Daniel Kokosenski

Document ID: FAA-2011-1397-0003
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: January 04 2012, at 12:00 AM Eastern Standard Time
Date Posted: January 5 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: December 27 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: February 27 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80f8dff9
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This is comment on Notice

Clarification of Policy: Approved Training Programs

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All Part 135 training programs, and most 91 programs are virtually identical in regards to curriculum and methodology employed by Flight Safety and Simuflite. They consist of the same checkride criteria for a given airplane. Not giving credit for previous training, and forcing companies to send each new-hire to a full initial, reduces flexibility and dramatically increases training costs, all while not improving safety by any appreciable margin. Furthermore, how is it that two pilots attending the same ground school, the same simulator, and the same checkride, at the same time be forbidden from receiving credit for a "different" operator? In my opinion, any "differences" (checklists, SOPs, etc.) apart from simulator (or flight based) training can be mitigated with "extra" ground instruction at the company's direction.