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NPA 2007/07 Type trainingPart 66 Annex III
Rulemaking task 66-011

• EASA workshop
• 05 July 2007
• jean-pierre.arnaud_at_easa.europa.eu

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66-011 Type training and examination standard

• A few pieces of information affecting rulemaking
  task 66-011
• Amendment n167 ICAO Annex 1
• Rulemaking task 21-039

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ICAO Annex 1 Licensing

• New amendment n167 (Tenth Edition) effective on
  July 2006, applicable on 23 November 2006
• Training should be competency based.
• It is flight operation orientated. No change for
  chapter 4 of Annex 1 (licences and rating for
  personnel other than flight crew members
  especially for aircraft maintenance) and for Doc
  7192 Part D-1 (training manual for aircraft
  maintenance)
• 3 phases of learning process
• 1) Knowledge
• 2) Skills
• 3) Experience

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ICAO Annex 1 Licensing

• Creation of Doc 9868 about training (first
  edition February 2006) and associated to the ICAO
  annex 1
• A methodology about training is given.
• Objectives / justification of a training need
• Task analysis and their formulation in an
  observable and measurable fashion
• Continuous evaluation process to ensure the
  effectiveness of training
• Indicators for evaluation / Assessment,
  assessors, performance oriented tests
• Performance or Criteria to be considered by the
  examiner when assessing each competency /
  Definition of competency a combination of
  skills, knowledge and attitude to perform a task
  to the prescribed standard /The tolerances
  applicable to all competency based tests

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21.039 Additional airworthiness specifications
for a given type of aircraft and type of
operation

• Rulemaking task 21-039
• Currently the following (for a given type of
  aircraft) are approved by the NAA following a
  recommendation of the Joint Operational
  Evaluation Board (JOEB / JAA times), such as
• the minimum syllabus of pilot type rating
  training
• the MMEL
• Objective of task 21.039
• To create in Part 21 the appropriate provisions
  describing how the Agency will approve the
  following additional airworthiness specifications
  for a given aircraft type, making them the
  minimum standard for all aircraft registered in
  the EU or operator by a European operator (lease
  in) to be used by the operators in order to
  develop their own training programmes, minimum
  equipment lists etc

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21.039 additional airworthiness specifications
for a given type of aircraft and type of operation

• The most likely option is the TC holder to
  provide stakeholders with a minimum standard
  (approved by the Agency) to be used by the
  operator / Training organisation... This package
  could include
• - the need for a type rating
• - minimum syllabus of maintenance certifying
  staff type rating,
• 21.039 is now under progress and the chairman of
  66-011 has been selected as member of the group
  to ensure coordination.
• An advanced-NPA / NPA could be ready by end 2007
  (to be confirmed) in order to determine the best
  option (what we expect to regulate) and the
  content of the selected option will be drafted in
  2008.
• A workshop will be organised after summer 2007
  operators, training organisations, NAAs will be
  invited monitor http//www.easa.eu.int/home/event
  s_en.html

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66-011 rulemaking task

• 66-011 Type training and examination standard
  (Part66 Appendix III)

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66-011 Type training and examination standard
(App III)

• Unfortunately, elements from 21-039 are not
  available so far and are likely to be required
  only for new brand aircraft.
• From a standardization point of view, it is
  observed that
• There is significant variation in duration (for
  example, duration of a type course for the same
  type and model can vary between 100 and 200h )
• Too much room for interpretation is left for the
  content of the practical elements (no sufficient
  guidance).
• Therefore, unequal treatment is reported in
  level, length and content

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66-011 Type training and examination standard
(App III)

• Some elements although quite extensive do not
  seem to be detailed enough to avoid too much
  significant variation in content and in duration.
• The duration for the practical elements as
  specified in the current AMC (between two weeks
  and four months, based on the experience of the
  applicant) is not uniformly implemented tendency
  was to limit the duration to two weeks, whatever
  the experience of the applicant was.

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66-011 Type training and examination standard
(App III)

• Current AMC 66.A.45(d)
• The practical training must comprise a period of
  4 months for applicants with no recent recorded
  previous practical experience of aircraft of
  comparable construction and systems, including
  the engines, but this can be reduced to a minimum
  of two weeks for applicant with such previous
  experience.
• A programme of structured OJT may be prepared to
  satisfy the practical training requirement
• The practical training should be supported by a
  detailed syllabus showing its content and
  duration (no existing guidance so far)

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66-011 Type training and examination standard
(App III)

• The OJT program was mis-implemented. No cross
  reference to the practical training elements and
  its objectives
• Standardization aspect throughout the Member
  states.
• The group was committed to fully review
  paragraph 66.A.45 (c) (d) as well as Appendix
  III

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66-011 Type training and examination standard
(App III)

• The term of reference was limited to large
  aircraft plus all aircraft where type training is
  required.
• The group started to work in 2005 and 12 meeting
  were necessary
• Difficulties in solving the problems
• No perfect solution
• Areas of non-consensus or dissents
• The NPA was produced late behind the schedule.
• 66-011 group was composed of engineer association
  representative, industry and NAAs members. EAMTC
  was consulted.

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66-011 Type training and examination standard
(App III)

• These facts encourage the following options
• Setting up a minimum duration for the theoretical
  elements and updating the current syllabus
• Defining a guidance or a syllabus to be adapted
  for the practical elements and/or
• Replace duration of the practical training
  (between two weeks and four months) by a fixed
  content.

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66-011 Type training and examination standard
(App III)

• Making a difference between practical training in
  a Part 147 environment and on the job training in
  a maintenance organisation environment (OJT)
• On the job training for the first type training
  within a sub-category to be compelled in order to
  gain experience and competency.
• Examination and assessment.

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66-011 Type training and examination standard
(App III)

• Some basic questions
• Do we need the pre-requisites (eligibility
  requirement) of each individual applicant to be
  systematically checked before an applicant enters
  a training room in order to adapt the syllabus to
  the competence or experience of the trainee?
• (Refer to point n42 of the NPA where the opinion
  of the stakeholders is sought)
• Do we need to recommend a minimum duration in
  hours for the theoretical elements?

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66-011 Type training and examination standard
(App III)

• What NPA 2007/07 (task 66-011) will propose.

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66-011 Type training and examination standard
(App III)

• Theoretical training
• Content has been re-organised new table
  available according to ATA chapter breakdown or
  subjects (in line with EAMTC proposal).
• Content has been updated to match new technology
  and new systems
• The concept of minimum duration is accepted
  (see next slides)
• It does not mean that all course duration should
  be at the minimum all course application must be
  supported by detailed training needs analysis.
• Where the analysis shows that more hours are
  needed, course lengths shall be longer that the
  minimum specified in the table.
• This training needs analysis will constitute a
  tool for the NAAs

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66-011 Type training and examination standard
(App III)

• Minimum duration of the theoretical elements
• It is not easy to establish different classes or
  categories of aircraft that covers the wide range
  of aircraft and technology, only generic classes
  will be identified and flexibility should exist
  about the variation of that duration.
• Therefore a guidance about flexibility is given
  in order to reduce the length of a training
  course when needed it should be based on
  justifications (training need analysis 1st step
  towards competency based training ) that have
  to be accepted by the NAA.

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66-011 Type training and examination standard
(App III)

• Minimum duration of the theoretical elements
  (/)
• Therefore, the group decided to remain generic
  and only proposed three categories
• Aeroplanes with a MTOM of more than 5700kg.
• Aeroplanes with a MTOM of 5700kg and below where
  type training is required
• Multi-engine helicopters and helicopters where
  type training is required.
• A proposed guidance material for a better
  understanding

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66-011 Type training and examination standard
(App III)

• Minimum duration of the theoretical elements
  (/)
• GM 66.A.45(g)(1) Type/task training and
  ratings
• The minimum duration for type training has been
  determined based on generic categories of
  aircraft and minimum standard equipment fit.
• Deviation below the minimum duration is only
  permissible in exceptional circumstances.
  Training program reductions for a particular
  aircraft type must be approved by the competent
  authority on a case-by-case basis appropriate to
  the type. For example, while it would be
  exceptional for a theoretical knowledge course to
  be below the minimum duration shown for a large
  transport category aircraft such as an A330 or
  B757, it would not necessarily be exceptional in
  the case of a General Aviation (GA) business
  aircraft such as a Learjet 45 or similar.
  Typically the training needs analysis (TNA) for a
  GA aircraft course will demonstrate that a course
  of a shorter duration satisfies the requirement.

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66-011 Type training and examination standard
(App III)

• Aeroplanes with a maximum take-off mass of more
  than 5700kg
• B1.1 150h
• B1.2 120h
• B2 100h
• C 25h
• Aeroplanes of a maximum take-off mass of 5700kg
  and below, where type training is required
• B1.1 120h
• B1.2 100h
• B2 100h
• C 25h
• Multi-engine helicopters and helicopters where
  type training is required
• B1.1 120h
• B1.2 100h
• B2 100h
• C 25h

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66-011 Type training and examination standard
(App III)

• A better distinction between the practical
  training and the OJT was proposed
• There will be no more duration (2weeks/4 months)
• For both cases, assessors should demonstrate
  training and experience on the assessment process
  being undertaken

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66-011 Type training and examination standard
(App III)

• Practical training
• A content or a table (list of tasks) is proposed
  (everything is mandatory) and the practical
  syllabus must be supported by either a detailed
  syllabus or practical logbook or worksheets
  showing content and duration
• Location / functional or operational test /
  service and ground handling / removal or
  installation / MEL / Trouble shooting
• Shall be assessed by approved assessors
• Demonstration of practical training must be
  retained during 5 years by the approved
  organisation

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66-011 Type training and examination standard
(App III)

• The OJT
• The OJT is mandatory for the first type training
  in any subcategory (of the licence) (theoretical
  and practical) in a sub-category and is optional
  for the second or subsequent ones
• The OJT shall be conducted by an approved MRO and
  approved by the NAA.
• The OJT should cover at least 50 of the Appendix
  II to AMCs (that has been updated)
• The OJT should be recorded in a harmonized manner
• OJT shall be supervised (supervisor) and shall be
  assessed by approved assessors (AMC F4).
• No pre-requisite management by Part 147

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66-011 Type training and examination standard
(App III)

• Why OJT in a maintenance environment?
• It is commonly accepted that true experience is
  mostly gained in an approved maintenance
  organisation where an aircraft is likely to be
  more available for training purposes.
• Few Part 147 organisations have permanent access
  to an aircraft and very few training
  organisations will perform maintenance for
  training purposes on an aircraft which is fit for
  fly because true trouble shooting cannot be
  performed and de-installation-re-installation
  could lead to a true failure.

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66-011 Type training and examination standard
(App III)

• Additional small amendments to fit to the overall
  changes
• Based on experience in the application of the
  current requirements and feedback received, some
  improvements have been taken into consideration
• The duration of type rating examination questions
  has been changed from a mixture of 75 and 120
  seconds to 90 seconds for all levels in order to
  standardise question generation.

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66-011 Type training and examination standard
(App III)

• Additional small amendments to fit to the overall
  changes (/)
• Changes to the number of questions per chapter to
  simplify the system presently in place.
• Highlighting that examination question level must
  be in proportion to the level of training
  conducted.
• Clarification on instructor requirements.
• A form 4 should be filled in for every assessor
  and proposed to the competent authority.

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66-011 Type training and examination standard
(App III)

• Responsibilities of the NAA related to type
  endorsement
• Practical training and OJT, when conducted by a
  maintenance organisation, shall be assessed,
  approved and audited by the competent authority.
• When the type training is conducted in different
  organisations (PART 147 and/or approved
  maintenance organisations or direct course
  approval) the authority shall be satisfied that
  the interfaces are appropriately handled.

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66-011 Type training and examination standard
(App III)

• Responsibilities of the NAA related to type
  endorsement (/)
• In the case of second or subsequent type rating
  within a license sub-category the aircraft type
  has to be granted based on a Part-147 Certificate
  of Recognition in the case all applicable
  elements (theoretical and practical part) are
  performed within an approved part-147
  organisation. This point has been raised because
  of a lack of mutual recognition between Member
  States.

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66-011 Type training and examination standard
(App III)

• Differences training has been addressed
• Some AMC are now binding (raised at the level of
  the implementing rules)
• Consistency with other rulemaking tasks such as
  66-006 (privileges of B1/B2 licences engineers)
• One member suggested that the engine running
  practical task, presently optional within Part-66
  appendix III should be a mandatory practical
  training task. Dissent area (paragraph 42 to be
  commented)

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66-011 Type training and examination standard
(App III)

• (SUM-UP)
• IMPACT and TRANSITION PERIOD

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66-011 Type training and examination standard
(App III)

• a) for Part-147 Maintenance Training
  Organisations
• Amendment of MTOE
• Generation of Training Needs Analysis (TNA) for
  all courses
• Develop and amend course material
• Review of examination questions
• Development of practical training schedules

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66-011 Type training and examination standard
(App III)

• b) for Part-145 / Part-M Maintenance
  Organisations
• Amendment of MOE / MOM
• Development of procedures for practical training/
  OJT
• Training and appointment of practical training/
  OJT Assessors
• Development of for practical training/ OJT
  schedules

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66-011 Type training and examination standard
(App III)

• C) for Competent Authorities
• Review of existing procedures
• Develop new procedures for the oversight of
  practical training/ OJT
• Training of Surveyors/ Inspectors

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66-011 Type training and examination standard
(App III)

• d) for students
• Formal use of logbook
• Requirement for assessment of practical training

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66-011 Type training and examination standard
(App III)

• Transition provisions / Entry into force
• (a) A period of 90 days has been proposed before
  entry into force of this Regulation amendment.
• (b) Applicants for an initial Part-147
  maintenance training organisation approval that
  are already subject to the applicable
  investigation process on the date of entry into
  force of this Regulation amendment, are subject
  to the requirements applicable prior to the entry
  into force of this Regulation amendment.
• /

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66-011 Type training and examination standard
(App III)

• Transition provisions / Entry into force
• /
• (c) Part-147 approved maintenance training
  organisations applying for approval of new type
  courses may elect not to apply this Regulation
  amendment until 15 months after the date of entry
  into force of this Regulation amendment. Partial
  implementation of selective items of this
  Regulation amendment is not allowed.
• (d) The provisions of paragraph 2(c) shall also
  apply to organisations applying to the competent
  authority for approval of type courses not
  imparted by Part-147 approved maintenance
  training organisations.
• /

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66-011 Type training and examination standard
(App III)

• Transition provisions / Entry into force (/)
• (e) Competent authorities shall accept and
  process applications for type course approval
  submitted under paragraphs 2(c) and 2(d).
• (f) Type courses approved in accordance with the
  requirements applicable prior to the entry into
  force of this Regulation amendment can only be
  imparted until 15 months after the date of entry
  into force of this Regulation amendment.
  Certificates for those type courses issued not
  later than 15 months after the date of entry into
  force of this Regulation amendment shall be
  considered as issued in accordance with this
  Regulation amendment.

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66-011 Type training and examination standard
(App III)

• Future of this rulemaking task
• Bridge with rulemaking task 21-039 (some elements
  have been already passed to this group)
  Consistency between 66-011 and 21-039 will have
  to be and will be enhanced
• 21-039 will only give the minimum syllabus but it
  will be responsibility of the training providers
  to build a course IAW 66-011 guidelines /
  recommendations
• It is unlikely that a catch up program will be
  mandatory optional catch up programme is more
  likely to happen the training syllabus IAW
  66-011 will remain valid. In any case, transition
  period to bridge will be proposed and the former
  training certificates will remain valid.
• If something wrong happen with 21.039, 66-011
  will apply. Entry into force for 66-011 would be
  before 21-039.

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