Every Part 135 operator is a charter broker at some point. A crewmember gets sick, an airplane breaks, or demand simply exceeds your fleet capabilities and you’re out looking for another charter operator to pick up a flight for you. How do you choose your supplemental lift providers? Do you have a vetting process in place or will any operator with a 135 certificate on the wall do in a pinch? Developing and consistently using a documented vetting process can help limit your liability when sending a customer to another air carrier.
To develop an evaluation process, start with the simplest aspects of Part 135 operations.
Is the air carrier legal? That is, do they have a valid Part 135 certificate to conduct the specific type of operation? Many charter operators stop there. Obviously the FAA wouldn’t certificate a company that isn’t really competent to run a Part 135 operation. Right? Well… I’ll let you ponder that one. But just remember – a Part 135 certificate is merely a passing grade. It’s a pretty low bar compared to where the industry really is in terms of safety, security, and efficiency. Do you want your customers flying with the operator who only got a “D” in Part 135 operations? A “D” is a passing grade and personally I don’t want the “D” pilot, the “D” charter operator, or the “D” brain surgeon. Achieving a passing grade really isn’t saying much.
Most operators go beyond the Part 135 certificate and require proof of certain insurance limits. While it’s certainly prudent to verify insurance coverage, that’s like putting on your seatbelt after the car has struck a tree. It’s far better to exercise due diligence and mitigate risk prior to starting the car.
Some charter operators very proudly only use companies with an ARG/US or Wyvern rating or a successful IS-BAO or Air Charter Safety Foundation registration. These ratings and registrations only have value if you know what they mean. What does it take for an operator to earn a particular rating? Is there an on-site safety and operations audit or does the operator just submit data about their fleet and pilots? If an audit is required, what standards must the operator meet in order to be registered? Do findings or concerns have to be addressed before being registered or rated? All “XYZ Rated!” logos are not equal. I’m not saying one audit or rating is superior to another. They all have some value in our industry. The individual rating or registration’s value depends on your needs and your expectations for your customers but if you don’t know what’s behind the rating, it’s meaningless.
Even an operator’s audit status shouldn’t be a single decision point for choosing supplemental lift. Audits are basically the gym membership of aviation. There are people who buy a gym membership and go work out regularly. Others get the membership and kick themselves every time the monthly fee shows up on their credit card statement because they don’t even remember how to get to the gym. And still other people are very fit and healthy but choose not to have a gym membership. The operators who work out at the gym regularly not only put themselves out to be evaluated by third party auditors but also strive to keep the audit standards and intent alive and well in between audits. Those who buy memberships and never go back are the operators who pretty up their manuals and bring in donuts for a two or three day audit but if you go back next week, no one knows where the new manuals ended up and the donuts are moldy. (That is purely for illustration purposes, of course. I know no charter operator would do such a thing…) And there are certainly operators who choose not to have a third party evaluation but are still safe, conscientious operators.
This post isn’t intended to tell you how to evaluate charter operators used for supplemental lift. The intent is to get all of us thinking about how and why we choose companies to work with. I get a little knot in my stomach every time an operator says they use any XYZ-rated operator for supplemental lift with no further evaluation beyond verification of the pretty logo. Aside from the personal guilt most of us would feel if we sent a customer to another operator and that flight was involved in an accident, you can limit your legal liability by exercising due diligence prior to choosing supplemental lift providers. You owe it to your employees to protect the company from unnecessary legal risk. You owe it to your customers to put them with carefully chosen air carriers.
I encourage you to develop a detailed, documented process for evaluating your supplemental lift providers and use it for each and every trip you have to send to another air carrier. If you already have a process, give it a good hard look. Is it still valuable? Is it enough? Once you have a reasonable process in place, use it consistently and conscientiously. Be smart about supplemental lift.