Should Part 91 Recurrent Pilot Training Be More Scenario-Based?

Historically, Part 91 pilots attend training courses at Part 142 training facilities to accomplish required annual 61.58 pilot-in-command proficiency checks and improve their skills. Aviation training experts say recent policy interpretations now require some Part 142 training centers to use the recurrent training course to focus on box-checking exercises, rather than improving a pilot’s skills by having them train for critical scenarios.

“About a year ago, the FAA changed its interpretation and application of guidance. NBAA has been advocating for the industry, meeting with the FAA in mid-2024 to discuss clarifications that will give the industry flexibility to implement more scenario-based training rather than re-training the same list of tasks every six months,” said Brian Koester, aviation operations and compliance analyst at Jetlaw, LLC.

For example, simulator instructors and check pilots are required, under the new interpretation, to train and then check everyday tasks, such as normal takeoffs and landings. Experts say this time is better spent conducting scenario-based and emergency training.

“We’ve been doing the same archaic training since 1972, and the industry has been trying to change this for quite some time,” said Dondi Pangalangan, senior vice president of strategic initiatives at Clay Lacy Aviation. “Why check things we know a pilot can do because they’re doing them every day?”

Part 121 airlines train by using advanced qualification programs (AQP), which essentially permit “progressive” checking. In other words, if a pilot proficiently conducts a normal takeoff during scenario-based training, the instructor can consider the normal takeoff “checked.”

“Airlines use AQP, rely on safety data and change training topics event over event,” said Timothy Schoenauer, senior director of training solutions for business aviation at CAE. “Meanwhile, business aviation is required to have a checking philosophy and we don’t have an opportunity to evolve the training environment. More scenario-based training would allow the industry to evolve.”

In the meantime, the industry is taking training improvements into its own hands. For example, CAE is implementing Continuously Optimized Recurrent (CORe) training. CORe training topics will change every six months based on analysis of risks and emerging threats. Schoenauer encourages operators to add the most current CORe training scenarios to a five-day recurrent training event.

“We aim to learn from the data and put it back into training to close the loop on the risk. We have to, as an industry, take steps to advance how we train, not just check,” said Schoenauer. “It has worked for 30 years for the airlines; now is the time for business aviation.”

Review NBAA’s safety resources at nbaa.org/safety.