Industry Comments on FAA Training Clarification Notice
There were 28 comments about the training clarification notice in the docket, some from aviation associations and many from key large charter/management companies and training provider CAE.
• NBAA: Various interpretations of the rules by operators and local FAA inspectors have brought us to a point where some operators’ approved programs erroneously provide complete credit for previous training and checking conducted under another Part 135 certificate holder’s program. Conversely, other interpretations require operators to put individuals who have significant experience in a given aircraft type that he or she will continue to fly for the “new” certificate holder through a complete initial training course for the aircraft. We consider these examples to be the ends of the spectrum, neither of which is fully consistent with what the FAA’s regulations actually dictate to and policy actually expects of Part 135 operators. We highlight this point to ensure that the FAA is aware of the significant differences in the interpretations of the existing requirements.
A coordinated widespread education effort will be needed to bring resolution to this issue to the inspector work force and operator community. It is NBAA’s position that previous Part 142 training received pursuant to another training program can safely be accepted as the basis of reducing that pilot’s training requirements. For example, if an individual has significant experience in a given aircraft make and model and moves from one certificate holder to another, the training program of the latter operator ought to allow a reduction in training required considering the previous training experience of the individual, but that company-specific items (i.e. checklists and callouts) need to be covered through differences training and then checked.
It is common in the Part 135 industry for crewmembers to fly for more than one operator over the course of [their] career. Sometimes a crewmember intentionally qualifies to fly for more than one Part 135 operator at a time, which is generally unique from crewmembers in Part 121 operations. A contract pilot is one example of this scenario. Contract pilots play an important role in the Part 135 industry. The needs of contract pilots, i.e. checking for multiple Part 135 operators during a training event, can be somewhat different [from those of] a crewmember permanently switching from one certificate holder to another. Contract pilots should be permitted to complete “back-to-back” check rides to receive an 8410 for each operator. Very clear FAA guidance to operators and inspectors that leaves no room for interpretation is the only way to truly resolve this issue.
• Executive Jet Management: [The FAA draft] notice does not identify the FAA regulations that make the proposed change in policy necessary. [Checks required by regulations (135.293(b), 135.297 and 135.299)] are not certificate-holder-specific checking events. These checks test an individual airman’s skill in operating the aircraft, performing standard instrument procedures and ability to operate in the national airspace system. They are not specific to the policies or procedures or other training needs of any individual certificate holder.
• Individual: This interpretation makes as much sense as requiring someone to go to initial or recurrent training just to fly the same make and model with a different N number. Pilots should be given credit for “ALL” aircraft-specific training. Operators should only be required to give in-house training for differences in their policies, operation specifications and so on. I can see no enhancement to safety by making a pilot go through each complete training program for every operator with no credit given for previous training. All I see is a huge financial hardship with no gain in safety.
• Cheryl Janke, CEO, Prime Jet: The proposed action to disallow credit for previous crew training places an undue economic burden on the operators without any quantifiable safety benefits to crew or passengers. The Part 135 training curriculum and methodology that FlightSafety and SimuFlite employ are uniform in nature, evaluating crew on aircraft-specific guidelines outlined in 135.293 (a)(2) and (3). New hires sent to training by another operator are evaluated on virtually indistinguishable training guidelines already approved by the FAA. To make a crewmember go back to a training center and enroll in “initial” training for a specific aircraft negates the purpose of training facilities standardizing aircraft-specific training in the first place. The only measured “difference” in training would be the operator name listed on the crew’s formal training documents. If there was an appreciable safety advantage to be gained from doing so, the rule may be worth considering. Should this rule pass, the financial benefits reaped by the training facilities far surpass any legitimate attempt to promote and foster operator safety.
• Individual: This will easily double the workload of your [FAA] inspectors to no advantage. Even with a reduction in planned training hours, you are required to follow the identical base curriculum. Why not, as an alternative, use the currently approved base program and then have an addendum approving a reduction in planned training hours listing specific prior experience that would qualify for the reduction? The planned hours then could be “as required” and “trained to proficiency” if qualified for a reduction.
• Gregory Wilcox, director of operations, Avjet: Part 135 air carriers must be allowed the flexibility to conduct the required aircraft-specific ground and flight training that reflects a pilot’s experience. If a pilot is qualified as a pilot-in-command of a particular type aircraft (example: Gulfstream GIV under Part 91 or Part 135) and has completed training and/or checking within the previous 12 months, the air carrier should be allowed to complete this individual’s Part 135 initial aircraft-specific ground and flight training in a reduced number of hours other than those hours specified for initial aircraft training in the 8900.1 guidance. There is no benefit to sending a pilot with these qualifications to an initial training course equivalent to the initial aircraft initial type rating if they are already qualified in the aircraft.
For many years Part 135 operators have been building training programs that provide for qualified pilots to complete Part 135 initial aircraft-specific ground and flight training under a reduced training hours curriculum equivalent to the Part 135 recurrent training curriculum and hours for the particular aircraft type. This process ensures that the pilot has current aircraft-specific ground and flight training and has completed the required Part 135 pilot checks before being assigned to line duties. A qualified pilot should not have to complete a training program equivalent to the aircraft type rating again to be Part 135 qualified.
The changes indicated in the “Clarification of Policy Regarding Approved Training Programs” [notice] and outlined in the 8900.1 for initial aircraft-specific ground and flight training can require up to three times as much time and money to complete, which is a huge financial impact on an air carrier, an expense that can be mitigated by hiring experienced and qualified pilots and allowing them to complete the initial aircraft-specific ground and flight training under a reduced training hours curriculum. We request that the policy changes described in “Clarification of Policy Regarding Approved Training Programs” are reconsidered to continue to allow Part 135 operators with pilots that have experience in a particular aircraft type to conduct initial aircraft-specific ground and flight training under a reduced training hour curriculum equivalent to the recurrent training curriculum and hours for the particular aircraft type.
• CAE requests that the FAA formally address the training and checking requirement for pilots who wish to serve as crewmember for multiple Part 135 certificate holders. CAE has received several inquiries about training from contract pilots under Part 135.
Contract pilots, or day pilots, are trained and checked in accordance with an air carrier’s training program, are under the operational control of that carrier for a defined period of time and in many cases are financially responsible for their own training. They are paid by the trip or by the hour by the certificate holder and are on an on-call basis for scheduling. CAE has received several requests for these types of pilots wanting Part 135 training and checking for multiple certificate holders based on one training and checking event.
CAE is proposing the following solution based on these requests: the contract training provider may issue training and checking records for multiple Part 135 certificate holders providing that: 1. The training programs are essentially similar with respect to checklist usage and standard operating procedures and flight profiles; 2. The contract simulator instructors and contract simulator check airman are common between the certificate holders; and 3. The directors of operations and POIs for the multiple certificate holders provide written approval to each other and to the training center.