Aircrew

Licensing

How can a national pilot licence be converted into an EASA pilot licence?

In accordance with Regulation (EC) No 216/2008 in the field of pilot licensing, the Agency is not authorised to issue pilot licences and therefore there will not be any EASA pilot licence in the future.

According to Annex I (Part-FCL) to Commission Regulation (EU) No 1178/2011 on Aircrew, the title of a new licence issued in accordance with this Annex is a Part-FCL licence.

National licences shall be converted into Part-FCL licences by the competent authority of the Member State that issued the national licence in accordance with Article 4 of Commission Regulation (EU) No 1178/2011 on Aircrew and its amending Commission Regulation (EU) No 290/2012.

Conclusion:
The competent authorities of Member States will convert and issue Part-FCL licences and not the Agency.

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How can a national pilot licence be converted into a Part-FCL licence?

Existing national pilots licences will be converted in accordance with Article 4 of Commission Regulation (EU) No 1178/2011 on Aircrew and its amending Commission Regulation (EU) No 290/2012.

JAR-compliant licences issued or recognised by the Member State before the applicability of Commission Regulation (EU) No 1178/2011 on Aircrew shall be deemed to have been issued in accordance with this Regulation, and shall be replaced with a Part-FCL licence by 8 April 2018 at the latest.

Non-JAR-compliant licences, including any associated ratings, certificates, authorisations and/or qualifications issued or recognised by the Member State before applicability of Commission Regulation (EU) No 1178/2011 on Aircrew shall be converted into Part-FCL licences by the Member State that issued the licence in accordance with the provisions of Annex II to that Regulation or the requirements laid down in a conversion report.

As stated in Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though flexibility was introduced via transition measures contained in Article 12 of Regulation (EU) No 1178/2011 on Aircrew and Article 1 paragraph (6) of Regulation (EU) No 290/2012.

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What is the difference between the terms FCL (Flight Crew Licensing) and Aircrew?

Aircrew is the common term for "Flight Crew" and "Cabin Crew".
The new Implementing Rules cover both flight crew and cabin crew, and were published as Commission Regulation (EU) No 1178/2011 laying down technical requirements and administrative procedures related to civil aviation aircrew and its amending Commission Regulation (EU) No 290/2012.

Annex I to the above-mentioned Regulation on Aircrew contains Implementing Rules for Flight Crew (Part-FCL).

Annex V to this Regulation on Aircrew contains Implementing Rules for Cabin Crew (Part-CC).

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Will a licence issued in accordance with JAR-FCL requirements still be valid once the new rules become applicable?

Commission Regulation (EU) No 1178/2011 on Aircrew contains transition measures to ensure that JAR-FCL licences issued by Member States in accordance with JAR-FCL requirements and procedures will be grandfathered.

This means that holders of JAR compliant pilots' licences can continue to exercise the privileges of their licences after Commission Regulation (EU) No 1178/2011 on Aircrew applies, without the need for any further administrative procedures, but these licences shall be replaced with Part-FCL licences by 8 April 2018 at the latest. Further information can be found in paragraph 3 of Article 1 of Commission Regulation (EU) No 290/2012 on Aircrew (which amends the date of 8 April 2017 as stated in paragraph 1 of Article 4 of Commission Regulation (EU) No 1178/2011).

Please note that Member States are not forced to replace valid JAR pilots' licences before the end of their validity period as these licences will be deemed to have been issued under the Part-FCL requirements.

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Will a national licence that does not comply with JAR-FCL requirements still be valid once the new rules become applicable?

Once Commission Regulation (EU) No 1178/2011 on Aircrew becomes applicable in a certain Member State, it will no longer be possible to fly with a licence that does not comply with those requirements (except in the case of aircraft included in Annex II to Regulation (EC) No 216/2008, according to Article 4(5)). 
Consequently, a national licence will need to be converted into a Part-FCL licence. To deal with those licences issued by Member States in accordance with national rules deviating from JAR-FCL, transition measures have been established in Commission Regulation (EU) No 1178/2011 on Aircrew. These transition measures foresee a certain amount of time to convert the national licences into fully compliant Part-FCL licences.

As stated in Article 12 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date is 8 April 2012, though by way of derogation from this paragraph, Member States may decide not to apply the provisions of Annex I related to pilot licences of powered-lift aircraft, balloons, airships and sailplanes until 8 April 2015. 
Member States may also decide not to convert non-JAR-compliant aeroplane and helicopter licences that they have issued until 8 April 2014.

Non-JAR compliant national licences may be converted into Part-FCL licences by the competent authority as follows:

  • for aeroplanes and helicopters, in accordance with the requirements of Annex II to Commission Regulation (EU) No 1178/2011 on Aircrew ;
  • for other categories of aircraft, on the basis of a conversion report drawn up by the competent authority.
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Could the Agency assist with interpreting the JAR-FCL requirements?

JAR-FCL was drafted to harmonise European regulations on flight crew licensing in order to facilitate mutual recognition of licences and ratings. However, the Joint Aviation Requirements (JAR) (see the JAA publications) have been implemented under national law and under the full responsibility of each Member State.

Therefore the Rulemaking Directorate is not in the position to interpret or make comments on JAR-FCL requirements. In addition, please note that the Agency cannot intervene in cases where the national JAR text deviates from the original.

The national aviation authorities are responsible for interpreting and implementing JAR-FCL requirements.
We therefore recommend that for assistance in interpreting the JAR-FCL requirements, the national aviation authorities should be contacted directly.

A list of the national aviation authorities can be found here.

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Is it correct that there are new requirements for instrument ratings (IR) and provisions to allow cloud flying for sailplane pilots published in the Aircrew Regulation?

Yes, this is correct.

On 3 April 2014 Commission Regulation 245/2014 and Agency ED Decision 2014/022/R entered into force. This Regulation and associated AMC/GM include a new competency-based instrument rating (CB IR) and an en route instrument rating (EIR) for private (PPL(A)) and commercial pilot (CPL(A)) licence holders, and a sailplane cloud flying rating.

The new provisions establish a more accessible IR enabling more European General Aviation (GA) pilots to obtain such rating, thereby increasing safety by reducing the number of potential controlled flights into terrain (CFIT). Moreover, the proposed CB IR course will contain a reduced theoretical knowledge (TK) syllabus appropriately reflected by a different level of TK examinations and a reduced amount of instrument flight instruction time when compared with the existing IR courses. Furthermore, the EIR requires less training, but nevertheless consists of more comprehensive flight training when compared to the basic instrument flight module of the existing IR. As the EIR only provides en route IFR privileges, this rating serves as a stepping stone towards the IR through the proposed competency-based route. Both CB IR and EIR include provisions for crediting a certain amount of instrument flight time on aeroplanes outside of an ATO, such as instrument flight time under instruction, prior pilot-in-command (PIC) instrument flight time, including crediting provisions for third-country IR holders.

The cloud flying rating for sailplane pilots allows holders to enter clouds whilst taking into account the airspace structure, the required minima in different airspace categories, and the relevant Air Traffic Control (ATC) procedures.

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Following the introduction of a new variant to an existing type rating, how do pilots attain the privileges to operate the new variant?

  1. Licensing following the introduction of a new variant to an existing type rating.

    When a new variant of a type is introduced the existing type endorsement in the pilot licence may remain unchanged but valid for all variants as included in the ‘EASA Type Rating & License Endorsement List Flight Crew’ published on the Agency’s web page. The new endorsement should be added by the pilot’s competent authority at the next routine licensing action or at the request of the pilot in accordance with ARA.FCL.220 (a).
     

  2. Exercise of the licence privileges in the new variant.

    The pilot must receive differences training or familiarisation as appropriate in accordance with FCL.710. This would mean the pilot has to undergo a differences training course under the responsibility of a qualified instructor and have it confirmed with the instructor’s signature in the pilot’s logbook.
     

  3. Qualification of pilots, instructors and examiners for the new variant:

     

    1. Pilots holding a type rating intending to operate the new variant should receive differences training in accordance with FCL.710. This differences training is to be recorded in the pilot’s logbook and signed by a qualified instructor.
       
    2. Instructors holding instructor privileges as a TRI or SFI on the existing type intending to use their instructor privileges also on the new variant should qualify in accordance with either FCL.900(b) (special conditions for the introduction of a new type) or with (a) above (differences training on the new variant).
       
    3. Examiners holding examiner privileges as a TRE or SFE on the existing type intending to use their examiner privileges also on the new variant should qualify in accordance with either FCL.1000(b) (special conditions for the introduction of a new type) or with (a) and (b) above (differences training on the new variant and instructor privileges).
       
    4. Pilots, instructors and examiners without existing type privileges shall complete the full type rating course and follow the requirements of Part-FCL for instructor and examiner privileges on any variant in the type.
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How should the new class and type rating list for aeroplanes which is published on the Agency’s website be understood ? (complex aircraft, SET class, PA 46, instructor qualification)

The new list intends to make it easier to find specific aeroplanes by putting them into alphabetical order and abandoning the former grouping into many different lists. The aeroplanes which belong to the group of single pilot high performance complex aeroplanes are identified as such.

  1. Information on the SET class:
    Those aeroplanes that belong to a specific group whilst they still require aeroplane specific training, testing and checking have a licence endorsement that specifies that they are in this group and the remarks column provides any information if an OSD report was established. (SET class with a validity of 2 years, FCL.740(a)).
    Nevertheless all members of the SET class rating group require a class rating specific for the aeroplane and those ratings have to be revalidated individually with the possibility of any credits that are mentioned in the OSD for the relevant aeroplane.
    There is no generic SET (land) or SET(sea) rating to be entered in a pilot licence.
     
  2. Information on PA 46:
    The piston engine variants of the PA 46 may now be treated as falling within the SEP(land) class but require a difference training on one of the PA 46 piston engine variants. For revalidation there is no class specific requirement the revalidation can be done by experience on any SEP plus a training flight on any SEP or any proficiency check or no experience and a proficiency check on any SEP.
    The SET PA 46 class rating can be obtained with an approved difference training course from the piston engine PA 46 or with a specific SET PA 46 class rating course both of which have to be done in an ATO on a SET PA 46. As it is a separate class rating the requirements of FCL.725 (a)(b)(c) apply and as it is an HPA also the relevant requirements for those aeroplanes apply.
     
  3. Information on instructor qualification for SET class:
    With the facts mentioned above the instructor requirements for a CRI or FI are to be considered class specific. Meaning PA 46 with piston engine will require an instructor qualification for SEP with difference training for the PA 46 piston engine. All SET class ratings to be covered as individual class ratings with individual instructor qualifications as indicated on the licence endorsement list.

The list will shortly undergo further editorial changes. The Agency tries to make the list more easily understandable and therefore has amended it and the explanatory note that comes with it.”

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When will the new rules on pilot licensing be applicable?

The new Implementing Rules implementing the requirements set out in Regulation (EC) No 216/2008 in the field of pilot licensing were published as Commission Regulation (EU) No 1178/2011 on Aircrew in the Official Journal of the European Union on 25 November 2011.
In November 2011, the first four annexes to Commission Regulation (EU) No 1178/2011 on Aircrew were published:

  • Annex I - Part-FCL (flight crew licensing)
  • Annex II - Conditions for the conversion of existing national licences and ratings for aeroplanes and helicopters
  • Annex III - Conditions for the acceptance of licences issued by or on behalf of third countries
  • Annex IV - Part-MED (medical).

The remaining annexes were published in the Official Journal of the European Union on 5 April 2012 as Commission Regulation (EU) No 290/2012 amending Commission Regulation (EU) No 1178/2011 on Aircrew. These annexes are:

  • Annex V - Part-CC (cabin crew)
  • Annex VI - Part-ARA (authority requirements for aircrew)
  • Annex VII - Part-ORA (organisation requirements for aircrew)

As stated in Article 12 paragraph 1 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though by way of derogation from this paragraph in accordance with Article 1 paragraph (6) and Article 2 paragraph 2. (a) of Commission Regulation (EU) No 290/2012, Member States could decide not to apply the provisions of the aforementioned Annexes until 8 April 2013.
The amending Regulation introduced additional transition measures deferring the applicability of certain Implementing Rules to a later date. Therefore the exact date of applicability of each requirement depends on the transition measures introduced by the Member States. 
Until the date the new Implementing Rules apply, Member States national rules remain in force. 
The related Acceptable Means of Compliance and Guidance Material to:

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How can a third country (non-EU) licence be converted into a Part-FCL licence?

Pilots licences issued by third countries will be accepted in accordance with Article 8 of Commission Regulation (EU) No 1178/2011 on Aircrew .

According to paragraph 1 of this Article 8, the Member State may accept a third country licence, and the associated medical certificate, in accordance with the provisions of Annex III to the Regulation.
For the issue of a Part-FCL licence, the holder of at least an equivalent third country licence issued in accordance with ICAO Annex 1 shall comply with all the relevant requirements of Annex I to the Regulation (Part-FCL), except that the requirements of course duration, number of lesson and specific training hours may be reduced.

As stated in Article 12 of Commission Regulation (EU) No 1178/2011 on Aircrew, the application date was 8 April 2012, though by way of derogation from this paragraph, Member States could decide not to apply the provisions of Annex I to pilots holding a licence and associated medical certificate issued by a third country involved in non-commercial flights until 8 April 2015.

The competent authority of the Member State to which an applicant applies will determine the conversion requirements, which can be reduced on the basis of a recommendation from an approved training organisation.

Therefore, the national aviation authority of the Member State where an applicant resides or wishes to work should be contacted for further information concerning the applicable acceptance requirements.

To find a list of the national aviation authorities, please follow this link.

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To whom can an appeal against the examination/test/check results be sent?

If an applicant does not agree with the result of his/her assessment, he/she can only resolve this problem at the national level.

An applicant cannot apply to the EASA management regarding a decision taken by his/her national aviation authority. Appeals to the Agency can only be made against decisions of the Agency.

Therefore the applicant should resolve this problem on the national level by sending his/her complaints to the national body dealing with complaints against state authorities.

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Could the European Central Question Bank be published?

The Agency is the administrator of the European Central Question Bank (ECQB).

Taking into account that:

  1. Ownership of the copyright of the ECQB database is vested to the European Aviation Safety Agency; and
  2. Ownership of the contents of the database remains vested to its respective owners; and
  3. The possession, management and administration of the contents of the database have been fully vested in the hands of the Agency; and
  4. The contents of the database are confidential and have been treated as such without interruption.

The Agency, acting in the capacity of copyright owner and administrator of the database, enjoys the exclusive right among others, to prevent temporary or permanent reproduction by any means and in any form, as well as to prevent any form of distribution to the public of the database or of copies thereof.

It is the opinion of the Agency that such reproduction and distribution would endanger the functionality and integrity of the applicable examination system and would invalidate the associated substantial investment in both intellectual and monetary terms.

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How can a military licence be converted to a civilian one?

The EU rules for recognising military licences can be found in Commission Regulation (EU) No 1178/2011 on Aircrew. Article 10 states that the knowledge, experience and skill gained in military service shall be credited towards the relevant requirements of Part-FCL in accordance with the principles of a credit report established by the competent authority of the Member State where a pilot served, in consultation with the Agency.

Therefore, the competent authority of the Member State where the pilot served should be contacted and asked for the provisions applicable for such credits.

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Which licence do I have to hold to become a TRI on a multi pilot aeroplane (MPA)?

The prerequisites to obtain and hold any TRI rating are regulated in FCL.915.TRI. There it is stated in a) that an applicant for a TRI rating shall hold a CPL, MPL or ATPL pilot licence on the applicable aircraft category.

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Can a co-pilot apply for a TRI rating on a multi pilot aeroplane (MPA)?

Yes, but the rating has to be restricted to simulator training only. The reason is that FCL.915 b) (3) stipulates that all instructors providing flight training in an aircraft have to be able to act as PIC during the training flight which would not be allowed to a co-pilot.

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Performance-based Navigation applicability

On which learning objectives will my theoretical knowledge training and exam for the instrument rating be based?

Until the 25 August 2018 all training courses follow the published learning objectives without PBN requirements. After this date Commission Regulation (EU) No 2016/539 applies and the IR training courses shall contain also the PBN elements. 

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When can I apply to my competent authority for a PBN extension to my instrument rating?

After the 25 August 2018, when the Commission Regulation (EU) No 2016/539 applies and the applicant fulfils the relevant training and checking requirements.  

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When does my approved training organisation have to comply at the latest with the PBN requirements?

The aircraft and FSTDs used for training have to comply with the requirements at the latest on 25 August 2018 if the training contains the required PBN elements. Approved training organisations providing training that started before 25 August 2018 may continue to train towards an IR until 25 August 2020. Such an IR cannot contain PBN privileges. 

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When can an ATO apply for an approval of a new course and on which learning objectives will the course be based?

The PBN related amendment to the Aircrew Regulation was published with Regulation (EU) 2016/539 and entered into force on 7 April 2016. Since this date an IR course including PBN privileges can be approved to an ATO provided that the course complies with the requirements specified in Regulation (EU) 2016/539 and the associated AMCs. But the course can only start after the entry into force of the PBN related elements of the Regulation (25 August 2018).

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When does my instrument rating have to include PBN privileges to be allowed to fly in IFR conditions ?

IR holders who want to fly PBN procedures have to hold PBN privileges from 25 August 2018. 

Pilots who fly on routes and approaches that do not require PBN privileges may continue to fly on an IR without PBN privileges until 25 August 2020. 

All IRs shall contain PBN privileges from 25 August 2020.

 

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Upset Prevention and Recovery Training

What is UPRT?

UPRT stands for aeroplane ‘upset prevention and recovery training’ and constitutes a combination of theoretical knowledge and flying training with the aim of providing flight crew with the required competencies to both prevent and to recover from situations in which an aeroplane unintentionally exceeds the parameters for line operation or training (aeroplane upsets).

With the objective to introduce different ‘levels’ of UPRT at various stages of a professional pilot’s career, EASA has published its Opinion No 06/2017 and is currently revising the existing acceptable means of compliance (AMC) and guidance material (GM) published with regard to the provisions of Annex I (Part-FCL) to Regulation (EU) No 1178/2011 as follows:

  • Basic UPRT will exercises to be integrated in all CPL and ATPL training courses as well as the MPL training course.
  • An ‘advanced UPRT course’ will include at least 5 hours of theoretical instruction as well as at least 3 hours of dual flight instruction in an aeroplane, with the aim to enhance the student’s resilience to the psychological and physiological aspects associated with upset conditions.
  • Class- or type-related UPRT during class or type rating training will address the specificities of the relevant class or type of aeroplane.
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Which pilots need to undergo what kind of UPRT?

The different ‘levels’ of UPRT (please refer to the FAQ ‘What is UPRT?’) will be integrated into pilot training as follows:

  • basic UPRT
    • all modular and integrated CPL and ATP training courses for aeroplanes as well as the integrated MPL training course
       
  • advanced UPRT course’
    • Part of; 
      • integrated ATP course
      • integrated MPL course
    • Perquisite to;
      • training courses for single-pilot class or type ratings operated in multi-pilot operations
      • training courses for single-pilot high performance complex aeroplanes
      • training courses for multi-pilot aeroplanes
  • class-or type-related UPRT
    • training courses for single-pilot high performance complex aeroplanes
    • training courses for multi-pilot aeroplanes
    • bridge course for extending privileges on a single-pilot aeroplane to multi-pilot operations
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From when UPRT will be mandatory?

The entry-into-force / start of applicability of the new UPRT provision will depend on the progress of the rulemaking process following the publication of EASA Opinion No 06/2017 on 29 June 2017. For the time being, 8 April 2019 is envisaged as the day from which the new regulatory framework on UPRT will apply. Transitional provisions will allow ongoing courses to be finished pursuant to the rules as in force today.

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To which extend flight synthetic training devices (FSTDs) can be used for UPRT?

Training and checking of UPRT exercises within the validated training envelope of the particular FSTD will be possible. In this context, it needs to be highlighted that the revised Part-FCL requirements will mandate the conduct of ‘approach-to-stall’ exercises only, with no obligation to conduct ‘post-stall’ exercises.

For further information, please refer to EASA Opinion No 06/2017, Section 2.3.8.

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Will UPRT also be mandatory for the LAPL and the PPL?

EASA Opinion No 06/2017 aims at integrating UPRT at various stages of a professional pilot’s career. The proposed new provisions of Part-FCL will therefore not be applicable to training courses for the light aircraft pilot licence (LAPL) and the private pilot licence (PPL).

However, in order to address the fact that loss of control in-flight is still a major issue in general aviation, EASA intends to revise the existing AMC/GM published with regard to the provisions of Part-FCL, with the objective to integrate basic UPRT elements into existing training syllabi for the LAPL and the PPL.

For further information, please refer to EASA Opinion No 06/2017, Section 2.3.1.

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Operational Suitability Data (OSD) for flight crew (FC)

How can I get access to OSD FC documents?

Contrary to Operational Evaluation Board (OEB) reports which were owned and published by EASA, OSD documents are certification documents which are held by the TC/STC Holder within the framework of Annex I to Commission Regulation No 748/2012 (Part-21). 

Paragraph 21.A.62 of Part-21 establishes requirements for the owner of the data (type certificate (TC)/supplemental type certificate (STC) holder) on making these OSD data available. It reads as follows:

21.A.62 Availability of operational suitability data
The holder of the type-certificate or restricted type-certificate shall make available: 

(a) at least one set of complete operational suitability data prepared in accordance with the applicable operational suitability certification basis, to all known EU operators of the aircraft, before the operational suitability data must be used by a training organisation or an EU operator; and 

(b) any change to the operational suitability data to all known EU operators of the aircraft; and 

(c) on request, the relevant data referred to in points (a) and (b) above, to: 

1. the competent authority responsible for verifying conformity with one or more elements of this set of operational suitability data; and 
2. any person required to comply with one or more elements of this set of operational suitability data.

Consequently, users should request OSD data from the relevant owner, when required. 

To assist users in contacting the relevant owner of the document, EASA provides some information on its website for OSD, in particular an OSD contact list based on feedback from manufacturers. 
 

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What is the content and purpose of the EASA type rating and licence endorsement lists?

Two separate EASA type rating and licence endorsement lists - flight crew are published by EASA (one for helicopters and one for all other aircraft): Type Ratings and Licence endorsement lists.

These lists constitute the class and type of aircraft categorisations in accordance with definitions of category of aircraft, class of aeroplane, and type of aircraft and paragraph FCL.700 and GM1 FCL.700 of Annex I (Part-FCL) to Commission Regulation (EU) No 1178/2011.  

The lists also indicates if operational suitability data (OSD) for flight crew are available. EASA type certificate data sheets (TCDSs) and the list of EASA supplemental type certificates contain further references to OSD. Complete current OSD information is held by the relevant type certificate (TC) or supplemental type certificate (STC) holder.

Furthermore, the lists provide aircraft-specific references relevant to flight crew qualifications and air operations, including references to (non-OSD) documents, such as (J)OEB reports or Operational Evaluation Guidance Material (OE GM).

Explanatory notes for these lists are found at the same website location.

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Why do the EASA type rating and licence endorsement lists not contain references to the latest applicable version of an OSD FC document?

The EASA type rating and licence endorsement lists indicate whether an OSD FC document for a relevant aircraft exists. OSD FC documents are certification documents which are held and maintained by TC/STC Holder and are subject to Annex I to Commission Regulation No 748/2012 (Part-21) provisions. Consequently, changes to OSD are handled in accordance with Part-21 procedures in the same way that e.g. changes to aeroplane flight manual (AFM’s) are dealt with. This includes the principle of delegation of privileges to DOAs based on which minor changes to OSD FC are approved under DOA privileges.

The responsibility of tracking the OSD FC document version resides therefore with the TC/STC holder and referencing that in the TR and licence endorsement list could potentially generate inconsistencies.

Users should consider establishing a process to ensure the regular receipt of OSD FC updates, similarly to what might exist for holding current AFM and quick reference handbook (QRH) documents.

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Are ODR tables available as part of the operational suitability data (OSD) for flight crew (FC) document?

ODR tables which have been established as part of an OSD FC operational evaluation, are part of the OSD FC data, approved under the type certificate (TC)/ supplemental type certificate (STC) and owned by the TC/STC holder. These ODR tables are original equipment manufacturer OEM generic and must be customized for use by operators to their specific aircraft configurations.

Such ODR tables should therefore be requested directly from the TC/STC holder which has an obligation according to Part-21 to make OSD FC documents available to users.

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When should changes to OSD FC provisions be implemented by users to take into account any revised mandatory elements included in a revision?

Article 9a of Commission Regulation No 1178/2011 (amended by Commission Regulation No 70/2014) contains a 2 year transition period for the implementation after initial publication of OSD FC report. This allows training providers, such as ATOs and operators time to adapt their training programmes and provide additional training if needed.

Pilot training courses which were approved before the approval of the OSD FC data should contain the mandatory elements not later than 18 December 2017 or within 2 years after the OSD FC was approved, whichever is later.

Implementation of changes to the OSD FC into existing approved training courses should be implemented within a reasonable timeframe following the OSD change. This timeframe is not clearly defined within the aircrew regulation, however a timeframe of 3 months (or 90 days as under the air ops requirements for an MEL) is considered reasonable. 

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What is the status of non-mandatory items in the OSD FC? How should users proceed if deviating from non-mandatory items in the OSD FC?

The data contained in OSD FC documents are identified as either ‘mandatory’ or ‘non-mandatory’ elements. While mandatory elements have the status of a rule, non-mandatory elements have the status of Acceptable Means of Compliance (AMC). 

In order to provide some flexibility to users, non-mandatory elements typically address such items as training devices, training duration, previous experience, or currency. In line with the general principles for AMCs, these elements are non-binding provisions established as a means of compliance with the Aircrew Requirements.

Users may choose Alternative Means of Compliance (AltMoC) to use alternatives to the OSD-FC non-mandatory parts by following the dedicated process for AltMoCs described in the implementing rules for aircrew licensing and air operations. Further details on the AltMoC process can be found on EASA's website.

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What aspects should be considered when substituting a training level or device described in the OSD FC by another training level or device?

The data approved in the OSD FC are linked to the minimum training syllabus for a pilot type rating. An evaluation of differences (e.g. for aircraft modifications or between variants) identifies minimum training levels and associated training devices, if required. 

With regard to the acquisition of knowledge through theoretical training, some elements may be validated as Level A and can be adequately addressed through self-instruction, whereas other elements may require aided instruction and are identified as Level B. Training organisations may find it more practical to combine Level A and Level B elements into one module of the higher level (such as computer-based training or instructor-led sessions).

With regard to the acquisition of skills through practical training, the OSD FC minimum syllabus identifies elements requiring Level C, D or E practical training and these elements are usually associated in the OSD FC document with specified training devices. 

In principle, the devices described in the OSD FC document and the devices used in pilot training should be of the same training level. The use of a more complex device requires additional considerations, regarding the capabilities and characteristics of the device and the impact this may have on the training objective(s).

As an example, the OSD FC may refer to an FMS desktop trainer for Level C training. FMS training in an FTD, an FFS (without motion or vision) or in the aircraft (static, on power) may provide the same training objectives. However, the more complex training environment introduces elements which may affect the focus of the training, the time required, or other factors and these should be taken into consideration.

The same principles apply for the substitution of an FTD. To replicate the characteristics of an FTD Level I with an FTD Level II, to replicate an FTD Level I with an FFS (without motion or vision), or to replicate an FTD Level II with an FFS (without motion or vision) require different considerations to preserve achievement of the training objective.

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