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FAA Information

This memo is to advise you of the FAA’s interpretations of FTEPA and to share with you ALPA’s list of FAQs concerning FTEPA. We expect to supplement and update this memo as additional information becomes available. Please continue to update Jim Wilson (james.wilson@alpa.org) about developments and issues that arise in this area on the properties on which you work so that we may remain consistent in our responses to members’ questions.

Since the FTEPA was signed into law the FAA has released information outlining its understanding of the legislation. The FAA has stated through the release of InFO Bulletins that:

-FAR 121.383(c), which established age 60 as the maximum age for service as a pilot, is no longer effective.
-A pilot over the age of 60 in international operations must be paired with a pilot under age 60 (consistent with the current ICAO requirement). The pilot under age 60 need not be on the flight deck at all times while a pilot over age 60 is on the flight deck. (But see Q/A 7 below regarding critical phases of flight.)
-In domestic operations both pilots may be over age 60.
-A pilot who reaches age 60 on or after 12/13/07 may continue to serve as a pilot.
-A person who reached age 60 before 12/13/07 may be employed or reemployed as a new-hire a pilot.
-A pilot over age 60 will not be subject to different, greater, or more frequent medical exams.
-A pilot over age 60 must hold a first class medical certificate, renewable on a 6 month cycle.
-An air carrier employing pilots over age 60 must adjust its training program to ensure that such pilots’ skill and judgment continue at acceptable levels.
-A pilot over age 60 must undergo a line check at 6 month intervals.
-For pilots over age 60 acting as SIC, a regularly scheduled simulator evaluation may substitute for a required line check.

The FAA likely will continue to update its statements concerning FTEPA as additional questions are submitted to them for clarification. We suggest that you monitor the Age 65 InFO portion of the FAA Web Site at http://www.faa.gov/other_visit/aviat...nfo/all_infos/
for up-to-date information from the FAA.

Please note that the statute as enacted by Congress takes precedence over any contrary view expressed by the FAA. At the same time, the FAA does have authority with respect to air carriers and flight crewmember certification that may enable it to place interpretations on the statute to fulfill its responsibilities. Accordingly, if there is at any point an apparent conflict between the FAA’s interpretation and the statutory language, it is especially important to seek guidance through Jim Wilson as discussed above.

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Frequently Asked Questions (Issues Other than Retirement & Insurance Benefits)

The following are questions that have arisen since enactment of FTEPA that we are able to answer based on information currently available. The following represents ALPA’s understanding of the statute and of guidance already provided by the FAA. We will continue to update this list of FAQs as additional questions arise and further information becomes available, including any further guidance and/or clarification from the FAA.

Q.1: What are “required flight deck crew members” and “pilots” for purposes of FTEPA?

A.1: FTEPA permits a person who reached age 60 before December 13 but who is serving on that date as a “required flight deck crew member” for a Part 121 carrier to serve as a pilot for that carrier without loss of prior seniority or longevity. For this purpose, a "required flight deck crew member” means a Flight Engineer or Second Officer, since only such person could have been serving as a “flight deck crew member” after reaching age 60. Hence, the term “required flight deck crew member” as used in this provision only refers to those required to fly (manipulate the controls) the aircraft. “Pilot” has the same meaning under FTEPA as it does elsewhere under the Federal Aviation Act, a person who is qualified to serve at the controls of the aircraft, as either pilot in command or as pilot second in command.

Q.2: A person attained age 60 prior to 12/13/07 but has not yet reached age 65. On that date he/she was engaged in Part 121 operations as a Flight Engineer or Second Officer. Is this person now eligible to serve as a pilot (Captain or First Officer)?

A.2: Under FTEPA, this person now is permitted to serve as a pilot until he/she attains the age of 65. FTEPA does not, however, require a carrier to permit the Flight Engineer or Second Officer to bump or displace into a pilot position. The Age Discrimination in Employment Act (ADEA) would require the carrier, and union, to treat the Flight Engineer or Second Officer at age 60 to 65 in the same way as if he or she were under age 60. Typically, this would mean under the relevant CBA that, in order to become a pilot, the Flight Engineer or Second Officer must exercise his or her seniority to bid into a pilot position. There may be exceptions based on the particular provisions of the relevant CBA.


Q.3: A person attained age 60 prior to 12/13/07 but has not yet reached age 65. On December 13 he had been awarded, and was awaiting training for or was in training for, a Flight Engineer or Second Officer position. Is this person eligible to bid into a pilot (Captain, F/O) seat without loss of seniority or longevity, in the same way as a person who was already serving as a Flight Engineer or Second Officer on December 13?

A.3 ALPA’s position is that this person may exercise his or her seniority to bid for a position as a pilot with that carrier to the same extent as a person who reached age 60 before 12/13/07 and who on that date was already trained, checked out, and serving as a Flight Engineer or Second Officer. This answer applies only to a person who on 12/13/07 was still in the employ of the carrier awaiting training or being trained to be a Flight Engineer or Second Officer. (Collective bargaining provisions regarding filling of vacancies would govern the way in which a crewmember who continues past age 60 could access the position of his choice.) ALPA is seeking an interpretation from the FAA consistent with this position.

Q.4: A person attained age 60 prior to 12/13/07 but has not yet reached age 65. On December 13 he/she was employed in a management position, instructor or in some other non-flying position. Assuming the person was not eligible to become a pilot based on the Flight Engineer/Second Officer exception (see Q/A.2 above), is he/she eligible to return to line flying as a pilot?

A.4: FTEPA provides that a carrier may hire or rehire this person to serve as a pilot but only without credit for prior seniority, longevity, etc. This person is not entitled to retain seniority and longevity credit because he/she attained age 60 prior to 12/13/07 and was not engaged in such operations as a required flight deck crew member on that date. FTEPA does not state that the carrier is obligated to rehire him or her, but the carrier must not engage in age discrimination in its hiring practices.

Q.5 A person who had been serving as a pilot or Flight Engineer was receiving disability benefits from his/her airline’s disability program but attained age 60 prior to 12/13/07. This person subsequently recovers from his/her disability prior to attaining age 65. Is he/she permitted to return to service as a pilot?

A.5 If the person was serving as a pilot for an air carrier that had no Flight Engineers or Second Officers, became disabled and then reached age 60 before 12/13/07, the disability would not give him or her a greater right than any other pilot for that carrier, which is only the right under FTEPA to be considered for rehire without seniority or longevity.

If the person became disabled while serving as a pilot or Flight Engineer/Second Officer for an air carrier that had Flight Engineers or Second Officers, then reached age 60 before 12/13/07, ALPA’s position is as follows:

·First, assume a case where the person had already voluntarily retired before 12/13/07 or worked for an airline where the collective bargaining agreement and disability provisions provided that the person had already exhausted his or her eligibility to return from disability. In that case, if the person recovered from the disability and obtained a First Class Medical he or she would be eligible to be rehired as a pilot but without seniority or longevity.

·Second, assume a case where the person worked for an airline where the collective bargaining agreement and disability provisions permitted the person to return to the airline as a Flight Engineer or Second Officer at the time when he or she recovered from the disability and where the person had not retired, exhausted his or her eligibility to return from disability, or otherwise separated from employment. If the person’s recovery from disability includes securing a First Class Medical, then he or she has the same right to exercise his or her seniority to bid for a pilot position with accrued seniority and longevity as any other Flight Engineer or Second Officer of that company. If a pilot position is not available when the person recovers from disability, or the person is not medically qualified for a pilot position, he or she can return as a Flight Engineer or Second Officer in accordance with the applicable pilot working agreement and terms of the disability plan, and then bid for a pilot position with seniority and longevity in accordance with the provisions of the applicable collective bargaining agreement, when a position becomes available and the person is medically qualified.

Q.6: A person had not yet attained age 60 on 12/13/07. On that date he/she was receiving disability benefits from his/her airline's disability program. This person subsequently recovers from his/her disability prior to attaining age 65. Is he/she permitted to return to service as a pilot (Captain or First Officer)?

A.6: Since this person had not attained age 60 as of 12/13/07, he/she is permitted under FTEPA to serve as a pilot until he/she reaches the age of 65, if otherwise qualified. His/her entitlement to return to service and, if entitled, the terms of his/her return to service would depend on applicable provisions of the CBA, but ADEA requires that such provisions must treat the person during the period age 60 to 65 the same as a person returning to work before age 60.

Q. 7: How does the ICAO “over/under” standard apply to augmented crews in international operations?

A.7: FTEPA provides that a member of the augmented flight deck crew in international operations must be under 60 and does not specifically require that this person be at the controls for any phase of flight. We understand from the FAA that when there is an augmented flight deck crew assigned to a flight, the assigned flight deck crew must include one pilot who is licensed, current, qualified, and appropriately rated for all phases of flight, and younger than age 60. A pilot younger than age 60 does not have to be on the flight deck when a pilot over age 60 is on the flight deck. However, ICAO and the FAA suggest that a pilot under age 60 be at the controls (a crew duty position) during critical phases of the flight (such as below 10,000 feet). The FAA expects air carriers and PICs to use best scheduling practices and crew management to ensure maximum compliance with this recommendation. Issues such as pilot seniority are not considered valid reasons for noncompliance.

The FAA “suggestion” as to critical phases of flight is not part of the statutory language and the impact of the Agency’s suggestion is unclear. The ALPA International Safety Committee endorses this suggestion and will provide further information and guidance as soon as possible.

Q.8: Are flights between a point in the United States and a point in Canada, Mexico or the non-U.S. Caribbean international operations for purposes of FTEPA?

A.8: Yes, under current FARs. The answer is the same even if the applicable CBA treats the applicable operation as domestic flying.

Q.9: Are flights between any one of the lower forty-eight states and Alaska or Hawaii domestic operations for purposes of FTEPA?

A.9: Yes. The answer is the same even if the applicable CBA treats one or both of these operations as international flying.

Q.10: Is a LOA negotiated in order to comply with FTEPA subject to membership ratification?

A.10: Such an LOA may or may not be subject to membership ratification depending upon the nature of the amendment and provisions of the MEC Policy Manual regarding ratification of LOAs. Put another way, the fact that the amendments are negotiated to comply with FTEPA doesn’t in itself change whether they are subject to membership ratification. If the membership declines to ratify reasonable terms, however, there is still an obligation to conform the CBA to FTEPA, and the implications of this requirement would need to be considered by the appropriate governing body. See A.11 below.

Q.11: What happens if ALPA refuses to negotiate, or the membership declines to ratify, CBA provisions required to comply with FTEPA?

A.11: FTEPA does not permit a carrier to make a unilateral change to the CBA or to a benefit plan, but does require that the parties negotiate terms to comply with the new law. So failure to do so could expose ALPA to risks of liability whether the failure was due to non-negotiation or non-ratification.

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Frequently Asked Questions (Retirement & Insurance)[1]

Q.12: If a person continues in service or is reemployed as a pilot after age 60, what is the impact of FTEPA on his/her retirement and insurance benefits?

A.12: The impact of FTEPA on a pilot's retirement and insurance benefits depends, in large part, on the precise terms of the applicable CBA and the applicable benefit plan(s). Applicable law (e.g., ADEA, the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code, and the regulations of federal agencies thereunder) also governs. In general:
ØA person who continues in service or is reemployed as a pilot after age 60 will be eligible for the same coverage and benefits, in accordance with the same formulas and subject to the same rules and procedures, as a pilot who had not yet attained age 60.
ØThe costs of providing LTD and health insurance benefits to active pilots are likely to increase due to coverage of an older workforce, but the costs of employer-provided subsidies for retiree health benefits are likely to decrease due to the shorter average duration of such coverage.

Q.13: How will a pilot be treated under his/her airline's 401(k) plan or other defined contribution plan (DC plan) with respect to service after age 60?

A.13: Under a DC plan, in general, all of the following will apply in the same manner as for a pilot under age 60:
ØThe employer must continue to make employer contributions to each of the pilot's accounts to the same extent as if the pilot were under age 60.
ØThe pilot will continue to be eligible to make employee contributions to each of his/her accounts (pre-tax and after-tax, as allowed by the plan) to the same extent as if the pilot were under age 60.
ØThe pilot will continue to have the same investment options available for each of his/her accounts.

Under a DC plan, the value of a pilot's accounts at retirement will probably be higher if the pilot retires after age 60, since the pilot will have more years of active service during which to accumulate contributions and earnings.

Note that, if specified in the DC plan, employer contributions may cease on account of circumstances other than age. For example, a DC plan that bases contributions on a target benefit formula may provide that contributions cease once a pilot's account is projected to reach the target. As another example, a DC plan may limit the number of years during which employer contributions will be made (e.g., a plan might provide that contributions will be made only for the first 25 years of service or plan participation).

Q.14: When will a person who continues in service or is reemployed as a pilot after age 60 be eligible to receive distributions from his/her DC plan accounts?

A.14: In general, a person who continues in service or is reemployed as a pilot after age 60 will not be eligible to receive distributions from his/her DC plan accounts unless the plan explicitly permits in-service distributions. For example, a DC plan could explicitly provide (or could be amended to provide) that a participant may elect to receive in-service distributions upon completion of a stated number of years of participation, upon attainment of age 59-1/2 (or some other age), upon furlough, or upon proof of financial hardship. Most DC plans do not provide for in-service distributions. Note that, under provisions of the Internal Revenue Code applicable to all DC plans, minimum distributions must commence to a plan participant by April 1 following the later of the year he/she attains age 70-1/2 or the year he/she retires from employment with the company maintaining the plan.

Q.15: Under most pilot DB plans, the normal retirement age (NRA) is defined as age 60. Will a DB plan's NRA change as a result of FTEPA?

A.15: In all but one of the pilot DB plans, age 60 is specified as the NRA under the plan (see last paragraph of this Answer for the exception). The NRA is a critical component in a DB plan since it is the age at which full, unreduced retirement benefits may begin (i.e., without the reduction, actuarial or otherwise, that would apply in the event of early retirement). FTEPA's increase in the mandatory retirement age will not change a DB plan's NRA; that may be accomplished only through collective bargaining, and there is no obligation under FTEPA or otherwise to agree to such a change. Further, under ERISA's "anti-cutback rule," a plan amendment cannot have the effect of reducing benefits that a participant has already earned. Therefore, even if the parties were to agree to amend the DB plan to increase the plan's NRA to age 65, the benefits a pilot had earned before the plan amendment cannot be subject to an early retirement reduction (actuarial or otherwise) if the pilot retires at age 60 (or older). Only the benefits a pilot earns after the plan amendment could be subject to an early retirement reduction if the pilot retires before the plan's new NRA.

The anti-cutback rule also applies to early retirement benefits. Thus, if the parties were to agree to increase the plan's earliest early retirement age, then with respect to the benefits earned before the plan amendment, a pilot will still be able to retire early and begin drawing the benefits in an amount not less than the amount he could have drawn under the plan's early retirement provisions in place before the plan amendment. Again, ERISA's anti-cutback rule applies only to benefits earned before a plan amendment.

Unlike the DB plans covering most pilots, the DB plan covering the pilots of Piedmont Airlines defines NRA as the "federally mandated retirement age," and defines the earliest early retirement age as 10 years before the NRA. ALPA is presently reviewing FTEPA's impact on this DB plan and the relationship to ERISA's anti-cutback rule.

Q.16: How is a pilot treated under his/her airline's defined benefit pension plan (DB plan) with respect to service past age 60 (assuming the plan's NRA is age 60)?

A.16: In general, in the case of an ongoing, non-frozen DB plan, the plan must either provide benefit accrual credit for service (and earnings) after age 60 or provide an actuarial increase to the retirement benefit that could have commenced at age 60. Most ongoing, non-frozen DB plans provide for continued benefit accrual credit for service (and earnings) after age 60 rather than an actuarial increase. Under most ongoing, non-frozen DB plans, a person who continues in service or is reemployed as a pilot after age 60 will have a higher retirement benefit, since he/she will be able to accumulate more years of credited service and higher average earnings, both of which are typical components of a DB plan's benefit formula.

Note that an ongoing, non-frozen DB plan may provide that accruals will cease on account of circumstances other than age. For example, credited earnings may be limited to a specified dollar amount or years of credited service may be limited to a specified number, such as 25 years. FTEPA will result in no increase in a pilot's retirement benefit for the period after the pilot reaches all of a DB plan's applicable caps.

DB plans that have been "hard-frozen" provide no benefit accrual credit for a pilot's service or earnings during any period after the freeze date, whether such period occurs before or after a pilot attains age 60. A participant in a hard-frozen DB plan will realize no increase in the amount of his/her accrued retirement benefits if he/she continues in service or is reemployed as a pilot after age 60, since the amount of his/her accrued retirement benefits became fixed as of the date the DB plan was frozen. Whether a hard-frozen DB plan must provide an actuarial increase to the amount of the accrued benefit that would have been payable at age 60 depends on the terms of the plan and applicable law; ALPA is presently reviewing this issue.

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Q.17: If a person continues in service or is reemployed as a pilot after age 60, when will he/she be eligible to begin receiving benefits from his/her DB plan? Also, if a retired pilot is reemployed as a pilot after age 60, will his/her DB plan benefits that were already in pay status continue to be paid during the period of reemployment? (The Answer below assumes the DB plan's NRA is age 60.)
A.17: 1. In this Part 1 of A.17, it is assumed that the person continues in service with, or is reemployed by, the same airline (or a corporate successor of the same airline) that maintains or had maintained the DB plan.

Payment of DB plan benefits is governed by the terms of the plan (see below for special rules applicable to terminated plans that are being administered by PBGC). A DB plan may provide either that plan benefits will be paid, or that plan benefits will not be paid, during a plan participant's period of continued employment or reemployment after age 60. However, in the case of reemployment, a participant's retirement benefits that were already in pay status must continue to be paid during the period of reemployment after age 60, unless the DB plan provides that benefits will be suspended during the period of reemployment and the plan administrator provides the participant with advance written notice of such suspension.

Several pilot DB plans have been terminated and are now being administered by the Pension Benefit Guaranty Corporation (PBGC). The NRA under these DB plans is age 60. Under PBGC policy, a pilot in a terminated plan may elect to commence receiving his/her pension benefits from PBGC at age 60, whether or not he/she continues in service with, or is reemployed by, his/her airline after age 60, even if the plan prior to its termination would have prohibited such in-service distributions. PBGC policy also permits a pilot in a terminated plan to elect to commence receiving pension benefits from PBGC after age 60, whether or not he/she is then employed or reemployed by the airline, at which time he/she will receive an actuarially increased retirement benefit (except that there will be no actuarial increase applied to Priority Category 3 benefits).

In addition, under PBGC policy, if a retired pilot with early retirement benefits already in pay status is reemployed by his/her airline prior to reaching NRA, PBGC will suspend payment of the monthly retirement benefits during the period of reemployment, unless the terminated plan had specifically provided that benefits would not be suspended upon reemployment. If a retired pilot with retirement benefits already in pay status is reemployed by his/her airline on or after NRA, PBGC will continue paying (and will not suspend) the monthly retirement benefits, regardless of the provisions of the terminated plan with respect to reemployment.

Some pilot DB plans have been terminated in a standard termination, with full accrued benefits provided by an insurance company under an insurance policy purchased by the plan. Under those plans, the terms of the insurance policy will govern the payment of retirement benefits to a participant who continues in service or is reemployed as a pilot by his/her airline after age 60.

2. In this Part 2 of A.17, it is assumed that the person continues in service with, or is reemployed by, a different company than the airline (or a corporate successor of the airline) that maintains or had maintained the DB plan.

While employed by a different company, the person may elect to begin receiving benefits from the DB plan at his/her early retirement age or later, and benefits that were already in pay status under the DB plan will continue without suspension. Put another way, a person's employment by a company that is unrelated to the one that had maintained the DB plan has no impact on the person's eligibility under the plan to begin or continue receiving retirement benefits under the plan. This is true whether or not the DB plan has terminated and whether or not the DB plan is being administered by the PBGC.

3. This Part 3 of A.17 discusses rules requiring participants to begin receiving benefits by a certain date.

In the case of an ongoing DB plan, the Internal Revenue Code requires a participant to begin receiving benefits by April 1 following the later of the year he/she attains age 70-1/2 or the year he/she retires from employment with the company maintaining the plan. In the case of a terminated DB plan that is being administered by PBGC, PBGC policy requires a participant to begin receiving benefits no later than April 1 following the year he/she attains age 70-1/2, whether or not he/she has retired from employment with the company that had previously maintained the plan.

Q.18: What is the impact of FTEPA on LTD plans?

A.18: Most LTD benefit plans are impacted substantially by FTEPA in the areas of eligibility, duration and cost.

Regarding eligibility, a pilot employed after age 60 will be covered for LTD benefits in the same manner as other actively-employed pilots.

Regarding duration of LTD benefits, in general, if before FTEPA an LTD plan provided that LTD benefits cease upon attainment of age 60 or the federally-mandated retirement age, then after FTEPA, the LTD plan must provide that LTD benefits cease no earlier than attainment of age 65 or the new, federally-mandated retirement age.

It is likely that the costs of pilot LTD plans will increase after FTEPA, due to the coverage of an older workforce and the extension of the duration of LTD benefit payments.

Note that an LTD plan may provide (or may be amended to provide), that LTD benefits will cease on account of reasons unrelated to age. For example, a plan may limit monthly benefits to a specified dollar amount, such as $5,000 per month, or may limit the duration of benefits that are attributable to certain causes, such as mental illness, emotional disorders, alcoholism and drug addiction, to a specified length, such as 24 months. In addition, LTD benefits may be offset by a participant’s other income, such as income from other employment, Social Security disability and retirement benefits, workers compensation benefits, and pension benefits. An LTD plan may also provide that LTD benefits are offset by retirement benefits that a participant who is age 62 or older is eligible to receive but does not actually receive (so long as the participant is not required to retire to receive those benefits).

Q.19: What is the impact of FTEPA on an active pilot's health benefits (medical, prescription, dental and vision)?

A.19: A pilot who continues in service or is reemployed after age 60 will be covered for health benefits in the same manner as other actively-employed pilots. It is likely that the costs of active pilot health benefits will increase after FTEPA, due to the coverage of an older workforce.

Q.20: What is the impact of FTEPA on retiree medical benefits?

A.20: In general, a pilot who retires after age 60 will be eligible for the same retiree medical benefits during retirement as a pilot who retires at age 60. If the applicable CBA presently provides employer-paid subsidies toward the cost of retiree medical coverage (pre-Medicare coverage and/or post-Medicare coverage), then a pilot retiring after age 60 will be eligible for the same subsidies during retirement as a pilot retiring at age 60. If no pre-Medicare retiree medical coverage is provided, then a pilot who retires at age 65 will become covered by Medicare immediately upon retirement and will experience no gap in medical coverage between the date coverage as an active pilot ceases and the date coverage under Medicare begins.

FTEPA will have no impact on the retiree medical benefits of a pilot who retired before FTEPA was enacted; however, in the case of a retired pilot who is reemployed as a pilot after age 60, different retiree medical benefits could apply under the applicable CBA upon the pilot's subsequent re-retirement.

Q.21: What is the impact of FTEPA on an active pilot's life insurance benefits?

A.21: A person who continues in service or is reemployed as a pilot after age 60 will be covered for life insurance benefits in the same manner as other actively-employed pilots. Under most employer-paid life insurance plans for active pilots, the life insurance benefit is expressed as either a flat dollar amount or as a multiple of the pilot's earnings, without regard to the active pilot's age. It is likely that the costs of active pilot life insurance coverage will increase after FTEPA, due to the coverage of an older workforce.

Q.22: Is more information available about the impact of FTEPA on pilots' retirement and insurance benefits?

A.22: For specific information, please contact your MEC Benefits Specialist (if your MEC has one), or an R&I Field Representative or Benefits Attorney in the R&I Department. In addition, you may find more specific information in the following documents:
ØMemo prepared by the R&I Department, June 1, 2007, "Age 60: Impact of Increase in Mandatory Retirement Age on Pilot Retirement and Insurance Benefits" (previously provided with Jim Wilson's memo of November 27, 2007, or available from the R&I Department)
ØExcel file prepared by the R&I Department in June, 2007, identifying references to age in various carrier-specific benefit plans (previously provided with Jim Wilson's memo of November 30, 2007, or available from the R&I Department)
ØLetter dated December 26, 2007, from Captain John Prater to Mr. Charles Millard, Executive Director of PBGC, requesting guidance, and confirmation of ALPA's analysis, with respect to certain FTEPA-related issues concerning pilot DB plans administered by PBGC (copy attached to the email by which this FAQ is transmitted)
ØLetter dated January 11, 2008, from Mr. Bennie Hagans, Director of Benefits Administration and Payment Department of PBGC, to Captain John Prater giving guidance requested by ALPA on December 26, 2007 (copy attached to the email by which this FAQ is transmitted)


[1] In Questions 12 through 22 the term “pilot” includes Flight Engineers and Second Officers.