Part 141 overhaul: AOPA speaks up for small schools

The comments filed May 11 on a 471-page report compiled by the National Flight Training Alliance are generally supportive of the recommended changes, which should come as no surprise since AOPA participated in the yearlong series of public meetings held to gather input from industry stakeholders. AOPA Foundation Senior Director of Flight Training Education Chris Moser noted in AOPA's formal response to the NFTA report that the association "generally supports the direction of many of the recommendations … particularly where they seek to improve consistency, efficiency, and flexibility while maintaining a strong focus on training quality and safety outcomes. At the same time, AOPA emphasized that modernization must not come at the expense of independent, third-party oversight, meaningful aircraft-based experience, or the foundational role of instructors and evaluators in maintaining airman standards."

The FAA received hundreds of comments on the NFTA report, which the FAA will now digest, along with the report, and develop an expansive rulemaking proposal likely to represent the first major overhaul of Part 141—which governs professional flight training­­—in more than 50 years.

AOPA voiced nuanced support for the core recommendations in the industry report, including that the FAA create a central office to manage Part 141 schools, with the caveat that the agency allocate sufficient resources to conduct active oversight and avoid becoming a regulatory bottleneck, "or, worse, allow programs to remain approved by default due to administrative inertia rather than the desired ideal of efficiency and authoritative leadership."

The industry discussions held between March 2025 and March 2026 also produced broad consensus around establishing safety management systems (SMS), which are already in widespread use, and the less familiar quality management systems (QMS), a variation on an SMS that focuses on validating and maintaining instructional quality.

"AOPA generally supports this direction," Moser wrote. "However, QMS and SMS must not be treated as substitutes for … external evaluation. Poorly defined criteria could allow low quality providers to 'check the box' while advancing marginal students. Quality assurance systems must be evaluated based on outcomes, including demonstrated willingness to fail or remediate students who do not meet established standards."

With respect to school management and oversight, AOPA voiced "concerns regarding proposals that would eliminate the requirements for assistant chief instructor or equivalent leadership at each authorized training location." Similarly, AOPA voiced concern about the industry-recommended expansion of examining authority, allowing school staff to conduct checkrides, up to and including testing flight instructor candidates.

"While AOPA acknowledges the persistent challenges associated with examiner availability and scheduling, there is concern among AOPA and other stakeholders that broad expansion of self-examining authority could unintentionally diminish the role of independent airman evaluation. Additionally, the FAA should ensure that the required Tier 2 level of QMS operation for achieving examining authority is properly scaled to make them achievable for smaller schools and single location operations," Moser wrote.

The association voiced strong support for another core recommendation, to utilize simulation and other emerging training devices: "We believe that simulation is an important tool for improving the flight training experience and moderating training costs when properly integrated." AOPA recommended that the FAA establish a process for periodic reassessment of flight simulation tools, and to avoid overreliance on simulation in flight training, maintaining a "meaningful minimum" of actual flight experience, including maneuvering by visual reference, communication with air traffic control, and stick-and-rudder skills. 

The industry recommendations also include the creation of an entry-level "Registered Pilot School" designation that could serve as an entry point for smaller operators seeking to build up to full Part 141 participation. "If implemented carefully, such a designation could provide value by introducing a limited set of foundational best practices without imposing the full regulatory framework applicable to certificated Part 141 schools," Moser wrote. "Questions remain regarding the intended scope of a Registered Pilot School designation, how registration status would be administered or maintained, and how the FAA will clearly differentiate this designation from Part 141 Tier 1 and Tier 2 programs, which are subject to substantially more rigorous certification, approval, and oversight requirements."

Broadly, AOPA's cautious support of the industry recommendations is based on general agreement that modernization is necessary, though AOPA urged the FAA to adopt a phased, data-driven approach to the Part 141 update—without excluding smaller schools "that remain critical to the nation's flight training ecosystem."

AOPA's submission to the FAA can be viewed online in the regulatory docket.

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