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3.26 TCO Approval. When the jurisdictional FSDO has approved the TCO(s), a letter of approved courses and ratings will be issued and the appropriate course(s) placed on the Air Agency Certificate. A school with a private pilot rating on its Air Agency Certificate may conduct one or several private pilot certification courses, provided a TCO is submitted and approved under part 141 subpart C for each course of private pilot training given.
Note: Each requested pilot school rating must be listed on the application.
3.27 Application Denial. Denial of an application will be substantiated by the jurisdictional FSDO with a letter to the applicant documenting the reasons for denial and what actions are needed in order to obtain a part 141 pilot or provisional pilot school authorization.
An applicant may reapply at any time for a rating(s) in the same manner as prescribed for initial application. At the jurisdictional FSDO’s discretion, reinspection of previously approved areas may not be necessary.
4-1 CHAPTER 4. DOCUMENT COMPLIANCE PHASE
4.1 General. This chapter will focus on the document compliance phase, the documents necessary for certification as a 14 CFR part 141 pilot school or provisional pilot school, and the review of these documents by the jurisdictional Flight Standards District Office (FSDO). The applicant’s proposed training course outline (TCO) and syllabus for each course, system for student record documentation, personnel records documentation, student safety guide, and training records of the chief instructor, assistant chief instructor, assigned instructors to a course, and check instructors, as well as other documents, are reviewed in depth to ensure compliance with part 141. At the conclusion of the document compliance phase, the proposed documents and proposed systems for record documentation reviewed will be evaluated during the next phase, the demonstration and inspection phase.
4.2 Student Training Records. A certificate holder must maintain enough information for the FAA to determine the quality of training given. The record system used must include more than a simple description of a training flight. It will include a very accurate detailed chronological record of all training, both ground and flight. Part 141, § 141.101 requires each school to establish and maintain a current and accurate record of the participation of each student enrolled in an approved course. These requirements are not separate from the logging of training time required in 14 CFR part 61 (typically recorded in the student’s logbook). Rather, the training records described here are an additional requirement to track part 141-specific activity. Aeronautical experience and flight training used to meet the requirements for a certificate or rating must be recorded in accordance with part 61, § 61.51(a) through (k), as appropriate. This includes both aeronautical knowledge training and flight training. The records maintained in a student’s logbook will not suffice for the recordkeeping requirements. This must be an independent training and recordkeeping system, not just a list of flights. It should be a detailed account of all of the student’s activity while enrolled in an approved course.
4.3 Credit for Previous Training. A student who transfers from one part 141 pilot school and enrolls in another part 141 pilot school may receive credit obtained in the previous course of training in accordance with §§ 141.67(b)(1) through (5) and 141.77.
The transferring student must present certified training records to the receiving school from the previous school, documenting topics and times of training completed and the result of each stage check. The receiving school must test a transferring student, document the results of that testing, and document any credit given. A student may not be credited with more training by the receiving school than was credited at the school from which the student transferred.
1. A student who enrolls in a course of training may receive credit for not more than 25 percent of the curriculum requirement for knowledge and experience received from other than a part 141 pilot school or 14 CFR part 142 approved aeronautical or flight training course.
2. A student who enrolls in a course of training may receive credit for not more than 50 percent of the curriculum requirement for knowledge and experience received from a part 141 pilot school or part 142 training center.
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3. The amount of credit for previous training allowed, whether received from a part 141 pilot school or other source, must be placed in the student’s enrollment record at the time of enrollment.
4. When a student transfers from a part 141 pilot school or terminates training for any reason, the student must be given, upon request, a transcript of the results of the student’s participation in that course of training. This transcript should be signed by the chief instructor of the course and should consist of at least the name of the school that gave the training, including the school’s certificate number, if applicable; kind of training given; course or courses taken; a statement the student was enrolled in the school’s course of training;
and the results of each stage check and final check.
5. If the student is transferring into a part 141 pilot school that holds examining authority, the credit that may be granted is limited to a transferring student who received his or her training from another part 141 approved pilot school and training course.
6. Students seeking certifying statements for a restricted privileges Airline Transport Pilot (ATP) Certificate in accordance with § 61.160 may transfer credit for aeronautical knowledge and flight training gained at an institution of higher education which holds an Institutional Authority Letter of Authorization (IALOA) to another institution holding an IALOA, in accordance with § 141.77. This would apply to previous training for the instrument rating and commercial certificate, taken under a part 141 pilot school at an institution of higher education that holds an IALOA.
4.4 Student Enrollment Certificate. When a student enrolls, a part 141 pilot school must furnish the student with a copy of a certificate of enrollment, containing:
• The student’s name;
• The name of the course in which the student is enrolled;
• The date of enrollment; and
• A copy of the safety procedures and practices, per § 141.93(a)(3).
4.5 Student Graduation Certificate. A certificate holder must issue a graduation certificate to each student who completes its approved course of training. The certificate holder may not issue a graduation certificate to a student, or recommend a student for a pilot certificate or rating, unless the student has completed all of the training requirements of that course. Section 61.71 states that a person who graduates from an approved training program under part 141 is considered to have met the applicable aeronautical experience, aeronautical knowledge, and areas of operation requirements of part 61, if that person presents the graduation certificate and passes the required practical test as appropriate within the 60-day period after the date of graduation. Should an applicant not accomplish pilot certification within 60 days of the date of graduation certificate, additional training and an additional final progress check may be accomplished,
4-3 facilitating the issuance of a new graduation certificate, unless expressly prohibited by the TCO.
Note: Some TCOs may encompass “combined courses” such as a combined Private Certificate and Instrument Rating under part 141 appendix M, or a combined Instrument Rating and Commercial Certificate Special Curriculum course under § 141.57. In these cases, a single graduation certificate will be issued at the completion of the entire course. However, as with conventional single-course TCOs, should an applicant not accomplish pilot certification within 60 days of the date of graduation certificate, additional training and an additional final progress check may be accomplished, facilitating the issuance of an updated graduation certificate, unless expressly prohibited by the TCO.
4.6 Chief Instructor Qualifications/Training Record. The certificate holder should keep a current and accurate record of the chief instructor’s qualifications and currencies. This record should include:
• The name and pilot certificate number of the designated chief instructor, including qualifications;
• A list of courses approved as chief instructor by the FAA;
• The date of approval from the FAA for the initial knowledge test and proficiency test for each course; and
• The date of all recurrent training or flight instructor refresher courses (FIRC), as applicable.
4.7 Assistant Chief Instructor Qualifications/Training Record. The certificate holder should keep a current and accurate record of the assistant chief instructor qualifications and currencies. This record should include:
1. The name and pilot certificate number of the designated assistant chief instructor, including qualifications.
2. A list of courses approved as assistant chief instructor by the FAA.
3. The date of approval from the FAA for initial knowledge test and proficiency test for each course.
4. The date of all recurrent training or FIRCs, as applicable.
5. The specific authorities designated by the chief instructor:
• Name of course authorized to conduct stage checks;
• Name of course authorized to conduct end-of-course checks; and
• Authorization to conduct annual instructor proficiency checks.
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4.8 Check Instructor Qualifications/Training Record. The certificate holder should keep a current and accurate record of any check instructor’s qualifications and currencies.
This record should include:
1. The name and pilot certificate number of the designated check instructor, including qualifications.
2. A list of courses approved as a check instructor by the FAA.
3. The date of approval from the FAA for each course as a check instructor.
4. The date of the proficiency test given by the chief instructor or assistant chief instructor on the flight procedures and maneuvers for each course designated as check instructor.
5. A listing of the specific authorities designated by the chief instructor, including:
• Name of course authorized to conduct stage checks;
• Name of course authorized to conduct end-of-course checks; and
• The authorization to conduct annual instructor proficiency checks.
4.9 Flight Instructor Qualifications/Training Record. The certificate holder should keep a current and accurate record of all flight instructors assigned to a course and keep a record of their qualifications and currencies. This record should include:
• The name and pilot certificate number of the flight instructor;
• The date of initial proficiency check given by the chief/assistant chief instructor or check instructor in each make and model (M/M) of aircraft used in the training course the instructor is authorized to instruct;
• The date of all recurrent proficiency checks given by the chief/assistant instructor or check instructor;
• A list of courses the instructor is approved to teach; and
• The part 141 pilot school must maintain a record verifying a review and briefing on the objectives and standards of any training course the instructor is assigned to in accordance with §§ 141.79(d) and 141.81(c).
4.10 Student Safety Guide. The certificate holder must provide the student with a copy of the safety procedures and practices during the enrollment process, describing the use of the school’s facilities and the operation of its aircraft. The procedures and practices must include at least the following information (§ 141.93):
• The weather minimums required by the school for dual and solo flights;
• The procedures for starting and taxiing aircraft on the ramp;
• Fire precautions and procedures;
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• Redispatch procedures after unprogrammed landings, on and off airports;
• Aircraft discrepancies and approval for return-to-service determinations;
• Securing of aircraft when not in use;
• Fuel reserves necessary for local and cross-country flights;
• Avoidance of other aircraft in flight and on the ground;
• Minimum altitude limitations and simulated emergency landing instructions; and
• A description of and instructions regarding the use of assigned practice areas.
4.11 Full Flight Simulators (FFS), Flight Training Devices (FTD), and Aviation Training Devices (ATD). If an FFS, FTD, or ATD is used in an approved training course, the specific lessons for its use must be clearly identified in the training syllabus.
The objectives and completion standards should be well defined. Part 141 specifies the maximum credit (see Appendix E for the maximum credit allowed) for the experience or training requirements for a certificate or rating. ATD allowances are also provided on the letter of authorization (LOA) provided to the manufacturer or operator of the training device. The training course syllabus must clearly identify the specific lessons that will be accomplished in a FFS, FTD, and/or ATD and fully described in the FAA-approved TCO. The objectives and completion standards when using these ground trainers must be well defined, just as they are in an aircraft. This will facilitate training to proficiency, as students transition to the aircraft to complete their flight training.
1. Section 141.41(a) prescribes the requirements for an FFS or FTD when using these devices for training credits in an approved pilot training course. FFSs or FTDs are evaluated and qualified under 14 CFR part 60 and require annual renewal.
2. Section 141.41(b) provides the requirements when using an ATD for training credits. Their approval and use is prescribed in Advisory Circular (AC) 61-136, FAA Approval of Aviation Training Devices and Their Use for Training and Experience. This includes allowances for both basic and advanced ATDs that are approved by the General Aviation and Commercial Division (AFS-800). ATDs must be accompanied by the FAA LOA and are valid for 60 calendar-months.
3. The FAA will use discretion when approving a training syllabus that substitutes instruction in an FTD or FFS for the flight time required in a complex airplane. Any use of an FFS or FTD in lieu of flight time in a complex airplane must be justified with clearly stated objectives in the training syllabus that are applicable to the skills expected to be learned in a complex airplane. Approval of the TCO will be based on the ability of the FFS or FTD to provide effective training for a complex airplane. ATDs cannot be used to substitute for time in a complex airplane.
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4. The National Simulator Program (AFS-205) qualifies a school’s FFS or FTD and provides a letter of qualification. The General Aviation and Commercial Division (AFS-800) provides an LOA for all ATD approvals.
5. The permitted use of FFSs, FTDs, and ATDs are covered in the appropriate appendices of part 141 and §§ 61.4 and 141.41.
6. There are no restrictions on the amount of training time accomplished and logged in training devices. The logging of additional training time is always acceptable. However, the regulatory limitations on the maximum credit allowed in an FFS, FTD, or ATD for the “minimum” pilot experience requirements remain, and are specified in parts 61 and 141 and in the device LOA. No approvals or authorizations are provided for aircraft type ratings or practical tests using ATDs.
4.12 Aircraft Requirements. Each aircraft used by a part 141 pilot school for flight training and solo flights must comply with § 141.39 and must be inspected and maintained in accordance with the requirements for aircraft operated for hire under 14 CFR part 91 subpart E. This requires aircraft used in an approved course of training to have 100-hour inspections and annual inspection, or to be maintained following a procedure prescribed under § 91.409(c). The aircraft, which the FAA inspects, must meet the requirements of the training aircraft described in the appropriate TCO. Aircraft used by part 141 pilot schools may be listed in an LOA, if LOAs are issued.
1. All aircraft used in a part 141 flight school must have a standard airworthiness certificate, a primary airworthiness certificate, or a special airworthiness certificate in the light-sport category. Restricted category aircraft may also be used; however, the use of these aircraft are limited to the special purpose in which the aircraft was certificated.
2. Applicants are requested to submit to the jurisdictional FSDO the aircraft types and N-numbers designated for use in part 141 pilot schools.
3. An aircraft not completely equipped for IFR operations may be used for instruction in the control and maneuvering of an aircraft by reference to instruments if it is approved in the TCO. For example, an airplane need only be equipped with appropriate flight instruments needed for the basic instrument portion of a course.
4. All aircraft used by a part 141 pilot school for flight training must have two pilot stations with engine power controls that can be easily reached and operated in a normal manner from both pilot stations.
4.13 Aircraft—Checklist and Manuals. A variety of airplanes are used in pilot training.
Some aircraft are less complicated while others are more complicated, and their checklists vary accordingly. The requirements for a checklist defined in the terms of “pretakeoff” and “prelanding” in § 141.75(a) are broad and allow less complicated aircraft to be equipped with relatively simple checklists. Schools may consider expanding checklists for aircraft that are more complicated. Both the checklist and pilot’s operating
4-7 handbook (POH) for the aircraft, and copies of the handbook if furnished to each student, must be carried on each aircraft used for flight training.
4.14 Aircraft—Instrument Training. Aircraft used for instrument training must be equipped to meet the requirements of § 141.39. For training in the control and precision maneuvering of an aircraft by reference to instruments, the aircraft may be equipped as provided in the approved course of training, if the approved training syllabus requires flights under IFR.
4.15 Aircraft—Commercial Training. The commercial pilot certification course (airplane) is set forth in part 141 appendix D, and requires flight instruction in an airplane with retractable gear, flaps, and controllable pitch propeller or turbine powered.
1. Single-engine or multiengine airplanes may be used to fulfill this requirement.
Use of an appropriately equipped multiengine airplane to meet the complex airplane requirements for a Commercial Single-Engine Airplane Certificate does not result in the issuance of a multiengine rating.
2. Utilizing an appropriately equipped multiengine airplane to meet the complex airplane requirements for a Commercial Single-Engine Airplane Certificate presents several issues. The instructors utilized must meet § 61.195(b)(1) and (f). At the completion of the training, the student must provide an airplane adequate to complete all tasks for the practical test. The requirements of the current edition of Commercial Pilot Practical Test Standards for Airplane (FAA-S-8081-12) or the Airman Certification Standards (ACS) for the commercial pilot, as appropriate, must be met.
3. If a school applies for a commercial pilot certification course (airplanes) with a seaplane class rating (using seaplanes for the entire course), a special curriculum should be submitted under § 141.57, which includes the general requirements of part 141 appendix D. The complex airplane used in such a course must have flaps, a controllable pitch propeller, and floats. The use of an amphibious airplane in a commercial pilot certification course could qualify a student for both a land and sea class rating, provided the TCO was so approved.
4.16 Document Deficiencies. If the jurisdictional FSDO’s review of the submitted documents reveals deficiencies in the applicant’s submissions, the jurisdictional FSDO will notify the applicant of the deficiencies in writing. In the letter to the applicant, the jurisdictional FSDO will advise the applicant what deficiencies must be corrected before certification can continue. The jurisdictional FSDO will place a reasonable time limit on when the corrections must be completed. If the applicant does not respond to the jurisdictional FSDO within 90 days of the time limit, the entire application package will be returned to the applicant with a cover letter stating that the certification process has been terminated.
5-1 CHAPTER 5. DEMONSTRATION AND INSPECTION PHASE
5.1 General. The demonstration and inspection phase is where the jurisdictional Flight Standards District Office (FSDO) inspects the applicant’s facilities and equipment and observes personnel in the performance of their duties. Emphasis in this phase is on compliance with the regulations and safe operating practices for a 14 CFR part 141 provisional pilot school.
5.2 Facilities Inspection. The applicant must demonstrate that it has adequate facilities to conduct its intended course(s) of training. These facilities include the business office, main base of operations, pilot briefing areas, aeronautical knowledge training facilities, airports, and any proposed satellite bases. A certificate holder is required to have the continuous use of an airport and a pilot briefing area. The school must, under part 141, § 141.31, have a written agreement indicating it has the continuous use of those facilities for 6 months at the time of certification or renewal of its certificate.
5.3 Principal Business Office. The jurisdictional FSDO will inspect the business office.
Each certificate holder must maintain a principal business office with a mailing address and name that matches its certificate. The purpose of a principal business office is to provide a specific location for the required part 141 pilot school files and records, and a location where the operation of school business may be conducted. This requirement should not be construed to mean that all school functions, such as scheduling flights and training functions, must be conducted at the principal business office. After certification, the FAA will continue periodic and routine inspections of the business office and facilities.
1. While part 141 does not require a business office to be a room with four walls and a door, the regulation does prohibit the sharing of a single business office by more than one part 141 pilot school. In that case, the business office must be conspicuously isolated by walls or partitions to ensure separation from another pilot school’s activity.
2. The business office should be situated so the required school files and student training records are kept up to date and available to students and instructors alike. This serves the purpose of providing on-the-spot information regarding training progress and other business interests.
5.4 Pilot Briefing Areas. A certificate holder is required to have continuous use of a pilot briefing area at each airport where training flights originate. This does not include airports used as destinations for cross-country flight training. The briefing area must meet the requirements of § 141.43. Pilots not participating in the school’s training programs can use the briefing facilities, providing orderly school functions are maintained.
However, no other pilot school may use the area during the period it is to be used by the certificate holder. Briefing areas are subject to the jurisdictional FSDO’s approval under the provisions of § 141.55(c)(4).
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1. To meet the requirements of § 141.43, the pilot briefing areas must be adequate to shelter students waiting to engage in flights and arranged and equipped for the conduct of pilot briefings.
2. If a school offers instrument or commercial pilot courses, it is required to have access to a Flight Service Station (FSS). A telephone, either by landline or other telephone communications such as the use of cell phones, is required in the briefing room.
3. To preclude a disruption of schedules due to excessive travel time between the business office and briefing area, the area should be located near enough to the airport where training flights originate.
4. The FAA recognizes that pilot training methods differ from other kinds of training methods. A part 141 pilot school enrolls students with widely varying backgrounds, goals, and degrees of motivation and aviation experience. For this reason, it is understandable it is not always possible to schedule large classes for aeronautical knowledge training at one time.
Individual instruction is often necessary for maximum benefit to a particular student. Therefore, it is anticipated that part 141 pilot schools will use classrooms, small isolated rooms, training booths, or other areas with an instructor or a training aid. Each aeronautical knowledge training area is required to be heated, lighted, and ventilated to meet the applicable building code requirements for the area concerned. All ground instructional facilities are subject to approval by the jurisdictional FSDO under § 141.45.
5. If a training course is conducted through an Internet-based medium, the holder of a part 141 pilot school certificate that provides such training need not comply with § 141.45(a) and (b), but must maintain in current status a permanent business location and business telephone number.
5.5 Records. Certificate holders are required to maintain records to provide proof of their enrolled students’ progress. A school is free to devise its own means of meeting the requirements of § 141.101. However, the school must demonstrate to the FAA that its recordkeeping method meets the regulatory requirements.
1. The school will be required to explain how its recordkeeping process works, as well as demonstrate that it is a permanent record. If the process uses paper, then permanent ink is necessary. The explanation and demonstration must also include a means of correcting errors. On subsequent inspections, the school must show it is continuing to maintain records in an acceptable fashion.
2. If a school chooses to maintain these records electronically, it must also show the records are as permanent and secure as paper records.
3. The jurisdictional FSDO must be provided access to examine part 141 pilot schools’ records during normal business hours.
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5.6 Training Aids. A certificate holder may use training aids to improve communication between instructors and students. Training aids are instructional aids defined by the National Education Association (NEA) as “devices that assist an instructor in the teaching and learning processes by presenting, supporting, or supplementing material, usually intermittently. They are not self-supporting.” The key factor is that such aids support, supplement, or reinforce the lesson being taught.
1. Training aids should be identified in each training course outline (TCO), and should be easily understood, readily visible, and compatible with the learning outcomes expected in the completion standards for the lesson. They must be accurate and appropriate to the course. The effectiveness of aids is judged by their organization, sequencing, pattern of logic, and overall effectiveness when used in support of obtaining the objectives and standards prescribed by the training syllabus.
2. Recent years have seen an abundance of excellent new material and techniques in training aids. The aids present many advantages for the school.
Each school must keep in mind the teaching goals to be achieved, including the continuous monitoring of student progress necessary to develop effectively the knowledge of each student according to the training syllabus.
Aids do not replace the instructor.
3. Notwithstanding the complexity or design of a training aid, the chief instructor or an authorized and qualified representative must determine through personal review or testing that the standards for each lesson have been attained when training aids are being used. The purpose of this personal review or testing is to ensure students meet the completion standards and understand missed questions, if a knowledge test is given. Only through such evaluation can the instructor make a sound determination the student should progress to the next lesson or the student requires review of subjects or procedures previously covered.
5.7 Aircraft. An Airworthiness inspector will inspect aircraft to be used by part 141 pilot schools. During the inspection, the school will demonstrate it has available aircraft appropriate for flight instruction in that course. Aircraft must meet the aircraft requirements listed in the Document Compliance Phase (see paragraph 4.12).
1. Each aircraft used by a part 141 pilot school for flight training and solo flights must comply with § 141.39 and must be inspected and maintained in with the requirements for aircraft operated for hire under part 91 subpart E. This requires aircraft used in an approved course of training to have 100-hour inspections and annual inspection, or to be maintained following a procedure prescribed under part 91, § 91.409(c).
2. Aircraft must meet the requirements of the training aircraft described in the appropriate TCO.
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5.8 Full Flight Simulators (FFS), Flight Training Devices (FTD), and Aviation Training Devices (ATD). During this phase the applicant should be prepared to demonstrate the operation of the FFS, FTD, or ATD as applied to its use in the pilot certification course and as described in the TCO. This would include presentation of the appropriate documentation required to verify current FAA qualification or approval as appropriate.
The operator is expected to ensure the ground trainer’s functionality and operation and facilitate any maintenance requirements.
5.9 Chief Instructor and Assistant Chief Instructor Tests. For designation as chief instructor or an assistant chief instructor, a person must hold the appropriate certificates and ratings, including medical certification, and must meet the pilot-in-command (PIC) requirements of 14 CFR part 61, § 61.57. During the demonstration phase, the chief instructor (and assistant chief, if one is being designated) must pass both a knowledge test and a proficiency test, as applicable. The knowledge test covers teaching methods, applicable provisions to the Aeronautical Information Manual (AIM), applicable provisions of parts 61, 91, and 141, and the objectives and approved course completion standards appropriate to the course. The proficiency test covers instructional skills and their ability to train students on the flight procedures and maneuvers appropriate to the applicable course. Both the chief and assistant chief instructor tests are administered by an FAA inspector. The school should keep a record of these tests.
5.10 Check Instructor Tests. For designation as a check instructor for a part 141 course, a person must hold the appropriate certificates and ratings, including medical certification, and must meet the PIC requirements of § 61.57, and the school must have an enrollment of at least 10 students. During the demonstration phase, a check instructor must pass both a knowledge and proficiency test on those items found in § 141.37.
A chief or assistant chief instructor gives the proficiency test. The jurisdictional FSDO must approve the check instructor. After successfully completing these tests, the chief instructor designates a check instructor in writing, and must be approved by the jurisdictional FSDO.
5.11 Flight Instructor Tests. Prior to being assigned as a flight instructor for a training course under part 141, a flight instructor must accomplish a review and receive a briefing on the objectives and standards of the training course. The flight instructor must also accomplish an initial proficiency check, given by a chief, assistant chief or check instructor in each make and model (M/M) of aircraft used in that training course.
5.12 Airports. An applicant for a part 141 pilot school certificate must show continuous use of each airport where training flights originate (airports where flights are dispatched or initiated, such as main or satellite bases).
1. Airports where flights originate must meet the requirements of § 141.38.
2. Each airport used for night training flight must have permanent runway lights.
3. Though the wind tee and tetrahedron may serve as landing direction or wind indicators, the Pilot’s Handbook of Aeronautical Knowledge (FAA-H-8083-25) and the AIM caution against using the tetrahedron