3-9
3.2.3.5.2 Aircraft of the same make having different TCs, that have training differences no greater than Level D, will be assigned different type ratings that may be considered in common with each other.
3.2.3.5.3 Aircraft of the same make that have Level E training difference requirements will be assigned a different type rating. Aircraft with systems such as Head-Up Display (HUD), Enhanced Flight Vision System (EFVS), or Synthetic Vision System (SVS) may require Level E training without requiring a new type rating.
3.2.4 Training Differences Levels.
3.2.4.1 Level A Training. Indicates 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:
3.2.4.1.1 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). 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).
3.2.4.1.2 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 non-normal “read and do” procedures).
3.2.4.2 Level B Training. Applies to related 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 audiovisual presentations, computer-based instruction, or standup lectures.
Situations not covered under Level A training may require Level B training (or higher levels) if certain tests described in later paragraphs fail.
3.2.4.3 Level C Training. Applies to related aircraft having part task differences that affect knowledge, skills, and/or abilities. Level C training can only be accomplished through use of devices that are capable of systems training. The 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
3-10 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.
Typically, the minimum acceptable training method for Level C training would be interactive computer-based training (CBT), Cockpit Procedures Trainers (CPT), ground flight simulation, partial task trainers (PTT), an FMS or Traffic Alert and Collision Avoidance System (TCAS), or a Level 4 or 5 flight training device (FTD).
3.2.4.4 Level D Training. Applies to related aircraft having full task differences of knowledge, skills, and/or abilities. Level D training can only be accomplished with devices capable of performing flight maneuvers 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 requires mastery of interrelated skills that cannot be adequately addressed by separate acquisition of those skills. However, the differences are not so significant that a full transition training course is required. 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 phenomena such as low visibility, Category III instrument landing system operations, or windshear may or may not be incorporated. Where simplified or generic characteristics of an aircraft type are used in devices to satisfy Differences Level D training, negative training must not occur as a result of the simplification. Typically, the minimum acceptable training method for Level D training would be FTD Level 6.
3.2.4.5 Level E Training. Applies to aircraft having such significant full task differences that a high-fidelity environment is required to attain or maintain knowledge, skills, or abilities. Training at Level E can only be satisfied by the use of a full flight simulator (FFS) 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 (e.g., an engine set at idle thrust to simulate an engine failure). Only the assignment of Level E training requirements may result in a separate type rating determination. As with other levels, when Level E training is assigned, suitable credit or constraints may be applied for knowledge, skills, and/or abilities associated with other pertinent related aircraft. Credits or constraints are specified for the subjects, procedures, or maneuvers shown in FSBRs.
Note: Training differences levels specified by the FSB represent minimum requirements. Operators may use a device associated with a higher differences level to satisfy a training difference requirement.
For example, if Level C differences are assessed due to installation of
3-11 a different FMS, operators may train pilots using the FMS installed in an FFS as a system trainer if a dedicated part task FMS training device is not available.
3.2.5 Checking Differences Levels.
3.2.5.1 Initial and Recurrent Checking. Related aircraft differences checking addresses any pertinent pilot qualification requirements and any other checks specified by FSBRs. 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 (TCPM), in coordination with the FSB, may require checking in the initial level device when doubt exists regarding pilot competency or program adequacy.
3.2.5.2 Level A Checking. Indicates that no check is required at the time of training.
A pilot is responsible for knowledge of each related aircraft flown. Difference items should be included as an integral part of subsequent recurring proficiency checks.
3.2.5.3 Level B Checking. Indicates that a “task” or “systems” check is required following training. Level B checking typically applies to particular tasks or systems such as an FMS, TCAS, or other individual systems or related groups of systems.
3.2.5.4 Level C Checking. Requires a device suitable for meeting Level C (or higher) difference training requirements following training. The checking is conducted relative to particular maneuvers or systems determined by the FSB.
An example of Level C checking would be an evaluation of a sequence of maneuvers demonstrating a pilot’s ability to use an FGCS or FMS. An acceptable scenario would include each relevant phase of flight that uses the FGCS or FMS.
3.2.5.5 Level D Checking. Requires a check for one or more related aircraft following training. The check covers the particular maneuvers, systems, or devices determined by the FSB. Level D checks are performed using scenarios representing a real-time flight environment and devices permitted for Level D difference training. A full proficiency check (FPC) is typically conducted on the base aircraft, and a partial proficiency check (PPC) on the related aircraft, covering all pertinent differences.
3.2.5.6 Level E Checking. Unless specified, requires an FPC in a Level C or D FFS, or aircraft. As with other levels, when Level E checking is assigned, suitable credit or constraints may be applied for knowledge, skills, and/or abilities
3-12 related to other pertinent related aircraft. Credits or constraints are specified for the subjects, procedures, or maneuvers shown in FSBRs.
3.2.6 Checking on Related Aircraft. The pilot who is receiving a type rating on the basis of being related should be current and qualified in the base aircraft at the time of the check.
The pilot is issued a type rating after receiving designated related aircraft differences training and checking on the candidate-related aircraft, as described in this AC, under training and checking differences levels. This check is not an FPC, but an abbreviated check on the differences (B, C, and D) from the base to the candidate aircraft. The designated related aircraft differences check, unless it includes the requirements for a recurrent check, cannot reset the “recurrent clock” (a pilot’s base month for checking purposes).
3.2.7 Competency Regarding Abnormal/Non-Normal/Emergency Procedures. Competency for non-normal maneuvers or procedures is generally addressed by checking requirements;
however, particular abnormal/non-normal/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 currency recommendations for training or checking applicable to abnormal/non-normal/emergency maneuvers or procedures that are to be performed. This is to ensure 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. If available, equivalency of malfunction documentation based on aircraft system malfunctions may be provided to the FSB by the OEM for use in the FSB for evaluation. When an abnormal/non-normal/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 determined by the FSB, these currency requirements identify each abnormal/non-normal/emergency maneuver or procedure and an applicable time period or any other necessary/appropriate constraints.
3.2.8 Differences Level Summary. Differences levels are determined by the FSB through a series of T-Tests for training and checking (see Figure 3-6, Test Definitions).
3.2.9 Operating Experience, Operating Cycles, and Consolidation of Knowledge and Skills.
Credits towards 14 CFR part 121 requirements for operating experience, operating cycles, and line operating flight time for consolidation of knowledge and skills may be permitted if performed in “designated” related aircraft.
3.2.10 Supervised Line Flying (SLF). FSB recommendations may also include postqualification enhancement of specific skills that require SLF. These recommendations are annotated in the FSBR as applicable. Among other reasons, one or more of the reasons described below may apply:
3-13
3.2.10.1 Introduction of new systems (e.g., Automatic Dependent Surveillance-Broadcast (ADS-B), Runway Area Advisory System (RAAS), etc.).
3.2.10.2 Introduction of new operations (e.g., oceanic operations, Extended Operations (ETOPS)).
3.2.10.3 Experience for a particular pilot position (e.g., pilot in command (PIC) or second in command (SIC)).
3.2.10.4 Special characteristics (e.g., effects of unique airports, mountainous areas, unusual weather, special air traffic control (ATC) procedures, or nonstandard runway surfaces) on this aircraft.
3.2.11 Recency of Experience. Credit towards the recency-of-experience requirements of 14 CFR part 121 may be permitted for takeoffs and landings performed in designated related aircraft.16 16 Under 14 CFR § 121.434(a)(4)(i), “[t]he Administrator may authorize a deviation from the operating experience, operating cycles, and line operating flight time for consolidation of knowledge and skills required by this section based upon a designation of related aircraft in accordance with § 121.418(b) of this part and a determination that the certificate holder can demonstrate an equivalent level of safety.”
3.2.12 O perator Differences Requirements (ODR).
3.2.12.1 ODR Purpose. ODRs and tables are developed by an operator in accordance with Order 8900.1, Volume 3, Chapter 19, Flightcrew Member Training and Qualification Programs. Applicant-produced ODR tables are available (if produced by the applicant).
3-14 Figure 3-3. Differences Tables—Design This Design Differences Table, from the [base aircraft name] to the [related aircraft name], was proposed by [Manufacturer, Modifier, Training Provider] and validated by the FSB on [date(s)]. It lists the minimum differences levels operators must use to conduct differences training and checking of flightcrew members.
FROM BASE AIRCRAFT:
[YYY]
TO RELATED AIRCRAFT:
[ZZZ]
DESIGN REMARKS FLT CHAR PROC CHNG TRAINING CHECKING [Autoflight] [TOGA Flight Director Command Bars initiate at 12° vs. 8°].
[No] [No] [A] [A] [Communications] [New audio system]. [No] [Yes] [B] [A] [Communications] [Radio tuning accomplished through RFMUs].
[No] [Yes] [C] [A] [Indicating/Recording Systems] [Engine parameters available on either RFMU].
[No] [Yes] [C CPT or PTT]17 [C FTD 5]18
17 Example: CPT or PTT is the minimum recommended.
18 Example: FTD 5 is the minimum recommended.
3-15 Figure 3-4. Differences Tables—Maneuvers This Maneuver Differences Table, from the [base aircraft name] to the [related aircraft name], was proposed by [Manufacturer, Modifier, Training Provider] and validated by the FSB on [date(s)]. It lists the minimum differences levels operators must use to conduct differences training and checking of flightcrew members.
FROM BASE AIRCRAFT: [YYY]
TO RELATED AIRCRAFT: [ZZZ]
MANEUVER REMARKS FLT CHAR PROC CHNG TRAINING CHECKING [Preflight Inspection] [Exterior inspection adds tailskid].
[No] [Yes] [A] [A] [Normal Takeoff] [Optional use of autothrottles]. [No] [Yes] [C CPT19] [C] [Normal Takeoff] [Flap 1 not certified for takeoff].
[No] [No] [A] [A] [Non-Normal] [Optional autopilot saturation alert].
[No] [Yes] [B] [B] [All Phases of Flight] [Addition of variable position speedbrake].
[Yes] [Yes] [D] [D]
19 Example: CPT is the minimum recommended.
3-16
3.3 Formulation of FSBRs, MDRs, and Determination of Type Ratings.
3.3.1 Process Overview. The FSB issues its final recommendations in the FSBR. An example of an FSBR that describes findings can be found in the Dynamic Regulatory System (DRS) under “Aircraft Evaluation Division (AED) Guidance Documents including MMELs”—“Flight Standardization Board Reports (FSBR).” The formulation and process of FSB recommendations 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 MFF takes place. The FAA addresses periodic revisions of requirements when necessary, and revisions are initiated by the FAA and applicants as needed.
3.3.2 Formulation of MDRs. The process for FAA formulation and revision of MDRs is shown in Figure 3-5, Master Differences Requirements Formulation. 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 recommendations. Applicants propose MDRs, and any other FSB recommendations that are necessary. Proposals for requirements are based on design objectives, analysis, evaluation of in-service experience, 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 in-service experience. 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 for differences and related aircraft differences training and checking.
3.3.3 Proposals for MDRs and Special Requirements.
3.3.3.1 When Proposals for MDRs and Special Requirements 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 certification programs. Necessary information may include HF analyses of training requirements, procedures or individual and aggregate system changes, MDRs for related aircraft, or other elements of the FSBRs.
3.3.3.2 Proposal Formulation. An applicant who modifies an aircraft and proposes a new design or modification will then do the following:
1. Formulate necessary information for training, checking, and currency for the aircraft in proposals for MDRs.
2. Identify related aircraft for the proposed MDR table.
3-17
3. Formulate any necessary tests to assess differences levels and associated training, checking, and currency requirements for incorporation in the MDR table.
4. 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.
5. Submit proposals for the following items to the FAA, as necessary:
• MDRs;
• Tests and criteria to be used;
• Other supporting information associated with training, checking, or currency programs; and
• HF-related information, as applicable, or required by regulations.
3.3.4 Differences Level Tests. A sequence of five standard tests, described in Chapter 2, is used to set MDRs, minimum acceptable training proposals, and other FSB recommendations and define type rating requirements. One or more of these tests is applied, depending on the differences 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 differences levels that apply, establish minimum requirements for training, checking, currency, and type ratings. The FAA will establish an additional type rating if it is determined during this testing that the assignment of a Level E difference training is required.
Note: One additional test, the T6 test, can be used to establish Common Takeoff and Landing Credit (CTLC) between related aircraft, when not previously demonstrated in a T2 test.
3.3.4.1 Steps in the Testing Process. The typical steps of the testing process are as follows:
1. The applicant develops representative training proposals, differences and/or related aircraft differences proposals, and necessary supporting information, as needed.
2. The applicant identifies proposed MDRs.
3. The applicant proposes and the FAA determines which tests and criteria apply.
4. The applicant proposes and the FAA determines which aircraft, simulation devices, or analyses are needed to support testing.
5. The applicant makes a proposal to the FAA, and agreement is reached on test procedures, schedules, and specific interpretation of possible results.
6. Tests are conducted and results evaluated.
7. The FSB draft minimum requirements are formulated.
3-18 Note: If the candidate aircraft is anticipated to have no greater than Level A or B differences with the base aircraft, the FSB may elect to directly apply a T1 test for equivalency.
3.3.4.2 Test Purpose and Proposal. A summary of the purpose and proposal of each of the six difference tests are shown in Figure 3-6.
3.3.4.3 Test Relationships and Proposals. 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 in-service experience. The test process relationships, the sequence of conducting tests when more than one test is needed, and the application of test outcomes are shown in Figure 3-9, “T” Tests T1 Through T5. The start of the process is shown at the top of Figure 3-9.
3.3.4.3.1 When a new aircraft is certificated and is not compared with an existing aircraft, the aircraft is evaluated using the T5 test to determine the effectiveness of the manufacturer training and evaluation plan. A type rating is determined as a result of the evaluation.
3.3.4.3.2 When two aircraft with the same TC are compared, a T1 or T2/T3 test is used to determine the level of differences between the two aircraft. The result can be the assignment of a same type rating if no greater than Level D training differences exist or the assignment of a different type rating if Level E training differences exist.
3.3.4.3.3 When two aircraft with different TCs are compared, a T2/T3 test is used to determine the level of differences between the two aircraft. An example of this is a determination of Level B, C, D, or E training differences between the two aircraft.
3.3.4.4 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 Level C or D after modification of the system, operational procedures, or training and retesting. Similarly, failure at Level D can subsequently lead to either Level D or E after modification of the system, operational procedures, or training and retesting, but not Level C. Failure at Level E can only lead to retesting with increased proposals, improved proposals, or improved devices, since there is no higher level. T5 test failure paths do not lead back to Level C or Level D. However, subsequent new proposals 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.
3.3.4.5 Type Rating Tests. Aircraft seeking a same type rating or type rating in common will follow the path in Figure 3-9 from the top right “START” of
3-19 Figure 3-9 through T1 or T2 and T3 tests, resulting in the assignment of Level A, B, C, or D differences.
3.3.4.6 Currency Tests. T4 currency tests are not shown in Figure 3-9 because they are necessary only when the applicant seeks relief from system, procedural, and maneuver currency requirements set by the FSB.
3.3.4.7 Detailed Test Specifications. The FSB develops a detailed specification describing the maneuvers to be conducted during the evaluation process and tests to establish differences levels. These documents are commonly called AED Flight Test Plans or Test Definition Sheets.
3.3.5 FSB Assessments and Proposal Formulation. The FSB assesses the applicant’s proposals, test results, analysis, and any other relevant factors to formulate a draft FSBR, which includes MDRs and other pertinent training, checking, and currency requirements. The FSB either validates the applicant’s proposed MDRs, training proposals, and other information, or generates alternate requirements, which may include more stringent requirements, additional training, additional testing, etc. The applicant should consider HFs regarding their proposal for type rating; specifically the number, magnitude, or type of systems, procedures, or pilot interactions with aircraft flight controls or differences with respect to the base aircraft.
3.3.6 Training Related to Pilot Interventions. Each aircraft manufacturer should provide the FAA with the information or findings necessary for the flightcrew to be trained on flight deck systems, along with any technical basis, justification, or rationale for the information and findings for the FSB to evaluate flightcrew training in an operational context, to include recommendations for special emphasis areas. This information should include the following:
3.3.6.1 For all aircraft, include information necessary to meet assumptions made during certification for failure conditions where the applicant takes credit for pilot interventions that result in a severity downgrade from catastrophic to hazardous, or hazardous to major, in response to a system or sub-system failure that has not been previously proven or studied through historic operational data.
3.3.6.2 For transport category airplanes certificated under 14 CFR part 25, include safety critical information on failure conditions or erroneous operation of components or systems that could result in a hazardous or catastrophic severity outcome, including any design and operational details, intended functions, failure modes, and mode annunciations of any system that, without being commanded by the flightcrew, commands the operation of any safety-critical function or feature required for control of an airplane during flight or that otherwise change the flight path or airspeed of the airplane. Such systems include autopilot and autothrottle systems, or any system where adverse handling quality fails to meet the requirements of applicable regulations without the addition of a software system to augment the flight
3-20 controls of the airplane to produce compliant handling qualities. Disclosure of safety-critical information is applied in accordance with Title 49 of the United States Code (49 U.S.C.) § 44704(e)(1) and 14 CFR parts 21 and 25, and is consistent with applicable international agreements. If necessary, the AED will coordinate with the Aircraft Certification Service (AIR) to obtain information applicable to the FSB.
3.3.6.3 For transport category airplanes designed for operation by an air carrier or foreign air carrier type-certificated with a passenger seating capacity of 30 or more, or an all-cargo or combi derivative of such an airplane, include the rationale and supporting information underlying pilot response assumptions regarding individual errors, malfunctions, or failures and the time necessary for pilots to respond to the malfunction before the effects worsen. The rationale and supporting information should cover errors, malfunctions, or failures from safety assessments for hazards classified “Major” or higher that are in response to a system or sub-system failure that has not been previously proven or studied through historic operational data.20
20 Aircraft Certification, Safety, and Accountability Act (ACSAA), Public Law 116-260 (Dec. 27, 2020), section 115.