MY 2 CENTS By Randy Rowles


DESERVES ANOTHER LOOK CONTRACT PART 135 TRAINING


As the helicopter emergency medical services community prepares to gather in Fort Worth, Texas, for this year’s Air Medical Transport Conference (AMTC), the industry’s attention will naturally focus on improving safety, maintaining operational readiness, controlling costs, and developing the next generation of professional helicopter pilots.


Those


discussions also present an opportunity to revisit an FAA authorized training option that has existed for years, yet remains largely overlooked by many Part 135 operators. The purpose of this article is not to advocate for one training provider over another, but to encourage discussion about a regulatory pathway that can help operators reduce administrative burden, improve flexibility, and maintain the uncompromising commitment to pilot proficiency that defines our industry.


Every chief pilot and director of operations understands the balancing act. Pilots must complete initial, transition, upgrade, and recurrent training to remain qualified under Part 135, yet every hour devoted to training is an hour an aircraft is unavailable for patient transport. Add the realities of instructor and check airman turnover, increasing administrative responsibilities, insurance training requirements, and the continual pressure to keep aircraft available for revenue producing operations, and it becomes clear why training has become one of the most demanding responsibilities within a commercial helicopter operation.


No operator questions the value of recurrent training. It is one of the foundations of aviation safety. The challenge is not whether to train, but how to accomplish it efficiently without sacrificing aircraft availability, operational readiness, or the quality of instruction.


For decades, most operators have relied on one of two proven approaches. They either conduct training internally using company instructors, check airmen, aircraft, and training resources, or they send pilots to an FAA-certificated Part 142 training center. Both models have served the industry exceptionally well. Internal programs provide mission-specific instruction tailored to an operator’s environment, while


10 July/Aug 2026


organizations such as Bell Training Academy, CAE, FlightSafety International, and others have elevated helicopter safety through standardized curricula and sophisticated simulation technology.


What many operators may not realize is that the FAA provides another fully authorized option.


Under 14 CFR 135.324, required Part 135 training,


testing, and checking may be


conducted not only by a certificated Part 142 training center, but also by another operator conducting operations under Part 135, provided the training is accomplished under the customer’s FAA-approved training program. The FAA intentionally created this flexibility because it recognized that certificate holders have different operational needs and varying training resources.


For some operators, this authority may provide an opportunity to rethink how recurrent training is delivered.


Maintaining an internal training department


requires considerably more than experienced instructors. It requires qualified check airmen, scheduling, records management, regulatory oversight, aircraft availability, and for many organizations, simulation resources. When instructor or check-pilot turnover occurs, maintaining those qualifications becomes even more difficult. Smaller operators may find themselves depending upon a single individual to support an entire training program, while larger organizations often struggle to balance training schedules against daily operational demands.


Aircraft availability presents another challenge. Every aircraft committed to training is temporarily unavailable for operational missions. While advanced flight maneuvers are safely conducted every day by experienced instructors, operators naturally seek to minimize unnecessary utilization of operational fleet aircraft whenever practical. The objective is not to reduce training; it is to deliver exceptional training while making the most effective use of limited resources.


This is where the FAA’s contract training authority deserves another look.


Rather than developing every capability internally, a Part 135 operator may contract another qualified Part 135 certificate holder to conduct training, testing, and checking under its approved training program. The contract provider effectively becomes an extension of the operator’s training department, supplying instructors, check airmen, aircraft when needed, administrative support, and training resources while allowing the customer to remain focused on daily operations.


This authority was never intended to replace Part 142 training centers — nor should it. In reality, today’s strongest training programs, whether delivered by an FAA-certificated Part 142 training center or a contract Part 135 provider, fully embrace simulation as a cornerstone of pilot development. High fidelity flight simulation devices safely expose pilots to emergencies, system failures, weather events, instrument procedures, and decision- making scenarios that cannot reasonably be recreated in an aircraft. Their contribution to aviation safety is undeniable. The difference is not simulation versus aircraft training, but how classroom instruction, simulation, and aircraft training are integrated into a comprehensive learning experience.


Aircraft training continues to provide important value when combined with simulation. Aircraft handling, energy management, touchdown autorotations where approved, environmental awareness, and night vision goggle (NVG) operations develop proficiency in ways that complement simulator based instruction. The strongest training programs recognize that each training medium contributes unique strengths, and together they produce more capable, confident, and proficient pilots.


Another advantage of the Part 135 contract model is flexibility. Training may be conducted in the customer’s aircraft or, when appropriate, in


aircraft provided by the contract training


operator. Depending upon the provider’s capabilities, FAA recurrent training and insurance-required recurrent training may also


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