How long can a Part 135 operator go without a chief pilot?

There is no grace period written into the rule. Section 119.69(e)(3) requires the responsible Flight Standards office to be notified within ten days of a vacancy in a required management position, and the certificate holder is expected to have qualified personnel serving in that position. In practice operators cover the gap with a documented interim appointment while the permanent search runs.

What are the FAA qualification requirements for a chief pilot?

Under 14 CFR 119.71, where the operation requires an ATP for pilot in command, the Chief Pilot must hold an ATP with appropriate ratings, be qualified to serve as pilot in command in at least one aircraft used in the operation, and have three years as PIC under Part 121 or 135 — within the past six years if it is their first Chief Pilot role. Commercial-certificate operations carry a lower licence bar and the same experience requirement.

Does an interim chief pilot have to be type-qualified in our fleet?

The rule requires the Chief Pilot to be qualified to serve as pilot in command in at least one aircraft used in your operation, so in practice yes — either on arrival or through training you sponsor early in the engagement. It is the single biggest filter on the candidate pool and the first thing worth confirming in a screening call.

Can we appoint an interim chief pilot who does not meet the experience requirements?

There is a route, not a loophole. Under 119.71(f) a certificate holder may request a deviation to employ someone who does not meet the airman, managerial or supervisory experience requirements, where the Manager of the Air Transportation Division, AFS-200, finds the person has comparable experience and can effectively perform the role. The Administrator can terminate a grant of deviation authority at any time.

What should we look for when screening interim chief pilot candidates?

Type qualification in your equipment or a realistic path to it, prior time in the seat rather than adjacent to it, direct experience with your operation type and area of operations, and a clear account of how they run a training and standards programme. Ask what their first thirty days look like — an experienced interim will answer in specifics.

Will the FAA accept an interim appointment to a required management position?

What the regulation asks is that a qualified person hold the position with documented duties and authority, and that changes in personnel be notified within ten days. A properly documented interim appointment — the right qualifications under 119.71, the manual amended, the notification made — fills the seat the same way a permanent appointment does. What draws scrutiny is a vacancy with no named holder and no plan.

Role guide

Filling the seat with an interim chief pilot

Of the three required Part 135 management positions, Chief Pilot is the hardest to backfill — because the rule does not just ask for experience, it asks for someone qualified to fly one of your aircraft as pilot in command. That single clause is why the seat sits empty for months.

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The clock starts the day they resign

Under 14 CFR 119.69(e)(3), a certificate holder must notify the responsible Flight Standards office within ten days of any change in personnel or any vacancy in any of the listed management positions. That notification is not a formality — it tells your principal operations inspector that a required seat is empty, and the reasonable next question is how and when it will be filled.

Nothing in the regulation grants a grace period in which the operation may run without the position. The practical posture most operators end up in is a documented interim arrangement: a qualified person named in the seat, the manual amended, and a credible plan for the permanent hire. What creates exposure is an unfilled position with no named holder and no plan — a state that is easy to drift into while a search runs long.

The knock-on effects arrive faster than the regulatory ones. Training records and currency tracking stop having an owner. Standards questions from the line get answered by whoever is nearest. Check airman and evaluator scheduling slips. None of that shows up as a finding on day one, and all of it does eventually.

Why this is the hardest seat to fill

The Chief Pilot qualifications in 14 CFR 119.71 carry a requirement the other management positions do not. Where the operator requires its pilots in command to hold an ATP, the Chief Pilot must hold an ATP with appropriate ratings and be qualified to serve as pilot in command in at least one aircraft used in the certificate holder's operation — plus three years as pilot in command under Part 121 or 135, within the past six years for a first-time Chief Pilot.

Read that middle clause again, because it is the one that breaks searches. The candidate does not merely need aviation management experience: they need to be current and qualified in your equipment, or get there. An operator flying a single type in a thin pilot market is recruiting from a pool measured in dozens, not thousands, and every one of those people already has a job.

This is precisely why interim engagement is the normal answer rather than a compromise. A leader who already holds the type, has been a Chief Pilot before, and can start in weeks is worth far more than a perfect permanent candidate who is nine months away — particularly since the interim can shape the role, stabilise the standards programme and hand over cleanly to whoever you eventually hire.

Type currency — Qualified to serve as PIC in at least one aircraft in your operation — the constraint that turns a national search into a narrow one.
Three years PIC under 121 or 135 — Within the past six years for a first-time Chief Pilot; the experience must be in air carrier or commuter and on-demand operations, not general aviation time.
ATP with appropriate ratings — Where your operation requires an ATP for pilot in command. Operators whose pilots need only a commercial certificate have a lower licence bar, with an instrument rating where one is required for PIC.
A deviation path exists — Under 119.71(f) a certificate holder may request a deviation for a candidate with comparable experience, decided by the Manager of the Air Transportation Division, AFS-200.

What a good interim does in the first thirty days

An interim Chief Pilot who has done this before does not spend the first month getting oriented. The pattern is consistent across engagements, and it is a fair thing to ask a candidate to walk you through in an interview.

Take the paperwork off the table — Confirm the ten-day notification went out, get the manual amended to name the position holder, and make sure the operations specifications reflect reality.
Audit currency and training — Rebuild the picture of who is current in what, where the recurrent-training cliff edges are in the next ninety days, and which records will not survive an inspection.
Stabilise standards — Re-establish who answers standards questions and how, so the line stops improvising, and get the check airman and evaluator programme back on schedule.
Write the handover from day one — A good interim treats the permanent hire as the deliverable: documenting the state of the department, the open items and the shape of the role so the successor inherits a working seat rather than an archaeology project.

Interim, fractional, or both

The two words get used interchangeably and they are not the same thing. An interim Chief Pilot holds the seat full-time for a defined term — the right shape when a departure has left a hole and the operation needs someone in it every day until a permanent hire lands. A fractional Chief Pilot holds the role on an ongoing basis for a share of their time, which suits a small certificate whose compliance and standards load is real but not a full week.

Small operators frequently start with one and settle into the other. An interim comes in to cover a resignation, spends three months discovering the job is genuinely two days a week rather than five, and converts to an ongoing fractional arrangement — with the operator keeping the seniority and paying for the share it actually uses. Both shapes put a qualified person in the position with documented duties and authority; the difference is term versus time-share.

Either way, the seat is real. The name in the manual is a person who answers the phone, owns the standards programme and is answerable for it — not a title of convenience parked on someone who is already doing two other jobs.

Keep reading

Fill the seat

Flight Level Partners is the curated directory of fractional and interim aviation leaders. Every listing states the certifications, frameworks and operations behind it — so you can vet fast without trading away rigor.

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Frequently asked questions

How long can a Part 135 operator go without a chief pilot?: There is no grace period written into the rule. Section 119.69(e)(3) requires the responsible Flight Standards office to be notified within ten days of a vacancy in a required management position, and the certificate holder is expected to have qualified personnel serving in that position. In practice operators cover the gap with a documented interim appointment while the permanent search runs.
What are the FAA qualification requirements for a chief pilot?: Under 14 CFR 119.71, where the operation requires an ATP for pilot in command, the Chief Pilot must hold an ATP with appropriate ratings, be qualified to serve as pilot in command in at least one aircraft used in the operation, and have three years as PIC under Part 121 or 135 — within the past six years if it is their first Chief Pilot role. Commercial-certificate operations carry a lower licence bar and the same experience requirement.
Does an interim chief pilot have to be type-qualified in our fleet?: The rule requires the Chief Pilot to be qualified to serve as pilot in command in at least one aircraft used in your operation, so in practice yes — either on arrival or through training you sponsor early in the engagement. It is the single biggest filter on the candidate pool and the first thing worth confirming in a screening call.
Can we appoint an interim chief pilot who does not meet the experience requirements?: There is a route, not a loophole. Under 119.71(f) a certificate holder may request a deviation to employ someone who does not meet the airman, managerial or supervisory experience requirements, where the Manager of the Air Transportation Division, AFS-200, finds the person has comparable experience and can effectively perform the role. The Administrator can terminate a grant of deviation authority at any time.
What should we look for when screening interim chief pilot candidates?: Type qualification in your equipment or a realistic path to it, prior time in the seat rather than adjacent to it, direct experience with your operation type and area of operations, and a clear account of how they run a training and standards programme. Ask what their first thirty days look like — an experienced interim will answer in specifics.
Will the FAA accept an interim appointment to a required management position?: What the regulation asks is that a qualified person hold the position with documented duties and authority, and that changes in personnel be notified within ten days. A properly documented interim appointment — the right qualifications under 119.71, the manual amended, the notification made — fills the seat the same way a permanent appointment does. What draws scrutiny is a vacancy with no named holder and no plan.