The National Air Transportation Association (NATA), on behalf of its members conducting air carrier operations under Part 135, requested rulemaking to expand the number of pilot line checks performed by operators, improving safety and decreasing demands on limited FAA resources. NATA’s petition, if adopted, would allow FAA-approved company check pilots to conduct the pilot line checks required by § 135.299 throughout the certificate holder’s fleet of aircraft that are of the same category and class. In addition, NATA requested the FAA provide guidance specifying the suggested content for the pilot line check.
“Although NATA previously filed a petition for exemption permitting the same authority for a limited duration due to COVID-19, we subsequently determined that the safety and efficiency gains afforded by this relief were beneficial enough to warrant a permanent change through a petition for rulemaking,” stated NATA President and CEO Timothy Obitts. “This amendment will result in long-term cost savings, safety improvement, and efficiency gains for operators, as well as a positive impact for the FAA and, potentially, the environment.”
The petition notes that “the purpose of the line check is not to evaluate piloting skill and that the carrier’s check pilots are best equipped to determine that pilots are operating in accordance with company policy and procedures.” NATA goes on to explain that, “the intended purpose of the line check is best fulfilled by company check pilots who have a full understanding of company procedures and culture.” NATA’s proposal stipulates that the carrier’s check pilots must be currently qualified as a Pilot in Command in the same category and class of aircraft in which the check is administered.
“Today, FAA inspectors conduct many pilot checks and are able to safely do so without being currently qualified in the aircraft. The FAA has also emphasized the importance of regulations stipulating that carriers conduct their own pilot checking rather than relying on FAA resources whenever feasible,” NATA Vice President of Regulatory Affairs John McGraw explained. “The changes we propose are consistent with the regulatory mandate and, because FAA inspectors have already demonstrated these checks can be safely accomplished in the manner proposed by NATA, the safety standard is maintained,” McGraw added.
NATA notes additional benefits, such as lower FAA costs from decreased inspector travel for checks, increased time for inspectors to perform other oversight functions, and safety benefits from decreased operational exposures (due to fewer flights conducted specifically for checks).
Further, because these changes allow a reduction in the number of flights that are conducted solely for the purpose of performing the line check, the change could prove beneficial to the environment.