90 Arrival Ave, Suite 20-LI MacArt hur Airport- Ronkonkoma, NY 11779

631-737-4430 / 800-516-4430 Fax 631-737-2093

www.naac.com 

### December 10, 2012

North American Air Charter petition for an exemption from

FAA N8900.197 Part 135 Training Program Review: Training/Checking Credit



### Dear Sirs:

The undersigned, on behalf of North American Air Charter, Inc. (“North American”)

hereby seeks to petition FAA for relief from National Policy letter 8900.197 in order to

utilize flight crewmembers in its flight operations after receiving aircraft ground and

flight training as described herein.

Background

As you know, National Policy Notice 8900.197 pr oscribes any FAR 135 operator from

accepting training and/or evaluations previously completed by a crewmember while that

crewmember was in the employment of another certificate holder. N8900.197 goes on to

state that: “Regulations do not permit a certificate holder to take credit for training and

evaluations conducted in accordance with another certificate holder’s approved training

program. Section 135.324 identifies what entities may conduct training, testing, and checking

of a certificate holder’s crewmembers. Trai ning, testing, and checking must only be

conducted by the certificate holder, another certificate holder (certificated under part 135)

under contract, or a training center (certificated under part 142) under contract. The

contractor must conduct all training, testing, and checking in accordance with the

contracting certificate holder’s approved training program”.

The FAA has taken the unusual step of including this National Policy Notice in the Federal

Register, in which FAA describes 

### Credit for Previous Qualification as an “ Erroneous

practice of accepting documentation or certifica tion that a crewmember has satisfactorily

completed ground and/or flight training and/or an evaluation while in the employment of

another part 135 certificate holder as meeting the requirements of the hiring certificate

holder’s training program”

Since the FAA has now taken the position that National Policy contained in N8900.197 is

regulatory in nature and so determined that credit for previous qualification is contrary to

FAR 135.324, North American is now seeking relief from this National Policy by allowing

credit for previous training for those crewmember s that have received aircraft specific ground

and flight training at a FAR 142 provider that North American has training arrangements in

place with. North American believes that this procedure is in full alignment with FAR

135.324. North American notes that the comments received in Docket 

### No. FAA-2011-1397

(which brought FAA N8900.197 up for comment) supported the position that FAA has

incorrectly interpreted FAR 135.324 and that the practice of granting training credit was not



### contrary to the regulatory inte nt of the regulation. Commente rs further stated that the

### 2 long established FAA practice of accepting such training was sound in principle and in

alignment with the intent of the regulation. North American notes that the FAA issued

final guidance which rejected most of the pub lic comments that were made. Interestingly,

FAA did so without any proper disposition of th ose comments. This makes it difficult for

the public to identify the reas oning behind FAA’s analysis a nd its move away from its

long established practice with respect to this issue.

FAR Part 135 on-demand operators must follo w the aircraft operating procedures as

designed by the manufacturer and the guidance in FAA handbook 8900.10. The aircraft

specific ground and flight training admini stered by the FAR 142 training provider is

therefore essentially identical between operato rs. Minor operator-specific differences are

left to the individual operato rs to include in their “Bas ic Indoctrination” training.

In support of this request, North American states the following:

North American proposes to conduct operations that allow training credit for training

received from an employee while employed fo r another operator within the following

guidelines:

1) North American seeks to utilize and allow cred it for the aircraft specific flight and

ground training that takes place at one of the Part 142 training centers that it has

contractual arrangements with, even though the training that credit that is being

sought may have taken place on behalf of another operator.

2) North American is not seeking credit for training evaluations under FAR 135.293

(a) 1, 4-8, (checkrides), and will conduct its own evaluation(s) under FAR Parts

135.293 (a) 1, 4-8. Evaluation under FAR parts 135.293(a) 1, 4-8, and the route

check under FAR 135.299 will examine operator specific areas very closely.

North American has no inte rest in utilizing a ny pilot that has not been thoroughly

evaluated by its own Check Airman as described.

3) Each Flight Crewmember that is granted credit for aircraft specific flight and

ground training received at a Part 142 tr aining center on behalf of another

operator will have successfully completed (and have been evaluated) the entire

North American Air Charter basic indoctr ination training program prior to the

allowing of any training credit.

4) The Pilot Record Improvement Act (PRIA) request to previous employers will

(when it is fulfilled) contain all of the in formation that is necessary to perform a

thorough gap analysis of the training fo r which training credit is being sought.

North American will not grant any equivale nt training credit un less it has first

received the information that is supplied by a PRIA request.

North American relies upon the prior statements of the FAA F light Standards Director to

support its request. In a lett er to FAR 135 operator Air Ru tter dated Janua ry 10, 2010

(attached hereto) FAA Flight Standa rds Director John Allen stated:

“Under certain controlled conditions we do, however, believe that some training,

specifically systems traini ng ... may be creditable.

### 3 For one operator to accep t the training conducted under another operator’s approved

curriculum, without first conducting a side-by- side comparison designed to identify the

differences between curriculums, is not c onsistent with sound operating practices”.

It is precisely the intent of North American to act within the limitations as stated by Mr.

Allen.

Industry Support

The comments and arguments already set forth by The National Business Aircraft

Association as well as the National Air Transportation Association (attached hereto)

accurately reflect industry posi tions with respect to N8900.197. For the sake of brevity,

those statements are not repeated here as they are already posted to docket number FAA2011-1397.

Public Interest

Approval of North American’s proposed tr aining operations would be in the public

interest. It is a generally accep ted fact that the use of fli ght simulator based aircraft

training is an asset to flight safety. Statistical analysis reveals that those that engage in

this training are less likely to be involved in an aircraft accident. This use of vendor

training serves to continually improve th e safety record of the Part 135 on-demand

operators, and as such should be embraced by the FAA in the quest to improve safety.

The establishment of any FAA policy which is likely to discourage the use of simulator

based aircraft training in any way whatsoever is contrary to the public interest. The

unintended consequence of N 8900.197 is to encourage oper ators to conduct aircraft

specific training on an in house basis in lieu of utilizing si mulator based training at a 142

provider, which is generally regarded to be less far less effective.

Economic Impact

The economic impact of this policy is substant ial. For a 135 operator to provide simulator

based training in the initial category for a si ngle pilot, the cost is approximately $35,000

per training event. The cost varies with the type of aircraft and or the 142 vendor that is

utilized, however large cabin class business airc raft are all within this cost range. Another

negative consequence is the lack of availa bility of qualified p ilots to choose from.

Independent free-lance pilots that are 135 qualified are no longer available within

constraints outlined in National Policy 8900.197. Operators that once had the freedom to

choose from a pool of FAR 135 qualified contra ct pilots no longer have this option. The

result is less on demand FAR 135 flyi ng, imposing additional strain on FAR 135

operators. The implementation of N8900.197 will also result in duplicative training and

excessive costs; neither of which will serve to improve safety.

To the extent the FAA deems this request a petition for exemption, North American

hereby requests that it be included Federal Register for publication.

Should the FAA have any questi ons regarding any aspect of this request for approval to

conduct Part 135 flight operations as described, please contact the undersigned.

### 4 Very truly yours,

Jonathan D. Ross

Director of Operations

(800) 516-4430

jonr@naac.com

### October 19, 2007

Mr. Richard Johnson

Swanson & Johnson PLLC

1906 S. Vista Avenue, Suite A

Boise, ID 83705

Dear Mr. Johnson:

This is in response to your June 16, 2007, in quiry, submitted on behalf of your client,

Aviation Specialties Unlimited, Inc., in which you seek an interpretation of 14 C.F.R.

§135.324, as it applies to the Night Vision Goggl e (NVG) guidance recently set forth in

Notice 8000.349, Appendix 1, § 1606(C)(2). In part, you quote the language in Appendix 1,

§1606 C(2), which states that a carrier that:

does not hold an operating certificate and Op Specs for the same type of

operation for which training is provided, or does not hold a part 142 training

center certificate, with approved courses applicable to the training provided,

must be qualified as a pilot and fli ght instructor for operations by the

certificate holder [to provide NVG training]. (emphasis added).

You ask whether this language re quires that your client enga ge in part 135 air ambulance

operations in order to provide NVG training to other part 135 air ambulance operators.

Because of the performance limitations that NVGs have on a pilot’s visual cues, Notice

8000.349 set forth a separate process for verify ing part 135 operators conducting operations

using NVGs, and for Part 135 operators providi ng NVG training. In regard to training, all

part 135 operators must meet the requireme nts of 14 C.F.R. § 135.324 in order to conduct

flight training. The language from the Notice, as quoted above, should not be read to limit

part 135 operators to training only other part 135 operators engaged in identical commercial

service. Rather, the Notice should be read as giving guidance to FAA inspectors on the

circumstances in which the FAA would allow Part 135 operators with the same type of

operation specifications, either on-demand or commuter, to tr ain another Part 135 operator

with the same type of opera tion specifications, either on-de mand or commuter. When the

entire Notice is read in contex t, an important piece of guidance to our inspectors is that they

should ensure that any NVG training in an air borne aircraft is administered by an NVG

instructor who is qualified to fly that particular aircraft, and whose pr incipal employer also

operates the same type of aircraft. For exampl e, if ASU, Inc., is certified as a Part 135 ondemand operator, flying a Bell -206 Helicopter, and its prin cipal operations inspector has

approved its use of NVGs in its operations, as well as its NVG training program, the FAA

would allow an FAA principal oper ations inspector for another part 135 operator to consider2

approving ASU, Inc., to provide NVG training to that other Part 135 on-demand operator

that also flies Bell-206 Helicopters. The guidance provided in the Notice, which states that

an air carrier must comply with § 135.324, is thus consistent with § 135.324, as well as

additional guidance set forth in FAA Order 8900.10, vo1.3, ch. 20, § 1, para. 3-1399 (Sept.

13, 2007), which states that an air transportation flight instructor must "hold the certificate

and ratings required to serve in revenue service in the specified crewmember duty position

on the specific aircraft (emphasis added)," in order to be eligible to conduct training.

We appreciate your patience and trust that the above responds your concerns. If you have

any questions, please contact my staff at (202) 267-3073. This response was prepared by

Anne Bechdolt, Attorney, reviewed by Joseph Conte, Manager, Operations Law Branch of

the Office of the Chief Counsel, and coordinated with the Air Transportation Division of

Flight Standards Service.

Sincerely,February 27 , 2012

Docket Operations

M

- 30

U.S. Department of Transportation (DOT)

1200 New Jersey Avenue, SE

Room W12

- 140

West Building Ground Floor

Washington, DC 20590

- 0001

R e : Docket No. FAA

- 201 1

- 139 7, Clarification of Policy Regarding Approved Training Programs

The National Business Aviation Association (NBAA) represents the aviation interests of over 8 ,000

Member companies that use business aircraft to support their company t ravel needs. Many Part 135

o perators are NBAA Members and we appreciate the opportunity to offer these comments to the FAA’s

draft notice

.

NBAA appreciates the FAA’s work to clarify expectations of Part 135 operators in this area. We agree that

Part 135 operators are required by FAA regulations to train and check crewmembers in accordance with

the operator’s approved training program and that t he operator has the responsibility to ensure that each

individual is proficient and fully qualified in the certif icate holder’s operations and procedures prior to

authorizing the individual to operate as a required crewmember. We also agree that an operator’ s training

program should be permitted to have multiple “tracks” that exist to take into consideration an indiv idual’s

prior experience, while ensuring that they receive the necessary operator

- specific training, relevant

differences training, and required checking to ensure qualification and proficiency.

Various interpretations of the rules by operators and local FAA inspectors have brought us to a point

where some operator’s approved programs erroneously provide complete credit for previous training and

checking conducted under another Part 135 certificate holder’s program. Conversely, other interpretations

requir e operators to put individuals who have significant experience in a given aircraft type that he or she

will continue to fly for the “new” certificate holder through a complete initial training course for the aircraft.

We consider these examples to be the e nds of the spectrum, neither of which is fully consistent with what

the FAA’s regulations actually dictate to and policy actually expects of Part 135 operators.

Feedback received from Part 135 operators about this notice shows that there are two groups of

operators. The first group does not consider this draft notice as a change in policy. They have not

accepted previous training and checking and view the draft notice as a clarification of existing FAA HQ

expectations. The second group of operators views t he draft notice and previous FSDO notices to

operators as a change in FAA policy. These operators have accepted training and/or checking from

previous employers of the pilots with the full knowledge and approval of their POIs.

We highlight this point to ensure that the FAA is aware of the significant differences in the interpretations

of the existing requirements. A coordinated widespread education effort will be needed to bring resolution

to this issue to the inspector work force and operator community.

It is NBAA’s position that p revious Part 142 training received pursuant to another training program can

safely be accepted as the basis of reducing that pilot’s training requirements. For example, i f an individual

has significant experience in a given air craft make and model moves from one certificate holder to

another, the training program of the latter operator ought to allow a reduction in training required

co nside r ing the previous training experience of the individual, but that company

- specific items ( i.e.

checklists and callouts) need to be covered through differences training and then checked.Page 2 Many Part 135 operator s develop t heir training program by starting with a Part 142 Training Center’s

approved curriculum. In many cases, those curriculums don’t currently have provisions for reduced

training hours for prior experience and/or training. NBAA is of the opinion that a concerted outreach to the

Part 142 Training Centers is a necessary step in the FAA’s efforts to resolve this is sue. Encouraging 142

Training Centers to build reduced training “tracks” in the curricula and advising them that operators need

to be permitted to check a crewmember at any point through the training program for knowledge and

proficiency , should be a part of that outreach. Ultimately, t he onus to ensure the crewmember has the

required knowledge and proficiency still lies on the Part 135 certificate holder.

It is common in the Part 135 industry for crewmembers to fly for more than one operator over the cou rse

of one’s career. Sometimes a crewmember intentionally qualifies to fly for more than one Part 135

operator at a time , which is generally unique from crewmembers in Part 121 operations. A contract pilot is

one example of this scenario. Contract pilots p lay an important role in the Part 135 industry. The needs of

contract pilots, i.e. checking for multiple Part 135 operators during a training event, can be somewhat

different than a crewmember permanently switching from one certificate holder to another. C ontract pilots

should be permitted to complete “back

- to

- back” check rides to receive an 8410 for each operator.

V ery clear FAA guidance to operators and inspectors that leaves no room for interpretation is the only

way to truly resolve this issue. A table specifying the specific training modules that still need to be

included in a reduced training program “track” should be included in the final version of the notice. While

specifying minimum hourly training requirements in the guidance may be easier to sta ndardize among

POIs, operators would prefer that the guidance specify required training subjects/modules in an effort to

improve the quality of the training.

NBAA offers the following as s pecific suggestions to incorporate in the final version of the notice:

• The guidance should include descriptions of acceptable and not acceptable practices with

respe ct to reduced training curriculum “tracks

. ”

• The guidance should make clear that check rides from prior operators can not be accepted,

since there is no provision in the regulations to accept training or checking, only experience.

• The guidance should make clear that all operator

- specific items must be trained and

checked.

• The guidance should recommend that the new operator document that the training received

from the previous operator has covered the subject matter required by their FAA Approved

Training Pr ogram in order to reduce the training requirement.

• The guidance should recommend that operators include reduced training table in their FAA

Approved Training Manual, and that the table is based on guidance from FAA.

• The guidance should address a scenario w here an individual’s previous training experience

was received from the same Part 142 T raining C enter

- provided program and where both

operators use the same Part 142 Training Center check airman.

• The guidance should also address what training experience ca n be considered when a

crewmember switch es from an operator t h a t use s one Part 142 training center to another

operator t h a t has its training program based on a completely different Part 142 training

center ’s approved curriculum

.

• T he guidance also needs to a ddress training experience received from non

- Part 142 Training

Center providers.

Thank you for the opportunity to submit these comments. Please contact us if we can provide any

additional information.Page 3 Sincerely,

Douglas Carr

Vice President

Safety, Security & RegulationFebruary 27, 2012

Docket Operations, M

‐ 30

U.S. Department of Transportation

1200 New Jersey Avenue, SE

Room W12

‐ 140, West Building Ground Floor

Washington, DC 20590

‐ 0001

Delivered electronically via www.regulations.gov

RE: D OCKET N O

. FAA

‐ 2011

‐ 1397, C LARIFICATION OF P OLICY R EGARDING A PPROVED T RAINING

P ROGRAMS

The National Air Transportation Association (NATA), the voice of aviation business, is the

public policy group representing the interests of aviation businesses before Congress, federal

agencies and state governments. NATA’s 2,000 member companies own, operate, and service

aircraft. These companies provide for the needs of the traveling public by offering services and

products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales,

storage, rental, airline servicing, flight training, Part 135 on

‐ demand air charter, fractional

aircraft program management and scheduled commuter operations in smaller aircraft. NATA

members are a vital link in the aviation industry providing services to the general public,

airlines, general aviation, and the military.

We commend the Federal Aviation Administration (FAA) for issuing this guidance in a draft

format and accepting comments. Overall, while NATA believes that the proposed notice

provides much needed clarity and is a good step toward ensuring consistency for training and

evaluation of newly hired crewmembers at Part 135 on

‐ demand operators, there are areas where

further information and guidance is necessary.

Recognition of Prior Approval

The key issue the draft notice addresses is the appropriateness of training programs that include

the ability for an air carrier hiring a new pilot to obtain “credit” for prior training and/or

evaluations conducted by a different Part 135 certificate holder, thereby reducing the training

and evaluations that must be conducted by the hiring carrier prior to placing a pilot into service.

The agency establishes that provisions permitting such credit are contrary to the regulatory

requirements. NATA appreciates that the FAA acknowledges that, despite the fact that

programs providing for a transfer or credit for prior training and checking are now deemed

inconsistent with current training program policy, numerous FAA Principal Operations

Inspectors (POI) have authorized programs with these elements for hundreds of operators.

Timeline

The efforts and timeline described in the notice to rectify the situation appear to be reasonable.

Specifically, following a POI’s review of an operator’s program if the POI determines revisions

are necessary, the FAA intends to permit operators up to 12 months to revise and re

‐ submit theComments of the National Air Transportation Association on Docket No. FAA

‐ 2011

‐ 1397, Clarification of Policy

Regarding Approved Training Programs

February 27, 2012

Page 2 of 5

training programs for approval. NATA believes this is a fair amount of time for operators to

respond.

Retraining Not Required

NATA appreciates the FAA affirmatively stating that retraining of affected crewmembers is not

generally required. Given that the training programs now in question were specifically

approved by inspectors nationwide and were used for the training of hundreds or perhaps

thousands of pilots, many of who have subsequently received other training (e.g. recurrent)

with the certificate holder, it would be inappropriate to call into question their legal status as

crewmembers.

Planned v. Programmed

Another point of emphasis in the draft notice is the distinction between “planned” and

“programmed” hours. NATA believes the reiteration that Part 135 training programs are based

upon planned hours (not the Part 121 fixed “programmed” hours standard) is key to

understanding the flexibility not only for the reduced hour training program outlined by the

agency notice, but is also an important point for inspectors and Part 135 operators in general.

Operators often have reported to NATA that their POI is demanding certain minimum hours of

training be completed. As stated in the notice, the Part 135 training standard is that the

proficiency and knowledge of a crewmember is certified (by the instructor/supervisor/check

airman) upon completion of the required training or evaluation.

Reduced Hour Training Curriculum

The Reduced Training Hour Curriculum (RTHC) articulated in the notice is an important

element for the industry and, while other guidance has alluded to the potential for such

programs, having this ability specifically articulated is welcome. In developing a reduced

training hour program, NATA believes it will benefit both industry and inspectors for there to

be a clear understanding of what potential maximum reduction in training hours could be

achieved, given the appropriate entry prerequisites.

NATA believes that the minimum baseline for a new hire crewmember should be defined

within the guidance to ensure that approval of RTHCs is consistent nationwide. It would be a

disservice to the industry for operators to devote the time and resources to creating a RTHC

consistent with programs approved for similar carriers only to have their POI reject the

program over a personal belief that the reduction is “too much.” A lack of a clear maximum

reduction policy could easily lead the agency and industry to the point we are at now

–

inconsistent application of training program requirements that necessitates yet another national

level review and new guidance.Comments of the National Air Transportation Association on Docket No. FAA

‐ 2011

‐ 1397, Clarification of Policy

Regarding Approved Training Programs

February 27, 2012

Page 3 of 5

NATA suggests that for a well

‐ qualified crewmember (e.g., current and qualified in the aircraft,

in the duty position desired, with current comparable Part 135 experience) the RTHC would

include training in all the certificate holder

‐ specific modules (i.e., basic indoctrination,

HAZMAT, etc.) all written tests and performance of the required evaluation/checks, but that

additional hours of instruction (ground or flight) would not be a required element for the

RTHC. In the event of a failure of a test/evaluation the operator’s existing program

requirements for requalification would be followed.

Further, NATA recommends that the FAA indicate that there is no maximum number of RTHCs

that an operator could have approved. NATA anticipates that many operators may have three

to four RTHC’s. To ensure this is clear and to help POIs anticipate potential programs they may

be asked to approve, NATA suggests that the FAA include a list of “possible” curriculums that

an operator may submit. This list could include, among other examples:

1. New crewmember with previous Part 135/Part 91K experience in the same duty

position, without previous aircraft experience

2. New crewmember without previous Part 135/Part 91K experience, with previous

experience in the aircraft to which the crewmember will be assigned

3. New crewmember with previous Part 135/91K experience, without previous experience

in the aircraft to which the crewmember will be assigned.

For the purposes of establishing eligibility prerequisites for entry to a particular RTHC, NATA

believes that the similarities in operational regulations between Part 135 and Part 91K are

sufficient to allow either to serve as suitable experience for entry to an RTHC and requests that

the FAA so state in the final notice.

Gap Analysis Based Option

NATA also recommends that the FAA include provisions for a “gap analysis”

‐ based program

for operators. A letter to a Part 135 operator dated January 28, 2010, and signed by Director,

Flight Standards Service John Allen, states that a side

‐ by

‐ side comparison between two

programs, could allow for some prior training to be accepted by a new employer.

Under certain controlled conditions we do, however, believe that some training, specifically

systems training

... may be creditable.

For one operator to accept the training conducted under another operator’s approved curriculum,

without first conducting a side

‐ by

‐ side comparison designed to identify the differences between

curriculums, is not consistent with sound operating practices.Comments of the National Air Transportation Association on Docket No. FAA

‐ 2011

‐ 1397, Clarification of Policy

Regarding Approved Training Programs

February 27, 2012

Page 4 of 5

The statements in that letter, attached herewith, establish that, in circumstances where a true

side

‐ by

‐ side gap analysis can occur, indeed there could be additional leeway granted to the

hiring carrier with regard to what specific training, testing and evaluations are required for a

new hire pilot.

If a current or prior carrier provides its training program to the hiring carrier, a gap analysis

could be performed that would permit the meaningful comparison described in Mr. Allen’s

letter to occur. In such a program, the necessary differences training could be determined and

provided to the crewmember. The hiring air carrier would still need to complete the required

training that is not eligible for reduction as well as flight evaluations/checks with the

crewmember.

One of the biggest potential economic impacts posed by this action is on the so

‐ called contract

pilot who may work for multiple air carriers on an ad hoc basis. Utilization of a contract pilot

by a Part 135 operator requires substantial coordination with other carriers for whom the pilot

works to ensure compliance with numerous regulations, such as total commercial flight hour

limits among others. In these work arrangements, the carriers are already engaged in

communications, and it is not unreasonable to believe that they would be willing to share their

training programs with each other to ensure that the contract pilot is properly training and able

to continue working for each operator. The benefit of such a program was acknowledged by

Mr. Allen in his 2010 letter and should be incorporated into the final notice. This approach to

analyzing training between operators could, and should, also be extended to other training

events (i.e., recurrent) to continue to permit what has been a successful and safe employment

choice for some pilots.

Negative Consequence Possible

An area of concern for NATA is that the FAA may not have fully considered a significant, and

likely unintended, consequence of the training program changes required by the notice. From a

regulatory standpoint, simulator

‐ based training for Part 135 is optional. It is highly likely that

some number of operators will conduct training and/or evaluations in the aircraft rather than in

a simulator as a result of this FAA notice. For economic reasons or because a training center

may not elect to provide a particular service, there may well be some movement away from

simulator

‐ based training and checking. This would be unfortunate and certainly not the

agency’s goal.

The value of simulation

‐ based training is well

‐ known and the FAA must use caution as it

proceeds in this area. Part 135 pilots will likely work for several air carriers, far more than their

Part 121 counterparts, during their career. This movement within the industry means that a Part

135 pilot will be subject to many initial new hire training courses, theoretically all but the firstComments of the National Air Transportation Association on Docket No. FAA

‐ 2011

‐ 1397, Clarification of Policy

Regarding Approved Training Programs

February 27, 2012

Page 5 of 5

reduced in some way, but nonetheless multiple training events will occur where prior to this

notice some credit for prior experience may have been awarded. The potential economic impact

on operators is significant, and for some operators in certain hiring situations it may make more

sense to provide all the training “in house” using the aircraft, forgoing simulation altogether

until perhaps the pilot is due for recurrent. NATA urges caution and careful consideration

when the FAA imposes new mandates on the industry that could have the consequence of

driving operators away from simulation for training and checking events.

The relationship between operator, POI, training centers and their TCPMs is elaborate and at

times unnecessarily burdensome for all involved. In 2011, NATA participated in an FAA

‐

chartered Aviation Rulemaking Committee 1 that recommended the FAA review the relationship

between Part 135 carriers and the Part 142 training centers. NATA reiterates its support of that

recommendation and encourages the FAA to dedicate the resources necessary to pursue a

meaningful review, with industry participation, that would allow for improvement of these

complex relationships while enhancing the training ultimately provided to crewmembers.

Sincerely,

Jacqueline E. Rosser

Director, Regulatory Affairs

1 The Flightcrew Member Training Hours Requirement Review ARC submitted its final recommendations to the

FAA in May 2011.