Anonymous

The FAA proposal to standardize pilot training is ill conceived and lacks common sense. The unintended consequences of the proposed requirements will have a significant negative impact on Part 135 operations with no safety benefits over exiting regulations. Existing pilot training requirements already maintain a high level of standardization for pilots operating under Part 135. The FAA currently mandates that all pilots complete training specific to company policies and procedures. This training is detailed and must be repeated yearly. In addition, pilots operating under Part 135 typically receive training once or twice per year by a large Part 142 training provider (i.e. Flight Safety or Simuflite). With a few minor exceptions, the Part 142 provider and the aircraft manufacturer standardize this training. As an example, pilots from different Part 135 operators sit side by side in the same ground school and simulator training because the training is standardized. The FAA proposal will require pilots to repeat the same training over again simply because the pilot works for a separate operator. This would be cost prohibited and unproductive. Contract pilots provide an essential service to the aviation community and public. Currently part 135 operators supplement their needs with contract pilots. Since working for a single operator is inherently limited, a contract pilot may work for more than one Part 135 operator. Being restricted to one operator is not financially viable. The duplicate training requirement would effectively regulate contract pilots out of business. The current system is safe and has worked well for many years. FAA Principal Operating Inspectors (POI) should continue to have the flexibility to use a common sense approach to insure that all pilots met training standardization. If unique circumstances dictate that additional steps are needed toward this goal, this can be easily done on a case-by-case basis.