2-1 CHAPTER 2. ENHANCED FLIGHT FOLLOWING CENTER (EFFC) FUNCTIONS
2.1 Regulatory Requirements. There are no specific regulatory requirements associated with EFFCs for commercial air tours. However, to promote safety in the National Air Space (NAS), the FAA strongly encourages commercial air tour operators to establish an EFFC as an additional safety enhancement to their existing programs and manuals.
2.2 Core Concepts—EFFC and Operational Control Procedures. There are three core concepts that define an effective EFFC with enhanced operational control procedures.
2.2.1 Joint Flight Safety Responsibility. The first core concept to establish an effective EFFC is a joint flight safety responsibility for each commercial air tour operation. Joint responsibility conveys ownership of the flight by all involved. The joint flight safety responsibility concept should include at least one qualified ground staff member, in addition to the pilot in command (PIC), to be actively involved in determining whether a flight can be completed safely. This involvement may include reviewing pilot and aircraft readiness (pilot currency, medical, and checkride status, aircraft airworthiness) current and forecast weather, Weight and Balance (W&B), and aircraft performance analysis, along with other risk factors and concurring with a risk analysis in accordance with a risk analysis program.
2.2.1.1 The EFFC should be staffed with trained personnel, referred to in this AC as Operations Control Specialists (OCS), who continuously provide safety input to each flight by monitoring factors affecting flight safety before, during, and after completion of every single flight.
2.2.1.2 The OCS personnel on the ground may provide additional Crew Resource Management (CRM) support for pilots during an emergency or situations where there is a potential for an emergency to occur, such as unforeseen weather or potential, unexpected airspace congestion of a known site-specific area.
2.2.2 Standard Operating Procedures (SOP). The second core concept is the development and implementation of documented SOPs that are used to guide training and to standardize EFFC operations. The FAA recommends OCS involvement in the creation of the operator’s SOPs. OCS involvement in the SOP process will likely result in organizational efficiency. These SOPs may be contained in the operator’s General Operations Manual (GOM), which is required for 14 CFR part 135 operators. In the same manner, OCS training may be a part of the operator’s Training Program Manual (TPM) or procedures may be self-contained in standalone documents.
2.2.3 Leveraging Technology and Communication. The third core concept of an EFFC is to enhance operations control procedures by leveraging advanced technology to continuously track and monitor all aircraft operations with the purpose of augmenting safety and efficiency. This technology should only be implemented if it provides an improved level of situational awareness to the PIC and the OCS personnel. An EFFC
2-2 may implement multiple forms of technology to provide communication and safety benefits to commercial air tour operations.
2.2.3.1 Example. For example, an EFFC may be able to acquire weather information for situational awareness purposes from non-aviation sources that do not feed into the National Weather Service (NWS) database. This information may come from a variety of non-aviation-related weather sources available at the EFFC, such as telephone calls, local television (TV) stations, state Department of Transportation (DOT) roadside weather monitoring stations, non-government weather cameras, etc., which should be used to enhance situational awareness and “no-go” decision making only. Such non-NWS/FAA sources may not be used for “go” decisions.
2.2.3.2 Provision of Situational Awareness Information. Operators are highly encouraged to implement advanced communication technology and Global Positioning System (GPS) tracking in their tour aircraft. To best utilize an EFFC, the operator should establish a tracking system and document procedures for acquiring and providing situational awareness information to the PIC via direct communication from the OCS or via relay through other individuals. Leveraging technology and communications is key to reducing risks associated with commercial air tour operations.
2.3 EFFC Models. Many physical configurations are possible depending on the size and scope of the operator. The EFFC provides a physical location where the OCS and any other personnel can access information technologies to assist the PIC.
2.3.1 Locations. EFFCs may be co-located with a communications center that schedules flights, passes flight information to the pilot, and performing flight monitoring, etc.
Alternatively, EFFCs may be located at one central site with one or more remotely sited communications centers that communicate flight information to the EFFC through various means.
2.3.2 Communication. Several key concepts should be considered regardless of the physical relationship between the EFFC and communications centers:
2.3.2.1 Direct communications between the EFFC and the PIC through the communications center should only be used for flight advisory information critical to flight.
2.3.2.2 The OCS should establish two-way communication with the PIC of the commercial air tour, if possible. This may occur through direct communication or established indirect procedures, such as relay through the communications center. The OCS should have the means available to immediately and directly communicate critical in-flight information or weather changes to the in-flight pilot. Additionally, the OCS should evaluate and concur or not with the pilot’s mitigation plan (e.g., turn around, land offsite, divert, deviate from planned course, etc.). The OCS should also
2-3 possess a means of continually updating the risk analysis due to changing conditions to relay dynamic updates and collaborate on flight plan changes that may not have been considered at the beginning of the commercial air tour.
2.4 EFFC Facilities.
2.4.1 Hardware and Software Resources. A well-functioning EFFC should be equipped with sufficient hardware and software resources for effective flight monitoring and operational control. This includes:
2.4.1.1 Enabling technologies (e.g., internet access, non-FAA weather resources, digital signature capabilities for form completion, computers, cellphones, TV, etc.).
2.4.1.2 Ground-based aircraft situational displays (ASD) depicting the position and status on a viewable display (e.g., large computer monitor, laptop computer, tablet, phone, etc.) of all certificate holder (CH) commercial air tour flights and other local operator flights, as well as non-air tour flights airborne inside the air tour airspace from all aircraft transmitting Automatic Dependent Surveillance-Broadcast (ADS-B) Out or from linked GPS trackers.
2.4.1.3 Aviation weather analysis tools (e.g., textual, graphical, Geographic Information System (GIS)-enabled, and weather cameras).
2.4.1.4 Notice to Airmen (NOTAM) tools (both textual and graphical).
2.4.1.5 Air traffic flow tools (e.g., temporary flight restrictions (TFR), special-use airspace, Special Areas of Operation, military operations airspace, high-density congested airspace, warning areas, and weather watch boxes).
2.4.1.6 Communication tools (e.g., telephones, email, datalink, radio, Voice, or Radio over Internet Protocol (VoIP/RoIP) capabilities), satellite communications (SATCOM), and advanced communication consoles.
2.4.1.7 Non-aviation situational awareness tools capable of accessing weather cameras or TV capable of receiving cable news channels. These tools should be used solely for situational awareness and making a “no go” decision.
2.4.1.8 In the event of a national security emergency or local disaster, news, websites, and phone lines (both landlines and cellular phones) may become inoperative due to the sheer volume of people trying to simultaneously access these resources. Therefore, news broadcasts delivered via TV may be the best means of acquiring information regarding the airspace where air tour flights may be directed to immediately land, other areas where flights might be prohibited, and as a tool to locate an aircraft in distress or that have been involved in an accident.
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2.4.2 Scoping of EFFC Facilities and Capabilities. Regardless of the organization’s size, EFFC concepts should be carefully planned and implemented to avoid unintended gaps or errors that may result in actions or omissions detrimental to safety. The following guidelines are provided to assist the operator in avoiding such failures:
2.4.2.1 Establish and document applicable governing policies, procedures, and personnel training curriculum, which may be included in the operator’s GOM or in the training program.
2.4.2.2 Demonstrate the maintenance of operational control and PIC responsibility and authority is maintained, ensuring safety is not compromised due to delegation of duties to staff members without proper OCS training.
2.4.2.3 Smaller operators may incorporate EFFC functions within their operational control system, with staff members providing OCS type services after receiving appropriate training.
2.4.2.4 Create SOPs suitable for the size and scope of the operation.
2.5 EFFC Physical Space Design Considerations. Consideration of human factors and physical space considerations should be considered when designing the layout of an EFFC for multiple aircraft operations.
2.6 EFFC Technology and Design Considerations.
2.6.1 Failure and Redundancy Considerations for Both Systems and Processes. As technology becomes increasingly integral to flight operations, the potential for its failure raises concerns. It is important to proactively plan for technology failures and implement redundant systems and processes. This ensures that contingency systems can deliver results without compromising the safety of normal operations or, when necessary, emergency operations. In addition to planning for temporary or minor failures and outages, comprehensive planning should also account for major technology failures. The development of an EFFC information technology (IT) disaster recovery plan is important to the success of an effective EFFC. This plan should be well-documented, and EFFC staff should periodically practice contingency operations, so they are prepared for such eventualities.
2.6.2 Common Technology Interruptions. When developing, implementing, and integrating an EFFC, it is important to plan for common technology interruptions. These include:
• Electrical power outages (localized to the building, the local area, or to a broader geographic area).
• Internet Service Provider (ISP) or ISP connectivity outages.
• Virus protection and firewalls to prevent system hackers.
2.6.3 ISP Connectivity. Software applications utilized by EFFCs are increasingly shifting to web-based platforms. Consequently, if an EFFC loses internet connectivity, web-based
2-5 applications become inoperative. The FAA recommends EFFCs to maintain at least two wholly independent internet access connections. For example, a primary internet source can be supported with a cellular system, such as a remote hot spot.
2.6.4 Phone Numbers. In the event of a Local Area Network (LAN) or local workstation failure, electronically accessible phone numbers may become inaccessible (see Appendix B, Diagrams and Examples, for examples of operator and out-of-company contact lists). Consequently, it is recommended to maintain hard copies of all phone number lists at each workstation.
2.6.5 Flight Monitoring. Flight-monitoring processes often rely on electronic applications or specialized communication equipment (e.g., radio, data link, SATCOM, etc.). These specialized flight monitoring technologies, in turn, often rely on internet or LAN connectivity or both within the data chain to transmit the aircraft location information to personnel responsible for flight monitoring functions. Therefore, it is important that an operator establishes and documents alternate flight locating procedures in the event the primary flight monitoring application and procedures become inoperative. Alternate flight monitoring processes typically involve alternate communication methods for tracking the aircraft, such as communicating with outstations, other aircraft, air traffic control (ATC), Flight Service Station (FSS), etc. An acceptable industry standard for flight monitoring is for all aircraft to update their position (electronically or verbally) every 15 minutes or less (see Appendix B for a flight monitoring procedures flowchart example).
2.7 Emergency and Abnormal Operations. Commercial air tour operators should establish and document procedures that most effectively leverage EFFC resources in response to abnormal or emergency operations before they occur. The following are some of the situations that may be encountered followed by possible solutions:
2.7.1 Partial or Full Loss of EFFC Function. Clearly defined procedures should address the effective management of partial or full shutdown of an EFFC. This encompasses handling scenarios such as power failure, loss of primary ISP connectivity, or instances requiring a complete evacuation due to emergencies such as fire, snow, earthquake, hurricane, tsunami, tornado, flood, etc. Computers, tablets, phones, and other essential equipment should be immediately available for the OCS to quickly execute a “grab and go” should an emergency evacuation be necessary.
2.7.2 Unavailable Facilities. Contingency plans should be in place for situations where local facilities are unavailable for relocating the EFFC. During such circumstances, operators should consider holding a temporary moratorium on launching new flights in anticipation of events that may trigger a EFFC temporary shutdown or a complete recall. This may involve temporarily transferring EFFC duties to alternative EFFC facilities or mobile resources until a suitable alternate EFFC facility is established.
3-1 CHAPTER 3. OPERATIONS CONTROL SPECIALIST (OCS) DUTIES AND
RESPONSIBILITIES
3.1 OCS Duties and Responsibilities. Each commercial air tour operator should describe in their General Operations Manual (GOM) or other FAA-accepted document the duties and responsibilities of an OCS. This includes preflight risk mitigation strategies, risk control measures, and the use of a shift change checklist. The level of operational control authority delegated to the OCS should be clearly defined in the commercial air tour operator’s GOM (for 14 CFR part 119 certificate holders (CH)) or described in Operations Specifications (OpSpec) A008, Operational Control, if applicable. Operators must also ensure that each person authorized to exercise operational control are listed in the GOM in accordance with 14 CFR § 135.23(a). The minimum duties of an OCS should include:
3.1.1 Operational Control. The commercial air tour operator should authorize each OCS to exercise operational control, directing the pilot to decline, divert, abort, or reroute the flight. The OCS should not provide opinions to the pilot suggesting that a flight can be initiated or completed when weather is a factor. Likewise, in the opinion of the pilot, whenever a flight should not be initiated or continued due to weather or other safety factors, the OCS should not suggest or direct otherwise.
Note: One principle employed by several operators is the OCS should follow the “advise, suggest, direct” concept, advising the pilot of any potential hazards along proposed routes, suggesting possible mitigation strategies, and, if needed directing the commercial air tour pilot to decline, divert, or terminate the flight.
3.1.2 Communications. Ideally, the OCS should communicate directly with the commercial air tour pilot via radio or other means to provide weather advisories and notifications of other factors affecting the overall safety of the flight. If direct communication is not possible between the OCS and pilots, a secondary means through a communications center staffed by trained communications specialist (CS), should be available. These procedures should be incorporated into the CH’s GOM or other written standard operating procedure (SOP). If communications between the air tour pilot and OCS are expected and there is a loss of communication, the operator should be prepared to activate the Accident/Incident Plan (AIP).
3.1.3 Weather Reporting. The OCS may provide pilots with weather briefings, to include current and forecasted weather along the planned route of flight. While the OCS may obtain weather from non-National Weather Service (NWS)/FAA weather sources to aid in situational awareness, only information derived from the NWS or other FAA-approved sources will be used in making “go” decisions. However, any weather source that is relevant to the safety of flight should be used for advisories as a flight progresses. This information may be relayed to the pilot by an appropriately trained OCS.
3.1.4 Monitor the Progress of the Flight. The OCS should monitor the progress of each commercial air tour flight. This may be accomplished through a variety of means, including satellite tracking, position reports, etc. Weather conditions in the area(s) of
3-2 operation should be monitored, and methods communicating adverse or forecast deteriorating weather conditions to the pilot should be established. In the event the OCS cannot directly monitor a flight’s progress via satellite or other graphic means, commercial air tour operators should have established procedures for monitoring the flight via position reports or other means.
3.1.5 Preflight Risk Analysis. EFFC personnel/pilots should be trained in basic risk analysis, with the ability to stop or terminate a flight as risk dictates. The analysis is ongoing as flights progress and conditions change. If the risk level increases as the day/flight progresses, the appropriate higher risk approval authority should be immediately notified to approve, mitigate, or terminate continued operations.
3.1.6 Risk Analysis. Risk analysis is a continuous and iterative process encompassing risk assessment, mitigation, and reassessment. The risk assessment phase is a key element within the broader risk analysis process. This involves identifying hazards, calculating the probability of their occurrence, and determining the likely severity of outcomes should a hazard occur.
3.1.7 Risk Mitigation. Risk mitigation and its effectiveness in reducing risk is an essential component of the risk analysis program. In cases where the risk assessment rates a particular risk element as high, preplanned, and preapproved mitigations may be advisable. Risk mitigations should not be improvised at the time of need to prevent unintended consequences. Following application of effective mitigation measures, both individual and total residual risk factors should be reassessed. This risk mitigation/reassessment cycle should be repeated until all higher risks are effectively mitigated.
3.1.8 Risk Threshold. Each individual risk element is evaluated against the operator’s predetermined risk threshold and aggregated into a total risk score after applying approved mitigation strategies. This total risk is then compared to the operator’s predetermined aggregate threshold. If the final aggregate residual risk or individual risk elements or both exceed the operator’s predetermined thresholds, a higher level of operator management approval (above the OCS) should be sought. If this approval cannot be obtained, the flight should be declined.
3.1.9 Participation of Personnel. The OCS should participate in preflight risk analysis, providing essential preflight information and should limit their approval to low-risk scenarios, typically routine commercial air tour flights with minimal risk. Unmitigated risks above the low level should be forwarded to upper-level management (e.g., Director of Operations (DO), Chief Pilot, etc.) for consideration in accordance with company procedures.
3.1.9.1 The OCS should ensure the pilot completes all items on the operator’s preflight risk analysis worksheet. Procedures for determining the minimum items for the risk analysis should be clearly outlined in the operator’s risk analysis program.
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3.1.9.2 The OCS should verify the pilot’s completion of all items on the preflight risk analysis worksheet. Additionally, they should assist the pilot in mitigating any identified risks prior to takeoff. If communication systems are available and maintained, the OCS can provide real-time information during flights in case of unexpected changes in conditions.
3.1.9.3 Risk mitigation strategies offered by the OCS should be presented as validated options previously endorsed by the operator. Ad hoc risks mitigation may lead to unintended consequences. It’s important to note that the PIC ultimately decides the acceptability of the recommended risk mitigation strategies.
Conversely, the OCS should assess mitigation strategies proposed by the PIC and have the authority to direct the PIC to decline or abort a flight if, in their opinion, the proposed risk mitigation is inadequate, inappropriate, or if the residual risk remains excessive.
3.1.9.4 Operators are encouraged to document the use of mitigation strategies and their impact on the safe conduct of a flight.
3.1.9.5 The air tour operator should establish a procedure for OCS acknowledgment in writing, specifying the accurate completion date and time of the preflight risk analysis worksheet. According to the OCS’s professional judgment, this documentation should confirm that the flight can be conducted safely.
3.1.9.6 The method of acknowledgement may vary as specified by the commercial air tour operator in their risk analysis program. This acknowledgement can be on the same risk analysis worksheet completed by the PIC or on a separate record. The record needs to include the acknowledgement date and time, sufficient information to identify the PIC, the flight date, the flight route details, confirmation of accurate completion of the preflight analysis worksheet, and the OCS’s professional judgment that the flight may be conducted safely, along with any other information deemed appropriate by the CH. The method of acknowledgement may be in writing, electronic, etc., as specified in the risk analysis program.
3.1.9.7 When, in their professional opinion, the OCS cannot concur that a flight can be conducted safely, the OCS should direct the PIC not to accept the flight. If the OCS observes changes in the risk analysis factors during a commercial air tour operation, the OCS should advise the PIC, recommend possible mitigation strategies, and, if the risk becomes unacceptable, direct the PIC to divert or abort the flight. This OCS authority should be documented in the CH’s or operator’s risk analysis program and GOM or other FAA-accepted document, as applicable.
Note: Chapter 7, Risk Analysis Tool, provides additional information related to the purpose, suggested use, of a risk analysis tool, and an example of a risk assessment matrix.
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3.1.10 Emergency Assistance Capabilities. The OCS plays an important role in providing emergency assistance to PICs during emergency situations, such as an encounter with inadvertent instrument meteorological conditions (IIMC), if equipped with advanced communication technology. Two-way communication systems have the potential to enhance situational awareness, preventing unknown IIMC encounters for the pilot. In many circumstances, the OCS may observe the aircraft’s position and maintain communication with the PIC when the aircraft is below air traffic control (ATC) radar and communications coverage. Under these circumstances:
3.1.10.1 The OCS may need to relay crucial information to ATC regarding an aircraft declaring an emergency and the pilot’s intentions.
3.1.10.2 Additional communication resources enable active OCS personnel to deliver accurate weather information or route recommendations to airborne aircraft.
This capability is important and crucial for a commercial air tour to avoid or navigate away from severe or deteriorating weather conditions. In certain situations, the OCS may be the only means by which the PIC can receive accurate weather information or route recommendations to escape severe or deteriorating weather conditions.
Note: The utilization of advanced communication technology by the OCS can significantly contribute to the overall safety of the flight, providing timely and critical information to the PIC, especially in emergency scenarios. The OCS’s ability to relay information to ATC and offer real-time guidance enhances the operational response and decision-making capabilities during unforeseen events, ultimately ensuring the well-being of the flight and its passengers.
3.2 OCS Shift Change and Relief Procedures. Commercial air tour operators should develop a shift change and relief checklists for use by OCS personnel during shift changes. Procedures for briefing the incoming OCS on ongoing and upcoming commercial air tour operations should be developed, documented, and regularly trained.
The shift change checklist should, at a minimum, encompass the following:
• Active ongoing commercial air tour operations.
• Weather affecting possible flight areas.
• Temporary flight restrictions (TFR).
• Technology anomalies to include “COMMUNICATION” and “INTERNET” status.
• New flight operations policies, manual changes, etc., that have taken effect since the last shift for an oncoming OCS.
Note: Refer to AC 120-96, Operations Control Center (OCC) for Helicopter Air Ambulance (HAA) Operations, for additional OCS shift change procedures.
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3.3 OCS Interfaces. Some commercial air tour operators may view it as a best practice for the OCS to transmit routine, noncritical information to the PIC through the communications center. This practice ensures that all involved parties (OCC, pilot, and any other EFFC personnel) are aware of information being provided and potential route deviations resulting from OCS suggestions or direction. Refer to AC 120-96, Chapter 3, Paragraph 3.2, OCS Shift Change/Relief Procedures, for additional information.
3.3.1 Direct Communications. In cases where the OCS is performing tasks such as those listed in 14 CFR § 135.619(a) and needs information from or intends to pass information to the pilot, the OCS will normally communicate directly with the PIC. This direct communications link is crucial, especially in time-critical situations or when technical discourse is necessary to reach a consensus position regarding risk analysis or weather options. It is recommended that the OCS promptly informs the communications center of the nature of the communication and any potential impacts on the commercial air tour operation as soon as it becomes feasible.
3.3.2 Non-Normal Event. The EFFC should be notified by all employees or personnel any time they are made aware of an out-of-the-ordinary event during a commercial air tour flight.
Such events include diversions, precautionary landings, or any occurrences deemed appropriate by the operator. These notification processes should be thoroughly documented in the operator’s GOM or any other accepted document or SOP. This documentation ensures a comprehensive record of non-normal events and supports subsequent analysis and improvement of operational procedures.
Note: The primary interface between the OCS and the PIC tour operations occurs primarily before the commercial air tour flight and at the termination of the flight.
Direct communication during any portion of the flight between the EFFC/OCS should be limited to matters related to the safety of the flight.
3.4 Accident/Incident Procedures. Procedures for the OCS to follow in the event of an overdue aircraft, or if an aircraft is known to have been involved in an accident or incident, should be thoroughly documented in the GOM or SOP. These procedures should include steps for notifying appropriate company personnel, as well as emergency medical services (EMS), fire, and police, if necessary, in the area where the aircraft is believed to be located. It is recommended that the OCS maintain a comprehensive listing of all EMS, fire, and police dispatch centers, along with their phone numbers for the areas where commercial air tour operations are typically conducted at the OCS workstation.
3.4.1 Task Delegation. The OCS may delegate some tasks related to the Post-Accident/Incident Plan (PAIP) to other EFFC personnel. If this delegation occurs, it should be noted in the PAIP documentation.
3.4.2 Overdue Aircraft. See Appendix B, Diagrams and Examples, for an overdue aircraft flowchart example to supplement GOM accident notification procedures.
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3.4.3 Human Factors. Operators should also consider the human factors associated with OCS staff involvement in risk analysis or other activities preceding an accident or incident and the impact of this involvement on the OCS’s ability to effectively continue in their duties.
3.4.4 OCS Involved With an Accident/Incident. In the event that an OCS involved with a flight
(e.g., having concurred with and signed off a personal Flight Risk Assessment Tool (FRAT), advised a pilot of inclement weather, or directed a diversion) subsequently experiences an accident or incident, it is recommended that the OCS be temporarily relieved of duty. The operator may choose to establish a policy ensuring that the individual receives adequate debriefing, appropriate counseling, and sufficient time to resolve the psychological trauma associated with peripherally involved in an accident or incident. The manager responsible for EFFC operations should review the OCS’s fitness for duty before authorizing the return of the OCS to their duties.
4-1 CHAPTER 4. OPERATIONS CONTROL SPECIALIST (OCS) TRAINING
4.1 Training General. Although not required by regulation for commercial air tour operations conducted under either 14 CFR part 91 or 135, commercial air tour OCS personnel should be trained in accordance with a training program established by the operator. Ideally, OCS personnel should be pilots experienced in commercial air tour operations.
4.1.1 Initial Training. Prior to performing the duties of an OCS, each individual should satisfactorily complete the commercial air tour operator’s OCS initial training program.
Documentation of initial OCS training documents should be maintained and retained for the entire duration of their employment and 90 days thereafter.
4.1.2 Recurrent Training. After completing initial training satisfactorily, each OCS should complete recurrent training every 12 months, focusing on the topics outlined in the operator’s training program. It is recommended to maintain and retain documentation of recurrent training for a minimum of 12 months unless superseded by more recent training.
4.2 Training Subjects. The recommendations below serve as a guide for developing commercial air tour OCS training.
4.2.1 Training Elements. In conjunction with initial classroom or computer-based training, OCS candidates should pass an operator-specific knowledge test. Initial training may adopt a scenario-based approach, incorporating one-on-one supervised sessions or coached on-the-job training (OJT), or both, leading to the operator-specific practical test.
Throughout OJT, the OCS instructor should be cognizant of and responsible and accountable for all actions undertaken by the OCS candidate under their direct and continuous supervision. Recurrent training should include periodic abnormal/emergency procedures drills, and both training and testing should be completed before the end of the twelfth calendar month since the last test was conducted.
4.2.2 Instructors. Individuals authorized by the commercial air tour operator to facilitate OCS training and testing should possess experience as OCS personnel or be individuals recognized as suitable and knowledgeable by the commercial air tour operator. Initial OJT should be conducted by specifically designated and current OCS trainers, and this authorization should be outlined by position or individual name in the OCS training program.
4.2.3 Training Hours. The training program should allocate sufficient hours of instruction to comprehensively cover the topics specified within the training program. One approach to determining necessary training hours for various topics may be conducting a knowledge assessment by the prospective OCS. This assessment can gauge the prospective OCS’s depth of knowledge in various areas, and the results may inform the appropriate allocation of training hours to ensure a thorough understanding across all subject areas.