It’s Time to Modernize FAA Part 141 Regulations
It’s Time to Modernize FAA Part 141 Regulations
H. Michael Miley Ph.D.
Throughout my aviation career, I’ve learned that the key to safety and excellence is continuous improvement. As such, the system that trained me decades ago is not the same system we need today, and certainly not the one we’ll need in the future. Our pilot training programs must evolve, and that means modernizing FAA Part 141 regulations to ensure we’re preparing aviators for the real-world challenges of flying.
Making Part 141 Certification Reflect Real-World Competency
Flying isn’t about checking boxes—it’s about developing sound judgment, skill, and professionalism. Yet, the current Part 141 certification process is more focused on paperwork than performance. We should be evaluating flight schools on their ability to actually teach, not just on their pass rates influenced by the variability of different examiners.
A strong training program should be judged on:
- The Chief and Check Instructor's leadership, instructional skills, and ability to fairly evaluate students.
- The school’s instructor development and training process.
- The real-world capabilities and experiences of the pilots it produces.
- How effectively a school operates under any new regulations.
Pass Rates Incentivise Bad Behavior
The current regulations focus on maintaining an 80% first-time pass rate for knowledge, practical, and end-of-course tests (14 CFR 141.5). That simplistic measure may seem black and white, but anyone who’s been around a 141 system has seen failed check rides ended because of a “weather deferment” or reclassified as less regulated (and less reported) stage checks. Outwardly, these actions are there to help the student who is close and needs another chance. But when pushed, I’ve heard administrators point to protecting their 80% pass rate. It isn’t hard to imagine that a struggling school might choose to use the grey areas to offer someone significant additional training and multiple extra “stage checks” rather than having them fail early and degrade the organization’s 80% stat.
It is time to change the bad habits by:
- Recognizing that not everyone is going to pass the first time… or at all.
- Expecting pathways for underperforming students that struggle with the 141’s accelerated training.
- Developing inclusion metrics that encourage safety and learning rather than stepping into grey areas.
Creating Consistency Across FSDOs
Aviation demands predictability and consistency, yet different Flight Standards District Offices (FSDOs) interpret Part 141 requirements in different ways. A pilot should receive the same high-quality training whether they’re in Florida or Alaska. Right now, that’s not guaranteed and that’s unacceptable.
The FAA must:
- Establish a central office to oversee Part 141 certification and operations.
- Ensure uniformity in standards and expectations across all FSDOs.
- Provide clear, transparent guidance so schools know exactly what’s required.
Harnessing Technology to Improve Training
Aviation has always been about progress. From the earliest days of flight, we’ve embraced technology to make flying safer and more efficient. The same must be true for training. However, this must be an option—not a requirement. Schools should have the freedom to adopt new tools where they make sense, rather than being forced into a rigid, one-size-fits-all approach.
Schools should have the flexibility to integrate:
- Advanced simulation technologies.
- Digital record-keeping.
- Cutting-edge avionics and airframes.
- Remote training.
Shifting to a Competency-Based Model
The best pilots aren’t just those who log the most hours; they’re the ones who develop the strongest decision-making skills and adaptability. This manifests at each stage of training up through the R-ATP hours. Today, someone can graduate from a university program and build time towards their 1000 hour R-ATP solely by flying 45 min at a time in the Arizona desert. We need to change the training hours (and ATP requirements) to recognize and reward real-world experiences rather than continuing to -hope- more hours equate to real-world experience.
Our training system should reflect that by:
- Prioritizing demonstrated competency and flight experiences over minimum flight hours.
- Using scenario-based training to enhance real-world decision-making.
- Leveraging data to refine and continuously improve training methods.
Helping Part 61 Schools Transition to Part 141
Many flight schools operating under Part 61 hesitate to make the transition to Part 141 because of the bureaucratic burden. That needs to change. If the FAA makes a more practical and transparent process, more schools will make the transition, improving training quality industry-wide. Additionally, if a school proves it meets the 141 standards, it should receive examining authority upfront for at least private pilot standards. New 141 rules should eliminate unnecessary barriers and allow schools to focus on what matters: developing the safest pilots possible.
To do this, the FAA should:
- Expect and provide mentorship from experienced aviation professionals.
- Streamline the certification process while maintaining rigorous standards.
- Offer a clear, structured path to certification that includes examining authority from the outset.
Integrating Safety Management Systems (SMS)
Aviation safety doesn’t happen by accident—it’s the result of meticulous planning and proactive risk management. Adding an SMS isn’t about adding more red tape. It’s about making safety an integral part of training, just as it is in every professional flight operation.
Implementing an SMS in Part 141 schools would:
- Foster a culture where safety is at the forefront.
- Allow schools to identify and mitigate risks before they become problems.
- Provide a structured, data-driven approach to continuous improvement.
The Time for Change is Now
Aviation is built on progress. We don’t fly the same airplanes we did 50 years ago, and we shouldn’t be training pilots the same way either. If we want to continue leading the world in aviation safety and excellence, we must modernize Part 141 training regulations.
That means:
- Moving toward competency-based, data-driven training.
- Embracing new technology while maintaining flexibility.
- Standardizing certification requirements across all FSDOs.
- Giving schools the support they need to succeed.
We have an opportunity to build a training system that produces not just good pilots, but pilots who are ready to lead, to adapt, and to uphold the highest standards of safety and professionalism. But we have to take action now. We need to demand the FAA 141 modernization listen to the various industry leaders calling for similar changes.
How do you help? Make sure to voice your ideas and concerns to organizations like the Society of Aviation and Flight Educators (SAFE) that are working with the National Flight Training Alliance (NFTA) to help shape the FAA’s upcoming 141 changes.
