What should a charter operator do when a captain needs an FAA 135.299 line check by the end of the month or they will be demoted to first officer status, and the FAA office is in overload and no inspectors are available? The inability to complete the line check in a timely manner could jeopardize the charter schedule, forcing the cancellation of many revenue-generating flights.
Michael McCullough, assistant director of operations at Aviation Resource Management and chair of the NBAA’s Part 135 Committee, had heard about a potential solution and decided to investigate. It turned out that others were already exploring the application of video and audio tools, or video and communications technology (VCT), to create a virtual record of a line check flight that FAA inspectors could observe in their offices instead of flying in the airplane. The result: a process for line checks that eliminates the complicated logistics, not to mention risks, that make in-flight line checks a huge challenge.
“We were hearing from our membership that the FAA was starting to conduct these virtual checkrides, but FAA inspectors often didn’t know where to start the process,” said McCullough. “Our committee decided to take a proactive step and create a document offering some recommended guidelines for virtual 135 checkrides. In the past, proactivity has been welcomed by the FAA, as long as the subject effort complies with applicable FAA guidelines and regulations.”
Line Check Guide
The committee’s work product is entitled VCT Line Check Best Practices Guide. It provides a step-by-step process for organizing a VCT-based checkride, including the video and audio components needed, how to arrange them in the cockpit, and how to work with the FAA to gain approval of the system as a method of documenting the line check.
According to the guide, GoPro action cameras are the suggested video and audio recording devices. GoPro offers a wide variety of simple, rugged cameras that are adaptable to almost any activity, be it a rugged mountain bike ride, a rocket into space, or a flight in a corporate jet. Weighing less than six ounces, these devices are small and can be securely fastened in place with portable clamps or flexible mounts, simplifying the setup process and eliminating the need for complex maintenance approvals. Later model GoPro cameras have built-in stabilization that ensures a rock-solid video.
Two cameras should be used in a flight deck setup, one focused on the flying pilot’s instrument panel and the windshield, and the second on the flying pilot’s primary instruments. Audio inputs can be captured via a special cable plugged into the headphone connector between the headset and aircraft, then into one of the GoPro cameras.
To initiate the process, the document suggests sending a test video to the FAA that gives the inspector insight into what the flight check will look like, along with a request for approval to conduct the virtual checkride. As well, the entire exchange between operator and the FAA, according to the guide, should be documented via email. Once the FAA is in agreement, the operator can firm up the VCT configuration and schedule the flight check.
An important part of this process is that a non-flying individual, preferably a company check airman, should ride along on the flight check to manage the VCT process, insuring that the crew being evaluated can concentrate on their flying duties. Once the flight crew is in place in the airplane, before they begin pre-start procedures, that non-flying person should start the GoPro cameras and state for the recording the date and time. When the flight is completed and the aircraft is shut down, the non-flying person announces the time of shutdown and switches off the cameras.
The guide suggests uploading the VCT file to a predetermined portal, then scheduling a remote debrief with the FAA inspector via an online meeting platform. The pilots involved in the checkride should be present for the debrief. Once everyone is in place virtually, the VCT recording will be played. The inspectors will electronically approve the appropriate records or note any failures or incomplete items that could require a re-check.
The FAA has not formally endorsed or approved the guide, according to McCullough. But inspectors have reviewed it and provided comments. Operators should work with their principal operations inspectors (POI) to determine when the VCT checkride process is appropriate. Many FAA inspectors are unaware of or have little knowledge of the process, so it is up to operators to provide as much information as possible to assist POIs in defining a path forward. The NBAA guide is an effective tool in that process.
Real-life Example
In 2020, amid the Covid shutdowns, Ashley Smith Jr., president and director of operations for Jet Logistics, had a need to accomplish line checks for two captains on a newly acquired jet. The airplane was based in Scottsdale, Arizona. The POI in South Carolina could not get his office to approve a trip across the U.S. But Smith found out from the flight crew on the airplane that the Scottsdale FSDO was experimenting with virtual line checks.
On further inquiry to both the Scottsdale FSDO and the NBAA, the latter where Smith is a contributing board member, he determined there was such a procedure. If it worked, it would solve his dilemma.
“The Scottsdale FSDO was administering line checks using GoPro cameras installed in the aircraft,” Smith said. “The recordings were then reviewed by the appropriate inspectors, after which they were signing off line checks.”
Smith thought the virtual line check process could help other operators and got McCollough and the NBAA involved in creating the guide so others could take advantage of this opportunity.
Familiar with GoPro cameras in aircraft from his aerobatic flying, Smith applied that knowledge to set up a functional recording system in a Citation XLS that would be the subject airplane for the planned line checks.
“The Scottsdale FAA team gave us some general guidelines,” Smith said, “but explaining that the process was, at this time, not officially approved. Still, it was our only option, so I decided to take the greatest care to provide a well-documented record.”
Early in the setup, one of the GoPros had a battery failure. Smith made sure their documentation added a suggestion to have extra batteries on hand during the flight. He organized the airplane and crew for the flight and flew with them, taking care of the cameras and identifying enhancements that could improve the quality of the record.
“We took the raw footage and developed a better-running, well-notated video record for the FAA,” Smith said. “Using iMovie, the Apple app on my Macintosh laptop, we added text notations identifying video scenes in the flight where an inspector could note key points in the flight for the record.
Based on Smith’s video and audio recording, Jet Logistics’ POI was able to approve the two line checks.
“We spent a lot of effort to make sure we got this right,” Smith said. “I do believe this virtual process will work for the industry, provided inspectors at the FSDOs around the country buy into it. To that end, the more we operators develop a well-documented, repeatable procedure, the more likely we are to get FAA inspector buy-in.”
