Discover how scenario-based training can revolutionize Part 91 recurrent pilot programs, enhancing safety, flexibility, and real-world preparedness.
The aviation industry constantly evolves to improve safety, efficiency, and operational effectiveness. However, one area where progress has been stifled is in the realm of recurrent pilot training for Part 91 operators. Recent changes in FAA guidance have led to increased scrutiny over how this training is conducted, raising an important question: should Part 91 recurrent pilot training place greater emphasis on scenario-based events rather than repetitive, checklist-driven tasks?
Traditionally, pilots operating under Part 91 regulations attend training courses at Part 142 training facilities to meet FAA-mandated annual pilot-in-command proficiency checks under FAR 61.58. These sessions aim to hone a pilot’s skills and ensure readiness for the unexpected.
However, according to aviation experts, recent policy interpretations now force some training centers to prioritize routine, task-oriented exercises—such as normal takeoffs and landings—over preparing pilots for critical, real-world scenarios.
This shift is a direct result of the FAA’s updated interpretation of inspector guidance, which, according to NBAA (National Business Aviation Association), emphasizes “box-checking” exercises at the expense of meaningful skill-building opportunities. While these procedural checks are important, critics argue that they don’t fully equip pilots for the challenges they may face in dynamic and unpredictable situations.
“We’ve been doing the same archaic training since 1972,” noted Dondi Pangalangan, senior vice president of strategic initiatives at Clay Lacy Aviation. “Why check things we know a pilot can do because they’re doing them every day? More scenario-based training would allow the industry to evolve.”
Recognizing the limitations of the current approach, NBAA has taken steps to advocate for more effective training solutions. In mid-2024, NBAA met with the FAA to request clearer guidance and greater flexibility in how recurrent training is implemented. The goal is to allow training providers to prioritize scenario-based learning over the repetitive re-validation of basic tasks.
“About a year ago, the FAA changed its interpretation and application of guidance,” explained Brian Koester, aviation operations and compliance analyst at Jetlaw, LLC.
“NBAA has been advocating for the industry, meeting with the FAA in mid-2024 to discuss clarifications that will give the industry flexibility to implement more scenario-based training rather than re-training the same list of tasks every six months.”
The commercial airline industry has long relied on advanced qualification programs (AQP) to revolutionize pilot training. AQP uses a data-driven approach to focus on progressive skill-checking.
For instance, if a pilot demonstrates proficiency in a normal takeoff during one training event, that task is considered “checked” and does not need to be repeated. This allows airline instructors to dedicate more time to scenario-based and emergency-response training.
“Airlines use AQP, rely on safety data and change training topics event over event,” said Timothy Schoenauer, senior director of training solutions for business aviation at CAE.
“Meanwhile, business aviation is required to have a checking philosophy and we don’t have an opportunity to evolve the training environment. More scenario-based training would allow the industry to evolve.”
In the absence of immediate regulatory change, some training providers are taking the initiative. CAE, a global leader in aviation training, has developed Continuously Optimized Recurrent (CORe) training.
This innovative program tailors training topics to address emerging risks and threats, revisiting and refining them every six months.
“We aim to learn from the data and put it back into training to close the loop on the risk,” said Schoenauer. “We have to, as an industry, take steps to advance how we train, not just check.
It has worked for 30 years for the airlines; now is the time for business aviation.”
As the industry continues to advocate for change, the need for more meaningful, scenario-based training remains clear.
By prioritizing critical thinking and real-world preparedness over rote procedural tasks, the business aviation sector can enhance safety, operational flexibility, and pilot competency.