U.
S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Standardized Curricula Delivered by Part 142 Training Centers Date: 4/27/20 AC No: 142-1 Initiated by: AFS-200 Change:
This advisory circular (AC) introduces the standardized curriculum concept for Title 14 of the Code of Federal Regulations (14 CFR) part 135 training provided by 14 CFR part 142 training centers and describes the associated benefits of this voluntary approach. This AC provides guidance to part 142 training centers on how to obtain approval to deliver a standardized curriculum to part 135 operators, including guidance on how a part 142 training center may qualify its personnel as instructors and check pilots under part 135. This AC also provides guidance on how a part 135 operator may obtain approval to use a standardized curriculum as part of its training program. Voluntary use of standardized curricula for part 135 training promotes safety and increases administrative efficiency for industry. Based on these benefits, the Federal Aviation Administration (FAA) believes that most part 135 training provided by part 142 training centers will occur through standardized curricula after implementation.
This AC describes the standardized curriculum concept and clarifies that it is as an acceptable means, but not the only means, for part 142 training centers to obtain authorization to offer training and for part 135 operators to obtain approval to use such training to comply with applicable regulations. This AC is advisory in nature, thus, it is not mandatory. It does not constitute a regulation, it is not legally binding in its own right, and it will not be relied upon as a separate basis for affirmative enforcement action or other administrative penalty. Further, it does not alter regulatory requirements or authorize deviations from regulatory requirements.
The FAA will consider other means of compliance that may be presented by part 142 training centers or part 135 operators to comply with applicable statutory and regulatory requirements.
ORIGINAL SIGNED by /s/ Robert C. Carty Deputy 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 Audience1-2
1.3 Where You Can Find This AC1-2
1.4 Regulatory Requirements1-2
1.5 Background1-2
1.6 What to Consider When Reading This AC1-4
1.7 AC Feedback Form1-4
Chapter 2. St andardized Curriculum Concept2-1
2.1 Standardized Curriculum Concept Overview2-1
2.2 Standardized Curriculum2-1
F i gure 2 -1. Standardized Curriculum Training Elements2-2
2.3 Standardized Curriculum Process2-2
2.4 Implementation Timeline2-3
2.5 Standardized Curriculum Benefits2-3
2.6 Other Part 135 Curricula Delivered by Training Centers2-4
Chapter 3. Tr aining Center Instructors and Check Pilots3-1
3.1 Instructor and Check Pilot Qualification3-1
Chapter 4. Tr aining Center Authorization4-1
4.1 Training Center Request for Approval of a Standardized Curriculum4-1
Chapter 5. Part 135 Operator Approval5-1
5.1 Part 135 Operator Approval to Use an SCP5-1
1-1 CHAPTER 1. GENERAL
1.1 Purpose of This Advisory Circular (AC). This AC introduces the standardized curriculum concept for Title 14 of the Code of Federal Regulations (14 CFR) part 135 training provided by 14 CFR part 142 training centers and describes the associated benefits of this voluntary approach. This AC provides guidance to part 142 training centers on how to obtain approval to deliver a standardized curriculum to part 135 operators, including guidance on how a part 142 training center may qualify its personnel as instructors and check pilots under part 135.1 This AC also provides guidance on how a part 135 operator may obtain approval to use a standardized curriculum as part of its training program.
1.1.1 Discussion of the Standardized Curriculum Concept. Under the standardized curriculum concept, the Training Standardization Working Group (TSWG), a subcommittee to be established under the Aviation Rulemaking Advisory Committee (ARAC), will use formalized stakeholder input to develop and recommend to the ARAC standardized curricula for each aircraft fleet.2 The ARAC, after full consideration and deliberation of those TSWG recommendations, will recommend to the Federal Aviation Administration (FAA) standardized curricula for each aircraft fleet. The FAA will review the recommendations and, if acceptable, the FAA will make draft standardized curricula available for public comment through published notices in the Federal Register. The FAA may task the ARAC, through the TSWG, to use the public comments to refine its recommendations to the ARAC. The ARAC, after full consideration of the refined recommendations by the TSWG, will recommend to the FAA standardized curricula for each aircraft fleet. The FAA will review the refined recommendations and, if acceptable, publish the standardized curricula at a national level. A part 142 training center may deliver a standardized curriculum to multiple part 135 operators, which supports quality and consistency of training and checking. Voluntary use of standardized curricula for part 135 training promotes safety and increases administrative efficiency for industry.
Based on these benefits, the FAA expects that most part 135 training provided by part 142 training centers will occur through standardized curricula after the implementation of the concept.
1.1.2 Advisory Material. The material in this AC is advisory in nature and does not constitute a regulation. This guidance is not legally binding in its own right and will not be relied upon by the Department of Transportation (DOT) as a separate basis for affirmative enforcement action or other administrative penalty. Conformity with this guidance document (as distinct from existing statutes and regulations) is voluntary only, and nonconformity will not affect rights and obligations under existing statutes and regulations. The contents of this document do not have the force and effect of law and are
1 For the purposes of this AC, the term “part 135 operator” applies to any certificate holder operating under part 135.
2 The establishment of this group and its governance documentation will be separate from this AC and will be consistent with all statutory requirements governing the formation of such a group. The TSWG is expected to be composed of industry stakeholders, including manufacturers, part 135 operators, part 142 training centers, and industry trade organizations.
1-2 not meant to bind the public in any way. This document is intended only to provide clarity to the public regarding existing requirements under the law or agency policies.
1.1.3 Means of Compliance. The material in this AC is advisory in nature and does not constitute regulation. It describes an acceptable means, but not the sole means, for demonstrating compliance with applicable regulations. The FAA will consider other means of compliance that an applicant may elect to present. While these guidelines are not mandatory, they are derived from extensive FAA and industry experience in determining compliance with applicable regulations.
1.2 Audience. This AC may be valuable to:
• Part 142 training centers providing training, testing, or checking to part 135 operators.
• Certificate holders conducting operations under part 135 that use a part 142 training center for training, testing, or checking.
• Training personnel who develop and deliver training under parts 135 and 142.
1.3 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.
1.4 Regulatory Requirements. Each of the following 14 CFR parts can be found at http://www.ecfr.gov:
• Part 1, Definitions and Abbreviations.
• Part 135, Operating Requirements: Commuter and On Demand Operations and Rules Governing Persons On Board Such Aircraft.
• Part 142, Training Centers.
1.5 Background.
1.5.1 Part 142 Training Center Authority to Conduct Part 135 Training.
1.5.1.1 Part 142 contains the certification and operating rules for part 142 training centers that use Flight Simulation Training Devices (FSTD) for pilot training, testing, and checking. The authority for a part 142 training center to provide training, testing, and checking to a part 135 operator is in part 135, § 135.324.
A part 135 operator may use a part 142 training center to conduct required training, testing, and checking if the part 142 training center:
1. Holds applicable training specifications (TSpecs) issued under part 142;
2. Has facilities, training equipment, and courseware meeting the applicable requirements of part 142;
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3. Has approved curricula, curriculum segments, and portions of curriculum segments applicable for use in training courses required by part 135 subpart H; and
4. Has sufficient instructor and check pilots qualified under the applicable requirements of §§ 135.337 through 135.340 to provide training, testing, and checking to persons subject to the requirements of part 135 subpart H.
1.5.1.2 When the conditions of the regulation are satisfied, TSpecs are issued that detail the specific training that a part 142 training center may offer to part 135 operators. This AC provides guidance on how a part 142 training center can obtain authorization to deliver part 135 training and how to incorporate such authorization into its TSpecs.
1.5.2 Arrangements Between Part 142 Training Centers and Part 135 Operators. There are two potential arrangements between part 135 operators and part 142 training centers:
1.5.2.1 Dry Lease. In this case, the part 135 operator develops and maintains its own approved training curriculum, associated courseware, materials, checklists, procedures, and personnel to conduct training and checking but elects to dry lease flight training equipment and facilities from a part 142 training center.
Section 135.324(b) does not apply to dry lease arrangements because, under this arrangement, the part 142 training center does not offer training or conduct testing or checking activities. This AC provides guidance on how a part 142 training center obtains approval to deliver part 135 curricula and does not address dry lease arrangements.
1.5.2.2 FAA-Approved Part 135 Special Rule Curricula. A part 135 operator may use a part 142 training center to conduct training, testing, and checking if the part 142 training center meets the requirements of § 135.324(b) (“the special rule”).
1.5.3 Air Carrier Training Aviation Rulemaking Committee (ACT ARC). On January 21, 2014, the FAA established the ACT ARC to provide a forum for the U.S. aviation community to discuss, prioritize, and provide recommendations to the FAA concerning operations conducted under parts 121, 135, and 142, specifically addressing air carrier training. The ACT ARC Steering Committee established an Air Carrier and Contract Training Workgroup (AC&CT WG) and tasked it to consider strategies to improve part 135 operator training and checking, including training and checking conducted by part 142 training centers. The AC&CT WG produced several recommendations it believed would achieve standardization (where appropriate) and significant administrative efficiency in check pilot qualification, flight instructor qualification, and part 135 air carrier training curricula delivered by part 142 training centers. The FAA publishes this guidance to address ACT ARC recommendations.3
3 ACT ARC recommendations are available on the FAA website at https://www.faa.gov/about/office_org/headquarters_offices/avs/offices/afx/afs/afs200/afs280/act_arc/ .
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1.6 What to Consider When Reading This AC. Part 142 training centers and part 135 operators may choose to implement standardized curricula to take advantage of the safety and administrative benefits derived from the concept. The implementation of standardized curricula is strictly voluntary and is a means to comply—but not the sole means to comply—with the special rule requirements of § 135.324 and other applicable regulatory requirements.
1.7 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. STANDARDIZED CURRICULUM CONCEPT
2.1 Standardized Curriculum Concept Overview. The standardized curriculum concept provides a means to standardize curricula offered by part 142 training centers to part 135 operators to meet the training requirements of part 135 subpart H. Under the standardized curriculum concept, the TSWG will use formalized stakeholder input to develop and recommend to the ARAC standardized curricula for each aircraft fleet. The ARAC will recommend to the FAA standardized curricula for each aircraft fleet. The FAA will review the recommendations and, if acceptable, publish the standardized curricula at a national level. The standardized curriculum concept aims to provide an efficient means for approving training curricula offered by part 142 training centers while increasing the consistency of training, testing, and checking delivered to part 135 operators. The standardized curriculum concept supports the overarching goals to enhance training and checking and promote safer operational practices, and is consistent with applicable regulations.
2.2 Standardized Curriculum. An aircraft-specific standardized curriculum is a segment of the training required to serve as a pilot in part 135 operations. The standardized curriculum does not provide part 135 operators with a complete training program. It provides a segment of training delivered by a part 142 training center to part 135 operators in accordance with § 135.324(b). As required for any training conducted in accordance with § 135.324(b), the part 142 training center must qualify its personnel to provide part 135 training, testing, and checking (see Chapter 3, Training Center Instructors and Check Pilots) in order to deliver the standardized curriculum. Figure 2-1, Standardized Curriculum Training Elements, illustrates which training, testing, and checking is included in the standardized curriculum and where the standardized curriculum resides in the path to part 135 pilot qualification. A curriculum outlines the training provided. A standardized curriculum is comprised of the part 135 training curricula as well as the supporting courseware, equipment, functionality, personnel, and facilities necessary to deliver a curriculum or group of curricula.
2-2 Figure 2-1. Standardized Curriculum Training Elements
2.3 Standardized Curriculum Process. A high-level overview of the process and key participants is as follows:
2.3.1 Training Standardization Working Group (TSWG). Under the ARAC, the FAA intends to approve the establishment of the TSWG. The TSWG will be industry led and composed of subject matter experts (SME) who represent stakeholders, such as manufacturers, part 135 operators, part 142 training centers, and industry trade organizations. The FAA will publicly solicit members for the TSWG through a Federal Register notice. The TSWG’s primary function will be to use formalized stakeholder feedback to develop and recommend to the ARAC part 135 standardized curricula for each aircraft type. The FAA will make draft standardized curricula available for public comment and will publish notices of availability in the Federal Register. The public comments will be used to refine the standardized curricula that the ARAC will recommend to the FAA. The FAA will review the ARAC’s recommendation and, if acceptable, publish the standardized curricula at a national level. Once the FAA accepts and publishes a standardized curriculum for a particular aircraft type, part 142 training centers can use it to develop part 135 training. The accepted standardized curriculum may incorporate several variant aircraft depending on the complexity and practicality. The TSWG will have the ability to recommend continuous improvements to each standardized curriculum for a specific aircraft or series of aircraft.4 The FAA anticipates that the TSWG’s initial task, as a
4 The ACT ARC recommended that the standardized curriculum concept integrate meaningful data collection, audit, and validation processes (consistent with Safety Management System (SMS) principles and industry best practices) to ensure feedback and continuous improvement of standardized curricula (refer to ACT ARC Recommendation 15-9, Aircraft-Specific Part 135 Standardized Curriculum Model). The FAA supports this recommendation and may establish a voluntary safety data analysis program in a future phase of standardized curriculum implementation.
2-3 subcommittee under the ARAC, will be to recommend a master schedule for the development of standardized curricula by aircraft type.
2.3.2 Part 142 Training Center. Part 142 training centers may incorporate the standardized curriculum into a Standardized Curriculum Package (SCP). An SCP is comprised of the training curricula, the supporting courseware, equipment, functionality, forms, personnel, and facilities necessary to deliver a curriculum or group of curricula. A part 142 training center that opts to offer a standardized curriculum must first qualify its personnel to provide training and checking in accordance with § 135.324(b)(4) (see Chapter 3). The part 142 training center’s SCP is reviewed by the part 142 Training Center Program Manager (TCPM). If acceptable, the TCPM will authorize the SCP by adding it to the part 142 training center’s TSpecs.
2.3.3 Part 135 Operator. A part 135 operator considering use of an SCP should thoroughly review the content and determine if it meets its training needs. If the part 135 operator opts to use the SCP, it should consider any actions necessary to integrate the curriculum (including use of the same standard operating procedures (SOP) and checklists) into its training program. The part 135 operator requests a training program amendment through its Principal Operations Inspector (POI). The POI reviews the part 135 operator’s request for amendment and determines compliance with part 135 subpart H. After the POI determines the part 135 operator meets the regulatory requirements, the POI approves the training program amendment and issues the appropriate operations specification (OpSpec) authority, which allows the part 135 operator to use that specific SCP.
2.4 Implementation Timeline. Once the ARAC recommends a standardized curriculum for a particular aircraft and the FAA accepts and publishes it, through the process described above, a part 142 training center may decide if it wants to seek approval to offer the training, testing, and checking to part 135 operators. In accordance with the FAA’s tasking, as a subcommittee of the ARAC, the industry-led TSWG will prioritize the development of aircraft-specific standardized curricula according to industry demand and resources. The FAA anticipates that the TSWG’s initial task, as a subcommittee of the ARAC, will be to develop a master schedule for the recommendation of standardized curricula by aircraft type.
2.5 Standardized Curriculum Benefits. The standardized curriculum concept is based partly on industry recommendations to improve the part 135 training provided by part 142 training centers. The FAA supports the standardized curriculum concept because it delivers the following safety and administrative benefits:
2.5.1 Enhanced Training, Testing, and Checking. The use of a common set of SOPs eliminates the situation in which part 142 training center personnel deliver training and checking to numerous part 135 operators with widely varying objectives, standards, and procedures.
This approach allows instructors and check pilots to focus on one operational method and increases their ability to comprehensively evaluate the pilots they are checking.
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2.5.2 Leveraging Expertise. Standardized curricula are developed and recommended by the industry-led ARAC, which integrates the collective feedback and expertise from various stakeholders.
2.5.3 Streamlined Approval Process. The TCPM evaluates if the SCP developed by the part 142 training center incorporates the FAA-accepted and published standardized curriculum for the aircraft. The TCPM also evaluates if the part 142 training center meets the regulatory requirements to provide part 135 training (§ 135.324). If the TCPM approves the SCP, then the part 142 training center can offer it to part 135 operators. This eliminates the need for multiple POIs to review technical elements of the same curriculum. Instead, the POI evaluates if the curriculum (and associated standards and procedures) fits the needs of the part 135 operator.
2.5.4 Administrative Efficiency. A part 142 training center qualifies its personnel as instructors and check pilots for the part 135 standardized curriculum. This occurs through an instructor and check pilot training curriculum, which meets the requirements of § 135.324(b)(4), and is approved under part 142. This eliminates the need for individually issued check pilot letters of approval. Check pilot approvals are issued by the TCPM as part of the Training Center Evaluator (TCE) authorization.
2.5.4.1 Part 142 training centers make curricula and instructor and check pilot information available to part 135 operators. Part 135 operators may use electronic records to verify the qualifications of all instructors and check pilots that provide standardized curriculum training, checking, or testing.
2.5.4.2 A part 135 standardized curriculum listed in TSpecs may be referenced in the part 135 operator’s training program as an FAA-published curriculum in accordance with § 135.341 without the need to reproduce a physical copy of the curriculum.
2.6 Other Part 135 Curricula Delivered by Training Centers. Part 135 operators are not required to use a standardized curriculum. A part 135 operator may develop its own curriculum that meets the requirements of part 135 subpart H and request that the part 142 training center seek approval to deliver that curriculum in accordance with § 135.324(b). A part 135 operator may decide to develop its own curriculum if, for example, the standardized curriculum does not suit its operations or because no standardized curriculum will be developed for a particular aircraft.
3-1 CHAPTER 3. TRAINING CENTER INSTRUCTORS AND CHECK PILOTS
3.1 Instructor and Check Pilot Qualification. By regulation (§ 135.324(b)(4)), a part 135 operator may only use a part 142 training center to conduct required training, testing, and checking if the training center has sufficient instructors and check pilots qualified under the applicable requirements of §§ 135.337 through 135.340. Therefore, a part 142 training center must qualify its personnel to provide part 135 training and checking in accordance with §§ 135.337 through 135.340 before it delivers a standardized curriculum for aircraft-specific pilot training to part 135 operators. Parts 142 and 135 include different requirements for the qualification of instructors and TCEs/check pilots. A training center instructor or evaluator who meets the requirements of part 142 needs additional training in order to meet the requirements of part 135. Part 135 requires instructors and check pilots to satisfactorily complete the training phases for the aircraft, which includes recurrent training, and the proficiency or competency checks, which are required to serve as a pilot in command (PIC) in operations under part 135 (§§ 135.337 and 135.338). This chapter provides guidance on how a part 142 training center can qualify its personnel to provide part 135 training, testing, and checking. It does not impose new regulatory requirements, but summarizes how existing requirements apply.
3.1.1 Instructor and Check Pilot Training Curriculum. A part 142 training center should have a curriculum to qualify its personnel in accordance with §§ 135.337 through 135.340. It is important to note these regulatory sections also reference other regulatory sections.
Part 142 training center instructors and check pilots must be adequately trained for the training, testing, and checking they provide (§ 135.323(a)(1)). Part 135 requires that instructors and check pilots complete the training phases for the aircraft that are required to serve as PIC in part 135 operations (§§ 135.337 and 135.338). Accordingly, a part 142 training center should ensure that its instructors and check pilots receive comprehensive training that addresses the knowledge necessary to serve as PIC. The information in the following table correlates the various duties that a part 142 training center instructor and/or check pilot may be assigned with the applicable training and qualification regulations.
Duty Training and Qualification Regulations Ground Instructors § 135.323(a)(2) Flight Instructors (Simulator) § 135.323(a)(1) § 135.340(c) § 135.340(g) Flight Instructors (Aircraft) § 135.323(a)(1) § 135.340(c) § 135.340(e) Check Pilots (Simulator) § 135.323(a)(1) § 135.339(c) § 135.339(g)
3-2 Duty Training and Qualification Regulations Check Pilots (Aircraft) § 135.323(a)(1) § 135.339(c) § 135.339(e) Note: The FAA anticipates that the TSWG, as a subcommittee of the ARAC, will develop a standardized curriculum for the qualification of part 142 training center instructors and check pilots to conduct part 135 training. The FAA anticipates that the TSWG will develop a full curriculum for the qualification of new personnel as well as a transition curriculum for the qualification of personnel that are currently qualified to provide part 135 or part 142 training. A part 142 training center should use the published FAA standardized curriculum as described above, for instructor and check pilot training, when it develops its curriculum for this purpose.
3.1.2 Continued Qualification. The part 142 training center will provide training to ensure that instructors and check pilots remain adequately trained (§ 135.323(a)). After qualification as an instructor/check pilot under part 135, qualification can be maintained by satisfying the training and checking requirements of §§ 135.247, 135.293, 135.297, 135.337, and 135.338 and the observations required by §§ 135.339(a) and 135.340(a).
3.1.3 Transition Training. Instructors and check pilots who transition from one aircraft to another are required to complete ground training and flight training in accordance with §§ 135.339(d), (e), and (g) and 135.340(d), (e), and (g).
3.1.4 Instructor and Check Pilot Training Curriculum Approval. The TCPM is responsible for review and approval of instructor and check pilot curricula developed by the part 142 training center. These curricula are approved in the part 142 training center’s TSpecs in accordance with § 135.324(b)(3). A curriculum for part 142 training center instructor and check pilot training is intended only to qualify them in their role as a part 135 qualified instructor or check pilot at the training center. When a part 135 operator has approval to use a standardized curriculum, the part 142 training center instructors and check pilots qualified to train, test, and check that curriculum come with that approval (see Chapter 5, Part 135 Operator Approval).
3.1.5 Instructor Designations. When a part 135 operator maintains approval to use an aircraft-specific standardized curriculum, the TCPM provides authorization for part 142 training center instructors to conduct training. This authorization is found in each individual’s training record. The records of instructors qualified by the part 142 training center are made available to the part 135 operator so that the part 135 operator can review qualifications and maintain compliance with § 135.337(c) or (d).
3.1.6 Check Pilot Approvals. When a part 135 operator maintains approval to use an aircraft-specific standardized curriculum, the TCPM provides check pilot approvals for part 142 training center personnel qualified to check that curriculum. This information is found in each individual’s training record. Check pilot approvals produced by the