FAA Responds to NBAA Concerns Over PIC Line Check Requirements

April 17, 2023

The FAA responded positively to comments from NBAA’s Part 135 Subcommittee regarding the ability to secure necessary checkride opportunities for business aviation flight crews and offered new guidance to assist operators in accomplishing these required checks.

The industry first raised concerns with the agency in 2016 about the requirements under 14 CFR 135.299, “Pilot in Command Line Checks,” and the inability to accomplish checks through traditional means. The NBAA Part 135 Subcommittee requested further guidance on the matter in November 2022, noting the situation had only grown more difficult in the aftermath of the pandemic.

“Due to current policy, operators rely heavily on local inspectors, but FAA national resources (FSIRP) as well as local FSDO resources are depleted,” read the subcommittee’s letter. “These issues are further amplified due to constraints on inspector travel and training for both industry and FAA. Consequently, operators are forced to ground pilots and aircraft, resulting in significant financial losses.”

Read the subcommittee’s full letter to the FAA.

In his recent response, Robert Ruiz, director of the FAA’s Office of Safety Standards, acknowledged these difficulties and welcomed NBAA’s suggestions for mitigating them, including expanded use of contract check pilots and other resources.

“To support greater awareness of this policy, the Air Transportation Division, AFS-200, is willing to partner with NBAA to develop a plan that creates greater awareness of the policy and how to utilize a contract check pilot who may be employed by a different air carrier,” he wrote.

Read Ruiz’s full letter to NBAA.

“We are grateful for the FAA’s willingness to work with NBAA and our industry to find innovative, and lasting, solutions for this situation,” said Brian Koester, CAM, NBAA director, flight operations and regulations. “Such collaboration will help our industry move forward past current challenges.”

Part 135 Subcommittee Chair Michael McCullough also welcomed the FAA’s response, noting the agency faces “a perfect storm” in resolving these issues.

“Not only is the FAA dealing with the lingering effects from COVID-19, but also with a shortage of qualified personnel and inspectors for certain older aircraft,” he said. “At the same time, the introduction of new aircraft into business aviation fleets has caused a similar lack of check airmen qualified on those types.”

Another option that first came into use during the pandemic is the use of remote technologies (RT) in which pilots record their checkride flight with an in-cockpit camera, with the video then reviewed by a qualified check airman.

While the agency has no formal guidance for RT checkrides, Ruiz noted continuation of such practices may help mitigate current shortages if no other options are available.

“FAA inspectors and the air carrier should work together and jointly design how RT will be used for a given checking event, taking into consideration the benefits and limitations of this technology,” he said.