Proposed Advisory Circular No. 120-53A, Crew Qualification and Pilot Type Rating Requirements for Transport Category Aircraft Operated Under 14 CFR Part 121, 49588-49620 [07-4116]
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Federal Register / Vol. 72, No. 166 / Tuesday, August 28, 2007 / Notices
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
[Docket Number FAA–2007–28498]
Proposed Advisory Circular No. 120–
53A, Crew Qualification and Pilot Type
Rating Requirements for Transport
Category Aircraft Operated Under 14
CFR Part 121
Federal Aviation
Administration, DOT.
ACTION: Notice of availability of a
proposed advisory circular and request
for comments.
rwilkins on PROD1PC63 with NOTICES3
AGENCY:
SUMMARY: This notice announces the
availability of and requests comments
on a proposed revision to Advisory
Circular (AC) No. 120–53, Crew
Qualification and Pilot Type Rating
Requirements for Transport Category
Aircraft Operated under 14 CFR part
121. That AC provides the Federal
Aviation Administration (FAA)
guidance for the evaluation and
approval of flight crew qualification
programs and the issuance of pilot type
ratings for flight crews operating under
14 CFR part 121. The proposed AC
streamlines the process described in AC
120–53 for determining the level of
differences between aircraft and the
credits the FAA assigns between those
aircraft for the purposes of training,
checking, and recency of experience
requirements. The applicability of the
proposed AC would be limited to
operations conducted under 14 CFR part
121.
DATES: Comments must be received on
or before October 29, 2007.
ADDRESSES: Send all comments on the
proposed AC to Docket Number FAA–
2007–28498, using any of the following
methods:
• DOT Docket Web site: Go to
https://dms.dot.gov and follow the
instructions for sending your comments
electronically.
• Government-wide rulemaking Web
site: Go to https://www.regulations.gov
and follow the instructions for sending
your comments electronically.
• Mail: Send comments to the Docket
Management Facility; U.S. Department
of Transportation, 1200 New Jersey
Avenue, SE., West Building Ground
Floor, Room W12–140, Washington, DC
20590.
• Fax: Fax comments to the Docket
Management Facility at 202–493–2251.
• Hand Delivery: Bring comments to
the Docket Management Facility in
Room W12–140 of the West Building
Ground Floor at 1200 New Jersey
Avenue, SE., Washington, DC, between
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9 a.m. and 5 p.m., Monday through
Friday, except Federal holidays.
FOR FURTHER INFORMATION CONTACT: Greg
Kirkland, Air Transportation Division
(AFS–220), Federal Aviation
Administration, 800 Independence
Avenue, SW., Washington, DC 20591;
telephone: (202) 267–8166, e-mail
Greg.Kirkland@faa.gov.
SUPPLEMENTARY INFORMATION:
Authority: 49 U.S.C. 106(g), 40113, 44701,
44702, 44703.
Comments Invited
The proposed AC is published at the
end of this notice. You may also receive
an electronic copy of the proposed AC
by accessing the FAA’s web page at
https://www.faa.gov/
regulationslpolicies/rulemaking/
recentlylpublished. Interested parties
are invited to submit comments on the
proposed AC to Docket No. FAA–2007–
28498. All communications received on
or before the closing date for comments
will be considered by the FAA before
issuing the final AC.
Advisory Circular (AC) NO. 120–53,
‘‘Crew Qualification and Pilot Type
Rating Requirements For Transport
Category Aircraft Operated under 14
CFR part 121.’’
On May 13, 1991, the FAA issued AC
120–53 to provide guidance on the
process the FAA uses when determining
the level of flight crew training required
to operate an aircraft under 14 CFR part
121. The regulations establish
requirements for training, checking, and
recency of experience for flight crews
operating an aircraft under part 121.
Further, the AC provides guidance for
determining the level of differences
between comparative aircraft when a
pair of aircraft have similar handling or
flight characteristics. An applicant may
submit documentation requesting the
FAA consider the commonality in that
pair of aircraft be sufficient to allow
credits for that commonality, which
may then reduce the amount of
duplicative training and checking
requirements and may also reduce, for
some aircraft, the recency of experience
required by 14 CFR 121.439 (a). After
completion of the comparative process,
if the FAA is convinced that the two
aircraft types share sufficient common
characteristics, then the FAA authorizes
qualified flight crews to receive training,
checking, and in some cases, recency of
experience credits for that commonality.
Advisory Circular 120–53
standardizes the application process for
applicants and explains the training and
checking credits available when the
system differences between related
aircraft models are from Level A
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through D. For example, a difference
that amounts to no more than a
knowledge-based difference that can be
addressed in pilot training by using a
computer-based course of instruction
(e.g., the B–757–200 and the B–767–200
hydraulic systems), would be a Level B
difference. On the other hand, a
difference that involves full pilot task
training (e.g., visual display and switch
position requirements between the B–
767–200 and the B–767–400) would be
a Level D difference necessitating pilot
training in a full task training device.
The AC also explains the process for
allowing full or partial credit for
recency of experience that may be
permitted when aircraft handling
qualities are similar. For example,
handling qualities for the Airbus A–320,
A–330, and A–340 aircraft were found
to be similar, therefore credit for
recency of experience was allowed.
If an additional series of related
aircraft models having similar handling
qualities and commonality of systems is
type certificated, the FAA uses the
guidance in AC 120–53 when deciding
to allow credit for training, checking,
and recency of experience. When
difference levels between the aircraft
models do not exceed Level D, credit is
usually allowed. For example,
evaluation of the differences in the
flight deck configuration (e.g., visual
displays and switch positions) of the B–
767–400 determined that Level D
differences existed between the B–767–
400 and the B–767–200 and B–767–300
series. Therefore, the FAA allows credit
for training and checking for Level A
through D differences between the B–
767–200/300 and the B–767–400.
These credits have been provided also
within families of aircraft (same make
but different models sharing
commonality) with similar handling
qualities and no greater than Level D
system differences. Examples of
programs that have taken advantage of
these credits are: ‘‘Common Pilot Type
Rating’’ used by Boeing and ‘‘Cross
Crew Qualification’’ (CCQ) used by
Airbus.
Proposed Revisions to AC No. 120–53A
In view of the success of the common
pilot type rating and CCQ programs
under AC 120–53, proposed AC 120–
53A describes the same process as AC
120–53 for evaluating the differences
between comparative aircraft and
determining the training, checking, and
recency of experience requirements
based on a commonality determination.
Proposed AC 120–53A restates certain
processes to make them more easily
understood and applied by the FAA and
industry in view of innovations and
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advancements in technology and aircraft
design that were not envisioned when
AC 120–53 was written.
This proposed AC:
• Updates the guidance to reflect the
increasing commonality evolving in
contemporary transport category aircraft
design.
• Streamlines the process, with
clearly defined tests, that permit an
applicant to apply for, and the FAA to
allow credit for demonstrating sufficient
commonality between aircraft. The
process is updated by incorporating
elements of the T2 and T4 tests into the
new T6 test.
• Shifts the emphasis from
documenting the commonalities to
documenting the differences between
aircraft types.
• Makes definitional changes.
‘‘Common type rating’’ is replaced by
‘‘Common pilot type rating.’’ The term
‘‘variant’’ has been eliminated and its
meaning has been consolidated into one
term, ‘‘related aircraft.’’ It also separates
the terms ‘‘Currency’’ and ‘‘Recent
experience.’’
• Introduces the term ‘‘Common
Takeoff and Landing Credit’’ applicable
to receiving credit for recency of
experience.
Updates the guidance to reflect the
increasing commonality evolving in
contemporary transport category
aircraft design.
Aircraft manufacturers are now
designing more aircraft that share
similar handling and flight
characteristics. The use of common
flight deck designs has also become
prevalent. These commonalities
improve the safety of aircraft operations
and provide an opportunity in the
proposed AC for the FAA to recognize
this improvement in safety by reducing
the need for some duplicative training.
Streamlines the process, with clearly
defined tests, that permit an applicant
to apply for, and the FAA to allow credit
for demonstrating sufficient
commonality between aircraft.
This proposed AC provides a
systematic means with clearly defined
tests that permit an applicant to apply
for, and the FAA to allow credit for
successfully demonstrating
commonality between aircraft. For
example, the T6 test criteria are clearly
defined to give applicants more
standardized, specific test criteria than
the current T2 and T4 tests. The T6 test
requires the applicant to show a
commonality within a specific weight
range, center of gravity range and
maximum demonstrated crosswind for
takeoff and landing.
Shifts the emphasis from
documenting the commonalities to
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documenting the differences between
aircraft types.
The proposed AC shifts the emphasis
from documenting the commonalities to
documenting the differences between
aircraft types. The applicant would
continue to show commonalities and
the similarities in handling and flight
characteristics by demonstrating the
absence of differences. Where
differences do exist, those differences
would be addressed by the appropriate
training, checking, and recency of
experience requirements. In the
proposed AC the FAA would continue
to allow credit for aircraft shown to
have commonality as in AC 120–53.
Makes definitional changes.
‘‘Common type rating’’ is replaced by
‘‘Common pilot type rating’’ to show a
clearer difference between a pilot type
rating and a type certificated aircraft.
The terms ‘‘variant’’ and ‘‘related
aircraft’’ were used interchangeably in
AC 120–53 causing some confusion. The
term ‘‘variant’’ has been eliminated and
its meaning has been consolidated into
one term, ‘‘related aircraft.’’ For
example, related aircraft would be two
or more aircraft of the same make
(Airbus), but not necessarily under the
same type certificate (A–320, A–330 and
A–340).
The AC 120–53 definitions of
‘‘currency’’ and ‘‘recent experience’’
were considered synonymous and used
interchangeably. This interchangeable
use ofterms has led to confusion. The
proposed revision separates the terms to
eliminate any further confusion.
Introduces the defined term Common
Takeoff and Landing Credit applicable
to receiving credit for recency of
experience.
A Common Takeoff and Landing
Credit (CTLC) allows recency of
experience credit between related
aircraft of the same make with different
type certificates that can be
demonstrated to have similar handling
and flying characteristics. This credit is
applied toward meeting the
requirements of 14 CFR 121.439.
Conclusion
The concept of commonality and the
use of credits can reduce unnecessary
training costs while providing an
acceptable method of compliance with
the existing regulations. Only the FAA
can make a determination of
commonality; and while an applicant
may ask the FAA for a finding of
commonality, the FAA will only make
such a finding after the FAA is satisfied
that sufficient commonality exists to
permit crediting.
The history of safe operation of the B–
757 and B–767 with a common pilot
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type rating, and the successful use of
similar programs (CCQ) with other
aircraft models by European
manufacturers demonstrates that the
FAA can continue to safely allow credit
for training, checking, and recency of
experience between aircraft that have
demonstrated commonality. The entire
proposed AC is published with this
Notice for the convenience of the reader
as Attachment 1.
Issued in Washington, DC, on August 14,
2007.
James J. Ballough,
Director, Flight Standards Service.
Attachment 1—Advisory Circular (AC)
No. 120–53, Crew Qualification and
Pilot Type Rating Requirements for
Transport Category Aircraft Operated
Under 14 CFR Part 121
Advisory Circular
Subject: Crew Qualification and Pilot
Type Rating Requirements for Transport
Category Aircraft Operated Under Part
121.
Date: MM/DD/YY.
Initiated by: AFS–200.
[AC No: 120–53A]
This advisory circular (AC) provides
an acceptable means, but not the only
means, of compliance with the Code of
Federal Aviation Regulations (CFRs)
regarding qualification and type rating
of flight crewmembers operating under
Part 121 of the CFRs. Included are
criteria for the determination and
approval of training, checking, and
currency necessary for the operation of
aircraft. This AC also describes the
process by which the Federal Aviation
Administration (FAA) determines the
qualification of the pilot-in-command
(PIC) or second-in-command (SIC) of
new or modified aircraft. Details of the
systems, processes, and tests necessary
to apply this AC are explained in the
appendices. Provisions of this AC are
intended to enhance safety by:
• Providing a common method of
assessing applicant programs.
• Directly relating pilot training and
qualification requirements to fleet
characteristics, operating concepts,
and pilot assignments.
• Permitting better planning and
management of fleets, pilot
assignments, and training resources
by outlining what FAA requirements
apply, what training resources or
devices are needed, and what
alternatives are possible.
• Permitting timely and consistent
decisions about fleet acquisition,
integration, modification, or phaseout
associated with pilot qualification or
pilot assignments.
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• Permitting manufacturers to design
aircraft that take advantage of new
technology or their similarity with
existing related aircraft, as
appropriate to a particular operator‘s
fleet.
• Encouraging cockpit standardization
by crediting commonality and
identifying necessary constraints
when differences exist.
• Providing a framework for application
of suitable credits or constraints to
better address new technology and
future safety enhancements.
1. Focus. This AC addresses aircraft
manufacturers or modifiers who design,
test, and certificate aircraft as well as
approved 14 CFR part 142 training
centers. In addition, it applies to
operators whose pilots operate several
related aircraft of the same manufacturer
in a mixed fleet and operators seeking
credit for prior pilot experience with
related aircraft of the same
manufacturer.
2. Cancellation. AC 120–53, Crew
Qualification and Pilot Type Rating
Requirements for Transport Category
Aircraft Operated Under CFR Part 121,
Dated May 13, 1991, Is Canceled.
3. Discussion.
a. A System for Pilot Qualification.
The FAA specifies qualification criteria
(minimum training, checking, and
currency) for particular aircraft through
Flight Standardization Board (FSB)
evaluations and findings. FSB findings
are described in reports for specific
aircraft. The reports provide guidance to
certificate-holding district offices
(CHDO) for use by principal operations
inspectors (POI) and other inspectors.
FSB report provisions serve as a basis
for the FAA to approve operators’
programs and for pilot certification.
b. Changing Needs. Necessary support
for the FSB process is provided by the
industry. In the past, procedures varied
by manufacturer, individual project,
operator, and other factors including:
(1) Introduction of new and related
aircraft and increases in the significance
of modifications to existing aircraft,
particularly with regard to engines or
avionics.
(2) Integration of related fleets of
aircraft following airline acquisitions or
mergers.
(3) Increased dependence on leased
aircraft, many of which are configured
differently than an operator’s basic fleet.
(4) A wider variety of equipment
options available in new or retrofit
aircraft.
(5) Introduction of new technology in
cockpit enhancements.
4. Summary of Revisions. This AC
describes necessary revisions and
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enhancements to the FSB process to
address uniform, systematic, timely, and
comprehensive application of pertinent
14 CFR parts in a changing and
increasingly complex operational
environment. This AC revision deletes
master common requirements due to a
lack of practical application. This AC
recognizes the concept of reduced
differences between related aircraft and
defines the training, checking, currency,
and recency of experience requirements.
a. This AC revision clarifies and
introduces new terms and concepts.
These include:
(1) Clarification of the terms ‘‘aircraft
type certificate’’ and ‘‘related aircraft’’.
(2) The difference between currency
and recency of experience is defined.
(3) A definition of ‘‘common pilot
type rating’’ now including levels A
through D for any aircraft of the same
make but of different aircraft type
certificates (TC).
(4) Modified checking requirements to
embrace the concept of checking only at
the difference levels between related
aircraft.
(5) A new term, ‘‘common takeoff and
landing credit’’ (CTLC).
(6) An introduction of the T6 test to
provide for CTLC (recency of
experience) in mixed fleet flying
between separate type-certificated
aircraft with common takeoff and
landing characteristics. The intent of the
T6 test is to provide a comparison of
aircraft that have not previously been
evaluated for CTLC using the T2 test.
(7) A means to identify and evaluate
new technologies that may not be
associated with an aircraft evaluation.
(8) A distinction between supervised
line flying (SLF) and operating
experience (OE).
b. Additional concepts are introduced
to uniformly apply the 14 CFR parts
applicable to pilot qualification and the
differences. The AC’s main concepts are
summarized as follows.
(1) Master Difference Requirement
(MDR). Master requirements are
expressed in the form of MDRs. MDRs
are requirements applicable to pilot
qualification that pertain to differences
between related aircraft. MDRs are
specified by the FSB in terms of
difference levels.
(2) Difference Levels. Difference levels
are formally designated levels of
training methods or devices, checking
methods, or currency methods that
satisfy difference requirements between
related aircraft. Difference levels specify
FAA requirements proportionate to and
corresponding with increasing
differences between related aircraft. A
range of five difference levels in order
of increasing requirements, identified as
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A through E, are each specified for
training, checking, and currency.
(3) Operator Difference Requirement
(ODR). Operators show compliance with
the FAA MDRs through an operator’s
specific ODR, which lists each
operator‘s fleet differences and
compliance methods. ODRs specify
requirements uniquely applicable to a
particular fleet and mixed flying
situation and are based on the MDRs.
ODRs are those operator-specific
requirements necessary to address
differences between a base aircraft and
one or more related aircraft, when
operating in mixed fleet flying or
seeking credit in transition programs.
ODRs include both a description of
differences and a corresponding list of
minimum training, checking, and
currency compliance methods that
address pertinent FSB requirements.
Note: These and other concepts are more
fully described in the appendices.
5. Setting FAA Requirements. The
FSB process is made up of proposal
development, testing, draft requirement
formulation, FSB final determinations
and FAA approval.
a. Applicants’ Proposals. Aircraft
manufacturers or modifiers usually
initiate proposals for formulation or
amendment of FSB requirements. This
is done in conjunction with application
for aircraft type certification or
supplemental type certification of an
aircraft or system. The FAA, operators,
and, in certain instances, other
organizations or individuals, may
initiate proposals or amendments.
b. Standardized Tests. A main
element of the requirements formulation
process is the use of standardized
testing to determine pilot qualification
requirements. One or more of six tests
are applied depending on the proposal’s
degree of differences between related
aircraft, difference levels sought, and
the outcome of any previous tests. Only
the necessary tests are used. Tests may
be waived or difference levels may be
assigned based on operational
experience.
c. FAA Formulation and
Implementation of Requirements.
Following testing and formulation of
draft requirements, FSB requirement
determinations are then made
specifying MDRs and any necessary
supporting information. Supporting
information may pertain to operator
certification, airmen certification,
approval of devices and simulators, and
other items necessary for proper
application of MDRs. FSB reports will
be used in the evaluation, certification,
and approval of operators’ programs.
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d. Revision of Requirements. FSB
reports are periodically updated when
new or modified aircraft are introduced,
when requested by an applicant based
on OE, or when the FAA determines it
is necessary for safety reasons.
e. Pilot Type Ratings. A new pilot
type rating is typically assigned when
level E training differences are
determined between the candidate
aircraft and the base aircraft. The pilot
type rating determination and any
training, checking, and currency
specifications established under the
testing process of this AC are
determined by evaluating the handling
qualities and core pilot skills related to
the candidate aircraft. Systems such as
heads-up display (HUD), Enhanced
Vision Systems (EVS), or Synthetic
Visions Systems (SVS) may require
Level E training without requiring a new
pilot type rating. The FSB, with the
concurrence of the Air Transportation
Division, AFS–200, will make this
determination.
f. Common Pilot Type Rating. A
common pilot type rating is assigned
when no greater than level D training
differences are determined between
aircraft of the same type with different
aircraft TCs.
g. Same Pilot Type Rating. A same
pilot type rating is assigned when no
greater than level D training differences
are determined between aircraft with
the same aircraft TCs (series).
6. Operator Compliance with FAA
Requirements.
a. Obtaining FSB Information.
Operators are advised of pertinent FSB
information through FAA CHDOs and
POIs. Operators may also obtain FSB
information from aircraft manufacturers
or modifiers, other operators, or other
aviation organizations that maintain
awareness of FAA policies, and the Web
site https://www.opspecs.com.
b. Certificated Operator Compliance
with Mixed Fleet Flying. When aircraft
are flown in mixed fleets, certificated
operators will comply with MDRs and
other FSB difference provisions.
Certificated operators accomplish this
by identifying a base aircraft, describing
differences that exist between their base
aircraft and the candidate aircraft, and
by specifying particular means of
compliance to satisfy MDRs. Sample
FSB ODRs provide guidance for the
approval of an operator’s mixed fleet
flying program and specify necessary
constraints or permissible credits. The
description of specific differences and
compliance methods are identified in
the operator’s ODRs. Constraints or
credits may relate to knowledge, skills,
devices, simulators, maneuvers, checks,
currency, or any other factors necessary
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for safe operations. Constraints or
credits may be applied generally or only
to specific aircraft or pilot positions.
Once approved, the operator’s program
must be conducted in accordance with
(IAW) these approved ODRs. ODR
proposals are provided to the FAA
CHDO in a standard tabular format and
are approved by POIs only if they meet
MDRs and other pertinent FSB
requirements. The operator must apply
to amend the ODRs when changes occur
in the base aircraft, comparison aircraft,
and/or training devices that affect the
approval basis of the ODRs.
c. Credit between Programs. In
addition to mixed fleet flying, ODRs
may be used to permit credit between
related aircraft in differences or
transition training and checking
programs, consistent with FSB
provisions.
7. FAA Approval of Operator
Programs.
a. POI Approval. FAA POIs approve
operator programs when those programs
comply with FSB provisions. If less
restrictive programs are proposed, POIs
advise the applicant that:
(1) A request for change of the MDRs
must be initiated;
(2) The differences between related
aircraft must be reduced or eliminated;
or
(3) An alternate approval must be
sought.
Note: An example of such a request is an
exemption to the applicable requirement of
the training section of the operational rule
under which the operation is conducted.
b. Limitations of POI Authority. When
applicable, POIs may approve programs
within provisions of the FSB report and this
AC. AC provisions apply because other
general constraints are identified such as a
limitation on the number of different related
aircraft that can be used in mixed fleet flying.
POIs shall not approve programs outside the
bounds of FSB or AC provisions without the
authorization of AFS–200. Deviation from
FSB or AC provisions will be approved by
AFS–200, only when an equivalent level of
safety can be demonstrated.
8. Application of FSB Requirements
to Airmen Certification. The evaluation
items that FSB reports specify include
the following:
• Knowledge;
• Skills;
• Abilities;
• Maneuvers;
• Performance criteria; and
• Other relevant items for proficiency
checking or other checks/tests may be
identified. This is appropriate to
address any aircraft-specific factors
affecting the safe operation of that
aircraft operated under 14 CFR.
9. Training Device and Simulator
Approvals.
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a. Standard Devices or Simulators.
Standardized training methods, devices,
or simulators are associated with each of
the training difference levels. Devices or
simulators are approved for particular
operators by their POIs, consistent with
National Simulator Program (NSP)
qualification and FSB master
requirements.
b. Special Criteria. In some instances,
standard device or simulator criteria
may not be appropriate for new
technology. The FSB may specify
additional criteria in FSB reports in
these instances.
10. Review and Approval. This is a
process for review of FSB evaluations
and approval of FSB reports.
11. Appeal of FAA Decisions. The
Director, Flight Standards Service, AFS–
1, assigns responsibility to resolve
appeals of the FSB findings.
James Ballough,
Director, Flight Standards Service.
APPENDIX 1.—DEFINITIONS AND
REFERENCES
Table of Contents
1. Definitions
2. References (current editions)
Appendix 1.—Definitions and References
1. Definitions.
Note: Definitions provided in Appendix 1
apply exclusively to this advisory circular
(AC).
Aircraft Evaluation Group (AEG). FAA
organization that sets training, checking,
currency, pilot type rating, Master Minimum
Equipment List (MMEL), and maintenance
standards Maintenance Review Board (MRB)
for assigned certificated aircraft types. AEGs
also address operational aspects of aircraft
type certification and resolution of service
difficulties.
Applicant. For the purposes of this AC, an
applicant may be a manufacturer, modifier,
or operator.
Base Aircraft. An aircraft designated by the
applicant used as a reference to compare
differences with another aircraft.
Candidate Aircraft. The aircraft that will be
subjected to the FSB evaluation process
outlined in this AC for comparison purposes.
Common Pilot Type Rating. A pilot license
endorsement between separate typecertificated aircraft for the purposes of pilot
type rating that passes the testing criteria of
the T1 (equivalence) or the T2 (handling
characteristics) and T3 (core pilot skills with
no greater than level D differences). A
common pilot type rating endorsement is
issued after a pilot has received differences
training and checking, where required, on the
type-certificated aircraft for which there is a
common pilot type rating designation. The
pilot who is receiving the additional
endorsement must be current and qualified
in the base aircraft; since, the check is not a
‘‘full’’ proficiency check as defined by Title
14 of the Code of Federal Regulations (14
CFR), but an abbreviated differences check
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on the differences from the base to the
candidate aircraft. The differences check,
unless it includes the requirements for a
recurrent check, cannot reset the ‘‘recurrent
clock’’ (a pilot‘s base month for checking
purposes).
Common Takeoff and Landing Credit
(CTLC). CTLC is a program/process that
allows recency of experience credit between
related aircraft (same make) with different
type certificate data sheets (TCDS) that can
be demonstrated to have the same handling
and flying characteristics during the
following:
• Takeoff and initial climb; and
• Approach and landing, including the
establishment of final landing configuration.
Note: The T6 test is used for aircraft that
were not tested (T2) during the initial aircraft
evaluation for pilot type rating designation.
Configuration. Aircraft physical features,
which are distinguishable by pilots, with
respect to differences in systems, cockpit
geometry, visual cutoff angles, controls,
displays, aircraft geometry, and/or number of
required pilots.
Currency. Currency is the recent
experience necessary for the safe operation of
aircraft, equipment, and systems as
designated by the Flight Standardization
Board (FSB).
Difference Levels. Difference levels are
formally designated levels of training
methods or devices, checking methods, or
currency methods that satisfy differences
requirements between related aircraft. A
range of five difference levels in order of
increasing requirements, identified as A
through E, are specified for training,
checking, and currency purposes.
Differences Training. Training required
before any person may serve as a required
crewmember on an aircraft of a type for
which differences training is included in the
certificate holder‘s approved training
program.
Differences Check. A partial proficiency
check of the qualification of a pilot at the
difference levels between related aircraft. A
differences check can be between series of
the same aircraft type certificate (TC) or
between aircraft of separate aircraft TCs of
the same manufacturer.
Flight Characteristics. Flight characteristics
are handling characteristics or performance
characteristics perceivable by a pilot. Flight
characteristics relate to the natural
aerodynamic response of an aircraft,
particularly as affected by changes in
configuration and/or flight path parameters
(e.g., flight control use, flap extension/
retraction, airspeed change, etc.).
Flight Operations Evaluation Board
(FOEB). The FOEB is responsible for
preparation and revision of MMELs. The
board members are drawn from the FAA.
Flight Standardization Board (FSB). The
FSB is responsible for specification of
minimum training, checking, currency, and
pilot type rating requirements, if necessary,
for U.S. certificated civil aircraft. The board
members are drawn from the FAA (AEG,
Headquarters, Flight Standards field offices
operations personnel).
Handling Characteristics. The manner in
which the aircraft responds with respect to
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rate and magnitude of pilot initiated control
inputs to the primary flight control surfaces
(e.g., ailerons, elevator, rudder, spoilers,
cyclic, collective, etc.).
Line Oriented Simulation (LOS). Use of a
simulator in place of the aircraft to reinforce
the understanding of differences between
related aircraft. LOS should not be confused
with operating experience (OE), which is
required by 14 CFR.
Line Operational Flying (LOF). The LOF
phase of the test is used at the discretion of
the FSB during the T3 test to validate the
proposed training and checking. The LOF
fully assesses particular difference areas,
examines implications of mixed fleet flying,
assesses special circumstances such as
minimum equipment list (MEL) effects, and
evaluates the effects of pilot errors
potentially associated with the differences.
Master Difference Requirements (MDR).
MDRs are those requirements applicable to
pilot qualifications that pertains to
differences between related aircraft. MDRs
are specified by the FSB in terms of the
minimum difference levels. MDRs form the
basis for an operator to develop their operator
differences requirements (ODR).
Mixed Fleet Flying. Mixed fleet flying is the
operation of a base aircraft and one or more
related aircraft for which credit may be taken
for training and/or checking events. The FSB
process defines minimum training and
checking difference levels between related
aircraft.
Operational Characteristics. As used with
respect to aircraft, means those features that
are distinguishable by limitations, flight
characteristics, normal procedures,
nonnormal procedures, alternate or
supplementary procedures, or maneuvers.
Operator Difference Requirements (ODR).
If differences exist within an operator‘s fleet
that affect pilot knowledge, skills, or abilities
pertinent to systems or procedures, ODR
tables provide a uniform means for operators
to comprehensively manage difference
programs and provide a basis for FAA
approval of mixed fleet flying.
Pilot Type Rating. A pilot type rating is a
‘‘one time’’, permanent endorsement on a
pilot certificate indicating that the holder of
the certificate has completed the appropriate
training and testing required for its issuance
as determined by regulation and by the
applicable FSB report. It is recorded by the
FAA on the pilot‘s certificate indicating the
make, model, and series of aircraft, if
applicable. Title 14 CFR requires a pilot type
rating to serve as pilot-in-command (PIC) and
in some cases as second-in-command (SIC) of
U.S. civil large or turbojet aircraft.
Recency of Experience. With respect to
flight experience as required by 14 CFR,
means a pilot’s completion of the required
number of takeoffs and landings as sole
manipulator of the controls within the
preceding 90 days.
Related Aircraft. Related aircraft are any
two or more aircraft of the same make that
have been demonstrated and determined to
have commonality to the extent that credit
between those aircraft may be applied for
training, checking, or currency, as
documented through MDR and approved by
the FSB.
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Same Pilot Type Rating. A pilot type rating
assigned when no greater than a level D
training difference is determined between
aircraft with the same aircraft TCs (series).
Series. Aircraft sharing the same aircraft
type certification with specific variations that
are usually defined by the manufacturer and
usually result in an amended aircraft TC.
Supplementary Procedures. Those
procedures that are identified in the Flight
Crew Operation Manual (FCOM) under the
section ‘‘Supplementary Procedures’’
describing procedures not described under
the ‘‘Normal Procedures’’ or ‘‘Nonnormal
Procedures’’ sections.
Supervised Line Flying (SLF). Supervised
experience associated with the introduction
of equipment or procedures requiring post
qualification skill enhancement during
which a pilot occupies a specific pilot
position and performs particular assigned
duties for that pilot position under the
supervision of a qualified company instructor
or check airman.
Training Footprint. A training footprint is
a summary description of a training program,
usually in short tabular form, showing
training subjects, modules, procedures,
maneuvers or other program elements, which
are planned for completion during each day
or phase of training.
2. References (Current Editions)
• Title 14 CFR parts 1, 61, 91, 135, and
121.
• Order 8400.10, Air Transport Operations
Inspector’s Handbook.
• AC 61–89, Pilot Certificates, Aircraft
Type Ratings.
• AC 120–35, Line Operational
Simulations: Line Oriented Flight Training,
Special Purpose Operational Training, Line
Operational Evaluation.
• AC 120–40, Airplane Simulator
Qualification.
• AC 120–45, Airplane Flight Training
Device Qualification.
• AC 120–51, Crew Resource Management
Training.
• FAA–S–8081–5, Aircraft Type Rating
Practical Test Standards for Airplane.
APPENDIX 2.—PILOT
QUALIFICATION AND PILOT RATING
REQUIREMENTS
Table of Contents
1. Purpose
2. Focus
3. Introduction
a. A Comprehensive System for Pilot
Qualification
b. Master Differences Requirements (MDR)
Set by FAA
c. Specifications of Constraints or Credits
d. Recognition of Unique Operator
Characteristics
e. Basis for Requirements
f. Relation to Other FAA Policies
4. Concepts
a. An Integrated System for Pilot
Qualification
b. MDRs
c. Difference Levels
d. Training Difference Levels
e. Checking Difference Levels
f. Currency Difference Levels
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g. Operating Experience (OE) for Aircraft
h. Supervised Line Flying (SLF)
i. Recency of Experience
j. Operator Difference Requirements (ODR)
5. Formulation of FSB Reports, MDRS, and
Designation of Pilot Type Ratings
a. Requirements Formulation Process
Overview
b. Proposals for MDRs, Example ODRs, and
Special Requirements
c. Difference Level Tests
d. FSB Assessments and Proposal
Formulation
e. Comments Solicited
f. FSB Determinations and Findings
g. FSB Report Preparation Distribution and
FAA Application
h. FSB Report Revision
6. Operator’s Application of FSB Provisions,
Preparations, Use, and Revision of ODRS
a. General
b. Application of MDRs and Preparation
and Use of ODRs
c. Selecting Base Aircraft
d. Identification of Differences and the
Analysis of Effects of Those Differences
e. Identification of Compliance Methods
f. When Proposed ODR Compliance
Methods Do Not Meet MDRs
g. Maximum Number of Related Aircraft
h. Application, Review and Approval
i. Implementation Provisions Transition
Period
j. ODR Revision
7. FAA Review and Approval of Operator
Programs
a. General
b. Operator’s Application of ODRs
c. Base and Other Aircraft Identification
d. Approval of ODRs
e. POI Uncertainty Regarding Program
Compliance
f. Proposals That Do Not Comply With FSB
Provisions
g. FSB Revision of MDRs or Other FSB
Provisions
h. Proving Tests
i. Line-Oriented Flight Training (LOFT),
LOS, or SLF
j. OE
k. Limitations on the Total Number of
Related Aircraft
l. Compliance Checklist for CHDOs
m. Implementation of FSB Provisions
n. Aircraft That Do Not Have an FSB
Report
8. Application of Requirements to Airmen
Certification
a. General
b. Checking Specifications
c. Checks Regarding Complex Systems
9. Training Device and Simulator Approval
a. Training Device and Simulator
Characteristics
b. Aircraft/Simulator/Device Compatibility
c. Simulator and Device Approvals
10. Review and Approval
11. Appeal of FAA Decisions
Illustrations
Figure 1 Master Difference Requirements
(MDR) Table Example
Figure 2 Difference Level Table
Figure 3–1 Design Operator Differences
Requirements Table Example
Figure 3–2 Systems Operator Differences
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Requirements Table Example
Figure 3–3 Maneuver Operator Difference
Requirements Table Example
Figure 4 Master Requirements Formulation
Figure 5 Test Definitions
Figure 6 ‘‘T’’ Tests 1 Thru 5
Figure 7 Standard Method, Devices, and
Simulators
Figure 8 FSB Process
APPENDIX 2.—PILOT QUALIFICATION
AND PILOT RATING REQUIREMENTS
1. Purpose
This appendix provides a comprehensive
description of the system for pilot
qualifications outlined in this advisory
circular (AC). It includes definitions, criteria,
processes, tests, methods, and procedures
necessary for uniform application of the
system.
2. Focus
The appendix applies to and is used by:
a. Aircraft manufacturers or modifiers who
design, test, and certificate Title 14 of the
Code of Federal Regulations (14 CFR) parts
23, 25, 27, and 29 aircraft.
b. Operators who operate under 14 CFR.
c. Operator, manufacturer, or other training
centers having programs approved for use
under 14 CFR.
d. Federal Aviation Administration (FAA)
offices and inspectors administering
programs under 14 CFR.
3. Introduction
a. A Comprehensive System for Pilot
Qualification. This AC and its appendices
provide a systematic means to address
requirements for training, checking, and
currency within applicable 14 CFR parts.
Definitions, criteria, processes, procedures,
tests, and methods are consistent with and
clarify application of current rules in
particular situations for specific aircraft. This
AC provides a comprehensive system for the
FAA and industry to describe, evaluate, and
approve use of particular aircraft and
operator programs. The respective roles of
training, checking, currency and airmen
certification are clarified. This includes
defining the role and criteria for designation
of pilot type ratings for existing, new, or
modified aircraft. The system is particularly
suited to addressing transition, differences
programs, and mixed fleet flying. The system
aids in assuring that pilots attain and
maintain the knowledge, skills, and abilities
needed to operate assigned aircraft safely.
b. Master Differences Requirements (MDRs)
Set by FAA. The FAA’s Flight
Standardization Board (FSB) sets MDRs to
address differences between related aircraft.
c. Specification of Constraints or Credits.
The system permits the specification of
constraints or permissible credits.
Constraints or credits may relate to
knowledge, skills, abilities, devices,
simulators, maneuvers, checks, currency, or
any other such factors necessary for safe
operations. Constraints or credits may apply
generally to aircraft, particular pilot
positions, or other situations or conditions.
d. Recognition of Unique Operator
Characteristics. The system recognizes the
unique characteristics of individual operators
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while achieving uniformity in application of
FAA safety standards. FAA MDRs determine
uniform bounds to tailor individual
operator’s unique requirements to a
particular fleet and situation. Principal
operations inspectors (POI) approve each
operator’s unique requirements within FAA
MDRs. Operator unique requirements
accommodate particular combinations of
related aircraft flown, pilot assignment
policies, training methods and devices, and
other factors that relate to the application of
the FAA MDRs. Accordingly, the system
preserves operator flexibility while
standardizing the FAA’s role in review,
approval, and monitoring of training,
checking, and currency programs within 14
CFR.
e. Basis for Requirements. The
determination of pilot type rating, minimum
differences training, checking and currency
requirements focus on basic operation of
aircraft in the National Airspace System
(NAS) under both instrument flight rules
(IFRs) and visual flight rules (VFR). Included
are all flight phases from preflight to
shutdown under both normal and nonnormal
conditions.
f. Relationship to Other FAA Policies.
Although this AC, and the FSB requirements
in some instances, address particular types of
operations or specific aircraft systems (e.g.,
use of flight guidance control systems for
Category II/III instrument approaches, longrange navigation, etc.), other ACs address
these issues more thoroughly. This AC and
FSB requirements address such issues only to
the extent necessary to assure that pilots are
qualified to operate pertinent systems or
equipment as part of initial or continuing
qualification.
4. Concepts
a. An Integrated System for Pilot
Qualification.
(1) System Elements. An integrated FAA/
applicant system and process established to
determine appropriate requirements, applies
the requirements, and meets those
requirements on a continuing basis, for
uniform pilot qualification.
(2) System Overview. The system uniformly
applies FAA master requirements in a way
that tailors a particular aircraft to any
operator’s unique situation or fleet. The FAA
approves unique operator and fleet
requirements for each operator based on FAA
master requirements. The system develops
FAA master requirements based on objective
criteria and tests, with applicants’ support for
analysis and testing. FSB reports for related
aircraft describe FAA master requirements.
MDRs express FAA master requirements.
Minimum acceptable difference levels
between related aircraft articulate MDRs. An
operator’s training program, checklist,
operations manuals, pilot certification, CTLC
programs, and other such approvals are byproducts of compliance with MDRs.
Operators comply with MDRs using unique
ODRs, tailored to that operator’s programs
and approved by the FAA. ODRs, based on
and in compliance with the MDRs, specify
requirements uniquely applicable to a
particular operator’s mixed fleet flying
situation. An operator’s specific document
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describes ODRs by identifying a base aircraft,
differences between related aircraft, and that
operator’s compliance methods for each
related aircraft. Paragraph 4j describes ODRs.
Paragraph 6 describes ODR preparation and
use. Paragraph 7 describes FAA approval of
ODRs.
b. MDRs.
(1) MDR Applicability. MDRs are those
requirements applicable to pilot qualification
that pertain to differences between related
aircraft. MDRs specify the minimum
acceptable difference levels between related
aircraft that may be approved for operators.
One related aircraft is selected by the
applicant as a reference for comparison
purposes and is considered a base aircraft.
This is typically the first aircraft on which
pilots are qualified, or is the aircraft of which
an operator has the largest number.
Difference levels between the base aircraft
and other related aircraft then specify the
minimum difference requirements to be met
for pilot qualification. Major differences in a
particular fleet are defined between groups of
related aircraft rather than specifying
differences between each possible
configuration and combination of
configurations between related aircraft.
MDRs are specified in terms of training
difference levels described in paragraph 4d
and are shown on an MDR table.
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(2) MDR Content. MDRs specify the
minimum training, checking, and currency
acceptable to the FAA for pilot qualification
regarding differences.
(3) MDR Formulation, Description, and
Revision. MDRs are formulated by the FAA
FSB for each related aircraft. MDRs are
originally specified when an aircraft is first
type certificated. MDRs are formulated using
standardized tests and evaluations in
conjunction with the type certification or
supplemental type certification process.
MDRs are based on an applicant’s (usually an
aircraft manufacturer) proposal, FAA
evaluation of that proposal, OE, and test
results when tests are necessary. FSB
determinations also consider operator
recommendations, safety history, and other
relevant information. MDRs are described in
provisions of an FSB report and may be
revised if necessary. MDRs are revised when
aircraft are developed or modified, tests or
OE shows a need for revision, a revision is
requested by an applicant and evidence
indicates the need for revision, or rules or
FAA policies change. MDRs are revised by a
process similar to that used for initial
formulation of requirements.
(4) MDR Use. MDRs are applied to specific
operators through formally described ODRs
that are developed by and tailored to each
operator. FAA field offices use the MDRs as
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the basis for approval of individual operator’s
differences programs for approval of initial or
transition programs where credit for previous
training or experience with other related
aircraft is sought.
(5) The MDR Table. An example of typical
MDRs for the B–737–200, –300, –400, –500,
–600, –700, –800, and –900 is shown in
Figure 1. MDR table requirements are shown
for each pair of aircraft by notations in each
element of corresponding columns and rows
of the table. Each element of the table
identifies the minimum differences training,
checking, and currency requirements
applicable to mixed fleet flying. The MDR
table identifies a pertinent base aircraft and
particular aircraft for which requirements are
sought. Note the minimum difference levels
that correspond to the pertinent column and
row, and special requirements in footnotes, if
applicable.
(6) Use of Higher or Lower Difference
Levels. Operators must satisfy difference
requirements by using the methods
acceptable for the specified level or a higher
level. Lower level methods may be used in
addition to the required levels but may not
substitute for the required level or be used
exclusively instead of the required level.
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(7) Differences Within a Series. Differences
may exist even within series shown on an
MDR table, such as within the A–318/319/
320/321 series. MDR elements may show
requirements from one series to another
identified in the footnotes. Such
requirements, however, apply only if
pertinent differences exist between those
aircraft.
(8) More Than Two Related Aircraft. When
pilot assignments apply to more than two
related aircraft, such as the A–320, A–330,
and A–340, each pertinent requirement of the
MDR table applies. Applications of multiple
requirements for flying two or more related
aircraft and certain limits to flying large
numbers of related aircraft are described in
paragraph 7k.
(9) Special Requirements.
(10) MDR Footnotes. Footnotes can be used
to credit, constrain, or set alternate levels
when special situations apply. Use of
footnotes permits accommodation of
variations in installed equipment, options,
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pilot knowledge or experience on other
aircraft, training methods or devices, or other
factors that are not addressed by basic levels
between aircraft. For example, a footnote may
allow credit or apply constraints to the use
of a particular flight guidance control system
(FGCS), flight management system (FMS), or
electronic flight instrument system (EFIS),
which is installed on aircraft. Footnotes are
an appropriate means to address
requirements that relate to specific systems
(e.g., flight director and FMS) rather than a
particular aircraft. In such instances, generic
knowledge or experience with the particular
system may be readily transferable between
related aircraft. Footnotes may also be used
to set different requirements for initial
training or checking rather than for recurrent
training or checking. When necessary,
footnotes are fully described in the body of
the FSB report.
(a) Other Limitations. Other limitations
may occasionally be identified within a
difference level (e.g., C*/C*/C). The asterisk
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49595
following the difference level in such
instances identifies a special requirement or
limitation pertaining to a particular training
method or device. Such notes typically relate
to acceptable training device characteristics
when the simulator evaluation and approval
process or standard criteria of this AC are not
available to address a particular situation
appropriately.
(11) MDRs for Aircraft With the Same or
Common Pilot Type Ratings. A single FSB
report and MDR table may apply to aircraft
that are assigned the same pilot type rating
(same aircraft TC). For example, a single
MDR table may cover the A–318/319/320/321
that have a same pilot type rating. A single
FSB report and MDR table may also apply to
aircraft that are assigned a common pilot type
rating. For example, a single MDR table may
cover both the B–767 and B–757 that have a
common pilot type rating. When level E
training is required for an aircraft with the
same aircraft TC and an additional pilot type
rating is assigned, such as the B–747 and B–
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747–400, a single MDR table for all series of
a type-certificated aircraft still applies.
(12) Minimum acceptable difference levels
are assigned based on standard tests
described in Appendix 3.
c. Difference Levels.
(1) General Description. Difference levels
are formally designated levels of training
methods or devices, checking methods, or
means of maintaining currency that satisfy
minimum difference requirements or pilot
type rating requirements. Difference levels
specify FAA requirements proportionate to
and corresponding with increasing
differences between related aircraft. A range
of five difference levels in order of increasing
requirements, identified as A through E, are
each specified for training, checking, and
currency. MDRs are specified in terms of
difference levels. Difference levels are used
to credit knowledge, skills, and abilities
applicable to an aircraft for which a pilot is
already qualified and current, during initial,
transition or upgrade training for other
related aircraft. Operators, who conduct
mixed fleet flying where credit is sought,
should apply difference levels and address
all mixed fleet flying requirements to ensure
compliance with FAA requirements
necessary to assure safe operations.
(2) Basis for Levels. Difference levels apply
when a difference with potential to affect
fight safety exists between related aircraft.
Differences may also affect knowledge, skills,
or abilities required of a pilot. If no
differences exist or if differences exist but do
not affect knowledge, skills, abilities or flight
safety, then difference levels are not assigned
or applicable to pilot qualification. When
difference levels A through E apply, each
difference level is based on a scale of
differences in design features, systems, or
maneuvers. In assessing the effects of
differences, both flight characteristics and
procedures are considered, since flight
characteristics address handling qualities and
performance, while procedures include
normal and abnormal/nonnormal/emergency
items.
(3) Relationship Between Training,
Checking, and Currency Levels. While
particular aircraft are often assigned the same
level (e.g., C/C/C) for training, checking, and
currency, such assignment is not necessary.
Levels may be assigned independently. For
example, an aircraft may be assigned level C
for training, level D for checking, and level
C for currency (e.g., C/D/C).
(4) Designation of a Pilot Type Rating.
Candidate aircraft having the same TC are
assigned the same pilot type rating if training
differences are not greater than level D.
Candidate aircraft having different TCs that
have training differences no greater than
level D may be assigned a common pilot type
rating. A candidate aircraft is assigned a
different pilot type rating when difference
training level E is required. When different
pilot type ratings are assigned because of one
or more candidates requiring level E training,
pilot type ratings may be assigned to related
aircraft consistent with a logical grouping of
the most similarly related aircraft.
d. Training Difference Levels.
(1) Level A Training. Level A difference
training is that differences training between
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related aircraft that can adequately be
addressed through self-instruction. Level A
training represents a knowledge requirement
that, once appropriate information is
provided, understanding and compliance can
be assumed. Level A compliance is achieved
by such methods as issuance of operating
manual page revisions, dissemination of
operating bulletins, or differences handouts
to describe minor differences in aircraft.
Level A training is limited to the following
situations:
(a) A change that introduces a different
version of a system/component for which the
pilot has already shown the ability to
understand and use (e.g., an updated version
of an engine).
(b) A change that results in minor or no
procedural changes and does not adversely
affect safety if the information is not
reviewed or forgotten (e.g., a different
vibration damping engine mount is installed,
expect more vibration in descent; logo lights
are installed, use is optional).
(c) Information that highlights a difference,
which is evident to the pilot, inherently
obvious, and easily accommodated (e.g.,
different location of a communication radio
panel, a different exhaust gas temperature
limit that is placarded, or changes to
nonnormal ‘‘read and do’’ procedures).
(2) Level B Training. Level B difference
training is applicable to aircraft with system
or procedure differences that can adequately
be addressed through aided instruction. At
level B, aided instruction is appropriate to
ensure pilot understanding, emphasize
issues, provide a standardized method of
presenting material, or aid retention of
material following training. Level B aided
instruction can utilize slide/tape
presentations, computer based tutorial
instruction, stand-up lectures or video tapes.
Situations not covered under the provisions
of level A training may require level B (or
higher levels) if certain tests described in
later paragraphs fail.
(3) Level C Training. Level C differences
training can only be accomplished through
use of devices that are capable of systems
training. Level C differences training is
applicable to related aircraft having part task
differences that affect skills or abilities and
knowledge. Training objectives focus on
mastering individual systems, procedures, or
tasks, as opposed to performing highly
integrated flight operations and maneuvers in
‘‘real time.’’ Level C may require selfinstruction or aided instruction, but cannot
be adequately addressed by a knowledge
requirement alone. Training devices are
required to supplement instruction, ensure
attainment or retention of pilot skills and
abilities, and accomplish the more complex
tasks, usually related to operation of
particular aircraft systems. While level C
systems knowledge or skills relate to specific
rather than fully integrated tasks,
performance of steps to accomplish normal,
nonnormal, alternate, recall procedures, or
maneuvers related to particular systems (e.g.,
flight guidance control systems/flight
management systems) may be necessary.
Typically, the minimum acceptable training
media for level C training would be
interactive computer-based training, cockpit
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systems simulators, cockpit procedure
trainers or part task trainers (e.g., FMS or
traffic collision avoidance system (TCAS)).
(4) Level D Training. Level D training can
only be accomplished with devices capable
of performing flight maneuvers and
addressing full task differences of knowledge,
skills, and/or abilities. Devices capable of
flight maneuvers address full task
performance in a dynamic real time
environment. The devices enable integration
of knowledge, skills, and abilities in a
simulated flight environment, involving
combinations of operationally oriented tasks
and realistic task loading for each relevant
phase of flight. Level D training, knowledge,
and skills to complete necessary normal,
nonnormal, alternate, or recall procedures are
fully addressed for each related aircraft.
Level D differences training requires mastery
of interrelated skills that cannot be
adequately addressed by separate acquisition
of a series of knowledge areas or skills that
are interrelated. The differences are not so
significant that a full transition training
course is required. If demonstrating
interrelationships between the systems is
important, use of a series of separate devices
for systems training will not suffice. Training
for level D differences requires a training
device that has accurate, high fidelity
integration of systems and controls, and
realistic instrument indications. Level D
training may also require maneuvers, visual
cues, motion cues, dynamics, control loading
or specific environmental conditions.
Weather phenomenon such as low visibility,
CAT III, or windshear may or may not be
incorporated. Where simplified or generic
characteristics of an aircraft type are used in
devices to satisfy difference level D training,
significant negative training must not occur
as a result of the simplification. Typically,
the minimum acceptable training media for
level D training would be flight training
device level 6.
(5) Level E Training. Level E training is
applicable to candidate aircraft having such
significant full task differences that require a
‘‘high fidelity’’ environment to attain or
maintain knowledge, skills, or abilities.
Training at level E can only be satisfied by
the use of a simulator qualified at level C or
D consistent with FAA criteria. Level E
training, if done in an aircraft, should be
modified for safety reasons where maneuvers
can result in a high degree of risk (i.e., an
engine set at idle thrust to simulate an engine
failure). As with other levels, when level E
training is assigned, suitable credit or
constraints may be applied for knowledge,
skills, and/or abilities related to other
pertinent related aircraft. Credits or
constraints are specified for the subjects,
procedures, or maneuvers shown in FSB
reports and are applied through the ODR
table.
Note: Training differences levels specified
by the FSB represent minimum requirements.
Operators may use a device associated with
a higher difference level to satisfy a training
differences requirement. For example, if level
C differences are assessed due to installation
of a different FMS, operators may train pilots
using the FMS installed in a full flight
simulator (FFS) as a system trainer if a
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dedicated part task FMS training device is
not available.
e. Checking Difference Levels.
(1) Initial and Recurrent Checking.
Difference checking addresses any pertinent
pilot testing or certification that includes
pilot type rating checks, proficiency checks,
Advanced Qualification Program (AQP)
evaluations, and any other checks specified
by FSB reports. Initial and recurrent checking
levels are the same unless otherwise
specified by the FSB. In certain instances, it
may be possible to satisfactorily accomplish
recurrent checking objectives in devices that
do not meet initial checking requirements. In
such instances, the FSB may recommend
certain devices that do not meet initial check
requirements for use to administer recurring
checks. The POI/Training Center Program
Manager, in coordination with the FSB, may
require checking in the initial level device
when doubt exists regarding pilot
competency or program adequacy.
(2) Level A Checking. Level A checking
indicates that no check related to differences
is required at the time of differences training.
A pilot is responsible for knowledge of each
related aircraft flown. Differences items
should be included as an integral part of
subsequent recurring proficiency checks.
(3) Level B Checking. Level B checking
indicates that a ‘‘task’’ or ‘‘systems’’ check is
required following transition and recurring
differences training. Level B checking
typically applies to particular tasks or
systems such as FMS, TCAS, or other
individual systems or related groups of
systems.
(4) Level C Checking. Level C checking
requires a partial proficiency check using a
device suitable for meeting level C (or higher)
differences training requirements following
transition and recurrent differences training.
The partial check is conducted relative to
particular maneuvers or systems designated
by the FSB. Example of a level C check:
Evaluation of a sequence of maneuvers
demonstrating a pilot’s ability to use a FGCS
or FMS. An acceptable scenario would
include each relevant phase of flight that
uses the FGCS or FMS.
(5) Level D Checking. Level D checking
requires a partial proficiency check for one
or more related aircraft following both
transition and recurrent training. The partial
proficiency check covers the particular
maneuvers, systems, or devices designated by
the FSB. Level D checks are performed using
scenarios representing a ‘‘real time’’ flight
environment and devices permitted for level
D differences training. A full proficiency
check is typically conducted on the base
aircraft, and a partial proficiency check on
the related aircraft, covering all pertinent
differences.
(6) Level E Checking. Unless specified,
level E checking requires that a full
proficiency check be conducted in a level C
or D FFS. As with other levels, when level
E checking is assigned, suitable credit or
constraints may be applied for knowledge,
skills, and/or abilities related to other
pertinent related aircraft. Credits or
constraints are specified for the subjects,
procedures, or maneuvers shown in FSB
reports and are applied through the ODR
table.
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Note: Assignment of level E checking
requirements alone does not result in
assignment of a separate pilot type rating.
Only the assignment of level E training
requirements may result in assignment of a
separate pilot type rating.
f. Currency Difference Levels. The term
‘‘currency’’ as used in this AC addresses
recent experience necessary for safe
operation of aircraft as designated by the
FSB. Currency issues not specified by the
FSB are covered by regulation.
(1) Level A Currency. Level A currency is
considered common to each related aircraft.
Thus, assessment or tracking of currency for
separate related aircraft is not necessary or
applicable. Maintenance of currency in any
one related aircraft or a combination of
related aircraft will suffice for any other
related aircraft.
(2) Level B Currency. Level B currency is
‘‘knowledge related’’ currency, typically
achieved through self-review by individual
pilots for a particular aircraft. Self-review is
usually accomplished by review of material
provided by the operator to pilot. Such
currency may be undertaken at an individual
pilot‘s initiative; however, the operator must
identify the material and the frequency or
other situations in which the material should
be reviewed. Self-review may be based on
manual information, bulletins, aircraft
placards, memos, class handouts, videotapes,
or other memory aids that describe the
differences, procedures, maneuvers, or limits
for the pertinent aircraft that pilots are flying.
Examples of acceptable compliance with
level B currency are:
(a) The issuance of a bulletin that directs
pilots to review specific operating manual
information before flying a related aircraft.
Level B currency may be regained by review
of pertinent information to include bulletins,
if that related aircraft has not been flown
within a specified period (e.g., fly that related
aircraft or have completed a review of the
differences in limitations and procedures
within a specified number of days).
(b) Pilot certification on a dispatch release
that they have reviewed pertinent
information for a particular related aircraft to
be flown on that trip. Level B currency
cannot, however, be achieved solely by
review of class notes taken by and at the
initiative of an individual pilot unless the
adequacy of those notes is verified by the
operator.
(3) Level C Currency. Level C currency is
applicable to one or more designated systems
or procedures, and relates to both skill and
knowledge requirements. An example would
be establishment of FMS currency, flight
guidance control system currency, or other
particular currency that is necessary for safe
operation of a related aircraft. Establishment
of level C for a related aircraft with an FMS
would typically require a pilot to fly that
related aircraft within the specified period of
time or re-establish currency. Currency
constraints for level C are established by the
FSB. When level C currency applies,
pertinent level B currency must also be
addressed. Examples of methods acceptable
for addressing level C currency are:
(a) Pilot scheduling practices resulting in a
pilot being scheduled to fly a related aircraft
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with the pertinent system/procedure within
the specified period of time;
(b) Tracking of an individual pilot’s flying
of related aircraft to ensure that the particular
system/procedure has been flown within the
specified period of time;
(c) Use of a higher level method (level D
or E currency); or
(d) Other methods as designated or found
acceptable by the FSB.
(4) Re-establishing Level C Currency. When
currency is lost, currency may be reestablished by completing required items
using a device equal to or higher than that
specified for level C differences training and
checking. Other means to re-establish
currency include flights with an
appropriately qualified check airman/
instructor, completion of proficiency
training, or a proficiency check. In some
instances, a formal refamiliarization period
in the actual aircraft with the applicable
system operating while on the ground may be
acceptable if permitted by the FSB. Such
refamiliarization periods are completed using
an operator-established procedure under the
supervision of a pilot designated by the
operator. In the case of a noncurrent SIC, a
designated pilot-in-command (PIC) may be
authorized to accompany a pilot to reestablish currency.
(5) Level D Currency. Level D currency is
related to designated maneuvers, and
addresses knowledge and skills required for
performing aircraft control tasks in real time,
with integrated use of associated systems and
procedures. Level D currency may also
address certain differences in flight
characteristics including performance of any
required maneuvers and related normal/
abnormal/emergency procedures for a
particular related aircraft. A typical
application of level D currency is to specify
selected maneuvers, such as takeoff,
departure, arrival, approach, or landing,
which are to be performed using a particular
FGCS and instrument display system. Either
a pilot must fly a related aircraft equipped
with the FGCS and particular display system
sufficiently often to retain familiarity and
competence within the specified currency
period, or currency must be re-established.
Currency constraints for level D are
established by the FSB. When level D
currency applies, pertinent level B and level
C currency must also be addressed. Examples
of methods acceptable for addressing level D
currency are:
(a) Tracking of flights by a particular pilot
in a particular related aircraft to assure
experience within the specified currency
period.
(b) Tracking the completion of specific
maneuvers based on logbook entries, Aircraft
Communication Addressing and Reporting
System (ACARS) data, or other reliable
records to assure experience within the
specified currency period.
(c) Scheduling of aircraft or pilots to permit
currency requirements to be met with
verification that each pilot has actually
accomplished the assigned or an equivalent
schedule.
(d) Completion of pilot certification,
proficiency check, proficiency training, AQP
evaluations, or other pertinent events in
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which designated maneuvers are performed
in a device or simulator acceptable for level
D currency.
(e) Use of a higher level method (level E
currency).
(f) Other methods as designated or found
acceptable by the FSB.
(6) Re-establishing Level D Currency. When
currency is lost, currency may be reestablished by completing pertinent
maneuvers using a device equal to or higher
than that specified for level D differences
training and checking. Other means to reestablish currency include flight with an
appropriately qualified check airman during
training or in line operations, completion of
proficiency training, a proficiency check, or
AQP proficiency evaluation.
(7) Level E Currency. Level E currency may
specify system, procedure, or maneuver
currency item(s) necessary for safe
operations, as identified by the FSB, to be
accomplished in a Level C/D simulator for
that related aircraft. FSB provisions related to
takeoff and landing are applied in a way that
addresses needed system or maneuver
experience. For example, if FGCS, FMS,
EFIS, navigation, or other system or
maneuver experience is the basis for a
currency requirement, approval of an
operator’s program at level E includes the use
of those systems in conjunction with
satisfying takeoff and landing requirements.
In this instance, making three simulator
takeoffs and landings in VFR closed traffic
without using the FGCS, EFIS, or FMS may
not be sufficient to meet level E currency
requirements.
Note: Assignment of level E currency
requirements does not result in assignment of
a separate pilot type rating. Only the
assignment of level E training requirements
may result in assignment of a separate pilot
type rating.
(8) Re-establishing Level E Currency. When
currency is lost, currency may be reestablished by completing pertinent
maneuvers using a device specified for level
E differences training and checking. Other
means to re-establish currency include flight
with an appropriately qualified check airman
during training or in line operations,
completion of proficiency training, a
proficiency check, or AQP evaluation.
(9) Competency Regarding Abnormal/
Nonnormal/Emergency Procedures.
Competency for nonnormal maneuvers or
procedures is generally addressed by
checking requirements; however, in
particular abnormal/nonnormal/emergency
maneuvers or procedures may not be
mandatory for checking or training. In this
situation, it may be necessary to periodically
practice or demonstrate those maneuvers or
procedures even though it is not necessary to
complete them during each check. In such
instances, the FSB may specify a currency
requirement for training or checking
applicable to abnormal/nonnormal/
emergency maneuvers or procedures that are
to be performed. This is to assure that
extended periods of time do not elapse in a
series of repeated training and checking
events in which significant maneuvers or
procedures may never be accomplished.
When an abnormal/nonnormal/emergency
maneuver or procedure is not mandatory and
is not accomplished during each proficiency
training or proficiency check, but is still
important to occasionally practice or
demonstrate, the FSB may establish a
currency requirement. When designated by
the FSB, these currency requirements
identify each abnormal/nonnormal/
emergency maneuver or procedure, the
currency level applicable, and an applicable
time period or any other necessary/
appropriate constraints.
(10) Difference Level Summary. Difference
levels are summarized in Figure 2 below for
training, checking, and currency. Complete
descriptions of difference levels for training,
checking and currency are given above.
FIGURE 2.—DIFFERENCE LEVEL TABLE
Difference level
Training
Checking
Currency
A ..........................................
Self instruction ..................................
B ..........................................
C ..........................................
D ..........................................
Aided instruction ...............................
Systems devices ..............................
Maneuver devices * ..........................
E ..........................................
Simulator c/d or aircraft # ................
Not applicable (or integrated with
next proficiency check).
Task or system check ......................
Partial check using device ...............
Partial proficiency check using device *.
Proficiency check using simulator c/
d or aircraft *.
Not applicable.
Self review.
Designated system.
Designed maneuver(s).
Designed maneuver(s) except takeoff and landings.
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# = New pilot type rating is normally assigned.
* = FFS or aircraft may be used to accomplish specific maneuvers.
g. Operating Experience (OE) for Aircraft.
(1) Application of OE. Requirements for OE
are consistent with provisions for OE
specified under 14 CFR.
(2) Credits or Constraints. OE must meet
the applicable requirements of the CFR part
under which operations are conducted,
except that credit for applicable OE in other
related aircraft may be permitted. When
approved by the FAA, OE associated with
differences may be accomplished as part of
or in conjunction with line oriented
simulation (LOS).
h. Supervised Line Flying (SLF).
Experience associated with the introduction
of equipment or procedures requiring post
qualification skill enhancement during
which a pilot occupies a specific pilot
position and performs particular assigned
duties for that pilot position under the
supervision of a pilot instructor or check
airman qualified for the operator. One or
more of the reasons described below may
apply:
(1) Introduction of new systems (e.g., Local
Area Augmentation System (LAAS),
Automatic Dependent Surveillance Broadcast
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(ADS–B), runway area advisory system
(RAAS), etc).
(2) Introduction of new operations (e.g.,
oceanic operations, Extended-Range
Operations with Two-Engine Airplanes
(ETOPS)).
(3) Experience for a particular pilot
position (e.g., PIC, SIC).
(4) Special characteristics (e.g., effects of
unique airports, mountainous areas, unusual
weather, special air traffic control
procedures, or nonstandard runway surfaces)
on this aircraft.
i. Recency of Experience. Credit towards
the recency of experience requirements of 14
CFR may be permitted for takeoffs and
landings performed in related aircraft as
provided by CTLC. CTLC must be validated
through the FSB process and must be carried
out in accordance with (IAW) the operator’s
CTLC approved program.
j. Operator Difference Requirements (ODR).
(1) ODR Purpose. If differences exist within
an operator’s fleet, which affect pilot
knowledge, skills, or abilities pertinent to
systems or procedures, ODR tables provide a
uniform means for operators to
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comprehensively manage difference
programs and provide a basis for FAA
approval of mixed fleet flying.
(2) ODR Content. ODRs identify a base
aircraft, describe differences between aircraft,
and show an operator’s methods of
compliance with FAA requirements. The
FAA approves an operator’s initial ODR and
each subsequent revision for the following:
(a) Base Aircraft. ODRs identify an aircraft
or group of aircraft (aircraft of the same series
with minor configuration differences) within
an operator’s fleet as a base aircraft. The base
aircraft serves as a reference for comparison
with candidate aircraft. Selection criteria and
characteristics of base aircraft are described
in paragraphs 6c and 7c.
(b) Candidate/Related Aircraft. ODRs
identify particular aircraft flown by an
operator within each fleet. ODRs consider
only those aircraft and combinations of
aircraft actually flown by that operator. ODRs
describe differences within an operator’s fleet
between the base aircraft and other related
aircraft.
(c) Significance of Differences. Differences
are described in summary form and are
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categorized by differences in design features,
systems, and maneuvers. Differences are
evaluated relative to their effect on either
flight characteristics, pilot skills, and/or
procedures. Procedures consider normal,
nonnormal, alternate, and recall items.
Limitations are considered in conjunction
with normal procedures.
(d) Compliance Methods. ODRs show how
each operator’s program addresses
differences, through description of training,
checking, or currency methods for each fleet.
ODRs describe the specific or unique
constraints or credits applicable, and any
precautions necessary to address differences
between aircraft. ODRs must comply with
and be just as or more restrictive than FAA
MDRs and other FSB provisions. Constraints
or credits may be applied to all aircraft in a
fleet or only to certain aircraft. Constraints or
credits may address training devices,
simulators, checking and currency methods,
knowledge, skills, procedure maneuvers, or
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any other factors that apply to or are
necessary for safe operations. Training,
checking, and currency compliance methods
are proposed and revised by each operator
consistent with ODR examples from a variety
of sources that are acceptable to the FAA.
ODR examples are found in FSB reports.
(3) Standard ODR Format. ODRs are
depicted in tables in summarized form. If
necessary, any explanation of details about
differences, constraints and credits,
precautions or compliance methods are
included in attachments or appendices to
ODR tables or are cross referenced to other
operator documents. Figure 3 shows the
general format for ODR tables, including
examples of design, systems, and maneuver
differences. The far-left column lists design,
system, or maneuver differences that are
pertinent. The ‘‘Remarks’’ column
summarizes specific areas or items of
difference. The ‘‘Flight Characteristics’’ and
‘‘Procedural Change’’ columns identify what
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(if any) difference effects are noted. The
‘‘Compliance Methods’’ section of the table
notes the particular operator’s approved
means of compliance with FAA MDR
provisions. The following abbreviations
apply:
ACFT—Aircraft.
AFDS—Auto Flight Display System.
AVT—Audio Visual Tapes.
CBT—Computer Based Training.
EFIS—Electronic Flight Instrument System.
EICAS—Engine Indicating and Crew Alerting
System.
FBS—Fixed Base Simulator.
FFS—Full Flight Simulator.
FLT CHAR—Flight Characteristics.
FMC—Flight Management Computer.
FMS—Flight Management System.
PROC CHNG—Procedural Changes.
SU—Stand Up Instruction.
BILLING CODE 4910–13–P
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(4) ODR Approval, Distribution, and
Availability. ODRs are approved for each
fleet by an operator’s FAA POI in accordance
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with FSB report provisions. ODRs must be
prepared, reviewed, approved and then used
to govern training before start of operations.
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The operator retains approved ODRs with a
duplicate copy as part of FAA certificateholding district office (CHDO) records.
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(5) ODR Revision. ODR tables are revised
by operators and re-approved by the FAA
when fleet characteristics change or when
compliance methods change. Fleet
characteristic changes include redesignation
of base aircraft, modification of aircraft,
addition of aircraft, change of aircraft, or
phaseout of aircraft. Changes in compliance
methods refer to introduction of new or
different training methods, contracting for
use of different devices or simulators,
revision of checking or currency methods, or
other such changes. Revisions to ODRs are
also prepared, reviewed, and approved before
operating.
Note: Paragraph 6 describes the
development, approval, and application of
ODR tables to individual operators’
programs. Paragraph 7 describes FAA review
and approval of programs by POIs.
5. Formulation of FSB Reports, MDRS, and
Designation of Pilot Type Ratings
a. Requirements Formulation Process
Overview. The process for FAA formulation
and revision of training, checking, currency,
and pilot type rating requirements is shown
in Figure 4.
(1) The process determines which
information is required for an aircraft; it
includes a proposal for requirements, tests,
and evaluations of the proposed
requirements; it then finalizes, applies, and
implements the FSB requirements.
Applicants propose MDRs, examples of
ODRs, and any other FSB provisions that are
necessary. Proposals for requirements are
based on design objectives, analysis,
evaluation of OE, other programs that have
been proved acceptable to the FAA, or other
methods. Setting of requirements is based on
an objective set of tests and standards,
analysis of results, and FAA judgments
considering OE. The applicant and the FAA
prepare and conduct standardized tests. The
applicant provides test support, and the FSB
conducts the evaluation. The FSB, in
conjunction with the applicant, evaluates the
results, and the FAA formulates proposed
minimum requirements. The FSB sets final
requirements by specifying MDRs and other
FSB provisions. An FSB report that describes
findings is disseminated to FAA field offices
and posted on the operations specifications
(OpSpecs) Web site for application to specific
operators’ programs. The formulation and
application process of FSB requirements
starts at the time a new aircraft is proposed
to the FAA and continues throughout the
fleet life of that aircraft. For aircraft already
in service the process may be initiated when
significant modifications are proposed, a new
piece of equipment (e.g., a HUD) requiring
operational evaluation is introduced and
requested by operators, or when mixed fleet
flying takes place. The FAA addresses
periodic revisions of requirements when
necessary, and revisions are initiated by the
FAA and applicants as needed.
b. Proposals for MDRs, Example ODRs, and
Special Requirements.
(1) When Proposals Are Necessary. The
FAA usually determines when proposals are
necessary and advises the applicant what
information is needed, in conjunction with
aircraft type certification or supplemental
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certification programs. Necessary information
may include MDRs for related aircraft or
other elements of the FSB reports. The
applicant considers existing MDRs and
existing or proposed ODRs.
(2) Proposal Formulation. The formulation
of a proposal typically starts when a
manufacturer proposes a new design or
design modification. The applicant will then
do the following:
(a) Formulate necessary information for
training, checking, and currency for the
aircraft in proposals for MDRs and example
ODRs.
(b) Prepare example ODR tables for
candidate aircraft to support development of
a proposed MDR. These examples represent
proposals for programs for those specific
aircraft and configurations that the FAA
could approve.
(c) Identify related aircraft for the proposed
MDR table.
(d) Formulate any necessary tests to assess
difference levels and associated training,
checking, and currency requirements for
incorporation in the MDR table.
(e) Identify interpretations of possible test
results. The FAA and the applicant will then
reach an agreement on specific tests, devices,
and schedules to be used for the test
program.
(f) The applicant submits proposals for the
following items to the FAA, as necessary:
• MDRs
• Example ODRs
• Tests and criteria to be used
• Other supporting information associated
with training, checking, or currency
programs
c. Difference Level Tests. A sequence of
five standard tests, described in Appendix 3,
is used to set MDRs, minimum acceptable
training programs, other FSB provisions, and
define pilot type rating requirements. One or
more of these tests are applied depending on
the difference level sought, and the success
of any previous tests used in identifying
MDRs. Only those tests needed are used to
establish minimum requirements. The
outcome of these tests, and any resulting
difference levels that apply, establish
minimum requirements for training,
checking, currency, and pilot type ratings.
The FAA will establish an additional pilot
type rating if it is determined during this
testing that the assignment of a level E
differences training is required.
Note: One additional test, the T6 test, can
be used to establish CTLC between related
aircraft, when not previously demonstrated
in a T2 test.
(1) Steps in the Testing Process. The
typical steps of the testing process are as
follows:
(a) The applicant develops representative
training programs, difference programs, and
necessary supporting information, as needed.
(b) The applicant identifies proposed
MDRs and example ODRs.
(c) The applicant proposes and the FAA
determines which tests and criteria apply.
(d) The applicant proposes and the FAA
determines which aircraft, simulation
devices, or analyses are needed to support
testing.
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(e) The applicant makes a proposal to the
FAA, and agreement is reached on test
procedures, schedules, and specific
interpretation of possible results.
(f) Tests are conducted and results
evaluated.
(g) The FSB draft minimum requirements
are formulated.
Note: If the candidate aircraft is anticipated
to have no greater than level A or B
differences with the base aircraft and a same
or common pilot type rating is the proposed
assignment, then the FSB may elect to
directly apply a T1 test for equivalency.
(2) Test Purpose and Application. A
summary of the purpose and application of
each of the six difference tests is shown in
Figure 5.
(3) Test Relationships and Applications.
The test process relationships, the sequence
of conducting tests when more than one test
is needed, and application of test outcomes
are shown in Figure 6. The start of the
process is shown at the top of Figure 6.
Resulting difference levels are at the bottom.
New aircraft, for which a new aircraft TC is
sought, follow the testing path at the right of
the diagram for a T5 test. At the end of the
process the aircraft is assigned a new pilot
type rating. For candidate aircraft seeking a
same or common pilot type rating the test
process follows a path at the left of Figure 6.
A series of decisions or tests leads to
assignment of one or more levels A through
D and in some instances may lead to level
E. If level E is assigned as a result of this
path, then a separate pilot type rating is
assigned. This process is followed whenever
a new aircraft is proposed, when significant
changes are proposed, or when revisions to
existing requirements are needed as a result
of requests for change or OE.
(4) Test Failures and Retesting. Generally,
failures do not have paths back to lower
levels. T3 test failure at level C can lead to
subsequent passage at C (after modification of
the system, operational procedures, or
training and retesting) or D. Similarly, failure
at level D can subsequently lead to either D
(after modification of the system, operational
procedures, or training and retesting) or E,
but not C. Failure at level E can only lead to
retesting with increased programs, improved
programs, or improved devices since there is
no higher level. T5 failure paths do not lead
back to level C or level D. However,
subsequent new programs do not preclude
making a proposal at a lower differences
level if technology changes, aircraft redesign
takes place, training methods significantly
change, or device characteristics and
effectiveness change.
(5) Same and Common Pilot Type Rating
Tests. Aircraft seeking same or common pilot
type rating will follow the path in Figure 6
from the top left of Figure 6 through T1 or
T2 and T3 tests resulting in the assignment
of level A, B, C, or D differences.
(6) ‘‘Currency’’ Tests. Currency tests T4 are
not shown in Figure 6 because they are
necessary only when the applicant seeks
relief from system, procedural, and maneuver
currency requirements set by the FSB.
(7) Detailed Test Specifications. A detailed
specification for the evaluation process and
tests to establish difference levels are
described in Appendix 3.
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d. FSB Assessments and Proposal
Formulation. The FSB assesses the
applicant’s proposals, test results, analysis,
and any other relevant factors to formulate a
draft FSB report, which includes MDRs and
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other pertinent training, checking, currency
requirements. The FSB either validates the
applicant’s proposed MDRs, training
programs, and other information, or generates
alternate requirements, which may include
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more stringent requirements, additional
training, additional testing, etc.
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FIGURE 5.—TEST DEFINITIONS
Test purpose
Application
T1 ...............................
T2 ...............................
Establishes functional equivalence ......................................
Handling qualities comparison .............................................
T3 ...............................
Evaluate differences and sets training/checking requirements.
Revises currency requirements ...........................................
Sets training/checking for new or ‘‘E’’ ACFT .......................
Evaluation for CTLC .............................................................
Sets levels A/B.
Pass permits T3, and A/B/C/D; failure sets level E and requires T5.
Pass sets levels A/B/C/D; failure sets level E and requires
T5.
Used to adjust FSB requirements if needed.
Sets level E.
Sets recency of experience requirements.
T4 ...............................
T5 ...............................
T6 ...............................
Note: Expanded descriptions are contained in Appendix 3.
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e. Comments Solicited. The FSB proposal
is circulated with interested parties
representing the manufacturer, operators, and
other pertinent FAA organizations such as
engineering, flight test, pilots’ associations,
and other aviation representatives for
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comment, relevant information, and
recommendations.
f. FSB Final Determinations and Findings.
(1) FSB Determinations. Any comments
submitted to the FAA are reconciled, and
final FSB determinations are made.
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Specification of MDRs, example ODRs,
acceptable training programs, and other FSB
provisions are completed. Any necessary
pilot testing or currency provisions are
identified. Assignment of any necessary pilot
type rating(s) is made.
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(2) Basis for FSB Judgments. FSB
judgments are based on review of the
applicant‘s supporting documentation,
proposed ODR tables, test results, and any
other pertinent information, such as FAA
policies, OE, and results of other similar FSB
evaluations. Specifically, FSB report
provisions are based on the following:
(a) Appropriate Data, Evaluation, or Tests.
Testing may include aircraft demonstration,
simulation tests, device testing, or analysis.
(b) Direct Experience. The industry may
have substantial experience with successful
operational programs, which can be useful in
the assignment of minimum difference level
requirements. This experience may include
particular training devices, training/
checking/currency requirements, and mixed
fleet flying.
(c) Indirect Experience. Applicable
experience with foreign operators, military
programs, or other programs that can
establish the suitability of training, checking,
or currency standards may be permitted as a
means for FSBs to set MDR or ODR levels.
(d) Applicant and Industry. FSB
requirements are set following solicitation
and review of comments.
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(3) Device or Simulator Characteristics.
Minimum characteristics for devices or
simulators for training, checking, or currency
are noted using standard training device or
simulator definitions. When standard criteria
for methods, devices, or simulators are not
appropriate for an aircraft, the FSB identifies
suitable criteria to be applied and
coordinates with the FAA National Simulator
Evaluation Team (NSET). Standard devices
and simulators applicable to each difference
level are shown in Figure 7.
FIGURE 7.—STANDARD METHOD, DEVICES, AND SIMULATORS
Difference level
Difference level definition
A ................................
Self instruction .....................................
B ................................
Aided instruction ..................................
C ................................
System devices ...................................
D ................................
E ................................
Maneuver devices ...............................
Simulator C/D or aircraft .....................
Devices or simulators 1
Methods
Bulletins, Manual revisions, Handout
material.
Slides/video tapes, Standup instruction, Computer-based training (CBT).
.............................................................. Training devices level 2/3/4/5 full task
computer based instruction (CBI).2
.............................................................. Training devices level 6/7. 3
.............................................................. Simulator C/D or aircraft.
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(1) Training level and simulator definitions are as specified by applicable ACs.
(2) Training device levels 3/4/5 typically include cockpit procedure trainers, cockpit system simulators, and similar devices.
(3) Training device 6/7 or simulator A/B typically includes fixed-base simulators or visual simulators.
g. FSB Report Preparation Distribution and
FAA Application.
(1) Report Preparation and Approval. After
MDRs are finalized, the FSB report is
prepared and approved. Sufficient
background or explanatory material is
provided in the report to permit FAA
personnel to properly administer FSB
provisions.
(2) FSB Report Distribution. The FSB report
is posted on the OpSpecs Web site for
implementation in approval of particular
operators‘ programs. The FAA technical
requirements described in FSB reports are
primarily intended for the operators use to
develop programs that will be approved by
the FAA.
(3) FSB Report Implementation. FSB
requirements, recommendations, and
guidance are provided to FAA field offices
through FSB reports for each aircraft. These
reports are directives to FAA offices to
identify acceptable methods of applying
pertinent 14 CFR parts to each specific
operator. FSB provisions set acceptable
standards by which FAA inspectors approve,
review, correct, or limit individual operator‘s
programs. The FSB report is the basis for
approval of training, checking, and currency
programs approved by each FAA office. The
report is also the basis for pilot certification
by FAA or operators and the surveillance of
operators‘ programs. POIs may approve
individual operator‘s programs that meet or
exceed master requirements, but they cannot
approve programs that are less than master
requirements. Aviation safety inspectors
(ASI), aircrew program managers (APM),
aircrew program designees (APD), and
designated pilot examiners (DPE) use the
report as the basis for administration of oral
examinations, simulator checks, flight
checks, proficiency checks, and OE.
Preparation and application of ODRs by
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operators is described in paragraph 6. Review
and approval of ODRs by FAA POIs is
covered in paragraph 7.
h. FSB Report Revision.
(1) General FSB Revision Process. A
general revision process is established to
update determinations and findings
contained in FSB reports. Revisions may be
needed annually for active fleets with
numerous change requests. Revisions may be
needed infrequently for aircraft not
undergoing significant change.
(2) Revisions for New Aircraft. When an
applicant proposes to develop or add a series
of a type-certificated aircraft, MDRs and other
FSB provisions must be revised to address
that series. If an applicant initiates this
action, the procedures noted in paragraph 5
regarding initial determination of minimum
training, checking, currency, and pilot type
rating requirements are followed. If an
operator proposes to add an aircraft that is
not covered within an existing FSB report
(e.g., a foreign manufactured aircraft) POIs
should consult with the pertinent Aircraft
Evaluation Group (AEG). An FSB will
determine the best method of addressing the
development of the necessary FSB report.
This is particularly important for older
aircraft fleets in which differences may be
significant, but manufacturer support is no
longer available and aircraft imported into
the United States that have been used only
by foreign operators.
(3) Revision for Aircraft Modified by
Operators. When an aircraft is to be modified
by an operator, the POI must determine if the
change affects MDRs, example ODRs, or other
FSB report provisions. The criteria for this
assessment includes whether or not the
difference affects pilot knowledge, skills, or
abilities pertinent to flight safety. If a change
meets the criteria, the operator should supply
the POI with a difference description and
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analysis of the effects of the difference. The
POI makes a preliminary estimate of the
difference levels then advises the applicable
AEG/FSB. The AEG/FSB may concur with
the POI‘s assessment or require other action.
If FSB action is required, the AEG will
initiate that action through the FSB
chairman. The FSB may require that
additional information or analysis be
provided or that the entire test process or
parts thereof be applied. The AEG may
authorize the POI to approve assignment of
the difference level. Changes to the MDRs
will be made through the normal FSB
revision process.
6. Operator’s Application of FSB Provisions,
Preparation, Use, and Revision of ODRS
a. General.
(1) Process Overview. FSB reports contain
MDRs and other provisions that are applied
by FAA offices in approving operators’
programs. MDRs are applied through a
particular method that identifies specific
ODRs and compliance methods. Application
of MDRs and other FSB provisions are one
means to ensure pilot qualification for safe
operations. This is necessary so that
regardless of which aircraft is flown, uniform
training, checking, and currency standards
are met within the constraints of 14 CFR.
Paragraph 6 describes operator application of
MDRs and other FSB provisions for training,
checking, and currency. This is done through
operator preparation and FAA approval of
ODRs for each operator. When aircraft are
used in mixed fleet flying, this AC’s
provisions and FSB provisions
comprehensively address differences in
training, checking, and currency
requirements for each aircraft. In some
instances, the FAA may limit the number of
different aircraft permitted in mixed flying.
ODRs are used to identify credits or
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constraints between aircraft. These credits
may also be applied to a related aircraft when
transitioning to another related aircraft when
those aircraft are intended for use in mixed
or nonmixed fleet operation. The overall
process for operator application of MDRs and
development, approval, use, and revision of
ODRs is shown in Figure 8.
(2) Availability and Use of FSB
Information. FSB requirements are made
available to operators through FAA CHDOs,
applicant, industry trade associations, posted
on the OpSpecs Web site, or other sources.
When preparing initial or difference
programs for specific fleets, individual
operators apply the requirements of the
applicable FSB report.
b. Application of MDRs and Preparation
and Use of ODRs.
(1) Need for ODRs. When operating a
mixed fleet, operators prepare the necessary
ODR table proposals to describe their
particular fleet and show compliance
methods. This is done to assess effects of
differences, plan compliance methods, and
obtain POI approval for that operator‘s
specific program. ODR tables must be
prepared and approved by the FAA for each
fleet in which FSB requirements are
established IAW FSB provisions.
(2) Operator Responsibilities. The
operator’s responsibilities include:
(a) Specification of a base aircraft.
(b) Identification of differences between
the aircraft within a mixed fleet.
(c) Preparation of proposed ODR tables.
(d) Assessment and description of the
effects of the differences on training,
checking, and currency.
(e) Proposal of training, checking, and
currency methods consistent with MDRs and
FSB provisions.
(f) Presentation of proposed ODR tables
with necessary supporting information to the
FAA POI for approval.
(g) Revision of ODR tables when aircraft
are introduced, modified, phased out,
devices change, or MDRs change.
(3) Use of Standard ODR Format. A
common format for ODR tables is used to
facilitate preparation, review, use,
comparison with MDRs, and ensure
consistency of application and approval by
POIs. The common format is used in all cases
where ODR tables are required except when
only a few minor differences exist and level
A applies. In this event, letters between an
operator and FAA containing the necessary
information and approval may suffice if
acceptable to the POI.
(4) Minimum Threshold for ODR
Preparation. Within the mixed fleet, a
minimum threshold for preparation of ODR
tables occurs when there are differences that
potentially affect knowledge, skills, or
abilities necessary for flight safety.
Differences not related to this criterion need
not be addressed in ODR tables.
(5) ODR Description and Examples. ODRs
are described in paragraph 4. Examples of
acceptable ODR tables for a particular typecertificated aircraft are shown in each FSB
report.
(a) Systems Shown on the ODR Table of
Figure 3. An example of several pages from
an ODR table is shown in Figure 3. Figure 3
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shows the application of ODRs to address
systems differences and compliance
methods. In Figure 3 differences are grouped
in the order associated with a typical
operations manual. Air Transport
Association (ATA) code numbers are shown
for cross-reference. The ‘‘Remarks’’ column
depicts differences and the ‘‘Flight
Characteristics’’ and ‘‘Procedural Change’’
columns address effects of differences.
(b) Maneuvers Shown on the ODR Table of
Figure 3. The ‘‘Remarks’’ column depicts
differences. The ‘‘Flight Characteristics’’ and
‘‘Procedural Change’’ columns address effects
of differences. The reference ‘‘SEE APP’’
refers you to an appendix to the table, which
the operator prepares to more fully list and
explain the particular procedural changes
that pertain to the maneuver in the
‘‘Procedural Change’’ column.
(6) Other Use of ODRs. The ODR process
may be used for other applications such as
flight attendant or dispatcher qualification
tracking, but such use is not required as part
of this AC’s provisions.
c. Selecting Base Aircraft. An operator
chooses a base aircraft from one of the
aircraft operated. Base aircraft are defined in
Appendix 1. Additional information
regarding base aircraft selection is in
paragraph 7.
d. Identification of Differences and the
Analysis of Effects of Those Differences.
Differences must be described between base
aircraft and other related aircraft. This may
be done from base to each other related
aircraft. Differences may also be described
from any related aircraft to each other related
aircraft. All MDR requirements must be
satisfied relative to the base aircraft so the
pairing of aircraft not authorized to be flown
in a mixed fleet environment by the FSB
reports is avoided. As long as a complete and
clear relationship can be drawn from the base
aircraft to each other related aircraft and all
MDR requirements are met from the base
aircraft, to each other related aircraft, there is
no need to describe each possible
combination of aircraft. This permits a
comprehensive identification of differences
that exist in the fleet, determines the effects
of those differences, and shows compliance
methods. Differences are generally organized
to follow an operations manual or flight
manual to facilitate use and review, and
should be categorized by design, systems,
and maneuvers. Effects of differences are
stated in terms of effects on flight
characteristics and procedures. Procedures
include normal, nonnormal, alternate, and
recall procedures, as applicable. Since
complete descriptions may be too lengthy for
direct incorporation in ODR tables,
appendices, or references to other operators’
documents may be used to describe
differences or effects. Some differences or
effects may be repeated in the analysis. For
example, an FMS difference may be noted in
both a navigation system section and
maneuver section associated with preflight
setup. The objective is to assure each
difference that pertains to pilot training,
checking, or currency is identified and
addressed, so it is not necessary to limit
difference descriptions to prevent overlap.
e. Identification of Compliance Methods.
Once differences and difference effects are
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described, methods of comprehensively
addressing each difference (compliance
methods) are shown. With the difference
descriptions, redundancy may occur. The
same training or checking compliance item
shown for one item may also be associated
with and credited for other items. The
objective for description of compliance
methods is to show that each difference is
addressed in some appropriate way, to show
that the method and level chosen is
consistent with the FSB MDRs, and example
ODRs at a level at least equal to that required
by the MDRs.
f. When Proposed ODR Compliance
Methods Do Not Meet MDRs. If proposed
ODR compliance methods do not satisfy
MDRs or other FSB report constraints, the
following alternatives exist:
(1) Differences may be reduced or
eliminated by modification of aircraft,
systems, or procedures.
(2) Other training methods or devices that
fully comply with MDRs and other FSB
provisions may be acquired, leased, or
otherwise applied.
(3) Pilot assignments may be separated for
a fleet so that mixed flying of related aircraft
does not occur.
(4) MDR change proposals may be
requested through FAA POIs to the FSB. If
FSB authorized changes to the MDRs are
made, the operator may then apply the
revised criteria.
g. Maximum Number of Related Aircraft.
Comparative differences between related
aircraft may comply with FSB provisions;
other limitations may also constrain mixed
fleet flying. To prevent cumulative effects of
differences for multiple related aircraft from
adversely affecting pilot performance, the
FAA sets guidelines for the maximum
number of related aircraft to be flown. At
difference level A, the number of related
aircraft is greater since differences are fewer
and less significant, whereas at level D or
level E the number of related aircraft that can
be flown is fewer because the differences are
greater. To accommodate an increase in the
differences level, increasing limitations are
placed on the number of related aircraft that
may be flown at the higher levels. Paragraph
7k contains specific guidance to POIs for
approval of multiple related aircraft.
h. Application, Review and Approval.
Paragraph 7 describes the FAA review and
approval process. The process is summarized
here to facilitate ODR table preparation. An
operator submits the proposed ODR tables
and necessary supporting information to the
POI to apply for differences program
approval. The supporting information may
include any appendices to the ODR tables
necessary for evaluation of the proposal, a
transition plan if needed, and a proposed
schedule for implementation. POIs may also
require review of such pertinent and
additional information as copies of bulletins,
manuals, or other training materials, before
they approve proposed ODRs. If devices are
proposed that are not approved by the POI,
or evaluated by the NSET, a review and
approval of those training devices may be
necessary before ODR approval. Sufficient
lead-time must be provided to the FAA for
review. Lead-time depends on such factors as
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the complexity of program, proposed
difference levels, number of related aircraft,
other operator precedents already set, and
FAA experience with the proposed aircraft,
training devices, and methods. Many
noncontroversial level A changes can be
reviewed and approved in a few days.
Complex programs with many related aircraft
can require months for review and approval.
It is the operator’s responsibility to consult
with the POI to ensure that sufficient leadtime is provided to review initial
submissions or changes. At least 60 days
notice is acceptable for most programs. After
the operator submits the program proposal,
POIs compare the proposed ODR with the
FSB report provisions including the MDRs.
POIs consult pertinent FAA policy directives
(Handbook, notices, Safety Alerts for
Operators (SAFO), etc.) for interpretations or
guidance in accomplishing the review. In
certain instances the POI must consult with
the FSB before ODR approval. If ODRs are
consistent with FAA policies and within the
constraints of the MDRs and example ODRs,
the POI will approve the operator’s ODR
tables and its proposed differences program.
When approved by the FAA, ODRs establish
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the basis for training, checking, and currency
programs for a given fleet for that operator.
i. Implementation Provisions Transition
Period. In certain instances, a transitional
period, agreed upon by the POI with FSB
concurrence, may be necessary to permit
operators to continue operations under
previously approved programs until they are
able to comply with FSB requirements. This
is necessary when FSB provisions are
initially set or revised and provisions require
lead-time for program preparation, device
acquisition, or to revise previously approved
programs. Paragraph 7m and the individual
FSB reports for each type-certificated aircraft
discuss FAA approval of transition
provisions.
j. ODR Revision. ODR revisions are
initiated when changes occur in an operator‘s
fleet relating to differences, difference effects,
or compliance methods. ODR revisions are
appropriate when such changes affect pilot
knowledge, skills, or abilities relevant to
flight safety. Examples of program changes or
factors that may require ODR revision
include:
(1) Addition or deletion of aircraft in a
fleet;
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(2) Modification of base aircraft or
comparison aircraft in a fleet;
(3) Change of base aircraft;
(4) Discontinuation of use, addition of new
or modification of training devices referenced
by ODRs;
(5) Revision of training methods with a
resulting change in compliance levels;
(6) Changes in effects of differences such
as revised procedures, performance, or flight
characteristics;
(7) FAA revision of MDRs or other FSB
provisions;
(8) Adverse OE or training and checking
experience that dictates inadequacy of ODRs,
MDRs, or other FSB provisions;
(9) FAA surveillance results, enforcement
actions, or failure of an operator to comply
with provisions of their approved ODRs; and
(10) Other factors as determined by the
POI.
Note: Revisions to ODRs are approved
using the same procedures as for initial
ODR’s approval.
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7. FAA Review and Approval of Operator
Programs
a. General.
(1) FAA Responsibilities. FAA has the
responsibility for review, approval, and
continuing surveillance of individual
operator programs consistent with this AC
and FSB provisions. Within a CHDO, POIs
have the responsibility for program review
and approval. In addition to review,
approval, and continuing surveillance of
operator programs, CHDO and other district
offices manage pilot certification consistent
with the criteria of this AC and FSB
provisions.
(2) Approval Basis. FAA approvals are
based on FSB report findings and policy
guidance included in FAA directives (e.g.,
Order 8400.10, Air Transportation
Operations Inspector Handbook, notices,
SAFOs, etc.). Except as provided for in
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transition plans, all preparations must be
complete and provisions approved before
conducting training, checking, or establishing
currency under this AC and an FSB report.
b. Operator Application of ODRs.
(1) Operators Using Related Aircraft in
Mixed fleet Flying. If FSB requirements are
published, operators operating aircraft in
mixed fleet flying must apply provisions of
this AC and the FSB report. AC criteria and
FSB MDRs must be applied anytime pilots
operate mixed fleets between training and
checking events.
(2) Threshold Requiring ODR Preparation.
Even though an operator has different
configurations of aircraft used in mixed fleet
flying, there is some threshold below which
ODR tables and POI approval is not required.
The threshold requiring AC and ODR
application occurs when differences in
related aircraft affect pilot knowledge, skills,
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and/or abilities pertinent to flight safety. If
systems, controls, indications, procedures, or
maneuvers are different and these differences
have an effect that significantly relates to
what the pilots needs to know or do for safe
mixed fleet flight operation, then an operator
must prepare ODR tables and seek FAA
approval. Conversely, ODR tables would not
need to be prepared in situations that do not
affect flight safety. In such instances ODR
tables are not needed even though pilots
routinely operate several related aircraft. A
minimum threshold is set to preclude
unnecessary administrative assessment of
mixed fleet flying, which has no safety
implications. If changes to the fleet do not
affect pilot knowledge, skills, or abilities
affecting flight safety, then such changes
need not be considered in addressing FSB or
this AC provision.
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(3) FAA Review of ODR Proposals. After
preparation the carrier submits proposed
ODR tables and supporting information to the
CHDO and POI for review and approval. POIs
evaluate the following:
(a) The operator has made an appropriate
identification of a base aircraft.
(b) Operators have comprehensively
identified differences in the particular fleet.
This includes appropriate ODR table
comparisons between the base aircraft and
each related aircraft.
(c) The operator‘s assessment of the affects
of differences on flight characteristics and
procedures for the base aircraft and each
related aircraft are suitable and valid.
(d) The compliance methods listed are
consistent with the requirements of the MDR
tables, footnotes, other pertinent FSB report
provisions, FAA Order 8400.10, and
associated advisory materials.
(e) ODR provisions adequately address any
‘‘subtle differences’’ between related aircraft
that have a possibility of inducing potentially
serious pilot errors.
(f) Training materials, methods, devices,
and simulators proposed are acceptable,
approved by the NSET if necessary, or if FSB
provisions apply, the ODR tables meet FSB
constraints.
(g) ASIs, APMs, and APDs are prepared to
apply FSB report checking standards.
(h) Implementation plans are adequate and
consistent with FSB provisions and other
FAA policy.
(i) Other factors determined necessary by
the POI are considered and any requirements
met.
(4) The POI uses the example ODR tables
and the MDRs provided in the FSB report as
a basis for evaluating the suitability of a
particular operator‘s proposed ODR table.
The MDR always remains the primary basis
for comparison. The AEG should be
consulted in the absence of conclusive
guidance in making such judgments.
Guidance for evaluation of specific system or
maneuver items may be found by comparison
of the proposal with the example ODR table
shown in the FSB report and other approved
ODR tables. The operator may use devices,
techniques, or methods of an equal or higher
difference level. Critical methods must be at
least at the level specified by the FSB on the
MDRs and shown in the example ODR table.
Actual ODR tables proposed by the operator
may show a variety of compliance methods
to satisfy a particular item, ranging from level
A through the level required by the MDRs.
For example, if the MDR requirement is a
minimum of level C, the operator may
propose to use a combination of level A
bulletins, level B slide tape presentations,
and level C training devices to satisfy
pertinent items. However, at least level C
must be shown for critical items. The
operator may choose to satisfy a level C MDR
provision with level D or level E methods.
(5) ODR Review Example. The following is
an example of the process for review of a
specific item on a proposed ODR table. For
each proposed ODR item both the FSB
example ODR table and MDRs are consulted
and compared with the operator‘s proposal.
If the MDRs specify that level C devices are
needed for training, checking, and currency
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between the base aircraft and a related
aircraft and the example ODR table shows
applicable level C systems differences or
maneuvers, then the POI should ensure that
the proposed ODR table submitted also
shows at least level C for those pertinent
systems or maneuvers.
c. Base and Other Aircraft Identification.
(1) Selecting the Base Aircraft. Base aircraft
are defined in Appendix 1. In general, base
aircraft are used as reference for comparison
of differences that affect, or could affect, pilot
knowledge, skills, or abilities pertinent to
flight safety. A base aircraft should typically
be the aircraft that the operator trains to first,
the aircraft that the operator has the largest
number of, the aircraft most pilots fly
frequently, or the aircraft that represents a
configuration that the operator eventually
will have as a standard. Another aircraft may
be selected as a base aircraft when the
previous base aircraft is being phased out,
converted to a new configuration, or other
such factors. A base aircraft may be
redesignated at the discretion of the operator
with FAA concurrence. A base aircraft is
identified by make, type-certificated aircraft,
model, and series or other distinguishing
classifications. Classification should
distinguish pertinent differences in
configuration, handling characteristics,
performance, procedures, limitations,
controls, instruments, indicators, systems,
installed equipment, options, or
modifications.
(2) Identifying Related Aircraft. A related
aircraft is an aircraft or a group of aircraft
with the same characteristics that have
pertinent differences from a base aircraft.
Pertinent differences are those that require
different or additional pilot knowledge,
skills, and/or abilities that affect flight safety.
Differences considered pertinent are those
relating to configuration, handling
characteristics, performance, procedures,
limitations, controls, instruments, indicators,
systems, installed equipment, options, or
modifications. Related aircraft can exist
between different models, series or within a
model/series. When designated in FSB
reports, any aircraft included in a MDR table
is considered a related aircraft. Like base
aircraft, operators designate related aircraft
by one of the following:
(a) Model/series.
(b) FAA registration ‘‘N number’’.
(c) Operator tail number.
(d) Any other classification that can
uniquely distinguish pertinent differences
between each related aircraft group and a
base aircraft.
(3) Accounting for Each Related Aircraft.
The important factor in base and related
aircraft identification and ODR table
preparation is that regardless of the
combination used, there should be direct and
complete traceability of both differences and
compliance methods. There must be a clear
description showing the adequacy of
compliance methods to assure proper
training, checking, and currency to safely
operate each aircraft assigned.
d. Approval of ODRs.
(1) Approval Method. Following review
and determination that an operator‘s program
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meets pertinent FSB requirements, the POI
approves that particular program by signing
ODRs. ODR tables are approved for each
applicable related aircraft. Signature of ODRs
or revisions, together with other relevant
documents such as training programs and
OpSpecs, constitute approval by the POI of
that operator’s differences training, checking,
and currency program requirements. ODR
tables are used for most programs. In
instances where aircraft have only a few
minor differences at level A, approval may
take the form of a letter including necessary
information in lieu of using tables.
(2) POI Authority at level A and B. POIs
have authority at A and B level to make
determinations without AEG coordination if
compliance methods are within the MDRs.
This is important to provide timely response
to minor differences requests. The results of
these determinations are forwarded to the
pertinent FSB for permanent retention,
comparison, and future FSB evaluation.
(3) POI Coordination Required at Level C
and Above. At C, D, and E level the POIs may
approve operator programs only if the
programs are clearly within the requirements
of the MDRs. If there is doubt whether or not
an operator’s program meets the MDRs, the
POI consults with the FSB well before the
operator’s program approval date, to allow
time for review and resolution of open issues.
If the operator request is unclear or less strict
than the MDRs requirements, the POI may
not approve that program.
(4) Initial and Final Approval. Like other
training programs, POIs may authorize
‘‘initial’’ approval for an assessment period to
review program effectiveness. Final approval
should be made after suitable experience is
obtained (generally within 6 months) IAW
criteria in FAA Order 8400.10. In situations
where initial approval is completed but final
approval is delayed because of continuous
revision or that results are uncertain should
be avoided. When operators propose to add
aircraft, modify existing aircraft, change base
aircraft, phase aircraft out, or take other
actions, which make the applicability of
ODRs unclear, then the ODR tables for that
operator must be updated. For some
operators a continuous series of ODR table
modifications will occur as its fleet changes.
Nevertheless, the ODR tables must be current
at all times. ODR tables are used as a primary
means for establishing regulatory compliance
and managing surveillance of training,
checking, and currency programs.
e. POI Uncertainty Regarding Program
Compliance. The POI must resolve any
questions before approval if it is not clear
that the operator’s proposal complies with
the MDR table and other FSB provisions.
When issues cannot be resolved to clearly
establish compliance with MDRs or other
FSB report provisions, the AEG/FSB should
be consulted. Early in program development,
POIs may need more consultation with FSB
members. In mature programs, better
examples will be available in FSB reports,
other operator ODR, and the manufacturer‘s
larger databases for operators.
f. Proposals that do not Comply with FSB
Provisions. If the operator proposes a
program less restrictive than the
requirements of the MDRs or other FSB
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provisions, then options of paragraph 6h.
apply. If an operator wishes to pursue a
proposal less restrictive than the FSB report
or MDRs, details of the proposal and
supporting documentation should be
presented to the POI for forwarding to the
AEG/FSB. The POI will evaluate the carrier‘s
proposal and, if justified, forward the
proposal with recommendations for revision
of MDRs.
g. FSB Revision of MDRs or Other FSB
Provisions. When requested by a POI, the
FSB reviews an operator‘s proposals and if
necessary modifies MDRs and other FSB
provisions. If master requirements have been
amended and the proposal meets the revised
requirement, the POI may approve the
proposal. Other operators can also apply for
similar approval or reductions based on the
revised FSB report. Major changes in the
MDR table may require review by the full
FSB. The FSB may consider minor changes
or interpretations on an ad hoc basis between
FSB meetings for that aircraft. For some
requests changes can be made based on
existing or the supplied information.
Complex cases may require testing to be
conducted by the applicant before the MDR
table is changed. Should the MDRs be
updated to accommodate a change request,
the proposed ODR can be approved within
the new MDRs. Proposals for revisions to
levels C, D, or E must be forwarded to the
FSB for resolution through the formal FSB
process. Allow at least 60 days for FAA
evaluation of such proposals.
h. Proving Tests. When a related aircraft
with difference levels C or greater is
introduced by an applicant, proving runs
may be needed. Proving runs are usually
needed for levels D and E. At level E,
regulatory provisions for proving runs must
be met. Training flights, test flights, delivery
flights, and demonstration flights may be
credited toward levels C and D proving
requirements if necessary operational
experiences are demonstrated and the flights
are IAW an FAA-approved plan. FAA Order
8400.10 describes policies for FAA approval
of proving tests.
i. Line-Oriented Flight Training (LOFT),
LOS, or SLF. When operators have LOFT/
LOS/SLF programs and additional related
aircraft are approved, the POI must review
those LOFT/LOS/SLF programs to assure
applicability to each related aircraft. SLF in
the aircraft, or in some instances simulator
(as determined by the FSB), may be necessary
IAW provisions of the FSB report and with
the approval of the POI.
j. OE. As described in this AC and FSB
reports, OE is consistent with definitions and
requirements of 14 CFR. OE credit, as
provided by the FSB for experience with
related aircraft, may be permitted with the
approval of the POI.
k. Limitations on the Total Number of
Related Aircraft.
(1) Mixed Flying of Multiple Related
Aircraft. When mixed fleet flying involves
pilots operating more than a base aircraft and
a single additional related aircraft, additional
constraints limiting the total number of
aircraft may apply. Operation of multiple
related aircraft requires a review by the POI
to ensure that pilots can retain and properly
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apply necessary differences information or
skills for each related aircraft without
confusion. When more than two related
aircraft are flown, POIs must specifically
ensure that subtle or compounded
differences between the various related
aircraft do not result in confusion of
procedures, maneuvers, or limitations. ODRs
proposed for the overall combination of
aircraft to be flown must be examined to
ensure the following:
(a) That multiple differences do not result
in confusion of requirements or an excessive
level of complexity for pilots to adjust to or
retain important differences information;
(b) That subtle variations in differences
information are not mistakenly applied and
lead to unsafe conditions; and
(c) That the amount of differences
information is not excessive, not applied to
the wrong aircraft, or not forgotten.
l. Compliance Checklist for CHDOs. FSB
reports provide a CFR compliance checklist.
The checklist identifies those 14 CFR parts,
ACs, or other FAA requirements that are in
compliance. Pertinent 14 CFR items not
shown on the checklist or items shown but
not reviewed by the AEG/FSB for compliance
must be reviewed by the CHDO before POI
approval of OpSpecs permitting those aircraft
to be used under 14 CFR. Items found not
compliant by the AEG/FSB must be
reconciled and compliance established before
operation. The compliance checklist is an aid
to CHDOs used to show the status of those
14 CFR items evaluated by the AEG/FSB, but
does not comprehensively address all
possible 14 CFR items and ACs that an
operator may need to demonstrate
compliance. OpSpecs, exemptions,
deviations, or other factors, which the AEG/
FSB may not be aware of, may also apply and
may modify compliance status or methods
shown in the checklist.
m. Implementation of FSB Provisions.
These provisions are addressed in each typecertificated aircraft FSB report and must
comply with any criteria shown in that
report. POIs approve implementation
provisions at the same time ODR tables or
revisions are approved. Operators that do not
elect to apply this AC or implement FSB
provisions specified by the FSB report
require approval by the Director, Flight
Standards Service, AFS–1.
n. Aircraft That Do Not Have an FSB
Report. When an FSB report is not prepared
for a given type-certificated aircraft, or when
MDRs or other provisions are not shown,
programs are approved IAW the 14 CFR,
Order 8400.10, and other pertinent inspector
guidance material.
8. Application of Requirements to Airmen
Certification
a. General. In addition to master
requirements, the FSB report contains
specifications for administration of pilot type
rating or proficiency checks by FAA
inspectors or operator check airmen. FAA
pilot certification inspectors, APMs, operator
check airmen, APDs, and DPEs should be
familiar with FSB provisions regarding the
proper administration of any necessary
checks or evaluations for type-certificated
aircraft or their series covered by the FSB
report.
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b. Checking Specifications. FAA pilot
certification inspectors and APMs should
assure proper application and administration
of checks required by FSB reports as
constrained by the MDR and specific ODR
tables. FSB reports describe difference levels
which constrain the various maneuvers,
procedures, or unique factors to be
considered by inspectors or check airmen
when administering checks or observing OE.
For example, certain nonnormal procedures
may be required and others may be waived
(for example no flap landings). Other unique
procedures or maneuvers particular to an
type-certificated aircraft may be necessary.
Any unique configurations or failure
conditions that should be observed while
administering checks are described.
c. Checks Regarding Complex Systems.
(1) Partial proficiency checking is required
for differences associated with systems that
are determined to be at or greater than level
C.
(2) Complex systems checks include
hands-on operation and ensure demonstrated
procedural proficiency in each applicable
mode or function. Specific items and flight
phases to be checked are specified (e.g.,
initialization, takeoff, departure, cruise,
arrival, approach, and pertinent nonnormals).
The FSB may require additional training
beyond that which is otherwise required by
14 CFR to qualify in each type-certificated
aircraft. This training may be in the form of
LOFT, LOS, or SLF.
9. Training Device and Simulator Approval
a. Training Device and Simulator
Characteristics.
(1) Minimum Device and Simulator
Characteristics. AC 120–40 and AC 120–45
describe minimum acceptable characteristics
and standards for flight training devices and
simulators. The FSB directly applies these
standards in difference level specifications.
When applicable, the FSB specifies other
device characteristics as the minimum
acceptable for differences training, checking,
or currency between certain related aircraft.
The FSB reports identifies these
characteristics.
(2) Coordination with the FAA National
Simulator Program (NSP). When the FSB
specifies device characteristics, the FSB
coordinates with the NSET to ensure
simulator criteria compatibility and approval
process definition. If device or simulator
characteristics have not been previously
recognized by the FAA as meeting the
provisions of this AC, FSB, or the simulator
evaluation and approval process, they must
be evaluated by the NSET in consultation
with the FSB before use in an approved
program.
b. Aircraft/Simulator/Device Compatibility.
(1) Devices and Simulators to Match
Aircraft. When pilots fly related aircraft in a
mixed fleet, the combination of simulators
and training devices used must satisfy MDR
and ODR provisions specific to the aircraft
flown by that operator. The POI, FSB, and the
NSP must address the acceptability of
differences between training devices,
simulators, and aircraft operated as
appropriate. The FSB, POI, and when
necessary, the Air Transportation Division,
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AFS–200, or the General Aviation and
Commercial Division, AFS–800, as
applicable, identify acceptable credit for
simulators and training devices.
(2) Differences Between Devices,
Simulators, and Aircraft. When differences
exist between related aircraft and the
proposed training devices, or simulators to be
used, then MDRs and ODRs may be used as
guidance for acceptance and approval as is
done between aircraft. The FSB, the NSP, and
AFS–200 or AFS–800, as applicable, should
be consulted when uncertainty exists
regarding the use of MDRs and ODRs for
acceptance or approval of these devices. The
FSB will not recommend use or approval of
devices that differ significantly from the
actual operated aircraft.
c. Simulator and Device Approvals.
(1) NSP Representation to the FSB. An NSP
member may serve as an advisor to the FSB
or a member of the FSB, to address
designation of and approval processes for
devices and simulators at C, D, and E
difference levels.
(2) Coordination of NSP Criteria with the
FSB. National simulator team development of
criteria for training devices and approval test
guides for new aircraft are coordinated with
the FSB. This ensures compatibility of FSB/
NSP requirements and effective use of
resources for development of approval test
guides and determination of FSB
requirements.
10. Review and Approval
FSB reports are approved as designated by
AFS–1. In the event that revision of an FSB
report is necessary, the FSB is provided with
necessary policy guidance to implement
applicable changes.
11. Appeal of FAA Decisions
When there is disagreement with
provisions of an FSB report, that
disagreement may be expressed to the FSB
chairman for the pertinent type-certificated
aircraft. If an issue cannot be resolved, the
issue may then be addressed to AFS–200.
Additional information, data, or analysis may
be provided to support differing views
regarding the FSB provisions in question.
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APPENDIX 3.—RATINGS AND LEVEL
TESTS—PLANNING AND
APPLICATIONS
1. Preparation
2. Pilot Type Rating Determination Through
Analysis-Level A or B Training Only
3. Function Equivalence-Level A or B Test 1
(T1)
a. Test Purpose
b. Test Subjects
c. Test Process
d. Safety Pilot
e. Successful Test
f. Failure of Test
4. Handling Qualities Comparison Between
Aircraft-Test 2 (T2)
a. Test Purpose
b. Test Subjects
c. Test Process
d. Safety Pilot
e. Successful Test
f. Failure of Test
5. System Differences Test and Validation of
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Training and Checking-Test 3 (T3)
a. Test Purpose
b. Test Subjects
c. Test Process
d. Successful Test
e. Failure of Test
6. Currency Validation-Test 4 (T4)
a. Test Purpose
b. Test Subjects
c. Test Process
d. Successful Test
e. Failure of Test
7. Initial or Transition Training/Checking
Program Validation-Test 5 (T5).
a. Test Purpose
b. Test Subjects
c. Test Process
d. Successful Test
e. Failure of Test
8. Common Takeoff and Landing Credit
(CTLC)-Test 6 (T6)
a. Test Purpose
b. Test Subjects
c. Test Process
d. Successful Test
e. Failure of Test
APPENDIX 3.—RATING AND LEVEL
TESTS—PLANNING AND APPLICATION
1. Preparation
a. The pilot type rating, difference level
definition, and test process are initiated
when an applicant presents an aircraft for
type certification. If the applicant presents a
candidate aircraft to the Flight
Standardization Board (FSB) as a new aircraft
type certification with no anticipated
application for pilot type rating credit for
similarities with aircraft previously type
certificated, then the FSB analyzes the
training program requirements using test T5.
The results of T5 will determine a separate
pilot type rating and the minimum required
training, checking, and currency standards as
applicable to that type-certificated aircraft. If
the applicant presents an aircraft seeking
pilot training, checking, or currency credit,
based on similarities with an aircraft
previously type certificated, a series of
possible tests (T1/T2/T3) are developed and
used to determine its level of difference with
the base aircraft of comparison. The results
of these tests will determine whether the
aircraft pilot type rating is a common pilot
type rating between separate type-certificated
aircraft; or the same pilot type rating of same
type-certificated aircraft. The level of
differences will determine the minimum
required training, checking, and currency
standards as applicable to the candidate
aircraft. T6 comparisons may permit
Common Takeoff and Landing Credit (CTLC)
between different type-certificated aircraft. In
Appendix 2 the details of these situations
provide further amplification.
b. To begin the evaluation process, the
applicant identifies candidate aircraft. The
aircraft are then assigned to logical aircraft
groups to be described in Master Difference
Requirements (MDR) tables and the FSB
report.
c. The applicant identifies major
differences pertinent to the aircraft and
makes comparisons with the proposed
candidate aircraft. A differences document
(i.e., an appropriate sample Operator
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Difference Requirement (ODR) table)
summarizes the identified differences. Since
combinations of related aircraft may be
numerous and only typical differences are
needed at this stage for test definition, the
applicant may select representative ODRs for
preparation.
d. Based on the above analysis (including
preliminary flight test results or flight
simulation estimates, if available), the
applicant proposes difference levels to be
specified in each cell of the MDR table for
the various aircraft combinations.
e. The applicant proposes applicable
elements of the test process (T1 through T5
and T6 for CTLC) and a plan for validation
of the intended difference levels. Specific
aircraft, times, devices, etc. are identified to
conduct the required tests for the candidate
aircraft. Included in the proposal are any
necessary interpretations of expected results
using established standards. Any special,
unique, or additional definitions of
successful outcomes are also identified.
f. The scope of T1 through T6 is keyed to
basic visual flight rules (VFR) and instrument
flight rules (IFR) operations in the National
Airspace System (NAS).
g. FAA/applicant agreement is reached on
the grouping of aircraft, proposed tests, test
plans, schedules, subjects, and interpretation
of possible outcomes.
h. Subject qualifications are addressed at
the time of test specification when test
agreement is reached with the applicant. Test
subjects for all tests except T6 are drawn
from the FAA. Subject selection considers
the factors such as the following:
(1) Needed background skills of candidates
(previously qualified aircraft);
(2) General flight experience and currency;
(3) Test requirements such as location,
short notice access, and skills needed for
subjects;
(4) Technical areas, qualifications, or
experience that subjects should not have to
avoid test prejudice;
(5) Eventual FAA geographic or operator
related distribution requirements for ASI,
APM, and POI personnel; and
(6) Other special experience as needed for
a particular program.
i. During preparation for testing and
evaluation of results, appropriate Aircraft
Certification Flight Test Branch coordination
is accomplished so that flight characteristic
issues and, in particular, special flight
characteristics can be suitably identified and
addressed.
Note: Tests T1 and T2 must be conducted
in the candidate aircraft for the
determination of training, checking, and
currency requirements. However, the FSB
chairman may elect to use a simulator before
its qualification by the National Simulator
Evaluation Team (NSET). This may be done
for selected FSB T-tests that involve partialtask evaluation of systems or components,
which do not directly relate to aircraft
handling qualities or core pilot skills. These
types of tests would normally require only a
training device with no visual or motion
capabilities.
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2. Pilot Type Rating Determination Through
Analysis-Level A or B Training Only
a. Typically, with the introduction of a
new aircraft, or when training credit is
sought in a comparison of a base and
candidate aircraft, the T1 through T5 testing
process determines pilot type rating. Not all
changes or modifications to an aircraft or on
occasion, the certification of a related aircraft
may require flight-testing to assess their
impact upon pilot type rating. Pilot type
rating determination through analysis may be
considered if the changes do not influence
aircraft handling, introduce no significant
change to systems operation or pilot
procedures, and can be addressed at level A
or B training.
b. The analysis process can be used if the
aircraft handling has not changed
significantly. In most cases, it should be
obvious that the change will not affect
aircraft handling but if additional data is
needed to make the determination, the
information can be obtained from the
assigned FAA Aircraft Certification Service
(AIR) or through the applicant’s flight test
data. Following is a list of typical changes
evaluated through the analysis process:
(1) Maximum operating weights (revised
aircraft type certificate data sheet (TCDS)).
(2) An engine type or thrust change that
does not require significant design changes to
aircraft flight controls.
(3) Maximum passenger capacity (revised
aircraft TCDS).
(4) Avionic upgrades (Supplemental Type
Certificate (STC) or manufacturer production
line upgrade).
(5) Proven electronic flight bag installation,
(STC or manufacturer production line
upgrade).
(6) Passenger to cargo conversions.
c. When the analysis process is completed,
it is recorded as a revision to the training
courseware and to the existing FSB report for
the base and/or candidate aircraft.
3. Functional Equivalence-Level A or B Test
1 (T1)
a. Test Purpose. The T1 test is conducted
to determine if training level A or B is
appropriate between the base and candidate
aircraft.
Note: If the applicant communicates that
the training, checking and currency
requirements for the candidate aircraft may
exceed level B, the T1 test can be waived and
the evaluation process then moves directly to
the T2 test. By waiving the T1, the applicant
acknowledges that differences exist between
the base and candidate aircraft, and may
demand that training, checking, and/or
currency requirements up to but not
exceeding level D are applied.
b. Test Subjects. Test subjects are
designated FAA FSB members, trained,
experienced, and current on the base aircraft
with no differences training for the candidate
aircraft. The applicant may provide
proficiency training to the designated FSB
members before testing begins.
c. Test Process. The applicant initiates the
test process when they propose that the
minimum training, checking, and currency
requirements for the base and candidate
aircraft are no greater than level B
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differences. At the discretion of the FSB
chairman, the T1 test may be accomplished
in a training device/simulator or airplane as
appropriate. T1 is typically conducted using
one group of test subjects. Subjects will
initially be given a ‘‘no jeopardy’’ flight
check for their base aircraft to calibrate
performance before taking the pertinent flight
check in the candidate aircraft being
evaluated. The flight check undertaken in the
candidate aircraft will address the differences
between the base aircraft and candidate
aircraft. The test may be administered or
observed by more than one FSB member to
ensure consistency and uniformity of test
procedures and common understanding of
subject performance and outcomes.
d. Safety Pilot. A ‘‘safety pilot,’’ serving as
PIC in the aircraft and functioning as pilot
monitoring in either seat, will intervene to
prevent damage to the aircraft or to limit
maneuvers that endanger safety of flight.
e. Successful Test. FSB members decide
the outcome of the T1 test consistent with
previously agreed upon criteria. The FSB
determines the areas of differences training
required and specifies necessary devices or
training limitations. If the T1 test is passed,
the pertinent aircraft pairs are assigned to
level A or level B training differences.
Successful completion of T1 results in
awarding of the same or a common pilot type
rating.
f. Failure of Test. If the T1 test is failed and
retesting is not considered, level A or B
cannot be assigned. This generally requires
completion of T2 and T3. If requesting
training credit, the applicant may ask for and
receive credit for those items passed in T1.
T1 retesting may be considered at the
discretion of the FSB.
4. Handling Qualities Comparison Between
Aircraft-Test 2 (T2)
a. Test Purpose. The T2 test compares
handling qualities between the base and
candidate aircraft to determine whether
training level B, C, or D is appropriate. At the
discretion of the FSB chairman the T2 test
may be completed through analysis, without
requiring an aircraft flight. Determining if the
analysis process can be used requires
verification that the aircraft handling has not
changed significantly as described in the
‘‘test process’’. In most cases, it should be
obvious that the change will not affect
aircraft handling but if the determination
requires additional data, the information is
obtained from the assigned FAA Aircraft
Certification Office or through the applicant’s
flight test data. With FAA agreement,
elements of T2 may be incorporated within
the T3 test to verify that an advanced
simulator or aircraft training is not needed to
address handling qualities.
Note: If T2 is conducted on an aircraft that
is expected to require a separate pilot type
rating with CTLC, credit will be validated by
using the T6 process.
b. Test Subjects. Test subjects are
designated FAA FSB members, who are
trained, experienced and current on the base
aircraft with no differences training for the
candidate aircraft. Training to proficiency
may be provided to the designated FSB
members by the applicant before the start of
testing.
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c. Test Process. The applicant initiates the
test process when they analyze available
flight or simulation test data, and aircraft
design or system differences, and determine
that handling similarities exist between the
base and candidate aircraft. From this
determination the applicant makes their T2
proposal. Before the test, representatives of
the FSB review the T2 test profile to ensure
that critical handling quality aspects of the
candidate aircraft are examined. The flight
evaluation consists of relevant parts of a
proficiency check as determined by the FSB
chairman. T2 consists of a comparison
between selected pilot certification flight
check maneuvers (normal and nonnormal)
administered first in the base aircraft (using
either the actual aircraft or a level C or D
simulator) then in the candidate aircraft.
Although T2 testing should always be
accomplished in the candidate aircraft, some
portions that significantly affect aircraft
safety, such as flight control failures, may be
conducted in a simulator suitable for the test.
Subject pilots are evaluated on performance
of required maneuvers consistent with
standards set by 14 CFR and an assessment
of the degree of difficulty in performing
maneuvers in the candidate aircraft
compared to the base aircraft. The test may
be administered or observed by more than
one FSB member to ensure consistency and
uniformity of test procedures and common
understanding of subject performance and
outcomes.
d. Safety Pilot. The safety pilot serving as
PIC in the aircraft and functioning as pilot
monitoring in either seat, will intervene to
prevent damage to the aircraft or to limit
maneuvers which endanger safety of flight.
The safety pilot can only assist the subject
pilot in areas unrelated to the handling
qualities determination. For example, the
safety pilot can remove impediments to
progression of the test but cannot fly, coach,
or train the subject on any aspect of the test
related to handling, vision cues, or motion
cues. The safety pilot may not actuate
primary flight controls during the evaluation,
or instruct, lead, or coach test subjects in any
manner. The safety pilot may:
(1) Perform all routine pilot monitoring
duties.
(2) Set up or adjust systems, including
those normally operated by the pilot flying in
accordance with pretest agreements.
(3) Address or resolve procedural
impediments.
(4) Manage and satisfy checklists.
(5) Make normal call outs.
e. Successful Test. The FSB members
decide T2 test outcome consistent with
previously agreed upon criteria. Acceptable
pilot performance in completion of
designated maneuvers, without differences
training, establishes that the candidate and
base aircraft are sufficiently alike in handling
characteristics to permit assignment of level
B, C, or D. The test process can then advance
to differences training and the T3 test.
f. Failure of Test. Failure of T2 means that
major handling differences exist during
critical phases of flight or that numerous less
critical differences were identified that
warrant training in a full flight simulator or
aircraft. Accordingly, level E differences will
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be assigned and the FAA will issue a separate
pilot type rating. With a T2 failure, the next
step in the testing process is T5, to validate
level E requirements and the proposed
training course. Failure of the T2 does not
necessarily mean that the base and candidate
aircraft do not share a high degree of system
and/or handling commonality. The applicant
may elect to use the data collected during the
T2 process to justify approval of a shortened
pilot type rating course for pilots that are
trained on the base aircraft and are
transitioning to the candidate.
5. System Differences Test and Validation of
Training and Checking—Test 3 (T3)
a. Test Purpose. Test 3 is used to evaluate
the proposed differences training, checking,
and training devices at levels B, C, or D.
b. Test Subjects. Test subjects are
designated FAA FSB members, trained,
experienced, and current on the base aircraft
with no differences training for the candidate
aircraft. Training to proficiency may be
provided to the designated FSB members by
the applicant before the start of testing.
c. Test Process. T3 is a system differences
test and a validation of training and
checking. It is used when the equivalent
handling test (T2) is successfully completed
or when T2 is being incorporated as part of
T3. T3 is administered in two phases
following differences training of a pilot in the
candidate aircraft.
(1) First Phase. The successful completion
of a pilot certification flight check to assess
pilot knowledge, skills, and abilities
pertinent to operation of the aircraft being
tested. If a full check is proposed, the tests
are similar to those used for T1 as described
in paragraph 2 above. If a partial check is
used, the process is similar, but the FSB
determines the test items based on the
applicant‘s proposals. The first phase will
include either a proficiency check as defined
by 14 CFR, partial proficiency check, or
individual aircraft system operation check
administered to pilots in the simulator or
candidate aircraft. The check is administered
assuming currency in the base aircraft and
completion of the proposed training in the
candidate aircraft.
(2) Second Phase. Line oriented flying
(LOF) following completion of the flight
check. The LOF phase of the test is used to
validate the training and checking being
proposed, fully assess particular difference
areas, examine implications of mixed fleet
flying, assess special circumstances such as
minimum equipment list (MEL) effects, and
identify the effects of pilot errors potentially
related to the differences. The test is done in
a real line flight environment that includes
typical weather, routes, airports, air traffic
control (ATC), and other factors that are
characteristic of those in which that aircraft
will be operated. LOF tests may be conducted
in test aircraft, simulators, or with a
combination of these in conjunction with
function and reliability certification tests.
The LOF portion of the test may be used to
evaluate complex issues or issues that cannot
be fully detailed in a brief flight check since
a check only samples pilot knowledge and
skills in a limited and highly structured
environment. LOF is an integral part of T3
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and must be successfully completed before
‘‘initial’’ assignment of difference levels. In
developing and selecting scenarios for
evaluation consider the following:
(a) Likelihood of occurrence;
(b) Possible consequences; and
(c) The timeliness of pilot discovery and
correction.
d. Successful Test. The FSB members
decide the outcome of the T3 consistent with
previously agreed upon criteria and
completion of LOF with appropriate pilot
performance. Passing T3 leads to setting
respective difference levels and validates
differences training and checking at level B,
C, or D between related aircraft.
e. Failure of Test. Failure of T3 occurs with
either failure of the check, agreed criteria, or
unsatisfactory performance during the LOF
portion of the test. In certain failure cases, T3
can lead to assignment of level E and a
separate pilot type rating. The following are
examples that may lead to the assignment of
level E differences:
(1) T3 experience or difficulties that show
the need for assignment of training levels
approaching typical initial/transition levels.
(2) T3 pilot performance that indicates that
devices or methods associated with level D
are not adequate to achieve training or
checking objectives.
(3) Repeated failures of attempts to pass T3
test at level D training differences. In the case
of retesting, new subjects may be required at
the discretion of the FSB Chairman.
Note: Repeated failure of test at level D
differences by one or more subject’s (pilot)
inadequate performance, that is not an
individual subject’s failure due to sub-par or
atypical personal performance as determined
by the FSB, may lead to assignment of level
E differences.
6. Currency Validation—Test 4 (T4)
a. Test Purpose. The T4 test is a currency
test that can be used when an applicant seeks
relief from existing FSB currency
requirements. In the context of this AC,
currency addresses system procedural and
maneuver differences between related
aircraft. T4 does not include takeoff and
landing recency of experience.
b. Test Subjects. Designated FAA FSB
members.
c. Test Process. If an applicant desires a
change in the currency requirements, a T4
test may be conducted. This test may be done
before or after the aircraft enters into service.
In the event the test cannot be done before
entry into service, the FSB established limits
apply. Criteria that may be used by the FSB
to set level B, C, D differences for currency
for initial FSB determinations include the
following examples:
(1) Complex flight critical systems affecting
control or navigation.
(2) Critical nonnormal maneuvers differing
between related aircraft (e.g., V1 engine
failure, emergency descent, etc.), requiring
one acceptable demonstration/training or
checking event (typically 6 months but
demonstration period may also vary by pilot
position).
(3) Secondary systems (e.g., Oxygen or
auxiliary power unit (APU)).
d. Successful Test. The FSB members
decide the outcome of T4 consistent with
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49619
previously agreed upon criteria. A successful
test validates that the proposed less
restrictive currency provisions are accepted
as a means of compliance with applicable
rules, provisions of this AC, and/or currency
provisions and provide an equivalent level of
safety.
e. Failure of Test. Failure indicates that the
proposed less restrictive currency
requirements do not provide an equivalent
level of safety. At the discretion of the FSB,
retesting may be appropriate.
7. Initial or Transition Training/Checking
Program Validation—Test 5 (T5)
a. Test Purpose. T5 test validates the
applicant’s training course(s) at level E (new
pilot type rating). It is appropriate when:
(1) A full initial or transition training/
checking program requires validation;
(2) An applicant seeks training credits
between two aircraft with different pilot type
ratings (a typical goal under shortened
training programs); or
(3) T2 or T3 are failed.
b. Test Subjects. Designated FAA FSB
members.
c. Test Process. There are two methods to
accomplish the T5 test process:
(1) Full Initial or Transition Training/
Checking Program Validation. This method
is used when an applicant has developed an
aircraft and seeks a new pilot type rating
without any credit for commonality with any
related aircraft. The applicant develops a
training program to qualify and check pilots
in the candidate aircraft at level E
differences. Subjects are trained, given flight
proficiency checks and complete LOF in a
process similar to that described in paragraph
5.
(2) Shortened Transition Training/
Checking Program Validation. This method
is used when an applicant has developed an
aircraft and seeks a new pilot type rating and
credit for commonality with related aircraft.
The applicant conducts a handling-qualities
evaluation based on the applicant’s proposed
ODR tables (similar to T2), followed by
training and checking program validation
(similar to T3). Subjects are trained, given
flight proficiency checks and complete LOF
in a process similar to that described in
paragraph 5.
Note: When an aircraft is assigned level E
differences because of a failure of T3 test at
level D differences, credit for successfully
passing individual elements of the T3 test
may be used as justification for not
duplicating those elements in the T5 test.
d. Successful Test. The FSB members
decide the T5 outcome consistent with
previously agreed upon criteria. A successful
outcome of T5 validates the proposed
training and checking programs.
e. Failure of Test. Failing T5 indicates the
proposed training or checking programs
require modification. A retest by mutual
agreement between the FSB and applicant
would normally be required.
8. Common Takeoff and Landing Credit
(CTLC)—Test 6 (T6)
a. Test Purpose. The applicant uses T6
when they seek credit between related
aircraft toward the takeoff and landing
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recency of experience requirements of the
applicable 14 CFR parts.
b. Test Subjects. The test should consist of
a sufficient number of pilots not trained or
qualified in the candidate aircraft. These
subjects will be drawn from the
manufacturer, industry and the FAA that the
FSB determines will represent a statistically
relevant cross-section of operational pilots.
The participants’ experience levels, pilot
type ratings and airplane currency should
reflect the proficiency difference levels
needed to validate testing assumptions.
c. Test Process. Test subjects are first
provided refresher training in the base
aircraft to establish a baseline of proficiency,
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then placed in the candidate aircraft, without
any training in it, and perform a minimum
of three takeoffs and landings without use of
the autopilot. It may not be practical to
conduct some tests in an aircraft. A simulator
may be used to conduct these tests. Test
subjects should be evaluated on their ability
to fly the aircraft manually through takeoff,
initial climb, and approach and landing
(including the establishment of final landing
configuration). The applicant should
consider the effects on the takeoff and
landing maneuvers for the following factors
when designing the T6 test:
(1) Aircraft weights.
(2) Aircraft center of gravity.
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(3) Takeoff and landing crosswinds.
d. Successful Test. The FSB members
decide the outcome of T6 consistent the FAA
Practical Test Standards (PTS) demonstrating
that an equivalent level of safety can be
maintained when full or partial credit for
takeoffs and landings is given between the
related aircraft.
e. Failure of Test. The test subjects’
performance relative to the FAA PTS
demonstrates an equivalent level of safety
cannot be maintained when either full or
partial credit for takeoffs and landings is
given between the related aircraft.
[FR Doc. 07–4116 Filed 8–27–07; 8:45 am]
BILLING CODE 4910–13–C
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]]>Agencies
[Federal Register Volume 72, Number 166 (Tuesday, August 28, 2007)]
[Notices]
[Pages 49588-49620]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 07-4116]
[[Page 49587]]
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Part IV
Department of Transportation
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Federal Aviation Administration
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Proposed Advisory Circular No. 120-53A, Crew Qualification and Pilot
Type Rating Requirements; Notice
Federal Register / Vol. 72, No. 166 / Tuesday, August 28, 2007 /
Notices
[[Page 49588]]
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
[Docket Number FAA-2007-28498]
Proposed Advisory Circular No. 120-53A, Crew Qualification and
Pilot Type Rating Requirements for Transport Category Aircraft Operated
Under 14 CFR Part 121
AGENCY: Federal Aviation Administration, DOT.
ACTION: Notice of availability of a proposed advisory circular and
request for comments.
-----------------------------------------------------------------------
SUMMARY: This notice announces the availability of and requests
comments on a proposed revision to Advisory Circular (AC) No. 120-53,
Crew Qualification and Pilot Type Rating Requirements for Transport
Category Aircraft Operated under 14 CFR part 121. That AC provides the
Federal Aviation Administration (FAA) guidance for the evaluation and
approval of flight crew qualification programs and the issuance of
pilot type ratings for flight crews operating under 14 CFR part 121.
The proposed AC streamlines the process described in AC 120-53 for
determining the level of differences between aircraft and the credits
the FAA assigns between those aircraft for the purposes of training,
checking, and recency of experience requirements. The applicability of
the proposed AC would be limited to operations conducted under 14 CFR
part 121.
DATES: Comments must be received on or before October 29, 2007.
ADDRESSES: Send all comments on the proposed AC to Docket Number FAA-
2007-28498, using any of the following methods:
DOT Docket Web site: Go to https://dms.dot.gov and follow
the instructions for sending your comments electronically.
Government-wide rulemaking Web site: Go to https://
www.regulations.gov and follow the instructions for sending your
comments electronically.
Mail: Send comments to the Docket Management Facility;
U.S. Department of Transportation, 1200 New Jersey Avenue, SE., West
Building Ground Floor, Room W12-140, Washington, DC 20590.
Fax: Fax comments to the Docket Management Facility at
202-493-2251.
Hand Delivery: Bring comments to the Docket Management
Facility in Room W12-140 of the West Building Ground Floor at 1200 New
Jersey Avenue, SE., Washington, DC, between 9 a.m. and 5 p.m., Monday
through Friday, except Federal holidays.
FOR FURTHER INFORMATION CONTACT: Greg Kirkland, Air Transportation
Division (AFS-220), Federal Aviation Administration, 800 Independence
Avenue, SW., Washington, DC 20591; telephone: (202) 267-8166, e-mail
Greg.Kirkland@faa.gov.
SUPPLEMENTARY INFORMATION:
Authority: 49 U.S.C. 106(g), 40113, 44701, 44702, 44703.
Comments Invited
The proposed AC is published at the end of this notice. You may
also receive an electronic copy of the proposed AC by accessing the
FAA's web page at https://www.faa.gov/regulations_policies/rulemaking/
recently_published. Interested parties are invited to submit comments
on the proposed AC to Docket No. FAA-2007-28498. All communications
received on or before the closing date for comments will be considered
by the FAA before issuing the final AC.
Advisory Circular (AC) NO. 120-53, ``Crew Qualification and Pilot
Type Rating Requirements For Transport Category Aircraft Operated under
14 CFR part 121.''
On May 13, 1991, the FAA issued AC 120-53 to provide guidance on
the process the FAA uses when determining the level of flight crew
training required to operate an aircraft under 14 CFR part 121. The
regulations establish requirements for training, checking, and recency
of experience for flight crews operating an aircraft under part 121.
Further, the AC provides guidance for determining the level of
differences between comparative aircraft when a pair of aircraft have
similar handling or flight characteristics. An applicant may submit
documentation requesting the FAA consider the commonality in that pair
of aircraft be sufficient to allow credits for that commonality, which
may then reduce the amount of duplicative training and checking
requirements and may also reduce, for some aircraft, the recency of
experience required by 14 CFR 121.439 (a). After completion of the
comparative process, if the FAA is convinced that the two aircraft
types share sufficient common characteristics, then the FAA authorizes
qualified flight crews to receive training, checking, and in some
cases, recency of experience credits for that commonality.
Advisory Circular 120-53 standardizes the application process for
applicants and explains the training and checking credits available
when the system differences between related aircraft models are from
Level A through D. For example, a difference that amounts to no more
than a knowledge-based difference that can be addressed in pilot
training by using a computer-based course of instruction (e.g., the B-
757-200 and the B-767-200 hydraulic systems), would be a Level B
difference. On the other hand, a difference that involves full pilot
task training (e.g., visual display and switch position requirements
between the B-767-200 and the B-767-400) would be a Level D difference
necessitating pilot training in a full task training device.
The AC also explains the process for allowing full or partial
credit for recency of experience that may be permitted when aircraft
handling qualities are similar. For example, handling qualities for the
Airbus A-320, A-330, and A-340 aircraft were found to be similar,
therefore credit for recency of experience was allowed.
If an additional series of related aircraft models having similar
handling qualities and commonality of systems is type certificated, the
FAA uses the guidance in AC 120-53 when deciding to allow credit for
training, checking, and recency of experience. When difference levels
between the aircraft models do not exceed Level D, credit is usually
allowed. For example, evaluation of the differences in the flight deck
configuration (e.g., visual displays and switch positions) of the B-
767-400 determined that Level D differences existed between the B-767-
400 and the B-767-200 and B-767-300 series. Therefore, the FAA allows
credit for training and checking for Level A through D differences
between the B-767-200/300 and the B-767-400.
These credits have been provided also within families of aircraft
(same make but different models sharing commonality) with similar
handling qualities and no greater than Level D system differences.
Examples of programs that have taken advantage of these credits are:
``Common Pilot Type Rating'' used by Boeing and ``Cross Crew
Qualification'' (CCQ) used by Airbus.
Proposed Revisions to AC No. 120-53A
In view of the success of the common pilot type rating and CCQ
programs under AC 120-53, proposed AC 120-53A describes the same
process as AC 120-53 for evaluating the differences between comparative
aircraft and determining the training, checking, and recency of
experience requirements based on a commonality determination. Proposed
AC 120-53A restates certain processes to make them more easily
understood and applied by the FAA and industry in view of innovations
and
[[Page 49589]]
advancements in technology and aircraft design that were not envisioned
when AC 120-53 was written.
This proposed AC:
Updates the guidance to reflect the increasing commonality
evolving in contemporary transport category aircraft design.
Streamlines the process, with clearly defined tests, that
permit an applicant to apply for, and the FAA to allow credit for
demonstrating sufficient commonality between aircraft. The process is
updated by incorporating elements of the T2 and T4 tests into the new
T6 test.
Shifts the emphasis from documenting the commonalities to
documenting the differences between aircraft types.
Makes definitional changes. ``Common type rating'' is
replaced by ``Common pilot type rating.'' The term ``variant'' has been
eliminated and its meaning has been consolidated into one term,
``related aircraft.'' It also separates the terms ``Currency'' and
``Recent experience.''
Introduces the term ``Common Takeoff and Landing Credit''
applicable to receiving credit for recency of experience.
Updates the guidance to reflect the increasing commonality evolving
in contemporary transport category aircraft design.
Aircraft manufacturers are now designing more aircraft that share
similar handling and flight characteristics. The use of common flight
deck designs has also become prevalent. These commonalities improve the
safety of aircraft operations and provide an opportunity in the
proposed AC for the FAA to recognize this improvement in safety by
reducing the need for some duplicative training.
Streamlines the process, with clearly defined tests, that permit an
applicant to apply for, and the FAA to allow credit for demonstrating
sufficient commonality between aircraft.
This proposed AC provides a systematic means with clearly defined
tests that permit an applicant to apply for, and the FAA to allow
credit for successfully demonstrating commonality between aircraft. For
example, the T6 test criteria are clearly defined to give applicants
more standardized, specific test criteria than the current T2 and T4
tests. The T6 test requires the applicant to show a commonality within
a specific weight range, center of gravity range and maximum
demonstrated crosswind for takeoff and landing.
Shifts the emphasis from documenting the commonalities to
documenting the differences between aircraft types.
The proposed AC shifts the emphasis from documenting the
commonalities to documenting the differences between aircraft types.
The applicant would continue to show commonalities and the similarities
in handling and flight characteristics by demonstrating the absence of
differences. Where differences do exist, those differences would be
addressed by the appropriate training, checking, and recency of
experience requirements. In the proposed AC the FAA would continue to
allow credit for aircraft shown to have commonality as in AC 120-53.
Makes definitional changes.
``Common type rating'' is replaced by ``Common pilot type rating''
to show a clearer difference between a pilot type rating and a type
certificated aircraft.
The terms ``variant'' and ``related aircraft'' were used
interchangeably in AC 120-53 causing some confusion. The term
``variant'' has been eliminated and its meaning has been consolidated
into one term, ``related aircraft.'' For example, related aircraft
would be two or more aircraft of the same make (Airbus), but not
necessarily under the same type certificate (A-320, A-330 and A-340).
The AC 120-53 definitions of ``currency'' and ``recent experience''
were considered synonymous and used interchangeably. This
interchangeable use ofterms has led to confusion. The proposed revision
separates the terms to eliminate any further confusion.
Introduces the defined term Common Takeoff and Landing Credit
applicable to receiving credit for recency of experience.
A Common Takeoff and Landing Credit (CTLC) allows recency of
experience credit between related aircraft of the same make with
different type certificates that can be demonstrated to have similar
handling and flying characteristics. This credit is applied toward
meeting the requirements of 14 CFR 121.439.
Conclusion
The concept of commonality and the use of credits can reduce
unnecessary training costs while providing an acceptable method of
compliance with the existing regulations. Only the FAA can make a
determination of commonality; and while an applicant may ask the FAA
for a finding of commonality, the FAA will only make such a finding
after the FAA is satisfied that sufficient commonality exists to permit
crediting.
The history of safe operation of the B-757 and B-767 with a common
pilot type rating, and the successful use of similar programs (CCQ)
with other aircraft models by European manufacturers demonstrates that
the FAA can continue to safely allow credit for training, checking, and
recency of experience between aircraft that have demonstrated
commonality. The entire proposed AC is published with this Notice for
the convenience of the reader as Attachment 1.
Issued in Washington, DC, on August 14, 2007.
James J. Ballough,
Director, Flight Standards Service.
Attachment 1--Advisory Circular (AC) No. 120-53, Crew Qualification and
Pilot Type Rating Requirements for Transport Category Aircraft Operated
Under 14 CFR Part 121
Advisory Circular
Subject: Crew Qualification and Pilot Type Rating Requirements for
Transport Category Aircraft Operated Under Part 121.
Date: MM/DD/YY.
Initiated by: AFS-200.
[AC No: 120-53A]
This advisory circular (AC) provides an acceptable means, but not
the only means, of compliance with the Code of Federal Aviation
Regulations (CFRs) regarding qualification and type rating of flight
crewmembers operating under Part 121 of the CFRs. Included are criteria
for the determination and approval of training, checking, and currency
necessary for the operation of aircraft. This AC also describes the
process by which the Federal Aviation Administration (FAA) determines
the qualification of the pilot-in-command (PIC) or second-in-command
(SIC) of new or modified aircraft. Details of the systems, processes,
and tests necessary to apply this AC are explained in the appendices.
Provisions of this AC are intended to enhance safety by:
Providing a common method of assessing applicant programs.
Directly relating pilot training and qualification
requirements to fleet characteristics, operating concepts, and pilot
assignments.
Permitting better planning and management of fleets, pilot
assignments, and training resources by outlining what FAA requirements
apply, what training resources or devices are needed, and what
alternatives are possible.
Permitting timely and consistent decisions about fleet
acquisition, integration, modification, or phaseout associated with
pilot qualification or pilot assignments.
[[Page 49590]]
Permitting manufacturers to design aircraft that take
advantage of new technology or their similarity with existing related
aircraft, as appropriate to a particular operator`s fleet.
Encouraging cockpit standardization by crediting commonality
and identifying necessary constraints when differences exist.
Providing a framework for application of suitable credits or
constraints to better address new technology and future safety
enhancements.
1. Focus. This AC addresses aircraft manufacturers or modifiers who
design, test, and certificate aircraft as well as approved 14 CFR part
142 training centers. In addition, it applies to operators whose pilots
operate several related aircraft of the same manufacturer in a mixed
fleet and operators seeking credit for prior pilot experience with
related aircraft of the same manufacturer.
2. Cancellation. AC 120-53, Crew Qualification and Pilot Type
Rating Requirements for Transport Category Aircraft Operated Under CFR
Part 121, Dated May 13, 1991, Is Canceled.
3. Discussion.
a. A System for Pilot Qualification. The FAA specifies
qualification criteria (minimum training, checking, and currency) for
particular aircraft through Flight Standardization Board (FSB)
evaluations and findings. FSB findings are described in reports for
specific aircraft. The reports provide guidance to certificate-holding
district offices (CHDO) for use by principal operations inspectors
(POI) and other inspectors. FSB report provisions serve as a basis for
the FAA to approve operators' programs and for pilot certification.
b. Changing Needs. Necessary support for the FSB process is
provided by the industry. In the past, procedures varied by
manufacturer, individual project, operator, and other factors
including:
(1) Introduction of new and related aircraft and increases in the
significance of modifications to existing aircraft, particularly with
regard to engines or avionics.
(2) Integration of related fleets of aircraft following airline
acquisitions or mergers.
(3) Increased dependence on leased aircraft, many of which are
configured differently than an operator's basic fleet.
(4) A wider variety of equipment options available in new or
retrofit aircraft.
(5) Introduction of new technology in cockpit enhancements.
4. Summary of Revisions. This AC describes necessary revisions and
enhancements to the FSB process to address uniform, systematic, timely,
and comprehensive application of pertinent 14 CFR parts in a changing
and increasingly complex operational environment. This AC revision
deletes master common requirements due to a lack of practical
application. This AC recognizes the concept of reduced differences
between related aircraft and defines the training, checking, currency,
and recency of experience requirements.
a. This AC revision clarifies and introduces new terms and
concepts. These include:
(1) Clarification of the terms ``aircraft type certificate'' and
``related aircraft''.
(2) The difference between currency and recency of experience is
defined.
(3) A definition of ``common pilot type rating'' now including
levels A through D for any aircraft of the same make but of different
aircraft type certificates (TC).
(4) Modified checking requirements to embrace the concept of
checking only at the difference levels between related aircraft.
(5) A new term, ``common takeoff and landing credit'' (CTLC).
(6) An introduction of the T6 test to provide for CTLC (recency of
experience) in mixed fleet flying between separate type-certificated
aircraft with common takeoff and landing characteristics. The intent of
the T6 test is to provide a comparison of aircraft that have not
previously been evaluated for CTLC using the T2 test.
(7) A means to identify and evaluate new technologies that may not
be associated with an aircraft evaluation.
(8) A distinction between supervised line flying (SLF) and
operating experience (OE).
b. Additional concepts are introduced to uniformly apply the 14 CFR
parts applicable to pilot qualification and the differences. The AC's
main concepts are summarized as follows.
(1) Master Difference Requirement (MDR). Master requirements are
expressed in the form of MDRs. MDRs are requirements applicable to
pilot qualification that pertain to differences between related
aircraft. MDRs are specified by the FSB in terms of difference levels.
(2) Difference Levels. Difference levels are formally designated
levels of training methods or devices, checking methods, or currency
methods that satisfy difference requirements between related aircraft.
Difference levels specify FAA requirements proportionate to and
corresponding with increasing differences between related aircraft. A
range of five difference levels in order of increasing requirements,
identified as A through E, are each specified for training, checking,
and currency.
(3) Operator Difference Requirement (ODR). Operators show
compliance with the FAA MDRs through an operator's specific ODR, which
lists each operator`s fleet differences and compliance methods. ODRs
specify requirements uniquely applicable to a particular fleet and
mixed flying situation and are based on the MDRs. ODRs are those
operator-specific requirements necessary to address differences between
a base aircraft and one or more related aircraft, when operating in
mixed fleet flying or seeking credit in transition programs. ODRs
include both a description of differences and a corresponding list of
minimum training, checking, and currency compliance methods that
address pertinent FSB requirements.
Note: These and other concepts are more fully described in the
appendices.
5. Setting FAA Requirements. The FSB process is made up of proposal
development, testing, draft requirement formulation, FSB final
determinations and FAA approval.
a. Applicants' Proposals. Aircraft manufacturers or modifiers
usually initiate proposals for formulation or amendment of FSB
requirements. This is done in conjunction with application for aircraft
type certification or supplemental type certification of an aircraft or
system. The FAA, operators, and, in certain instances, other
organizations or individuals, may initiate proposals or amendments.
b. Standardized Tests. A main element of the requirements
formulation process is the use of standardized testing to determine
pilot qualification requirements. One or more of six tests are applied
depending on the proposal's degree of differences between related
aircraft, difference levels sought, and the outcome of any previous
tests. Only the necessary tests are used. Tests may be waived or
difference levels may be assigned based on operational experience.
c. FAA Formulation and Implementation of Requirements. Following
testing and formulation of draft requirements, FSB requirement
determinations are then made specifying MDRs and any necessary
supporting information. Supporting information may pertain to operator
certification, airmen certification, approval of devices and
simulators, and other items necessary for proper application of MDRs.
FSB reports will be used in the evaluation, certification, and approval
of operators' programs.
[[Page 49591]]
d. Revision of Requirements. FSB reports are periodically updated
when new or modified aircraft are introduced, when requested by an
applicant based on OE, or when the FAA determines it is necessary for
safety reasons.
e. Pilot Type Ratings. A new pilot type rating is typically
assigned when level E training differences are determined between the
candidate aircraft and the base aircraft. The pilot type rating
determination and any training, checking, and currency specifications
established under the testing process of this AC are determined by
evaluating the handling qualities and core pilot skills related to the
candidate aircraft. Systems such as heads-up display (HUD), Enhanced
Vision Systems (EVS), or Synthetic Visions Systems (SVS) may require
Level E training without requiring a new pilot type rating. The FSB,
with the concurrence of the Air Transportation Division, AFS-200, will
make this determination.
f. Common Pilot Type Rating. A common pilot type rating is assigned
when no greater than level D training differences are determined
between aircraft of the same type with different aircraft TCs.
g. Same Pilot Type Rating. A same pilot type rating is assigned
when no greater than level D training differences are determined
between aircraft with the same aircraft TCs (series).
6. Operator Compliance with FAA Requirements.
a. Obtaining FSB Information. Operators are advised of pertinent
FSB information through FAA CHDOs and POIs. Operators may also obtain
FSB information from aircraft manufacturers or modifiers, other
operators, or other aviation organizations that maintain awareness of
FAA policies, and the Web site https://www.opspecs.com.
b. Certificated Operator Compliance with Mixed Fleet Flying. When
aircraft are flown in mixed fleets, certificated operators will comply
with MDRs and other FSB difference provisions. Certificated operators
accomplish this by identifying a base aircraft, describing differences
that exist between their base aircraft and the candidate aircraft, and
by specifying particular means of compliance to satisfy MDRs. Sample
FSB ODRs provide guidance for the approval of an operator's mixed fleet
flying program and specify necessary constraints or permissible
credits. The description of specific differences and compliance methods
are identified in the operator's ODRs. Constraints or credits may
relate to knowledge, skills, devices, simulators, maneuvers, checks,
currency, or any other factors necessary for safe operations.
Constraints or credits may be applied generally or only to specific
aircraft or pilot positions. Once approved, the operator's program must
be conducted in accordance with (IAW) these approved ODRs. ODR
proposals are provided to the FAA CHDO in a standard tabular format and
are approved by POIs only if they meet MDRs and other pertinent FSB
requirements. The operator must apply to amend the ODRs when changes
occur in the base aircraft, comparison aircraft, and/or training
devices that affect the approval basis of the ODRs.
c. Credit between Programs. In addition to mixed fleet flying, ODRs
may be used to permit credit between related aircraft in differences or
transition training and checking programs, consistent with FSB
provisions.
7. FAA Approval of Operator Programs.
a. POI Approval. FAA POIs approve operator programs when those
programs comply with FSB provisions. If less restrictive programs are
proposed, POIs advise the applicant that:
(1) A request for change of the MDRs must be initiated;
(2) The differences between related aircraft must be reduced or
eliminated; or
(3) An alternate approval must be sought.
Note: An example of such a request is an exemption to the
applicable requirement of the training section of the operational
rule under which the operation is conducted.
b. Limitations of POI Authority. When applicable, POIs may
approve programs within provisions of the FSB report and this AC. AC
provisions apply because other general constraints are identified
such as a limitation on the number of different related aircraft
that can be used in mixed fleet flying. POIs shall not approve
programs outside the bounds of FSB or AC provisions without the
authorization of AFS-200. Deviation from FSB or AC provisions will
be approved by AFS-200, only when an equivalent level of safety can
be demonstrated.
8. Application of FSB Requirements to Airmen Certification. The
evaluation items that FSB reports specify include the following:
Knowledge;
Skills;
Abilities;
Maneuvers;
Performance criteria; and
Other relevant items for proficiency checking or other
checks/tests may be identified. This is appropriate to address any
aircraft-specific factors affecting the safe operation of that aircraft
operated under 14 CFR.
9. Training Device and Simulator Approvals.
a. Standard Devices or Simulators. Standardized training methods,
devices, or simulators are associated with each of the training
difference levels. Devices or simulators are approved for particular
operators by their POIs, consistent with National Simulator Program
(NSP) qualification and FSB master requirements.
b. Special Criteria. In some instances, standard device or
simulator criteria may not be appropriate for new technology. The FSB
may specify additional criteria in FSB reports in these instances.
10. Review and Approval. This is a process for review of FSB
evaluations and approval of FSB reports.
11. Appeal of FAA Decisions. The Director, Flight Standards
Service, AFS-1, assigns responsibility to resolve appeals of the FSB
findings.
James Ballough,
Director, Flight Standards Service.
APPENDIX 1.--DEFINITIONS AND REFERENCES
Table of Contents
1. Definitions
2. References (current editions)
Appendix 1.--Definitions and References
1. Definitions.
Note: Definitions provided in Appendix 1 apply exclusively to
this advisory circular (AC).
Aircraft Evaluation Group (AEG). FAA organization that sets
training, checking, currency, pilot type rating, Master Minimum
Equipment List (MMEL), and maintenance standards Maintenance Review
Board (MRB) for assigned certificated aircraft types. AEGs also
address operational aspects of aircraft type certification and
resolution of service difficulties.
Applicant. For the purposes of this AC, an applicant may be a
manufacturer, modifier, or operator.
Base Aircraft. An aircraft designated by the applicant used as a
reference to compare differences with another aircraft.
Candidate Aircraft. The aircraft that will be subjected to the
FSB evaluation process outlined in this AC for comparison purposes.
Common Pilot Type Rating. A pilot license endorsement between
separate type-certificated aircraft for the purposes of pilot type
rating that passes the testing criteria of the T1 (equivalence) or
the T2 (handling characteristics) and T3 (core pilot skills with no
greater than level D differences). A common pilot type rating
endorsement is issued after a pilot has received differences
training and checking, where required, on the type-certificated
aircraft for which there is a common pilot type rating designation.
The pilot who is receiving the additional endorsement must be
current and qualified in the base aircraft; since, the check is not
a ``full'' proficiency check as defined by Title 14 of the Code of
Federal Regulations (14 CFR), but an abbreviated differences check
[[Page 49592]]
on the differences from the base to the candidate aircraft. The
differences check, unless it includes the requirements for a
recurrent check, cannot reset the ``recurrent clock'' (a pilot`s
base month for checking purposes).
Common Takeoff and Landing Credit (CTLC). CTLC is a program/
process that allows recency of experience credit between related
aircraft (same make) with different type certificate data sheets
(TCDS) that can be demonstrated to have the same handling and flying
characteristics during the following:
Takeoff and initial climb; and
Approach and landing, including the establishment of
final landing configuration.
Note: The T6 test is used for aircraft that were not tested (T2)
during the initial aircraft evaluation for pilot type rating
designation.
Configuration. Aircraft physical features, which are
distinguishable by pilots, with respect to differences in systems,
cockpit geometry, visual cutoff angles, controls, displays, aircraft
geometry, and/or number of required pilots.
Currency. Currency is the recent experience necessary for the
safe operation of aircraft, equipment, and systems as designated by
the Flight Standardization Board (FSB).
Difference Levels. Difference levels are formally designated
levels of training methods or devices, checking methods, or currency
methods that satisfy differences requirements between related
aircraft. A range of five difference levels in order of increasing
requirements, identified as A through E, are specified for training,
checking, and currency purposes.
Differences Training. Training required before any person may
serve as a required crewmember on an aircraft of a type for which
differences training is included in the certificate holder`s
approved training program.
Differences Check. A partial proficiency check of the
qualification of a pilot at the difference levels between related
aircraft. A differences check can be between series of the same
aircraft type certificate (TC) or between aircraft of separate
aircraft TCs of the same manufacturer.
Flight Characteristics. Flight characteristics are handling
characteristics or performance characteristics perceivable by a
pilot. Flight characteristics relate to the natural aerodynamic
response of an aircraft, particularly as affected by changes in
configuration and/or flight path parameters (e.g., flight control
use, flap extension/retraction, airspeed change, etc.).
Flight Operations Evaluation Board (FOEB). The FOEB is
responsible for preparation and revision of MMELs. The board members
are drawn from the FAA.
Flight Standardization Board (FSB). The FSB is responsible for
specification of minimum training, checking, currency, and pilot
type rating requirements, if necessary, for U.S. certificated civil
aircraft. The board members are drawn from the FAA (AEG,
Headquarters, Flight Standards field offices operations personnel).
Handling Characteristics. The manner in which the aircraft
responds with respect to rate and magnitude of pilot initiated
control inputs to the primary flight control surfaces (e.g.,
ailerons, elevator, rudder, spoilers, cyclic, collective, etc.).
Line Oriented Simulation (LOS). Use of a simulator in place of
the aircraft to reinforce the understanding of differences between
related aircraft. LOS should not be confused with operating
experience (OE), which is required by 14 CFR.
Line Operational Flying (LOF). The LOF phase of the test is used
at the discretion of the FSB during the T3 test to validate the
proposed training and checking. The LOF fully assesses particular
difference areas, examines implications of mixed fleet flying,
assesses special circumstances such as minimum equipment list (MEL)
effects, and evaluates the effects of pilot errors potentially
associated with the differences.
Master Difference Requirements (MDR). MDRs are those
requirements applicable to pilot qualifications that pertains to
differences between related aircraft. MDRs are specified by the FSB
in terms of the minimum difference levels. MDRs form the basis for
an operator to develop their operator differences requirements
(ODR).
Mixed Fleet Flying. Mixed fleet flying is the operation of a
base aircraft and one or more related aircraft for which credit may
be taken for training and/or checking events. The FSB process
defines minimum training and checking difference levels between
related aircraft.
Operational Characteristics. As used with respect to aircraft,
means those features that are distinguishable by limitations, flight
characteristics, normal procedures, nonnormal procedures, alternate
or supplementary procedures, or maneuvers.
Operator Difference Requirements (ODR). If differences exist
within an operator`s fleet that affect pilot knowledge, skills, or
abilities pertinent to systems or procedures, ODR tables provide a
uniform means for operators to comprehensively manage difference
programs and provide a basis for FAA approval of mixed fleet flying.
Pilot Type Rating. A pilot type rating is a ``one time'',
permanent endorsement on a pilot certificate indicating that the
holder of the certificate has completed the appropriate training and
testing required for its issuance as determined by regulation and by
the applicable FSB report. It is recorded by the FAA on the pilot`s
certificate indicating the make, model, and series of aircraft, if
applicable. Title 14 CFR requires a pilot type rating to serve as
pilot-in-command (PIC) and in some cases as second-in-command (SIC)
of U.S. civil large or turbojet aircraft.
Recency of Experience. With respect to flight experience as
required by 14 CFR, means a pilot's completion of the required
number of takeoffs and landings as sole manipulator of the controls
within the preceding 90 days.
Related Aircraft. Related aircraft are any two or more aircraft
of the same make that have been demonstrated and determined to have
commonality to the extent that credit between those aircraft may be
applied for training, checking, or currency, as documented through
MDR and approved by the FSB.
Same Pilot Type Rating. A pilot type rating assigned when no
greater than a level D training difference is determined between
aircraft with the same aircraft TCs (series).
Series. Aircraft sharing the same aircraft type certification
with specific variations that are usually defined by the
manufacturer and usually result in an amended aircraft TC.
Supplementary Procedures. Those procedures that are identified
in the Flight Crew Operation Manual (FCOM) under the section
``Supplementary Procedures'' describing procedures not described
under the ``Normal Procedures'' or ``Nonnormal Procedures''
sections.
Supervised Line Flying (SLF). Supervised experience associated
with the introduction of equipment or procedures requiring post
qualification skill enhancement during which a pilot occupies a
specific pilot position and performs particular assigned duties for
that pilot position under the supervision of a qualified company
instructor or check airman.
Training Footprint. A training footprint is a summary
description of a training program, usually in short tabular form,
showing training subjects, modules, procedures, maneuvers or other
program elements, which are planned for completion during each day
or phase of training.
2. References (Current Editions)
Title 14 CFR parts 1, 61, 91, 135, and 121.
Order 8400.10, Air Transport Operations Inspector's
Handbook.
AC 61-89, Pilot Certificates, Aircraft Type Ratings.
AC 120-35, Line Operational Simulations: Line Oriented
Flight Training, Special Purpose Operational Training, Line
Operational Evaluation.
AC 120-40, Airplane Simulator Qualification.
AC 120-45, Airplane Flight Training Device
Qualification.
AC 120-51, Crew Resource Management Training.
FAA-S-8081-5, Aircraft Type Rating Practical Test
Standards for Airplane.
APPENDIX 2.--PILOT QUALIFICATION AND PILOT RATING REQUIREMENTS
Table of Contents
1. Purpose
2. Focus
3. Introduction
a. A Comprehensive System for Pilot Qualification
b. Master Differences Requirements (MDR) Set by FAA
c. Specifications of Constraints or Credits
d. Recognition of Unique Operator Characteristics
e. Basis for Requirements
f. Relation to Other FAA Policies
4. Concepts
a. An Integrated System for Pilot Qualification
b. MDRs
c. Difference Levels
d. Training Difference Levels
e. Checking Difference Levels
f. Currency Difference Levels
[[Page 49593]]
g. Operating Experience (OE) for Aircraft
h. Supervised Line Flying (SLF)
i. Recency of Experience
j. Operator Difference Requirements (ODR)
5. Formulation of FSB Reports, MDRS, and Designation of Pilot Type
Ratings
a. Requirements Formulation Process Overview
b. Proposals for MDRs, Example ODRs, and Special Requirements
c. Difference Level Tests
d. FSB Assessments and Proposal Formulation
e. Comments Solicited
f. FSB Determinations and Findings
g. FSB Report Preparation Distribution and FAA Application
h. FSB Report Revision
6. Operator's Application of FSB Provisions, Preparations, Use, and
Revision of ODRS
a. General
b. Application of MDRs and Preparation and Use of ODRs
c. Selecting Base Aircraft
d. Identification of Differences and the Analysis of Effects of
Those Differences
e. Identification of Compliance Methods
f. When Proposed ODR Compliance Methods Do Not Meet MDRs
g. Maximum Number of Related Aircraft
h. Application, Review and Approval
i. Implementation Provisions Transition Period
j. ODR Revision
7. FAA Review and Approval of Operator Programs
a. General
b. Operator's Application of ODRs
c. Base and Other Aircraft Identification
d. Approval of ODRs
e. POI Uncertainty Regarding Program Compliance
f. Proposals That Do Not Comply With FSB Provisions
g. FSB Revision of MDRs or Other FSB Provisions
h. Proving Tests
i. Line-Oriented Flight Training (LOFT), LOS, or SLF
j. OE
k. Limitations on the Total Number of Related Aircraft
l. Compliance Checklist for CHDOs
m. Implementation of FSB Provisions
n. Aircraft That Do Not Have an FSB Report
8. Application of Requirements to Airmen Certification
a. General
b. Checking Specifications
c. Checks Regarding Complex Systems
9. Training Device and Simulator Approval
a. Training Device and Simulator Characteristics
b. Aircraft/Simulator/Device Compatibility
c. Simulator and Device Approvals
10. Review and Approval
11. Appeal of FAA Decisions
Illustrations
Figure 1 Master Difference Requirements (MDR) Table Example
Figure 2 Difference Level Table
Figure 3-1 Design Operator Differences Requirements Table Example
Figure 3-2 Systems Operator Differences Requirements Table Example
Figure 3-3 Maneuver Operator Difference Requirements Table Example
Figure 4 Master Requirements Formulation
Figure 5 Test Definitions
Figure 6 ``T'' Tests 1 Thru 5
Figure 7 Standard Method, Devices, and Simulators
Figure 8 FSB Process
APPENDIX 2.--PILOT QUALIFICATION AND PILOT RATING REQUIREMENTS
1. Purpose
This appendix provides a comprehensive description of the system
for pilot qualifications outlined in this advisory circular (AC). It
includes definitions, criteria, processes, tests, methods, and
procedures necessary for uniform application of the system.
2. Focus
The appendix applies to and is used by:
a. Aircraft manufacturers or modifiers who design, test, and
certificate Title 14 of the Code of Federal Regulations (14 CFR)
parts 23, 25, 27, and 29 aircraft.
b. Operators who operate under 14 CFR.
c. Operator, manufacturer, or other training centers having
programs approved for use under 14 CFR.
d. Federal Aviation Administration (FAA) offices and inspectors
administering programs under 14 CFR.
3. Introduction
a. A Comprehensive System for Pilot Qualification. This AC and
its appendices provide a systematic means to address requirements
for training, checking, and currency within applicable 14 CFR parts.
Definitions, criteria, processes, procedures, tests, and methods are
consistent with and clarify application of current rules in
particular situations for specific aircraft. This AC provides a
comprehensive system for the FAA and industry to describe, evaluate,
and approve use of particular aircraft and operator programs. The
respective roles of training, checking, currency and airmen
certification are clarified. This includes defining the role and
criteria for designation of pilot type ratings for existing, new, or
modified aircraft. The system is particularly suited to addressing
transition, differences programs, and mixed fleet flying. The system
aids in assuring that pilots attain and maintain the knowledge,
skills, and abilities needed to operate assigned aircraft safely.
b. Master Differences Requirements (MDRs) Set by FAA. The FAA's
Flight Standardization Board (FSB) sets MDRs to address differences
between related aircraft.
c. Specification of Constraints or Credits. The system permits
the specification of constraints or permissible credits. Constraints
or credits may relate to knowledge, skills, abilities, devices,
simulators, maneuvers, checks, currency, or any other such factors
necessary for safe operations. Constraints or credits may apply
generally to aircraft, particular pilot positions, or other
situations or conditions.
d. Recognition of Unique Operator Characteristics. The system
recognizes the unique characteristics of individual operators while
achieving uniformity in application of FAA safety standards. FAA
MDRs determine uniform bounds to tailor individual operator's unique
requirements to a particular fleet and situation. Principal
operations inspectors (POI) approve each operator's unique
requirements within FAA MDRs. Operator unique requirements
accommodate particular combinations of related aircraft flown, pilot
assignment policies, training methods and devices, and other factors
that relate to the application of the FAA MDRs. Accordingly, the
system preserves operator flexibility while standardizing the FAA's
role in review, approval, and monitoring of training, checking, and
currency programs within 14 CFR.
e. Basis for Requirements. The determination of pilot type
rating, minimum differences training, checking and currency
requirements focus on basic operation of aircraft in the National
Airspace System (NAS) under both instrument flight rules (IFRs) and
visual flight rules (VFR). Included are all flight phases from
preflight to shutdown under both normal and nonnormal conditions.
f. Relationship to Other FAA Policies. Although this AC, and the
FSB requirements in some instances, address particular types of
operations or specific aircraft systems (e.g., use of flight
guidance control systems for Category II/III instrument approaches,
long-range navigation, etc.), other ACs address these issues more
thoroughly. This AC and FSB requirements address such issues only to
the extent necessary to assure that pilots are qualified to operate
pertinent systems or equipment as part of initial or continuing
qualification.
4. Concepts
a. An Integrated System for Pilot Qualification.
(1) System Elements. An integrated FAA/applicant system and
process established to determine appropriate requirements, applies
the requirements, and meets those requirements on a continuing
basis, for uniform pilot qualification.
(2) System Overview. The system uniformly applies FAA master
requirements in a way that tailors a particular aircraft to any
operator's unique situation or fleet. The FAA approves unique
operator and fleet requirements for each operator based on FAA
master requirements. The system develops FAA master requirements
based on objective criteria and tests, with applicants' support for
analysis and testing. FSB reports for related aircraft describe FAA
master requirements. MDRs express FAA master requirements. Minimum
acceptable difference levels between related aircraft articulate
MDRs. An operator's training program, checklist, operations manuals,
pilot certification, CTLC programs, and other such approvals are by-
products of compliance with MDRs. Operators comply with MDRs using
unique ODRs, tailored to that operator's programs and approved by
the FAA. ODRs, based on and in compliance with the MDRs, specify
requirements uniquely applicable to a particular operator's mixed
fleet flying situation. An operator's specific document
[[Page 49594]]
describes ODRs by identifying a base aircraft, differences between
related aircraft, and that operator's compliance methods for each
related aircraft. Paragraph 4j describes ODRs. Paragraph 6 describes
ODR preparation and use. Paragraph 7 describes FAA approval of ODRs.
b. MDRs.
(1) MDR Applicability. MDRs are those requirements applicable to
pilot qualification that pertain to differences between related
aircraft. MDRs specify the minimum acceptable difference levels
between related aircraft that may be approved for operators. One
related aircraft is selected by the applicant as a reference for
comparison purposes and is considered a base aircraft. This is
typically the first aircraft on which pilots are qualified, or is
the aircraft of which an operator has the largest number. Difference
levels between the base aircraft and other related aircraft then
specify the minimum difference requirements to be met for pilot
qualification. Major differences in a particular fleet are defined
between groups of related aircraft rather than specifying
differences between each possible configuration and combination of
configurations between related aircraft. MDRs are specified in terms
of training difference levels described in paragraph 4d and are
shown on an MDR table.
(2) MDR Content. MDRs specify the minimum training, checking,
and currency acceptable to the FAA for pilot qualification regarding
differences.
(3) MDR Formulation, Description, and Revision. MDRs are
formulated by the FAA FSB for each related aircraft. MDRs are
originally specified when an aircraft is first type certificated.
MDRs are formulated using standardized tests and evaluations in
conjunction with the type certification or supplemental type
certification process. MDRs are based on an applicant's (usually an
aircraft manufacturer) proposal, FAA evaluation of that proposal,
OE, and test results when tests are necessary. FSB determinations
also consider operator recommendations, safety history, and other
relevant information. MDRs are described in provisions of an FSB
report and may be revised if necessary. MDRs are revised when
aircraft are developed or modified, tests or OE shows a need for
revision, a revision is requested by an applicant and evidence
indicates the need for revision, or rules or FAA policies change.
MDRs are revised by a process similar to that used for initial
formulation of requirements.
(4) MDR Use. MDRs are applied to specific operators through
formally described ODRs that are developed by and tailored to each
operator. FAA field offices use the MDRs as the basis for approval
of individual operator's differences programs for approval of
initial or transition programs where credit for previous training or
experience with other related aircraft is sought.
(5) The MDR Table. An example of typical MDRs for the B-737-200,
-300, -400, -500, -600, -700, -800, and -900 is shown in Figure 1.
MDR table requirements are shown for each pair of aircraft by
notations in each element of corresponding columns and rows of the
table. Each element of the table identifies the minimum differences
training, checking, and currency requirements applicable to mixed
fleet flying. The MDR table identifies a pertinent base aircraft and
particular aircraft for which requirements are sought. Note the
minimum difference levels that correspond to the pertinent column
and row, and special requirements in footnotes, if applicable.
(6) Use of Higher or Lower Difference Levels. Operators must
satisfy difference requirements by using the methods acceptable for
the specified level or a higher level. Lower level methods may be
used in addition to the required levels but may not substitute for
the required level or be used exclusively instead of the required
level.
[[Page 49595]]
[GRAPHIC] [TIFF OMITTED] TN28AU07.001
(7) Differences Within a Series. Differences may exist even
within series shown on an MDR table, such as within the A-318/319/
320/321 series. MDR elements may show requirements from one series
to another identified in the footnotes. Such requirements, however,
apply only if pertinent differences exist between those aircraft.
(8) More Than Two Related Aircraft. When pilot assignments apply
to more than two related aircraft, such as the A-320, A-330, and A-
340, each pertinent requirement of the MDR table applies.
Applications of multiple requirements for flying two or more related
aircraft and certain limits to flying large numbers of related
aircraft are described in paragraph 7k.
(9) Special Requirements.
(10) MDR Footnotes. Footnotes can be used to credit, constrain,
or set alternate levels when special situations apply. Use of
footnotes permits accommodation of variations in installed
equipment, options, pilot knowledge or experience on other aircraft,
training methods or devices, or other factors that are not addressed
by basic levels between aircraft. For example, a footnote may allow
credit or apply constraints to the use of a particular flight
guidance control system (FGCS), flight management system (FMS), or
electronic flight instrument system (EFIS), which is installed on
aircraft. Footnotes are an appropriate means to address requirements
that relate to specific systems (e.g., flight director and FMS)
rather than a particular aircraft. In such instances, generic
knowledge or experience with the particular system may be readily
transferable between related aircraft. Footnotes may also be used to
set different requirements for initial training or checking rather
than for recurrent training or checking. When necessary, footnotes
are fully described in the body of the FSB report.
(a) Other Limitations. Other limitations may occasionally be
identified within a difference level (e.g., C*/C*/C). The asterisk
following the difference level in such instances identifies a
special requirement or limitation pertaining to a particular
training method or device. Such notes typically relate to acceptable
training device characteristics when the simulator evaluation and
approval process or standard criteria of this AC are not available
to address a particular situation appropriately.
(11) MDRs for Aircraft With the Same or Common Pilot Type
Ratings. A single FSB report and MDR table may apply to aircraft
that are assigned the same pilot type rating (same aircraft TC). For
example, a single MDR table may cover the A-318/319/320/321 that
have a same pilot type rating. A single FSB report and MDR table may
also apply to aircraft that are assigned a common pilot type rating.
For example, a single MDR table may cover both the B-767 and B-757
that have a common pilot type rating. When level E training is
required for an aircraft with the same aircraft TC and an additional
pilot type rating is assigned, such as the B-747 and B-
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747-400, a single MDR table for all series of a type-certificated
aircraft still applies.
(12) Minimum acceptable difference levels are assigned based on
standard tests described in Appendix 3.
c. Difference Levels.
(1) General Description. Difference levels are formally
designated levels of training methods or devices, checking methods,
or means of maintaining currency that satisfy minimum difference
requirements or pilot type rating requirements. Difference levels
specify FAA requirements proportionate to and corresponding with
increasing differences between related aircraft. A range of five
difference levels in order of increasing requirements, identified as
A through E, are each specified for training, checking, and
currency. MDRs are specified in terms of difference levels.
Difference levels are used to credit knowledge, skills, and
abilities applicable to an aircraft for which a pilot is already
qualified and current, during initial, transition or upgrade
training for other related aircraft. Operators, who conduct mixed
fleet flying where credit is sought, should apply difference levels
and address all mixed fleet flying requirements to ensure compliance
with FAA requirements necessary to assure safe operations.
(2) Basis for Levels. Difference levels apply when a difference
with potential to affect fight safety exists between related
aircraft. Differences may also affect knowledge, skills, or
abilities required of a pilot. If no differences exist or if
differences exist but do not affect knowledge, skills, abilities or
flight safety, then difference levels are not assigned or applicable
to pilot qualification. When difference levels A through E apply,
each difference level is based on a scale of differences in design
features, systems, or maneuvers. In assessing the effects of
differences, both flight characteristics and procedures are
considered, since flight characteristics address handling qualities
and performance, while procedures include normal and abnormal/
nonnormal/emergency items.
(3) Relationship Between Training, Checking, and Currency
Levels. While particular aircraft are often assigned the same level
(e.g., C/C/C) for training, checking, and currency, such assignment
is not necessary. Levels may be assigned independently. For example,
an aircraft may be assigned level C for training, level D for
checking, and level C for currency (e.g., C/D/C).
(4) Designation of a Pilot Type Rating. Candidate aircraft
having the same TC are assigned the same pilot type rating if
training differences are not greater than level D. Candidate
aircraft having different TCs that have training differences no
greater than level D may be assigned a common pilot type rating. A
candidate aircraft is assigned a different pilot type rating when
difference training level E is required. When different pilot type
ratings are assigned because of one or more candidates requiring
level E training, pilot type ratings may be assigned to related
aircraft consistent with a logical grouping of the most similarly
related aircraft.
d. Training Difference Levels.
(1) Level A Training. Level A difference training is that
differences training between related aircraft that can adequately be
addressed through self-instruction. Level A training represents a
knowledge requirement that, once appropriate information is
provided, understanding and compliance can be assumed. Level A
compliance is achieved by such methods as issuance of operating
manual page revisions, dissemination of operating bulletins, or
differences handouts to describe minor differences in aircraft.
Level A training is limited to the following situations:
(a) A change that introduces a different version of a system/
component for which the pilot has already shown the ability to
understand and use (e.g., an updated version of an engine).
(b) A change that results in minor or no procedural changes and
does not adversely affect safety if the information is not reviewed
or forgotten (e.g., a different vibration damping engine mount is
installed, expect more vibration in descent; logo lights are
installed, use is optional).
(c) Information that highlights a difference, which is evident
to the pilot, inherently obvious, and easily accommodated (e.g.,
different location of a communication radio panel, a different
exhaust gas temperature limit that is placarded, or changes to
nonnormal ``read and do'' procedures).
(2) Level B Training. Level B difference training is applicable
to aircraft with system or procedure differences that can adequately
be addressed through aided instruction. At level B, aided
instruction is appropriate to ensure pilot understanding, emphasize
issues, provide a standardized method of presenting material, or aid
retention of material following training. Level B aided instruction
can utilize slide/tape presentations, computer based tutorial
instruction, stand-up lectures or video tapes. Situations not
covered under the provisions of level A training may require level B
(or higher levels) if certain tests described in later paragraphs
fail.
(3) Level C Training. Level C differences training can only be
accomplished through use of devices that are capable of systems
training. Level C differences training is applicable to related
aircraft having part task differences that affect skills or
abilities and knowledge. Training objectives focus on mastering
individual systems, procedures, or tasks, as opposed to performing
highly integrated flight operations and maneuvers in ``real time.''
Level C may require self-instruction or aided instruction, but
cannot be adequately addressed by a knowledge requirement alone.
Training devices are required to supplement instruction, ensure
attainment or retention of pilot skills and abilities, and
accomplish the more complex tasks, usually related to operation of
particular aircraft systems. While level C systems knowledge or
skills relate to specific rather than fully integrated tasks,
performance of steps to accomplish normal, nonnormal, alternate,
recall procedures, or maneuvers related to particular systems (e.g.,
flight guidance control systems/flight management systems) may be
necessary. Typically, the minimum acceptable training media for
level C training would be interactive computer-based training,
cockpit systems simulators, cockpit procedure trainers or part task
trainers (e.g., FMS or traffic collision avoidance system (TCAS)).
(4) Level D Training. Level D training can only be accomplished
with devices capable of performing flight maneuvers and addressing
full task differences of knowledge, skills, and/or abilities.
Devices capable of flight maneuvers address full task performance in
a dynamic real time environment. The devices enable integration of
knowledge, skills, and abilities in a simulated flight environment,
involving combinations of operationally oriented tasks and realistic
task loading for each relevant phase of flight. Level D training,
knowledge, and skills to complete necessary normal, nonnormal,
alternate, or recall procedures are fully addressed for each related
aircraft. Level D differences training requires mastery of
interrelated skills that cannot be adequately addressed by separate
acquisition of a series of knowledge areas or skills that are
interrelated. The differences are not so significant that a full
transition training course is required. If demonstrating
interrelationships between the systems is important, use of a series
of separate devices for systems training will not suffice. Training
for level D differences requires a training device that has
accurate, high fidelity integration of systems and controls, and
realistic instrument indications. Level D training may also require
maneuvers, visual cues, motion cues, dynamics, control loading or
specific environmental conditions. Weather phenomenon such as low
visibility, CAT III, or windshear may or may not be incorporated.
Where simplified or generic characteristics of an aircraft type are
used in devices to satisfy difference level D training, significant
negative training must not occur as a result of the simplification.
Typically, the minimum acceptable training media for level D
training would be flight training device level 6.
(5) Level E Training. Level E training is applicable to
candidate aircraft having such significant full task differences
that require a ``high fidelity'' environment to attain or maintain
knowledge, skills, or abilities. Training at level E can only be
satisfied by the use of a simulator qualified at level C or D
consistent with FAA criteria. Level E training, if done in an
aircraft, should be modified for safety reasons where maneuvers can
result in a high degree of risk (i.e., an engine set at idle thrust
to simulate an engine failure). As with other levels, when level E
training is assigned, suitable credit or constraints may be applied
for knowledge, skills, and/or abilities related to other pertinent
related aircraft. Credits or constraints are specified for the
subjects, procedures, or maneuvers shown in FSB reports and are
applied through the ODR table.
Note: Training differences levels specified by the FSB represent
minimum requirements. Operators may use a device associated with a
higher difference level to satisfy a training differences
requirement. For example, if level C differences are assessed due to
installation of a different FMS, operators may train pilots using
the FMS installed in a full flight simulator (FFS) as a system
trainer if a
[[Page 49597]]
dedicated part task FMS training device is not available.
e. Checking Difference Levels.
(1) Initial and Recurrent Checking. Difference checking
addresses any pertinent pilot testing or certification that includes
pilot type rating checks, proficiency checks, Advanced Qualification
Program (AQP) evaluations, and any other checks specified by FSB
reports. Initial and recurrent checking levels are the same unless
otherwise specified by the FSB. In certain instances, it may be
possible to satisfactorily accomplish recurrent checking objectives
in devices that do not meet initial checking requirements. In such
instances, the FSB may recommend certain devices that do not meet
initial check requirements for use to administer recurring checks.
The POI/Training Center Program Manager, in coordination with the
FSB, may require checking in the initial level device when doubt
exists regarding pilot competency or program adequacy.
(2) Level A Checking. Level A checking indicates that no check
related to differences is required at the time of differences
training. A pilot is responsible for knowledge of each related
aircraft flown. Differences items should be included as an integral
part of subsequent recurring proficiency checks.
(3) Level B Checking. Level B checking indicates that a ``task''
or ``systems'' check
