ACP / AQP Bulletin 02/12

Subject

Amendment to the policy governing recurrent monitoring intervals

Purpose

To finalize an amended policy governing the frequency upon which Transport Canada Civil Aviation (TCCA) will conduct recurrent ACP and AQP Evaluator monitors.

Background

Effective 01 January 2012 as an interim measure while an ACP program review was being conducted, Internal Process Bulletin 2011-06 - Temporary Changes to Transport Canada’s Oversight Policy of Approved Check Pilots provided for a temporary extension to recurrent monitoring intervals from one year to two years for all ACPs (with the exception of those ACPs who were scheduled for their first recurrent monitor following initial delegation, which remained set at a one-year interval). 

As similar monitoring policies apply under an Advanced Qualification Program (AQP), this interim measure was expanded to capture recurrent AQP Evaluator monitoring intervals as well.

Since this temporary measure is scheduled to end on 31 December 2012, TCCA aims to finalize an amended policy governing the frequency upon which it will conduct recurrent ACP and AQP Evaluator monitors before year end in order to be in a position to implement changes by 01 January 2013.

Intended Staff Guidance

With respect to the ACP program:

The overarching objective of the ACP program is to provide reasonable assurances that ACPs can be relied upon to conduct valid and reliable assessments of pilot performance in a safe and efficient manner.

In the wake of its ACP program review, TCCA is prepared to adopt a uniform recurrent monitoring policy, with a twelve-month interval initially for new delegates, and a twenty-four-month base interval thereafter.

All issuing authorities however are strongly encouraged to give proper consideration to maintaining shorter intervals (as short as a twelve-month interval where warranted), in response to various criteria which may adversely affect risk levels.  These criteria typically relate to the following:

  • platform used (simulator v. aircraft)
  • operating rules (Instrument Flight Rules v. Visual Flight Rules)
  • regulatory subpart(s) involved (subparts 702, 703, 704 or 705)
  • aircraft category involved (rotary wing v. fixed wing)
  • aircraft type complexity (new generation v. early generation)
  • level of experience (new v. experienced ACP)
  • level of exposure (low v. high activity level as an ACP)
  • crew composition (single crew v. multi crew aircraft)
  • area of ACP activity (dedication to a single air operator v. freelancing with more than one air operator)
  • scope of ACP delegation (narrow scope v. broad scope involving multiple aircraft types, air operators and regulatory subparts)

TCCA’s recent ACP program review determined that the likelihood of generating less reliable assessments of pilot performance tends to increase when ACPs:

  • are relatively inexperienced;
  • do not conduct flight checks on a regular basis;
  • rely on a stale type rating with no recent operational or instructional experience on type, for the benefit of another air operator, as opposed to conducting PPCs while also being an active pilot on type for that particular employer;
  • hold a delegation spanning across a number of aircraft types, categories, and regulatory subparts, as opposed to a narrowly focused delegation involving a single type and used specifically for the benefit of a single air operator; 
  • conduct PPCs in an actual aircraft, while sometimes acting as a flight crewmember, using a sequence of events not formally scripted but developed by the ACPs themselves - a far more complex situation than those ACPs who are merely observing performance by virtue of conducting highly scripted PPCs, based on a mature set of Standard Operating Procedures, in a full flight simulator sometimes operated by another person; and/or
  • do not receive extensive support from the air operator they work for, such as the availability of PPC scripts, tailored ACP training, mentoring, communication with TCCA via the employer, and records maintenance.

This broad range of variables, with respect to the conduct of PPCs, necessarily translates into a broad spectrum of risk levels; it is therefore quite conceivable that TCCA could apply more restrictive recurrent monitoring intervals to specific ACP sub-sets deemed to be posing a higher risk level overall (for example only, with relatively inexperienced ACPs conducting PPCs infrequently under Subpart 703 in actual aircraft).

Therefore, where deemed appropriate or necessary by virtue of one or any combination of criteria discussed above that may place a particular ACP sub-set at a greater risk of misapplying flight checking procedures, issuing authorities should consider implementing shorter ACP monitoring intervals for those particular ACP sub-sets deemed to pose a higher risk level overall.

TCCA will maintain its current practice of using discretion to monitor delegates more often for cause where deemed necessary, based on risks associated with the individual (as opposed to a particular sub-set of ACPs), in the form of enhanced or special monitoring.

Existing policies with respect to early renewals and temporary extensions of ACP privileges, as per Chapter 1, sub-section 1.8.8 of the ACP Manual, remain unchanged. 

With respect to AQP:

It is largely recognized that AQP has reached a level of sophistication, both from an air operator perspective and a surveillance standpoint, which would permit the development of a comprehensive risk matrix well suited to defining monitoring intervals associated with AQP evaluators. 

The ACP program policy as amended in this bulletin can be applied as is under an AQP, meaning that AQP Evaluators subject to recurrent monitoring will be monitored at a twelve-month interval following initial delegation, and every twenty-four months thereafter.  TCCA's recent ACP program review however suggested that given our growing AQP expertise based on robust program data collection and analysis, TCCA's AQP oversight team (namely the Airlines division of the National Operations branch) could develop, if and when it deems appropriate, a comprehensive risk-based matrix defining monitoring intervals for AQP evaluators under an AQP, and propose its resulting matrix for inclusion in TP 14672 – AQP Evaluator Manual

Existing policies with respect to early renewals and temporary extensions of AQP Evaluator privileges, as per Chapter 6, sections 6.2 and 6.4 of the AQP Evaluator Manual, remain unchanged. 

Workload distribution:

Implementation of these changes will necessitate that issuing authorities attempt to spread the resulting monitoring workload judiciously in order to properly manage a workload level that, upon implementation, may approximate the monitoring workload that existed under the previous policy of annual recurrent monitors.

An issuing authority should determine as soon as able if it deems necessary to limit specific ACP sub-sets to a monitoring interval of less than twenty-four months.  It should schedule recurrent monitors, with priority given to those ACPs / AQP Evaluators who have not been monitored for the longest period of time, and/or to those sub-sets that represent higher levels of risk overall if such an assessment has already been done. 

In some cases, an issuing authority should consider conducting early monitors as a means to better distribute the initial workload and ensure that it does not have to provide extensions to delegations, due to excessive workload.  Although this strategy should be avoided to the extent possible, an issuing authority may also consider allowing certain delegations to lapse for a short time with no extensions being provided, if acceptable to the individuals holding these delegations and/or the air operators that use them. 

With a view to avoid creating activity spikes in the future and evenly spread monitoring activities in subsequent years, an issuing authority should also consider staggering the valid-to dates of recurrent monitors, once successfully completed, so as to better suit its needs in terms of future workload planning.

The practice of applying different valid-to dates to successful recurrent monitors cannot be considered normal practice; it would be deemed acceptable in the circumstances explained above however, keeping in mind that recurrent monitors do not constitute a Canadian Aviation Document (CAD) but merely an ongoing requirement for maintaining delegation privileges.  By staggering valid-to dates of recurrent monitors, it must be understood that an issuing authority will not assign a valid-to date beyond the 24-month interval (or beyond a shorter interval where assigned to specific sub-set(s) of delegates).   

Effective Date

This instruction takes effect on 01 January 2013.  The next editions of TP 6533 – ACP Manual and TP 14672 – AQP Evaluator Manual will reflect these changes in due course.

Contact Person

Tom Dunn
Program Manager, Approved Check Pilot / Advanced Qualification Programs (AARTF)
613-998-8168
tom.dunn@tc.gc.ca

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