Between COVID and the post-pandemic surge in flights, Part 135 charter operators have recently seen the worst and perhaps best of times. Both situations have greatly strained an operator’s ability to keep up with their crews’ 14 CFR 135.299 line checks.
Whether due to travel restrictions or the lack of a type-rated and current check pilot, there just weren’t enough qualified FAA flight check pilots available in the right places at the right time.
“Recognizing that charter operators were having to ground crews due to lapses in their qualifications, the FAA released an internal memo outlining the use of video and communications technology, which is now more broadly known as remote technology (RT), to provide guidance for performing virtual Part 135 checkrides,” said Michael McCullough, assistant director of operations for Aviation Resource Management Inc., and chair of the NBAA Domestic Operations Committee, Part 135 Subcommittee. “The individual FSDOs took this memo and started conducting video check rides with no FAA inspector on board.”
“The prime benefit of the virtual flight check is it can be integrated into fight operations fairly easily,” said Hall Lewallen, director of operations for Summit Aviation, a member of NBAA’s Part 135 Subcommittee and co-author of NBAA’s Virtual Part 135 Checkride Best Practices Guide. An additional benefit is that an RT check enables an even more thorough critique by the FAA and the operator’s flight department personnel because it gives the observer the ability to replay any portion of the flight without any aircraft environmental distractions.”
“The willingness of the FAA to address industry concerns and keep an open mind to this kind of solution has been phenomenal.”
Michael McCullough Assistant Director of Operations, Aviation Resource Management Inc.
While putting a few GoPro cameras in the cockpit may seem simple enough, it’s not. It requires careful consideration to ensure it is accomplished safely and in compliance with regulations. That’s why NBAA drafted its best practices guide.
“Every situation is different, so it requires some experimentation and fine-tuning,” Lewallen explained. “If the quality of the video or audio is compromised, the recording may be unusable by the FAA.”
But just because an operator wants to use RT as an option, it does not mean the FAA will allow it.
“While the FAA does not publish any official guidance for the use of VCT , it does allow each FSDO to work with an operator to explore the option,” said Brian Koester, CAM, NBAA director, flight operations & regulations. “The FAA’s recent revision of Order 8900 reaffirms its support of RT in some situations.”
“But, like many things within the FAA, it comes down to the individual FSDO’s decision about whether or not virtual checkrides are allowed,” McCullough said. “The first step is for the operator to contact their principal operations inspector (POI) to determine if an RT is possible and then create a plan around how it’s done.”
While the easing of COVID restrictions may have put RTs on the back burner for many operators, some may still find it a viable solution to meet their needs. Either way, McCullough believes it’s had a lasting benefit.
“The willingness of the FAA to address industry concerns and keep an open mind to this kind of solution has been phenomenal,” he said.