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Pilots employed by a Part 135 operation pursue a training
program customized to meet the crewmember training
requirements of its on-demand or commuter operating
certificate, said Phillips. A combination of ground and
flight training, it must cover everything from new-hire
indoctrination, pilot responsibilities, crew resource
management, and the contents of the company's operating
certificate to initial, recurrent, differences, and upgrade
flight training.
Part 135 requires "flight and practice in each of the maneuvers
and procedures in the approved training program curriculum."
These "must be performed in flight, except to the extent that
certain maneuvers and procedures may be performed in
an aircraft simulator, or an approved training device." If the
approved training program includes simulator training, each
pilot must successfully learn and demonstrate the maneuvers
and procedures in the simulator to the "level of proficiency of a
pilot in command or second in command, as applicable."
As Part 135 illustrates, training in simulators is a choice.
Many believe the aviation insurance industry requires their
employment for all pilot training in turbine-powered aircraft
types. Not so, said Paul Ratté, USAIG's safety program
director. "Underwriting standards typically require simulator
training for initial type qualification, but there are points
thereafter where in-aircraft training might be integrated."
Those could include an initial operating experience program
where a newly-qualified second-in-command operates
exclusively with an instructor PIC for a break-in period. "In
some specific cases, underwriters might approve use of
in-aircraft recurrent training for experienced pilots," Ratté
said, "but given their ability to deliver comprehensive training
at low risk, on a reliable schedule that's immune to weather
and other operational factors, simulators tend to be the
sensible choice for most operators."

as what the operation is doing, where it is flying, and who is
leading it, equally important when determining risk. "Given
market size, aviation insurance is not comparable to the auto
insurance industry where you can actuarially predict the risk of
a 23-year-old in a Toyota Camry. In aviation, every operation
is different, and underwriters address them individually." To
encourage operators to employ the best operating practices,
underwriters offer incentives. "Having all pilots perform
recurrent training twice per year in simulators is considered a
preferred practice, and USAIG has a Good Experience Return
program that returns a percentage of the insurance premium
at the conclusion of a no-loss year to our policyholders that
make that investment," said Ratté.
Most operators subscribe to an organized, structured
simulator-based training program because it provides a safe,
comprehensive, and up-to-date education. It's also financially
prudent. An operator's airplanes only earn their keep when
flying their primary mission. Training pilots is an ancillary,
higher-risk mission that is better suited to simulators.
There is no denying that "quality sim training costs a lot,"
said Ratté. "But the old safety officer's paradigm applies:
What would have been your cost of the safety mishap you
did not have?" It is equally important for pilots just starting
their careers. "When moving on to the next job, it is unlikely
that a pilot resume without sim training will make it to the
queue of consideration."

- Scott M. Spangler fell in love with aviation at age 5,
when he found his father's World War II U.S. Navy aircraft
identification manuals. A pilot since 1976, he was the founding
editor of Flight Training magazine. He is a contributing editor
at, Aviation for Women, and Kitplanes.

Logically, underwriters would assign greater risk to an
operation that did not have an organized, structured initial and
recurrent training program. But they find other factors, such


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