At a time a shortage of pilots has prompted regional airlines to contemplate relaxing their experience minimums to attract new first officers, the proposed rule issued recently by the FAA to require an Air Transport Pilot (ATP) certificate for first officers—along with its accompanying 1,500-hour flight-time minimum—must keep human resource managers awake at night. It also puts alphabet organizations such as the Regional Airline Association in a serious bind.

To the general public, the RAA cannot show anything other than an unassailable commitment to safety, regardless of the cost consequences to its membership. To its airline members, its responsibility lies not only with projecting a positive public image but also with cost containment, which, in effect, translates into lobbying for less regulation, not more. Meanwhile, the members of the association serve another master—their major airline partners—whose interests sometimes conflict with those of the smaller airlines on which they depend for passenger feed or low-cost supplementary service.

In a way serving cross purposes, the RAA finds itself in an unenviable position. As a result, rather than taking a definitive stance on an issue, it must walk a fine line between projecting a commitment to public interest and delivering on its obligations to its members.

So when AIN asked for a position from the RAA on the new pilot qualification NPRM, the fact that it declined comment beyond a somewhat non-committal written statement on its website seems understandable given the circumstances. In effect, it did little more than restate its commitment to safety and emphasize the need for further study.

Unfortunately, all the study in the world won’t change the laws of supply and demand for the nation’s airlines. Fewer qualified pilots will mean a smaller pool of recruits from which to choose. Costs will inevitably rise for everyone.

In effect, safety cost-benefit analyses place a value on a human life. And we, as a society, accept a certain level of risk for cheap airline tickets. Unfortunately, it took the loss of 50 lives in the 2009 crash of a Colgan Air Q400 to expose the level of risk all of us had accepted for too long.