The objective of this Notice of Proposed Amendment (NPA) is to propose amendments to the Certification Specifications for Operational Suitability Data (OSD) for Flight Crew to reflect, within the scope of regular updates, best practices and experience gained since its first implementation. (CS FCD Initial Issue was published on 31 January 2014).
To this end, this NPA proposes the following amendments to CS-FCD:
- An update of the evaluation process setting up type rating requirements, training programmes and evaluation descriptions. The update comprises the review of evaluation tests (T Tests) to facilitate the comprehension and understanding.
- An update of the evaluation process (diagram) to clarify the T test evaluation flow and logic for same or new type rating.
- The inclusion of guidance material (GM) on the evaluation process. The new GM runs through the stages of the process, describes the purpose of each evaluation test, and identifies type ratings and level of training and checking requirements.
- Clarification of the applicability of OSD Flight Crew to new applications for TC. The clarification was required due to the removal of the ‘complex motor-powered aircraft’ definition from the Basic Regulation (Regulation (EU) 2018/1139), and does not change the applicability.
- Alignment with the ongoing revision of CS-FSTD in the context of the upcoming Issue 3. The alignment takes on board the updated FSTD capability signature and difference level of training for FSTD features.
- A revision of the scope of CS-FCD to identify all the subjects covered in the CS.
- Development of definitions for ‘checking’, ‘evaluation subjects’, ‘modification’ and ‘type of aircraft’ for the purpose of CS-FCD.
- Clarification of the content of Master Difference Requirement tables. Elements identified in the table are the highest difference levels for training, checking and currency from the Difference Requirement (DR) tables.
- Review and update of the difference levels for training, checking and currency. The removal of Level E for currency to align with the evaluation process setting type rating requirements and training programmes.
- Renaming of Operator Difference Requirement (ODR) tables as DR tables to differentiate from Regulation (EU) No 965/2012 on air operations, including revision of elements pertaining to the table.
- Alignment with current practice of the location to record the determination of a type rating or variant. The OSD for flight crew are identified to record this data.
The proposed amendments are expected to facilitate the applicant’s compliance with the OSD requirements for flight crew and increase efficiency by rendering the evaluation process of applications more comprehensible. Overall, the proposed changes are expected to have a moderate safety benefit, and they would have no social or environmental impact.