Are not Type Ratings on an Airman's Certificate "credited" by the FAA for meeting FAA REQUIRED STANDARDS? If true, then why is there not ONE STANDARD for AIRCRAFT SPECIFIC training? A 135 Operator should NOT re-invent a aircraft specific training standard! SERIOUS consideration needs to be given to REWRITING FAA pilot training standards so that EVERY pilot attending training will meet ALL FAA REQUIREMENTS for that aircraft. Aircraft Specific training needs to be a credential that the pilot carries & SHOULD be acknowledged by ALL operators & the FAA. Safety needs to be enhanced by the practical operation of the aircraft. It is NOT enhanced by spending most of the time in the classroom without real world experience. Required training for a new hire pilot should target Operator Operations & a refresher on Part 135 regulations. After all, do not ALL 135 Operators function under the same rules?
A new hire pilot who has attended aircraft specific training within the last 6 months should be CREDITED with that training if the FAA STANDARDS have been met. He/She should undergo several supervised flights by the company Check Airman, Chief Pilot, or most experienced pilot on that aircraft type. This Supervisor would be required to document & sign off the pilot when they are ready to perform their duties. JAA/EASA requires 10-20 supervised & documented "sectors" (legs) to be signed off by the supervising pilot with "Base Trainer" authority prior to assuming normal duty. While I rarely agree with JAA/EASA, I think they are on to something with this performance evaluation process. THIS would enhance safety and pinpoint performance deficiencies if there are any. Before the FAA "clarifies" this ruling to no longer "credit" your OWN FAA DETERMINED Aircraft Specific training and checkrides, you need to perform a cost analysis of the financial impact that this rule will have on Part 135 Operators. The numbers for this excessive & redundant training will be staggering.
Susan Anderson
This is comment on Notice
Clarification of Policy: Approved Training Programs
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