Policy Letter 173

Subject

Flight Crew Member Qualification Credits for Transition Programs and Mixed Fleet Flying Programs

File Number

RDIMS # 1040396

Date

2005.07.25

Policy Statement

The purpose of this Policy Letter is to provide Commercial and Business Aviation (CBA) Inspectors with guidance regarding the use of Operational Evaluation Board (OEB), Flight Standardization Board (FSB) or Joint Operational Evaluation Board (JOEB) reports to support an exemption from the applicable subsection, paragraph and subparagraph of Section 705.106 and 705.113 of the Canadian Aviation Regulations (CARs). This policy ensures that there is an alternate means of compliance for training, checking and currency requirements, when air operators request credits for Transition Programs of flight crew members transitioning from a base aeroplane to one or more variants of the same, common or different aeroplane type and if applicable operating more than one variant of the same, common or different type in an approved Mixed Fleet Flying (MFF) Program.

Applicability

This policy applies to all CBA Inspectors involved in approving training programs for air operators and persons acting as pilot-in-command (PIC) or second-in-command seeking pilot qualification credits to operate an aeroplane(s) that is a variant of the same, common or different type based on an aeroplane type they have or are currently operating under Subpart 705 of the CARs.

Definitions

Base Aeroplane:  An aeroplane or group of aeroplanes, designated by the applicant, used as a reference to compare differences with another aeroplane.

Transition programs:  For the purpose of this Policy Letter, it is the process of qualifying one or more flight crew members on an aeroplane type and one or more variant of the same, common or different type through a program, which may or may not involve credits from previous qualifications based on the recommendations of an Operational Evaluation (OE) report that is acceptable to the Minister.

Variant:  Aeroplane or a group of aeroplanes with the same characteristics that have pertinent differences from a base aeroplane. Pertinent differences are those that require different or additional flight crew member knowledge, skills and/or abilities that affect flight safety.

Same Type Rating, Common Type Rating, Single License Endorsement:  Terms used by Transport Canada Civil Aviation (TCCA), the Federal Aviation Administration (FAA), and the Joint Aviation Authorities (JAA) to indicate that the flight crew member type rating applies to one or more aeroplane variants. Differences training may be required between variants.

New Type Rating, Different Type Rating, Separate Type Rating:  Terms used by TCCA, the FAA and the JAA to indicate that a unique flight crew member type rating applies to the candidate aeroplane.

Flight Crew Members:  For the purpose of this Policy Letter, flight crew members include:  Pilot-in-Command and the Second-in-Command (First Officer).

Currency:  Recency of experience necessary for the safe operation of the aeroplane type or variants. Flight crew members qualification requirements that relate to take-offs, landing or sectors; an approved ground simulator, or flight training program; and pertinent checks, typically within a specific period of days or months.

Recency:  Used interchangeably with currency by the FAA and TCCA.

Initial Training:  Training required for flight crew members who have not qualified on a particular aeroplane type.

Differences training:  Training required for flight crew members who have qualified on a particular aeroplane type, when the regulator finds differences training is necessary before a flight crew member serves on a particular variant of that aeroplane.

Upgrade Training:  For the purpose of this Policy Letter upgrade training is the training required for flight crew members who have qualified and served as Second-in-Command, on a particular aeroplane type, before they serve as Pilot-in-command, on that aeroplane.

Recurrent Training:  For the purpose of this Policy Letter recurrent training is the periodic training required to ensure that flight crew members are adequately trained with respect to the aeroplane type or types (including differences training, if applicable).

Flight Standardization Board (FSB):  The FAA board responsible for specification of training, checking, currency and type rating requirements necessary for operating a United States (U.S.) civil registered transport category aeroplane.

Operational Evaluation Board (OEB):  Typically composed of regulatory personnel from the FAA's FSB, a JAA's JOEB operations sub-group, and from a TCCA OE Team. The OEB is responsible for establishing the flight crew members type rating, and assessing training, checking and currency issues associated with the introduction of a new aeroplane type or a variant of an existing type.

Operational Evaluation Board Report:  A report produced by a board composed of regulatory personnel from one or more competent Civil Aviation Authority, responsible for establishing the flight crew members type rating, and assessing training, checking and currency issues associated with the introduction of a new aeroplane type or variant of an existing type.

Master Difference Requirements (MDRs):  MDRs are those requirements applicable to crew qualification which pertain to differences between variants of the same type, common type, or different type. MDR's are specified by the OEB, FSB, or JOEB in terms of difference levels (i.e. A, B, C, D, E) respecting training, checking and currency. MDR's apply between particular pairs of variants or variant group, and are shown in a MDR table.

Operator Difference Requirements (ODRs):  ODRs are a formal and detailed description of differences between variants flown by a particular air operator, with a corresponding list of CARs compliance methods pertinent to training, checking and currency.

Mixed Fleet Flying Program:  A program permitting the operation of a base aeroplane and one or more variant of the same, common or different type by one or more flight crew member, between training or checking events in accordance with an approved process based on the recommendations of an OE report that is acceptable to the Minister.

Alternate recurrent training plan:  Plan that identifies an alternate means to ensure that flight crew members are adequately trained and currently proficient with respect to the base aeroplane and each applicable variant(s) when operating under a Mixed Fleet Flying and/or Transition Program.

Alternate recurrent checking plan:  Plan that identifies an alternate means to ensure that flight crew members are adequately checked and currently proficient with respect to the base aeroplane and each applicable variant(s) when operating under a Mixed Fleet Flying and/or Transition Program.

Alternate recurrent line check plan:  Plan that identifies an alternate means to ensure that flight crew members have successfully completed a line check and are currently proficient with respect to the base aeroplane and each applicable variant(s) when operating under a Mixed Fleet Flying and/or Transition Program.

Alternate consolidation period plan:  Plan that identifies an alternate means to ensure that flight crew members complete a consolidation period with respect to the base aeroplane and each applicable variant(s) when operating under a Mixed Fleet Flying and/or Transition Program after successfully completing a Pilot Proficiency Check.

Alternate currency plan:  Plan that identifies an alternate means to ensure that a flight crew member meets the 90 day take-off, landing and sector currency requirements with respect to the base aeroplane and each applicable variant(s) when operating under a MFF program.

Background

Part IV and Part VII of the CARs require that a pilot operating a large aeroplane hold a type rating and be qualified by maintaining the training, checking and currency requirements for the aeroplane type to be flown.

Air operators are introducing additional aeroplane types into their fleet and are seeking training, checking or currency credits for their flight crew members from current pilot qualifications of a "base" aeroplane type to one or more variant of the same, common or different type as an alternate means of compliance to meet flight crew member qualifications as required by the CARs. However, the current regulatory structure does not allow the use of the recommendations of an OEB, FSB, or JOEB report as a means of crediting training, checking and currency of one aeroplane type to meet the regulatory requirements of one or more variants of the same, common or different type.

The requirement to conduct an OE (Policy Letter No. 136) was introduced, because establishing a flight crew member type rating, and determining training, checking and currency requirements are not part of the aeroplane certification phase when introducing a new aeroplane type in Canada.

For many years, the FAA has had their own FSB, which not only issues new reports but also periodically updates earlier drafted FSB reports to meet emerging regulatory requirements or technical evolution. The process to conduct a FSB and use a FSB report is described in Advisory Circular (AC) 120-53 found at:

http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/
C9574229A4AAB7E9862569EA00695F04?OpenDocument
.

This AC establishes type rating criteria and crew qualification requirements.

The JAA has recently formed JOEBs to conduct similar activities in partnership with TCCA and the FAA. They have recently started allowing the use of JOEB reports by describing in the JAA JOEB Handbook Part I, the joint TCCA, FAA and JAA methodology and test process for establishing type rating and crew qualification in accordance with Joint Aviation Requirements-Flight Crew Licensing 1 (JAR-FCL 1 and Joint Aviation Requirements-Operations 1 (JAR-OPS 1) found at:

http://www.jaa.nl/publications/jars/607069.pdf.

TCCA, FAA and the JAA generally form a combined OE Team for each transport category aeroplane to be operated in Canada, the U.S. or a JAA member state to avoid duplication of the work involved in an OE. The OE Team is responsible for establishing the flight crew member type rating and the training, checking and currency requirements for each aeroplane type they evaluate, and document their recommendations in a report.

TCCA is in the process of developing amendments to the Aeroplane Common Qualification and Training Manual (TP 12993). Once published, it will become the reference tool for conducting an OEB that establishes flight crew members type rating and training, checking and currency requirements, including recommendations concerning credits for Transition Programs and MFF. The findings and recommendations will be published in a TCCA OEB report.

Policy

Principal Operations Inspectors (POI) are to ensure that air operators wanting to obtain flight crew member training, checking or currency credits to operate an additional aeroplane type from a currently or previously operated variant with the same pilots, are aware that they need to submit an exemption request form (Appendix "C" of the Civil Aviation Directive #1).

Two separate national exemptions have been issued to identify the conditions under which an air operator and a person may be allowed to take advantage of the relief they provide. The need to issue two exemptions has emerged from the requirement that an air operator and a person may only want to benefit from the training and checking credits allowed to provided training and checking from a base aeroplane to one or more variants of the same common or different type under an approved Transition Programs and never wish to operate them under a MFF program between training and checking events. Thus, a second exemption allows for certain credits as an acceptable alternate means of compliance to maintain currency requirements for the type(s) of aeroplane and one or more of its variants to be operated between training and checking events in an approved MFF program. The conditions of both of these exemptions are based on the recommendations of an approved OEB, FSB, or JOEB report.

The OE report that will be used is subject to the approval of the POI. Where two or more OE reports are available for a base aeroplane and the applicable variant(s) of the same type, common type or different type, the TC OEB report should be used. Where a TC OEB report is not available or where TC was not part of the OE, the JOEB or FSB report should be used. Where none of the above is available the OE report of the country that has the greatest regulatory commonality with Canada should be used. In case of uncertainty of what OE is to be used and approved, POIs should contact the Chief of Certification and Operational Standards (AARXB).

POIs are to ensure that the air operator and persons seeking pilot qualification credits demonstrate in its exemption request that there is suitable alternate method of compliance to meet the flight crew member qualifications required by the applicable subsection, paragraph and subparagraph of Section 705.106 and 705.113 of the CARs for each aeroplane type to be flown, based on the recommendations of the OEB, FSB or JOEB report. The air operator must submit a transition or differences training program, and an alternate checking and currency plan based on an OEB, FSB, or JOEB report recommendations in order to qualify flight crew members on an additional type within a Transition program or to operate the additional type within MFF program.

POIs will refer to the MDR tables when reviewing ODR tables that an air operator will submit as part of a proposed transition or differences training, checking and if applicable currency plans.

OEB, JOEB and FSB recommendations in terms of the alternate method of compliance to maintain validity period effective for training, checking and currency under a Transition or MFF program must be respected. Otherwise, the air operator and the person will be required to revert to regulatory requirement for each individual aeroplane applicable type or variant. For example, if the 90 day take-off, landing and sector currency recommendations of an OEB, JOEB or FSB for a particular variant pair are not complied with, on the 91st day the air operator will only be credited for training and checking credits and will be required to comply with regulatory requirements to regain currency for the type or variant for which the flight crew member has not maintained currency.

Once an air operator's plan is approved, the applicable exemption(s) from the applicable subsection, paragraph and subparagraph of Sections 705.106 and 705.113 of the CARs may be issued provided that the method of compliance is described in the company operations manual.

FSB reports can be found at: http://www.faa.gov/aircraft/draft_docs/fsb/ and OEB/JOEB reports at:  http://www.jaa.nl/operations/secured/joeb/joeb_index.html.

TC is in the process of creating a similar site. Until this site is available, contact the Chief of Certification and Operational Standards at (613) 993-6975 for TCCA OEB report information.

It is important to note that these reports have been drafted and approved by OEBs composed of Civil Aviation Authorities recognized by TC.

Flight crew members are only eligible for the conditions of this Policy Letter provided they meet the conditions of Subsection 705.113 (6) of the CARs.

Future Disposition

This Policy Letter will remain in effect until further notice.

Reference Number

This Policy Letter is designated AARX No. 173.

Michel Gaudreau
Director
Commercial & Business Aviation