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FAA Attempting to Standardize Initial Part 135 Training Requirements The FAA can’t win.
Long reviled for inconsistently applying its own regulations, the agency is now being questioned for trying to standardize the way initial training is conducted for newly hired Part 135 charter pilots. The fact that FAA Flight Standards District Offices (FSDOs) haven’t been applying these rules consistently for many years is a big part of why many charter operators are unhappy with the FAA. Many FAA inspectors allowed previous training received by new pilot candidates, including temporary (contract) pilots, to be used to meet the initial training requirements of Part 135.
Of more concern to some operators is that the newly interpreted standards cost operators a lot of money for little, if any, safety benefit. The FAA’s standardization effort comes in the form of a draft notice that proposes to require that FAA inspectors review Part 135 operators’ training programs “to identify and correct those programs which erroneously issued credit for previous training or checking.” By incorrectly allowing credit for previous training, the FAA inspectors made it easier for contract pilots to fly for multiple operators. This in turn also made it less expensive for a charter operator to hire a pilot who flies the exact same aircraft type and had just recently concluded training with another operator.
According to the FAA draft notice, “Regulations do not permit the crediting of such training.” A comment from Henry Schubach, president and chief pilot of Carlsbad, Calif.-based Schubach Aviation, summarizes this issue succinctly: “I recently attended FlightSafety International in Long Beach for a GIV initial type rating, and 135.293 and 135.297 check. I attended with a friend of mine, who happens to work for a competitor on this same airport. We took the same class, on the same days, with the same course content, from the same instructors, took the same simulator training from the same instructor and took our check rides together from the same check airman.
Before the changes contemplated in the action referred to in this letter, either he or I could walk across the ramp, take some company-specific training on the company’s [Part 135] certificate and go flying in each other’s airplane. After the change contemplated by this ‘clarification,’ each of us would now be required to take the exact same training again at significant cost with no reasonable or rational need, to fly on the other company’s certificate. The fact is this change will result in no realistic operational or safety benefit.” Schubach continued: “What this change won’t do is increase safety or eliminate any existing risks or problems. What it will do is impose undue economic hardship on numerous [Part] 135 operators who use contract pilots for either all or some of their crewing requirements, and impose an unbearable economic burden on those pilots, who will be faced with having to pay for the same training over and over again. It seems to be an attempt to bring training appropriate to Part 121 operations to the Part 135 arena, where it clearly does not fit. The example cited above clearly illustrates the absurdity of this.
