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November 14, 2006
The Honorable Marion Blakey
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Dear Administrator Blakey:
This letter is in response to the Federal Aviation Administration (FAA) request for comments on changing the Age 60 rule for U.S. pilots. AARP urges elimination of the outdated and discriminatory age limit which requires that commercial airline pilots cease flying at age 60. At the very least, the FAA should conform to the new standard adopted by the International Civil Aviation Organization (ICAO) that will allow pilots to fly until they are 65 if there is another pilot younger than age 60 in a two-pilot operation.
AARP is a nonprofit, nonpartisan membership organization that helps people aged 50+ maintain independence, choice, and control in ways that are beneficial and affordable to them and to society as a whole. With more than 37 million members, AARP is the largest organization representing the interests of Americans age 50 and older and their families. Nearly half of AARP members are working either full-time or part-time, and they have a vital interest in remaining on the job or finding work without facing age discrimination by their employers.
Older pilots should be judged on ability, not age.
AARP has long opposed the FAA’s Age 60 rule as well as any law or regulation imposing an upper limit on how long an individual can continue in a job. Older workers should be judged on the basis of their individual competence and ability, not on inaccurate and stigmatizing stereotypes. AARP has testified before Congress and the FAA in opposition to the Age 60 rule; filed amicus curiae briefs in the federal courts; filed comments in FAA rulemakings; and supported the efforts of individual pilots seeking exemptions from that rule. AARP has formally supported pending legislation to raise the age limit to 65 because it represents an important step toward recognizing that pilots should be judged on their skills, not on assumptions about age.
The Age 60 rule is discriminatory because age, rather than knowledge, skills, or experience, determines who can fly as a commercial airline pilot. Airline industry observation indicates that older, experienced pilots are often more capable and less subject to human error than are their younger counterparts. Airlines already test individual pilots regularly for their fitness to fly through medical certification and flight simulator exercises. Eliminating the age limit would not require additional medical exams, line or simulator checks, or operational restrictions. The FAA’s rigorous medical and operational performance standards screen out pilots of all ages who are unhealthy or poor performers, ensuring that commercial pilots of all ages are among the healthiest and most capable pilots employed.
Requiring commercial airline pilots to stop flying at age 60 affects not only individual pilots, but the U.S. workforce as a whole.
Airline pilots who reach age 60 are likely to leave their employers when they can no longer fly. They may retire or they may search for another job. If they look for work, former airline pilots will likely face obstacles to finding a new job; it takes older displaced workers longer to find work than it does for younger workers. The average duration of unemployment in 2005 was 25.9 weeks for jobseekers aged 60 or older and 17.5 weeks for jobseekers ages 16-59. Older workers who lose their jobs are more likely to drop out of the labor force. Twenty-six percent of workers ages 55-64 who were displaced between 2003 and 2005 left the workforce. This compares to 12 percent of workers ages 25-54. Older displaced workers who get jobs are more likely to experience earnings losses than younger job finders. Among workers ages 60-64 who had been displaced between 2001 and 2003 and rehired as of January 2004, the average drop in weekly earnings was 31 percent.
If they decide to retire, former pilots may face a significant drop in their retirement income. As the FAA is aware, a number of airline defined benefit pensions have defaulted in recent years, resulting in their takeover by the Pension Benefit Guaranty Corporation (PBGC). As a result, pilots have been hit with pension cuts twice: first, because the maximum annual benefit the PBGC pays is $47,659, much less than most pilots have earned; and, second, because benefits are further reduced for those who retire earlier than age 65. The reduction in what a pilot was expecting to collect in pension benefits before the PBGC takeover can be greater than 50 percent. In addition, those under age 62 are not yet eligible for Social Security benefits and consequently do not have a secure source of retirement income immediately available if they leave the work force. Furthermore, retired pilots who start collecting Social Security at age 62 will collect smaller monthly benefits than they would if they waited until full retirement age to collect—age 66 for persons turning 60 this year.
At the same time older workers experience roadblocks to finding work, policymakers predict there will be shortages of workers in the general economy as the boomers retire. This projected shortage includes airline pilots. The demand for pilots is expected to increase as the economy grows because there is likely to be more need for air travel.[1] Add to that expected growth in retirements among airline pilots and navigators – a projected increase of 173 percent during the period 2003 through 2008 - and there is likely to be a scarcity of qualified pilots within the next five to ten years.[2] Eliminating the age 60 rule would help mitigate the expected smaller pool of experienced pilots and help maintain healthy growth in the economy.
At the very minimum, the FAA should adopt the age 65 standard approved by the international aviation community.
New standards adopted by the International Civil Aviation Organization (ICAO), effective later this month, provide that a non-U.S. commercial pilot may continue to fly on two-pilot flights until age 65 as long as there is another pilot younger than age 60. While AARP believes the current Age 60 rule should be eliminated, U.S. commercial airline pilots should be afforded, at the very minimum, the same right to work that foreign pilots will receive in U.S. airspace.
Conclusion
The age 60 rule should be eliminated: it discriminates against pilots on the basis of age and no job qualification justifies its existence. Erasing the age 60 limit would alleviate the financial hardships faced by pilots forced prematurely from the cockpit as well as benefit the economy by allowing seasoned pilots to fly and continue to contribute to their and the U.S.’s economic well-being.
AARP appreciates the willingness of the FAA to re-examine its obsolete policy forcing otherwise qualified pilots from the controls at age 60. It is long past the time to eliminate this archaic rule adopted nearly a half century ago. At the very least, we urge the FAA to conform with the new ICAO standard as a first step to eliminating arbitrary age-based mandatory retirement for commercial airline pilots.
If you have any further questions, please do not hesitate to call me, or contact Amy Shannon of our Federal Affairs staff at 202/ 434-3760.
Sincerely,
David Certner
Legislative Counsel and
Director of Legislative Policy
Government Relations and Advocacy
The Honorable Marion Blakey
Administrator
Federal Aviation Administration
800 Independence Avenue, SW
Washington, DC 20591
Dear Administrator Blakey:
This letter is in response to the Federal Aviation Administration (FAA) request for comments on changing the Age 60 rule for U.S. pilots. AARP urges elimination of the outdated and discriminatory age limit which requires that commercial airline pilots cease flying at age 60. At the very least, the FAA should conform to the new standard adopted by the International Civil Aviation Organization (ICAO) that will allow pilots to fly until they are 65 if there is another pilot younger than age 60 in a two-pilot operation.
AARP is a nonprofit, nonpartisan membership organization that helps people aged 50+ maintain independence, choice, and control in ways that are beneficial and affordable to them and to society as a whole. With more than 37 million members, AARP is the largest organization representing the interests of Americans age 50 and older and their families. Nearly half of AARP members are working either full-time or part-time, and they have a vital interest in remaining on the job or finding work without facing age discrimination by their employers.
Older pilots should be judged on ability, not age.
AARP has long opposed the FAA’s Age 60 rule as well as any law or regulation imposing an upper limit on how long an individual can continue in a job. Older workers should be judged on the basis of their individual competence and ability, not on inaccurate and stigmatizing stereotypes. AARP has testified before Congress and the FAA in opposition to the Age 60 rule; filed amicus curiae briefs in the federal courts; filed comments in FAA rulemakings; and supported the efforts of individual pilots seeking exemptions from that rule. AARP has formally supported pending legislation to raise the age limit to 65 because it represents an important step toward recognizing that pilots should be judged on their skills, not on assumptions about age.
The Age 60 rule is discriminatory because age, rather than knowledge, skills, or experience, determines who can fly as a commercial airline pilot. Airline industry observation indicates that older, experienced pilots are often more capable and less subject to human error than are their younger counterparts. Airlines already test individual pilots regularly for their fitness to fly through medical certification and flight simulator exercises. Eliminating the age limit would not require additional medical exams, line or simulator checks, or operational restrictions. The FAA’s rigorous medical and operational performance standards screen out pilots of all ages who are unhealthy or poor performers, ensuring that commercial pilots of all ages are among the healthiest and most capable pilots employed.
Requiring commercial airline pilots to stop flying at age 60 affects not only individual pilots, but the U.S. workforce as a whole.
Airline pilots who reach age 60 are likely to leave their employers when they can no longer fly. They may retire or they may search for another job. If they look for work, former airline pilots will likely face obstacles to finding a new job; it takes older displaced workers longer to find work than it does for younger workers. The average duration of unemployment in 2005 was 25.9 weeks for jobseekers aged 60 or older and 17.5 weeks for jobseekers ages 16-59. Older workers who lose their jobs are more likely to drop out of the labor force. Twenty-six percent of workers ages 55-64 who were displaced between 2003 and 2005 left the workforce. This compares to 12 percent of workers ages 25-54. Older displaced workers who get jobs are more likely to experience earnings losses than younger job finders. Among workers ages 60-64 who had been displaced between 2001 and 2003 and rehired as of January 2004, the average drop in weekly earnings was 31 percent.
If they decide to retire, former pilots may face a significant drop in their retirement income. As the FAA is aware, a number of airline defined benefit pensions have defaulted in recent years, resulting in their takeover by the Pension Benefit Guaranty Corporation (PBGC). As a result, pilots have been hit with pension cuts twice: first, because the maximum annual benefit the PBGC pays is $47,659, much less than most pilots have earned; and, second, because benefits are further reduced for those who retire earlier than age 65. The reduction in what a pilot was expecting to collect in pension benefits before the PBGC takeover can be greater than 50 percent. In addition, those under age 62 are not yet eligible for Social Security benefits and consequently do not have a secure source of retirement income immediately available if they leave the work force. Furthermore, retired pilots who start collecting Social Security at age 62 will collect smaller monthly benefits than they would if they waited until full retirement age to collect—age 66 for persons turning 60 this year.
At the same time older workers experience roadblocks to finding work, policymakers predict there will be shortages of workers in the general economy as the boomers retire. This projected shortage includes airline pilots. The demand for pilots is expected to increase as the economy grows because there is likely to be more need for air travel.[1] Add to that expected growth in retirements among airline pilots and navigators – a projected increase of 173 percent during the period 2003 through 2008 - and there is likely to be a scarcity of qualified pilots within the next five to ten years.[2] Eliminating the age 60 rule would help mitigate the expected smaller pool of experienced pilots and help maintain healthy growth in the economy.
At the very minimum, the FAA should adopt the age 65 standard approved by the international aviation community.
New standards adopted by the International Civil Aviation Organization (ICAO), effective later this month, provide that a non-U.S. commercial pilot may continue to fly on two-pilot flights until age 65 as long as there is another pilot younger than age 60. While AARP believes the current Age 60 rule should be eliminated, U.S. commercial airline pilots should be afforded, at the very minimum, the same right to work that foreign pilots will receive in U.S. airspace.
Conclusion
The age 60 rule should be eliminated: it discriminates against pilots on the basis of age and no job qualification justifies its existence. Erasing the age 60 limit would alleviate the financial hardships faced by pilots forced prematurely from the cockpit as well as benefit the economy by allowing seasoned pilots to fly and continue to contribute to their and the U.S.’s economic well-being.
AARP appreciates the willingness of the FAA to re-examine its obsolete policy forcing otherwise qualified pilots from the controls at age 60. It is long past the time to eliminate this archaic rule adopted nearly a half century ago. At the very least, we urge the FAA to conform with the new ICAO standard as a first step to eliminating arbitrary age-based mandatory retirement for commercial airline pilots.
If you have any further questions, please do not hesitate to call me, or contact Amy Shannon of our Federal Affairs staff at 202/ 434-3760.
Sincerely,
David Certner
Legislative Counsel and
Director of Legislative Policy
Government Relations and Advocacy
TC
