Tiers Being Proposed Within Part 141 Modernization Project

The 141 Modernization workgroups continue to work on proposals and content that will eventually be formulated into a report that will be finalized before the end of 2025 and presented to the FAA for consideration for NPRM development. FSANA representatives continue to be a part of some of the work on behalf of member flight training providers.

Some key points of the recent discussions include proposals that there would end up being multiple tiers of 141 certificate holders. For example, tier levels as defined on July 7, 2025 were proposed that might look as follows:

Tier One - Air Agency Certificate
- A basic level with low bar to entry such as small pilot club, fractional ownership or “two people and a plane" demonstrates intent of permanency;

Tier Two - Flight School
- First level school with permanent staff, small school instructing recreational GA pilots, multiple aircraft, and examining authority in 24 months;

Tier Three - Flight Training Center
- Larger fleet, full-time staff with higher education association, professional pilot vector, director versus chief instructor option; 

Tier Four - Flight Training Academy
- Professional pilot training pipeline, accredited, direct commercial certification, required to give professional development/mentoring.

Future Considerations included final integrations with other working groups, how to integrate current 141 and larger 61 schools, bed down privileges, and responsibilities for each tier.

It was noted in the proposed structure that Part 61 schools were thought of as “One on One Mentors”. 

A key factor in the discussions is the establishment of a national office for 141 certificate management. It is anticipated that this would:
- Reduce workload on local FAA offices;
- Expedite approval processes for 141 applications and updates;
- Provide a focused and specialized work team at the FAA that would be a knowledgeable resource for 141 operations

In a presentation on the FAA’s Rulemaking, Jim Croddy with the FAA, noted that they have a staff of 40 people with approximately 33 current projects. He explained there are two processes to rulemaking, the first is a minimum of 20 months of research, the second is minimum of 16 months for comments, etc. 36 months is optimal, however it can take much longer depending on how well the new rules are written. Jim said the earliest for new rulemaking would be spring of 2027.

This process remains a dynamic one and FSANA will continue to provide updates as the project proceeds forward. Debbie Sparks, FSANA Vice President is the FSANA leader on the 141 Modernization project. She can be reached at debbie@fsana.com