COMMON SENSE MUST BE APPLIED TO ANY RULE CONCERNING TRAINING PROGRAMS FOR AIRCRAFT AND SPECIFICALLY WHEN ACCEPTING OR REJECTING PREVIOUS TRAINING WHEN HIRING A NEW PILOT. AS PROPOSED A PILOT COULD GO TO INITIAL TRAINING AT FLIGHT SAFETY IN A HAWKER 800. THE DAY HE COMPLETES THE TRAINING HE LOSES THAT JOB AND ACCEPTS A NEW JOB AT ANOTHER CHARTER OPERATOR FLYING ANOTHER HAWKER 800. UNDER THE CURRENT ADVISORY HE WOULD RECEIVE NO CREDIT FOR THE TRAINING HE JUST RECEIVED AND HAVE TO GO BACK TO INITIAL TRAINING AT FLIGHT SAFETY AGAIN. EVEN IF THE TRAINING PROGRAMS ARE IDENTICAL BETWEEN THE TWO 135 OPERATORS.
THIS GOES AGAINST THE SPIRIT AND INTENT OF THE FAA'S MANDATE TO OVERSEE COMMERCIAL OPERATIONS AND PUTS AN UNDUE BURDEN ON THE OPERATOR WITH NO RESULTING INCREASE IN AVIATION SAFETY. WHEN TRAINING PROGRAMS ARE IDENTICAL COMMON SENSE WOULD CALL FOR THE TRAINING TO BE ACCEPTABLE UNDER CERTAIN CONDITIONS AND REQUIREMENTS. I.E. IF AN OPERATOR ASSURED THE TRAINING PROGRAMS ARE IDENTICAL AND A SIDE BY COMPARISON IS DONE BETWEEN THE TWO TRAINING PROGRAMS TO SHOW THIS AND RETRAINING IS ACCOMPLISHED WHERE THERE ARE SLIGHT DIFFERENCES A WELL TRAINED PILOT WOULD BE THE RESULT WHICH IS THE INTENT, OF COURSE.
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Bradford Cole Public SubmissionPosted: 02/14/2012
ID: FAA-2011-1397-0024
Bradford Cole
This is comment on Notice
Clarification of Policy Regarding Approved Training Programs; Correction
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Public Submission Posted: 02/14/2012 ID: FAA-2011-1397-0024
Feb 27,2012 11:59 PM ET