GM1 to Appendix 9 Section A point 1c Training, skill test and proficiency check for the MPL, and the ATPL, and for type and class ratings, and proficiency checks for the BIR and the IR

FRAMEWORK FOR THE MANDATORY USE OF A FULL-FLIGHT SIMULATOR IN THE CASE OF SINGLE-PILOT AEROPLANES AND HELICOPTERS

(a)Partial availability of FFS and additional in-aircraft training In the case of single-pilot aeroplanes (SPAs) and helicopters, Appendix 9, Section A, point 1c requires training to be conducted in a full-flight simulator (FFS), if available and accessible, or in a combination of such FFS and FSTD(s). In that context, an FFS can be deemed ‘available’ only to the extent to which that FFS can, based on its technical capabilities, serve as training platform for class rating or type rating training. For example, if the FFS that exists for a particular type of aircraft can only serve as a training platform for 80 % of the type rating training syllabus (e.g. in the case of helicopters, near-ground manoeuvres cannot be simulated appropriately), that FFS is ‘available’ only to 80 % of the training syllabus. The remaining 20 % of the training syllabus need to be completed in an FSTD that is suitable for the relevant exercises, or in the aircraft. Independently, Appendix 9 Section A point 1a contains a requirement for applicants to complete additional take-off and landing training in the aircraft (unless undergoing ZFTT, or undergoing type rating training for cruise relief co-pilots).

(b)In-aircraft training arrangements in older operational suitability data (OSD) for flight crew The framework and conditions for the mandatory use of FFSs and other flight simulation training devices (FSTDs) in training, skill tests, and proficiency checks for class ratings and type ratings were introduced into Part-FCL, Appendix 9, Section A through Regulation (EU) 2018/1974 and became applicable as from 20 December 2019. From that day, training, skill tests, and proficiency checks for class ratings and type ratings for SPAs and helicopters needed to be conducted in FFSs, or, in cases where an FFS is not available and accessible, in other FSTDs in combination with in-aircraft training. The subsequent Regulation (EU) 2024/2076 complemented this framework with the option to combine training in FFS, if available and accessible, and FSTDs. Completing training courses solely in the aircraft is only possible in the case of SPAs or helicopters for which no FSTD exists. Training considerations (not mandatory training elements) in OSD for flight crew which was established prior to 20 December 2019 may refer to in-aircraft training although an FFS exists for the respective type of aircraft. Today, that OSD for flight crew needs to be understood in the light of the requirements of the currently applicable Part-FCL, Appendix 9 Section A as those requirements do not allow OSD to determine alternative training platform arrangements (OSD cannot overrule Part-FCL, Appendix 9 as regards the requirements of that Appendix for the use of FSTDs). This means that the in-aircraft training content that is referred to in training considerations for flight crew in such older OSD after 20 December 2019, needs to be delivered in an FFS in accordance with Part-FCL Appendix 9 Section A and considering the content of point (a) of this GM.