**Question (Updated March 2008):** No standards are set as to the number
of Training Center Evaluators (TCEs) that may act as contract check
airmen for an operator. Some Principle Operations Inspectors have set a
low number that limits the ability to schedule training.

**Response:** There are two separate issues raised by this question. The
first concerns standards for the number of contract check airman that
POIs will or may authorize for their particular operator and the second
concerns scheduling of center personnel.

First Issue---The policy divisions within the FAA do not believe it is
in the public interest to provide formulas that determine or set
arbitrary figures on the number of check airman the operator's POI may
authorize. Current regulations require air operators to "...have
sufficient qualified management and technical personnel to ensure the
highest degree of safety in its operations." In this context guidance
does not limit the number of check airman that an operator may qualify
and train in support of their operations. FSIMS Order 8900.1 outlines in
detail the training required, and training that may be credited, toward
meeting the requirements of certain operating rules.

From a policy perspective we are not inclined to establish, nor in any
artificial way limit, the POI's ability to manage a particular
certificate holder's capability to comply with current regulations
including the training, qualification, and continued surveillance of
their authorized check airmen. We are, however, providing guidelines
concerning the variable elements that should be considered when
evaluating an operator's request for check airmen. For example:

1.  \- The kind of operation, and the number and type of airplanes used;

    \- The area of operation, and the crewing ratios and geographical
    distribution;

    \- Number and type of evaluations expected;

    \- How does the operator structure their evaluations;

    \- Crew turnover ratios, and the projected initial, upgrade, and
    recurrent workload;

    \- Accessibility of appropriate training facilities;

    \- Calendar timing of evaluations; and

    \- Any other factors the POI and operator deem appropriate.

The overriding issue remains the quality and currency of the operator's
check airmen. In their capacity as evaluators, check airmen are
representatives of the Administrator and are an operator's first line of
quality control. To arbitrarily establish a formula, in the name of
standardization, that determines the quantity of check airmen without
consideration of their primary function would not enhance the overall
quality of training or flight safety.

Second Issue---Although the scheduling of training seems to be an
instructor rather than a contract check airman issue, it's assumed the
reference to training includes evaluation modules. The issue of how a
center manages its employees is not an appropriate issue for the FAA to
comment upon.

**Question (Updated March 2008):** Are standards set as to TCE training
records that must be made available to operators.

**Response:** The following response assumes your question is referring
to an operator who wishes to use the services of a center TCE as a
contract check airman. FSIMS Order 8900.1 is very clear concerning the
procedures to be followed for the appointment of check airmen. If a
Training Center does not wish to have their TCEs act for or on behalf of
an operator as a contract check airman, then no record requirements
exist for this purpose. If a Training Center chooses to permit their
TCEs to act as contract check airmen for an operator and to also take
credit for a portion of their TCE training to meet the contract check
airman training requirements of the operator, then the center is obliged
to provide whatever documentation the operator requires to justify
crediting the TCE's part 142 training and qualification to be a contract
check airmen. Operators must provide their POI with sufficient
documentation to enable the POI to review the nominee's background,
qualifications, and training in order for them to appoint an individual
as a contract check airman. Again, if no credit is being requested for
the training that the TCE received from the center as part of his/her
appointment as a TCE, then no records would be required by the operator
since the operator would be completing all of the required training.

**Question (Updated March 2008):** Regarding multiple centers for the
same aircraft type, some Principle Operations Inspectors believe that
current guidance requires an operator to designate only one contract
training provider in training specification A0-3.

**Response:** FSIMS 8900.1 cautions POIs about the inherent difficulties
and additional surveillance required when an operator requests to have
their training curriculum conducted by two different providers. If the
POI has reason to believe that multiple centers can provide the quality
training required by the operator's approved curriculum, they may
authorize two or more facilities to conduct the subject training.
However, if a POI suspects that an operator's curriculum cannot be
adequately presented at multiple centers due to differing courseware,
FTDs, simulators, etc., and/or the operator may not have the ability to
adequately monitor their training, the POI has the
[responsibility]{.underline} to limit such training. Operator and/or FAA
surveillance workload may also play a role in the decision concerning
multiple training locations.

**Question (Updated March 2008):** Two (2) aircraft type limit for
TCEs---Under what circumstances, could a TCE be authorized to evaluate
in a third aircraft type?

**Response:** This issue is currently being reviewed. Future policy
and/or rule making will more clearly define make/model/series as it
relates to aircraft manufactured by the same company. For example,
although the Learjet family shares a common type rating across the
family, the difference between the various series is significant. The
Lear-25 and 55 may carry the same type rating; however, they are vastly
different series.

**Question (Updated March 2008):** Visa requirements for foreign part
142 training center students. What is the role of the FAA with regard to
the immigration status of foreign pilots enrolled in part 142 training
centers?

**Response:** The agency's role is not one of an immigrations officer.
The FAA does not set or regulate the Government's policies or procedures
relating to visa requirements. Our obligation extends only to verifying
an individual's identity and the reporting of suspicious situations to
local authorities. It is the center's responsibility to comply with
applicable immigration and TSA requirements. TSA requirements may be
found in 49 CFR part 1552- Flight schools.

**Question (Updated March 2008):** Is there an FAA initiative to create
a simulator PTS for ATP and type ratings?

**Response:** This issue has been a point of discussion and we currently
are holding discussions on this subject. We are also considering
amending the PTS to provide for simulator-specific standards. We
anticipate those standards to be associated with qualification modules
within approved programs. Tasks which might be allowed to defer to an
approved qualification module are:

> 1\. Stalls: Type-specific stall scenarios, in operational conditions
> (high cruise with auto-throttle roll back, low speed maneuvering in a
> traffic pattern),
>
> 2\. Approaches: FMS LNAV/VNAV approach operations in lieu of VOR, NDB,
> LOC, LOC B/C, etc., with one conventional non-precision approaches
> using raw data as an "abnormal."

Any comments you may wish to offer would be welcomed.

**Question (Updated March 2008):** Certain modifications and
improvements are required to make IACRA more user friendly for part 142
training centers use (flight time record for an additional aircraft
type).

**Response:** We have made some changes to the IACRA system which will
enable training centers to more fully use it certificating abilities.
Please reference the IACRA website
([http://acra.faa.gov/iacra/]{.underline}) and forward your
suggestion(s). You may also call 1-866-285-4942 and provide comments.

**Question (Updated March 2008):** Steep Turns and Stalls and the CRM
Issue---Not all Training Centers, TCPMs, and Principle Operations
Inspectors agree with the part 142 guidance for these tasks. We need to
re-visit this issue.

**Response:** The current policy concerning steep-turns and stalls and
the participation of the PNF has been revisited on numerous occasions.
The guidance posted on AFS-210's Training Center web site is current and
accurately reflects the FAA's policy on this issue.

**Question (Updated March 2008):** Circling Approach Restrictions and
the 90 degree Rule---Currently all simulator circling approach tasks
must be performed at a visual database that will permit compliance with
the 90 degree rule. This policy restricts the airports used for
practical tests and proficiency checks to a limited number due to the
visual capabilities of visual models used. If all checks are conducted
at the same set of airports, training, testing and checking become too
predictable, and the full training value of a simulator may be lost.
What alternative could be proposed?

**Response**: We do not view this issue as restrictive. There are
numerous possibilities for the entry into the circling maneuver.
Additionally there are no restrictions on the number of visual models
that can be approved for a particular centers use.

**Question (Updated March 2008):** FAR Part 142, §142.65, Use of Takeoff
Reset---We need to discuss the restriction of the use of takeoff reset
during testing and checking.

**Response:** Takeoff reset may be used anytime the simulator is on the
ground and the instructor or evaluator wishes to position the simulator
for the next departure. The prohibition on using the simulators slew or
reposting modes does not apply to setting the simulator up for second
and subsequent departures during training or checking events. (See
AFS-210 Training Center web site)

**Question (Updated March 2008):** Is Land and Hold Short (LAHSO)
Training required for ATP or type rating by FSGA-99-02A?

**Response:** LAHSO is required to be trained, but there is no
requirement to accomplish the maneuver during a certification or
proficiency evaluation.

**Question (Updated March 2008):** The standards for Instructor
Standardization Training for part 121 carriers should not exceed the 16
hour base. (Basic Indoc???) (PAIFA)

**Response:** Hourly limits or mandatory hours for such training miss
the objective. FSIMS 8900.1 requires training to qualify a center's
flight instructors to train an air carrier's curriculum. AFS-210 has
developed a job aid for operators and POIs to use when evaluating the
amount of training a centers instructor must complete to meet the
minimum requirements of the appropriate operating rule.

**Question (Updated March 2008):** Crew/individual oral exams---Some
training centers have received TCPM guidance that requires that separate
oral exams be conducted even though two applicants have trained together
as a crew, and are being tested as a crew for the type rating. FAA Order
8900.1 guidance does permit this.

**Response:** The objective of an oral evaluation is to determine an
individual's knowledge, not the knowledge of the crew. The fact that
individuals are being trained and flight-tested as a crew is really not
pertinent to the issue. The demonstration of knowledge pertaining to the
certificate being sought is not a crew event. Additionally, it is the
responsibility of the evaluator to determine that the "individual" has
the knowledge required to support the skills necessary to satisfactorily
complete the flight portion of the subject evaluation.