In December 2018 the European Commission published an amendment to the Aircrew Regulation. ‘Commission Implementing Regulation (EU) 2018/1974 of 14 December 2018’ amends the Aircrew Regulation (‘Regulation (EU) 1178/2011’) and introduces the following changes:
Upset Prevention and Recovery Training
The work on introducing Upset Prevention and Recovery Training (UPRT) into European Regulations has been going on for several years. We already have requirements for ‘operators’ (airlines) to provide UPRT for pilots. This amendment implements UPRT for issue of licences and ratings as follows:
ATOs providing ATPL or CPL training will need to include basic UPRT into courses starting after 20 December 2019. Pilots who start their training before this date and pass a skill test before 20 December 2021 will be exempt.
Pilots starting their first type rating course (or class rating for complex or high-performance aeroplanes) after 20 December 2019 will need to have completed an ‘Advanced UPRT’ course. The course will involve a minimum of three hours flight training in an aerobatic category aircraft as well as ground school and briefings. Pilots who follow integrated ATP or MPL training starting after December 2019 will complete advanced UPRT as part of the integrated course.
From 20 December 2019 type-rating courses (and class rating for complex or high-performance aeroplanes) will include theoretical and practical UPRT related to the specific characteristics of the aeroplane type (or class).
UPRT for Instructors
Instructors delivering ‘Advanced UPRT’ will need to meet minimum experience requirements and complete a specific course of training at their ATO. They will also need to complete refresher training every 12 months. The instructors who train these instructors need extensive experience in delivering the advanced UPRT course. As there will initially be no instructors with such experience a provision has been introduced to allow Competent Authorities to issue temporary instructor certificates to suitable candidates for new training courses.
Instructors providing type rating training (TRI and SFI) will need specific training in UPRT similar to the training required for instructors providing UPRT with operators (airlines).
Anyone preparing to take a type rating after December 2019 should be very careful about booking an ‘Advanced UPRT’ course. Each ATO providing this training will need to have the course approved by their Competent Authority and the Competent Authorities cannot issue approval for these courses until the detailed requirements have been published. Training provided by organisations that don’t have approval, or carried out before an approval is issued, won’t count and may have to be repeated.
Pre-requisites for type rating training
Under existing regulations pilots starting a type-rating course are required to have a valid multi-engine instrument rating (MEIR). This is difficult for pilots taking a new type-rating courses whose previous type-ratings have expired. These pilots have to renew their old type-ratings before starting the course for a new type. After 20 December 2019 it will be sufficient to ‘hold or have held’ an MEIR.
Pilots taking their first type-rating will need to complete ‘Advanced UPRT’ (see above) but the requirement is not retrospective, it does not apply to pilots who already have a type rating on any complex or multi-pilot type.
Multi-pilot operations on single-pilot types.
Some smaller aeroplanes, certified as single-pilot types, are flown with two pilots for certain operations. An example is commercial air transport operations with small jet aircraft such as the Cessna Citation Mustang. If a pilot completes a proficiency check for a single-pilot type as part of a crew of two then the rating Is only valid for multi-crew operations.
The amended regulation clarifies the requirements for switching between single-pilot and multi-pilot operations by introducing the concept of a ‘bridge course’ and listing the contents of the course and the proficiency check for pilots qualified in single-pilot operations to fly multi-pilot and vice-versa.
Use of FSTD for type rating training and skill tests/proficiency checks
It has always been possible to use different types of flight simulation training device (FSTD) for type-rating training but the existing regulation (Appendix 9 to Part-FCL) is unclear about which types of FSTD should be used. The amended regulation stipulates that certain exercises must be performed in a full-flight simulator (FFS) and that others may be performed in other types of FSTD. The suitability of a particular FSTD is determined by reference to the validation tests required for qualification of the device, not by the its classification (FTD I, FTD II etc.). Use of individual FSTDs must be specifically approved for each course conducted by an ATO (as now).
The existing regulation requires that skill tests and licence proficiency checks must be conducted on a simulator ‘if available’. The meaning of ‘available’ in this context has been open to interpretation.
The amended regulation clarifies that an FFS must be used if it is ‘available’ and ‘accessible’. Definitions are provided. ‘Accessible’ means that the device can be used by the ATO or Examiner and ‘available’ means that the device is ‘vacant for use […] irrespective of any time considerations’. If there is no ‘available and accessible’ FFS, then a combination of an aircraft and another FSTD could be used for a test/check. An aircraft will only be used for the entire check if there is no FSTD ‘available and accessible’.
The certification specifications for flight simulation training devices (CS-FSTD) were recently updated to include guidance on stall model evaluation. This introduced the possibility of being confident that an FFS will adequately represent the characteristics of an aeroplane during an aerodynamic stall.
The amended Aircrew regulation stipulates that an ATO may include training in type-specific stall characteristics and recovery from a stall if the FFS used has been qualified using the special evaluation requirements of CS-FSTD and if the ATO has been approved for this training. In any other case training is limited to recovery from an ‘approach to stall’ (i.e. from the first indication of the stall).
Aeroplane training (aka ‘base training’)
When a pilot completes a type-rating course in a flight simulator there is usually a requirement to make a number of take-offs and landings on the actual aeroplane (except in the case of ‘zero flight time’ training). Under the current regulation this aeroplane training must be completed at an ATO.
The amended regulation allows for a commercial air transport operator (AOC holder) to be approved to provide aeroplane training. For single-pilot types, if there is no approved training provider, then an individual instructor could also be approved.