Appendix 2
(4) ODR Approval, Distribution, and Availability. ODRs are approved for each fleet by an operator’s FAA POI in accordance with FSB report recommendations. ODRs must be prepared, reviewed, approved and then used to govern training before start of operations. The operator retains approved ODRs with a duplicate copy as part of FAA certificate-holding district office (CHDO) records.
(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 operator’s 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. Formulation Process Overview. The process for FAA formulation and revision of training, checking, currency, and pilot type rating requirements is shown in Figure 4. 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 recommends 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 operator’s programs. The formulation and application process of FSB provisions 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 Page 24
Appendix 2 certification or supplemental 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. An operator, manufacturer, or an organization that modifies airplanes proposes a new design or 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:
Appendix 2
(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.
(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.
Appendix 2
(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 is described in Appendix 3.
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 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 more stringent requirements, additional training, additional testing, etc.
Appendix 2 FIGURE 4. MASTER REQUIREMENTS FORMULATION
Appendix 2 FIGURE 5. TEST DEFINITIONS
TEST PURPOSE APPLICATION T1 Establishes functional equivalence Sets levels A/B Pass permits T3, and A/B/C/D; failure sets level E and requires T5 T2 Handling qualities comparison T3 Evaluate 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 provisions—if needed T5 Sets training/checking for new or “E” ACFT Sets level E T6 Evaluation for CTLC Sets recency of experience requirements Note: Expanded descriptions are contained in Appendix 3.
Appendix 2 FIGURE 6. “T” TESTS 1 THRU 5
Appendix 2
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 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. Specification of MDRs, example ODRs, acceptable training programs, and other FSB provisions and recommendations are completed. Any necessary pilot testing or currency provisions are identified. Assignment of any necessary pilot type rating(s) is made. This information is published in a report that is sent to AFS-200 for coordination. After approval, it is to be used by the POI as guidance in approving operator training, checking, and currency programs.
(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 provisions are set following solicitation and review of comments.
(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.
Appendix 2 FIGURE 7. STANDARD METHOD, DEVICES, AND SIMULATORS
Difference Level Difference Level Definition Methods Devices or Simulators (1) A Self instruction Bulletins Manual revisions Handout material ------------------------- B Aided instruction Slides/video tapes Standup instruction Computer-based training (CBT) ------------------------- C System devices ------------------------- Training devices level 2/3/4/5 Full task computer based instruction (CBI)(2) D Maneuver devices ------------------------- Training devices level 6/7 (3) E Simulator C/D or aircraft ------------------------- Simulator C/D Or aircraft
(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 simulato r 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 apply FSB recommendations. The following are elements of an FSB report:
(a) Purpose and Applicability
(b) Pilot Type Rating requirements
(c) Master Difference Requirements (MDRs)
(d) Acceptable Operator Difference Requirements (ODR) Tables
(e) FSB Specifications for Training
(f) FSB Specifications for Checking
(g) FSB Specifications for Recency of Experience Page 32
Appendix 2
(h) Aircraft Regulatory Compliance Checklist
(i) FSB Specification for Training Devices and Simulators
(j) Applications
(k) Alternate Means of Compliance
(l) Regulatory Coordination and Approval
(m) Board Record
(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 recommendations and guidance are provided to FAA field offices through FSB reports for each aircraft. These reports are recommendations 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 a 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 may not approve programs that are less than master requirements unless authorization is obtained from AFS-200. Aviation safety inspectors (ASI), aircrew program managers (APM), aircrew program designees (APD), and designated pilot examiners (DPE) may 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 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 are 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 Page 33
Appendix 2 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 will determine if the change affects MDRs, example ODRs, or other FSB report provisions. This determination should assess 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 analysis of the effects of the difference. The POI will make a preliminary estimate of the difference levels, then advise the applicable AEG/FSB. The AEG/FSB may concur with the POI’s assessment or propose 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 may be 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 and FSB reports comprehensively address differences training, checking, and currency 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 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 provisions 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 Page 34
Appendix 2 operator’s specific program. ODR tables must be prepared and approved by the FAA for each fleet in which FSB provisions are established.
(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 type-certificated 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 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 Page 35