Devising a Training Plan for a Part 91 Flight Department, Part 1

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In aviation, we train to obtain knowledge and skills for initial qualification and certification as pilots and flight instructors, maintenance techs, flight dispatchers and flight engineers (if there are still any out there “flying sideways” in first-generation jetliners) and then periodically undergo recurrent training to review, reinforce and, in some cases, re-qualify for those disciplines.

What is required in the U.S. for training and certification of pilots by the FAA was set forth in FAR Part 61 during the mid-20th century. The rules, which have not changed much in more than 70 years, are specific in terms of initial training, flight time and post-certification recurrent training. But on the operational side under Part 91, where many holders of Commercial Pilot and Airline Transport Pilot Certificates will eventually find employment in business aviation flight departments, the regulation itself is fairly vague in terms of training expectations other than pilot-in-command and second-in-command requirements and recurrent training for compliance under Part 61.58. (Commercial operations governed by Parts 135 and 121, on the other hand, are much more specific in terms of training requirements.)

So, in devising a training plan for a noncommercial operation under Part 91, how would an aviation manager hired to put together a new flight department proceed? Obviously, the emphasis is going to be placed on designing a training regimen to reinforce competency and promote safety and risk management. The first two of these qualifiers is the obvious reason why we train; the third is a more recent component introduced to the operational realm by safety-management systems like the International Standard for Business Aircraft Operations (IS-BAO) and Flight Operational Quality Assurance (FOQA), the former introduced by the International Business Aviation Council (IBAC) and the latter by the FAA and oriented primarily toward commercial operators.

A ‘Wide Birth’ Under Part 91

Conceding that training “is given a wide berth by Part 91,” Dan Boedigheimer, founding partner at Advanced Aircrew Academy, went on to observe that “little training is specified,” and the FAR only requires a Part 61.58 qualification for pilots. Originally, when the rules were formulated, this had to be conducted in the relevant aircraft for which the pilot was seeking a type rating (or a recurrent check) but now is permitted in a flight simulator covered under Part 142 at an OEM or training organization that has made the very expensive investment in the device.

“So, Part 61.58 allows training and a check for compliance,” Boedigheimer says. “It is aircraft-specific training. You can qualify the right-seat occupant to be second in command [SIC] in-house, but most insurance companies require simulator training for both pilots, depending on the type of aircraft and the experience level of the pilots. So, you will probably send both the pilot in command [PIC] and SIC to a Part 142 center for initial and recurrent qualification.”

Given this, our new av manager’s first priority will be to ensure their PICs and SICs are properly qualified. Concerning the latter, a chief pilot we know commented that “SICs will have lower requirements: Can you train him or her in the airplane? Sure, but try and justify that with your insurance people. Also, the PIC may not be suited to train an SIC in the airplane, as not all captains are good teachers. Sometimes your insurance company may have stronger requirements than the FAA.”

Beyond basic pilot qualifications, the flight department’s mission, or the nature of its operations, will determine what training will be necessary and how often it must be refreshed. If the flight department will be operating only domestically, a small set of FAA approvals will more than likely be necessary. On the other hand, if international operations are intended, then more approvals will be required. These, of course, are in the form of FAA Letters of Authorization, or LOAs, and for Part 91, they frame the operator’s mission, or what kind of flying the flight department can legally perform.

“The only other thing that will drive training from the FAA’s perspective is the LOAs that the operator may hold,” Boedigheimer says. “This is where, for example, international procedures training will come in, as you may have to hold up to 11 of these LOAs, and we track about nine of them at AAA.” This collection, typical of international ops in oceanic airspace, includes A56 for controller pilot data link communications (CPDLC); B34, area navigation systems; B36, oceanic and remote nav using multiple nav systems; B37, Central and East Pacific airspace; B38, North Pacific airspace; and B39, North Atlantic high-level airspace.

“The LOAs then specify what you must train for,” Boedigheimer adds. “You will have to have a manual explaining how you will train to comply with the authorizations. And this therefore becomes very operator-specific, as the requirement is coming out of the LOAs the operator holds. So, you may add in operator-specific requirements that the FAA has approved in the LOA. In addition to these, the operator may also hold LOAs for the minimum equipment list [MEL] and RVSM [reduced vertical separation minimum].”

Next, there may be a requirement for precision runway monitoring (PRM) at some airports, not an LOA but a requirement for operations into some airports. Certain RNP-AR (required navigation performance authorization required) approaches also require this, and a periodic refreshment will need to be included in the operator’s training plan. Note that all these requirements driven either by LOAs or the above procedures may or may not specify training intervals, or how often the operator’s pilots must review and reinforce their knowledge and competency, and in the latter case the training interval may be determined at the discretion of the operator. This is where a safety management system (SMS) or simply the flight department’s operations manual can be used to determine the training schedule, e.g., annually or biennially.

The foregoing represents the bare minimum for compliance. “But the Occupational Safety and Health Administration [OSHA] will require training, too, under CFR Part 1910,” Boedigheimer points out. “Also, if operating internationally, there are the ICAO Annexes--the state you are operating to may adopt these as their state regulations.” (And remember, when flying internationally, an operator is obliged to observe the rules of the state in whose airspace it is operating.) As an example, these rules may require training for carrying dangerous goods and the recognition of them. “You may not carry them,” Boedigheimer said, “but you have to be able to identify them.” Or anything going into your airplane.

Need For ‘Evidence-Backed’ Training

Beyond the minimum requirements enumerated here, Boedigheimer looks at adopting best practices and strategies for managing operational risk. “These would be covered under IS-BAO and the Business Aviation Safety Consortium [BASC],” he says, “and these would drive additional training requirements over and above the minimums. Adopting these standards can go a long way toward managing risk in my [hypothetical] flight department and may give me some insurance discounts and benefits, as well. So, consider adopting these, too.”

But training must be relevant if it is to be truly effective, and this admonition factors into an ongoing discussion within the aviation industry--especially business aviation--about whether recurrent training should be structured around existing operational deficiencies, i.e., accident trends like runway excursions or unstabilized approaches. Thus, it should mirror the dynamic nature of operations.

According to Nat Iyengar, a senior international Gulfstream 650 captain with Jet Aviation and member of the NBAA International Operations Committee, there is a pressing need for “evidence-backed training” addressing negative trends that have emerged across the fleet. “The biggest problem is that over the years the FAA keeps adding items to training, so now a training event becomes a checking event rather than a training exercise,” he told BCA. “There is a big push from the industry to do evidence-backed training--what issues we are seeing, what failures. You need to have this option to address nescient problems--what ‘hot’ trends we are seeing in the field.” For example, unstabilized approaches continue to be a problem, as is “landing long” while attempting to do “greaser” landings to impress the passengers--with the consequent result of overshooting the runway. “So, we [at Jet Aviation] are not doing the same check ride we have done for 50 years. We are now dealing with a totally different technology than half a century ago, anyway. But Part 61 hasn’t adapted to the new technology.”

While Jet Aviation, a major international charter/management company overseeing a huge fleet of business jets, has the resources to design its own training regimen, a small Part 91 flight department, especially one with limited resources, is often forced to follow the existing regulation-driven syllabus for recurrent training. “They will do the same training they’ve done for years,” Iyengar says. “There is nothing original to their training. What resources do you have financially? FlightSafety International does offer an enhancement program, a four-hour, half-day, go/no-go course or a CRM [cockpit resource management] course, involving several hours in the classroom and several more in the simulator. But you have to have the money to support that. The reality is that Part 91 requirements are obsolete--they don’t address the modern SMS world we are living in now. We need more evidence-based training, copying the successful airline programs that allow the training center to provide a more flexible training.”

So to be relevant, Iyengar believes, “you have to design your own training and be willing to pay for it.  How do you want to operate, to the regulatory level—the very minimum required training—or the effective, real-world level?  There is no training level under Part 91 to create an AQP [Advanced Qualification Program].  You have to be doing additional work.  The only thing I have to do for my aircraft-specific training is to complete my Part 61.58 recurrent every twelve months.”

Customizing the syllabus allows for Iyengar’s inclusion of “hot topics,” or training that addresses dangerous trends in the field. “We have a training module on runway excursions,” Boedigheimer says. “We track them all--25 to 30 a year--and whether we should we modify the training for them--for example, what has happened recently in business aviation where we operate into out-of-the-way airports that may not be monitored. We looked at 12 of these last year where the crews got outdated information on the actual conditions of the runways they were headed for: In other words, the conditions had changed. These [weather-related conditions] are dynamic changes and need to be tracked, especially at uncontrolled airports. They are business-aviation-specific operating conditions.”

In devising a training plan that is relevant to problem trends, operators are also encouraged to frequently check out the NBAA’s top safety focus areas, i.e., the biggest risks globally for business aviation. The NBAA Safety Committee has identified these safety focus areas, including upset prevention and recovery training (UPRT), runway excursions, controlled flight into terrain, and ground and maintenance accidents.

Editor's note: This is the first of a three-part article on Part 91 training. The next two parts will run this week.


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