Two Exemptions Are Available To All Part 119 Certificated Carriers Operating Under Part 135

The FAA has granted a NATA request for an extension to exemptions regarding certain crew training and checking requirements.

The two exemptions, available to all Part 119 certificated carriers operating under Part 135, were initially granted to NATA in late March, with  Exemption No. 18509 A extended until 07/31/2020 and Exemption No. 18510 A extended until 10/31/2020. Operators that submitted a Letter of Intent prior to May 29, 2020, in accordance with the original issuance of this exemption have met the requirement of Condition and Limitation No. 1 and do not have to submit another letter. Also, operators will be required to update the safety risk assessment or safety analysis and corresponding risk mitigations. Every Part 135 operator should obtain and carefully review these exemptions.

Exemption No. 18509A

Regulations addressed: §§ 135.293(b), 135.295(e) and (g), 135.297(c)(1)(i) and (ii), 135.331(c)(3), (5), and (7), 135.347(a), and 135.351(b)(2) and (c) Provides alternative methods to conduct certain required crewmember emergency procedures during recurrent and upgrade training, testing, and checking.

Exemption No. 18510A

Regulations addressed: §§ 135.245(c), 135.247(a), 135.301(a), 135.323(b), 135.337(g), 135.338(g), 135.339(b), 135.340(b), and 135.505(d)

The exemptions provide additional time for completion of recurrent training and qualification activities of up to three calendar months after the month that the activity was due to have been completed. As an example, the inclusion of training due through July 31, 2020 means that, for a crewmember who was due to complete recurrent training in July as to a requirement that already allowed for one grace month, the original grace month is August. With this two-month extension, the crewmember’s grace months are August, September, and October. If the crewmember completes the training in August-October, the crewmember will be considered to have completed it in July.

"NATA’s continued engagement with the FAA is crucial as restrictions are lifted and the country begins a gradual return to operations. We are grateful the FAA understands the needs of the industry in ensuring access to air transportation remains available and the timeline required to address the currency matters of operators,” stated NATA Vice President of Regulatory Affairs John McGraw.

FMI: www.nata.aero/advocacy/coronavirus