Damon Danneker - NATA

Addressing Part 135 Training Concerns-Standardized Aircraft Training RequirementsJune 12, 20102Damon Danneker- Director of Operations, JFI JetsNATA 135 Committee

2008 – POI requested change to my initiallyapproved training program.◦ Would no longer accept credit for previous aircrafttraining.◦ Would no longer accept training not done under myprogram. 5/2009 - Process of successive challenges led allthe way to Washington. AFS-200 1/2010 – John Allen, AFS-1, promised guidanceby 2/2010.THERE IS STILL NO DEFINITIVE GUIDANCE ON THISSUBJECT.Air Charter Summit - June 12, 2012

AFS -200 – Air Transportation Division◦ AFS-210 – Air Carrier Training and 142 TrainingCenter Branch◦ They write guidance to bridge the gap between theregulations and practice. Principal Operation Inspectors (POI) Training Center Program Managers (TCPM)Air Charter Summit - June 12, 2012

Operator –◦ Clear concise training curriculums that can be easilyintegrated into a part 142 environment◦ Utilize contract pilots◦ Reduce redundant training costs FAA – AFS 200◦ Ensure the law is being followed◦ Empower POIs/TCPMs to be able to make practicaldecisions at the local level.• Due to the dynamic nature of Part 135 details are left vague onpurpose in order to facilitate a body of law that coversHelicopters to G550The system requires us to use common sense tosolve the range of training possibilities.V3, CH19, S6, P3-1230GAir Charter Summit - June 12, 2012

FAR Part 135 Subpart H◦ 135.323 – General◦ 135.325 – Initial and Final Approval◦ 135.335 – Use of Simulators◦ 135.324 – Use of Part 142 Unlike Part 121, Part135 Training Regulationsare silent on basic minimum standards◦ No regulations for programmed hours unlike part121.Air Charter Summit - June 12, 2012

Part 135 is not 121 1Order 8900.1◦ Training Hours are Planned not Programmed Minimum INH standard is to complete allmaneuvers and procedures 2 Multiple Curriculums can be developed 31 V3, CH19, S6, P3-12302 V3, CH19, S6, P3-1245, Table 3-623 V3, CH19, S1, P3-1077EAir Charter Summit - June 12, 2012

A “Clarification of Policy” request forcomment was made in 12/2011 by the FAA.◦ Part 135 Training Program Review:Training/Checking Credit It clarified nothing (and is still under review):◦ No standard for aircraft training hours◦ “credit” is now “reduced”◦ Re-packages guidance already found in order 8900.Air Charter Summit - June 12, 2012

Training Curriculums - -◦ MUST BE ACCEPTABLE TO THE OPERATOR’S POI◦ THERE IS NO NATIONAL STANDARD• Guidance says that the AFS-200 should already havethese other curriculums for standardization purposes.V3, CH19, S5, P3-1200A(2)Air Charter Summit - June 12, 2012

Pilot must go through your training program. Clarification from AFS-200 is that theregulations do not permit giving credit fortraining or checking given by anotheroperator. More scrutiny on other training issues◦ Common sense solutions are being thrown out.Air Charter Summit - June 12, 2012

Financial◦ Very difficult to add airplanes to certificate.• Increased cost in money and time◦ Contract Pilots◦ Inordinate amount of time spent on subject• 2008 to Present (4 years)• Missing training improvement opportunities Safety◦ Pushes flight training to the airplane.Air Charter Summit - June 12, 2012

Own your training program!◦ There are differences….• Operators,• Part 142 Training Providers, and• Contract Flight InstructorsAir Charter Summit - June 12, 2012