6-1 CHAPTER 6. PILOT TRAINING
6.1 New Hire/Initial/Recurrent Pilot Ground and Flight Training. As part of the application package, CHs who wish to obtain OpSpec B048 must (per 14 CFR part 135, § 135.329(e)) include pilot training subjects to support the conditions and limitations stated in OpSpec B048. Similarly, as part of the application package, operators who wish to obtain LOA B048 should include pilot training subjects to support the conditions and limitations stated in LOA B048. (This section applies to both part 91 operators and all CHs, including those who use only one pilot in the CH’s operations.)
6.1.1 Air tour procedures and flight training should be considered part of the normal training program where possible and be conducted in accordance with a separate curriculum segment solely involving air tour operations within the training program. The new hire initial and recurrent (as applicable) pilot ground and flight training should demonstrate that the CH or operator will provide pilots with the necessary knowledge and skills to conduct the commercial air tour flights and should include operations below 1,500 feet, as authorized by OpSpec/LOA B048. If a CH has already incorporated air tour training subjects into their FAA-approved training program, a pilot trained in accordance with such approved training program may receive credit for such training in order to comply with the parameters set forth in the operator’s accepted B048-related operating procedures.
6.1.2 The training subjects should include the following, as it pertains to the authorization given through OpSpec/LOA B048:
1. The manner in which the CH or operator intends to conduct pilot evaluations and observations (every 12 calendar months, with a grace period (§ 135.301(a)) preceding and following the due month);
2. The manner in which the CH or operator intends to train and evaluate their flight instructors;
3. The manner in which the CH or operator intends to conduct pilot training and evaluations, including the procedures utilized on each specific aircraft that considers the flight characteristics of each aircraft; and
4. The manner in which the CH or operator intends to evaluate their pilots on representative KSSAs during recurrent flight evaluations. The flight training prior to recurrent flight evaluations should be detailed in the CH’s or operator’s specific commercial air tour operator approved training subjects.
5. CHs and operators should emphasize the continuous in-flight identification of adequate precautionary and emergency helicopter landing sites, and to minimize flight over areas where such sites may not be available in KSSAs and in transition areas. CHs and operators should provide specific training and checking in such continuous awareness and ability to utilize identified off airport landing sites in the event of an emergency or precautionary off airport landing.
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6.1.3 CHs’ and part 91 operators’ ground training must be conducted by an instructor who is qualified by the CH or the operator to provide ground instruction (refer to § 135.388). In the case of operators and CHs who use only one pilot in their operations, the ground training may be self-taught. A record of the training must be kept and made available to the Administrator upon request.
6.1.4 The hours credited for meeting the minimum hours for ground training, as per the CH’s or operator’s designated training, should be administered by a CH or operator air tour authorized instructor in a formalized classroom format or via web-based training (WBT) that is capable of tracking the pilot’s unique user name and password, online training hours, and final completion scores. Any training conducted online may also be evaluated verbally and documented in the pilot’s training record by a company-approved ground instructor, flight instructor, or the Administrator.
6.1.5 Current and qualified authorized air tour ground and flight instructors may take credit for the ground and/or flight training for which they teach. All instructors should remain current on the latest air tour developments to impart this information to their students.
6.1.6 The Administrator, or a person approved by the Administrator, should perform the ground and flight observations of CHs who use only one pilot in the CH’s operations.
6.1.7 If pilots are currently qualified and operating with a specific CH under OpSpec B048 (HQ Revision: 020) authorization, credit may be given for previous training and observations toward the conditions and limitations set forth under the revised OpSpec B048 (HQ Revision: 030) for continued air tour operations with that same CH or operator. Similarly, for pilots currently qualified and operating with a specific § 91.147 LOA holder under LOA B548 (HQ Revision: 000), credit may be given for previous training and observations toward the conditions and limitations for continued air tour operations with that same LOA holder set forth under the revised LOA B048 (HQ Revision: 030). To receive credit for this training and observation, records of successful completion under the previous authorization and documentation that includes all aspects of the revised authorization given through OpSpec/LOA B048 should be retained for the same period as other training documentation. These records should be available to the Administrator for review and inspection.
6.2 Requalification for Ground and Flight. It is recommended that the CH or operator consider including policy and procedures for recovering currency lapses for pilots that did not complete recurrent training and did not satisfactorily complete an air tour ground and flight observation/evaluation conducted by an authorized air tour observer prior to the end of the 12 calendar month plus grace month term (§ 135.301(a)). If a pilot’s currency, as per the CH’s or operator’s specific approved training curriculum of the CH’s or operator’s accepted operating procedures and of part 136, lapses for any reason as per the CH’s or operator’s set timelines (i.e., 12 calendar months plus the following grace month), they should be requalified. The requalification may depend on how long the pilot has been noncurrent as per the CH’s or operator’s authorized or accepted operational training procedures.
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6.2.1 Consider applying the following range of requalification options. If there is a currency lapse of less than 24 calendar months, requalification may consist of the pilot completing recurrent ground training and satisfactorily completing a recurrent flight observation/evaluation before using the authorization given through OpSpec/LOA B048.
If there is a currency lapse of 24 calendar months or more, the CH or operator may choose to require the pilot to complete all initial qualification training subjects and satisfactorily complete the ground/flight observation required for initial qualification before using the authorization given through OpSpec/LOA B048.
6.3 Aircraft-Specific Training. Ground (G) and flight (F) training, whether this is part of the part 135 approved training program already or, in the case of § 91.147, a new standalone requirement, should specify that each pilot receive training and demonstrate proficiency in the following maneuvers specific to each aircraft the pilot will operate under the authorization:
• Aircraft-specific performance computation (G),
• Aircraft systems (G/F),
• Abnormal and emergency procedures (G/F),
• Autorotation (F),
• Hover autorotation (G/F), and
• IMC recovery procedures (G/F).
6.4 KSSA Familiarization Flights. The pilot training subjects should specify that all pilots complete a CATFP and KSSA familiarization flights for each KSSA that they will be authorized to fly. The familiarization flight should include:
6.4.1 At least two complete CATFP familiarization flights to each authorized KSSA should be done as part of the initial KSSA familiarization process. The familiarization flights should be completed prior to the initial flight observation.
6.4.2 All familiarization flights should be conducted under the direct supervision of a KSSA-qualified instructor, as designated by the CH or operator, or the Administrator.
6.4.3 When a KSSA-qualified instructor is conducting a CATFP familiarization flight, they should occupy a pilot seat and be designated by the CH or operator as PIC of the flight.
6.4.4 Pilots receiving instruction during a KSSA familiarization flight should be the sole manipulator of the aircraft flight controls, unless the KSSA-qualified instructor needs to intervene to maintain safety of flight.
6.4.5 CHs or operators may, at the CH’s or operator’s discretion and per the accepted or approved operating and training procedures, reduce the two initial familiarization flights to one flight if the pilot who is being familiarized has previously received familiarization on the same KSSA with another CH or operator within the past 12 calendar months. (See paragraph 6.7 for records.)
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6.5 Initial or Annual Flight Observations. The training should specify that, after successfully completing all the training as outlined in the CH’s or operator’s specific training approved by the Administrator, each pilot should receive a KSSA flight observation, and the following should be emphasized:
6.5.1 All pilots should have satisfactorily passed a KSSA flight observation since the beginning of the 12th calendar month before that service, within a grace period of one month before and after the due month. This observation should consist of:
• Satisfactory completion of a written or oral test that especially emphasizes preflight and cue-based weather evaluation and aeronautical decision making and B048 conditions and limitations to be observed while conducting air tour operations, and
• Satisfactory completion of a flight observation that includes at least one representative KSSA (subsequent flight observations should include different KSSA locations before repeating observations conducted at previously observed KSSA locations ).
6.5.2 KSSA flight observations should be conducted by the Administrator or a person approved by the Administrator.
6.5.3 Upon satisfactory completion of a KSSA flight observation, all events should be recorded on a CH- or operator-produced form accepted by the Administrator. The recording of tasks, as per the CH’s or operator’s FAA-approved training and FAA-accepted operating procedures, should be completed by the person conducting the flight observation.
Recurrent KSSA flight observations conducted in compliance with OpSpec B048 conditions and limitations should be conducted in the same timeframe as other regulatory checks such as § 135.293. They should also allow for a grace month in accordance with § 135.301(a).
6.6 Instructor Qualifications. The CH’s or operator’s training should specify that the FAA inspector or FAA-authorized air tour operations observation pilot will conduct an initial observation of each CH’s or operator’s air tour operations instructor while the instructor provides training in procedures and maneuvers in accordance with this chapter. The performance of the instructor being observed should be satisfactory before the conditions and limitations are satisfied and the instructor may be accepted as an air tour operations instructor by the FAA.
6.6.1 All pilot training and evaluation records (ground and flight) should be maintained by the holder of OpSpec/LOA B048 for the period of the pilot’s employment, at the CH’s or operator’s principal base of operations as registered on the CH’s or operator’s issued OpSpec/LOA A001.
6.7 Pilot Training and Flight Observation Documentation and Recordkeeping.
6.7.1 Pilot ground and flight training records pertaining to KSSA operations should reflect part 135 pilot training recordkeeping policies and procedures. Specific records for air tour training for each air tour profile should include island-specific unique climatology and
6-5 terrain influence upon the aeronautical decision making required to safely navigate the profile, KSSA entry and exit waypoints, all appropriate types of air tour radio calls, knowledge of landmarks commonly used to describe locations of flight hazards, traffic circulation patterns at KSSAs, etc. The training program should specify that KSSA training and flight observations should be documented and should include the following information:
6.7.1.1 Ground Training:
• Name of pilot receiving training,
• Date of completion,
• Total training hours received, and
• Instructor certification.
6.7.1.2 Initial KSSA Familiarization Flight:
• Name of pilot receiving KSSA familiarization;
• Date of flight;
• Flight time (for each familiarization flight);
• KSSA and Hawaiian island(s) flown;
• Aircraft registration number;
• Name, title, and signature of person providing the KSSA familiarization flight; and
• CH or operator certification.
6.7.1.3 KSSA Flight Observation (CH’s or Operator’s Part 136 Form).
6.7.1.3.1 A statement should be entered in the remarks section indicating the pilot is authorized to operate below 1,500 feet above the surface, in accordance with the OpSpec/LOA B048 conditions and limitations.
6.7.1.3.2 Each CH’s or operator’s recordkeeping system for air tour training and flight observations must comply with the pilot recordkeeping set forth under § 135.63. The FAA recommends that § 91.147 air tour operators follow the same pilot training and checking recordkeeping practices as those required for part 135 CHs.
6.7.2 A ll pilot and instructor training and evaluation records (ground and flight) should be maintained by the CH or operator and holder of OpSpec/LOA B048.
6.8 Training Subjects. Training should specify the following for all pilots conducting commercial air tour flights below 1,500 feet above the surface in the State of Hawaii in
6-6 order to remain in VMC and avoid entering IMC, as authorized through OpSpec/LOA B048 (see Table 6-1, Training Subjects and Standards).
6.8.1 Each CH’s or operator’s part 136 new hire/initial/recurrent training should include training on each of the following subjects:
• Mountain flying techniques and high density altitude;
• Controlled flight into terrain (CFIT) avoidance;
• Performance planning;
• Cue-based, island-specific weather training;
• Go/no-go procedures;
• Operations inside the boundaries of a unit of the NPS under an ATMP, a VA, or an IOA;
• Hawaii commercial air tour accident review;
• KSSAs, entry and exit points and procedures to each KSSA location, radio communications protocol, CTAFs, position reports, and revisions to traffic and CTAF advisory procedures over the past year;
• Operations over water, ditching procedures appropriate to equipment being operated;
• Height velocity diagram and raw terrain descriptions (helicopter only);
• Preflight safety risk analysis and weather factors affecting operations;
• Inclement weather, IMC avoidance, escape, and recovery procedures;
• Successful transition to IFR/IMC, if inclement weather avoidance is unsuccessful followed by recovery offshore or via a published IAP to an airport/runway;
• Aircraft-specific equipment and related IFR limitations;
• Familiarization flights;
• Abnormal and emergency procedures;
• Autorotation; and
• Hover autorotation.
6-7 Table 6-1. Recommended Training Subjects and Standards Module Initial Ground Training (2 Hour Minimum) Initial Flight Training Recurrent Ground Training (1 Hour Minimum) Recurrent Flight Training Initial Flight Observations Recurrent Flight Observations Requalification Ground Flight Mountain Flying Techniques X X X X ** X X X * X * Performance Planning and High Density Altitude Ops X X Oral Oral X * CFIT Avoidance X X Oral Oral X * Cue-Based, Island-Specific Weather Evaluation and Aeronautical Decision Making X X Oral Oral X * Inclement Weather, IMC Avoidance, Escape, and Recovery Procedures X X X X X X X * X * Go/No-Go Procedures X X Oral Oral X * Familiarization Flights X X X X X X X * X * Preflight Safety Risk Analysis and Weather Factors Affecting Operation X X X * Operations Inside the Boundaries of a Unit of the NPS Under an ATMP, a VA, or an IOA X X X X ** X X X * X * Hawaii Commercial Air Tour Accident Review X X Oral Oral X * KSSAs, Entry and Exit Points and Procedures to Each KSSA Location, Radio Communications Protocol, CTAF, and Position Reports X At least 1 rep site X X ** X At least 1 rep site X At least 1 rep site X * At least 1 rep site * Operations Over Water, Ditching Procedures Appropriate to Equipment Being Operated X X Oral Oral X
6-8 Module Initial Ground Training (2 Hour Minimum) Initial Flight Training Recurrent Ground Training (1 Hour Minimum) Recurrent Flight Training Initial Flight Observations Recurrent Flight Observations Requalification Ground Flight Height Velocity Diagram and Raw Terrain Descriptions (Helicopter Only) X Oral Oral X * Transition to IFR/IMC, if Inclement Weather Avoidance is Unsuccessful
X X X X X X X X Abnormal and Emergency Procedures
X X X X X X X X Aircraft-Specific Equipment and Related IFR Limitations
X X X X X X X X Autorotation X X X X X Hover Autorotation X X X X X X X X ** Recurrent flight training for pilots should include, at least flight training in the procedures relative to each KSSA, except that satisfactory completion of a recurrent flight evaluation, evaluating all training elements above, conducted within the previous 12 calendar months, may be substituted for recurrent flight training.
* Items of recurrent training that were not completed when due for requalification or eligibility should be completed within 12 calendar months of the last tour flight.
6.9 Courseware. The CH or operator should include and present to the Administrator, at a minimum, the training courseware to support the training listed in paragraph 6.8.1 above.
6.10 Supplemental Courseware. The CH or operator should include and present to the Administrator the following supplemental courseware, which is dependent on the geographic area and scope of operation. Supplemental courseware may vary greatly among CHs and operators depending on their specific area of operation, as applicable.
• ATC letter(s) of agreement and procedures;
• National Park Service ATMPs;
• IOA, OpSpec/LOA B057, and OpSpec/LOA B048; and
• VAs.
Advisory Circular Feedback Form If you find an error in this AC, have recommendations for improving it, or have suggestions for new items/subjects to be added, you may let us know by contacting the Air Transportation Division at 9-AFS-200-Correspondence@faa.gov or the Flight Standards Directives Management Officer at 9-AWA-AFB-120-Directives@faa.gov.
Subject: AC 136-4, Supplemental Information for the Creation of Operating Procedures and Pilot Training Subjects Related to OpSpec/LOA B048 Date: _____________________ Please check all appropriate line items:
An e rro r (proc edur al or typographical) has been noted in paragraph ____________ on page _______.
Recommend paragraph _____________ on page __________ be changed as follows:
______________________________________________________________________ ______________________________________________________________________ In a future change to this AC, please cover the following subject:
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