Navigating the initial days as a Chief Pilot or Director of Operations (DO) in a Part 135 Air Carrier requires a comprehensive understanding of regulatory compliance, operational intricacies, and effective management strategies. This article serves as a guide tailored for first-time Chief Pilots in small Part 135 operators, acknowledging the common responsibilities shared with Directors of Operations. Given the typical collaboration between these roles, the insights provided herein are valuable for both positions.
From qualifying under 14 CFR 119.71 to the intricate process of gaining approval, this guide outlines key considerations and expectations for individuals undertaking the responsibilities of a Chief Pilot or DO. As the aviation landscape experiences dynamic shifts, characterized by an influx of new personnel in leadership roles, the importance of adherence to safety standards and regulatory requirements becomes paramount. This article delves into the qualifications, approval process, and subsequent responsibilities, providing a foundation for effective leadership in the realm of Part 135 private air charter and pilot training.
Before being assign as a CP you need to make sure you meet the current requirements of 14 CFR 119.71. If you don’t meet some of the experience requirements, the FAA may grant you a waiver based on your other industry work. That said, don’t count on it. Although allowed by the regulation, most inspectors will be hesitant to endorse you in such a high responsibility position. Due to the pilot hiring craze, there’s been significant movement felt industry wide, which has led to a lot of newbie Chief Pilots and DOs. Inspectors realize this, and rarely will they waiver their commitments and standards of safety to satisfy this rapid career movement.
Assuming you meet the requirements, next comes the approval phase. Your company’s FAA management team will want to meet you, put a name to a face, and get a feel for your personality and decision-making skills. At some point, they’ll schedule a visit. Be prepared for the interview! Make sure you have proof for past experience, resume, training records, certificates, etc. Treat this interview like you would any other check ride, and expect to be tested on anything and everything related to your job. Below are some of the topics to expect:
After being approved as the company Chief Pilot, it’s time to get to work. Since you are now a responsible party to the company’s regulatory compliance, you’ll first need to audit the existing operation as it stands. Here are some of the areas that you’ll want to look into.
Your manuals act as an agreement between the certificate and the FAA as to how your company intends on running its operation. If a pilot does something they weren’t supposed to do, but is an accepted procedure in the GOM, what do you do as their CP? Checking the accuracy of the manuals currently being used by the company will be tedious but necessary. The Training Program might still be in initial approval, and the HazMat manual might not reflect the latest in regulatory matters. You should be well versed in the current manuals as they stand; obviously because you will be tested on them by your POI, but also so you can prioritize your updates accordingly.
As for OpSpecs, you’re checking them all. Firstly, don’t rely on printed out OpSpecs. Download the latest from WebOps and skim through them. You’re checking for addresses, names, contacts, deviations, expirations, etc. Dedicate some time to comb through the list in detail, and read the footnotes! There’s plenty of hidden details in there that can completely change the meaning of an authorization. Compile a list of errors and come up with a corrective plan of action with your FSDO.
Two easily forgotten forms are the DOT’s OST-4607 and 6410s. The OST-4507 is proof of Economic Authority, which is paired with a Certificate of Insurance (OST-6410) for each aircraft in commercial operations. Not only is maintaining accurate forms a legal requirement, but it is often required by safety accreditation companies such as Argus and Wyvern.
First off, you’ll need a company FAA Safety Assurance System (SAS) account. You may need to request a login from your POI if this is a new company email address (some companies use cp@company.com specifically because of the high turnover- don’t take this personally). You’ll also need a WebOps account as well to make OpSpec changes. Finally, create a company Pilot Record Database PRD account too. There are instructions online on how to do all of that. Finally, get access to all the other software the company uses, such as ForeFlight, SMS software, and Scheduling software. Even if you won’t be using ForeFlight personally, you’ll be surprised to find that app being used for electronic manuals, when your company's OpSpec A025 might specify another approved program instead. Clean that up!
Being a good Part 119 manager is not an easy task. You must become an expert at juggling several somewhat antagonistic concepts at once. You must maintain a good relationship with your FAA inspectors, but also the company owner, and your pilot group. Each of these entities have different priorities. In some instances, your experience and authority will need to stop an owner from committing illegal or unsafe actions. In other cases, you will take an actionable stance on protecting company profitability and not allowing slow or unfair government processes from causing economic hardship. There is a reason why Part 119 managers are highly compensated. This is not an easy job.
So how do you do a good job? First off, start by understanding the weight of your responsibilities. The certificate’s growth, stagnation, and collapse are all directly affected by the daily decisions and actions you take and delegate daily. Secondly, focus on interpersonal relationships. We’ve all experienced the fake “open door” policy that many managers try to adopt. You can’t have an open door but a closed mind if you actually want employees to come to you. Trust takes time to establish. Your decisions might not be challenged at first, but if you commit enough errors or are too combative then trust will disappear and will be almost impossible to regain back. That said, know when to stand your ground. You are in this position for a reason. Pilots are taught to have personal minimums and learn when to refuse a flight if it compromises safety. As a DO or CP, you must do the same. Just because something is legal, doesn’t mean its safe, and vice versa.
Learn about the company, its culture, its policies, its operations. Take the time to listen to your pilots, mechanics, dispatchers, and formulate relationships with them. Far too often will a new manager attempt to change a million things all at once. Often times the new managers demand changing schedule software, maintenance procedures, training contractors, all at the same time. This is mostly because that’s what they’ve been using and fail to learn new programs, even when they are better. With the industry experiencing poor attrition on all levels, it becomes imperative as a new manager to slow down your pace and hold off from completely renovating the whole operation at once.
The FAA offices across the country are backed up for months, so you should strive to submit things in order of importance and in their best possible versions. Playing ping-pong with your inspectors over manual corrections is a sure way to jeopardize your relationship with your managing office.
We know all of this may be overwhelming, especially if this is your first time being a Chief Pilot or even Director of Operations. The industry is rapidly changing, which is both good and bad. But there is a plethora of resources available out there, including your friends here at Sky Safety Solutions.
