As far as the Federal Aviation Administration (FAA) is concerned, there are only two ways for a civilian to learn to fly … either the school you use is FAA approved, or it is not.
WAIT… you mean you can receive flight instruction from a facility that’s not approved by the FAA?!!?
That’s right, not all instructors, nor even all the “big name” flight schools are “approved.” In fact, most of us learned at “unapproved” facilities. Federal approval does not necessarily guarantee better instruction than non-federally approved instruction. Which system is “better” for your education and training dollar? To understand this, you need to know the differences (including the advantages and disadvantages) of “approved” and “unapproved” flying programs.
Federal pilot certification rules and requirements are found in two Parts of the Federal Aviation Regulations (14 CFR): Part 61, “Certification: Pilots, Flight Instructors and Ground Instructors,” and Part 141, “Pilot Schools.” By definition flight training programs conducted under Part 141 are “approved” or “certificated” by the FAA, while those under Part 61 are not. So what are the differences? What makes Part 141 “special” in terms of FAA approval?
FAR 61: Spells out the requirements for all the pilot certificates (Student, Recreational, Private, Commercial and Airline Transport Pilot) and ratings (Instrument, Multiengine, Flight Instructor — including Instrument and Multiengine Instructor add-ons — and Type ratings). Part 61 also lists the needs for and methods to obtain endorsements for such things as tailwheel, high performance and complex airplanes; and pilot currency requirements including the Flight Review and Instrument Proficiency Checks.
FAR 141: The purpose of Part 141 is to regulate flight schools that, by virtue of their detailed organization and documentation, are granted special privileges by the FAA in training and certifying pilots. Most notably, pilots training in Part 141 schools qualify for pilot certificates and ratings with less flight and instructional time than the same credentials earned in Part 61 operations. Pilots must take and pass “Stage Checks,” or mini-checkrides, at specific points during the course of training. FAR 141 requires individuals with specific instructional experience to be assigned as “Chief Flight Instructor” and “Assistant Chief Flight Instructor.” Similarly, Part 141 schools must have detailed flight dispatch procedures and formalized ground training conducted by certificated ground or flight instructors. Approved schools have enormous documentation requirements. Further, Part 141 often gives the school “examining authority.” Translation: The school has the ability to grant pilot certificates and ratings on the basis of passing in-house Stage Checks and without checkrides from the FAA or Designated Examiners.
Here’s a comparison of the total flight experience requirements for pilot credentials (note that there are additional requirements as subparts of these totals — check the regs for details):
|Part 61||Part 141|
|RECREATIONAL PILOT||30 HOURS||30 HOURS|
|PRIVATE PILOT||40 HOURS||35 HOURS|
|INSTRUMENT PILOT||(no minimum)||(no minimum)|
|COMMERCIAL PILOT||250 HOURS||120 HOURS|
|AIRLINE TRANSPORT PILOT||1500 HOURS||1500 HOURS|
You can see the big advantage is a lower required time to qualify for the Commercial Pilot practical test — because Part 141 is designed to govern schools that turn out future professional pilots.
Note: Part 141 does not address requirements for Flight Reviews (FRs, formerly BFRs) or Instrument Proficiency Checks (IPC). Part 141 is all about earning pilot certificates and ratings, not maintaining them once they are earned. Pilots who earn credentials through Part 141 programs must still adhere to the currency rules of Part 61 to retain pilot privileges.
Part 61 instructors are free to train pilots in whatever order they wish, substituting items on flights on a whim or to better adapt to the student’s learning style so long as the student masters all tasks of the Practical Test Standards (PTS) before going off for a checkride. Part 141 operators don’t have that luxury — all lessons need to be followed to the letter, and one lesson must be completed satisfactorily before moving on to the next.
In addition to strict personnel requirements, schools desiring Federal approval must submit:
TCOs: TCOs, or Training Course Outlines are detailed descriptions of exactly how flight training operations will be conducted. The TCO contains:
- A general description of the program and the main airport base;
- A precise description of the classroom and other facilities used by the school (the Feds will actually conduct an on-site conformity inspection to check your description matches the “true” floorplans);
- The types of airplanes that will be employed;
- The names of all required personnel (Chief Instructor, Assistant Chief, etc.), and the minimum experience and certification requirements for all instructor positions;
- Individual lesson plans for all classroom presentations (“ground labs“), including student evaluation procedures;
- Individual lesson plans for all flight training sessions, including evaluation procedures.
The Part 141 certificate holder must also have an approve FOM, or Flight Operations Manual, which is a written procedures manual that governs all school policies. Once reviewed and approved by the FAA, the FOM is essentially another set of Federal regulations to which the school is responsible to adhere. The school must also maintain strict, lesson-by-lesson training files for all students.
PROVISIONAL CERTIFICATION (Part 141)
You can’t just hire a team of instructors, put together the paperwork, and start up a Part 141 school right away. The new flight school must first obtain somewhat limited “provisional approval” (which, among other things, does not grant self-examining authority). This probationary period lasts at least two years, during which time the school must recommend at least 10 students for written or flight tests, with no less than 80 percent of those students passing on the first attempt. Only after this provisional period can a school earn full Part 141 certification, and privileges.
One big advantage of Part 141 schools is that they are recognized by other Government entities. Want to use your VA (Veterans Administration) or Federal education loans or grants to pursue your flying dreams? You’ll have to enroll in a Part 141 approved program to use government money. (“Provisional” certificate holders don’t count.)
THE FUTURE: PART 142 AND AQP
Part 142, “Training Centers,” is designed to provide stricter Federal oversight (and some measure of FAA “endorsement“) for airline simulator-based training programs providing type rating and other aircraft-specific training. This Part extends to many non-airline, simulator programs; Part 142 does seem to have provision for covering professional pilot development even for beginning pilots in piston airplanes.
Advanced Qualification Program (AQP) there is a growing vision in the professional pilot training industry to expand airline-style training to ab initio (“from the beginning“) pilots. AQP could conceivably substitute the traditional “private, commercial, instrument” pilot progression with an airline-specific training track producing an airline-only qualified pilot — the civilian version of current military pilot training philosophy.
Presumably if such programs do gain Federal approval for certificate and rating training, the requirements for students and schools will be similar to those under Part 141.
PART 61 — A BROADER RANGE OF OPTIONS
Despite the perceived advantages of Part 141, many excellent instructors and schools elect to operate under Part 61 to avoid the somewhat onerous paperwork and operating restrictions of Part 141. Schools specializing in non-certificate/rating training (aerobatics schools, many type rating programs, and even some powerhouse names like portions of FlightSafety International) operate under Part 61 simply because there is no provision for them to train under Part 141. Plus, anyone providing Flight Review, IPC or pilot checkout training is by definition operating under Part 61.
BOTTOM LINE: There are advantages and disadvantages to both Part 61 and Part 141 pilot training. The deciding factor for many aspiring pilots is the need for federal financial aid. Only Part 141 certification is required if Veterans Administration and other Government funds will be used to pay for flight training. But Part 61 is flexible, more forgiving in its training techniques and scheduling, and sometimes better suited for those who must also maintain other responsibilities (i.e. work, school, family). Whether your training is under Part 61, Part 141, or some other set of Federal rules, you should expect (and if necessary, insist on) quality flight instruction and seek out what works best for you.