an approved Part 141 curriculum at the institution of higher education or at a Part 141 school that has a written training agreement with the institution of higher education.

If the school lacks FAA approval, the R-ATP minimums do not apply.

Some graduates find this out the hard way, after they've spent $100,000 on an aviation degree from a two- or four-year program and thousands more to acquire a multiengine commercial pilot certificate through a Part 141 program. Some find out when they've been hired at an airline and are going through training—they don't understand they're coming up short until they apply for the ATP certificate and learn their school is not authorized for R-ATP.

When the FAA authorizes a Part 141 program or an institution for the R-ATP there will be an accompanying letter of authorization (LOA). The LOAs are usually framed and displayed prominently at the school. LOAs indicate when a school is Part 141, and when an advanced aviation training device (AATD) can be used to meet experience requirements. Read the letter carefully.

Recently students at the University of Memphis in Tennessee filed a lawsuit against the school for allegedly leading them to believe that graduating with a four-year degree would enable them to qualify for the R-ATP with 1,000 hours total time. Flight students from U of M complete their training at Crew Training International (CTI) at Millington-Memphis Airport (KNQA), a well-established Part 141 program. On their website, CTI notes the R-ATP minimums apply for graduates of approved universities, but does not mention the University of Memphis.

Kyle Mullen, the president and CEO of CTI, told FLYING that it was his understanding that the university has applied for the letter of authorization, and CTI has been working with the FAA for several years on the project, but the combination of staffing changes at the FAA and the pandemic have slowed the process. Additionally, CTI's operation at KNQA is considering a satellite operation as their main location is in Fort Lauderdale, Florida, and as such they are required to go through the Miami Flight Standards District Office. According to Mullen, they often wait weeks for correspondence to be answered by the FSDO.

Mullen is skeptical of the allegation that the university misled the students, saying most students were aware of the situation, and suggests a lack of the general public’s understanding about the FAA's role in certification of programs that are eligible for the R-ATP may be partially to blame.

On August 16, 2018, the University of Memphis published a media release announcing its new commercial aviation program.

The last paragraph states "By earning a bachelor's degree in aviation, pilots reduce the required number of flight hours needed to become commercial pilots by 500 hours. Personnel in University College, including a dedicated academic adviser, will work with students pursuing the degree. In addition, the University College will work closely with CTI personnel to handle administration of student attendance, billing and course selection."

In addition, FLYING found two news stories about the new program dated in August 2018. 

The Memphis Daily News on August 13 ran the story under the headline “University of Memphis Commercial Aviation degree Takes Flight this Fall.” The story contains the line: "A bachelor’s degree in aviation also reduces the FAA-required flight hours to become a commercial pilot from 1,500 to 1,000 hours, Mullen said, making it more convenient and realistic for people to fly for an airline."

A story appearing General Aviation News in August 2018 attributed to General Aviation News Staff contains the same information as the story appearing in the Memphis Daily News and ends with the phrase: "By earning a bachelor’s degree in aviation, pilots reduce the required number of flight hours needed to become commercial pilots by 500 hours, university officials said."

FLYING reached out to the University of Memphis, hearing back from Captain Warren F. Travis, instructor/coordinator/advisor from the Commercial Aviation program, who stated he could not respond to our questions due to pending litigation.

One of the complaints made by a student at the U of M is that he could have enrolled in a flight experience building program instead of wasting four years at college, with the understanding that having a bachelor’s degree would reduce the amount of time needed to be hireable at the airlines.

A degree used to be a requirement in order to work for the airlines as a pilot. Most pilots who attend college aviation programs earn aviation degrees. The lucky ones end up as flight instructors or in other time building jobs. The not-so-lucky ones often have had difficulty finding or holding those time-building aviation jobs, or who realize that the airline life wasn't for them find themselves unqualified for anything other than flying. This has led to the suggestion that pilots back up their aviation skills by getting a more pragmatic degree such as business or engineering, so they would have something to fall back on.

As the pilot shortage has caused most airlines to drop the degree requirement, there are more pilots who are pursuing accelerated aviation programs to get the required flight experience—and in their spare time, using distance e-learning to acquire backup skills in the event the aviation career doesn't work out. (You'd be amazed at how many pilots also hold real estate licenses or are state-certified electricians).

If you want a career in aviation, pursue it with passion and enthusiasm—but also have a fallback in case it doesn't turn out how you expect it to. Think of this plan as your 'alternate' if the flight cannot be completed as filed.