Figure 3-5. Master Differences Requirements Formulation
MDR FORMULATION (AN FAA/APPLICANT PROCESS)
APPLICANT
FAA FLIGHT
STANDARDIZATION
BOARD (FSB) DESIGN
OBJECTIVES & FHAS PROPOSED MDRs → EVALUATION & TESTING COMMENTS → FSBR MDRs & DTs FSBR TYPICAL MDRS & DTs FSB RESPONSIBLE APPROVAL &
FS OFFICE USE 3-21
3-22 Figure 3-6. Test Definitions T-Test (#) Test Purpose Process T1 Establishes functional equivalence Sets Levels A/B T2 Handling qualities comparison Pass permits T3, and A/B/C/D; failure sets Level E and requires T5 T3 Evaluates differences and sets training/checking requirements Pass sets Levels A/B/C/D; failure sets Level E and requires T5 T4 Revises currency requirements Used to adjust FSB recommendations if needed T5 Sets training/checking for new or “E” aircraft Sets Level E T6 Evaluation for Common Takeoff and Landing Credit (CTLC) Sets recency-of-experience requirements Note: Expanded descriptions are contained in Chapter 2.
3-23 Figure 3-7. Training Differences Legend Differences Level Type Training Method Examples Conditions A Self-Instruction • Operating manual revision (handout).
• Flightcrew operating bulletin (handout).
• Crew has already demonstrated understanding on base aircraft (e.g., updated version of engine).
• Minor or no procedural changes required.
• No safety impact if information is not reviewed or is forgotten (e.g., different engine vibration damping mount).
• Once called to attention of crew, the difference is self-evident.
B Aided Instruction • Audiovisual presentation.
• Tutorial computer-based instruction.
• Standup instruction.
• Systems are functionally similar.
• Crew understanding required.
• Issues need emphasis.
• Standard methods of presentation required.
C Systems Devices • Interactive (full-task) computer-based instruction.
• Cockpit Procedures Trainers (CPT).
• Partial task trainers (PTT).
• Level 4 or 5 flight training device (FTD 4-5).
• Training can only be accomplished through systems training devices.
• Training objectives focus on mastering individual systems, procedures, or tasks versus highly integrated flight operations or “real-time” operations.
• Training devices are required to ensure attainment or retention of crew skills to accomplish more complex tasks usually related to aircraft systems.
D Maneuvers Devices • Level 6 or 7 flight training device (FTD 6-7).
• Level A or B full flight simulator (FFS A-B).
• Training can only be accomplished in flight maneuver devices in a real-time environment.
• Training requires mastery of interrelated skills versus individual skills.
• Motion, visual, control-loading, and specific environmental conditions may be required.
E Level C/D FFS or Aircraft
• Level C or D full flight simulator (FFS C-D).
• Aircraft (ACFT).
• Motion, visual, control-loading, audio, and specific environmental conditions are required.
• Significant full-task differences that require a high-fidelity environment.
• Usually correlates with significant differences in handling qualities.
3-24 Figure 3-8. Checking Differences Legend Differences Level Checking Method Examples Conditions A None. None.
B • Oral or written exam. • Tutorial computer-based instruction self-test. Individual systems or related groups of systems.
C
• Interactive (full-task) computer-based instruction.
• Cockpit Procedures Trainers (CPT).
• Partial task trainers (PTT).
• Level 4 or 5 flight training device (FTD 4-5).
• Checking can only be accomplished using systems devices.
• Checking objectives focus on mastering individual systems, procedures, or tasks.
D
• Level 6 or 7 flight training device (FTD 6-7).
• Level A or B full flight simulator (FFS A-B).
• Checking can only be accomplished in flight maneuver devices in a real-time environment.
• Checking requires mastery of interrelated skills versus individual skills.
• Motion, visual, control-loading, and specific environmental conditions may be required.
E • Level C or D full flight simulator (FFS C-D). • Aircraft (ACFT). Significant full-task differences that require a high-fidelity environment.
Figure 3-9. "†" Tests T1 Through T5 "T" TESTS 1 THRU 5 START NO T1 Req'd? NO Candidate Level E?
YES Waive T1 YES T1 T2 Fail Fail Pass Pass NO T3 Req'd?
T5 LEVEL E No Commonality or LEVEL Fail T5 LEVEL E With B/C/D A or B Pass Commonality E Level A Level B Level C Level D Level E Differences Differences Differences Differences Differences New T/R
SAME OR COMMON PILOT TYPE RATING 3-25
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3.3.7 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 comment, relevant information, and recommendations.
3.3.8 FSB Final Determinations and Findings.
3.3.8.1 FSB Determinations. Any comments submitted to the FAA are reconciled, and final FSB determinations are made. Specification of MDRs, DTs, acceptable training proposals, and other FSB recommendations are completed.
Any necessary pilot checking or currency recommendations are identified.
Determination of any necessary type rating(s) is made.
3.3.8.2 Basis for FSB Judgments. FSB judgments are based on review of the applicant’s supporting documentation, proposed differences, test results, and any other pertinent information, such as FAA policies, in-service experience, and results of other similar FSB evaluations. Specifically, FSBR recommendations are based on the following:
3.3.8.2.1 Appropriate Data, Evaluation, or Tests. Testing may include aircraft demonstration, simulation tests, device testing, or analysis.
3.3.8.2.2 Direct Experience. The industry may have substantial experience with successful operational proposals, which can be useful in the assignment of minimum differences level requirements. This experience may include particular training devices, training/checking/currency requirements, and MFF.
3.3.8.2.3 Indirect Experience. Applicable experience with foreign operators, military programs, or other proposals that can establish the suitability of training, checking, or currency standards may be permitted as a means for FSBs to set differences levels.
3.3.8.2.4 Applicant and Industry. FSB recommendations are set following solicitation and review of comments.
3.3.8.3 FSTD Characteristics. Minimum characteristics for FSTDs for training, checking, or currency are noted using 14 CFR part 60 FSTD definitions.
When standard criteria for FSTDs are not appropriate for an aircraft, the FSB identifies suitable criteria to be applied and coordinates with the FAA National Simulator Program (NSP). Standard FSTDs applicable to each differences level are shown in Figure 3-10 below.
3-27 Figure 3-10. Standard Method and Flight Simulation Training Device (FSTD) Differences Level Differences Level Definition Method FSTD A Self-Instruction
• Bulletins
• Manual revisions
• Handout material — B Aided Instruction
• Presentations
• Videos
• Standup instruction
• CBT — C Systems Devices — Level 4 or higher FSTD D Maneuvers Devices — Level 6 or higher FSTD E Level C or D FFS — Level C or D FFS or aircraft
3.3.9 FSBR Preparation Distribution and FAA Proposal.
3.3.9.1 Report Preparation and Approval. After MDRs are finalized, the FSBR is prepared and approved. Sufficient background or explanatory material is provided in the report to permit FAA personnel to apply FSB recommendations. The following are elements of an FSBR:
1. Record of Revisions;
2. Introduction;
3. Highlights of Change;
4. Background;
5. Acronyms;
6. Definitions;
7. Pilot Type Rating;
8. Related Aircraft;
9. Pilot Training;
10. Pilot Checking;
11. Pilot Currency;
12. Operational Suitability;
13. Miscellaneous;
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14. Appendix 1, Differences Legends;
15. Appendix 2, Master Differences Requirements (MDR) Table; and
16. Appendix 3, Differences Tables.
3.3.9.2 FSBR Distribution. FSBRs are posted in DRS at https://drs.faa.gov under “Aircraft Evaluation Division (AED) Guidance Documents including MMELs”—“Flight Standardization Board Reports (FSBR).” The FAA technical requirements described in FSBRs are primarily intended for the operators’ use to develop programs for FAA review and approval.
3.3.9.3 FSBR Implementation. FSB recommendations inform the establishment of pilot type ratings under 14 CFR § 61.31. Guidance on the use of FSB recommendations is provided to the Office of Air Carrier Safety Assurance (ACSA) and the Office of General Aviation Safety Assurance (GASA) in Order 8900.1. FSBRs contain recommendations for acceptable criteria for flightcrew member training, checking, and currency programs under 14 CFR § 91.1079, § 121.403, or § 135.327; differences training under 14 CFR § 91.1063, § 121.418, or § 135.321; and training program curricula under 14 CFR § 142.39. Air carriers and operators under 14 CFR parts 91K, 121, and 135 incorporate FSBR recommendations into their training, checking, and currency programs, manuals, and checklists for review and approval or acceptance by their POIs. Title 14 CFR part 142 training centers and other training providers incorporate FSB recommendations into their training center curricula for FAA approval. FSB recommendations set acceptable standards for aircraft by which FAA inspectors review and approve individual air carrier and operator programs and training curricula.
3.3.10 FSBR Revision.
3.3.10.1 General FSBR Revision Process. A general revision process is established to update determinations and findings contained in FSBRs. Revisions occur as necessary for active fleets with numerous change requests. Revisions may be needed infrequently for aircraft not undergoing significant change.
3.3.10.2 Revisions for New Aircraft. When an applicant proposes to develop or add a series of a type-certificated aircraft, MDRs and other FSB recommendations are revised to address that series. If an applicant initiates this action, the procedures regarding initial determination of minimum training, checking, currency, and type rating requirements are followed. If an operator proposes to add an aircraft that is not covered within an existing FSBR (e.g., a foreign-manufactured aircraft), POIs should consult with the pertinent AED branch. An FSB will determine the best method of addressing the development of the necessary FSBR. This is particularly important for older aircraft fleets in which differences may be significant, but manufacturer support is no longer available; as well as when aircraft that have been used only by foreign operators are imported into the United States.
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3.3.10.3 Revision for Aircraft Modified by Operators. When an aircraft is to be modified by an operator, the POI determines if the change affects MDRs, DTs, or other FSBR recommendations. The criteria for this assessment include 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, an analysis of the effects of the difference, and a proposed training program for the difference. The POI evaluates the proposal and if it is acceptable, seeks concurrence from the Air Transportation Division. The Air Transportation Division will advise the AED/FSB. The AED/FSB may concur with the POI’s analysis or propose other action. If FSB action is proposed and accepted by the Air Transportation Division, the AED will initiate that action through the FSB Chair. The FSB may require that additional information or analysis be provided or that the entire test process or parts thereof be applied. The AED may authorize the POI to approve assignment of the differences level. Changes to the MDRs will be made through the normal FSB revision process.
3.4 FSBR Requirements.
3.4.1 General. FAA pilot certification inspectors and Designated Pilot Examiners (DPE) should be familiar with FSBR recommendations regarding the proper administration of any necessary checks or evaluations for aircraft covered by the FSBR.
3.4.2 Checks Regarding Complex Systems.
3.4.2.1 Checking is required for differences associated with systems that are determined to be at or greater than Level B.
3.4.2.2 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 non-normals).
Note: The FSB may recommend additional training beyond that which is otherwise required by 14 CFR to qualify in each type-certificated aircraft.
3.5 FSTD Approval.
3.5.1 NSP Representation to the FSB. An NSP member may serve as a Technical Advisor to the FSB if invited, or as a member at the discretion of the FSB Chair, to address designation of and approval processes for FSTDs.
Note: The FSB Chair may elect to use an FFS before its qualification by the NSP, 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.
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3.5.2 Coordination of NSP Criteria with the FSB. NSP development of criteria for FSTDs 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 recommendations.
Note 1: FSTDs are qualified for use in accordance with 14 CFR part 60.
Note 2: The FAA accepts the outcomes of evaluations of FSTDs, as applicable, in accordance with the appropriate authority’s Bilateral Aviation Safety Agreement (BASA) Simulator Implementation Procedure (SIP).
3.6 Review and Approval. FSBRs are approved as designated by the Executive Director, Flight Standards Service. In the event that revision of an FSBR is necessary, the FSB is provided with necessary policy guidance to implement applicable changes.
3.7 Appeal of FAA Decisions. When there is disagreement with recommendations of an FSBR, that disagreement may be expressed to the FSB Chair for the pertinent type-certificated aircraft. If an issue cannot be resolved, the issue may then be addressed to the AED. Additional information, data, or analysis may be provided to support differing views regarding the FSB recommendations in question.
Appendix A A-1 APPENDIX A. ADMINISTRATIVE PARAGRAPHS A.1 Acronyms and Abbreviations.
Term Definition 14 CFR Title 14 of the Code of Federal Regulations AC Advisory Circular ACS Airman Certification Standards ACSA Office of Air Carrier Safety Assurance ACSAA Aircraft Certification, Safety, and Accountability Act ACT ARC Air Carrier Training Aviation Rulemaking Committee ADF Automatic Direction Finder ADS-B Automatic Dependent Surveillance Broadcast AED Aircraft Evaluation Division AFM Aircraft Flight Manual AIR Aircraft Certification Service ASI Aviation Safety Inspector ATC Air Traffic Control BASA Bilateral Aviation Safety Agreement CBT Computer-Based Training CPT Cockpit Procedures Trainer CTLC Common Takeoff and Landing Credit CVR Cockpit Voice Recorder DPE Designated Pilot Examiner DRS Dynamic Regulatory System DT Differences Table EFB Electronic Flight Bag EFVS Enhanced Flight Vision System ETOPS Extended Operations F&R Function and Reliability FAA Federal Aviation Administration FLT CHAR Flight Characteristics FFS Full Flight Simulator
Appendix A A-2 Term Definition FGCS Flight Guidance Control System FHA Functional Hazard Assessment FMS Flight Management System FOEB Flight Operations Evaluation Board FPC Full Proficiency Check FS Flight Standards Service FSB Flight Standardization Board FSBR Flight Standardization Board Report FSTD Flight Simulation Training Device FTD Flight Training Device FTP Flight Test Pilot FTPM Fleet Training Program Manager GASA Office of General Aviation Safety Assurance HF Human Factor HUD Head-Up Display IFR Instrument Flight Rules LOA Letter of Authorization LOF Line-Oriented Flying MDR Master Differences Requirements MFF Mixed Fleet Flying M/M Make/Model M/M/S Make, Model, and Series MMEL Master Minimum Equipment List NAS National Airspace System NSP National Simulator Program ODR Operator Differences Requirements OEM Original Equipment Manufacturer OSS Office of Safety Standards PIC Pilot in Command POI Principal Operations Inspector PPC Partial Proficiency Check