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VOLUME 2 AIR OPERATOR AND AIR AGENCY CERTIFICATION AND

APPLICATION PROCESS

CHAPTER 9 CERTIFICATION OF A PART 141 PILOT SCHOOL

Section 1 Safety Assurance System: Initial Certification or Renewal of a Part 141

Pilot School

Source Basis:
• Section 141.5, Requirements for a Pilot School Certificate.
• Section 141.7, Provision Pilot School Certificate.
• Section 141.11, Pilot School Ratings.
• Section 141.13, Application for Issuance, Amendment, or Renewal.
• Section 141.25, Business Office and Operations Base.
• Section 141.33, Personnel.
• Section 141.35, Chief Instructor Qualifications.
• Section 141.36, Assistant Chief Instructor Qualifications.
• Section 141.37, Check Instructor Qualifications.
• Section 141.38, Airports.
• Section 141.39, Aircraft.
• Section 141.41, Full Flight Simulators, Flight Training Devices, Aviation Training
Devices, and Training Aids.
• Section 141.43, Pilot Briefing Areas.
• Section 141.45, Ground Training Facilities.
• Section 141.53, Approval Procedures for a Training Course: General.
• Section 141.55, Training Course: Contents.
• Section 141.57, Special Curricula.
• Section 141.63, Examining Authority Qualification Requirements.
• Section 141.93, Enrollment.
• Section 141.95, Graduation Certificate.
• Section 141.101, Training Records.

2-1066 REPORTING SYSTEM(S). Use Safety Assurance System (SAS) automation.

2-1067 OBJECTIVE. Determine whether an applicant for a Title 14 of the Code of Federal
Regulations (14 CFR) part 141 pilot school qualifies to operate as a pilot school or provisional
pilot school. This is a certificated entity, and successful completion of this task results in the
issuance, renewal, or denial of Federal Aviation Administration (FAA) Form 8000-4, Air
Agency Certificate. These procedures facilitate the issuance of a provisional pilot school
certificate, for added ratings (amendments), and for a pilot school certificate renewal.

2-1068 GENERAL. Before beginning any certification process, inspectors should review
Volume 3, Chapter 1, Section 1; and Volume 2, Chapter 1, Section 1. Definitions of the terms
used in this chapter are contained in Volume 3, Chapter 53, Section 1.

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NOTE: All five phases of this certification process involve the use of SAS. See
Volume 10, the SAS Automation User Guide (AUG), and the SAS External Portal
Enhanced Checklist (EPEC) to be aware of current policy and automation updates
as the process continues.

2-1069 PREAPPLICATION PHASE. The applicant initiates the process leading to

certification as a provisional pilot school. The applicant contacts the appropriate Flight Standards
District Office (FSDO) to obtain pertinent information concerning a path to certification as a
provisional pilot school. After the preapplication meeting, the applicant may submit an
application for a part 141 pilot school certificate through the SAS External Portal
(https://sas.faa.gov/sas.external.portal/ext/accounts). Once the application has been assigned to a
certification team or an aviation safety inspector (ASI), the documentation of the certification
process will be done in SAS. However, the SAS External Portal is not mandatory for applicants
and part 141 schools. For an initial certification, inspectors should discuss the following items
with an applicant during an initial inquiry about a part 141 certificate.

A. Pilot School Ratings. The term “pilot school rating” used in part 141, § 141.11
describes the certification and rating courses that can be approved for part 141 pilot schools.
Pilot school ratings are listed on a part 141 pilot school’s Air Agency Certificate. For schools
that submit training course outlines (TCO) and the associated syllabi and must meet minimum
time requirements of part 141, in accordance with § 141.55(d) or (e) (as appropriate), it is
imperative that these schools’ TCOs and syllabi cover all of the aeronautical knowledge areas
and flight training required for the rating and course. Inspectors must ensure the pilot school
ratings listed on an Air Agency Certificate reflect the certification and rating courses in
accordance with § 141.11(b)(1) as listed below.

NOTE: Part 141 appendix M does not appear in § 141.11. However, it is one of
the possible certification courses that can be listed on an Air Agency Certificate.

1) Certification and Rating Courses (Part 141 Appendices A through J and M).

• Recreational Pilot Course,

• Private Pilot Course,
• Instrument Rating Course,
• Combined Private Pilot and Instrument Rating Course,
• Commercial Pilot Course,
• Airline Transport Pilot (ATP) Course,
• Flight Instructor Course,
• Flight Instructor Instrument Course,
• Ground Instructor Course,
• Additional Aircraft Category or Class Rating Course, and
• Aircraft Type Rating Course.

2) Special Curriculum Course Under § 141.57, Special Curricula, and Part 141
Appendix K, Special Preparation Courses.

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• Pilot Refresher Course,

• Flight Instructor Refresher Course (FIRC),
• Ground Instructor Refresher Course,
• Agricultural Aircraft Operations Course,
• Rotorcraft External-Load Operations Course,
• Special Operations Course,
• Test Pilot Course, and
• ATP Certification Training Program (CTP).

3) Part 141 Appendix L, Pilot Ground School Course.

B. Recreational Pilot Course. The approval of one or more courses of training that
result in the original issuance of a recreational pilot certificate entitles the school to have a
recreational pilot rating placed on its school certificate. The approval of one or all of the
following certification courses entitles the school to a recreational pilot rating for the following
courses, as appropriate:

• Airplane—Single-Engine,
• Rotorcraft—Helicopter, and/or
• Rotorcraft—Gyroplane.

C. Private Pilot Course. The approval of one or more courses of training that result in
the original issuance of a private pilot certificate entitles the school to have a private pilot rating
placed on its school certificate. The approval of one or all of the following certification courses
entitles the school to a private pilot rating for the following courses, as appropriate:

• Airplane—Single-Engine,
• Airplane—Multiengine,
• Rotorcraft—Helicopter,
• Rotorcraft—Gyroplane,
• Powered-Lift,
• Glider,
• Lighter than Air (LTA) Airship, and/or
• LTA Balloon.

D. Instrument Rating Course. The approval of one or more courses of training that
result in the original issuance of an instrument rating entitles the school to have an instrument
rating placed on its school certificate. The approval of one or all of the following certification
courses entitles the school to an instrument rating for the following courses, as appropriate:

• Instrument—Airplane,
• Instrument—Helicopter, and/or
• Instrument—Powered-Lift.

E. Commercial Pilot Course. The approval of one or more courses of training that
result in the original issuance of a Commercial Pilot Certificate entitles the school to have a

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commercial pilot rating placed on its school certificate. The approval of one or all of the
following certification courses entitles the school to a commercial pilot rating for the following
courses, as appropriate:

• Airplane—Single-Engine,
• Airplane—Multiengine,
• Rotorcraft—Helicopter,
• Rotorcraft—Gyroplane,
• Powered-Lift,
• Glider,
• LTA Airship, and/or
• LTA Balloon.

F. ATP Course. The approval of one or more courses of training that result in the
original issuance of an ATP Certificate entitles the school to have an ATP rating placed on its
school certificate. The approval of one or all of the following certification courses entitles the
school to an ATP rating for the following courses, as appropriate:

• Airplane—Single-Engine,
• Airplane—Multiengine,
• Rotorcraft—Helicopter, and/or
• Powered-Lift.

G. Flight Instructor Course. The approval of one or more courses of training that result
in the original issuance of a flight instructor certificate entitles the school to have a flight
instructor rating placed on its school certificate. The approval of one or all of the following
certification courses entitles the school to a flight instructor rating for the following courses, as
appropriate:

• Airplane—Single-Engine,
• Airplane—Multiengine,
• Rotorcraft—Helicopter,
• Rotorcraft—Gyroplane,
• Powered-Lift, and/or
• Glider.

H. Flight Instructor Instrument Rating Course. The approval of one or more courses
of training that result in the original issuance of a flight instructor certificate with an instrument
rating entitles the school to have a flight instructor instrument rating placed on its school
certificate. The approval of one or all of the following certification courses entitles the school to
a flight instructor instrument rating for the following courses, as appropriate:

• Flight Instructor Instrument—Airplane,

• Flight Instructor Instrument—Helicopter, and/or
• Flight Instructor Instrument—Powered-Lift.

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I. Ground Instructor Course. The approval of one or more courses of training that
result in the original issuance of a ground instructor certificate entitles the school to have a
ground instructor rating placed on its school certificate. The approval of one or all of the
following certification courses entitles the school to a ground instructor rating for the following
courses, as appropriate:

• Ground Instructor Instrument—Basic,

• Ground Instructor Instrument—Advanced, and/or
• Ground Instructor Instrument—Instrument.

J. Additional Aircraft Category or Class Rating Course. The approval of one or

more courses of training that results in the issuance of an additional aircraft category or class
rating to an existing pilot certificate entitles the school to have “Additional Aircraft Category or
Class Rating” placed on its school certificate. The approval of one or all of the following
additional aircraft rating courses entitles the school to the above listed rating.

• Airplane—Single-Engine,
• Airplane—Multiengine,
• Rotorcraft—Helicopter,
• Rotorcraft—Gyroplane,
• Powered-Lift,
• Glider,
• LTA Airship, and/or
• LTA Balloon.

K. Aircraft Type Rating Course. The approval of one or more courses of training that
result in the issuance of an aircraft type rating entitles the school to have aircraft type rating
placed on its school certificate. The approval of one or all of the following aircraft type rating
courses entitles the school to an aircraft type rating for the following courses, as appropriate:

• A type rating in an airplane category, single-engine class;

• A type rating in an airplane category, multiengine class;
• A type rating in a rotorcraft category, helicopter class; and/or
• A type rating in a powered-lift category.

L. Special Preparation Course. Under part 141 appendix K, the approval of one or
more courses of training that prepares the graduate with the necessary skills, competency, and
proficiency to exercise safely the privileges of a certificate, rating, or authorization for which the
course is established. This course entitles the school to have that special preparation course
rating (e.g., pilot refresher course or agricultural aircraft operations course) placed on its school
certificate. The approval of one or all of the following special preparation courses entitles the
school to a pilot school rating for the following courses, as appropriate:

• Pilot Refresher Course,

• FIRC,
• Ground Instructor Refresher Course,

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• Agricultural Aircraft Operations Course,

• Rotorcraft External-Load Operations Course,
• Special Operations Course,
• Test Pilot Course, and/or
• ATP CTP.

M. Pilot Ground School Course. The approval of one or more ground school courses
under the provisions of part 141 appendix L entitles the school to have a pilot ground school
rating placed on its school certificate.

N. Special Curriculum Course. The approval of a special curriculum course under

§ 141.57 entitles the school to have “Special Curriculum Course” appear on its school certificate,
the student enrollment certificate, and the graduation certificate. This applies to a curriculum that
is not already prescribed in the appendices of part 141. The special curriculum course must
contain features that could achieve a level of proficiency equivalent to that achieved by a training
course prescribed in the appendices of part 141 or the requirements of 14 CFR part 61. Some
examples include high performance training, complex aircraft training, tailwheel training, model
transition training, technically advanced aircraft (TAA) training, turboprop transition training,
mountain flying, and many others that may not necessarily lead to a certificate or rating, but are
otherwise specialized training.

O. Certification Team Assignment. As described in the procedures in Volume 2,

Chapter 1, Section 1, the FSDO manager assigns the applicant a certification team. The manager
also designates one member of the team as the certification project manager (CPM).

P. Contact With the Appropriate FSDO. When the prospective applicant contacts the
FSDO, the FSDO manager and assigned inspector(s) will outline the part 141 certification
requirements, aircraft requirements, and FAA policy and procedures. This is a time for the
prospective applicant to ask questions, learn what is required to be certificated as a provisional
pilot school, and learn what will be necessary to maintain the part 141 pilot school’s certificate.
This is a time for the assigned inspectors to learn about the applicant and what resources will be
necessary in order to support the prospective applicant during the certification process.

Q. Letter of Intent (LOI). During the preapplication phase, the inspector’s FSDO
should brief the applicant on submitting an LOI that includes the following:

1) Statement of intent (SOI) to become a certificated pilot school under part 141.

2) The company’s legal name and any doing business as (DBA) names, the principal
operation’s base address, the primary airport address, the mailing address, telephone numbers,
and email addresses.

3) Make and model (M/M) of aircraft, number of aircraft, numbers of each type of
aircraft, and if available, aircraft registration numbers of the proposed part 141 pilot school’s
aircraft.

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4) Listing any FAA-qualified and approved full flight simulators (FFS), flight
training devices (FTD), or Aviation Training Devices (ATD) that will be used for training credit
for a certificate or rating.

5) Estimated date when operations are planned to begin.

6) Training courses to be offered and ratings requested with any training course(s).

7) Name and qualifications of a proposed chief instructor for each course, and name
and qualifications of any assistant chief instructor(s), if applicable, for each course who will be
employed by the proposed part 141 pilot school.

8) Training aids to be used, including computer programs.

9) Intent to use computers, tablets, or other electronic devices for course delivery or
portions of course delivery, including the use of electronic recordkeeping and the use of tablets
during the operation of an aircraft.

10) Recordkeeping methods, including electronic logbooks and other electronic data
storage, and the proposed method of security with these devices.

11) Any intended use of tablets in order to provide students with copies of syllabi, to
be used by students in flight courses, or for student recordkeeping.

12) Three separate, three-letter designators (in order of preference) for use in Letters
of Authorization (LOA) and certificate management.

13) Proposed maintenance on the training aircraft, and if they will be contracting their
maintenance out to another source.

14) A briefing on SAS and the SAS External Portal.

R. FSDO Review of the LOI. The appropriate FSDO will review all submissions and
provide feedback to the applicant within 30 days of receiving an LOI. The FSDO will determine
if the LOI provides sufficient information for the certification process to continue. The
preapplication phase ends and the formal application phase begins with receipt of the completed
FAA Form 8420-8, Application for Pilot School Certification.

S. The Applicant’s Responsibility. It is the applicant’s responsibility to know,

understand, and be prepared to comply with relevant parts of 14 CFR parts 61, 91, and 141. It is
also the applicant’s responsibility to contact the appropriate FSDO for guidance, ask questions if
something is not understood, and devote the necessary time, financial, and human resources
during the certification process. Ultimately, the applicant is responsible to its prospective
students to deliver quality instruction based on a well-thought-out course of instruction.

T. The Appropriate FSDO’s Responsibility. It is the appropriate FSDO’s

responsibility to devote the time and resources to new and existing part 141 pilot schools and

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explain and answer questions the applicant may have. The FSDO will keep the applicant
apprised on the status of their application.

U. Joint Responsibility. The applicant and the assigned FSDO personnel on the
certification team must work together in order for the application to result in the initial
certification of a provisional pilot school. This joint responsibility does not end with the
certification of a part 141 pilot school; rather, this joint responsibility is an ongoing process.

2-1070 FORMAL APPLICATION PHASE. The formal application phase begins when FAA
Form 8420-8 is submitted to the appropriate FSDO.

A. Requested Part 141 Pilot School Training Courses and Ratings. Each part 141
pilot school training course must be listed on the FAA Form 8420-8 when the application is
submitted. Because the process to certificate a provisional pilot school is complex, inspectors
should suggest to the applicant they begin the certification process by requesting certification for
one or two rating courses only. After the initial certification, the part 141 pilot schools are
encouraged to add more ratings and courses to its certificate as needed.

B. Signatures on FAA Form 8420-8. All applications must be signed, either in ink on
paper or electronically. FAA Form 8420-8 contains information on who is authorized to sign the
form. This depends on whether the applicant is an individual, partnership, corporation, company,
club, or association.

C. TCO and Syllabus. A TCO and syllabus are required for each course under a rating
when the formal application is submitted. The TCO describes the content of a particular course
by statement of objectives, description of teaching aids, definition of evaluative criteria,
indication of desired outcomes, and duties and responsibilities of the chief instructor and other
personnel. The syllabus is an outline and summary of the topics to be covered in a training
course.

D. Electronic Recordkeeping/Manual/Signature Systems. Handwritten signatures,

paper records, and paper manuals continue to be acceptable. However, an applicant may use
electronic submissions, including submitting an electronic application (FAA Form 8420-8),
electronic TCOs, and electronic syllabi, and may maintain a system of electronic recordkeeping.
During the preapplication phase, the prospective applicant must inform the FAA of its intent to
utilize electronic submissions for all TCOs, syllabi, records, and applications. One electronic
TCO submission is equal to two paper copy submissions. As outlined in Advisory Circular
(AC) 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals,
applicants and certificate holders intending to use electronic recordkeeping, TCOs, syllabi,
applications, training records, or other documents must inform the appropriate FSDO prior to
implementing an electronic system. To obtain authorization, the applicant must submit a letter to
the appropriate FSDO describing the proposed computer and electronic system, including the
proposed sections or revision to the part 141 pilot school’s electronic recordkeeping, TCOs,
syllabi, applications, and other documents.

NOTE: Authorization of electronic systems can be done after certification

provided the guidance in this paragraph and the AC is followed.

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E. The Formal Application Meeting. If the certification team convenes a formal

application meeting, all Operations, Maintenance, and Avionics members of the team should be
present.

F. Meeting Topics. The meeting should review, but not be limited to, the following:

• The application.
• The Schedule of Events (SOE), if applicable.
• TCO and syllabus.
• Personnel including the chief instructor and assistant chief instructor, aircraft, and
facility requirements.
• Electronic recordkeeping, signature, and/or manual systems.
• How approvals and authorization will be issued by automated LOA through the
Web-based Operations Safety System (WebOPSS).
• Training aircraft qualifications.
• What training aircraft will be used.
• Plan for the maintenance of training aircraft.

G. Application Denial. Within 30 days of a denial of an application, the appropriate

FSDO must substantiate this denial with a letter to the applicant. The letter from the appropriate
FSDO must state the reasons for the denial, and what actions are needed by the applicant in order
to obtain a part 141 pilot or provisional pilot school authorization. An applicant may reapply at
any time for a rating(s) in the same manner as prescribed for initial application. At the discretion
of the appropriate FSDO, reinspection of previously approved areas may not be necessary.

2-1071 DOCUMENT COMPLIANCE PHASE. The applicant’s proposed TCO and syllabus
for each course, system for student record documentation, personnel records documentation,
student safety guide, and training records of the chief instructor, assistant chief instructor,
assigned instructors to a course, and check instructors, as well as other documents, are reviewed
during the document compliance phase in depth to ensure compliance with part 141.

A. TCOs. TCOs must be submitted in duplicate. However, submission of TCOs and

syllabi may be done electronically, with one electronic submission equal to two paper copies.
During initial approval of the TCO, the inspector may request only one paper copy for review.
Once the TCO has met all the requirements, the applicant submits the required two paper copies,
or one electronic copy.

B. Commercially Produced Syllabi. Commercially produced syllabi should be

submitted a minimum of 30 days before the expected training begins. ASIs do not need to do any
further review on these commercially produced syllabi as these syllabi have already been
reviewed by the Airmen Certification and Training Branch and have received a letter indicating
the syllabus has been found to meet the part 141 standards for that rating and course, provided
the syllabus is not used in a § 141.57 special curriculum course. Refer to §§ 141.53 and 141.55.
This letter from the Airmen Certification and Training Branch is submitted with the syllabus.

NOTE: When the part 141 pilot school uses a commercially developed syllabus,
it must ensure the syllabus remains up-to-date. The part 141 pilot school can only
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use the FAA-approved version. In the event of a commercial syllabus revision, the
part 141 pilot school must submit to the appropriate FSDO the updated syllabus
for review and approval.

C. Special Curricula. A pilot school or provisional pilot school may apply for approval
to conduct a special course of pilot training provided the training curriculum is not one that is
prescribed in the appendices of part 141. A special course of airman training must contain
features that can be expected to achieve a level of pilot competency equivalent in scope and
depth to that achieved by the curriculum prescribed in the appendices of part 141 or the
requirements of part 61. This includes any ground instruction required for a certificate or rating.
A Designated Pilot Examiner (DPE) may only conduct a practical test for pilot certification
provided the applicant has completed all of the pilot school/provisional pilot school’s special
curriculum training course requirements and has received a graduation certificate for the entire
course of training. Provisional pilot schools and pilot schools may not issue a graduation
certificate unless the entire course is completed. A pilot school may not apply for examining
authority unless the training course meets the requirements set forth in the appropriate
appendices of part 141. A pilot school may not apply for a training course with reduced training
minimums under § 141.55(d) or (e) unless that pilot school holds a pilot school certificate and
has held the rating and course for at least 24 calendar-months. A pilot school with a provisional
pilot school certificate is not eligible for a course with reduced training minimums in this section.
If a pilot school applies for a special course of airman training with reduced training times, that
pilot school must comply with the provisions set forth in § 141.55(d) and (e). In accordance with
§ 141.55(d)(3) and (e)(4), a pilot school may not be approved for examining authority for a
special course of airman training that has been approved for reduced training times. A
provisional pilot school may not apply for a special course of airman training with reduced
training times under § 141.55(d) and (e).

1) Required Documentation. An original and one copy, or one electronic original,

of a proposed special curriculum must be submitted along with a cover letter requesting FAA
approval at least 60 days before the training is scheduled to begin. Approval or denial should be
accomplished within 30 days, allowing the school sufficient time to develop a TCO based on the
special curriculum.

2) Special Curriculum Graduation Certificate. The graduation certificate the pilot

school or provisional pilot school issues will state that the student has completed the special
curriculum course. Before the pilot or provisional pilot school issues the graduation certificate,
the student must have completed the entire special curriculum course including all stage checks
and the final end-of-course test. This must be explained to the pilot or provisional pilot school
applicant who wishes to develop a special curriculum course.

3) Special Curriculum Approved. When a special curriculum is approved, each

page of the original and office copies should be dated and signed by the Principal Operations
Inspector (POI). The original paper copy, or the signed electronic copy, of the special curriculum
should be returned to the school.

4) Special Curriculum Disapproved. When a special curriculum is disapproved,

the original and copy, and any electronic submissions submitted to the FAA, should be returned

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to the applicant along with a letter clearly explaining why the materials were disapproved (see
Figure 2-63, Sample Letter Disapproving Special Curricula or TCOs). A copy of the letter to the
applicant is retained in the school’s file at the appropriate FSDO. If major changes to a special
curriculum or TCO are necessary, the letter to the school should clearly state the additional items
that will be needed for review when resubmitted.

D. Internet-Based Training. An applicant for a part 141 pilot school certificate seeking
to utilize internet-based training must comply with § 141.53(d), ensuring security, integrity,
confidentiality, availability, access control, and identification/authentication of its internet-based
training course.

1) A part 141 pilot school may use a commercially produced internet course if it
meets all of the requirements of § 141.53.

2) The internet training provider (ITP) will receive a letter from the General
Aviation and Commercial Division stating that its syllabus and content meets the requirements of
part 141.

3) The applicant for a part 141 pilot school may receive a letter from the ITP stating
that its course appears to meet the FAA’s internet-based requirements and meets the syllabus
requirements of part 141.

4) The ASI approving the TCO, which includes the syllabus, may use this letter in
verifying the internet-based training meets the requirements of part 141. However, the
appropriate FSDO retains the final authority for the approval of this ITP for use in the school’s
TCO.

E. Training Agreements. A part 141 pilot school may elect to provide flight training to
an institution of higher education. The training agreement could make the institution of higher
education eligible under part 61, § 61.169 to receive an LOA for certifying its graduates for an
ATP Certificate under the academic and aeronautical experience requirements in § 61.160. The
training agreement under § 141.26(b) is a bridging document for a rating and course. This allows
an institution of higher education to provide the aeronautical knowledge training in a rating and
course and a flight training provider to provide the flight training in that exact same rating and
course. Each provider in this training agreement should use the same syllabus.

F. Part 61 Amendments. If ground or flight time requirements are amended in part 61,
at the time of renewal of the part 141 pilot school certificate, affected TCOs must be amended to
meet these new training time requirements.

2-1072 DEMONSTRATION AND INSPECTION PHASE. During the demonstration and

inspection phase, the applicant’s facilities and equipment are inspected, and ASIs observe
personnel in the performance of their duties. Emphasis in this phase is on compliance with the
regulations and safe operating practices for a part 141 provisional pilot school.

A. Facilities and Training Aids. A pilot school is required to have certain facilities in
order to obtain and maintain an FAA Form 8000-4. Included in these facilities are the business

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office and main base of operations, pilot briefing areas, aeronautical knowledge training
facilities, use of airports, and satellite bases.

1) The applicant having ownership of the required facilities or by having a written

agreement with the facility owners may show continuous use of facilities. A written agreement
must state that the applicant has the required continuous use of the necessary facilities for at least
6 months from the date of the application for the initial certification or renewal of a school
certificate.

2) Each pilot school or provisional pilot school is required to maintain a principal

business office with a mailing address the same as that on the school certificate. The purpose of a
principal business office is to provide a specific location for the required school files and records,
and a location where the operation of school business may be conducted. This requirement
should not be construed to mean that all school functions, such as scheduling flights and training
functions, must be conducted at the principal business office.

a) While part 141 does not require that a business office be a room with four
walls and a door, the regulation does prohibit the sharing of a single business office by more than
one pilot school. Therefore, walls or partitions to ensure separation from another pilot school’s
activity should conspicuously isolate the business office.

b) The business office should be situated so the required school files and student
training records are kept up-to-date and available to students and instructors alike. This serves
the purpose of providing on-the-spot information regarding training progress and other business
interests.

c) If the pilot school should choose to change the location of its business office
or base of operations, the school is required to notify the appropriate FSDO in writing of the
planned move at least 30 days prior to the change. Such written notice should be accompanied by
a new application, FAA Form 8420-8, showing the change of address or the change in the base
of operations as appropriate. In any case, the notice of a change of operating base must be
accompanied by necessary amendments to approved TCOs.

d) Any changes the pilot school requests must be done through the SAS External
Portal. This includes anything from an address change to a course, new satellite base, or chief
pilot change. The SAS External Portal and change request are described in Volume 10.

3) A school is required to have continuous use of a pilot briefing area at each airport
where training flights originate. This does not include airports used as destinations for
cross-country flight training. The briefing area must meet the requirements of § 141.43. Pilots
not participating in the school’s training programs can use the briefing facilities, provided that
orderly school functions are maintained. However, no other pilot school may use the area during
the period it is to be used by the applicant. Briefing areas are subject to FSDO approval under the
provisions of § 141.43.

a) To meet the requirements of § 141.43, the equipment should include a

chalkboard and tables of adequate size to lay out aeronautical charts, and also support the use of
computers and internet access.
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b) If a school offers instrument or commercial pilot courses, it is required to have

access to a Flight Service Station (FSS). A telephone, either by landline or other telephone
communications such as the use of cell phones, is required in the briefing room.

c) To preclude a disruption of schedules due to excessive travel time and a lack

of communications between the flight line, business office, and briefing area, the area should be
located near enough to the airport where training flights originate.

4) The FAA recognizes that pilot training methods differ from other kinds of
training. Pilot schools enroll students with widely varying backgrounds, goals, and varying
degrees of motivations and aviation experience. For this reason, it is understandable that it is not
always possible to schedule large classes for aeronautical knowledge training at one time.
Individual instruction is often necessary for maximum benefit to a particular student. Therefore,
it is anticipated that FAA-approved schools will use classrooms, small isolated rooms, training
booths, or other areas with an instructor or a training aid, as appropriate. Each aeronautical
knowledge training area is required to be heated, lighted, and ventilated to meet the applicable
building code requirements for the area concerned. All ground instructional facilities used by the
applicant must be shown to the appropriate FSDO to verify it meets the requirements of
§ 141.45.

5) A certificate holder may use training aids to improve communication between

instructors and students.

a) Training aids are instructional aids defined by the National Education

Association (NEA) as “devices that assist an instructor in the teaching and learning processes by
presenting, supporting, or supplementing material, usually intermittently. They are not
self-supporting.” The key factor is that such aids support, supplement, or reinforce.

b) Identified in each course outline, training aids should be easily understood,

readily visible, and compatible with the learning outcomes expected in the completion standards
for the lesson. They must be accurate and appropriate to the course. The effectiveness of aids is
judged by their organization, sequencing, pattern of logic, and overall effectiveness when used in
support of obtaining the objectives and standards prescribed by the training syllabus.

c) Recent years have seen an abundance of excellent new material and

techniques in training aids. The aids present many advantages for the school. Each school must
keep in mind the teaching goals to be achieved, including the continuous monitoring of student
progress necessary to develop effectively the knowledge of each student according to the training
syllabus. Aids do not replace the instructor. It is not expected that students be sent off alone to
learn from a training aid.

d) Notwithstanding the complexity or design of a training aid, the chief instructor

or an authorized, qualified representative must determine through personal review or testing that
the standards for each lesson have been attained through use of the training aid. The purpose of
this personal review or testing is to ensure that students meet the completion standards and
understand missed questions if a knowledge test is given. Only through such evaluation can the
instructor make a sound determination that the student should progress to the next lesson or that

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the student requires review of subjects or procedures previously covered. This helps in
determining the effectiveness of the training aid.

6) An applicant for a pilot school or provisional pilot school certificate must show
that it has the continuous use of each airport where training flights originate (airports where
flights are dispatched or initiated, such as main or satellite bases).

a) Airports the applicant uses where flights originate must meet the requirements
of § 141.38. Note that § 141.38(b) only applies for airports used for airplanes or gliders.

b) Landing area outline lights, water area boundary lights, or temporary lighting
such as flare pots or deployed portable electric runway lighting systems do not meet the
requirements of § 141.38(e).

c) Though the wind tee and tetrahedron may serve as landing direction or wind
indicators, according to the FAA-H-8083-25, Pilot’s Handbook of Aeronautical Knowledge, the
Aeronautical Information Manual (AIM) cautions against using the tetrahedron as a wind
indicator. The wind tee, under certain circumstances, may be either an active runway or wind
indicator.

d) When required, the traffic direction indicator (refer to § 141.38(d)) must show
the direction of traffic patterns for all runways regardless of landing or takeoff direction.

NOTE: When referring to pilot schools approved for LTA balloons, the term
“airport” should be taken to mean launch site. An important training element in
balloon training is proper site selection. Before the launch of a balloon, an
instructor authorized by the school must approve the site. The specific equipment
requirements of § 141.38 (i.e., runway lights, traffic direction indicators, and wind
direction indicators) are inappropriate for LTA balloon operations. Wind direction
may be determined by means of a pilot balloon. The area downwind from the
launch site should be free of obstructions for 100 feet for each knot of wind. For
example, a 4-knot wind requires a 400-foot area free of obstruction downwind.
Landing site selection will be determined by the pilot in command (PIC).

B. Satellite Bases. A pilot school may conduct aeronautical knowledge or flight training
in an approved course of training at one or more satellite bases. A satellite base may be located
outside of the United States, and the same procedures apply if the satellite school was located in
the United States. The FSDO should coordinate this satellite base outside of the United States
with the International Program Division to determine the associated fees in accordance with
14 CFR part 187. An assistant chief instructor must be designated for each satellite base. The
airport, facilities, aircraft, and personnel used at the satellite base must meet the requirements of
part 141, including approval of the satellite base and its facilities in the approved TCOs for
courses provided at those locations. A copy of the school’s Air Agency Certificate and a copy of
the automated letter indicating the list of approved courses for the school must be displayed at
the satellite base. The school’s record in the SAS Vitals (referred to as Vitals) will indicate the
satellite base. The FSDO with oversight for the pilot school may coordinate satellite base
inspections with another FSDO when necessary.

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1) The ASI who has oversight for the part 141 school will contact the Aviation Data
Systems Branch for a separate and unique designator code for each satellite pilot school, based
on the primary school designator. This is for recordkeeping and to ensure the satellite school is
associated with the primary base. However, the satellite school does not receive a separate Air
Agency Certificate. The main base and each satellite school location should have its own entry in
Vitals. Request precertification numbers and designator codes through SAS. The automation
walks you through the process; then there is a button the principal inspector (PI) can select to
request the code.

2) The holder of a provisional pilot school certificate or pilot school certificate may
conduct training at a location other than the primary address on record and would not be required
to apply for a satellite base of operations, provided the secondary location is within the same
metro area, town, or airport as the provisional pilot school or pilot school. The pilot school or
provisional pilot school would need to utilize the same chief instructor, flight instructors, and
TCO and syllabus on record for that course. Those training locations must be located within the
same appropriate FSDO and must be sanctioned and approved by that same appropriate FSDO.
If a valid reason exists, training may be conducted for periods up to 7 consecutive days at a
satellite base, excluding any satellite base outside of the United States, without approval of the
appropriate FSDO. For example, runways may be closed at the main operations base for
maintenance, or other activities may be underway on the airport. The appropriate FSDO must be
notified in writing if training is conducted at a satellite base for more than 7 consecutive days.

3) When the appropriate FSDO is notified that a school will conduct training at an
unapproved satellite base for more than 7 consecutive days, an operations inspector should
determine if the operations are of a temporary nature or if they will involve extended use of the
unapproved base. If, in the opinion of the operations inspector, temporary use of the unapproved
base will not derogate safety or the quality of training, temporary operations at that base may be
authorized for a period of time not to exceed 30 days.

4) If operations at the unapproved satellite base will exceed a period of 30 days, the
school should apply to the appropriate FSDO for the approval of a satellite base on FAA
Form 8420-8. Along with the application, two copies of the appropriate amendments for each
approved training course to be given at the satellite base must be submitted.

5) Each satellite base that approval is requested for is inspected to ensure that each
meets the requirements of part 141 and training, as described in each approved course of
training, can be effectively accomplished. (See Volume 6, Chapter 7, Section 1.)

6) If a satellite base is located in another FSDO’s area of responsibility, the FSDOs

involved must coordinate directly with each other.

7) If the applicant intends to conduct training at a satellite base located in another

FSDO’s area, the FSDO where the applicant’s principal business office and main operating base
is located is responsible for inspection and approval of the satellite base.

a) The appropriate FSDO may request assistance directly to the satellite or the
responsible Flight Standards office for the area, manager to manager. (In some FSDOs, the

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responsible Flight Standards office for the area rather than a satellite FSDO may be responsible
for surveillance and inspection.) SAS has a geographic request process that should be used to
request the assistance of another PI, ASI, or FSDO. This process is described in Volume 10. In
addition, document the lack of assistance in SAS.

b) If a satellite or the responsible Flight Standards office for the area determines
that it cannot provide the requested assistance (because of inspector workload or other reasons),
the appropriate FSDO needs to request assistance from their respective division manager. In
addition, document the lack of resources in SAS.

c) Coordination between all FSDOs where the school maintains a satellite base
must be accomplished before issuance of the FAA Form 8000-4.

8) The inspector completing FAA Form 8420-8, as shown in Figure 2-64, Sample
FAA Form 8420-8, Application for Pilot School Certification, Filled Out for Approval of
Satellite Base, accomplishes approval of the satellite base. One copy of the form may be returned
to the applicant, and one copy is placed in the school files at the FSDO. Amendments to each
course of training to be given at the satellite base are approved individually, as appropriate.

9) When an application is disapproved, the applicant should be notified in writing

(see Figure 2-65, Sample Letter Denying Satellite Base). This notification should include all of
the reasons why the application was disapproved.

10) When an operator plans to conduct training at a location other than the main base
of operations for more than 7 consecutive days, they must notify the appropriate FSDO. The new
training location is not considered a separate school operating under the main base Operating
Certificate number designation; a separate Operating Certificate is not issued. Appropriate
FSDOs should coordinate efforts to ensure that standardized certification of applicants within
their FSDO area occurs and that the necessary work program functions are accomplished.

C. Aircraft, FFSs, FTDs, and ATDs (§§ 141.39 and 141.41). Each aircraft used for
pilot training by a school located in the United States is required to be a civil aircraft of U.S.
registry. If the school’s training facility is located outside the United States and the training will
be conducted outside the United States, the aircraft may be a civil aircraft of foreign registry.
Training aircraft must have a valid Standard Airworthiness Certificate, a Special Airworthiness
Certificate in the primary category, or a Special Airworthiness Certificate in the light-sport
category. Aircraft used for a course of training specific to a special operation such as agricultural
aircraft operations, external-load operations, and similar aerial work operations (e.g., banner
towing and skywriting) may be certificated in the restricted category (part 91, § 91.313 and
14 CFR part 21, § 21.25(b)). No other Special Airworthiness Certificate is acceptable. If the
school’s training facility is located outside the United States and the training will be conducted
outside the United States, the aircraft must have a standard or primary airworthiness certificate or
an equivalent certification from the foreign aviation authority. If an FAA-qualified FFS or FTD
or an FAA-authorized ATD is used in an approved training course, the details of its utilization
should be clearly stated in the training syllabus and the learning objectives should be well
defined.

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1) A valid FAA Statement of Qualification (SOQ) (for FFS or FTD) or LOA (for
ATD) must accompany each FFS, FTD, or ATD.

2) Each aircraft used by a school for flight training and solo flights must comply
with § 141.39 and must be inspected and maintained in accordance with the requirements for
aircraft operated for hire under part 91 subpart E. If the school’s training facility is located
outside the United States, and the training will be conducted outside the United States, the
aircraft may meet equivalent maintenance and inspection requirements from the foreign aviation
authority.

a) This requires aircraft used in an approved course of training to have 100-hour

inspections and annual inspections or to be maintained following a procedure prescribed under
§ 91.409(c).

b) It should be clearly understood that these inspection requirements include

aircraft used for dual instruction, solo, and PIC flights.

c) Aircraft to be used by pilot schools will be inspected by an Airworthiness

inspector.

3) When a student enrolled in an approved school provides an aircraft for personal

use in an approved course, that aircraft must meet the requirements of the training aircraft
described in the appropriate TCO. In addition, that aircraft must meet the same inspection
requirements as aircraft operated by the approved school.

4) Aircraft used for instrument training should be equipped as follows to meet the
requirements of part 141:

a) If the approved training syllabus requires flights under instrument flight rules
(IFR), the aircraft used must be one in which instrument flight is authorized by its operating
limitations and by its equipment.

b) If the approved training syllabus requires only simulated IFR operations, the
aircraft must be equipped and maintained for IFR operations. However, IFR operations need not
be authorized by its operating limitations.

c) An aircraft not completely equipped for IFR operations may be used for
instruction in the control and maneuvering of an aircraft by reference to instruments if it is
approved in the TCO. For example, an airplane need only be equipped with appropriate flight
instruments needed for the basic instrument portion of a course.

5) The commercial pilot certification course (airplane), set forth in part 141
appendix D, requires flight instruction in a complex airplane, a turbine-powered airplane, or a
technically advanced airplane.

a) Single or multiengine airplanes may be used to fulfill this requirement. Use of

an appropriately equipped multiengine airplane to meet the complex airplane requirements for a

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Commercial Single-Engine Airplane Certificate does not result in the issuance of a multiengine
rating.

b) If a school applies for a commercial pilot certification course (airplanes) with

a seaplane class rating (using seaplanes for the entire course), a special curriculum should be
submitted under § 141.57 that includes the general requirements of part 141 appendix D,
Commercial Pilot Certification Course. The complex airplane used in such a course must have
flaps, a controllable propeller, and floats. The use of an amphibian airplane in a commercial pilot
certification or course could qualify a student for both a land and sea class rating, provided the
TCO was so approved.

6) A variety of airplanes are used in pilot training. Some are uncomplicated while
others are more complicated, and their checklists vary accordingly. The requirements for a
checklist defined in the terms of “pretakeoff” and “prelanding” in § 141.75(a) are broad and
allow less complicated aircraft to be equipped with relatively simple checklists. The FAA
expects (because of good operating practices) that schools should expand checklists for aircraft
that are more complicated.

7) Under § 141.75, when the manufacturer provides a pilot’s operating handbook

(POH), Airplane Flight Manual (AFM), or Rotorcraft Flight Manual (RFM), it (or a copy) must
be carried aboard the aircraft. The primary purpose of carrying the handbook (or a copy) aboard
the aircraft is to provide the pilot with information such as performance data, servicing
instructions, and Weight and Balance (W&B) information. Some handbooks contain checklists
that may be useful in developing a standard checklist. They should be available to the pilot
during emergency procedures training or an actual emergency, particularly when there is only
one pilot aboard the aircraft.

8) The training syllabus should clearly state the full extent of how that approved
training course will use an ATD, FTD, and/or FFS. The objectives for the use of simulation
training should be well-defined.

9) Section 141.41(a) prescribes the FFS and FTD requirements when used to obtain
flight training credit allowances in an approved pilot training course curriculum.
Section 141.41(b) provides the criteria for ATDs used to obtain flight training credit in an
approved pilot training course curriculum.

a) Part 141 provides maximum simulation training credits for the minimum
experience requirements for a certificate or rating. The provisions in part 141 allow a certain
percentage of training credit for total instruction requirements in FFS, FTD, or ATD.

b) Discretion must be used when approving a training syllabus that substitutes

instruction in an FTD or FFS for the flight time required in a complex airplane. Any use of an
FFS or FTD in lieu of flight time in a complex airplane must be justified with clearly stated
objectives in the training syllabus, that are applicable to the skills required to safely operate a
complex airplane. Approval of the TCO must be based on the ability of the FFS or FTD to
provide effective training for a complex airplane.

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c) Guidance from the National Simulator Program (NSP) Branch will be

necessary to qualify a school’s FFS or FTD. An ATD requires an LOA issued by the General
Aviation and Commercial Division.

d) In addition to the permitted use of FFSs, FTDs, and ATDs that are covered in
the appendices of part 141, § 61.4 also facilitates the approval and use of these trainers.

e) A pilot school may submit a course curriculum that exceeds the permitted
time credits for ATDs, FTDs, or FFSs. In general, a training provider should not be discouraged
from providing additional training in these devices. However, when a TCO contains time that
exceeds the maximum credit allowed for an ATD, FTD, and/or FFS, only the time permitted by
the appropriate appendix to part 141 or by the device’s LOA/approval/qualification, as
appropriate, can be credited to meet the minimum aeronautical experience requirements for that
certificate or rating. The FAA LOA may not exceed a regulatory limitation. For example, if the
aeronautical experience requirements permit 5 hours in a training device to be credited, the
device’s LOA/approval/qualification cannot be used to authorize crediting of more than 5 hours
toward the minimum aeronautical experience requirements.

D. Chief Instructor and Assistant Chief Instructor Tests. For designation as chief
instructor or an assistant chief instructor, a person must hold the appropriate certificates and
ratings, including medical certification, and must meet the PIC requirements of § 61.57. During
the demonstration phase, the chief instructor (and assistant chief, if one is being designated) must
pass both a knowledge test and a proficiency test, as applicable. The knowledge test covers
teaching methods, applicable provisions to the AIM, applicable provisions of parts 61, 91,
and 141, and the objectives and approved course completion standards appropriate to the course.
The proficiency test covers instructional skills and their ability to train students on the flight
procedures and maneuvers appropriate to the applicable course. Both the chief and assistant chief
instructor tests are administered by an FAA inspector. The school should keep a record of these
tests. Volume 5, Chapter 12, Section 1 provides detailed information on conducting these
proficiency tests.

E. Check Instructor Tests. For designation as a check instructor for a part 141 course, a
person must hold the appropriate certificates and ratings, including medical certification, and
must meet the PIC requirements of § 61.57. During the demonstration phase, a check instructor
must pass both a knowledge and proficiency test on those items found in § 141.37 given by the
chief instructor or assistant chief instructor. The person who meets the eligibility requirements
must be designated in writing by the chief instructor to conduct student stage checks,
end-of-course tests, and instructor proficiency checks. The appropriate FSDO must approve the
check instructor. This request must be submitted through the SAS External Portal as a change
request. Documentation may be uploaded in the SAS External Portal. If the applicant does not
enter the request in SAS, the PI will have to document the change request in SAS (see
Volume 10). The PI approves certificate holders’ requests using SAS.

F. Flight Instructor Responsibilities. Part 141 requires all flight instructors employed
by a school to be qualified to teach each course of training they are assigned. Certain knowledge
and proficiency tests, to be accomplished before being assigned to an approved course of

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training, are also prescribed. If the chief instructor or assistant chief instructor also flight
instructs in the course they are assigned to, they must also comply with this section.

1) The instructor must satisfactorily accomplish a proficiency check in each M/M of

aircraft used in that training course in which the person provides training (e.g., Cessna 150 and
Cessna 172) before giving any flight instruction in the particular aircraft.

a) This proficiency check is given to the instructor by the designated chief

instructor, assistant chief instructor, or check instructor.

b) The instructor must accomplish a recurrent proficiency check in one of the

aircraft the instructor trains students every 12 months thereafter for each course of training.

c) The pilot school must maintain a record of these proficiency checks to show
compliance with § 141.79(d).

2) The chief instructor, assistant chief instructor, or check instructor must brief all
instructors teaching that course on the objectives and standards of the course.

a) The pilot school must maintain a record verifying this briefing to show
compliance with §§ 141.79(d) and 141.81(c).

b) At any time, an inspector may ask an instructor to explain the objectives and
standards of an approved course.

3) The instructor must maintain records of instructor briefings and instructor

practical tests in either a logbook or in the permanent school records at the home base of
operations.

4) Student pilots cannot be authorized to start a solo practice flight from an airport
until an authorized flight instructor, who is present at the airport, has approved the flight. Solo
cross-country flights, when properly approved by the school’s certificated instructor from the
originating airport, are considered to have approval for the entire flight (§ 141.79(b)).

a) If unexpected weather or mechanical problems delay a student en route or a

student intends to remain overnight, the school should either:

• Arrange for another instructor based at the point of delay to dispatch the
flight, or
• Have a school instructor dispatch the flight by telephone.

b) Cross-country flights should be made to specific airports that the school

determines are suitable. The operator may wish to provide students with a list of these suitable
airports or include the list in the appropriate TCO.

5) All certificated instructors must meet the FAA Aviation English Language
Standard (AELS) as described in AC 60-28, FAA English Language Standard for an FAA
Certificate Issued Under 14 CFR Parts 61, 63, 65, and 107.
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6) Instructors who work for a part 141 pilot school must be able to assess if an
applicant for a certificate or rating, or holder of an FAA certificate, does or does not meet the
FAA regulatory English language eligibility requirements for his or her respective part 61 FAA
certificate. If the enrollee/certificate holder’s ability to meet the FAA AELS is in question, the
instructor must refer that individual to the appropriate FSDO so that an ASI can make an AELS
determination in accordance with Volume 5, Chapter 14, Section 1. This responsibility also
applies to a chief instructor, any assistant chief instructor, and any Airman Certification
Representative (ACR) associated with the pilot school.

G. Other School Personnel.

1) Section 141.33 states that an applicant for a pilot school or provisional pilot
school certificate must show that there are adequate personnel and authorized instructors,
including a chief instructor, for each course of training. All instructors (flight or ground) must be
qualified and competent to perform their assigned duties.

2) In addition, each dispatcher, aircraft handler, line crewman, and serviceman to be

used must have been instructed in the procedures and responsibilities of employment. The
inspector should recommend that the pilot school keep a record of this instruction in the
employee’s personnel file.

H. Terminating the Demonstration and Inspection Phase. When all demonstrations

and inspections are complete and any demonstrations or inspections are considered
unsatisfactory, the applicant should be expeditiously advised in writing of corrective actions
needed. The appropriate demonstration or inspection will be rescheduled accordingly.

2-1073 CERTIFICATION PHASE.

A. Completion of Reports. The certification team will confirm that all required items
have been reviewed, inspected, and approved. Once all items have been addressed as satisfactory
or not applicable, the certification team can complete the certification process. The next step is
for the certification team to complete all applicable documents, prepare the certification file, and
send the entire file to FSDO management for review and signature.

B. Ratings. FAA Form 8000-4 must list the various pilot school ratings for which a pilot
school/provisional pilot school qualifies under §§ 141.11 and 141.57, if applicable. These ratings
do not specifically address each approved course of training that a school may be authorized to
give. Under the broad listing of pilot school ratings found in §§ 141.11 and 141.57, if applicable,
a school could be authorized to conduct nearly a hundred different courses.

C. Approved Courses. The certification team issues a list of approved courses of

training, identifying each authorized course by its title, along with the FAA Form 8000-4. All
courses must conform to the ratings listed in § 141.11 and/or § 141.57. Automated LOAs
through WebOPSS will be issued instead of individual letters written by the appropriate FSDO to
the applicant. See Volume 3, Chapter 18, Section 14.

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NOTE: If a list of approved courses is amended, the original is returned to the

appropriate FSDO. The list remains in effect until it is amended or the school
certificate is expired, surrendered, suspended, or revoked.

2-1074 SCHOOL ENROLLMENT, GRADUATION, AND TRAINING RECORDS.

A. Enrollment. When a certificate holder enrolls or reenrolls a student in an approved

course of training, § 141.93 requires the student be furnished the following information and
materials:

1) A certificate of enrollment containing the name of the course the student is

enrolled in and the date of enrollment.

2) A copy of the training syllabus required under § 141.55(c)(7).

3) A copy of the safety procedures and practices developed by the school, such as
procedures for the use of training aids, off-limit areas, handling of aircraft, parking instructions,
and other safety instructions that the school deems necessary. These safety procedures must
include the following:

a) The weather minimums required for dispatching dual and solo flights. For
example, minimum ceiling visibility and wind velocities for local flights and specific weather
minimums for cross-country flights.

b) The procedures for starting and taxiing aircraft on the ramp.

c) The precautions and procedures for aircraft fire.

d) The redispatch procedures after unplanned landings on and off airports. This
should include emergency security of the aircraft and a list of telephone numbers of persons to
contact.

e) The procedures for listing aircraft discrepancies and how corrective action is
taken, including the importance of not using an aircraft with a listed discrepancy until a properly
qualified person determines its airworthiness.

f) The securing of aircraft when not in use.

g) The fuel reserves necessary for local and cross-country flights.

h) The avoidance of other aircraft in flight and on the ground.

i) The minimum altitude limitations certain minimum altitudes may be specified

for teaching and practicing stalls or other maneuvers.

j) The instructions concerning simulated forced landings. Instructions should be

clear on simulated emergency landings with respect to engine cooling down during prolonged
glides, proper engine leaning, proper procedures for setting zero thrust, engine response with

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rapid throttle application, and a specific minimum altitude for terminating simulated emergency
landings and other instructions deemed necessary by the school.

k) The assigned practice areas, including descriptions and diagrams of the areas
and special instructions with respect to how to operate in them, how to get to them, and
minimum altitudes en route.

l) Any instructions or guidance that the school believes necessary to provide the
highest standards of safety and operational control expected of an FAA-approved school.

B. Student Graduation Certificate. A certificate holder must issue a graduation

certificate to each student who completes its approved course of training. The certificate holder
may not issue a graduation certificate to a student, or recommend a student for a pilot certificate
or rating, unless the student has completed all of the training requirements of that course.
Section 61.71 states that a person who graduates from an approved training program under
part 141 is considered to have met the applicable aeronautical experience, aeronautical
knowledge, and areas of operation requirements of part 61, if that person presents the graduation
certificate and passes the required practical test as appropriate within the 60-day period after the
date of graduation. Should an applicant not accomplish pilot certification within 60 days of the
date of graduation certificate, additional training and an additional final progress check may be
accomplished, facilitating the issuance of a new graduation certificate, unless expressly
prohibited by the TCO.

C. Combined Course. Some TCOs may encompass “combined courses” such as a

combined Private Certificate and Instrument Rating under part 141 appendix M, or a combined
instrument rating and commercial certificate using special curriculum course approval under
§ 141.57. Part 141 appendix D, paragraph 2(b)(2) for the commercial pilot certification course
also describes an allowance to be concurrently enrolled in an instrument rating course. In these
cases, a single graduation certificate is issued at the completion of the entire course. However, as
with conventional single-course TCOs, should an applicant not accomplish pilot certification
within 60 days of the date of graduation certificate, additional training and an additional final
progress check may be accomplished, facilitating the issuance of an updated graduation
certificate, unless expressly prohibited by the TCO.

D. Training Records. Each pilot school and provisional pilot school must keep accurate
and current records of each student’s participation and accomplishments in an approved course.

1) A student’s personal logbook is not considered an acceptable record under

§ 141.101.

2) For each student, the training record should include:

• The date of the student’s enrollment.

• A chronology of the student’s attendance, subjects, and flights.
• The names and grades of any tests taken.
• The date of graduation, termination of training, or transfer.

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3) The record should also show the credit allowed for a student transferring from
another school, if applicable.

4) Whenever a student graduates, terminates training, or transfers, the chief

instructor must certify the record.

5) Pilot schools must retain each student’s record for at least 1 year from the date the
student graduates, terminates a course, or transfers to another school.

6) On a student’s request, a pilot school must make a copy of a student’s record

available to the student. The pilot school must also permit the FAA to view any or all student
records upon request.

2-1075 RENEWAL, AMENDMENT, AND CANCELLATION.

A. Renewal. A pilot school or provisional pilot school certificate, and any associated
ratings or examining authority on that certificate, expires at the end of the 24th month after the
month it was issued. A provisional pilot school may apply for a pilot school certificate once they
meet all of the requirements found in § 141.5, including § 141.5(d) and (e), and need not wait
24 months to apply for a pilot school certificate. A pilot school may not apply for examining
authority until they have held the rating for at least 24 consecutive months preceding the month
of application for examining authority. Note that the time holding the rating as provisional pilot
school counts towards the 24 consecutive months. The pilot school may not apply for reduced
ground and or flight minimums until they have held their pilot school certificate for a period of at
least 24 consecutive calendar-months. The pilot school may not apply for examining authority if
the course is one with reduced ground and or flight minimums.

NOTE: Under § 141.83, the pilot school must maintain the quality of training.
Failure to do so may result in suspension or revocation of their pilot school
certificate.

1) A pilot school may apply for renewal of its school certificate and ratings within
30 days preceding the month the pilot school’s certificate expires. All applications and requests
should be made through the SAS External Portal. This form can be uploaded by the applicant.

a) Application is made by submitting two copies of FAA Form 8420-8,

completed as shown in Figure 2-66, Sample FAA Form 8420-8, Application for Pilot School
Certification, Filled Out for Renewal.

b) A school may apply for the renewal of any or all of the courses (TCOs) it
holds, and/or it may apply for the addition of new courses.

c) Examining authority should be renewed at the same time the school certificate
is renewed.

d) An institution of higher education that holds a valid LOA issued by the

General Aviation and Commercial Division, that gives it the authority to certify its graduates

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meet the reduced aeronautical experience requirements for an ATP Certificate, will have the
LOA revalidated for content and currency every 2 years.

2) A school must meet the same requirements for renewal as for original
certification. However, there is no requirement for a pilot school to meet the quantity of training
under § 141.5(e) when it renews its Air Agency Certificate. Therefore, upon the receipt of an
application for the renewal of a school certificate, the appropriate FSDO should conduct the
same evaluation of qualifications and inspection of facilities as required for original certification.
However, if the FSDO is very familiar with the school’s operation or has recently inspected it,
there may be no need for an extensive reinspection or for reexamination of instructors. The
FSDO always has the option of a full inspection.

3) When all requirements are met, a new FAA Form 8000-4 is issued and is valid for
additional 24 calendar-months. The original certificate number is reissued and the provisional
pilot school’s Vitals record is appropriately updated.

a) Renewal of pilot school certificates and ratings is discussed in § 141.27. If a

pilot school does not meet the recent quality of training requirements of § 141.5(d), but
otherwise meets the requirements of § 141.7 at the time of renewal, the FSDO may issue a
provisional pilot school certificate and the Vitals would be updated to reflect the change.
However, a school with examining authority and/or reduced time courses loses examining
authority and/or reduced time courses when downgraded to a provisional school.

b) Section 141.5(d) states that, in order to issue a pilot school certificate, the
school must have established a pass rate of 80 percent or higher for all: “(1) Knowledge tests
leading to a certificate or rating; (2) Practical tests leading to a certificate or rating;
(3) End-of-course tests for an approved training course specified in appendix K of this part; and
(4) End-of-course tests for special curricula courses approved under § 141.57.” A pilot school
only needs to maintain a passing rate of 80 percent, and comply with §§ 141.27 and 141.83 when
renewing a pilot school certificate.

NOTE: A pilot school applying for renewal of their current Air Agency
Certificate need not meet the requirements of § 141.5(e) that describe graduating
at least 10 different people from the school’s approved training courses. This
requirement is only applicable to a “provisional” pilot school qualifying for an
initial (or first-time) pilot school certificate. Existing pilot school certificate
renewals only need to meet the renewal criteria requirements described in
§§ 141.27(a)(2) and 141.83.

c) If, after another renewal period (24 calendar-months), the school that is now a
provisional pilot school does not meet the quality and quantity requirements of § 141.5(d)
and/or (e), the school must wait a period of 180 days before reapplying for certification as a
provisional school. All training conducted during that 180 days must meet the requirements of
part 61, including passing knowledge and practical tests for certificates or ratings.

NOTE: In the event a provisional pilot school associated with an institution of

higher education does not meet the quality requirements specified in § 141.5(d) at

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the time of certification expiration, the POI will notify the General Aviation and
Commercial Division to address, on a case-by-case basis, students enrolled in the
curriculum that may qualify them for an ATP Certificate with reduced
aeronautical experience. Refer to § 61.160.

d) If renewal of a rating is denied or a course of training does not meet the

appropriate requirements, the applicant is notified in writing of the reasons for the denial of the
rating.

e) In addition, the school must be advised, in writing, that continued training in

any course of training in question cannot be used to meet part 141 requirements until appropriate
changes are made and the courses again meet the requirements of part 141 (see Figure 2-67,
Sample Notice of Course Cancellation).

4) A new list of approved courses should be issued with the same expiration date as
the Air Agency Certificate (FAA Form 8000-4).

5) Any change in the overall status of the certificate for a provisional pilot school or
pilot school (e.g., the need to reissue a provisional pilot school certificate) associated with an
institution of higher education that has the authority to certify its graduates are eligible for a
reduced aeronautical experience ATP Certificate, must be conveyed to the General Aviation and
Commercial Division to determine if the school’s status change affects the authority of the
institution of higher education.

B. Amendment. Application for amendment of an FAA Form 8000-4 is made to the

appropriate FSDO. The FAA can also initiate the amendment under Title 49 of the United States
Code (49 U.S.C.) and 14 CFR part 13.

1) Application for the approval of a course of training that results in the addition of a
rating to an FAA Form 8000-4 is made by submitting two copies of FAA Form 8420-8 with the
amendment checked (as shown in Figure 2-68, Sample FAA Form 8420-8, Application for Pilot
School Certification, Filled Out for Amendment), through the SAS External Portal with the
amendment request, two copies of the course of training, and a cover letter requesting approval
of the course. The same process is used for the deletion of ratings.

a) After review of the course, an inspection of the school’s facilities and

personnel should be made, as necessary, to ensure that training can be conducted in accordance
with the proposed course, before it is approved.

b) If the school inspection is satisfactory, a new FAA Form 8000-4 bearing the
new ratings will be issued, along with an amended list of approved courses. The amended
certificate should bear the original number, the original expiration date, and the reissue date.

2) An application for the deletion of a rating from an FAA Form 8000-4 may be
accepted in the form of a letter from the certificate holder.

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a) Such a letter must be signed by a person authorized to sign for the school,
such as the person who signed the original application or a person in a similar position in the
school.

b) No inspection is required for deletion of a rating.

c) The FSDO issues a new certificate bearing the original number, the original
expiration date, and a reissue date. The deleted rating is omitted from the certificate and a new
list of approved courses is issued. The old certificate should be retained in the FSDO school file
for 2 years.

3) A change in the ownership of a pilot school does not terminate that certificate if
the new owner applies for an appropriate amendment to the certificate by submitting, through the
SAS External Portal, two copies of FAA Form 8420-8 within 30 days after the date that the
change in ownership occurs. The new ownership may not involve a change in the facilities,
instructor personnel, or training course. There is no prohibition for a non-U.S. citizen or
company to own a part 141 provisional pilot school or pilot school.

4) A change of ownership involving a change in the school facilities, instructor

personnel, or training courses terminates the school certificate. The school may be issued another
certificate when it demonstrates that it meets all the requirements for original certification.

5) When a certificated school changes its name only, and the name change involves
no change in ownership, facilities, instructor personnel, or training courses, a new certificate is
issued in the new name, bearing the same certificate number, ratings, and original expiration
date. An inspection is not required under such circumstances.

6) An application for an amendment to a previously approved special curriculum or

TCO is made by submitting two copies of the curriculum or one electronic copy of the outline
pages to be amended to the appropriate FSDO.

a) Each proposed amendment should be accompanied by a cover letter

explaining the basic changes and the intent, and requesting FAA approval.

b) Approval or disapproval is accomplished in the same manner as the original

approval or disapproval.

c) If a certificate amendment requires an inspection of the aircraft to be used, all

specialists should sign FAA Form 8420-8 under the “Recommendations of Inspector(s)” block.

7) Any changes to the pilot school that would cause the certificate holder to no
longer be able to offer training for the instrument-airplane rating or the Commercial Pilot
Certificate in the airplane category, if the school holds institutional authority and a training
agreement under § 141.26, must be conveyed to the General Aviation and Commercial Division
for any additional action.

C. Cancellation. An FAA Form 8000-4 can be canceled by the school or by the FSDO
as the result of actions taken under 49 U.S.C. and part 13.
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6/9/20 8900.1 CHG 628

1) The appropriate FSDO may suspend or revoke FAA Form 8000-4 on any grounds
that would be a cause for denying an application for the original certificate. In such a case, the
certificate must be surrendered to the FAA in a manner prescribed by the Regional Counsel.

2) The holder of an FAA Form 8000-4 may request cancellation of the certificate or
any rating at any time. The request should be submitted in writing to the appropriate FSDO,
accompanied by the FAA Form 8000-4 to be canceled. The request must be signed by the person
or persons authorized to sign for the certificate holder.

a) If there is no violation action pending or contemplated against the school, the

FSDO may accept the certificate for cancellation.

b) If enforcement action is pending or contemplated, the applicant should be

advised that acceptance for cancellation must await the decision of the Regional Counsel and the
school will be notified of the action taken. The school’s request should then be forwarded to the
Regional Counsel’s office with a summary of the circumstances under which it was submitted.
Cancellation should be effective only after clearance is received from that office.

3) If a request for the surrender of a rating or ratings on an FAA Form 8000-4 is

accepted, a new certificate should be issued bearing the ratings that remain valid and the original
expiration date.

4) A cancellation, suspension, or revocation of FAA Form 8000-4 issued to a pilot

school associated with an institution of higher education that has the authority to certify its
graduates are eligible for a reduced aeronautical experience ATP Certificate must be conveyed to
the General Aviation and Commercial Division.

2-1076 PREREQUISITES AND COORDINATION REQUIREMENTS.

A. Prerequisites. Requires knowledge of the regulatory requirements of part 141 and

FAA policies, and qualification as an ASI (Operations).

B. Coordination. Requires coordination with the airworthiness unit, the Aviation Data
Systems Branch, the Airman Testing Branch, and possibly the NSP Branch.

2-1077 REFERENCES, FORMS, AND JOB AIDS.

A. References (current editions):

• Title 14 CFR Parts 1, 11, 60, 61, 91, 97, and 141.
• AC 61-136, FAA Approval of Aviation Training Devices and Their Use for
Training and Experience.
• AC 61-138, Airline Transport Pilot Certification Training Program.
• AC 61-139, Institution of Higher Education’s Application for Authority to Certify
its Graduates for an Airline Transport Pilot Certificate with Reduced Aeronautical
Experience.
• AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic
Manuals.
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• AC 141-1, Part 141 Pilot Schools, Application, Certification, and Compliance.

• Volume 2, Chapter 9, Section 2, Introduction to Part 141 Airworthiness Related
Tasks.
• Volume 2, Chapter 9, Section 3, Evaluate Airworthiness Issues of a Part 141 Pilot
School.

B. Forms:

• FAA Form 8000-4, Air Agency Certificate (Figure 2-62).

• FAA Form 8420-8, Application for Pilot School Certification (see Figures 2-64,
2-66, 2-68, and 2-69).

C. Job Aids:

• Sample letters and figures.

• Job Task Analyses (JTA) 3.4.7, 3.4.9, 3.4.11, 3.4.13, 3.4.17, 3.4.18, 3.4.20,
3.4.21, 3.4.22, and 3.4.23.

2-1078 PREAPPLICATION PHASE PROCEDURES.

A. Initial Inquiry. Upon initial inquiry from an applicant, determine the following:

• The identity of applicant and address of the principal base of operations,

• Any intended satellite base(s),
• The type of ownership (e.g., private, corporate, etc.),
• The proposed curriculum,
• The types of aircraft,
• The intended chief instructor and that instructor’s experience level,
• The possible use of ATDs,
• The possible use of commercially produced syllabi,
• If the operator intends to request examining authority for renewing or amending
only, and
• If the operator intends to use contract training.

B. Applicant Resources. Ensure the applicant has current copies of parts 61, 91,
and 141, and AC 141-1. If there is any question, explain:

• The general applicability and definition of terms.

• The certification requirements.
• The operating rules of part 141.
• The required records and reports.

C. After Initial Inquiry. Once the applicant has made the initial certification inquiry,
they can make application through the SAS External portal. All part 141 certifications will be
documented in SAS.

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D. LOI. Request an LOI from the applicant. (See subparagraph 2-1069Q for content of
an LOI and Figure 2-70, Sample Letter of Intent.)

E. FSDO Review of LOI. Within 30 days of the FAA’s receipt of an LOI, review it to
determine that it provides sufficient information for the certification process to continue.

F. Application. Based on the review of the LOI, if the applicant appears to meet the
basic eligibility requirements, provide the applicant with at least three copies of FAA
Form 8420-8. The applicant may submit the application electronically (one electronic submission
is equal to three paper copies), which is kept in the office file for this school.

1) Discuss how to complete these forms. Advise the applicant to review AC 141-1
and the regulations before completing and returning the application to the appropriate FSDO.

2) Advise the applicant to submit the original and copies with original signatures.

3) Explain the certification process to the applicant, including the requirements for:

• The Preapplication Phase,

• The Formal Application Phase,
• The Document Compliance Phase,
• The Demonstration and Inspection Phase, and
• The Certification Phase.

G. Preapplication Meeting.

1) The applicant may contact the appropriate FSDO and make an appointment to
meet with a manager. The appropriate FSDO manager and assigned inspector will outline the
part 141 certification requirements, aircraft requirements, and FAA policy and procedures.

2) Determine if a preapplication meeting is necessary, based on the following

considerations about the applicant:

a) Any previous part 141 operating experience;

b) The size and scope of operation;

c) The area of operation; and

d) The applicant’s apparent ability to comply with requirements.

3) If a preapplication meeting is not necessary, schedule a date and time for a formal
application meeting.

4) If a preapplication meeting is necessary, schedule a date and time. At the meeting,

discuss the following:

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• The area of operation (primary airport and any satellite bases);

• The operation as an individual, corporation, or partnership;
• Any previous experience with part 141 operations;
• The categories and classes of aircraft to be used in training courses;
• The number and types of training courses to be offered;
• The possible need for any waivers or exemptions;
• The qualifications and experience of instructors;
• The applicability of parts 61, 91, and 141;
• AC 141-1;
• Any previous or pending enforcement actions against the applicant or
proposed personnel;
• The type of training aircraft, quantity of each type of aircraft, and if available,
aircraft registration; and
• Who will perform maintenance on the proposed training aircraft, and if they
will be contracting their maintenance out to another source.

H. Establish a FSDO Working File. This file will form the basis for the eventual
operator file if certification is successful. Place any correspondence, documents, etc., in this file.
Using office procedures, conduct an Enforcement Information System (EIS)/Accident Incident
Data System (AIDS) check on the chief instructor applicant or assistant chief instructor
applicant.

1) If the applicant has no previous enforcement or accident/incident history, place

the EIS/AIDS report in the FSDO file.

2) If the EIS/AIDS report shows a prior enforcement or accident/incident, evaluate

the results to determine if the problems were related to flight training. If the problems do relate to
flight training, ensure the applicant is able to meet the requirements for designation as a chief
instructor or assistant chief instructor.

I. Terminating the Preapplication Phase. This ends the preapplication phase. The
formal application phase begins with the receipt of the completed application form.

2-1079 FORMAL APPLICATION PHASE PROCEDURES. Within 30 days of receiving an

application, the certification team should review it and determine whether it is of sufficient
quality to proceed with certification.

A. Application Review. Review the application only to determine if it is of sufficient

quality to continue with certification (i.e., the applicant supplied enough information on the
application and/or LOI). Review it in depth during the document compliance phase. An example
of a properly completed application for an initial certification is shown in Figure 2-69, Sample
FAA Form 8420-8, Application for Pilot School Certification, Filled Out for Initial Certification.

B. Application Incomplete or Inaccurate. If the application is not complete or not

accurate, notify the applicant in writing of changes needed before certification can continue (see
Figure 2-72, Sample Letter Indicating Application is Unsatisfactory). Return the application for
any necessary corrections.
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C. Need for Formal Application Meeting. Determine if the optional formal application
meeting is necessary.

1) If a formal application meeting is not necessary, schedule the certification

inspections. Review the procedures required during the demonstration and inspection phase with
the applicant.

2) If a formal application meeting is necessary, schedule a date and time.

D. Formal Application Meeting.

1) Discuss the following items that would have been covered in a preapplication
meeting, if none was conducted:

• The application.
• The SOE, if applicable.
• The TCOs and syllabi.
• The personnel, aircraft, and facility requirements.
• The FFS, FTD, and ATD requirements.
• An inspection of facilities related to any contractual training agreements.
• Section 141.23, Advertising Limitations.

2) Discuss any discrepancies in the application and their corrective actions.

3) Discuss the requirements that must be met during the demonstration and
inspection phase.

E. Terminating the Formal Application Phase. This completes the formal application
phase. The next phase is the document compliance phase.

2-1080 DOCUMENT COMPLIANCE PHASE PROCEDURES. After accepting the

application, the team ensures each document is complete and correct through an indepth review.

A. Document Review. The certification team evaluates the following items.

1) Check the application. (Note that the blocks on the application are not numbered.)
Check that the application contains the following information (beginning with upper left corner):

a) The legal name and any appropriate DBA of the proposed school, telephone
number, address of the principal business office, location of the main operations base, and the
location of any satellite bases.

b) Whether the application is for original issuance, approval of satellite base, or

change of name or ownership. Appropriate boxes should be marked for issuance, renewal, or
amendment of the certificate.

c) The training courses for which approval is sought. Check the space provided
on the reverse of the form for additional courses.
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d) The application is signed and dated in the last section by the applicant or
authorized officer (original signatures on each application form):

• A person acting as an individual should personally sign the application.

• All partners should sign an application from a partnership.
• An officer who is authorized by the corporation bylaws and certified by
the corporate secretary should sign an application from a corporation.
• The president or other such officer or director should sign an application
from a company, club, or association, as authorized by the organization’s
secretary.

e) The next section is for FAA use only. Confirm that the applicant did not mark
or complete this section.

2) Check the qualifications of all proposed chief instructors, assistant chief

instructors, and check instructors for each course that approval is sought for and the
qualifications of all other instructors. Refer to §§ 141.35 through 141.37.

a) If not already accomplished, following office procedures, contact EIS to

determine the chief instructor’s, assistant chief instructor’s, and other instructors’ enforcement,
accident, and incident histories.

b) Verify employment history pertaining to parts 61 and 141, and other related
aviation experience.

3) Evaluate the TCOs. Volume 3, Chapter 53, Section 2 provides detailed

information on TCOs and the associated syllabi.

4) Evaluate any commercially developed or FAA/Industry Training Standards

(FITS)-developed training syllabi. Ensure that:

• The school fully understands the objectives and standards of the commercially
developed or FITS-developed training syllabi.
• The school can actually give the training in the manner described in the
syllabus.
• The syllabus contains all required pilot operations for the related course.
• The syllabus and related training aids are on a current revision schedule.

5) Evaluate the special curriculum. Special curricula developed under § 141.57 must
be evaluated with flexibility in mind. Special curricula may be used in experimental curricula
under research and development. When approving special curricula, the inspector must ensure
that the curricula cover the aeronautical knowledge areas and flight proficiency areas of
operations listed in the appropriate appendices of part 141. The inspector must determine that
objectives, content, and completion standards are not less than those contained in the appropriate
practical test standards (PTS) or Airman Certification Standards (ACS).

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6) Check the aircraft checklists, minimum equipment lists (MEL), safety practices
and procedures, etc., when applicable. (Refer to §§ 141.75 and 141.95.)

7) Check the graduation certificates required by § 141.95 to ensure that they contain
at least the information indicated in § 141.95(b).

8) Ensure that the applicant can track enrollment information (i.e., that the student
was enrolled in the school’s approved course of training before receiving the instruction and
training that is certified).

9) Review the maintenance program (airworthiness).

B. Unsatisfactory Items. If there are any unsatisfactory items, advise the applicant in
writing that they must be corrected before certification can continue.

1) Place a reasonable time limit on when the corrections must be completed. The
certification section in SAS has a timeline, which the applicant must propose and the Certificate
Management Team (CMT) must agree to. All timelines, including resubmissions, are tracked
in SAS.

2) If the applicant does not respond within 90 days of the time limit, send the entire
application package back to the applicant with a cover letter stating that the certification process
is terminated.

3) Make the appropriate work entry in SAS automation.

C. Terminating the Document Compliance Phase. When all documents are

satisfactory, conclude the document compliance phase and arrange scheduling for the
demonstration and inspection phase.

2-1081 DEMONSTRATION AND INSPECTION PROCEDURES. During the

demonstration and inspection phase the team must ensure these steps are accomplished:

A. Conduct Chief Instructor Proficiency Test. Administer a knowledge and

proficiency test to the chief instructor(s) and any assistant chief instructors. (See Volume 5,
Chapter 12, Section 1.) Verify the chief instructor and any assistant chief instructor(s) meet the
FAA AELS as outlined in AC 60-28.

B. Recordkeeping Requirements. Inspect the applicant’s recordkeeping system for

compliance with §§ 141.67, 141.77, 141.85, 141.93, and 141.101.

C. Inspect Aircraft. The Airworthiness inspector conducts the aircraft inspection. See
Volume 2, Chapter 9, Sections 2 and 3. Operations inspectors may examine each aircraft for the
requirements of § 141.75.

D. Conduct a Base Inspection. See Volume 6, Chapter 7, Section 1.

E. Inspect Satellite Bases. See Volume 6, Chapter 7, Section 1 and § 141.91.

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F. Inspect FFSs, FTDs, ATDs, Training Aids, and Other Equipment. Refer to
§§ 141.41 and 141.45. If an FFS or FTD must be approved or qualified, contact the NSP Branch.

G. Terminating the Demonstration and Inspection Phase. When all demonstrations

and inspections are complete, the demonstration and inspection phase is concluded.

1) If any demonstrations are unsatisfactory, advise the applicant immediately of

corrective actions. If necessary, confirm the discrepancies in writing (see Figure 2-73, Sample
Letter Indicating Discrepancies Found During Inspection). Reschedule the inspections
accordingly.

2) When all demonstrations and inspections are satisfactory, proceed with the
certification phase.

2-1082 CERTIFICATION PHASE PROCEDURES. When all certification requirements

have been met, obtain an Air Agency Certificate number (see Volume 2, Chapter 1, Section 3).

A. Complete Inspection Reports and Job Aids.

1) On the application, in the section marked, “For FAA Use Only,” indicate
approval; provisional pilot school or pilot school; effective date of the certificate; and expiration
date of the certificate. Indicate if the task was a renewal or amendment to a certificate, if
applicable. Make any necessary comments and sign the application. The POI assigned to that
pilot school will then sign and date the application.

2) Ensure all items on the certification/inspection job aid are resolved. Initial the job
aid and place in the FSDO file.

B. Prepare and Issue the Air Agency Certificate. Use FAA Form 8000-4
(Figure 2-62).

1) Enter the certificate holder’s full legal name directly below the words “This
certificate is issued to.” Show other names (such as any DBAs) on the certificate. If necessary,
list DBAs on a separate, attached letter (see Figure 2-74, Sample Part 141 Letter Listing DBAs).

2) Enter the address of the certificate holder’s base of operations directly below the
certificate holder’s name. Use a post office box address only if the address reflects the physical
location of the base of operations.

3) Enter the certificate number, as obtained in Volume 2, Chapter 1, Section 3, on

the certificate.

4) Enter the date all requirements for certification are met.

5) Enter the four-character, alphanumeric designator and city and state of the
appropriate FSDO under the signature line of the form (e.g., EA21, Richmond, VA).

6) Submit the certificate to the FSDO manager for signature.

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a) Use the full title of the person signing the certificate.

b) Enter the FSDO acronym and number in the office space (e.g., WP FSDO 04).

C. Prepare List of Approved Courses. Prepare a list of approved courses, issue the
appropriate LOAs, and issue these with the Air Agency Certificate. See Volume 3, Chapter 18,
Section 14 on issuing part 141 LOAs.

D. Certificate Denial. If any certification requirement is not met, issue a letter of denial
(see Figure 2-75, Sample Letter Denying Certificate). Specify the reasons for denial. On the
application, in the section “For FAA Use Only” indicate disapproval. Make any necessary
comments and sign. Have the FSDO manager sign and date the application.

E. Certification Report. Assemble a certification report containing the following:

• A copy of the LOI, if applicable;

• A certification job aid (see Figure 2-76, Part 141 Certification Job Aid);
• The application;
• The SOE (see Figure 2-77, Part 141 Schedule of Events) (this is tracked in SAS);
• A copy of the Air Agency Certificate issued; and
• A summary of any difficulty encountered during certification and its resolution.

F. MEL. Issue an LOA to operate with an MEL, if applicable (see Volume 4, Chapter 4,
Section 2).

G. All Appropriate Information in the SAS Vitals Basic File.

H. FSDO File. The CPM must ensure an official office file is established after
certification is complete. The file must contain at least the following:

• The material from any working file used up to this point, including the TCO and
syllabi;
• The certification report and attachments;
• The EIS/AIDS profile on applicant and personnel, including a negative report, if
applicable;
• The approved MELs, if applicable;
• The surveillance reports; and
• All general correspondence relevant to the school or the FAA.

2-1083 TASK OUTCOMES. Completion of the task results in either:

A. Certificate. A certificate issued that authorizes operations under part 141.

B. Record. A record on file consisting of the following:

• Written notification to the applicant denying the certificate, and

• Indication of the return of all documents to the applicant.

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C. Letter Confirming Termination. A letter to the applicant confirming termination of

the certification process per the applicant’s request (see Figure 2-78, Sample Letter Confirming
Termination of Certification Process at Applicant’s Request).

2-1084 FUTURE ACTIVITIES.

A. Develop Post-Certification Plan. When developing a post-certification plan,

perform additional surveillance or inspections during the first 90 days the organization is in
business. This may require assistance from other FSDOs.

B. Conduct Surveillance. According to the established post-certification program,

conduct surveillance at appropriate intervals.

C. Renewal of Certificate. Part 141 pilot school Air Agency Certificates are valid for
2 years and the pilot school must submit an application for renewal to maintain their pilot school
status.

D. Amendment of Certificate. Amend the Air Agency Certificate at the operator’s

request or the FAA’s determination.

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Figure 2-62. FAA Form 8000-4, Air Agency Certificate

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Figure 2-63. Sample Letter Disapproving Special Curricula or TCOs

FAA Letterhead

[Date]

Carolyn Brannon
Brannon Aviation
Fairfax Airport
P.O. Box 123
Fairfax, VA 23456

Dear Ms. Brannon:

We are unable to approve your [name of course] training course outline (TCO) [or special
curriculum] for the following reasons:

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

All other TCOs [and/or special curricula] have been approved and are reflected in your list of
approved courses. If you wish to continue to seek approval for the [above course or special
curriculum], you may reapply when appropriate corrections have been made.

Sincerely,

[POI’s Signature]

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Figure 2-64. Sample FAA Form 8420-8, Application for Pilot School Certification, Filled
Out for Approval of Satellite Base

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Figure 2-65. Sample Letter Denying Satellite Base

FAA Letterhead

[Date]

[Applicant’s Name and Address]

Dear [Name]:

We are unable to approve your application for a satellite base at [location] for the following
reasons:

[List reasons]

When you feel your organization meets the certification requirements for a satellite base, you
may reapply to this office.

Sincerely,

[POI’s Signature]

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Figure 2-66. Sample FAA Form 8420-8, Application for Pilot School Certification, Filled
Out for Renewal

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Figure 2-67. Sample Notice of Course Cancellation

FAA Letterhead

[Date]

[Applicant’s Name and Address]

Dear [Name]:

After reviewing your application for renewal of your pilot school certificate and conducting the
appropriate inspection, we require that you cease [name of course] training immediately for the
following reasons:

[List reasons]

Failure to cease [name of course] training shall result in enforcement action against your
certificate.

All other courses of training and pilot school ratings inspected at the time of renewal were
acceptable, and you may continue to conduct training under them. When you feel that your
organization meets the certification requirements for [name of course], you may apply for
reinstatement of the course.

Sincerely,

[POI’s Signature]

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Figure 2-68. Sample FAA Form 8420-8, Application for Pilot School Certification, Filled
Out for Amendment

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Figure 2-69. Sample FAA Form 8420-8, Application for Pilot School Certification, Filled
Out for Initial Certification

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Figure 2-70. Sample Letter of Intent

RUTHIE’S FLYING SCHOOL

888 CHANDELLE CIRCLE
BELLVILLE, IL 35454
312-555-1212

March 15, 2018

Federal Aviation Administration

Flight Standards District Office #3
DuPage Country Airport
West Chicago, IL 60185

Gentlemen:

This is to notify the Federal Aviation Administration (FAA) of our intent to become an approved
pilot school under Title 14 of the Code of Federal Regulations (14 CFR) part 141. Our
company’s legal name is Ruthie’s Flying Service, 888 Chandelle Circle, Bellville, IL 35454, and
our email address is [email protected].

We are prepared to begin operations on July 1, 2018 and are ready for your certification
inspection at this time. Enclosed is an electronic submission of FAA Form 8420-8, Application
for Pilot School Certificate. Operations will be confined to the DuPage County Airport. We plan
to operate: two Cessna 152s, one Cessna 172, and a Piper Comanche (PA-24-250) that meets the
complex aircraft requirements for commercial pilot certification.

Courses identified on FAA Form 8420-8 will be supervised by our chief instructor, Mr. Robert
Cartwright, holder of ATP Certificate number 555121128. He meets the requirements of
§ 141.35 and his instructor resume is available for verification when you conduct your
certification inspection.

Also enclosed are three copies of each training course outline (TCO) for your review and
approval. Our requested three-letter certificate designators are EPS, ELS, and SFS, in that order
of preference. We plan on using a file cabinet and paper to log students’ progress. No computers
will be used at this time.

Sincerely,

Ruth Vaght
President

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Figure 2-71. Sample Letter Indicating Certification Process Cannot Continue Because of
Pending Enforcement Action

FAA Letterhead

[Date]

[Name and Address of Applicant]

Dear [Name]:

This letter is to inform you that your application for a pilot school certificate cannot be processed
because of enforcement action [pending/taken] against [cite the specific certificate—Airman,
other air operator certificate, etc.]. Until such time that this enforcement action is fulfilled, you
are ineligible for certification.

Enclosed with this letter is a copy of your application and the training course outlines (TCO) you
submitted for approval.

Should you wish to discuss this matter, please contact this office at [telephone number].

Sincerely,

[FSDO Manager’s Signature]

Figure 2-72. Sample Letter Indicating Application is Unsatisfactory

FAA Letterhead

[Date]

[Name and Address of Applicant]

Dear [Name of Applicant]:

The enclosed FAA Form 8420-8, Application for Pilot School Certificate, is returned because
[cite discrepancies].

Enclosed are three blank application forms that you may use to reapply when the above items are
corrected. In order to continue the certification process, the corrected applications must be
received no later than [date, no longer than 30 days from the date of the letter]. If we do not hear
from you by that date, we will consider the certification process terminated.

If you have any questions concerning this matter, please feel free to contact this office at
[telephone number].

Sincerely,

[CPM’s Signature]
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Figure 2-73. Sample Letter Indicating Discrepancies Found During Inspection

FAA Letterhead

[Date]

[Name and Address of School]

Dear [Name]:

These discrepancies were found during a Title 14 of the Code of Federal Regulations (14 CFR)
part 141 certification inspection conducted as part of your certification as an air agency under
part 141.

[List each discrepancy]

[List methods of correcting the discrepancies, if appropriate]

[Indicate a reasonable length of time for the corrections to be made (not to exceed 90 days from
the date of the letter)]

[Indicate that if no response is received within 90 days, the certification process will be
terminated]

Sincerely,

[CPM’s Signature]

Figure 2-74. Sample Part 141 Letter Listing DBAs

FAA Letterhead

[Date]

[Air Agency’s Name and Address]

Dear [Name]:

This letter, accompanied by Air Agency Certificate No. [number] issued to [legal name of
school] on [date of issuance], authorizes the following additional persons to exercise the
privileges and limitations of the certificate.

[List all DBA names]

Sincerely,

[FSDO Manager’s Signature]

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Figure 2-75. Sample Letter Denying Certificate

FAA Letterhead

[Date]

[Name and Address of Applicant]

Dear [Name of Applicant]:

Your application for a pilot school certificate is denied because of the following reasons:

[List specific items that have not been corrected in the document compliance phase or
demonstration and inspection phase within a reasonable time (i.e., not to exceed 90 days from the
time the applicant was notified of the discrepancy).]

[If applicable, cite any false or fraudulent information that was provided.]

[If applicable, indicate why TCOs were not approved.]

[If applicable, specifically list the lack of qualifications of personnel or deficiencies in facilities
and equipment.]

If you have any questions concerning this matter, please contact this office at [telephone
number].

Sincerely,

[FSDO Manager’s Signature]

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Figure 2-76. Part 141 Certification Job Aid

NAME OF SCHOOL: CERTIFICATION TEAM:

Name: Specialty:
ADDRESS: INSP.
DATE YES NO NA
INITIAL
1. Initial contact handled by
2. LOI
3. Preapplication meeting
4. Applicant provided resources/advised
how to obtain
5. Formal application meeting
6. Application properly completed and
submitted
7. TCOs submitted (§ 141.53)
a. TCO contains description of each
room used for aeronautical knowledge
training (§ 141.55)
b. TCO describes all training aids
c. TCO describes each FFS, FTD,
or ATD
d. TCO lists airports at which training
flights originate
e. TCO describes minimum instructor
qualifications
f. TCO describes trainee’s enrollment
qualifications
g. TCO describes each lesson’s
objectives and training standards
h. TCO describes tests and checks used
to measure each stage of training
8. Verification of flight instructor’s
qualifications (§ 141.33)
9. Chief instructor/assistant for ground
school course has 1 year experience in
approved school (§ 141.35/§ 141.36)
10. Enrollment method meets the
requirements of § 141.93
11. Safety procedures/practices
developed (§ 141.93)
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12. Graduation certificates appropriate

(§ 141.95)
13. Method for student recordkeeping
(§ 141.101)
14. MEL approved
15. School has use of aircraft
appropriate for each course (§ 141.75)
a. U.S.-registered standard category
b. At least two-place with
full-functioning dual controls
c. Maintained in accordance with
parts 43 and 91
d. Inspected by Airworthiness inspector
(1) Optional equipment installation
(2) Airworthiness Directive (AD)
records current
(3) In-house or contract maintenance
observed
(4) Aircraft for IFR courses properly
equipped/maintained
e. Electronic
components/communications
equipment inspected (Avionics)
f. Checklists required by § 141.75
16. Chief instructor/assistance for each
course tested (§ 141.35/§ 141.36)
a. Knowledge test
b. Proficiency test
17. Chief instructor’s method to test
other instructors
18. Pilot briefing areas (§ 141.43)
19. Aeronautical knowledge training
facilities (§ 141.45)
20. Airports (§ 141.38)
a. Continuous use where flights
originate (§ 141.38)
b. One runway/takeoff area for normal
takeoff at full gross weight (§ 141.38)
c. Wind direction indicator (§ 141.38)
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d. Traffic direction indicator (if

required by § 141.38)
e. Permanent runway lights (if required
by § 141.38)
21. FFSs or FTDs (§ 141.41)
a. Cockpit meets requirements of
§ 141.41
b. Simulates rotation around three axes
(§ 141.41)
c. Minimum instruments/equipment
required by § 91.205 (§ 141.41)
d. For visual flight rules (VFR)
instruction, a means of simulating
visual flight conditions (§ 141.41)
e. For IFR instruction, a means of
recording flight path (§ 141.41)
22. Training aids meet requirements of
§ 141.41
23. Certificate number obtained from
the Aviation Data Systems Branch
24. Air Agency Certificate prepared and
issued
25. List of approved courses prepared
26. Issue LOAs
27. Certification report and appropriate
FSDO file prepared
28. Surveillance plan developed
29. Other

REMARKS:

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Figure 2-77. Part 141 Schedule of Events

NAME OF SCHOOL: NAMES OF MANAGEMENT PERSONNEL:

Name Title
ADDRESS: SCHOOL FAA FAA
FAA INSP
DATE DATE DATE
RET’D INIT
READY REC’D APP’D
1. LOI
2. Application (FAA Form 8420-8)
3. TCOs
4. Special curricula (if applicable)
5. Recordkeeping procedures
6. Enrollment method
7. Safety procedures/practices
8. Graduation certificates
9. Instructors’ qualifications
10. Chief instructor/assistant practical test
11. Base inspection (including satellite bases)
12. Appropriate aircraft for each course
13. Aircraft conformity inspections
(Airworthiness)
14. FFS, FTD, or ATD inspection
15. Training aids inspection
16. Pilot briefing areas
17. Aeronautical knowledge training facilities
18. Airports
19. Proposed date to start operations
20. Issue LOA
21. Other

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Figure 2-78. Sample Letter Confirming Termination of Certification Process at

Applicant’s Request

FAA Letterhead

[Date]

[Name and Address of Applicant]

Dear [Name of Applicant]:

This letter confirms your request to terminate the project to certificate you as an air agency under
Title 14 of the Code of Federal Regulations (14 CFR) part 141.

All materials submitted for review are enclosed with this letter. Any attempt to reapply after the
date of this letter will require reinitiating the entire certification process.

Sincerely,

[CPM’s Signature]

RESERVED. Paragraphs 2-1085 through 2-1100.

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