2-10 cases, T3 can lead to assignment of Level E and a separate type rating. The following are examples that may lead to the assignment of Level E differences:
2.5.4.1 T3 experience or difficulties that show the need for assignment of training levels approaching typical initial/transition levels.
2.5.4.2 T3 pilot performance that indicates an aircraft or FFS (T2 elements when combined), or methods associated with Level D, are not adequate to achieve training or checking objectives.
2.5.4.3 Repeated failures of attempts to pass T3 test at Level D training differences.
Note: Repeated failure of a test at Level D differences by one or more test subjects’ inadequate performance, which is not attributed to an individual subject’s failure due to subpar or atypical personal performance as determined by the FSB, may lead to assignment of Level E differences.
2.6 Currency Validation—Test 4 (T4).
2.6.1 T4 Test Purpose. If technology, regulations, or policy has changed since the current issuance of the FSBR, an applicant or any person who can provide the means to justify the request (e.g., an aircraft and/or device necessary to perform the test) may petition for reconsideration of the original currency recommendations. An example circumstance for a T4 test is if a simulator has been approved for the aircraft since the FSBR was issued.
In the context of this AC, currency addresses system procedural and maneuvering differences between aircraft. T4 does not include takeoff and landing recency of experience.
2.6.2 T4 Test Process. If an applicant desires a change in the FSBR recommendations, 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 differences for currency for initial FSB determinations include the following examples:
2.6.2.1 Complex flight critical systems affecting control or navigation.
2.6.2.2 Critical non-normal maneuvers differing between related aircraft (e.g., 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).
2.6.2.3 Secondary systems (e.g., oxygen or auxiliary power unit).
2.6.3 T4 Successful Test. The FSB members decide the outcome of T4 consistent with previously agreed-upon criteria. A successful test validates that the proposed less-restrictive currency recommendations are accepted as a means of compliance with applicable rules, recommendations of this AC, and/or currency recommendations and provide an equivalent level of safety.
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2.6.4 T4 Failure of Test. Failure indicates that the proposed less-restrictive currency recommendations do not provide an equivalent level of safety to the FSB currency recommendations in the most recent approved FSBR. At the discretion of the FSB, retesting may be appropriate.
2.7 Initial Type Rating Training/Checking or Transition Training/Checking Validation—Test 5 (T5).
2.7.1 T5 Test Purpose. For the T5 test, the FSB uses a training proposal submitted by the applicant to evaluate and recommend a pilot type rating, training and checking requirements, and special emphasis areas for new aircraft types or for transition training between aircraft with different type ratings. The goal of the T5 test is to provide recommendations critical to the development of effective pilot training programs and curricula for aircraft that have not been previously evaluated. A T5 test is appropriate when:
• An applicant presents a candidate aircraft as a new aircraft type certification with no anticipated application for type rating credit for similarities with aircraft previously type certificated;
• An applicant seeks an evaluation of commonality between two aircraft with different type ratings to apply credit between those aircraft in transition training programs; or
• T2 or T3 are failed.
2.7.2 T5 Test Process. There are two methods to accomplish the T5 test process depending on the proposal being evaluated:
2.7.2.1 Initial Type Rating Training/Checking Proposal. This method is used when an applicant seeks a new type rating without any credit for commonality with any related aircraft. The applicant develops an evaluation plan to qualify and check pilots for the candidate aircraft at Level E differences. Test subjects are trained, given FPCs, and complete LOF, if applicable, in a process similar to T3 LOF, as described in paragraph 2.5.2.2 above. An FFS may be used for training, but an aircraft is required for the type rating test.
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.
2.7.2.2 Transition Training/Checking Proposal. This method is used when an applicant seeks a new type rating and credit for commonality with related aircraft. The applicant conducts a handling qualities evaluation based on the applicant’s evaluation plan (similar to T2), followed by training and checking proposal validation (similar to T3). Test subjects are then trained, given an FPC, and then complete a LOF, if applicable, in a process similar to T3.
2-12 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. A T5 does not automatically combine 14 CFR part 142 training program approval, unless a 14 CFR part 142 inspector is on the FSB conducting a concurrent evaluation.
2.7.3 T5 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. Upon completion of the FSB, checking commences for the applicant, based on the Letter of Authorization (LOA) issued by the FAA. When completed, the FAA will draft an FSBR, which will be published in the Dynamic Regulatory System (DRS).
2.7.4 T5 Failure of Test. Failing T5 indicates the proposed training or checking requires a modification. A retest by mutual agreement between the FSB and applicant would normally be required.
2.8 Common Takeoff and Landing Credit (CTLC)—Test 6 (T6).
2.8.1 T6 Test Purpose. Applicants use T6 when they seek credit between related aircraft toward the takeoff and landing recency-of-experience requirements of the applicable 14 CFR part.
Note: The T6 test is used for aircraft that were not previously tested during the initial aircraft evaluation for type rating designation.
2.8.2 T6 Test Process. Test subjects are first provided refresher training in the base aircraft to establish a baseline of proficiency. This training may be accomplished in an approved FFS.15 The test subject is then tested in the candidate aircraft, without any training in it, accomplishing a minimum of three takeoffs and landings without use of the autopilot.
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:
15 T-Tests in an FFS without a validation in the aircraft is at the discretion of the FSB based on the FFS fidelity (realistic indications) and approval from the NSP or attestation that the device is representative of a production equivalent of the aircraft and accepted by the FAA.
• A ircraft weights.
• Aircraft center of gravity.
• Takeoff and landing crosswinds.
2.8.3 T6 Successful Test. The FSB members decide the outcome of T6 consistent with the FAA test standards (i.e., Airman Certification Standards (ACS) or practical test standards
2-13 (PTS)) by 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.
2.8.4 T6 Failure of Test. The test subjects’ performance relative to the FAA ACS/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.
3-1 CHAPTER 3. FSB EVALUATION AND DEVELOPMENT OF
REPORT RECOMMENDATIONS
3.1 Introduction. This chapter describes the FSB process for establishing minimum differences and related aircraft differences training, checking, and currency requirements for pilot training and qualifications in 14 CFR parts 91 subpart K (part 91K), 121, and 135; and describes a comprehensive process for recommending aircraft-specific pilot training and qualification and for establishing pilot type ratings in accordance with 14 CFR § 61.31. It applies to aviation industry groups, aircraft operators, and training providers using published evaluation data to develop training programs and curricula.
The process is particularly suited to addressing transition, differences, and related aircraft differences training programs and Mixed Fleet Flying (MFF). The process aids in ensuring that pilots attain and maintain the knowledge, skills, and abilities needed to operate assigned aircraft safely. Related aircraft differences training may be approved for 14 CFR part 121 air carriers in accordance with 14 CFR § 121.418(b) and (c); and for 14 CFR part 91K program managers and 14 CFR part 135 operators that are required, or have elected, to comply with the applicable sections of 14 CFR part 121 subparts N and O, as described in 14 CFR §§ 91.1063(b) and 135.3(b) and (c), respectively.
3.1.1 Candidate Aircraft. The applicant may request an evaluation of a candidate aircraft it considers could be successfully demonstrated as compared to a base aircraft under the evaluation process defined within this AC. This determination should be independent of the operating rules under which the related aircraft is likely to be operated.
3.1.2 Designation of Related Aircraft for 14 CFR Part 121 Operations. Certain aircraft of the same make with different type certificates (TC) may be demonstrated and determined to have commonality to the extent that credit between those aircraft may be applied for training, checking, recency of experience, operating experience, operating cycles, or line operating flight time for consolidation of knowledge and skills. In order to use these training and qualification efficiencies in that operation, the operator must obtain a related aircraft designation from the Administrator in accordance with 14 CFR § 121.400(c) (refer to FAA Order 8900.1, Volume 3, Chapter 19, Section 12, Safety Assurance System: Related Aircraft Designations, Training, and Deviations—Part 121). The process for related aircraft designation and deviation approval is as follows:
3.1.2.1 The operator identifies the related aircraft (including specific information regarding make and type) and makes a request through the Principal Operations Inspector (POI) to the Air Transportation Division for the designation. This designation should be based on FAA analysis published in the applicable FSB Report (FSBR).
3.1.2.2 A request for a deviation provided in 14 CFR §§ 121.434, 121.439, and
121.441 must be sent to the Air Transportation Division through its responsible Flight Standards office. The Air Transportation Division will consider the deviation on the basis of guidance from the Aircraft Evaluation Division (AED) and its FSBRs and will provide a memo of concurrence or nonconcurrence to the responsible Flight Standards office.
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3.1.3 Master Differences Requirements (MDR) Formulation by the FAA. The FAA’s FSB formulates MDRs to address differences between related aircraft. These MDRs are presented in the appropriate FSBR. See paragraph 3.2.2.
3.1.4 Specification of Constraints or Credits. The program permits the specification of constraints or permissible credits. Constraints or credits may relate to knowledge, skills, abilities, a flight simulation training device (FSTD), 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.
3.1.5 Recognition of Unique Operator Characteristics. The program recognizes the unique characteristics of individual operators while achieving uniformity in application of FAA safety standards. FAA MDRs determine uniform bounds to tailor an individual operator’s unique requirements to a particular fleet and situation. POIs approve each operator’s unique requirements within FAA MDRs. Operator-unique requirements accommodate particular combinations of aircraft flown, pilot assignment policies, training methods and devices, and other factors that relate to the application of the FAA MDRs. Accordingly, the program preserves operator flexibility while standardizing the FAA’s role in review, approval, and monitoring of training, checking, currency, and MFF programs, as applicable.
3.1.6 Basis for Requirements. The determination of 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 (IFR) and visual flight rules (VFR). All flight phases, from preflight to shutdown, under both normal and non-normal conditions, are included.
3.1.7 Same Type Rating or Related Aircraft. When determining if two aircraft can reasonably be designated as related aircraft, or if a new variation of that aircraft can be considered the same type rating, the candidate aircraft must have a commonality of handling qualities and flight characteristics with the base aircraft. However, there are other factors to consider when ensuring aircraft are safely operated in this manner that should also be considered during an FSB evaluation, such as the number and magnitude of systems, procedures, pilot interactions with aircraft flight controls, design, or other aircraft differences which either individually or in aggregate may result in training or checking requirements that exceed Level D. When performing T1 through T4 evaluations, it is imperative to select an appropriate base aircraft that allows for a comprehensive evaluation to consider both the most significant differences and the aggregate changes made to the aircraft make, model, and series (M/M/S) over its design lifecycle.
3.1.7.1 Design Application for a Derivative Aircraft (same TC). Applicants should develop and produce data that supports assessments of any effects of the design modifications on operational data within the scope of the FSB (pilot type rating, pilot training, and operational suitability). The list should include any applicant-developed information concerning:
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• Design attributes that might impact the operational data;
• Applicant determinations of level of impact, and data used to make those determinations; and
• Applicant determination data (if any) for attributes found to have no impact.
3.1.8 Relationship to Other FAA Policies. Although this AC, and the FSB recommendations in some instances, address particular types of operations, specific aircraft systems (e.g., use of flight guidance control systems (FGCS) for Category II/III instrument approaches, long-range navigation, etc.), or human factor (HF) considerations and assessments, other Flight Standards (FS) procedures-centric ACs provide more detailed discussion of these subjects. This AC and FSB recommendations address such issues only to the extent necessary to ensure that crewmembers are qualified to operate pertinent systems or equipment as part of initial or continuing qualification.
3.2 Concepts.
3.2.1 Pilot Training and Qualification Process.
3.2.1.1 Purpose. This paragraph describes an integrated FAA/applicant/operator process to determine, apply, and meet appropriate requirements on a continuing basis for pilot training and qualification.
3.2.1.2 Overview. The process applies the MDR in a way that tailors a particular aircraft to any applicant/operator’s unique situation or fleet. The FAA approves unique operator and fleet requirements for each operator based on the MDR, if applicable. The FSB determines the MDR based on objective criteria and tests, with the applicant’s/operator’s (usually an aircraft manufacturer) support for analysis and testing. FSBRs describe the MDR, which expresses the minimum acceptable differences levels between the base and candidate aircraft. An operator’s training and qualification program, checklist, operations manuals, and other such approvals are byproducts of compliance with MDRs. Operators comply with MDRs using unique operator differences requirements (ODR), 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 MFF situation. An operator’s specific document describes ODRs by identifying a base aircraft, differences between related aircraft, and that operator’s compliance methods for each related aircraft.
3.2.2 MDRs.
3.2.2.1 MDR Applicability. MDRs are those requirements applicable to training and qualification that pertain to differences between aircraft that have been designated as related by the Administrator and aircraft variations within the same type. MDRs specify the minimum acceptable differences levels between
3-4 aircraft that may be approved for operators. A suitable aircraft is selected by the operator 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. Differences levels between the base aircraft and candidate aircraft then specify the minimum difference requirements to be met for pilot training and 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. MDRs are specified in terms of training and checking differences levels as shown on an MDR table.
3.2.2.2 MDR Content. MDRs specify the minimum training and checking acceptable to the FAA for pilot training and qualification regarding differences.
3.2.2.3 MDR Formulation, Description, and Revision. MDRs are formulated by the FAA FSB for 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 aircraft type certification or supplemental type certification process. MDRs are based on an applicant’s proposal, FAA evaluation of that proposal, in-service experience, and test results when tests are necessary. FSB determinations also consider operator recommendations, safety history, and other relevant information. MDRs are described in recommendations of an FSBR and may be revised if necessary. MDRs are revised when aircraft are developed or modified, tests or in-service experience 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.
3.2.2.4 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 an individual operator’s differences or related aircraft differences training program.
3.2.2.5 The MDR Table. The MDR table contains the minimum levels of training and checking, derived from the highest level in the training and checking differences required when used in 14 CFR part 91K, 121, or 135 ODRs.
Examples of MDRs for the make and model (M/M) are shown in Figure 3-1, Master Differences Requirements Table. The 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 MDR table identifies the minimum difference training and checking requirements applicable to MFF.
Differences levels are arranged as training/checking. The MDR table identifies a pertinent base aircraft and particular aircraft for which requirements are sought. Note the minimum differences levels that correspond to the pertinent column and row, and special requirements in footnotes, if applicable.
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3.2.2.6 Use of Higher or Lower Differences Levels. Operators 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.
3-6 Figure 3-1. Master Differences Requirements Table These are the minimum levels of training and checking required, derived from the highest level in the Differences Tables (DT).
Differences levels are arranged as training/checking.
To Related Aircraft ↓ From Base Aircraft → [XXX] [YYY] [ZZZ] [XXX] [Not Applicable] [B/A] [Not Evaluated] [YYY] [A/B] [Not Applicable] [B/C] [ZZZ] [C/B] [C/B] [Not Applicable]
• Footnotes and/or other limitations may be inserted here.
• Not applicable if related aircraft have not been identified.
• The related aircraft rows should only list aircraft which are part of the Type Certificate Data Sheet (TCDS) shown on the FSBR cover page; this includes variations or modifications that may or may not be listed on the TCDS or on the FSBR cover page. See examples in Figure 3-2 below.
• MDRs previously determined and approved by the FAA between related aircraft of a single make (same Original Equipment Manufacturer (OEM)) may be contained in a single FSBR if doing so would provide MFF clarity for users.
Figure 3-2. MDR Table Example for Make/Model [XXX] on FSBR Cover Page To Related Aircraft ↓ From Base Aircraft → [WWW] [XXX] [YYY] [ZZZ] [XXX] C/C Not Applicable D/C Not Evaluated
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3.2.2.7 Differences Within a Series. Differences may exist even within series shown on an MDR table. 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.
3.2.2.8 More Than One Related Aircraft. When an operator assigns a pilot to more than one related aircraft of the same TC (e.g., M/M/S next generation), or more than one aircraft with different TCs (e.g., M/M) designated as related, each pertinent requirement of the MDR table applies.
3.2.2.9 Special Requirements.
3.2.2.9.1 MDR Footnotes. Footnotes can be used to credit, constrain, or set alternate levels when special situations apply. Use of footnotes permits accommodation for differences of 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 automatic flight control system, flight management system (FMS), or navigation system, 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 FSBR.
3.2.2.9.2 Other Limitations. Other limitations may occasionally be identified within a differences level (e.g., C*). The asterisk following the differences level in such instances identifies a special requirement or limitation pertaining to a particular training method, checking method, or device. Such notes typically relate to acceptable FSTDs when the FSTD evaluation and approval process or standard criteria of this AC are not available to address a particular situation appropriately.
3.2.2.10 MDRs for Aircraft with the Same or Different TC. A single FSBR and MDR table may apply to aircraft that are assigned the same TC with the same type rating (e.g., M/M and next generation). A single FSBR and MDR table may also apply to different type-certificated aircraft (e.g., M/M). When it is determined that Level E training is required for an aircraft with the same aircraft TC and a different type rating is determined, a single MDR table for all series of that type-certificated aircraft still applies (e.g., M/M). Minimum acceptable differences levels are assigned based on standard tests described in Chapter 2, T-Tests Used to Evaluate Type Ratings and Pilot Training, Checking, and Currency.
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3.2.3 Differences Levels.
3.2.3.1 General Description. Differences levels specify FAA requirements proportionate to and corresponding with increasing differences between related aircraft or variations of aircraft. Figure 3-7, Training Differences Legend, and Figure 3-8, Checking Differences Legend, show the training and checking differences legends, respectively, for five differences levels used for ODR table development, in order of increasing requirements, identified as A through E, are each specified for training and checking. MDRs are specified in terms of differences levels. Differences 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 MFF where credit is sought should apply differences levels and address all MFF requirements to ensure compliance with FAA requirements necessary to ensure safe operations.
3.2.3.2 Differences Tables (DT). DTs, as shown in Figure 3-3, Differences Tables— Design, and Figure 3-4, Differences Tables—Maneuvers, show examples of design and maneuvers, respectively, for which there is a difference. If no changes exist from the base aircraft to the candidate aircraft for a specific design item or maneuver, then a design or maneuver would not be included, and the term “not applicable” would be entered.
3.2.3.3 Basis for Levels. Differences levels apply when a difference with potential to affect flight 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 differences levels are not assigned; nor are they applicable to pilot training and qualification. When Differences Levels A through E apply, each differences level is based on a scale of differences in design features 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/non-normal/emergency items.
3.2.3.4 Relationship Between Training and Checking Levels. While particular aircraft are often assigned the same level (e.g., C/C) for training and checking, such assignment is not necessary. Levels may be assigned independently. For example, an aircraft may be assigned Level C for training and Level B for checking (e.g., C/B).
3.2.3.5 Evaluation for Determination of Aircraft Type Ratings.
3.2.3.5.1 Aircraft with the same TC when evaluated for type rating determination are assigned the same type rating if training differences are no greater than Level D.