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Hey FAA, IT’S TIME FOR A CHANGE! | Aviation Management Experience Deficit

Posted 1 years 111 days ago ago by Admin

The general aviation industry is hemorrhaging pilots to the airlines, and it doesn’t appear that this practice will slow soon. For decades, helicopter pilots were not a targeted market for the airline industry, but times have changed. Qualified and highly skilled helicopter pilots have their own path to airline selection from both military and civilian backgrounds. This situation has placed a strain on the helicopter industry to obtain and retain qualified aviation management personnel. 

Early in my career, I was given an opportunity to apply for a Part 135 chief pilot position. This was an exciting opportunity; however, I did not meet the regulatory requirements for the position. My employer, fully supportive of my selection for the position, applied to the Federal Aviation Administration (FAA) for an exemption.  That exemption would provide the path for my appointment to the chief pilot role. I was interviewed by the FAA and found satisfactory, and my career within Part 135 management began. 

At the time of my Part 135 chief pilot appointment, I was well rooted in the rotorcraft industry and planning for a long career with helicopters. My flight experience was approximately 2,000 flight hours but with only two years as a Part 135 pilot-in-command. With a minimum requirement of at least 3 years of pilot-in-command experience, within the past 6 years, to be eligible for the chief pilot role, this was an issue requiring the exemption request. To be clear, I had been fulfilling the role of chief pilot from a workload perspective for some time, so the FAA interview that occurred to facilitate my exemption was rather anticlimactic.

Today, with qualified staffing shortages plaguing the helicopter industry, are the requirements to hold aviation management positions realistic?

The chief pilot is not required to be more proficient than any other Part 135 pilot. The chief pilot’s role is to provide a management interface with the FAA regarding the pilot staff as directed by the director of operations. Pilot mentorship and guidance to enhance the operational safety of the organization and to support good aeronautical decision making is a positive attribute and critical capability to this role.

The FAA has held that proficiency checks are the preferred method of evaluating pilots under Part 135. Although an hour metric is required in accordance with 14 CFR Part 135.243(b), it is the pilot’s ability to pass a proficiency check that earns the ability to fly as a Part 135 pilot-in-command. Of course, this makes complete sense. 

Why then does the chief pilot position require so many years of experience? Many very competent pilots have moved into management roles as I’ve described only rising to their own level of incompetence. Why? Because of a complete lack of training for their new role. This must change.

Is it possible for a pilot not meeting the current regulatory experience requirements to fulfill an aviation manager role, such as Part 135 chief pilot, safely and effectively? I may be biased, but I say— Yes! 

My enthuisiastic claim does not come without the realism that not all pilots will be capable of making this leap without maturing in the industry first. There are exceptions, but with severe shortages of qualified helicopter pilots and aviation managers, the adverse effect on our industry is becoming more and more apparent if we don’t provide early management opportunities and training. As described, Part 135 has a path for an exemption for aviation managers lacking required experience. This exemption may be applied for at the local FAA office level. 

The Part 141 pilot training industry is finding its own set of challenges for their management cadre as well. FAA experience requirements for Part 141 aviation management staff, including chief and assistant flight Instructor positions, are becoming very hard to find and retain. By the time a pilot achieves the requirements to hold one of these positions, he has surpassed the minimum requirements for airline selection or a more advanced helicopter position as well.  

A Part 141 chief instructor to be eligible for the more advanced certificates and ratings has a minimum of 2,000 flight hours pilot-in-command and 1,500 flight hours of instruction given. In today’s industry, pilots with this level of experience are already working in the field. Since Part 141 pilot schools may not operate without a chief flight Instructor, alternative processes like using an FAA designated pilot examiner (DPE) to aid with student stage checks during training are often utilized, but this is a short-term solution and one with very limited capability. 

In contrast to the airlines or large helicopter operators, there are limited funds available for staff compensation in flight training. Flight training is a pay-to-play process and the rate of pay for staffing directly contributes to the price of flight training charged to the customer. For staffing shortages and employment retainment issues, the industry often cites compensation as a culprit. With lowering thresholds to move into higher paying jobs combined with limited abilities to increase tuition for flight training, an easy solution to attract and retain Part 141 management staff is challenging.

Adding to the challenge is the lack of regulatory process to request an experience exemption for a Part 141 chief or assistant chief flight Instructor. That process doesn’t exist. Part 141 pilot schools are falling victim to this experience deficit and the situation is only getting worse. The choice on the table for Part 141 schools experiencing these staffing challenges is to continue operating in a non-compliant manner—or close. It’s very sad, but we’re seeing many pilot schools choosing the latter option. This fact is only adding to the pilot shortage and stimulating a steady trend of flight instructor skill degradation.

I believe it's time for the FAA to move away from arbitrary experience requirements for aviation management positions. Having a minimum standard is not a bad idea, however always having a proficiency based alternative is key to improving, growing, and sustaining a healthy aviation industry. 

Hey FAA, it’s time for a change! 

About the Author: Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award. Rowles is the owner/president of Helicopter Institute.

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