SkyWest Tries to Skirt Pilot Shortage with New Subsidiary


On June 14, SkyWest’s newly-formed subidiary SW Charter Holdings, Inc bought a nearly defunct operator called USAC 691 Airways LLC. This move, as unlikely as it may seem, was planned in order to set off a chain reaction. It will allow SkyWest to do an end run around current pilot rules. That in turn will help the airline to create a pilot pipeline and restore service to a variety of cities which it had decided to abandon earlier this year.

SkyWest, like all regional airlines, has struggled to attract enough regional pilots to backfill the enormous number who are leaving to fly for the majors as those airlines see mass early retirements. The situation had started off by forcing regionals to curtail service and park airplanes. Earlier this year, it became dire enough that SkyWest announced it would end service to 29 cities that it flew under the Essential Air Service (EAS) program, because it just couldn’t staff the 50-seaters it used to fly those routes while still maintaining the more important contracts flying for Alaska, American, Delta, and United.

The list of routes was broad, and they were largely focused on Denver and Chicago as you can see here.

Proposed Routes Abandoned by SkyWest

Map via Cirium

With the situation becoming increasingly desperate, SkyWest crafted a plan and made its move for USAC 691 Airways. This was effectively just buying a certificate that would allow SkyWest to create a subsidiary that wouldn’t have to fly under Part 121 rules.

The problem for SkyWest and the other regionals was the ill-advised increase in pilot hours required to 1,500 (with few exceptions) before being allowed to fly in the right seat of a commercial aircraft. That created a lengthy and expensive process for anyone who wanted to become a pilot, and it lengthened the time before someone could be put to work for an airline. Airlines have tried a variety of ways to adapt to the new reality, and one of those involves trying to go around the rules. That’s the tack SkyWest is taking with this new subsidiary.

This “1,500 hour rule” applies to airlines flying under federal Part 121 rules. That applies to any regularly-scheduled airline with aircraft having 10 or more seats. Other than only flying 9-seaters, there is one way around this rule. Airlines have increasingly discovered the ability to fly under less strict Part 135 rules using Part 380. This allows airlines to operate public charters with no more than 30 seats under Part 135 rules. In other words, they can put pilots in the right seat with fewer hours and still put 30 seats on an airplane.

It’s no coincidence that JSX, for example, puts only 30 seats on its ERJ aircraft that could hold more. SkyWest will now do the same, taking 18 of its 50-seat CRJs and converting them down to a more spacious 30 seats. With that, it will ramp up to serving these routes…

Proposed Routes for SkyWest Charters

Map via Cirium

Gee, these two maps look similar, don’t they? Many of these are EAS routes, and as SkyWest spokesperson Marissa Snow told me, “…while not all the routes are EAS, for those that are we’ll continue to work with the DOT and each market on what any implementation would look like.”

SkyWest will also try to work with local communities to get funding to support these routes, especially those that aren’t EAS. The airline’s applicaton to DOT was full of letters of support from communities desperately hoping to hang on to their jet flights.

Let’s just put aside the absurdity of the regulation here for a moment. I mean, it makes perfect sense to me that an airplane with 30 seats is totally safe when flown by less experienced pilots, but as soon as that same airplane has 31 seats, HELL NO. Let’s ask the bigger question… is this unsafe?

I don’t feel that way. First of all, yes, you can have less experience pilots in the right seat. But they can’t be completely inexperienced. Further, that captain is still required to have 1,500 hours of flying time by rule. So it’s not like there are two kids with no experience flying these airplanes.

It’s right to question whether number of hours is a good metric. We’ve seen plenty of examples saying no, it is not. Just look at what caused this regulation in the first place, the crash of Colgan Air 3407 in 2009. This was attributed to fatigue and poor piloting. But guess what? Both pilots on that airplane had more than 1,500 hours. (The captain had 3,379 and the first officer 2,244.) There’s also Atlas Air 3591 which crashed in Houston back in 2019. The first officer there was largely faulted for his poor piloting, but he had over 5,000 hours.

So, if you don’t believe that the number of hours defines a “good” pilot, then this shouldn’t bother you. This is just an example of a company using the government’s rules against it. But of course, if you think that more hours makes a good pilot, then you might not enjoy this plan.

One thing is clear, though SkyWest used to fly these routes under the United Express banner, as I understand it, that will no longer be possible since the new airline is not a Part 121 operator. That doesn’t mean United can’t still sell connecting flights, but it would be as an interline partner which gives a little more transparency. (United does this today with Denver Air Connection flights, but we don’t know for sure that this arrangement would exist with SkyWest.)

So, credit to SkyWest for taking a swing at this.

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35 comments on “SkyWest Tries to Skirt Pilot Shortage with New Subsidiary

  1. I would much rather have a pilot trained this way anyway. Right now, to get their 1500 hours, a lot of pilots serve as flight instructors. But those hours are the same flights and skills over and over – teaching someone like me (I’m a student pilot) to fly is not the same as flying passengers in different weather and traffic conditions.

    A guy getting his hours by being a CFI flies Cessnas or whatever in good weather to smaller airports. If there are weather challenges or maintenance delays or traffic issues, they don’t go.

    My former CFI is now with Skywest, and I ran into him on a flight a few months ago. He said being an FO is completely different from what he was doing and he felt unprepared (but was growing into it).

    I would much rather get them real world experience piloting passengers.

    1. Next time you run into your CFI (or any airline pilot) ask them when they felt like they had the best actual stick and rudder skills.

      I would put money on it that 90-95% of pilots would say it was when they were instructors.

      Then ask them what the toughest flying they’ve ever done is. Again it’ll either be instructing or flying 135 single pilot.

      1. And the lack of stick and rudder skills is what has resulted in countless accidents over the years in countries that lack a true GA environment. Even AF447 was a classic example of basic airmanship failures.

        1. But AF447 actually makes my point. Being a CFI in a Cessna 172 over and over would not prepare you for flying a large complicated jet through weather with multiple alarms going off.

      2. Stick and rudder practice is great…but as a CFI they never fly in bad weather…on a schedule…with a ticking clock toward them going illegal.

        They don’t have to plan for backup airports and possible reroutes and flying into places they don’t know.

        1. Flight instructing would certainly help teach them that you could stall at any airspeed and altitude.

          I’d still easily argue that 1000 hours spent teaching people basic airmanship and maneuvers in a 172 would make a far better pilot than an extra 1000 hours of flying straight and level from ORD to LGA in a jet after receiving the bare minimum of training prescribed by the FAA.

          1. Except training flights are done under perfect conditions. Doing touch and gos at the same three airports in VFR and light winds doesn’t prepare anyone for PROBLEMS.

            Most pilots are good pilots when the wind is 7 knots straight down the runway, you aren’t being asked to do S turns to give more clearance to the guy in front of you, and the sky is clear. It’s a lot different when you are at the end of a 9 hours day, it’s raining, there is a 20 knot crosswind, and you are racing heavier weather and trying to decide if you have enough fuel to make the alternative airport if you have to go around.

            Those are things that guys can only learn flying passengers on a schedule.

        2. As a current airline pilot and former flight instructor. I can say with full certainty that your viewpoint is a bit misguided. Get some more experience before becoming the resident expert.

          1. I’ll defer to your experience, but I have some of my own too.

            I will stand by my assertion that teaching students the same 8 maneuvers in the same place in perfect weather over and over is not great preparation for PROBLEMS.

            It’s one thing to get stick and rudder practice. Always a good thing. But that wouldn’t have helped in the Colgate Air or Atlas crashes. In both cases, the pilot essentially panicked when presented with an unexpected issue.

            I’m no CFI or airline pilot, but I recognize that many if not most recent crashes have occurred because the pilot panicked and did not respond correctly when presented with adverse issues, and all of these folks had well over 1500 hours too.

  2. So you might need to reword part of your post. 135.243(a)1 still requires turbojet powered captains to have an ATP, and an ATP requires 1500 hours (it is literally the first section you linked). Skywest won’t get any relief with as far as that goes (neither does Cape Air for that matter since they fall under the commuter section of that clause).

    Where Skywest does get a little relief is that the FO requirements are a lot less (ME commercial rating at the very least…or realistically whatever their insurance says their minimums are). The other requirement that this helps with is you can upgrade captains right at ATP minimums, whereas 121 PIC requires a certain amount of time (121.436(a)3) on top of your ATP certificate before you can be captain.

    Skywest now gets to put pilots in the door with well under 1500 hours, upgrade them right at 1500 hours on their 135 side, and the use that 135 PIC time to meet the requirements for their 121 time. Instead of parking them as 121 FOs for the first 18-24 months, now they can at least have them act as captains. Additionally, 135 SIC’s don’t require a full type rating so they save slightly on training costs too.

    Lastly, since 2013 the minimum realistic hours for a 121 captain is 2500. They need the 1500 for the ATP and then another 1000 as 121 SIC, 135 PIC, or 91k PIC (fractional).

    As a parting question. Where would you draw the line? It’s clear you’d do away with the 1500 hour rule if you were king. But I assume you also wouldn’t feel comfortable flying a 767 across the Pacific with a 700 hour captain and 250 hour FO. Or a 200 hour captain and 200 hour FO.

    1. Mike – Thank you for clarifying that. I updated the post to say 1,500 hours instead of 1,200 hours. Either way, the broader point is the same.

      As for what I’d do, well, that’s hard to say where to draw the line. I don’t have huge concerns about the old rule, primarily because you still had an experienced captain flying with the more junior person. I think there is also the ability to include a lot more nuance in the rules. I mean, if you have time flying a CRJ-equivalent corporate jet to build your hours, those hours should probably count as being worth more than if someone is still flying a single engine prop to build hours.

      There should also be more accelerated options for training programs that are specifically designed to create an airline pilot. Some of these carveouts exist but not enough, especially with some of these cadet programs hastily being built.

      I’d also like to see better data sharing between airlines, so when someone like the FO on the Atlas crash flames out at one airline, that information will be fully accessible by all airlines.

      To me, the 1,500 hour rule was an arbitrary hammer that didn’t measurably improve safety. I always found it so strange that the crash to which they were responding did not have a pilot with under 1,500 hours onboard.

      1. Your comment here gets to the heart of the matter, Cranky, and is something that I was trying to find a good way to express… Hours are easy to measure, but not all hours flying (or driving, to use a more common example) are worth the same in terms of experience. For example, experience driving/flying/landing on bumpy air/roads with snow or sleet falling is probably worth much more in terms of building skills than experience driving/flying on a day with little wind and no clouds or precipitation.

        I think a key part of experience should include experience in a variety of conditions, not just weather conditions but times of the day, body conditions (one isn’t always 100% alert), and different types of stress, along with different levels of complexity in terms of operating, planning, and thinking that are required.

        The real challenge, however, is how to build requirements that attempt to measure those skills and experience that have been gained, without making it too easy to cheat the system and just punch the boxes for the sake of punching the boxes, or without making the requirements far too arcane and elaborately detailed, and I have no ideas for solutions for that.

        1. The only real way to get that experience is as a FO with an experienced captain beside you.

          Students aren’t out learning in less than optimal conditions. I would allow an FO to start working with only 500 hours as long as the captain has ample time.

    1. Ian – Whether or not they were hired with less than 1,500 hours is irrelevant. They had WELL over 1,500 hours at the time of the accident.

  3. I commend Skywest for trying to be creative in ways to maintain air service and to get pilots into the pipeline.

    From a pilot experience/time standpoint, I am pretty sure that pilots can fly for an airline with a restricted ATP at 1000 hours. There are hundreds of pilots flying for regional airlines that have R-ATPs because they graduated from an FAA approved university flight training program. Those are undoubtedly first officers and start building pilot in command time from there.

    The SKYW proposal would lower the requirement to 500 hours which will probably benefit people that do not have university degrees or do have them but not enough hours. Captains will remain more experienced – but there are already many low time captains flying for regional airlines right now.

    The reason why few will object is because this is existing law; SKYW isn’t doing what others also aren’t doing. Add in that SKYW is doing this as dozens of cities will lose service absent this proposal and it seems the best of many less than optimal solutions. Every one wants a pair of 30 year experienced pilots but that is not reality.

    There are other ways to gain experience and to ensure safety and part of the reason for the Colgan accident was fatigue which resulted in new rules against fatigue; raising pilot experience requirements did nothing to change fatigue.

    It is also worth noting that most of the overlap and the potential beneficiary even on an online basis is United – because they pursued EAS service more aggressively than AA AS or DL.

    30 passenger regional jets will have very high unit costs so a lot of cities will either have to perpetually put up a lot of cash to maintain air service or face the reality that economics have already started to push air service back to the place where it is economically sustainable. It is not a mistake that Southwest and every other low cost carrier does not operate hub and spoke services to small cities that can’t support mainline service. The ULCCs have stepped in to small cities but only with less than daily service to a handful of the top leisure destinations which weakens the ability of network carriers to support service to small cities.

    SKYW proposes a fairly short timeline to get this going so we should know soon if it works.

  4. Does anyone have a good summary of the restrictions that apply to flying a “public charter” under Part 380 vs. “scheduled air service” under part 121? Does it have implications for how you can sell the ticket, what facilities you can use at the airport, interline and codeshare agreements, etc.? Other than the seat count restriction, I’m curious what a regional gives up by operating under Part 380 instead of Part 121.

  5. Once the existing stock of 50-seat jets reaches the end of their useful lives, are there any aircraft in production that could economically handle 30-seat charter flights? I think the ATR 42 is the only production option that kinda fits, and it’s still significantly oversized.

    This might be a viable niche for the various electric aircraft startups to tackle – a regulatory “sweet spot” with no existing competition from the major aircraft manufacturers.

    1. SKYW is at best kicking the can down the road; a lack of pilots (or high costs at regional airlines) and high fuel costs will be a be an issue for a long time. And, yes, the regional carrier fleet will time out at some point. Embraer can keep selling E1 jets but I’m not sure that the economics of those will last very long.
      Perhaps pilotless electric aircraft can serve small cities but that is a lot of development cost to pass on to consumers who are largely just interested in connecting to the national airspace system where much more efficient turbine aircraft flown by 2 pilots will be the backbone of the US’ system for years to come.
      Southwest probably got it right when they decided years ago that it took 100 or more passengers to make a flight viable; JetBlue is clinging to that number with its aging Ejets with Delta just above that with its A220-100s but the US industry as a whole is largely moving to either 140+ seat mainline jets or 76 seat regional jets – with a few exceptions.
      Cities will have to live with that reality or subsidize air service while there will be workarounds such as what SKYW is doing to regional jets but when regional carriers have to pay over $100k for regional jet pilots at current minimum experience levels vs. an average of “just” $200k in salary for all pilots at “the big boys” it will be hard to justify a lot of non-mainline service.

      1. Yeah, realistically the actual replacements for 50-seat jets will be:

        1. 100+-seat jets, flown only a couple times per week, instead of multiple times per day, or

        2. Buses to the nearest airport big enough to justify the above

    2. Heart claims their ES-19 electric turboprop will be certified by 2026. At 19 seats, it might be a better fit for EAS markets than something in the 30-50 seat range. United and Mesa each have agreements (not orders) for 100 aircraft each. I suspect there could be an opportunity to grow that aircraft into the 30 seat range.

      1. Yeah, that could be a great fit for exploiting this “loophole”. The reason it has 19 seats is so that it can be certified under Part 23. 30 seats would be more economical for this use-case, but would require getting the aircraft certified under Part 25.

        19-seat “commuter” aircraft certified under Part 23 flown by low-time FOs and (comparatively) low-time PICs is probably the niche that various electric aircraft designers are trying to fill with their initial designs.

        The pilot shortage and terrible economics of 50-seat jets mean it might just be crazy enough to work, at least for some markets.

        1. Actually it looks like just this month Heart announced that they will switch to pursuing a Part 25 certification rather than Part 23, due to the risk that their final design would exceed the Part 23 weight limit:

          If they are going for Part 25 anyway, then there is no particular reason to target 19 seats, and it might be ideal to “stretch” to 30 seats to reach the maximum permitted capacity under Part 380.

  6. I always felt like the 1500 hour rule was a reaction to the media right after Colgan 3407 making it sound like pilot inexperience contributed to the crash. But there is a huge difference between getting your commercial pilot’s certificate at 250 hours and flying for an airline. Before, it was dictated by the available pilots, the market, and insurance. Most of my friends hired in the early to mid 2000’s were hired at 550-800 hours. As far as I know, no other country in the world has these requirements and planes are not constantly falling out of the skies. In my opinion the only good the 1500 hour did was give regional pilots a decent standard of living. That’s also why a lot of airline pilots want to see the rule stay. I do think this is a great move by Skywest. If the 1500 hour rule is going to stay, there needs to be more options for aspiring airline pilots to move up (pun intended).

  7. I’m an anesthesiologist in a university hospital, and I try to think about the minimum hour requirements by analogy to the training required in my specialty.

    On one hand, it doesn’t require anything near 1500 hours of experience to be left alone in an OR with a patient. Anesthesia residents can be left in an OR without a faculty member after the first couple of months of training. Of course, fully trained faculty are always very close at hand. But to be the last word in caring for a patient–that is, to finish residency and fully trained and board-certified–requires something like 5000 hours of clinical experience. (We don’t total the hours as such, but that’s probably a pretty typical number.)

    I think my feelings about flight crew are similar: I’m not too worried if the FO has little experience, as long as the captain’s experience is ample. I would feel much more comfortable with a 5000-hour captain and a 500-hour FO than with both of the flight crew near the 1500-hour minimum. I think a plan to shave the minimum hours for an FO makes me nervous without accompanying guarantees that the pilot will be more experienced.

    1. Good comment. Buttigeg was on NBC stating that he sees no reason to bump up the 65 year mandatory retirement age. Somewhat of the same scenario for me. Do I want two 70 year old guys piloting a plane? Maybe not. But a 70 year old person, that gets a yearly physical and is in good health + a 55 year old? Sure. Why not.

      I don’t see doctors getting flushed out the same way and in many ways there is a similar analogy.

      1. There was an book written by a surgeon a while back, called The Checklist Manifesto. The author argues for greater use of checklists in medicine.

        I know of ER doctors who (before doing a diagnosis or procedure they have done hundreds of times) will whip out their phones, open an (accredited) emergency medicine app, and check the app’s section on that condition (using it as a sort of checklist, to remind them of best practices and watchouts), to ensure that they aren’t inadvertently missing or forgetting something… Patients don’t always like it, but sometimes start to understand when told, “You weren’t going to get any worse in the 30 seconds it took me to check the best practices for your condition on my phone, but you might get MUCH worse if I forgot to do something I should have, and that’s what I’m trying to prevent.”

        I’m not in the medical or aviation fields, but I find it fascinating how techniques and concepts like CRM and checklists have started to move from one field to a seemingly unrelated one, united only by the need to make better decisions under stress.

  8. Cranky the Atlas pilot shouldn’t be cited as a valid example. He used his protected status to make claims of discrimination, which inhibited the usual process of termination. He also dishonestly manipulated aviation reporting systems.

    So yes he had thousands of hours and yes he could not fly, but he would have been eliminated as an experienced inept outlier had it not been for his abuse of insubstantial HR claim procedures and US law. Put differently, pilots who can’t fly are normally eliminated unless woke HR processes are invoked.

    It is far less normal for experienced pilots to be inept than for low time pilots to be experienced.

  9. There are plenty of pilots with 1500+ hours to fill these positions. Applauding skywest for trying to circumvent the rules, keep wages low, and fill the pockets of management is naive. There is no shortage of pilots, there’s a shortage of pilots willing to work for terrible wages. Skywest and the likes of them had their time, now it’s time to start to pay up. You get what you pay for, if you want highly qualified professionals, you need to pay them.

  10. I’m not an aviation expert or anything, but have been working around aviation for years. Personally, I think the best solution would be to create a new category for pilots under 1500 hours. Simply keep the 1500 hour rule for FOs but create a new category called Pilot Apprentice. You earn that at 250 hours.

    An apprentice is a pilot who CAN fly commercially but with strict rules. I think a pilot who is training in simulator hours can be valuable to safely train more serious situations like bad weather. But on days of good weather and paired with a captain with say 3000 plus hours, sure why not allow them to fly in the cockpit. Also allow said apprentice to fly those dead head flights like maintenance or fleet transitioning flights. As said pilot accrues certification and training hours, increase more flying time and less simulator time BUT always having a well trained captain paired with them. I think the bigger issue will be the 1500 hour rule, I just think it should apply as the basis for being a FO, but why not have a pilot apprenticeship for people to slowly transition into the FO seat.

    As for those small cities, I’m sorry to say but maybe the rules need to be redefined. Instead of EAS flights going to a major or medium hub, how about an airport with adequate service. Example crescent city CA. It’s isolated but a short 30 minute flight would be nearby Medford Oregon. Why can’t commuter level flights be flown there instead of Oakland?

  11. You’re missing the point about the 1,500 hour requirement and the Colgan air crash.

    After the crash, there was a large and comprehansive examination of pilot qualification for regional airlines, partly because of their significant growth and that more and more secondary markets were served exclusively by regionals. Those cities were feeling like they were treated as second class cities and were already taking exception to that as more and mire turboprops replaced jets.

    The study took over a year and included a broad spectrum of interests across the aviation communjty. To call the 1,500 hour rule “ill advised” suggests that it was done on a whim. Nothing could be further from the truth.

    While the co-pilot who was flying the plane when the accident happened did indeed have more than 1,500 hours, the study looked at broader issues. One of them was that sometimes a crisis pops up in a moment and there isn’t enough time for the more experianced captain to take over, so at any moment, both pilots must have the same minimum qualifications because the flight crew is only as skilled as its least skilled pilot.

  12. No one has brought up the economic factors, especially since the taxpayer will foot the bill for the EAS routes. It seems to me more logical to bring back the Brisilias (a true 30 seat airplane) and put them back in service.

    It’s been said by Mike Boyd, and other industry “experts” that there was not place for 50 seat jets in the industry…that’s was over 15 years ago. If 50 seats jets are marginally profitable at 50 seats, I can’t imagine what the economics of a 50 seat jet with only 30 seats.

  13. It will be interesting to see what happens with their application. For a lower-time Commercial Pilot, this would be a pretty attractive option to build the required time for an ATP compared with other options (being a CFI, hauling skydivers, towing banners, or aerial surveying). It hasn’t been stated in the coverage of this, but I would assume that there’s also a period of time a pilot would need to stay with them once they become qualified to upgrade to captain. Other 135 operators like Cape Air or Denver Air Connection have financial penalties for leaving early to go to a major after they’ve basically paid for the training to get them to captain.

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