FAA Draft Notice Clarifies Part 135 Initial Training

 - January 12, 2012, 3:35 PM

The FAA published a draft Notice that proposes to require that FAA inspectors review Part 135 operators’ pilot training programs “to identify and correct those programs which erroneously issued credit for previous training or checking.” Operators have been complaining that their FAA inspectors are no longer allowing previous training by new job candidates or temporary (contract) pilots to be used to meet initial training requirements. The big sticking point for operators has been that some FAA inspectors apparently incorrectly allowed credit for previous training, which made it easier for contract pilots to fly for multiple operators. But according to the FAA, “Regulations do not permit the crediting of such training.” However, the draft notice also offers a small consolation, outlining “guidance on constructing reduced hour training programs based on previous experience.” The new notice shows how operators “may then also apply for a reduced new-hire curriculum for pilots who have previous experience as a crewmember in Part 135 operations and/or the particular aircraft and duty position.” Comments on the draft notice (docket number FAA–2011–1397) are due by February 27.


This is much more far reaching than initial new hires. This affects recurrent training much more than initial training. There are 1000s of part time pilots out there that are current, qualified, and flying the line on several operator's certificates, right now, that are going to have to attend a specific training event for each individual operator they are working for. Not only will this double triple or quadruple the pilots training costs...it is completely unnecessary as we all know the training you receive at the 142 centers is, for the most part, not operator specific...it's aircraft specific. This is not new. Operators have been using contract pilots for as long as I can remember, and pilots have been using 1 set of training and checking documents all this time to satisfy the operators requirements.

There are serious implications to changing the interpretation to these rules. We all need to go to the docket folder and make our comments. I hope everyone does. -Eric

This is a classic case of an FAA lesson bringing their own views on an issue without weighing the consequences. This rule apparently came about because the new person in charge came from the 121 world and was surprised that 135 pilots could fly for more than one operator and sought to change things. While it's true that 121 pilots rarely, if ever, fly for more than one operator the same isn't true of 135 pilots. This rule simply doesn't take into account what is happening in the real world. this has driven up costs for everyone and the only winners are the training centers. It's done nothing to improve safety and everything to further burden pilots and operators alike. We have missed out on quite a few trips already because the cost of keeping contract pilots "trained" is simply too high and we don't have enough crews to do back to back trips when the need arises.

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