VOLUME 2 AIR OPERATOR AND AIR AGENCY CERTIFICATION AND APPLICATION
CHAPTER 2 GENERAL INFORMATION FOR AIR CARRIER CERTIFICATION
AND FRACTIONAL OWNERSHIP APPLICATION
Section 3 Safety Assurance System: Evaluate Part
2-151 REPORTING SYSTEM(S).
A. Program Tracking and Reporting Subsystem (PTRS).
For evaluating proposed part 119
management personnel, use PTRS activity code 1352, 3352, or 5352, as appropriate.
For processing management deviation requests, use PTRS activity code 1328,
3319, or 5319, as appropriate. A change of management personnel requires the
initiation of a configuration change request in SAS (see
Volume 10, Chapter 2, Section 1).
B. Safety Assurance System (SAS). For evaluating
certificate holders’ existing Title 14 of the Code of Federal Regulations
(14 CFR) part
119 management personnel, use SAS automation and the associated Data Collection
2-152 OBJECTIVE. This section provides guidance
on evaluating the qualifications and management deviations of part
119 management personnel for certificate holders/applicants conducting operations
under 14 CFR parts
135. The term “certificate holder” within this section applies
to air carrier or operating certificates issued under part
A. Required Management Personnel Positions.
119 establishes the requirements for which management positions are required
for both parts
135. These management personnel are the primary individuals the Federal
Aviation Administration (FAA) relies on for the management and operations of
the certificate holder. These individuals are integral for the safe operations
of the certificate holder and are required to be knowledgeable in the type of
operations the certificate holder is authorized to conduct. Their experience
and knowledge should not only meet the specifics of the regulations, but they
should also meet the intent of the experience requirements. Certificate holders
may wish to employ people in these required management positions when the candidate
lacks the required pilot-in-command (PIC) experience, operational management
experience, or aircraft maintenance experience, but possesses other comparable
experience which suitably prepares them for the needed position.
121 Positions. Part
119.65 establishes management and technical personnel positions for certificate
holders operating under part
121 (e.g., Director of Safety (DOS), Director of Operations (DO), Chief
Pilot (CP), Director of Maintenance (DOM), and Chief Inspector). Section
119.67 specifies the airman qualifications and experience for personnel
serving in these positions for part
135 Positions. Section
119.69 establishes management and technical personnel positions for certificate
holders operating under part
135 (e.g., DO, CP, and DOM). Section
119.71 specifies the airman qualifications and experience for personnel
serving in these positions for part
3) Airman Qualifications and Experience. Candidates
for these required part
121 or 135
management and technical positions must have the airman qualifications and experience
needed to carry out their duties and responsibilities with a degree of expertise
consistent with the certificate holder’s responsibility to operate
with the highest level of safety. Sections
119.71(f) specify deviation authority for other comparable managerial and
supervisory experience to provide flexibility for those candidates who do not
meet the regulatory experience requirements, yet may effectively manage the
certificate holder operation. It is quite possible a candidate may not possess
the regulatory experience required to hold a position, but has other comparable
experience which exceeds the expertise gained in meeting the minimum experience
qualifications for the position. Required pilot qualifications are not the subject
of a deviation under §
4) CP Qualification. Candidates for part
135 CP must comply with §
(d), which states that they must be “qualified to serve as pilot in
command.” This means the person must meet all regulatory requirements
to serve as PIC, including holding a valid appropriate-class medical certificate.
If at any time the person’s medical has been denied, suspended, revoked,
or has expired, that person is no longer qualified to serve as PIC and can no
longer hold the CP position (see subparagraph 2-153B below). Under the provisions
of 14 CFR part 61, §
61.53(a), a temporary loss of the ability to exercise the privileges of
a pilot certificate does not disqualify that person to hold the CP position.
5) Deviation Request and Approval Procedure.
The deviation request and approval procedure described below offers the certificate
holder flexibility to employ persons who may not possess the exact type or quantity
of experience required by the regulations, but who possess other comparable
experience. However, the deviation request procedure is not applicable to individuals
who do not possess the required airman certificate and ratings.
6) Previous Experience. A person who was granted
a management deviation cannot use that deviation to meet the previous experience
position criteria of §
(d)(2), or § 119.67(a)(3)(ii)
(b)(2) until the deviation is no longer required. For example, §
119.71(a)(2)(ii) states, “In the case of a person with previous
experience as a Director of Operations,” if that person was under a qualification
deviation to serve as DO, that person cannot be considered to meet the requirements
as previous DO under §
119.71(a)(2)(ii). This requirement does not apply to the DOM or Chief Inspector
B. Management Vacancies Under §§
119.69. If there is a vacancy in one of these required positions, the
certificate holder is required to notify the certificate-holding district office
(CHDO), per § 119.65(e)(3)
119.69(e)(3), of any vacant positions and should state the course of action
the certificate holder is taking to fill the position. The certificate holder
may take any of the following courses of action to comply with §§ 119.65
119.69 when there has been a change in personnel or a vacancy in one of
the required management personnel positions:
1) Current Employee Appointment. If the certificate
holder operating under part
121 has an employee who meets the certification and experience requirements
119.67, or a certificate holder operating under part
135 has an employee who meets the certification and experience requirements
119.71, the certificate holder may appoint that employee to the vacant position.
The notice required by §
119.65(e)(3) or 119.69(e)(3)
should state this change in personnel. The certificate holder should demonstrate
in the notice that the individual meets the qualification requirements of §
119.71. The individual can show he or she meets those requirements by submitting
a copy of his or her résumé showing his or her qualifications, certificates,
ratings, and experience.
2) Deviation for Individual. If the certificate
holder has an employee or candidate who does not meet the appropriate airman
experience, managerial experience, or supervisory experience requirements of § 119.67
119.71, but who has comparable experience and can effectively perform the
functions associated with the position, the certificate holder may request a
deviation from these experience requirements in accordance with the guidance
provided in this section. If the FAA grants the deviation, the certificate holder
can then appoint that employee to the vacant position, thus complying with §
119.69. Deviations are authorized by issuing operations specification (OpSpec)
A005(c). Deviation authority is not available for a person who does not hold
the required airman certificates and ratings.
3) Deviations for Required Positions. If a
certificate holder can show that it can perform the operation with the highest
degree of safety under the direction of fewer or different categories of management
personnel, the certificate holder can utilize §§
119.69(b) to ask the FAA to amend its OpSpecs and approve the operation
without filling the otherwise required position. Deviations are authorized by
issuing OpSpec A005(c).
4) Unable to Fill Within 10 Days. If a certificate
holder is not able to fill the vacancy within the 10‑day period prior
to being required to notify the CHDO of the vacancy or use one of the options
outlined above, the certificate holder is not in compliance with applicable
regulations. There are several situations that create extenuating circumstances
and the CHDO must decide, per
Volume 14, Chapter 1, Section 1, the most appropriate course of action to
regain compliance. In the notification required by §
119.69(e)(3), it must state which position is vacant and should include
an explanation for the vacancy and a plan to fill the vacancy within 30 days.
The CHDO reviews this plan and may grant an extension of an additional 30 days,
when appropriate, with a written response. A vacancy in one of the required
positions should only exist for a reasonable duration of time needed by the
certificate holder to fill the position. Based on current industry practice,
this process should not exceed 60 days. Should this vacancy exceed 60 days,
consult with the Chief Counsel’s Office (AGC) for appropriate certificate
action. Some of the options may include voluntary suspension of certificate,
surrender, or other adverse action of the certificate holder.
2-154 PROCEDURES TO REVIEW FOR THE PROPOSED PART
119 MANAGEMENT POSITION CANDIDATE.
A. Items for the Principal Inspector (PI) to Complete.
When a certificate holder submits an applicant for one of the part
119 required management positions, the PI will complete the following:
1) Check the applicant’s FAA certificate(s)
for appropriate ratings and validity, including a current medical where appropriate.
2) Check the National Program Tracking and
Reporting Subsystem (NPTRS) database for Compliance Action and other contact
history, Accident Incident Data System (AIDS) for events, and Enforcement Information
System (EIS) for previous violation history.
3) Verify employment history (résumé) to ensure
applicant meets the necessary experience requirements;
applicant is not serving in a management position with another certificate holder,
unless approval has been granted in accordance with paragraph 2-158;
applicant has not held a similar position and contributed materially to a certificate
revocation in a part
135 operation; and
work history conducted in another CHDO indicates there have been no past performance
4) Interview the candidate within your own
discipline. Determine the candidate’s knowledge of the following:
of the certificate holder/applicant’s manual;
holder’s OpSpecs; and
provisions of 14 CFR parts
5) Determine the eligibility of the candidate.
Base the decision on the information above.
B. Final Steps. The PI will inform the certificate
holder/applicant of the results after receiving all the information. The PI
will inform the certificate holder in writing either via formal letter or email
and keep a copy in the certificate holder’s file. Official authorization
will be accomplished via issuance of OpSpec A006.
2-155 EVALUATING MANAGEMENT EXPERIENCE OF MAINTENANCE
PERSONNEL. Personnel responsible for the inspection and maintenance organizations
must possess the qualifications required in §§ 119.67(c)
119.71(e). If a certificate holder/applicant elects to contract out all
maintenance, the positions defined by parts
135 are still required.
A. FAA Required Positions:
135) has the authority and the overall responsibility for managing and implementing
the certificate holder/applicant’s maintenance program, including all
inspection functions; and
Chief Inspector (part
121) is directly responsible and accountable for administering the certificate
holder/applicant’s required inspection program.
B. Part‑Time and Full‑Time Positions.
Operations conducted under part
121 must have qualified personnel serving full-time in the required positions.
The aviation safety inspector (ASI) must determine if the part 135
certificate holder/applicant has sufficiently qualified management personnel
to ensure the safety of its operations. Each person employed on a part‑time
basis must be readily available to fulfill all responsibilities of the position
that are consistent with the certificate holder’s operations.
C. DOM Position. Individuals considered for
the DOM position should have experience in any position where the normal duties
and responsibilities included management oversight and/or control of the development,
upkeep, and responsibility for one or more of the following elements of an aircraft
maintenance or inspection program:
and inspection organization;
and approval of maintenance, preventive maintenance, and alterations;
of alterations performed by maintenance providers or contractors;
Analysis and Surveillance System (CASS);
D. Chief Inspector Position. Individuals considered
for the Chief Inspector position should have experience in any position where
the normal duties and responsibilities included management oversight and/or
control of the development, upkeep, and responsibility for one or more of the
following elements of an aircraft maintenance inspection, quality control (QC),
or quality assurance (QA) functions within a maintenance or inspection program:
program policy and procedures;
of the performance and approval of maintenance, preventive maintenance, and
and approval of alterations performed by maintenance providers or contractors;
2-156 EVALUATING MANAGEMENT EXPERIENCE OF OPERATIONS
PERSONNEL. Personnel requesting to serve as the DO or CP must possess the
qualifications required in §
119.67 for part
121 operations and §
119.71 for part
135 operations. For those situations where proposed individual(s) do not
meet the requirements of §
119.71, a management deviation under §
119.71(f) must be requested by the certificate holder and approved per the
appropriate regulation and as described herein. A certificate holder/applicant
may not contract out the responsibilities for these positions, and they are
required to be filled by employees of the certificate holder.
2-157 EVALUATING MANAGEMENT EXPERIENCE FOR DOS.
A. DOS Position. Each certificate holder that
conducts operations under part
121 must have a DOS. There are no qualifications listed in §
119.67 for the DOS position. Therefore, the CHDO shall consider the following
information when approving an individual for the DOS position. This person is
responsible for keeping the certificate holder’s highest management officials
fully informed about the safety status of the company and, therefore, should
have extensive operational experience and professional qualifications in aviation.
This should include the knowledge and understanding of aviation safety programs,
aviation safety standards, and safe aviation operating practices.
1) The DOS should have established professional
credentials. These credentials may be any of the following:
a) An FAA Commercial or Airline Transport Pilot (ATP)
b) An FAA Mechanic Certificate, or
c) An FAA Aircraft Dispatcher Certificate.
2) The DOS should have professional aviation
supervisory experience. Such experience may include any combination of the following,
providing the total experience is greater than or equal to 3 years:
a) Experience in a supervisory position with a part
121 or a scheduled part
135 certificate holder.
b) Experience in a position comparable to a) above
in U.S. military aviation operations.
c) Experience in a supervisory position with a government
department, board, or agency that deals directly with aviation matters.
d) Experience in a supervisory position with a part
125 operations/aviation department.
e) One year of experience may be listed if the candidate
has completed a degree in higher education relating to aviation safety.
B. DOS Functions. An independent, full‑time
position is required. However, in a small part 121
operation, the DOS functions may be an additional function of a current manager.
Any request for a management deviation from the regulatory requirement involving
a combined DOS position must be approved by the Air Transportation Division
(AFS‑200) in accordance with §§
NOTE: Requests for one individual to fill this position
for more than one certificate holder concurrently will not be considered.
NOTE: For the purposes of part
119 management personnel, small part
121 certificate holders are generally defined as those carriers operating
five airplanes or fewer.
2-158 MANAGEMENT PERSONNEL SERVING MULTIPLE CERTIFICATE
A. The Difference Between §§
119.69. Regulatory constraints in §
119.65 require that management personnel for part
121 certificate holders be full-time. This precludes any and all part 121
management personnel from holding any other part
119 management positions concurrently, including any part 135
management positions. Deviations for combined part
119 management positions operating under part 121
are approved in accordance with §
119.65(b) and paragraph 2-163.
119.69 Criteria. Section
119.69 does not contain equivalent wording to §
119.65 requiring full‑time management personnel for part
135 certificate holders. An individual who is fully qualified may serve
as a management person for more than one part
135 certificate holder. Section
119.69(b) uses the following criteria in determining the positions and number
of management personnel:
1) The kind of operation involved.
2) The number and type of aircraft used.
3) The area of operations.
C. Multiple Certificate Holders. The PI should
use the same criteria in approving or denying the same individual for multiple
certificate holders. The PI ultimately is responsible to determine if the best
interest of aviation safety is served by multiple certificate holders sharing
one individual. The following norms should be considered when a determination
is made whether part
119 management personnel can serve for more than one part 135
1) Size. Multiple turbojet aircraft with international
authorizations would be an example of a complex certificate holder and an unlikely
situation to share management personnel. Certificate holders authorized one
aircraft or a few single-engine visual flight rules (VFR) aircraft is an example
of a situation where sharing management personnel could be acceptable.
2) Location. Certificate holders not located
in close proximity would also be a factor to consider and justification of a
denial to share management personnel.
3) Multiple CHDOs. Multiple CHDOs involved
is another concern and should be avoided.
D. Review Process. As part of the review process,
the individual who meets regulatory requirements must be interviewed. The respective
PIs must reach consensus that the individual meets the regulatory requirements
and can perform the assigned duties for the certificate holder before approving.
For individuals who do not meet the regulatory requirements, the certificate
holder may request a qualification deviation by using the process described
in paragraph 2‑159. The PIs must agree that a deviation is appropriate
and the CHDO manager must concur before forwarding to the Regional Office (RO)
NOTE: Headquarters (HQ) will not approve part
135 commuter operations or part
121 operations to share part
119 management personnel, as provided for in this paragraph.
2-159 MANAGEMENT DEVIATION REQUEST. Under
those circumstances when the certificate holder submits a written request for
a management deviation, the following process will be followed:
A. Make the Request Through the CHDO. When
a certificate holder requires a management deviation, the certificate holder
must initiate such requests through its CHDO in writing. The request must adhere
to the processes and procedures and contain a minimum of the information shown
in subparagraphs 2-159B1) through 10) for evaluation.
B. Submit a Request Letter. The certificate
holder’s written request must contain the following:
1) Full certificate name, including doing
business as (DBA) of the requesting entity (e.g., ABC Airlines, Inc. DBA XYZ
2) Complete address and certificate number
of the certificate holder.
3) Full name and airman certificate number
of the management applicant.
4) Number of aircraft by category, class,
5) Number of employees/pilots/other crewmembers.
6) Areas and kinds of operations authorized
(e.g., contiguous United States, State of Alaska, domestic, supplemental,
and helicopter air ambulance (HAA)).
7) Statement of operations authorized (e.g.,
single PIC, basic part
135 on‑demand only, and part 121
8) Any other management deviations held by
the certificate holder.
9) Statement of why the certificate holder
requires a management deviation, management position(s) involved, and an explanation
of what comparable experience the individual has that would justify the management
10) A résumé for the individual that specifically
outlines their work experiences and duration of each work experience (month/year)
to include: PIC/second in command (SIC) time in type of aircraft and/or management
experience for the kind of operations conducted, to include the 14 CFR part
under which the certificate holder was certificated (part
etc.). Include the various types and numbers of aircraft in the operation. PIC
time is from month of PIC check/authorization and not necessarily the date of
NOTE: The information contained in the résumé must
be verified by a PI assigned to the certificate, including supporting documentation.
C. Statement. The PI will include a statement
indicating the NPTRS, AIDS, and EIS records of the certificate holder and management
applicant have been reviewed. If any adverse findings were encountered, the
PI should verify that the adverse history has been appropriately resolved.
2-160 EVALUATING DEVIATION REQUESTS FOR DOM AND
CHIEF INSPECTOR POSITIONS.
NOTE: Deviations may be granted from the minimum
experience requirements in § 119.71.
However, the applicant must hold the appropriate certificates and ratings.
A. Consider Overlapping Duties. Before allowing
an individual to serve as DOM or Chief Inspector, the PI must consider the other
duties performed by that person. For example, if that person also plans to serve
as a flightcrew member, the ASI must ensure that those duties will not interfere
with the person’s responsibilities as DOM or Chief Inspector.
NOTE: Operations conducted under part
121 require personnel to serve full-time in the required positions.
B. PI Responsibilities. The PI is responsible
for the following:
1) Interviewing the individual involved to
verify aviation experience and qualifications;
2) Determining the size, scope, any known
expansion plans, and safety record of the certificate holder;
3) Verifying the applicant’s résumé
and experience; and
4) Recommending approval or denial of the
2-161 EVALUATING DEVIATION REQUESTS FOR DO AND
NOTE: The regulations do not permit the grant of
a deviation against an airman certificate requirement for individuals who do
not hold the required airman certificate or rating. However, they may apply
for an exemption under 14 CFR part
A. Comparable Experience. A management position
experience deviation may be issued for individuals who lack the minimum management
experience requirements, PIC experience requirements, or recency‑of‑experience
requirements (specified in §§
119.71) if appropriate comparable experience is presented and accepted by
1) For the DO, the evaluation of experience
in any position where the normal duties and responsibilities included management/supervisory
oversight and/or responsibility and authority over the development, upkeep,
and performance of one or more elements of a certificate holder’s operational
control system may be considered as comparable experience. Management positions,
wherein the applicant exercised aviation management decisionmaking processes,
may be considered as comparable experience (e.g., Assistant DO, Assistant
CP, Flight Department Manager, Military Flight Unit Commander, Standards and
Evaluation Officer, and Aviation Safety Officer). Experience involving operational
control may also be acceptable (e.g., supervisory aircraft dispatcher,
keeping in mind for part
135 operations the documentation of proof rests with part
2) For CP positions, the candidate should
possess a minimum of 12 months PIC experience in either part 121
135 operations within the previous 72 months.
3) For other comparable experience to be used
for both the DO and CP positions, all comparable experiences added together
should equal or exceed the required 3 years. The following examples may
be considered as comparable experience:
as a PIC conducting the same kinds of operations that the applicant would be
responsible for managing;
as a manager of a corporate flight department (parts
operating more than one comparable aircraft with operations similar to a parts
in a military PIC position with responsibilities and experience comparable to
a civil aircraft operation PIC;
in a civilian or military management position with responsibilities for safely
transporting passengers and/or cargo with aircraft of similar or more complex
systems and capability; or
in service with a foreign air carrier including management positions.
B. Unacceptable Experience. The following
may not be considered as comparable experience: military single‑pilot
operations without unit leadership or command responsibility experience, ground
or flight instruction, 14 CFR part
137 aerial application operations, 14 CFR part
133 helicopter external-load operations, 14 CFR part
142 training center instruction, academic education, or writing manuals
without managerial experience implementing the same manuals.
2-162 THE EVALUATION TOOL FOR MANAGEMENT EXPERIENCE
DEVIATION REQUESTS (OPERATIONS). AFS-200 has developed a job aid to assist
principal operations inspectors (POI) in evaluating comparable experience. These
are specific for the DO for part
135 certificate holders and CP for part 121
certificate holders. These four worksheets will help guide and standardize management
deviation requests for both part
135 operations. You can find these worksheets via the links provided in
subparagraph 2‑162D2). These matrices are only a tool and they are
not regulatory. These worksheets are referred to as an Experience Rating Worksheet
(ERW) and have a total point value that should be met; however, even though
the qualifications may have driven the score to either higher or lower than
the base standard, the user/evaluator at any level may accept or reject the
results with an operationally valid reason. An example of a valid reason to
deny could be the candidate has extensive military flight management experience,
but does not yet have enough part
certificate holder experience regardless of the points received. Another example
would be a previous FAA inspector who does not meet the requirements in either
135, but in his or her previous career, had extensive certificate holder
management and line experience. See subparagraph 2-162B below for experience
A. ERW Instructions. At the end of the worksheet,
find basic instructions for using the worksheet. Due to the limited space on
the worksheet, expanded instructions are located below.
1) Recency-of-Experience. The maximum period
that can be included in the ERW is the past 10 years. The ERW expands the
6-year look-back period in the regulation to allow the look-back period to increase
up to 10 years for equivalent experience, but decreases the value of this experience.
An individual who cannot meet these requirements most likely has not been active
in the aviation environment during this 10‑year look‑back period.
2) Military Experience. Military experience
is limited to a maximum of 24 months in aggregate. Military experience
has value, but do not rely upon this experience as the sole source of the total
points required. There must be either some part
135 experience in the applicant’s past.
Experience Limit. Part
experience is limited to a maximum of 36 months in aggregate. Once again,
this experience has value, but do not rely upon this experience as the sole
source of the total points required. There must be either some part
135 experience in the individual’s past.
4) Foreign Experience.
a) PIC experience gained by the applicant at an International
Civil Aviation Organization (ICAO)‑certificated foreign air carrier may
be credited on the ERW as “Other Experience.” The entire operating
experience cannot consist of exclusively foreign experience. Individuals must
always have at least 12 months PIC experience with a U.S. part
135 certificate holder within the last 72 months. Experience operating
in the U.S. National Airspace System (NAS) and according to FAA regulations
are essential qualifications to serve in a management position for a U.S. part
135 certificate holder.
b) Management experience gained by the applicant
at an ICAO-certificated foreign air carrier may be credited on the ERW as “Part
91 Management Experience.”
c) Foreign experience listed on a résumé must be supported with documentation
and include a statement concerning any accidents, violations, or enforcement
action or lack thereof that occurred during that foreign air carrier service.
5) Management Experience. Use caution when
evaluating qualifications for a DO position in part 121
operations. PIC time cannot be the only factor accounting for points. Management
experience is a requirement.
6) Regional Technical Branch Office Approval.
The appropriate regional technical branch office approval shall be based upon
a review of the CHDO work.
B. Experience Interpretation Discrepancies.
If a discrepancy is noted, the regional Flight Standards division (RFSD) must
return the worksheet with an explanation to the CHDO for reconsideration.
1) If the RFSD does not concur with the CHDO
and denies the request, the RFSD must return the request, the package, and a
memo indicating the reason for the denial. Any disagreement between CHDO and
RFSD may be submitted to AFS-200 for final determination.
2) If a submittal package contains experience
which is not listed on the ERW (“Other Experience,” line 15),
the CHDO must explain what that “Other Experience” is and forward
the applicant’s résumé with a recommendation and supporting rationale
to accept the experience as comparable to the RFSD. The burden of submitting
complete and helpful information in favor of acceptance of the candidate rests
with the submitting CHDO based on information provided by the certificate holder.
3) If the RFSD needs assistance interpreting
or rating the submittal, they may forward the entire package to AFS-200 with
a memo explaining their concerns and request assistance.
C. After Completion of ERW Job Aid.
1) The RFSD technical branch representative
who conducted the review must check the appropriate approval check box on the
top of the ERW and enter their initials and date.
2) The RFSD must retain a copy and return
the original deviation package, including the ERW, to the CHDO. If the deviation
package is sent to HQ in the case of part
135 commuter operations, be sure to include a copy of the ERW.
3) The POI must retain the original deviation
package, including the ERW and the approval memo from the RFSD or HQ, in the
certificate holder’s file until the applicant has acquired sufficient
experience that a management deviation is no longer required.
1) The ERW depicted below is only a sample.
The most current worksheet version can be found on the respective website listed
in subparagraph 2-162D2). These worksheets are Excel spreadsheets and will calculate
the respective values when the months are entered. Values are specific to each
worksheet and they are not interchangeable.
2) There are four separate worksheets, one
for each of the following positions:
Figure 2-82. Sample of Experience Rating Worksheet
for Chief Pilot Under §
119.71 (Part 135)
NOTE: DO NOT USE THIS WORKSHEET. This is a sample
only and may not be current. Refer to the appropriate website.
Figure 2-82 Sample
of Experience Rating Worksheet for Chief Pilot Under §
119.71 (Part 135)
2-163 FEWER, COMBINED, OR DIFFERENT CATEGORIES
OF REQUIRED MANAGEMENT POSITIONS.
A. Combined Positions. Any certificate holder
who requests approval to combine two or more required part 119
management positions into one position must ensure that the person who will
serve in that position meets the qualifications for, or receives a deviation
for, each management position they will hold (e.g., CP and DO). This is in addition
to receiving an approval to combine the management positions. The size, scope,
complexity, organizational dynamics, and workload of the operations that the
applicant has been involved with, and will be involved with in the combined
management position, must be considered when evaluating this request. Requests
to combine the positions of DOM and Chief Inspector will not be approved. Applicants
who serve in a part 119
combined management position should not be assigned to any additional duties
(e.g., check airman and instructor).
NOTE: A combined part
119 management position for single PIC and basic operators is granted via
OpSpecs A039 and A038. Single-pilot operators issued OpSpec A040 are not required
to have management positions.
B. Consolidated Positions, Part
1) Depending on the organization’s needs,
the Administrator may allow required part 119
management personnel to hold other nonrequired positions and duties.
2) Before allowing an individual to serve
in any of the required part
119 management positions along with any other positions, the PI must consider
the other duties performed by that person. For example, if that person also
plans to serve within another management position, the ASI must ensure that
those duties will not interfere with the person’s responsibilities in
the required part
C. Combined/Consolidated Management Position Steps.
1) The certificate holder/applicant should
submit a request to the CHDO. The request should contain the following information:
a) The type and number of aircraft operated by the
b) Size, scope, any known expansion plans, and safety
records of the certificate holder.
c) Any accident or enforcement history of the certificate
holder and management applicant.
d) All ongoing certificate holder corrective action
commitments made by the involved management position holders prior to the request,
and an updated corrective action plan (CAP) if the request will affect any of
NOTE: The field office will include a statement indicating
the NPTRS, AIDS, and EIS history of the certificate holder and management applicant
have been reviewed. If any adverse findings were encountered, the PI should
verify that the adverse history has been appropriately resolved.
e) A résumé of the individual who is, or will be,
in combined or consolidated positions, including:
areas of experience,
of management positions previously held, and
2) The PI appropriate to the specialty seeking
the deviation is responsible for the following:
a) Interviewing the individual involved to verify
aeronautical experience and qualifications;
b) Determining the size, scope, any known expansion
plans, and safety record of the certificate holder;
c) Verifying the applicant’s résumé and experience;
d) Ensuring that any applicant or certificate holder
corrective action commitments are not adversely affected by the requested management
position change; and
e) Recommending approval or denial of the request.
3) The approval process for combining or consolidating
management positions is the same as that for management deviations found in
2-164 APPROVING MANAGEMENT DEVIATIONS.
A. Authority to Approve or Deny Management Deviation
Requests for Part
121 and 135
Commuter Operations. Deviation authority in §
119.67(e) for part
121 and §
119.71(f) for part
135 commuter operations for granting or denying deviations from this section
is the sole responsibility of the AFS-200 manager and the Aircraft Maintenance
Division (AFS-300) manager, as appropriate. This authority shall include approval
to combine positions or numbers of positions under §§
B. Authority to Approve or Deny Management Deviation
Requests for Part
135 On‑Demand Operations. Deviation authority in §
119.71(f) for part
135 on-demand operations extends the accountability for granting or denying
deviations from this section to the RFSD manager. This authority shall include
approval to combine positions or numbers of positions under §
119.69(b) for on‑demand certificate holders. If the RFSD encounters
a situation where the criteria in the request is peculiar and they are uncomfortable
in making the decision, the package may be forwarded to AFS-200 or AFS-300,
as appropriate, with the explanation as to why it is being elevated and what
the RFSD is recommending.
C. Process for Requesting a Management Deviation.
A certificate holder may request a deviation (see paragraph 2-159) through
the assigned PI; and the CHDO, which recommends approval or denial of the deviation,
will forward their recommendation to the RFSD in the form of a memo including
supporting documentation. For DO and CP positions, the ERW tools will be used
and attached with the package.
D. RFSD Evaluation. The RFSD office will evaluate
the recommendation received and either make final determination in the case
135 on-demand operations or forward their recommendation in the form of
a memo to HQ in the case of part
135 commuter certificate holders. For determinations made at the RFSD office,
a written response to the CHDO in the form of a memo of approval or denial is
E. Reply from HQ. AFS‑200 and/or AFS‑300
will reply, in writing, to the CHDO through the RFSD with a memo of approval
or denial of the request. AFS‑200 and/or AFS‑300 will not take action
on requests received directly from certificate holders or CHDOs without CHDO
manager and RFSD manager recommendations.
NOTE: Once the applicant meets the experience requirement
for the position held and a management deviation is no longer necessary, the
OpSpec A005 deviation should be removed.
Figure 2-83. Parts
135 Commuter Deviation Flowchart
Figure 2-84. Part
135 On-Demand Flowchart
2-165 TASK OUTCOMES.
A. Complete the Task. Completing this task
will result in the following:
1) If the candidate is not acceptable, notify
the certificate holder in writing, either via email or formal letter stating
the reasons for denial, as appropriate.
2) If the candidate does not meet the regulatory
requirements of §
119.67 or §
119.71 and a deviation may be appropriate, notify the certificate holder
to use the deviation process addressed in paragraph 2-159.
3) If the candidate is acceptable, with or
without a deviation, notify the certificate holder in writing, either via email
or formal letter, and authorize the use of the candidate by issuing OpSpecs A006
and A005 listing the deviation (if applicable).
4) File all supporting paperwork in the certificate
B. Document the Task.
1) SAS. For evaluating certificate holders’
119 management personnel, use SAS automation and the associated DCTs. This
section is related to SAS DCTs 1.2.1, (OP) Part
119 Required Personnel, and 1.3.1, (AW) Part
119 Required Personnel.
2) PTRS. For evaluating proposed part
119 management personnel, use PTRS activity code 1352, 3352, or 5352
as appropriate. For processing management deviation requests, use activity code 1328,
3319, or 5319 as appropriate. A change of management personnel requires
the initiation of a configuration change request in SAS (see
Volume 10, Chapter 2, Section 1).
3) File Supporting Paperwork. File all supporting
paperwork in the certificate holder’s file.
2-166 REFERENCES, FORMS, AND JOB AIDS.
A. References (current editions):
14 CFR Parts
120‑59, Air Carrier Internal Evaluation Programs.
10, Safety Assurance System Policy and Procedures.
B. Forms. None.
C. SAS Elements:
119 Required Personnel.
119 Required Personnel.
2-167 FUTURE ACTIVITIES. Follow SAS Volume
10 guidance to plan future risk-based surveillance in SAS. The PI should periodically
review the appropriate related OpSpec and the deviation, if applicable.
RESERVED. Paragraphs 2-168 through 2-180.