ORO.FC.140 Operation on more than one type or variant

GENERAL

(a)The concept of operating more than one type or variant depends on the experience, knowledge and ability of the operator and the flight crew concerned.

(b)The first consideration is whether operations on one aircraft type or variant allow the safe operation of all other types and variants.

(c)The second consideration is whether and how adequate training to address potential confusion and increased workload caused by the operation of several types or variants is achieved.

GENERAL

(a)Terminology The terms used in the context of operation on more than one type or variant have the following meaning:

(1)‘Base aircraft’ refers to an aircraft used as a reference to compare differences with another aircraft.

(2)‘Variant’ refers to an aircraft or a group of aircraft within the same pilot type or class rating that has differences with the base aircraft and requires differences training or familiarisation.

(3)A ‘variation in aircraft configuration’ refers to an aircraft or a group of aircraft within the same variant that has differences with the base aircraft and requires equipment and procedure training.

(4)‘Credit’ refers to the recognition of recurrent training, checking or recent experience based on commonalities between aircraft.

(5)‘Operator difference requirements (ODRs)’ refer to a formal description of differences between types or variants or aircraft configurations flown by a particular operator.

(6)‘Training’ refers to differences training, familiarisation and equipment training.

(7)‘Currency’ refers to the recurrent training on types and variants.

(b)Scope of ODRs The operator should use the ODRs methodology, a means of evaluating aircraft differences and similarities, in order to define the training and checking in the following cases:

(1)for the introduction of a change of equipment on a type or variant currently operated;

(2)for the introduction of a new variant within a type or class currently operated;

(3)for the recurrent training and checking of variations in aircraft configuration. The operator may define credit based on ODRs tables;

(4)for the operation of more than one type or variant when credit is sought, in which case all of the following should apply:

(i)All training, checking and currency requirements should be completed independently for each type or variant unless credits have been established by using ODRs tables.

(ii)All recent experience requirements should be completed independently for each type unless credits have been established by using ODRs tables.

(iii)The operator may define credit based on ODRs tables that should not be less restrictive than the OSD.

(c)ODRs methodology

(1)The operator should conduct a detailed evaluation of the differences or similarities of the aircraft concerned in order to establish appropriate procedures or operational restrictions. This evaluation should be based on the OSD for the relevant types or variants and should be adapted to the operator’s specific variations in aircraft configuration. This evaluation should take into account all of the following:

(i)the level of technology;

(ii)operational procedures; and

(iii)handling characteristics.

(2)ODRs tables The operator should first nominate one aircraft as the base aircraft from which to show differences with the second aircraft type or variant or variation in aircraft configuration, the ‘difference aircraft’, in terms of technology (systems), procedures, pilot handling and aircraft management. These differences, known as ODRs, preferably presented in tabular format, constitute part of the justification for operating more than one type or variant and also the basis for the associated differences/familiarisation or reduced type rating training for the flight crew.

(3)The ODRs tables should be presented as follows:

(4)Compilation of ODRs tables

(i)ODRs 1: General The general characteristics of the candidate aircraft are compared with the base aircraft with regard to:

(A)general dimensions and aircraft design (number and type of rotors, wing span or category);

(B)flight deck general design;

(C)cabin layout;

(D)engines (number, type and position);

(E)limitations (flight envelope).

(ii)ODRs 2: Systems Consideration is given to differences in design between the candidate aircraft and the base aircraft. For this comparison, the Air Transport Association (ATA) 100 index is used. This index establishes a system and subsystem classification and then an analysis is performed for each index item with respect to the main architectural, functional and operations elements, including controls and indications on the systems control panel.

(iii)ODRs 3: Manoeuvres Operational differences encompass normal, abnormal and emergency situations and include any change in aircraft handling and flight management. It is necessary to establish a list of operational items for consideration on which an analysis of differences can be made. The operational analysis should take the following into account:

(A)flight deck dimensions (size, cut-off angle and pilot eye height);

(B)differences in controls (design, shape, location and function);

(C)additional or altered function (flight controls) in normal or abnormal conditions;

(D)handling qualities (including inertia) in normal and in abnormal configurations;

(E)aircraft performance in specific manoeuvres;

(F)aircraft status following failure;

(G)management (e.g. ECAM, EICAS, navaid selection, automatic checklists).

(iv)Once the differences for ODRs 1, ODRs 2 and ODRs 3 have been established, the consequences of differences evaluated in terms of flight characteristics (FLT CHAR) and change of procedures (PROC CHNG) should be entered into the appropriate columns.

(v)Difference levels — crew training, checking and currency

(A)In order to operate more than one type or variant, the operator should establish crew training, checking and currency requirements. This may be done by applying the coded difference levels from the table in point (d)(2) to the compliance method column of the ODRs tables.

(B)Differences identified in the ODRs tables as impacting flight characteristics or procedures, should be analysed in the corresponding ATA section of the ODRs manoeuvres. Normal, abnormal and emergency situations should be addressed accordingly.

(d)Difference levels

(1)Difference levels — general Difference levels are used to identify the extent of a difference between a base and a candidate aircraft with reference to the elements described in the ODRs tables. These levels are proportionate to the differences between a base and a candidate aircraft. A range of five difference levels in order of increasing requirements, identified as A through E, are each specified for training, checking, and currency. Difference levels apply when a difference with the potential to affect flight safety exists between a base and a candidate aircraft. Differences may also affect the knowledge, skills, or abilities required from a pilot. If no differences exist, or if differences exist but do not affect flight safety, or if differences exist but do not affect knowledge, skills or abilities, then difference levels are neither assigned nor applicable to pilot qualification. When difference levels apply, each level is based on a scale of differences related to design features, systems, or manoeuvres. In assessing the effects of differences, both flight characteristics and procedures are considered since flight characteristics address handling qualities and performance, while procedures include normal, non-normal and emergency items. Levels for training, checking, and currency are assigned independently, but are linked depending on the differences between a base and candidate aircraft. Training at level E usually identifies that the candidate aircraft is a different type from the base aircraft.

(2)Difference levels are summarised in the table below regarding training, checking, and currency.

Footnote (1): Aeroplane: FTD level 2, or FFS, or aeroplane Helicopter: FTD levels 2 and 3, or FFS, or helicopter Footnote (2): Aeroplane: FFS level C or D, or aeroplane Helicopter: FSTDs having dual qualification: FFS level B and FTD level 3, or FFS level C or D, or helicopter Training levels A and B require knowledge, levels C and D require additional skills. Training level E means that the differences are such that type rating training is required or, in the context of equipment and procedure training, aircraft/FSTD training and checking is required.

(3)Difference levels — training The training difference levels specified represent the minimum requirements. Devices associated with a higher difference level may be used to satisfy a training differences requirement.

(i)Level A training Level A differences training is applicable to aircraft with differences that can adequately be addressed through self-instruction. Level A training represents a knowledge requirement such that once appropriate information is provided, understanding and compliance can be assumed to be demonstrated. Training needs not covered by level A training may require level B training or higher, depending on the outcome of the evaluations described in the aircraft evaluation process (CS FCD.420).

(ii)Level B training Level B differences training is applicable to aircraft with system or procedure differences that can adequately be addressed through aided instruction. At level B aided instruction, it is appropriate to ensure pilot understanding, emphasise issues, provide a standardised method of presentation of material, or to aid retention of material following training.

(iii)Level C training Level C differences training can only be accomplished through the use of devices capable of systems training. Level C differences training is applicable to variants having ‘part task’ differences that affect skills or abilities as well as knowledge. Training objectives focus on mastering individual systems, procedures, or tasks, as opposed to performing highly integrated flight operations and manoeuvres in ‘real time’. Level C may also require self-instruction or aided instruction of a pilot, but cannot be adequately addressed by a knowledge requirement alone. Training devices are required to supplement instruction to ensure attainment or retention of pilot skills and abilities to accomplish the more complex tasks, usually related to operation of particular aircraft systems. The minimum acceptable training media for level C are interactive computer-based training, cockpit systems simulators, cockpit procedure trainers, part task trainers (such as inertial navigation system (INS), flight management system (FMS), or traffic collision avoidance system (TCAS) trainers), or similar devices.

(iv)Level D training Level D differences training can only be accomplished with devices capable of performing flight manoeuvres and addressing full task differences affecting knowledge, skills, or abilities. Devices capable of flight manoeuvres address full task performance in a dynamic ‘real time’ environment and 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. At level D, knowledge and skills to complete necessary normal, non-normal and emergency procedures are fully addressed for each variant. Level D differences training requires mastery of interrelated skills that cannot be adequately addressed by separate acquisition of a series of knowledge areas or skills that are interrelated. However, the differences are not so significant that a full type rating training course is required. If demonstration of interrelationships between the systems was important, the use of a series of separate devices for systems training would not suffice. 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 manoeuvre visual cues, motion cues, dynamics, control loading or specific environmental conditions. Weather phenomena such as low-visibility conditions or wind shear may or may not be incorporated. Where simplified or generic characteristics of an aircraft type are used in devices to satisfy level D differences training, significant negative training should not occur as a result of the simplification. Appropriate devices as described in CS FCD.415(a), satisfying level D differences training range from those where relevant elements of aircraft flight manoeuvring, performance, and handling qualities are incorporated. The use of a manoeuvre training device or aircraft is limited for the conduct of specific manoeuvres or handling differences, or for specific equipment or procedures.

(v)Level E training Level E differences training is applicable to candidate aircraft that have such significant ‘full task’ differences that a full type rating training course or a type rating training course with credit for previous experience on similar aircraft types is required to meet the training objectives. The training requires a ‘high-fidelity’ environment to attain or maintain knowledge, skills, or abilities that can only be satisfied by the use of FSTDs or the aircraft itself as mentioned in CS FCD.415(a). Level E training, if done in an aircraft, should be modified for safety reasons where manoeuvres can result in a high degree of risk. When level E differences training is assigned, suitable credit or constraints may be applied for knowledge, skills or abilities related to other pertinent aircraft types. The training programme should specify the relevant subjects, procedures or manoeuvres.

(4)Difference levels — checking Differences checking addresses any pertinent pilot testing or checking. Initial and recurrent checking levels are the same unless otherwise specified. It may be possible to satisfactorily accomplish recurrent checking objectives in devices that do not meet the initial checking requirements. In such instances, the applicant may propose for revalidation checks the use of certain devices that do not meet the initial checking requirements.

(i)Level A checking Level A differences checking indicates that no check related to differences is required at the time of differences training. However, a pilot is responsible for knowledge of each variant flown.

(ii)Level B checking Level B differences checking indicates that a ‘task’ or ‘systems’ check is required following initial and recurring training.

(iii)Level C checking Level C differences checking requires a partial check using a suitable qualified device. A partial check is conducted relative to particular manoeuvres or systems.

(iv)Level D checking Level D differences checking indicates that a partial proficiency check is required following both initial and recurrent training. In conducting the partial proficiency check, manoeuvres common to each variant may be credited and need not be repeated. The partial proficiency check covers the specified particular manoeuvres, systems or devices. Level D checking is performed using scenarios that represent a ‘real-time’ flight environment and uses qualified devices permitted for level D training or higher.

(v)Level E checking Level E differences checking requires that a full proficiency check be conducted in FSTDs or in an aircraft as mentioned in CS FCD.415(a), following both initial and recurrent training. If appropriate, alternating Level E checking between relevant aircraft is possible and credit may be defined for procedures or manoeuvres based on commonality. Assignment of level E checking requirements alone, or in conjunction with level E currency, does not necessarily result in assignment of a separate type rating.

(5)Difference levels — currency Differences currency addresses any currency and re-currency levels. Initial and recurrent currency levels are the same unless otherwise specified.

(i)Level A currency Level A currency is common to each aircraft and does not require separate tracking. Maintenance of currency in any aircraft suffices for any other variant within the same type rating.

(ii)Level B currency Level B currency is ‘knowledge-related’ currency, typically achieved through selfreview by individual pilots.

(iii)Level C currency

(A)Level C currency is applicable to one or more designated systems or procedures and it relates to both skill and knowledge requirements. When level C currency applies, any pertinent lower-level currency is also to be addressed.

(B)Re-establishing level C currency When currency is lost, it may be re-established by completing required items using a device equal to or higher than that specified for level C training and checking.

(iv)Level D currency

(A)Level D currency is related to designated manoeuvres and addresses knowledge and skills required for performing aircraft control tasks in real time with integrated use of associated systems and procedures. Level D currency may also address certain differences in flight characteristics including performance of any required manoeuvres and related normal, non-normal and emergency procedures. When level D is necessary, any pertinent lower-level currency is also to be addressed.

(B)Re-establishing level D currency When currency is lost, currency may be re-established by completing pertinent manoeuvres using a device equal to or higher than that specified for level D differences training and checking.

(v)Level E currency

(A)Level E currency requires that recent experience requirements of Part-FCL and operational requirements be complied with in each aircraft separately. Level E currency may also specify other system, procedure, or manoeuvre currency item(s) necessary for safe operations and may require procedures or manoeuvres to be accomplished in FSTDs or in an aircraft as mentioned in CS FCD.415(a). Provisions are applied in a way which addresses the required system or manoeuvre experience. When level E is assigned between aircraft of common characteristics, credit may be permitted. Assignment of level E currency requirements does not automatically lead to a determination on same or separate type rating. Level E currency is tracked by a means that is acceptable to the competent authority. When common take-off and landing credit (CTLC) is permitted, any credit or constraints applicable to using FSTDs, as mentioned in CS FCD.415(a), are also to be determined.

(B)Re-establishing level E currency When currency is lost, currency may be re-established by completing pertinent manoeuvres using a device specified for level E differences training and checking.

(6)Competency regarding non-normal and emergency procedures — currency Competency for non-normal and emergency manoeuvres or procedures is generally addressed by checking requirements. Particular non-normal and emergency manoeuvres or procedures may not be considered mandatory for checking or training. In this situation, it may be necessary to periodically practise or demonstrate those manoeuvres or procedures specifying currency requirements for those manoeuvres or procedures.

OPERATOR DIFFERENCE REQUIREMENTS (ODRS) The ODRs tables may result in different training programmes, depending on the training needs, regardless of the ‘base aircraft’ used to establish the table (e.g. the trainee may know the ‘other aircraft’ and be trained towards the ‘base aircraft’).

GROUPS OF SINGLE-ENGINED PISTON HELICOPTER TYPES FOR THE REVALIDATION OF THE OPC When establishing groups of single-engined helicopter types for the purpose of crediting of proficiency checks, the operator should only take into account the helicopter types considered for crediting in AMC1 FCL.740.H(a)(3).

LINE CHECKS — HELICOPTERS AND VCA

(a)Prior to using a line check on one helicopter type or variant or on one VCA type or variant to revalidate the line check on other helicopter types or variants or VCA types or variants, the operator should consider whether the types of operations are sufficiently similar in terms of:

(1)use of aerodromes, operating sites or diversion locations;

(2)day VFR or night VFR;

(3)use of operational approvals and specific approvals;

(4)normal procedures, including flight preparation, take-off and landing procedures; and

(5)use of automation.

(b)For IFR operations of helicopters, an operation should only be considered sufficiently similar to allow a line check on one type or variant to revalidate the line check for the other type or variant if such credits are defined in the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012, as determined in point (a) of ORO.FC.140.

(c)Line check cross-crediting should be defined in the operations manual.