AIN Blog: Torqued: Part 135 Needs Plug-and-Play Training Option

 - August 1, 2012, 1:40 AM

Most companies looking to improve the speed and efficiency of their operations look to buy off-the-shelf products, whether software or hardware. The cost and time of customization and the upkeep of custom-made products is usually just not worth the money and effort, and usually the products are just not as good. Producers of the off-the-shelf products are the experts, whose business it is to make and regularly update their products. That’s what makes “plug and play” products so valuable to users, especially small operators who have their hands full running their businesses. You buy ’em, plug ’em in and you’re good to go. 

Plug-and-play concepts don’t have to apply just to products; they can also apply to services. Many companies find better quality services available from specialized providers, and flight training is an obvious example in the aviation industry. There are internationally renowned, FAA-certified training centers in the U.S. that provide the lion’s share of the Part 135 pilot training under their own approved training programs. 

But even though the flight schools are FAA-approved, when an operator seeks to add these training programs to its own certificate it can take weeks and often months to get the FAA to approve them. Why can’t “plug and play” apply to training programs for Part 135 operators, especially when operators have approved training programs and are just looking to add a new type of aircraft to their fleet? 

Right now, it is all too often a major hassle for small operators to get their training programs approved by the FAA when they add a new type of aircraft to their ops specs–even when they purchase that training from leading providers like FlightSafety International or CAE SimuFlite. And even when they make no changes to those programs. Why does each training request get treated as though the operator were reinventing the yoke?

I understand that the regulations require that an operator’s training program be approved. But there are only some 5,000 FAA inspectors and they are clearly spread thin with a lot of demands on their time. It’s obvious that approving additional aircraft types to small operators’ ops specs is not the highest priority. And maybe it shouldn’t be in the larger scheme of safety demands. But if we ever want to get the aviation sector out of turbulent skies, a little timely help from the FAA would be nice. Why not come up with a way of leveraging the approval of Part 142 training centers’ flight programs to save Part 135 operators some time and money?

I am certainly not advocating skimping on training or relaxing training requirements. I know from my years as an NTSB member the number of accidents that have resulted from poor or ineffective training programs. We had two fairly recent reminders, if we needed reminding of the importance of proper flight training. One is the Colgan accident just outside Buffalo, N.Y. in February 2009, which reinforced for all of us of the importance of solid training. Many of us were incredulous to learn that the captain of that ill-fated flight pulled, instead of pushed, on the yoke when the aircraft entered a stall.

Did he not know how to recognize that his aircraft was stalling? Or did he really not know how to recover from a stall? In any event, proper training for identifying a stall and recovering from it might have made all the difference in the world to the passengers on that flight and the people on the ground who were killed or injured. The crash of Air France Flight 447 in the middle of the Atlantic Ocean in June 2009 might also have been avoided if the crew had recognized an imminent stall and knew the proper procedures to follow. (And I don’t mean to let Air France or Airbus off the hook for their potential role in the reasons the aircraft stalled in the first place. Pilot training might just have been the link in the chain that–if it hadn’t broken–could perhaps have kept the aircraft from its deadly plunge.)

So I am not arguing for relaxing training requirements. Not at all. I’m arguing for standardizing training programs that could result in the FAA being able to approve an operator’s use of the programs more rapidly and without any diminution of safety. Basically, couldn’t the plug-and-play model be adapted so that there would be less work for the operator and less work for the FAA, allowing the agency to focus on more important operational issues than whether standardized training provided by the leading training providers met the standards that the FAA sets and that these providers train to? 

Wouldn’t it make more sense for the FAA to approve training packages provided by training centers–which are themselves certified entities–and allow Part 135 operators who choose to use those approved programs in whole to go through an abbreviated training approval process? 

Speeding up the approval process does not mean approving programs that are less safe. Not at all. In fact, I believe a large number of Part 135 operators would agree to enhanced requirements if it meant a swifter process. Time is clearly money when a company is trying to add a new aircraft type. The pilots need to be trained and ready to fly without the aircraft sitting on the ground any longer than is necessary to ensure a safe operation. I have heard complaints from respected industry professionals that their new aircraft have sat unused for as many as four months awaiting approval of standard FlightSafety or SimuFlite training for that aircraft type. Those are costly months, with aircraft lease payments, ramp and hangar fees, insurance, pilot salaries and so on.

Maybe it’s not a perfect analogy but take the Aviation Safety Action Program (Asap). When the FAA first started approving Asaps for airlines each airline’s program took months and months to negotiate until the FAA hit on a boilerplate model. If an airline used the boilerplate, approval would be fast. If an airline wanted to negotiate its own program, it was free to do that but the approval process would take longer as the FAA had to review it in detail. Sounds like a good model for Part 135 pilot training.


Mr. Goglia - you are spot on. I was surprised to learn that our (air carrier's) assigned POI is responsible for each operator's Check Airman at the training center, even though that Check Airman is checked and approved by the training center's own FAA Inspector! This is definitely an unnecessary duplication of tasks.

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