The FAA could make the certification of Part 141 pilot schools more efficient by streamlining approval of training courses and dropping requirements for flight standards district offices (FSDOs) to approve training programs previously reviewed by the agency, AOPA said in comments on a draft update to an FAA publication on flight school certification.
AOPA submitted comments on the FAA’s draft advisory circular AC 141-1B, Part 141 Pilot Schools, Application, Certification, and Compliance, the proposed update to a guidance publication that dates to 1993.
The FAA should remove “prescriptive and unnecessary” certification requirements such as approval procedures for training course outlines that have “introduced significant delays” to the course-approval process, AOPA said.
For example, some companies sell FAA-reviewed training syllabi for use in Part 141 training—sparing a flight school from having to create its own syllabus. Under the draft advisory circular, however, FSDOs “are directed to complete ‘the approval process [for commercial syllabi] in the same manner as it would for a syllabus developed and submitted by the school.’”
AOPA recommended that the FAA identify applicable commercially developed training syllabi that have been approved, and allow their use without further FSDO approval.
The FSDO with jurisdiction over a pilot school would still approve the school’s training course outline to ensure that the training institution can comply with it, wrote Justin Barkowski, AOPA director of regulatory affairs.
Similarly, amending a training course outline requires FSDO review—but the draft advisory circular provides no guidance on how that should be accomplished. AOPA recommended that a FSDO approve only each proposed amendment, and to avoid costly delays, “provide for the approval of an amended TCO or syllabus upon notice to the FSDO and a lack of objection after a specified period of time.”
AOPA detailed other FSDO functions that should be eliminated because they either exceed Part 141 requirements or are dealt with by other rules. Among them were the FSDO conducting a flight test inspection before issuing examining authority at the flight school; FSDO examination and approval of simulators and flight training devices; a requirement for the FSDO to administer proficiency and knowledge tests to the chief instructor and assistant chief instructor; the requirement “for the FSDO to verify and check the minimum qualifications of instructors designated or assigned to a Part 141 training course”; and a requirement for the FSDO to ensure that the applicant has access to adequate aircraft maintenance resources and facilities, which imposes burdens not required by Part 141.
AOPA welcomed the FAA’s effort to tackle important questions about pilot training and certification, and stands ready to assist, Barkowski wrote.