Bob Chipperfield

I am writing this flying home from recurrent training at Simuflite. It cost me $11,000 out of my own pocket. As the rules are presently interpreted, if I was to fly for another 135 operator I would have absolutely no credit for this and would have to repeat and pay not for recurrent but for a complete initial training course which will range from $15,000 to $55,000 depending upon the aircraft model. I can guarantee you it will be the identical training I have already done with the same training materials, the same instructors, and the same simulators. I would have to do it all over again if I flew for a subsequent operator. The current interpretation is going to cause an intolerable financial burden on thousands of individuals and hundreds of 135 carriers who depend upon supplementary crewmembers. What purpose does this interpretation actually serve? Recommendations. Part 135 carriers are already providing “in house” Certificate Holder (“CH”) training for company specific subjects such as Operations Specifications, company policies and procedures, operations manual, flight control and flight locating procedures. This is appropriate and no change to this category needs to be done. All crewmembers have to have this company specific knowledge to operate properly. Training for all other company neutral subjects such as weather, ATC procedures, flight training etc. should be given credit if given by a certified carrier or by an Approved Outsource Contractor(s) (“OSC”). To say that one Part 135 certificate holder’s training for company neutral subjects is not satisfactory for another carrier is saying in effect that the FAA oversight of the first carrier’s training was insufficient. What was wrong or missing in the first carrier’s training? Additionally, minimum required hours of training is a concept that dates to the 1930’s. Today the criteria should simply be performance / results based with training hours as necessary.