135 New Company Training

[ljcms]

We have just moved an aircraft from on management company to another and have run into the issue that the FAA is requiring us to retrain on the airplane(5 day recurrent). I was just wondering if anyone else has run into this.

 

[Maurus]

To clear this up, you mean an aircraft changed owners but is still under the same Part 135 operating certificate?

For some reason this sounds like some sort of insurance thing instead of FAA.

 

[gne in prog]

To clear this up, you mean an aircraft changed owners but is still under the same Part 135 operating certificate?

For some reason this sounds like some sort of insurance thing instead of FAA.

I'm pretty sure he means same owner, new management company. Having to go back to recurrent isn't that uncommon in that scenario, especially if it's a different poi. Dumb, but not uncommon.

 

[SteveC]

I agree it seems pretty silly, but the requirement is for each 135 operator to have their own training program, and for all pilots to train under THAT specific program. Almost identical doesn't count. Not saying I agree with it, but that's often the way it is. The only possible work-around I can think of is if you had full up-front access to both training programs and were able to convince the POI to train the differences, but that's a real long shot.

 

[ljcms]

Yeah sorry for the confusion. Same aircraft new management company. They way it is coming across is that all contract work for 135 is null and void unless you have trained under each certificate holder. I have always worked under the fact that I can go to simulator training for a particular type, then do an indoc and company specific training and would then be good to go as an SIC. If I wanted to contract as a PIC I would then only need a 299 ride for each operator. Now they are telling me I need simulator, company specific, and indoc for each operator I would work for. If I contract out the 3 or 4 different operators on the field that would work out to tens of thouands of dollars for the same training, but company specific. 135 contract work is dead at my airport if all this is all true.

 

[Maurus]

I would say this reg will explain this a bit.

(a) Initial, transition, upgrade, and differences training for pilots must include flight and practice in each of the maneuvers and procedures in the approved training program curriculum.
(b) The maneuvers and procedures required by paragraph (a) of this section must be performed in flight, except to the extent that certain maneuvers and procedures may be performed in an aircraft simulator, or an appropriate training device, as allowed by this subpart.
(c) If the certificate holder's approved training program includes a course of training using an aircraft simulator or other training device, each pilot must successfully complete—

(1) Training and practice in the simulator or training device in at least the maneuvers and procedures in this subpart that are capable of being performed in the aircraft simulator or training device; and
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(2) A flight check in the aircraft or a check in the simulator or training device to the level of proficiency of a pilot in command or second in command, as applicable, in at least the maneuvers and procedures that are capable of being performed in an aircraft simulator or training device.
​

Each certificate holder has their own training program and they must send each pilot through their own training program.

 

[gne in prog]

I agree it seems pretty silly, but the requirement is for each 135 operator to have their own training program, and for all pilots to train under THAT specific program. Almost identical doesn't count. Not saying I agree with it, but that's often the way it is. The only possible work-around I can think of is if you had full up-front access to both training programs and were able to convince the POI to train the differences, but that's a real long shot.

I understand that, and the reg quoted, but I still think it's a waste. Flight safety and the other training providers only train the aircraft, not op spec stuff. Assuming you work at certificate a, and you're going to certificate b. If certificate a's op specs are the same or more restrictive than b, then ideally they would just require a line check. If certificate b is more restrictive than company a, then require a recurrent.

Obviously, indoc should be required, as that's where the real differences in the certificate holders are going to be learned.