U.S.
Department of Transportation Federal Aviation Administration Advisory Circular Subject: Part 141 Pilot Schools, Application, Certification, and Compliance Date: 9/12/17 AC No: 141-1B Initiated by: AFS-800 Change:
Federal Aviation Administration (FAA)-certificated pilot schools are regulated in accordance with Title 14 of the Code of Federal Regulations (14 CFR) part 141. Unlike pilot training conducted under 14 CFR part 61, part 141 pilot schools are required to use a structured training program and syllabus. Part 141 pilot schools may be able to provide a greater variety of training aids and require dedicated training facilities, flight instructor oversight, and FAA-approved course curricula. Colleges and universities, which may offer aviation degrees, often provide pilot training under part 141.
This advisory circular (AC) provides guidance for part 141 pilot school applicants and others interested in the certification standards and requirements for certification under part 141. This revision updates information found in AC 141-1A, Pilot School Certification, dated February 18, 1993, including additional information on compliance with part 141, and includes a chapter on Transportation Security Administration (TSA) requirements for part 141 pilot schools.
ORIGINAL SIGNED by /s/ John S. Duncan Executive Director, Flight Standards Service
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CONTENTS Paragraph Page
Chapter 1. General1-1
1.1 Purpose of This Advisory Circular (AC)1-1
1.2 Audience1-1
1.3 Cancellation1-1
1.4 References and Related Information1-1
1.5 Definitions1-1
1.6 Background1-3
1.7 Provisional Pilot School Versus Pilot School1-3
1.8 Certification Process1-3
1.9 Where You Can Find This AC1-4
1.10 AC Feedback Form1-4
Chapter 2. Preapplication Phase2-1
2.1 General2-1
2.2 Actions Prior to LOI2-1
2.3 Pilot School Ratings2-2
2.4 TCO and Syllabus2-3
2.5 Training Records2-3
2.6 Aircraft2-3
2.7 Contact With the Jurisdictional FSDO2-4
2.8 LOI2-4
2.9 FSDO Review of the LOI2-5
2.10 The Applicant’s Responsibility2-5
2.11 The Jurisdictional FSDO’s Responsibility2-5
2.12 Joint Responsibility2-5
Chapter 3. Formal Application Phase3-1
3.1 General3-1
3.2 FAA Form 8420-83-1
3.3 Requested Part 141 Pilot School Training Courses and Ratings3-1
3.4 Signatures on FAA Form 8420-83-1
3.5 Training Course Outline (TCO) and Syllabus3-1
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3.6 TCO3-1
3.7 Syllabus Location3-3
3.8 Formal Application Meeting3-3
3.9 Electronic Recordkeeping/Manual/Signature Systems3-3
3.10 Signature Authenticity/Verification3-4
3.11 FAA Acceptance of Electronic Recordkeeping, Signature, and/or
Manual Systems3-5
3.12 Syllabus Content3-5
3.13 Syllabi With Reduced Time Requirements3-6
3.14 Syllabus Stage Checks and End-of-Course Tests3-6
3.15 Commercially Developed Training Syllabi3-6
3.16 Internet-Based Training3-7
3.17 Training Agreements3-7
3.18 Chief Instructor3-7
3.19 Assistant Chief Flight Instructor3-8
3.20 Chief Instructor and Assistant Chief Instructor Test3-8
3.21 Chief Instructor and/or Assistant Chief Instructor Who Also
Provides Instruction3-8
3.22 Chief and Assistant Chief Instructor Availability3-8
3.23 Flight Instructor Requirements3-8
3.24 Flight Instructor Responsibilities3-9
3.25 Other Part 141 Pilot School Personnel3-9
3.26 TCO Approval3-10
3.27 Application Denial3-10
Chapter 4. Document Compliance Phase4-1
4.1 General4-1
4.2 Student Training Records4-1
4.3 Credit for Previous Training4-1
4.4 Student Enrollment Certificate4-2
4.5 Student Graduation Certificate4-2
4.6 Chief Instructor Qualifications/Training Record4-3
4.7 Assistant Chief Instructor Qualifications/Training Record4-3
4.8 Check Instructor Qualifications/Training Record4-4
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4.9 Flight Instructor Qualifications/Training Record4-4
4.10 Student Safety Guide4-4
4.11 Full Flight Simulators (FFS), Flight Training Devices (FTD), and
Aviation Training Devices (ATD)4-5
4.12 Aircraft Requirements4-6
4.13 Aircraft—Checklist and Manuals4-6
4.14 Aircraft—Instrument Training4-7
4.15 Aircraft—Commercial Training4-7
4.16 Document Deficiencies4-7
Chapter 5. Demonstration And Inspection Phase5-1
5.1 General5-1
5.2 Facilities Inspection5-1
5.3 Principal Business Office5-1
5.4 Pilot Briefing Areas5-1
5.5 Records5-2
5.6 Training Aids5-3
5.7 Aircraft5-3
5.8 Full Flight Simulators (FFS), Flight Training Devices (FTD), and
Aviation Training Devices (ATD)5-4
5.9 Chief Instructor and Assistant Chief Instructor Tests5-4
5.10 Check Instructor Tests5-4
5.11 Flight Instructor Tests5-4
5.12 Airports5-4
5.13 Airports—Satellite Bases5-5
5.14 Terminating the Demonstration and Inspection Phase5-6
Chapter 6. Certification Phase6-1
6.1 Completion of Reports6-1
6.2 Air Agency Certificate Number6-1
6.3 Air Agency Certificate Information6-1
6.4 List of Approved Ratings and Courses6-1
6.5 Certification File for Applicant6-1
6.6 Display of Certificate6-2
6.7 Certification Denial6-2
v Chapter 7. Other Certification Information, Post-Certification, and
Acceptable Practices7-1
7.1 Advertising7-1
7.2 Ongoing Documentation7-1
7.3 Training Records7-1
7.4 Inspections7-1
7.5 Inspection of Aircraft Maintenance Records7-1
7.6 Maintenance Facilities7-2
7.7 Contract Maintenance7-2
7.8 Examining Authority7-2
7.9 Renewal of a Part 141 Pilot School’s Certificate7-3
7.10 Changing the Location of the Principal Business Office or
Base of Operations7-3
7.11 Change in Chief and/or Assistant Chief Instructors7-3
7.12 Flight Instructor Refresher Courses (FIRC) (Part 141 Appendix K)7-4
7.13 Institution of Higher Education With Letters of Authorization (LOA) to Certify Its Graduates for an Airline Transport Pilot (ATP) Certificate With
Reduced Aeronautical Experience7-4
Chapter 8. Flight Training of U.S. Citizens and Foreign Nationals8-1
8.1 Background8-1
8.2 Title 49 CFR Part 15528-1
8.3 Categories of Training Under TSA8-1
8.4 Flight Training for U.S. Citizens8-2
8.5 Recordkeeping Requirements8-2
8.6 The Student and Exchange Visitor Program (SEVP)8-2
8.7 Schools Certified by SEVP8-3
Appendix A. Application InformationA-1
Appendix B. Sample Training Course Outline and SyllabusB-1
Appendix C. References and Additional Information (Current Editions)C-1
Appendix D. Frequently Asked Questions (FAQ)D-1
Appendix E. Part 141 Pilot School Simulation Training Credit AllowancesE-1
vi List of Figures
Figure A-1. Sample Air Agency CertificateA-1
Figure A-2. Sample Application for Pilot School CertificationA-2
Figure A-3. Sample Letter of IntentA-4
Figure A-4. Sample Letter of Intent—Electronic Recordkeeping and
Electronic SignatureA-5
Figure B-1. Sample Training Course OutlineB-1
Figure B-2. Sample SyllabusB-4
Figure B-3. Training Course Outline ChecklistB-8
Figure B-4. Syllabus ChecklistB-9
Figure E-1. Simulation Credit TableE-1
Figure E-2. Airline Transport Pilot (ATP) Simulation Credit TableE-1
1-1 CHAPTER 1. GENERAL
1.1 Purpose of This Advisory Circular (AC). AC 141-1, Pilot School Certification, was issued on August 29, 1974 and was revised on February 18, 1993. AC 141-1 was designed to assist in the certification of Title 14 of the Code of Federal Regulations (14 CFR) part 141 pilot schools. Since 1993, the Federal Aviation Administration (FAA) has made several amendments to part 141, which are reflected in this updated version.
Additionally, after the events of September 11, 2001, the Transportation Security Administration (TSA) implemented requirements on the training of foreign nationals in the United States. This revision updates guidance on part 141; provides guidance on application, renewal, amendment, and compliance under part 141; and adds information on TSA requirements. FAA regulations can be found at: https://www.faa.gov/regulations_policies/faa_regulations/.
1.2 Audience. The primary audience for this AC includes persons seeking certification for a part 141 provisional pilot school or pilot school, certificated provisional pilot schools and pilot schools, and provisional pilot schools and pilot schools seeking to renew their certificates. The secondary audience includes FAA Flight Standards District Offices (FSDO) and principal inspectors (PI) assigned oversight of certificate holders conducting operations under part 141.
1.3 Cancellation. AC 141-1A, Pilot School Certification, dated February 18, 1993, is cancelled.
1.4 References and Related Information. Appendix C contains a list of references and related information.
1.5 Definitions. The following definitions apply to this AC and to the certification, renewal, and operation of a pilot school under part 141 (refer also to AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals):
1.5.1 Air Agency Certificate. An Air Agency Certificate is required for operation as a certificated pilot school under part 141, and is issued using FAA Form 8000-4, Air Agency Certificate.
1.5.2 Aviation Training Device (ATD). A training device, other than a full flight simulator (FFS) or flight training device (FTD), that has been evaluated, qualified, and approved by the Administrator. In general, an ATD includes a replica of aircraft instruments, equipment, panels, and controls in an open flight deck area or an enclosed aircraft cockpit. It includes the hardware necessary to represent a category and class of aircraft (or set of aircraft) operations in ground and flight conditions having the appropriate range of capabilities and systems installed in the device.
1.5.3 Certification Course. A certification course is a training course for a certificate or rating normally accomplished by a student from “zero time” to completion and prescribes the curriculum within a particular subject such as a recreational pilot course, private pilot course, or other listed approved training course.
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1.5.4 Certification Job Aid. A checklist used by the jurisdictional FSDO to ensure the part 141 pilot school applicant has met all of the requirements for the issuance of an Air Agency Certificate.
1.5.5 Certificated Pilot School. A part 141 pilot school applicant meeting the pertinent requirements of part 141 that has been issued an Air Agency Certificate. This term, as well as part 141 pilot school, as used in this AC, refers to both provisional pilot schools and pilot schools.
1.5.6 Check Instructor. A check instructor is authorized to conduct student stage checks, end-of-course tests, and proficiency checks.
1.5.7 Curriculum. The courses offered by a part 141 pilot school. A set of courses depicting planned flight and/or ground instruction offered by a part 141 flight or ground school.
Curricula are contained in a training course outline (TCO).
1.5.8 Examining Authority. The authority granting the holder of a pilot school certificate to conduct practical tests of its own graduates for the issuance of pilot certificates and ratings without further testing by the FAA.
1.5.9 Jurisdictional Flight Standards District Office (FSDO). The FAA FSDO assigned to a part 141 pilot school that provides certification and oversight to that school.
1.5.10 Lesson Plan. An organized outline for a single instructional period. It is a necessary guide for the instructor because it outlines what to do and in what order to do it, and what procedures to use in teaching the material of a lesson. Lesson plans should be prepared for each training period and be developed to show specific knowledge and/or skills to be taught.
1.5.11 Letter of Authorization (LOA). Issued to a part 141 pilot school by the jurisdictional FSDO as a standardized set of authorizations and approvals through the Web-based Operations Safety System (WebOPSS), in lieu of individual LOAs and approvals.
1.5.12 Letter of Intent (LOI). A letter sent to the jurisdictional FAA FSDO notifying the office of intent to submit an application for certification as a part 141 provisional pilot school.
1.5.13 Pilot School Rating. A part 141 pilot school is issued a rating for each of its approved courses. A part 141 pilot school rating is not to be confused with an airman certification rating, such as an instrument rating.
1.5.14 Provisional Pilot School. A part 141 pilot school that does not meet the requirements of § 141.5, but does meet the requirements of § 141.7 when its Air Agency Certificate is issued.
1.5.15 Satellite Base. A location other than the main operations base where approved ground or flight training courses are conducted.
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1.5.16 Schedule of Events (SOE). A timetable provided by the applicant and accepted by the certification team, setting a reasonable expectation for the progression of the certification process.
1.5.17 Syllabus. An outline and summary of topics to be covered in a training course, textbooks, and other material used in the course. It is a step-by-step (building block) progression of learning with provision for regular review and evaluation at prescribed stages of learning. The syllabus defines the unit of training, states by objective what the student is expected to accomplish during the unit of training, shows an organized plan for instruction (building blocks, from the simple to the complex), and dictates an evaluation process for either the unit or stages of learning. A syllabus is contained within a training course outline (TCO).
1.5.18 Tablet. A wireless general purpose mobile computer with a touchscreen display.
1.5.19 Training Course Outline (TCO). A document describing the content of a particular course through a statement of objectives, description of teaching aids, definition of evaluative criteria, and indication of desired outcomes.
1.6 Background. Part 141 prescribes rules governing the operation of part 141 pilot schools and their use of course curricula for pilot training under this part. This ensures that training by a part 141 pilot school is adequate, appropriate, and administered by qualified persons. Compared to 14 CFR part 61, flight time requirements for completing a course under part 141 are often reduced, in large part because part 141 training is more controlled through the structured courses approved by the FAA. Training is overseen by experienced chief instructors, and all instructors must have familiarization training and proficiency checks in the types of aircraft in which they provide training. Additionally, certificated schools receive regular surveillance from the FAA.
1.7 Provisional Pilot School Versus Pilot School. An applicant for an Air Agency Certificate meeting the requirements of § 141.7 is issued a provisional pilot school certificate as initial certification under part 141, as the applicant will not have met the recent training activity requirements of § 141.5(d). It is a prerequisite for a part 141 pilot school to hold certification as a provisional pilot school before it may apply for a pilot school certificate. An applicant for a pilot school certificate must meet all of the requirements of § 141.5, including graduating at least 10 different people and establishing a pass rate of 80 percent or higher. Once a provisional pilot school has met all of the requirements of § 141.5, and all other pertinent sections within part 141, it may apply for a pilot school certificate.
1.8 Certification Process. The certification of a part 141 pilot school is accomplished through a five-phase certification process. This includes (1) preapplication, (2) formal application, (3) document compliance, (4) demonstration and inspection, and
(5) certification.
1.8.1 Preapplication Phase. The applicant initiates the process leading to certification as a provisional pilot school. The applicant contacts the jurisdictional FSDO to obtain
1-4 pertinent information concerning a path to certification as a provisional pilot school.
The applicant meets with one or more inspectors from the office (the certification team), who explain the certification process and can answer the applicant’s questions.
1.8.2 Formal Application Phase. The applicant submits the formal application, FAA Form 8420-8, Application for Pilot School Certification; an LOI; TCOs, including a syllabus that is contained in the TCO; a safety procedures guide; all other applicable documents required by part 141; and any other applicable FAA guidance and as outlined during the preapplication meeting.
1.8.3 Document Compliance Phase. The certification team reviews all relevant documents for completeness and compliance. Should there be items missing or not in compliance, the team may delay the review process until the required corrections are submitted.
1.8.4 Demonstration and Inspection Phase. Testing of the chief instructor and any assistant chief instructors, if applicable, by the FAA takes place, along with all required inspections. During this phase, the applicant will have to demonstrate it is capable of delivering training that is expected to meet the objectives of its TCO.
1.8.5 Certification Phase. When all requirements are satisfied, the FAA will issue the letters to the applicant, indicating approval of courses and pilot school ratings based on the TCOs submitted to the certification team. The applicant is then issued a Provisional Pilot School Air Agency Certificate.
1.9 Where You Can Find This AC. You can find this AC on the FAA’s website at http://www.faa.gov/regulations_policies/advisory_circulars.
1.10 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.
2-1 CHAPTER 2. PREAPPLICATION PHASE
2.1 General. This chapter will discuss the preapplication phase, in which the applicant generates and submits a Letter of Intent (LOI) to the jurisdictional Flight Standards District Office (FSDO). Contact information for FSDOs can be found at http://www.faa.gov/about/office_org/field_offices/fsdo/.
2.2 Actions Prior to LOI. Before contacting the jurisdictional FSDO, a prospective applicant is encouraged to evaluate its capability to meet the initial certification, as well as the ongoing requirements of a 14 CFR part 141 pilot school. Some considerations include:
1. Will the prospective applicant for a provisional pilot school certificate have adequate personnel, adequate certified flight and ground instructors, a chief instructor, and aircraft meeting the requirements of part 141?
2. Do the proposed chief instructor and any assistant chief instructors, if applicable, meet the requirements of part 141, §§ 141.35 and 141.36?
3. Will check instructors be utilized, and do they meet the requirements of § 141.37?
4. Does the applicant have continuous use of each airport at which training flights originate?
5. Does each airport used by the part 141 pilot school meet the requirements of § 141.38(b) through (f)?
6. Does the applicant intend to utilize satellite bases, and how will compliance with § 141.91 be achieved?
7. What aircraft will be utilized in the course(s) the applicant is seeking and who will maintain these aircraft? How will the applicant comply with § 141.39?
8. If the applicant proposes to utilize full flight simulators (FFS) or flight training devices (FTD), has the FFS or FTD received National Simulator Program (NSP) evaluation and an approval letter in the past 12 months?
Has the applicant received training on the use of these devices? Does the FFS/FTD comply with § 141.41(a)?
9. If the applicant plans to use aviation training devices (ATD), have the ATDs received an FAA letter of authorization (LOA) from the General Aviation and Commercial Division (AFS-800) within the past 5 years? Has the applicant received training on the use of the trainer? Does the ATD comply with § 141.41(b)?
10. Will pilot briefing areas be in place as required under § 141.43?
11. Does the applicant intend to use electronic recordkeeping and/or signatures, in accordance with Advisory Circular (AC) 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals?
12. Does the applicant propose to submit electronic documents?
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13. Will the Internet be utilized for the delivery of classroom instruction or other purposes, such as filing flight plans? If yes, how will the applicant comply with § 141.53(d)?
14. Does the applicant understand its responsibility to maintain ongoing compliance with the standards regarding its aircraft, facilities, and personnel as specified in an approved training course outline (TCO) in accordance with § 141.89?
15. Have the limitations in advertising under § 141.23 been considered?
16. What TCO and syllabus does the school plan to use for each course? Does the school plan to use a commercially developed syllabus, or will they develop their own?
2.3 Pilot School Ratings. An applicant should review § 141.11 and the appendices of part 141 and determine what course(s) will be part of the initial application package.
The term “pilot school rating” as used in § 141.11 describes the certification and rating courses that are approved for part 141 pilot schools. Pilot school ratings are listed on a part 141 pilot school’s Air Agency Certificate. Examples of pilot school ratings include Recreational Pilot, Private Pilot, and Commercial Pilot. Courses are approved under § 141.55. There are more than 40 different courses, with each requiring a separate TCO and separate syllabus. The typical courses include:
1. Recreational pilot certification courses: Airplane Single-Engine Land (ASEL), rotorcraft helicopter, and rotorcraft gyroplane.
2. Private pilot certification courses: ASEL, Airplane Multiengine Land (AMEL), Airplane Single-Engine Sea (ASES), Airplane Multiengine Sea (AMES), rotorcraft helicopter, gyroplane, glider, lighter-than-air airship, lighter-than-air gas balloon, lighter-than-air balloon with an airborne heater, and powered-lift.
3. Commercial pilot certification courses: ASEL, AMEL, ASES, AMES, rotorcraft helicopter, rotorcraft gyroplane, glider, lighter-than-air airship, lighter-than-air gas balloon, lighter-than-air balloon with an airborne heater, and powered-lift.
4. Instrument rating courses: airplane, helicopter, and powered-lift.
5. Airline transport pilot (ATP) certification courses: ASEL, AMEL, ASES, AMES, rotorcraft helicopter, and powered-lift.
6. Flight instructor certification courses: airplane single-engine, airplane multiengine, rotorcraft helicopter, rotorcraft gyroplane, glider, and powered-lift.
7. Special preparation courses: pilot refresher courses, flight instructor refresher course, ground instructor refresher course, agriculture aircraft operations course, rotorcraft external load-operations course, special operations course, test pilot course, and Airline Transport Pilot Certification Training Program (ATP CTP).