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FAA Clarification of Policy Regarding Credit for Previous Part 135 Training and Checking
February 13, 2012
Part 135 operators are required by Federal Aviation Administration (FAA) regulations to train and check crewmembers in accordance with the operator’s approved training program. The operator has the responsibility to ensure that each individual is proficient and fully qualified in the certificate holder’s operations and procedures prior to authorizing the individual to operate as a required crewmember.
It is common in the Part 135 industry for crewmembers to fly for more than one operator over the course of one’s career. Sometimes a crewmember intentionally qualifies to fly for more than one Part 135 operator at a time. Various interpretations of the rules by operators and local FAA inspectors have brought us to a point where some operator’s 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.
To remedy this variance, the FAA issued a draft notice on December 27, 2011 that would require FAA inspectors to review Part 135-approved training programs to identify and correct programs that erroneously issued credit for previous training or checking. The notice also provides guidance on constructing reduced-hour training programs based on previous experience.
NBAA Issue Position
Members of NBAA’s Domestic Operations Committee and staff met on February 9 with the FAA to discuss concerns with the proposed requirement raised by NBAA Members. NBAA will submit comments to the FAA on this notice and will provide a copy on this page when available.
NBAA agrees with the FAA that the regulations do not permit the crediting of training previously completed while in the employment of another certificate holder, with the specific exceptions of CRM and DRM training. Likewise, NBAA agrees that the crediting of evaluations/checking conducted by the previous certificate holder may not be credited pursuant to the intent and technical provisions of Part 135.
NBAA agrees that Part 135 certificate holders should be permitted to develop and submit for approval multiple curriculums for a particular crewmember position and aircraft make/model variant that take into account the previous experience of the individual as a crewmember in Part 135 operations or on that aircraft make/model by reducing the curriculum content/hours. For example, if an individual has previously received training on a system on a given aircraft type that is the same from one serial number to the next, reduced training on that system should be permitted with any operator-specific differences trained. That said, it is NBAA’s position that the operator is still required to ensure the individual has the requisite knowledge of that system through appropriate evaluation/checking.
NBAA believes that the quality of the training, not merely the quantity, should be the FAA’s and operator’s primary focus and remains committed to working with the FAA to ensure the guidance reflects this.
The FAA announced the availability of this draft notice in the Federal Register on December 27, 2011 with a request for comments. NBAA encourages Part 135 operators to send their comments to the FAA by the February 27, 2012 deadline, especially considering the interests of Part 135 certificate holders in this matter and the fact that the FAA generally does not request comment on internal Notices and orders. Comments may be submitted via the Federal eRulemaking Portal, mail, hand delivery or courier, or fax and should be identified by docket number FAA-2011-1397. Further instructions for submitting comments to the FAA on this draft notice can be found in the following Federal Register notice.