NBAA Files Support for NFTA Part 141 Modernization Proposal, Calls for Business Aviation-Specific Refinements

USA – The National Business Aviation Association (NBAA), representing more than 10,000 member companies and professionals, has filed a formal response to the FAA supporting the National Flight Training Alliance (NFTA) report on comprehensive modernization of Part 141 pilot training, while identifying areas requiring further refinement to address business aviation-specific training needs.

• In comments submitted to FAA Docket FAA-2024-2531 on 11 May 2026, NBAA expressed strong support for the NFTA report's central premise of shifting from an hours-based, compliance-centric regulatory model toward a performance-based, data-driven training system, describing the modernization as critical for preparing pilots for the high-consequence, technologically advanced environment of Part 91, 91K, and 135 operations.
• NBAA endorsed four key elements of the NFTA proposal: the proposed "Two-Tier" Safety and Quality Management System (SMS/QMS) framework mandating formal QMS for Tier 2 flight schools; the Professional Pilot Track (Appendix P) establishing a 200-hour integrated curriculum with Industry Advisory Boards (IABs) allowing business aviation flight departments to provide direct input to schools; expanded recognition of Enhanced Advanced Aviation Training Devices (EAATD) and Extended Reality (XR) simulator credits in primary training; and the establishment of a Central Management Office (CMO) to eliminate inconsistent FSDO interpretations across regions.
• NBAA raised four areas requiring further refinement: ensuring Tier 2 QMS requirements are scalable for specialized boutique Part 141 schools providing transition training (such as UPRT or turbine transitions) to avoid inadvertently shuttering critical safety training providers; aligning the NFTA's Professional Pilot Track with the ACT ARC 24-1 "Jet Transition" standards for high-altitude, high-speed flight training; strengthening the proposed Initial Teaching Experience (ITE) for new CFIs through mentorship models with senior instructors holding Part 135 or 91 experience; and streamlining the FAA's Letter of Authorization (LOA) process for adding aircraft to a pilot school's operational fleet.
• The submission was signed by Douglas Carr, NBAA Senior Vice President of Safety, Security, Sustainability & International Affairs.
• The NBAA response follows the FAA's launch of a public input phase in early 2026 on Part 141 modernization, the first substantial revision of the regulations since 1997, responding to shifts in aviation technology, training methods, and airspace operations.

Source: NBAA