Legal Interpretations
Dent 2016
Summary
The Question
May a Part 135 simulator checkride or training under 14 CFR 135.293 and 135.297 use a support pilot who is not qualified under part 135 with the certificate holder?
Background
A requester asked whether a support pilot who is not part 135 qualified or current with the air carrier may be used for multi-engine turbojet simulator checkrides under 14 CFR 135.293 and 135.297, and for training.
The FAA’s Interpretation
The regulations do not address it. FAA regulations set no specific requirements for a support pilot, but FAA Order 8900.1, paragraph 3-4414 F, addresses crew pairing for simulator checking and training, and an air carrier's approved training program should outline seat support protocols, especially with a contract training provider. The FAA referred further questions to the Air Transportation Division (AFS-200).
- Requester
- Dent
- Issued
- September 26, 2016
- Subject
- Air Carrier & Commercial Operations
Regulations Cited
Page 1
U.S. Deportment
of Transportation
Federal Aviation
Administration
SEP 2 6.2016
Jim Dent
310SW120 Terr
Plantation, FL 33325
Re: Support Pilot Qualifications
Dear Mr. Dent:
Office of the Chief Counsel 800 Independence Ave., S.W.
Washington, D.C. 20591
This letter responds to your April 29, 2016 request for interpretation of the qualifications of a support pilot. In your letter, you ask the following questions:
1) On a multi-engine turbo-jet simulator can a Part 135(§§135.293, 135.297) checkride be conducted with a support pilot who is not a pilot that is qualified under Part 135 with the certificate holder?
2) Can training be conducted utilizing a support pilot that is not a Part 135 current pilot with the air carrier?
I presume your use of the term "support pilot" refers to a person who is acting as pilot monitoring (either pilot in command or second in command) during air carrier simulator training or checking. It is noted that "support pilot" could also refer to a person performing the role of pilot flying so that another pilot may be trained to perform the duties of pilot monitoring. Although FAA' s regulations do not address specific requirements for a support pilot, the FAA does address crew pairing for simulator checking and training in Order 8900.1 at paragraph 3- 4414 F. An air carrier's approved training program should additionally outline seat support protocols, especially for use with a contract training provider. For further information about these policies, please contact the Air Transportation Division (AFS-200) of the Flight Standards Service.
We appreciate your patience and trust that the above responds to your inquiry. If you need further assistance, please contact my staff at (202) 267-3073. This response was prepared by Courtney Freeman, an attorney in the Regulations Division of the Office of the Chief Counsel, and coordinated with the Air Transportation Division of the Flight Standards Service.
Lorelei Peter
Assistant Chief Counsel for Regulations
Page 2
Office of the Chief Counsel
800 Independence Ave., S.W.
Washington, D.C. 20591
Jim Dent
310 SW 120 Terr
Plantation Fl 33325
To Whom It May Concern, My question is regarding a Part 135.293/297 check ride. On a multi-engine turbo-jet simulator can a Part 135 checkride be conducted with a support pilot who is NOT a pilot that is qualified under Part 135 with the certificate holder?
Additionally can training be conducted utilizing a support pilot that is NOT a Part 135 current pilot with the air carrier.
RespectfuTfy ~to~,
Jim Dent
Regulations Referenced
Snapshot retrieved August 6, 2026.