Pop quiz. What is wrong with this seat map that recently popped up on Great Lakes Airlines’ website?

If you said it looks like there are seats missing, you’d be right. This is a Beechcraft 1900D, an airplane that most commonly has 19 seats. Nate, who writes EASFlights.com and pays close attention to these things, sent me a note showing that Great Lakes has recently put this seat map showing just nine seats onboard in its Flight Info section on its website. Why would anyone deliberately pull off more than half the seats on the airplane? Though I don’t know the official reason, this would be one way to get around the pilot shortage that cause the airline to shutter its Minneapolis hub. Let me explain.

Just about every airline in the US operates under 14 CFR Part 121. That’s part of the code of federal regulations. You’ll commonly hear it referred to as just Part 121. Any airline operating under Part 121 is subject to those new pilot rules requiring each hired pilot to have 1,500 hours of flying (with a few exceptions).

But there is another piece of the code, 14 CFR Part 135 (commonly just Part 135) that can apply to carriers that operate tiny airplanes. While it’s been said that safety at a Part 135 operator is comparable to a Part 121 operator, there’s no question that the rules are less restrictive. That more lax rulebook actually caused the federal government to act back in the 1990s.

Until the 1990s, operations under 30 seats could be conducted under Part 135. But in the mid-1990s, as scrutiny increased on the safety of regional operations, a rule was introduced that said scheduled Part 135 operators could only operate aircraft with fewer than ten seats. If you’re curious why we don’t see a lot of 19-seat aircraft anymore, that’s one reason. A Part 121 operation is more costly to run and the economics haven’t made nearly as much sense since the rule went into place.

Of the remaining operators in the 19-seat range, most aren’t as concerned about economics since they are operating a lot of Essential Air Service routes that are subsidized by the government. There’s only one problem with that. They can’t find pilots. As mentioned, Great Lakes shut its Minneapolis hub. Silver Airways has also said it will ditch its 19-seat operation, because it can’t find enough people to fly the airplanes. If you had a bunch of airplanes sitting on the ground with nobody to fly them, what would you do?

Well, if you started a separate airline that operated under Part 135, you would have lower operating costs, but more importantly, you could hire pilots that had fewer than the 1,500 hours required under the new regulations for Part 121 operators.

Though there seems to be conflicting information in the rules, my understanding is that under Part 135, the pilot in command has to have either 1,200 or 1,500 hours of experience, the latter being just as in Part 121. But the second in command? He or she only needs to have 250 hours of experience. The pool of pilots with between 250 and 1,500 hours is large, and this would allow Great Lakes to tap into that and operate a lot more flights.

The natural reaction is… isn’t that insane to run a 19-seat airplane with only 9 seats? In the normal world, yes. That would mean your costs are going to be much higher on a per-seat basis. But we’re not in the normal world. We’re in Essential Air Service world. And in Essential Air Service world, airlines are lucky to get 9 people in those 19 seats on a good day.

Pull out all those seats, and the airplane is lighter. So if Great Lakes isn’t running with more than 9 seats filled anyway, it would end up being cheaper to do. And it’s much easier. Kind of brilliant, actually, assuming the feds don’t find some reason to kill this plan.

Is it a safety issue? Well, the pilots that Great Lakes can find would be the same ones that were probably going to get hired at another regional before the new rules. There are plenty of very good pilots with fewer than 1,500 hours that should be flying. So as long as they hire right, it wouldn’t be a safety issue from that perspective. There’s obviously a lot more to Part 135 than just pilot hiring, and I can’t speak to any safety ramifications of that, but there are plenty of airlines who have safely operated under Part 135 for years.

As I said, I don’t have an official word on why this is happening, but I can’t think of another reason why you’d bother pulling seats off the airplane.