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NPA 2018-07

Lennuamet · 8. august 2018
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3.4-6/18/4109-1
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8. august 2018
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Kiri sissetulev
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Euroopa Lennundusohutusamet
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e-post
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3.4 Euroopa lennuohutusametiga (EASA) koostöö korraldamine
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3.4-6 NPA’d ja EASA opinion’id
Toimik
3.4-6/2018
Vastutaja
Mari Reinfeldt (Juhtkond, Juhtkond)
Lahendamise tähtaeg
31. oktoober 2018

Failid

  • 📎NPA 2018-07(A).pdf1028 KB
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European Aviation Safety Agency Notice of Proposed Amendment 2018-07(A) Update of ORO.FC — evidence-based training subtask RMT.0599 EXECUTIVE SUMMARY The European Aviation Safety Agency (EASA) identified the need to ensure that aviation personnel have the right competencies and training methods to cope with new challenges. This is one of the most significant systemic issues in the European Plan for Aviation Safety (EPAS) 2018-2022. The objective of this notice of proposed amendment (NPA) is to update the flight crew training requirements to improve pilot competencies. At the same time, it provides additional efficiency in the field of flight crew training and achieves a smooth transition to competency-based training. The International Civil Aviation Organization (ICAO), in a joint effort with the International Air Transport Association (IATA), the International Federation of Air Line Pilots’ Associations (IFALPA) and other industry partners, developed a new paradigm for competency-based recurrent assessment and training of flight crew, which is based on evidence (evidence- based training (EBT)). The EBT project is a global safety initiative whose objective is to determine the relevance of existing pilot training according to aircraft generation. The EBT methodology identifies areas for improvement and allows the re- prioritisation of training topics. EBT is intended to enhance the confidence and capability of flight crews to operate the aircraft in all flight regimes and to be able to recognise and manage unexpected situations. This NPA is a second step in the European rulemaking actions that helps competent authorities, commercial air transport (CAT) operators and approved training organisations (ATOs) to implement EBT. The first step was completed in 2015 with the publication of ED Decision 2015/027/R that provided guidance material to allow the implementation of 'mixed EBT’ which maintains the current operator proficiency check (OPC) and licence proficiency check (LPC). This NPA proposes further changes to the Air OPS and Air Crew Regulations to allow the full implementation of EBT, replacing OPC and LPC. This will allow a single philosophy of recurrent training within the airline. Further work is foreseen in rulemaking task (RMT).0599 to allow expansion of EBT to the operator conversion course and initial type rating, while expanding the EBT concept to other types of aircraft (e.g. helicopters and business jets). The impact assessment (IA) shows that the implementation of EBT on a voluntary basis by the operator is the preferred option in regulating recurrent training and checking of flight crew. It provides an opportunity for the air operator certificate (AOC) holders to implement EBT for recurrent training and checking of the flight crew. The IA illustrates that the proposed rules contribute to significant improvement in safety by strengthening the competencies of flight crews while providing a cost-efficient and socially acceptable framework. NPA 2018-07 is divided in two parts. The present sub-NPA(A) includes: — the presentation of the issue under discussion; — the impact assessment; and — the proposed actions to support implementation. Sub-NPA(B) includes the proposed draft rules (implementing rules, acceptable means of compliance and guidance material. Action area: Human factors and competence of personnel Affected rules: Definitions, Part-ARO and Part-ORO of the Air OPS Regulation, Part-FCL and Part-ARA of the Aircrew Regulation (and the associated AMC & GM) Affected stakeholders: Member States, pilots, instructors, examiners, ATOs and operators Driver: Safety Rulemaking group: Yes Impact assessment: Full Rulemaking Procedure: Standard 05.02.2016 27.07.2018 2019/Q3 2020/Q3 2020/Q3 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) Table of contents Table of contents 1. About this NPA ..................................................................................................................................... 3 1.1. How this NPA was developed ................................................................................................................... 3 1.2. How to comment on this NPA .................................................................................................................. 4 1.3. The next steps ........................................................................................................................................... 4 2. In summary — why and what ............................................................................................................... 5 2.1. Why we need to change the rules — issue/rationale............................................................................... 5 2.2. What we want to achieve — objectives ................................................................................................... 9 2.3. How we want to achieve it — overview of the proposals ...................................................................... 10 2.4. What are the expected benefits and drawbacks of the proposals ......................................................... 11 3. Impact assessment (IA) ....................................................................................................................... 13 3.1. What is the issue ..................................................................................................................................... 13 3.2. Regulatory background and evolution.................................................................................................... 13 3.3. What we want to achieve — objectives ................................................................................................. 17 3.4. How it could be achieved — options ...................................................................................................... 17 3.5. Methodology and data ........................................................................................................................... 21 3.6. What are the impacts ............................................................................................................................. 24 3.7. Conclusion ............................................................................................................................................... 52 3.8. Monitoring and evaluation ..................................................................................................................... 53 4. Proposed actions to support implementation...................................................................................... 54 5. References ......................................................................................................................................... 55 5.1. Affected regulations................................................................................................................................ 55 5.2. Affected decisions ................................................................................................................................... 55 5.3. Other reference documents ................................................................................................................... 55 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 2 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 1. About this NPA 1. About this NPA 1.1. How this NPA was developed EASA developed this NPA in line with Regulation (EC) No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is included in the European Plan for Aviation Safety (EPAS) 2018-2022 under rulemaking task (RMT).0599. The text of this NPA has been developed by EASA based on the input of Rulemaking Group (RMG) RMT.0599. This group is divided in the: (a) Main Group3, which ensures consistency across the different tasks of RMT.0599. It also develops an aviation blended learning environment (ABLE) concept and deals with other updates of ORO.FC including interoperability solutions; (b) Evidence-based training (EBT) subgroup4, that is responsible for developing the EBT concept; and (c) Helicopter subgroup5 that is developing and updating the helicopter training requirements including EBT. This NPA is primarily based on the inputs provided by the EBT subgroup. Due to the novelty of the EBT concept, EASA also consulted the Main group RMT.0599 on a regular basis, organised a workshop6 with the participation of industry representatives in February 2017 and performed 4 rounds of focus consultation with: (1) the Netherlands Aerospace Centre (NLR)7 with regard to instructor concordance and grading; (2) the Spanish competent authority (AESA)8 and Iberia9 for the implementation of the EBT programme; (3) the Italian competent authority (ENAC)10 and Alitalia11 with regard to equivalency of malfunctions; and (4) CAA Denmark (Trafik)12 and Thomas Cook Scandinavia13 on the oversight and follow-up of the EBT programme. 1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal- content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216). 2 EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management- board/decisions/easa-mb-decision-18-2015-rulemaking-procedure). 3 Chaired by Yann Renier (IATA) and Phill Adrian (AIA). Members: Enrique Monzón (AESA España), Rogier Leeflang (IACA), Ståle Rosland (CAA Norway), David Lord (GAMMA). Project management Francisco Arenas Alvariño EASA. 4 Chaired by Phil Cullen (UK CAA). Secretariat Ascanio Russo EASA. 5 Chaired by Tim Rolfe (Heli-offshore). 6 st 1 Workshop on the Implementation of the Evidence-based Training https://www.easa.europa.eu/newsroom-and- events/events/1st-workshop-implementation-evidence-based-training 7 Focal point: Frederik Mohrmann. 8 Focal point: Carlos Artiles and Enrique Monzón. 9 Focal point: Captain Ignacio Gallego Alemany. 10 Focal point Mario Tortorici and Sandro Apolloni. 11 Focal point: Massimo Giavalisco and Fabio Polloni. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 3 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 1. About this NPA The text of this NPA is hereby submitted to all interested parties14 for consultation. 1.2. How to comment on this NPA Please submit your comments using the automated Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/15. The deadline for submission of comments is 31 October 2018. 1.3. The next steps Following the closing of the public commenting period, EASA will review all comments. Based on the comments received, EASA will develop an opinion containing the proposed amendments to Regulation (EU) No 965/201216 (hereinafter referred to as the ‘Air OPS Regulation’) and to Regulation (EU) No 1178/201117 (hereinafter referred to as the ‘Aircrew Regulation’). The opinion will be submitted to the European Commission, which will use it as a technical basis in order to prepare an EU regulation. Following the adoption of the regulation, EASA will issue a decision containing the related acceptable means of compliance (AMC) and guidance material (GM). The comments received and the EASA responses thereto will be reflected in a comment-response document (CRD). The CRD will be annexed to the opinion. The following future efforts in relation to EBT are foreseen: — Operator conversion course (OCC) and type rating training for CAT. This activity will ensure a single philosophy of training in the operator. An NPA pertaining to this activity is scheduled to be published in the course of 2021. — EBT for helicopters and non-commercial complex motor-powered aircraft (NCC). This activity will ensure a single philosophy of training across the industry. This may also allow training data exchange across the industry. An NPA pertaining to this activity is scheduled to be published in the course of 2021. 12 Focal point Lise-Lotte Olsen Deigaard 13 Focal point: Henrik Lyngse. 14 In accordance with Article 52 of Regulation (EC) No 216/2008 and Articles 6(3) and 7) of the Rulemaking Procedure. 15 In case of technical problems, please contact the CRT webmaster ([email protected]). 16 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0965&rid=1). 17 Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311, 25.11.2011, p. 1) (https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1528301490110&uri=CELEX:32011R1178). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 4 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what 2. In summary — why and what A further analysis of the rationale and objectives addressed by this proposal is provided in the IA Chapter. 2.1. Why we need to change the rules — issue/rationale The complexity of the aviation system is continuously increasing; also, new technologies are emerging rapidly on the aviation market. Therefore, it is of key importance for the aviation personnel to: 1- have the right competencies through the adaptation of training methods in order to cope with new challenges. This is one of the most significant systemic issues in the EPAS18, 2016-2020, 2017-2021 and 2018-2022. 2- take advantage of the safety-enhancing opportunities presented by new technologies. (EPAS 2018-2022 Chapter 5.2.2 Human factors and competence of personnel). 2.1.1. Why we need to include EBT in Europe Aircraft design and reliability has improved steadily and significantly over time; yet, accidents still occur, even in cases when the aircraft and systems were operating without malfunction. It is impossible to foresee all plausible accident scenarios, especially in today’s aviation system where its complexity and high reliability mean that the next accident may be something completely unexpected. In addition to this, the wealth of accident and incident reports and the provision of flight data analysis offer the possibility to identify risks encountered in actual operations and therefore offer the industry with the possibility to tailor training programmes in order to mitigate those risks that flight crew members face in operations. EBT addresses both elements (prepare the pilot for the unexpected and mitigate operational risks) by moving from task-based training to prioritising the development and assessment of key competencies, leading to a better training outcome. The scenarios recommended in EBT are simply a vehicle and a means to assess and develop competence. Mastering a finite number of competencies should allow a pilot to manage situations in flight that are unforeseen by the aviation industry and for which the pilot has not been specifically trained. (ICAO Doc 9995 AN/497 ‘Manual of Evidence-based Training’ First edition - 2013 (hereinafter referred to as ‘Doc 9995’ – Chapter Background). 18 https://www.easa.europa.eu/easa-and-you/safety-management/european-plan-aviation-safety TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 5 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what 2.1.2. Safety recommendations (SRs) — outcome of the EASA safety assessment The following safety recommendations (SRs) addressed to EASA from aircraft accident investigation report(s) published by the designated safety investigation authority19, are considered during this RMT. FRAN-2013-017 The French Accident Investigation Board recommends that EASA, in coordination with manufacturers, operators and major non-European aviation authorities ensure that go- around training integrates instruction explaining the methodology for monitoring primary flight parameters, in particular, pitch, thrust then speed. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where are all the following are required at a frequency of twice per year (frequency A): — the training topics:  monitoring, cross-checking, error management, mismanaged aircraft state; and  go-around management; and — the manoeuvres training on:  go-around, all engines operative;  go-around, all engines operative followed by a visual circuit, manually flown; and  go-around, all engines operative during flare/rejected landing. FRAN-2013-018 The French Accident Investigation Board recommends that EASA, in cooperation with the national civil aviation authorities and major non-European aviation authorities, ensure that during recurrent periodic training, training organizations and operators give greater importance to the assessment and maintenance of the monitoring capabilities of public transport pilots. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where the training topic: ‘Monitoring, cross-checking, error management, mismanaged aircraft state’ is required at a frequency of twice per year (Frequency A) FRAN-2013-022 The French Accident Investigation Board recommends that EASA review regulatory requirements for initial and periodic training in order to ensure that go-arounds with all engines operating are performed sufficiently frequently during training. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where are all the following are required at a frequency of twice per year (frequency A): — the training topic ‘Go-around management’; and — the manoeuvres training on:  go-around, all engines operative: high energy, initiation during the approach at 150 to 300 m (500 to 1000 ft) below the missed approach level 19 Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L 295, 12.11.2010, p. 35) (http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1479716039678&uri=CELEX:32010R0996). TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 6 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what off altitude;  go-around, all engines operative followed by a visual circuit, manually flown; and  go-around, all engines operative: during flare/rejected landing. FRAN-2013-033 The French Accident Investigation Board recommends that EASA, in cooperation with the national civil aviation authorities and major non-European aviation authorities, ensure that the risks associated with dispersion and/or channelized attention during the go- around, to the detriment of the primary flight parameters, be taught to crews. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where are all the following are required at a frequency of twice per year (frequency A): — the training topics:  monitoring, cross-checking, error management, mismanaged aircraft state; and  go-around management; and — the manoeuvres training on:  go-around, all engines operative: high energy, initiation during the approach at 150 to 300 m (500 to 1000 ft) below the missed approach level off altitude;  go-around, all engines operative followed by a visual circuit, manually flown; and  go-around, all engines operative: during flare/rejected landing. FRAN-2013-035 The French Accident Investigation Board recommends that EASA, in coordination with manufacturers, operators and major non-European aviation authorities, study whether to extend these measures to other procedures requiring high workload in a short time frame. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where training topic ‘Competencies non-technical (CRM)’ and 14 other example scenarios where the competency ‘workload management’ is trained, are required at a frequency of twice per year (frequency A), (crew resource management (CRM) includes communication, leadership and teamwork, problem-solving and decision-making, situation awareness, and workload management) TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 7 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what FRAN-2014-005 The French Accident Investigation Board recommends that EASA, in coordination with national authorities, make changes to the training requirements for pilots so as to include periodic reminders on the effects of contaminants such as ice on stall and loss of control on take-off. Evaluation of the This NPA addresses the SR through the transposition of Appendices 2 to 6 to Doc 9995 SR where training topic ‘adverse weather’ is addressed at a frequency of twice per year (Frequency A). Furthermore, for CAT, EASA is taking benefit of this recurrent training and checking scheme to mandate recurrent flight crew upset prevention and recovery training (UPRT) (see ED Decision 2015/012/R, published on 4 May 2015). The related AMC1 ORO.FC.220&230 identifies icing and contamination effects as key components of the upset prevention training programme, and recurrent training now covers all upset aspects over a period not exceeding 3 years. In EBT, these provisions still apply. FRAN-2015-062 [unofficial translation]: EASA should define the terms on how an operator can set up a risk-based training as described in Doc 9995. [French] [original text] - L’AESA définisse les modalités permettant à un exploitant de mettre en oeuvre la formation basée sur les risques telle que précisée dans le doc OACI 9995 de l’OACI. [Recommandation 2015-062] Evaluation of the This NPA addresses the SR through the transposition of Doc 9995. SR 20 Furthermore, ED Decision 2015/027/R , published on 16 December 2015, enables the implementation of EBT according to the principles established in Doc 9995 taking into account the European Union regulatory framework. FRAN-2015-063 [unofficial translation]: EASA promotes CAT operators to consider issues related to CRM and wind shear in the EBT scenario. [French] - L’AESA incite les exploitants de transport aérien commercial à prendre en compte des problématiques relatives au CRM et au cisaillement de vent dans la conception des scénarii EBT. [Recommandation 2015-063] Evaluation of the This NPA addresses the SR through the transposition of Doc 9995. SR Furthermore, ED Decision 2015/027/R, published on 16 December 2015, contains new GM to support the implementation of EBT by operators, to be conducted in flight simulation training devices (FSTDs), according to the principles established in Doc 9995. The GM is associated with the existing points (a), b) and (f) of ORO.FC.230 ‘Recurrent training and checking’ and ORO.FC.A.245 ‘Alternative training and qualification programme’ (see Organisation Requirements for Operators - Flight Crew (ORO.FC) of the Air OPS Regulation. CRM and wind shear are specifically addressed in the recurrent assessment and training matrices in Doc 9995, to which the new GM refers. 20 https://www.easa.europa.eu/document-library/agency-decisions/ed-decision-2015027r TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 8 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what 2.1.3. ICAO amendments Following the work initiated by the Flight Crew Licensing and Training Panel (FCLTP)21, in 2006 ICAO published Doc 9868 ‘Procedures for Air Navigation Services — Training (PANS-TRG)’ — a document that contains procedures for the development and implementation of a competency-based training programme to support the Annex 122 requirements. This was followed in 2013 by an amendment of the aforementioned document for the introduction of EBT, which was accompanied by Doc 9995. The intention was to provide guidance to civil aviation authorities (CAAs), operators and ATOs on the recurrent assessment and training of pilots referred to in ICAO Annex 6 ‘Operation of Aircraft’ and ICAO Annex 1 ‘Personnel Licensing’, 1.2.5 ‘Validity of licenses’. Finally, through Amendment 2 to Doc 9868 (also issued in 2013), procedures for EBT were introduced in order to provide a means of assessing and training key areas of flight crew performance in a recurrent training system. In addition, more detailed guidance on qualifications of the instructor was provided. 2.2. What we want to achieve — objectives The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation. This proposal will contribute to the achievement of the overall objectives by addressing the issues outlined in Chapter 2. The objective of this NPA is to update the flight crew training requirements to improve assessment and training of human factors; in particular, the personnel competence. At the same time, it provides additional efficiency in the field of flight crew training while achieving a smooth transition to competency-based training. The specific objectives of this proposal are to: (a) maintain the high aviation safety level by: (1) ensuring that the recurrent training and checking programmes are adequate to provide pilots with the necessary knowledge, skills and attitude to be competent in their job— under this objective, EASA proposes in this NPA new provisions to implement EBT as a first step towards the full implementation of competency-based training across Subpart FC of Part-ORO; and (2) addressing the SRs outlined in Section 2.1.2 ‘Safety recommendations’; (b) remain in compliance with ICAO by ensuring that the European rules align with the latest amendments outlined in Section 2.1.3 ‘ICAO amendments’, especially with regard to the EBT; and (c) contribute to the production of efficient regulations by adapting the necessary training standards and rules to ensure that the level of safety can only be positively affected by: (1) introducing performance-based regulation principles; (2) ensuring consistency of training-related rules across the applicable parts of Annex III (Part-ORO) to the Air OPS Regulation and Annex I (Part-FCL) to the Aircrew Regulation; and 21 Meeting held in Montreal, from 8 to 19 December 2003. 22 International Standards and Recommended Practices ICAO — Annex 1 to the Convention on International Civil Aviation — Personnel Licensing. TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 9 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what (3) ensuring the correct balance between implementing rules (IRs) and AMC & GM on the subject issue. 2.3. How we want to achieve it — overview of the proposals Doc 9995 contains a complete competency framework (‘core competencies’) with competency descriptions and related behavioural indicators, encompassing what was previously known as both technical and non-technical knowledge, skills and attitudes. This way, the training content is aligned with the actual competencies necessary to operate safely, effectively and efficiently in a CAT environment. Following this rationale, EASA decided to contribute to the development of regulations that ensure that pilot training and checking is adequate to provide a pilot with the necessary knowledge, skills and attitude (KSA) to recognise and manage unexpected and unusual situations. Traditional approaches to training development involve the decomposition of jobs into tasks. For each task, there is a related objective, an assessment and associated elements in a training plan. A limitation of this approach is that each task must be taught and assessed. In complex systems or when jobs evolve rapidly, it may not be possible to teach and assess each task. Moreover, learners may demonstrate the ability to perform tasks in isolation without being competent in their job. Competency-based assessment and training on the other hand are based on the concept that competencies are transferable. In the design of a competency-based assessment and training programme, a limited number of competencies are defined and used across a variety of activities and contexts. As new technologies emerge and the complexity of the aviation system increases, the existence of a competency framework is of key importance in order for pilots to be trained on complete and relevant set of competencies. This competency framework should allow pilots to operate more safely, effectively and efficiently in a CAT environment. Furthermore, should allow the training community to adapt their training methods in order to manage unexpected events that are unforeseen through reactive analyses. Mastering a finite number of competencies should allow a pilot to manage situations in flight that are unforeseen by the industry and for which the pilot has not been specifically trained. In 2014, ICAO established the Competencies Task Force. The task force proposals contained an amended set of definitions for terms related to competencies, a description of how competency- related concepts relate to one another and a generic methodology to design competency-based assessment and training. Furthermore, the ICAO AN-WP/8962 established that many competency frameworks were task-orientated. The task force also addressed the inconsistencies among these different competency frameworks. In addition, it described the relationships between keys concepts in competency-based assessment and training, and outlined the general principles and procedures to be followed in the design and implementation of competency-based assessment and training. TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 10 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what 2.4. What are the expected benefits and drawbacks of the proposals Studies23 show that the effective implementation of EBT should bring a significant contribution to aviation safety by strengthening the competencies of flight crews and empowering them to handle abnormal and unexpected situations safely. It is expected that the safety benefit of EBT would be demonstrated over time by continually improving a system targeted at focused learning. The implementation of the EBT programme should ensure a level of safety at least equivalent to that provided by compliance with ORO.FC.230 of Annex III (Part-ORO) of the Air OPS Regulation and Appendix 9 to (Part-FCL of the Aircrew Regulation. Safety benefits should be expected through a qualitative approach, using competencies to develop resilience by exposure to varying and challenging situations. The level of education and training of personnel within AOC holders is expected to be improved due to EBT. The EBT concept is designed to maximise learning and minimise formal checking. Where checking is required, it should evolve towards measuring the process of managing situations rather than only the outcome of this process. This will lead to a substantial change towards providing more learning opportunities, by recognising the expectation that professionals should continuously strive to learn and develop their capabilities, rather than only being focused on demonstrating performance according to minimum regulatory standards. The pilots will be assessed and their licences will be revalidated based on evidence from EBT evaluation modules and development of competencies throughout the EBT programme, instead of an LPC. Therefore, the proposal is expected to have positive social impact on the stakeholders (pilots, and organisations). Negative social impact is expected for the examiners whose workload would be reduced due to the revalidation of the licences not based on a single simulator session, but based on the evidence, gained through the EBT system. Reduced workload might affect negatively the current role, position and the number of examiners. Although the amount of training in EBT remains unchanged, the role of the trainer will be now performed under the privileges of type rating instructor (TRI) licence, instead of type rating examiner (TRE) licence. The cost-benefit analysis (CBA) for a medium/large operator with 1 000 pilots concludes that the implementation of EBT in recurrent training and checking of flight crew is a cost-effective solution. It is expected to cost 0.32 % of a medium/large operator’s turnover which is 0.03 % more than the expenditure that same operator makes for running traditional recurrent training and checking for its pilots (very low negative economic impact in terms of costs). In addition, it has the potential to generate significant economic benefits and to introduce an estimated saving of EUR 900 per pilot/year which represent around EUR 900 000 saving per year for the operator which represents 0.02 % of the operator’s turnover. The profitability indicators show that the return of investment is generated shortly after 3 years of EBT implementation, considering that competent authorities grant full economic alleviations to the operator. The CBA for a small operator with 100 pilots supports the overall positive economic results. Similarly, to the medium/large operator, EBT has the potential to reap significant economic benefits and to introduce an estimated saving of EUR 1 000 per pilot/year which represents around EUR 100 000 saving per year for the operator. The profitability indicators show that the return of investment is generated 4 years after EBT implementation, considering that competent authorities grant economic alleviations to the operator. The net benefit represents around 23 There are numerous books and studies that support the benefits of competency based training — Doc 9995, Doc 9868 ‘PANS TRG’, IATA Data report for EBT, IATA EBT implementation Guide and in the educational system: ‘A review of twenty years of competency‐ based training in the Australian vocational education and training system’ (author Erica Smith). TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 11 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 2. In summary — why and what 0.1 % of the annual turnover of a small operator. Despite that, a small operator may encounter difficulties in EBT implementation that are exhaustively analysed in the RIA. The requirement for inspectors to be competent in the approval of and the oversight over EBT programmes would result in increased competent authority’s costs for staff training in the short term that will be offset with normalisation of the workload in the consecutive years in EBT oversight. In addition, the workload and the relative costs for the competent authority are expected to decrease with the time, as there might be a greater take-up of the EBT programmes by AOC holders. As EBT implementation supports performance- and risk-based oversight, the overall impact on the competent authority is considered very low negative in the first years and neutral in the consecutive years. Finally, the regulatory impact assessment (RIA) illustrates that the proposed rules for voluntary implementation of EBT by AOC holders contribute to maintaining a high level of aviation safety while providing a cost-efficient and socially acceptable framework. The expected benefits and drawbacks of the proposal are summarised below. For the full impact assessment of alternative options, please refer to the IA. TE.RPRO.00034-006© European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 12 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) 3. Impact assessment (IA) 3.1. What is the issue Rapid technological changes and a diverse, dynamic and competitive operating environment create a need for effective and efficient training aligned with the needs of the job. Traditional approaches to training development involve decomposition of jobs into elements or tasks. For each task/element, there is a related objective, an assessment, and the associated elements in a training plan. A limitation of this approach is that each task/element must be taught and assessed. In complex systems or when jobs evolve rapidly, it may not be possible to accommodate all these elements. Moreover, learners may demonstrate the ability to perform any number of tasks without being competent in their job. In that context, pilots need to be exposed to the unexpected in a learning environment, and be more challenged and immersed in dealing with complex situations, rather than repetitively being tested in the execution of specific predefined manoeuvres. Furthermore, the checking of flight crew does not measure sufficiently the process of managing situations, as it is mainly focused on the outcome of the process by demonstrating performance according to minimum regulatory standards. Hence, it lags behind in providing more learning opportunities and fails to meet the expectation that professionals should continuously strive to learn and to develop their capabilities. Competency-based training is a performance orientated approach in the assessment and training, putting emphasis on performance standards and their measurement and developing training with regard to the specified performance standard24. Competency-based training has been successfully used across many industries. It is based on a job-related performance that encompasses technical task- related skills and non-technical performance. The EBT approach to competency-based training is to ensure that flight crew’s performance is captured across a range of observable behavioural indicators, thus guaranteeing that what is trained and checked is relevant to the job. 3.2. Regulatory background and evolution EASA started in September 2015 RMT.0696 ‘Implementation of evidence-based training within the European regulatory framework’ and created an EBT Task Force to develop interim guidance material (GM) in order to promote a standardised and consistent means for the implementation of EBT within the existing rule structure. This first step was completed with the publication of ED Decision 2015/027/R (published in December 2015) containing GM1 ORO.FC.230 and GM1 ORO.FC.A.245. RMT.0696 followed an accelerated process within the existing regulatory system to bring forward the safety benefits of EBT, by maintaining the existing IRs and AMC, in order to provide a robust safety net until more experience in the EBT concept is gained. RMT.0696 was planned as an interim step preceding RMT.0599 to gain EBT implementation experience and thus identify certain difficulties and inconsistencies that will need to be addressed through RMT.0599. 24 . ICAO DOC 9995 Definition TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 13 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Presently, EASA Member States (and other States that have elected to adhere to the European aviation IRs) do not have a regulatory framework that lends itself to the full implementation of EBT. In fact, within the current regulatory framework, it is only possible to achieve mixed EBT implementation25. Data analyses26 reveal the difficulties encountered by pilots when faced with surprising or unexpected situations. The commercial aviation system has a high level of safety reliability, but there remains a resistant rate of serious and fatal accidents. The availability of substantial data allows a systemic improvement, mostly through reactive redesign, improved operations, training and maintenance/airworthiness activities. This improvement though will result in lead to a decreased rate of serious and fatal accidents, which will become less predictable over time due to the difficulty in predicting the root cause. Since complex linear models could not provide answers to these events, alternative explanations are needed. They can be seen as due to an unexpected combination or aggregation of conditions or events. The continuous development of pilot core competencies is seen as an effective means to address what will be unexpected and ultimately unforeseeable, the so-called ‘black swan’ events. One of the key facets of EBT is learning enabled through exposure to unexpected, dynamic and challenging situations. Exposure during training to variable and dynamic threat conditions should help pilots develop and improve their ability to handle unforeseen events. With variability of exposure, confidence should be developed through the repetitive deployment of core competencies under many different conditions and across the aircraft flight envelope. The EBT project is a global safety initiative whose objective was to determine the relevance of existing pilot training and to identify the most critical areas of pilot training according to aircraft generation. The outcome of this initiative was the publication of ICAO Doc 9868 ‘PANS-TRG’ (Chapters 5 and 6). In May 2013, ICAO published Doc 9995 which contains the details of a new approach to recurrent training and checking of flight crew. As part of RMT.0599, EASA commits to the development of a dedicated regulation to enable the full deployment of EBT programmes in accordance with the Doc 9995 philosophy. The implementation of EBT within the European aviation regulatory framework is a paradigm shift, assessing crew performance across a range of core competencies, rather than checking performance in managing prescribed events. Training topics drawn from comparative risk analyses are used as a vehicle for developing and assessing core competencies. Given the paradigm shift proposed by competency-based programmes like EBT, one of the principal challenges for implementation is the adaptation of the current instructor and examiner population to the concept. With this in mind, competent authorities and operators implementing EBT should focus on the development of instructor and examiner competencies. The safety risk assessment and analysis of fatal aircraft accidents worldwide for the period 2001-2011 shows that in more than 50 % of these accidents the action of the flight crew was the primary causal factor (CAA UK, 2013). This analysis shows that flight crew handling skills were a factor in 14 % of the accidents, whereas flight crew non-technical skills were a factor in more than twice as many (32 %). It is generally accepted that further improvements in flight safety require a comprehensive review of pilot training (IATA, 2013), and the accident statistics show that the emphasis of this training should be placed on the development of both the non-technical as well as the technical pilot skills. 25 Mixed EBT implementation means that only some portion of the recurrent assessment and training is dedicated to the application of EBT. 26 IATA, Data Report for Evidence-based Training, First Edition, August 2014 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 14 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Traditional (legacy) recurrent training requirements for pilots operating with airlines are, largely, not relevant to the operation of modern multi-crew transport category aeroplanes (IATA, 2011) and have not kept up with the development of the operating environment. The current requirements are largely based on the evidence of accidents involving early-generation jet aircraft (IATA, 2013) and do not reflect the risks of the today operating environment. Operators and industry bodies have recognised that the legacy training processes do not guarantee that the trained pilots are competent, or they do not adequately address ‘human factors’ issues (IATA, 2013). Therefore, the implementation of EBT should be a first step towards the full implementation of a competency-based training framework in all aspects of flight crew training and licensing. The following SRs pertain to specific accidents/incidents. RMT.0599 will ensure that they are taken into account in the scope of the recurrent EBT and checking, either as regards training events during the recurrent training, i.e. ‘equivalence of malfunctions’, or enhancing training for a specific core competency: FRAN-2013-017: The French Accident Investigation Board recommends that EASA, in coordination with manufacturers, operators and major non-European aviation authorities ensure that go-around training integrates instruction explaining the methodology for monitoring primary flight parameters, in particular pitch, thrust then speed. FRAN-2013-018: The French Accident Investigation Board recommends that EASA, in cooperation with the national civil aviation authorities and major non-European aviation authorities, ensure that during recurrent periodic training, training organizations and operators give greater importance to the assessment and maintenance of the monitoring capabilities of public transport pilots. FRAN-2013-022: The French Accident Investigation Board recommends that EASA review regulatory requirements for initial and periodic training in order to ensure that go-arounds with all engines operating are performed sufficiently frequently during training. FRAN-2013-033: The French Accident Investigation Board recommends that EASA, in cooperation with the national civil aviation authorities and major non-European aviation authorities, ensure that the risks associated with dispersion and/or channelized attention during the go-around, to the detriment of the primary flight parameters, be taught to crews. FRAN-2013-035: The French Accident Investigation Board recommends that EASA, in coordination with manufacturers, operators and major non-European aviation authorities, study whether to extend these measures to other procedures requiring high workload in a short time frame. FRAN-2014-005: The French Accident Investigation Board recommends that EASA, in coordination with national authorities, make changes to the training requirements for pilots so as to include periodic reminders on the effects of contaminants such as ice on stall and loss of control on take-off. FRAN-2015-062: [unofficial translation]: EASA should define the terms on how an operator can set up a risk-based training as described in Doc 9995. [French] [original text] - L’AESA définisse les modalités permettant à un exploitant de mettre en oeuvre la formation basée sur les risques telle que précisée dans le doc OACI 9995 de l’OACI. [Recommandation 2015-062] TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 15 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) 3.2.1. Who is affected The following stakeholders are affected by the proposed changes of RMT.0599 in recurrent training and checking of pilots: CAT operators — Full deployment of EBT by the AOC holders will require some changes regarding the recurrent flight crew training and checking (OPC and LPC) in order to accommodate the training under the new philosophy. The impacts will differ for operators who are currently providing legacy recurrent training (under the existing ‘prescriptive’ requirements) and for those who implemented the alternative training and qualification programme (ATQP). The latter ones are considered much more advanced and close to the implementation of EBT. Competent authorities — Within the new regulatory proposals and the EBT framework, competent authorities are responsible for approval of EBT recurrent pilot training and regulatory oversight. Pilots — Pilots would be the ‘end users’ of the new provisions. However, their role is analysed from the perspective of the impacts for the AOC holders who would undertake necessary changes to shift the recurrent training and checking to the EBT model. Therefore, although pilot data is used, this data is anonymous and pilots are not individually analysed. Instructors and examiners, according to Subparts J and K of Part-FCL of the Aircrew Regulation and most notably TRIs and TREs. Although RMT.0599 is not directly addressed to instructors and examiners (RMT.0596 ‘Review provisions for examiners and instructors (Subpart J & K of Part-FCL) is going to integrate the EBT provisions for instructors and examiners in Part-FCL), it affects directly the roles and positions of instructors and examiners and therefore the impact on them is analysed in the current document. 3.2.2. How could the issue/problem evolve As a matter of example, in the last decade, safety investigation authorities (SIAs) have issued 99 SRs related to flight crew training. These SRs were issued as a result of the investigation of 55 occurrences (accidents, in most of the cases) involving a CAT aeroplane operation with a maximum take-off weight (MTOW) above 5 700 kg. In said occurrences, the SIAs judged the training provided to the flight crew inadequate, inefficient or insufficient for the flight crew to recognise flight deviations and to handle them safely. In almost all cases, the crew received the training in accordance with prescribed requirements at the time of the occurrence. If no action is taken, these safety issues may remain unaddressed. Traditional approaches to training could not solve the outlined issues. As mentioned, legacy training involves the decomposition of jobs into elements or tasks, which must be taught and assessed. This approach has certain limitations, because in complex systems or when jobs evolve rapidly, it may not be possible to accommodate all these elements. Moreover, learners may demonstrate the ability to perform any number of tasks without being competent in their job. The adaptability and flexibility of human work, however, is also a reason behind the failures that occur, although it is rarely the actual cause behind those failures. Actions and responses are almost always based on a limited rather than a complete analysis of the current conditions, i.e. a trade-off between thoroughness and efficiency. Still, since this is the normal mode of acting, normal actions can, by definition, not be wrong. Failures occur when this adjustment goes away, even though both the actions and the principles of adjustment are technically correct. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 16 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) In order to respond to these challenges, continuous development of pilot core competencies is seen as an effective means to address them. EBT enables exposure to unexpected, dynamic and challenging situations to variable and dynamic threat conditions, which should help pilots develop and improve their ability to handle unforeseen events. This should be done through the repetitive deployment of core competencies under many different conditions and across the aircraft flight envelope. It is acknowledged that EBT will provide a more flexible and efficient framework as operators will provide flight crew training that will: — address the core competencies; and — consider specific risks they face and thus be tailored to their needs. 3.3. What we want to achieve — objectives The objectives of the European Union (EU) in the field of civil aviation are defined in Article 2 of the Basic Regulation. This RMT will contribute to the achievement of these objectives by addressing the issues outlined above. The specific objectives of this proposal are to: (a) maintain the high aviation safety level by: (1) ensuring that the recurrent training and checking programmes are adequate to provide pilots with the necessary knowledge, skills and attitude to be competent in their job— under this objective, EASA proposes in this NPA new provisions to implement EBT as a first step towards the full implementation of competency-based training across Subpart FC of Part-ORO; and (2) addressing the SRs outlined in Section 2.1.2 ‘Safety recommendations’; (b) remain in compliance with ICAO by ensuring that the European rules align with the latest amendments outlined in Section 2.1.3 ‘ICAO amendments’, especially with regard to the EBT; and (c) contribute to the production of efficient regulations by adapting the necessary training standards and rules to ensure that the level of safety can only be positively affected by: (1) introducing performance-based regulation principles; (2) ensuring consistency of training-related rules across the applicable parts of Annex III (Part-ORO) to the Air OPS Regulation and Annex I (Part-FCL) to the Aircrew Regulation; and (3) ensuring the correct balance between implementing rules (IRs) and AMC & GM on the subject issue. 3.4. How it could be achieved — options The analysis of the most controversial issues was followed by a definition of the policy options regarding the implementation of EBT for the recurrent training and checking. The following options have been identified to address the issues presented above. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 17 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Table 1: Initial list of policy options Option Short title Description 0 No policy change Continuation of legacy training or ATQP for the conduct of recurrent training and checking to flight crew. In addition, ED Decision 2015/027/R27 developed interim guidance material (GM) in order to promote a standardised and consistent means for the implementation of EBT within the existing rule structure. It allows therefore mixed EBT implementation where EBT is implemented only for a certain portion of the recurrent assessment and training. The risks and the problems stay unresolved, as mentioned in the issue analysis. 1 Voluntary EBT It provides an opportunity for the AOC holders to take a decision to implement the EBT system for the recurrent training and checking of the flight crew, including LPCs and OPCs. It means that the operator will shift from following the existing ‘prescriptive’ (legacy) training or ATQP to EBT recurrent training and checking. This option has three sub-options: 1.1 Implement EBT It envisages a traditional LPC and renewal/revalidation of the licence according within the current to the current system (1 module LPC and 3 other modules of EBT). During the LPC licence simulator check, pilots undergo a check of prescriptive manoeuvres according to revalidation Appendix 9 to the Aircrew Regulation. process This option maintains the current examination system, performed by the TREs based on the simulator results. 1.2 Implement EBT It envisages that the licence will not be revalidated, but it will have a restricted with revalidation validation within the AOC holder. It will not be signed by an examiner, but by an of licence AOC holder. This sub-option restricts the exercise of the privileges of the pilot restricted to the licence in that particular AOC holder. AOC holder 1.3 Implement EBT This option envisages a separation of the administrative work for revalidation of with separation of the pilot licence from the technical work for assessment of the pilot. the administrative The administrative work will be maintained and performed by the TREs, as the action of current system suggests. TREs will continue to revalidate the licence; however, revalidation of not based on the simulator results, but based on evidence provided by EBT. This licence from the option guarantees that pilots will be assessed and their licences will be technical revalidated based on additional evidence from EBT evaluation modules. The assessment/check assessment will be disconnected from the revalidation of the licence and this of the pilots would ensure a more objective revalidation process. The revalidation of the licence will be signed by the TREs and the validity of the licence will be maintained for 1 year (as currently). The TREs will be the nominated person of crew (or the deputy(ies)) as they have the responsibility of the EBT programme, meaning they are responsible for the 27 https://www.easa.europa.eu/system/files/dfu/ED%20Decision%202015-027-R%20-%20Explanatory%20Note%20.pdf TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 18 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Option Short title Description evidence provided by EBT. The technical part will be performed by the AOC TRIs based on the concept of the continuous monitoring of the pilots’ performance. 2 Mandatory EBT This option envisages mandatory EBT for all operators and discontinuation of the legacy training. Implementation of mandatory use of competency-based training in all flight crew training performed by an AOC holder. Furthermore, for those types of aircraft subject to EBT (see Appendix 2 to Doc 9995), its implementation would be mandatory by removing the current prescriptive rules, thus making EBT the only alternative to ATQP. In terms of content, this policy option has the same features and description as policy option 1. However, it is defined as a separate alternative, because it refers to mandatory EBT. Based on an initial analysis of the options, the following sub-options have been discarded due to the reasons mentioned below: Table 2: List of discarded policy sub-options Sub- Title Rationale for being discarded option 1.1 Implement EBT within — Retaining LPC in its current form does not support the full EBT the current licence competency-based training according to Doc 9995. revalidation process — Assessing the performance of the pilots based on the simulator prescriptive manoeuvres results in the LPC does not consider the whole EBT concept. 1.2 Implement EBT with — It implies restricted validation of the licence to the particular revalidation of licence AOC holder (similar to the MPL type rating). restricted to the AOC — It may lead to potential problems with third-country holder authorities (in the SAFA inspections) because there might be a risk of grounding the aircraft, as their licence will not have any validation period. — The pilots will not be able to work for another AOC holder because the revalidation will be only for the AOC holder for whom they are working. This may have potential negative social and economic costs and might lead to administrative burden. — It would deteriorate the level playing field between the AOC holders. — The role of the examiners would disappear, thus leading to serious negative social and economic impact. — There is legal uncertainty in the Member States’ national legal systems because the revalidation of the licence is a public service attested by a public document issued by the competent authorities. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 19 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) The final list of retained policy options is presented in the table below. Table 3: Final list of policy options Option Short title Description 0 No policy change Continuation of legacy training or ATQP for the conduct of recurrent training and checking to flight crew. In addition, ED Decision 2015/027/R developed interim guidance material (GM) in order to promote a standardised and consistent means for the implementation of EBT within the existing rule structure. It allows therefore mixed EBT implementation where EBT is implemented only for a certain portion of the recurrent assessment and training. The risks and the problems stay unresolved, as mentioned in the issue analysis. 1 Voluntary EBT It provides an opportunity for the AOC holders to take a decision to implement the EBT system for the recurrent training and checking of their pilots and to shift from following the existing ‘prescriptive’ (legacy) training or ATQP to EBT. It envisages a separation of the administrative work for revalidation of the pilot licence from the technical work for assessment of the pilot. The administrative work will be maintained and performed by the TREs, as the current system suggests. TREs will continue to revalidate the licence; however, not based on the simulator results, but based on evidence provided by EBT. This option guarantees that the pilots will be assessed and their licences will be revalidated based on additional evidence from EBT evaluation modules. The assessment will be disconnected from the revalidation of the licence and this would ensure a more objective revalidation process. The revalidation of the licence will be signed by the TREs and the validity of the licence will be maintained for 1 year (as currently). The technical part will be performed by the AOC TRIs based on the concept of the continuous monitoring of the pilots’ performance. 2 Mandatory EBT This option envisages mandatory EBT for all operators and discontinuation of the legacy training. Implementation of mandatory use of competency-based training in all flight crew training performed by an AOC holder. Furthermore, for those types of aircraft subject to EBT (see Appendix 2 to Doc 9995), its implementation would be mandatory by removing the current prescriptive rules, thus making EBT the only alternative to ATQP. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 20 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) 3.5. Methodology and data 3.5.1. Data collection This RIA is performed based on several sources: — Questionnaires to the operators representatives of which participate in the RMG Six AOC holders provided data on their experience in commencing and/or running mixed EBT recurrent training and checking, starting from a different basis. As mentioned in the issue analysis, within the current regulatory framework, it is only possible to achieve mixed EBT implementation28. Due to the novelty of the EBT approach in the EU context, there is not extensive expertise in the EASA Member States operators/ATOs for its implementation. Information was, therefore, sought also outside the EU. In the analysis of the responses to the questionnaires, an important distinction was made with regard to the type of recurrent training and checking the operator had before they implemented mixed EBT. Some operators before the implementation of mixed EBT, performed legacy training, others provide ATQP to their pilots. In addition, the size of the operator has also been considered in estimating the impacts. The analysis, therefore, recognises different impacts for small/medium operators in starting and running EBT. — Questionnaire to other operators who implement EBT for recurrent training and checking Αpart from data from the RMG, complementary sources (e.g. data from other operators) were sought to ensure that different business models and operators who have initiated a shift towards EBT are represented. Hence, the analysis of the expected costs and benefits is based on real cases. — Questionnaire to the competent authorities Data regarding the impact of EBT on the workload, fees, charges and internal work was analysed from EU and non-EU competent authorities. They were contacted as part of or through the RMG members, some of whom were representatives of competent authorities. 3.5.2. Methodology applied The RIA is developed by combining different impact assessment tools: Cost Benefit Analysis (CBA): it is applied for the economic impacts, because the data on benefits and costs was sufficiently quantified and monetarised. The method entails identification and evaluation of the expected economic benefits and compliance costs for the industry to implement EBT. The outcome is expressed in terms of net present value (NPV), cost-benefit ratio and year of return of investments in EBT. Apart from the advantage of measuring and quantifying the net benefits, the CBA is also chosen due to its quality to quantify the costs and benefits over time. This is considered highly relevant, because the benefits of EBT are unevenly distributed in the years of the EBT implementation and the CBA captures that feature. However, the CBA is performed mainly for the economic impacts. There is no quantification of the safety impacts, because of the limitations of data currently available. Consequently, safety impacts will be qualitatively assessed. The reference period in the CBA is 10 years 28 Mixed EBT implementation means that only for a portion of the recurrent assessment and training there is application of EBT. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 21 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) (2018-2027) and the analysis is made following the European Commission guidelines for the CBA29. The CBA is performed in several steps: STEP 1 — Estimation of the costs of recurrent legacy/prescriptive training and checking implementation (baseline scenario) STEP 2 — Estimation of the costs (one-off and recurrent) for preparation and implementation of EBT STEP 3 — Calculation of the difference between costs for EBT recurrent training and checking and legacy recurrent training and checking (delta of EBT costs) STEP 4 — Distribution of the one-off and recurrent costs for EBT, as well as recurrent costs for legacy training in 10 years’ time STEP 5 — Quantification and monetisation of the economic benefits of EBT, e.g. alleviations envisaged in the regulatory proposal for operators who might be granted with these privileges upon the discretion of the competent authority’s decision. Distribution of the economic benefits in 10 years’ time STEP 6 — Comparison of the economic benefits and costs for EBT. Calculation of cost-benefit ratio and year of return of investments in EBT Multi-criteria analysis: multi-criteria analysis allows comparison of all options by scoring them against a set of criteria (safety, social, economics…) through a common qualitative scale. This method allows a trade-off between different impact assessment criteria, e.g. low scores on one criterion may be compensated by high scores on another. MCA covers a wide range of techniques that aim at combining a range of positive and negative impacts into a single framework to allow easier comparison of scenarios. The scoring of the impacts uses a scale of – 5 to + 5 to indicate the negative and positive impacts of each option (i.e. from ‘very low’ to ‘very high’ negative/positive impacts). Table 4: Scale with scoring of the impacts Positive Score Negative Score impact impact +5 Very high positive impact – 5 Very high negative impact +4 High positive impact –4 High negative impact +3 Medium positive impact – 3 Medium negative impact +2 Low positive impact –2 Low negative impact +1 Very low positive impact – 1 Very low negative impact 0 Neutral — — 29 http://ec.europa.eu/smart-regulation/better_regulation/documents/com_2015_215_en.pdf TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 22 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) For the economic impacts, the above scale is further detailed with the scores using the budget of the CAs and the turnover of the airlines (for the EASA MS geographic area). The CBA provides the outcome of the economic impact of the regulatory options. These impacts can be measured in relative share against the budget or turnover of a stakeholder group. Table 5: Definition for the economic scale COMPETENT AIRLINES AUTHORITIES Turnover (M€) 2 800 220 000 2016 QUALITATIVE DESCRIPTION Score Turnover impact VERY HIGH IMPACT +/- 5 > +1.5% >42.0 >3316.5 ]1 to 1.5 %[ 42.0 3316.5 HIGH IMPACT +/- 4 ]0.8 to 1 %[ 28.0 2211.0 ]0.6 to 0.8 %[ 22.4 1768.8 MEDIUM IMPACT +/- 3 ]0.4 to 0.6 %[ 16.8 1326.6 ]0.2 to 0.4 %[ 11.2 884.4 LOW IMPACT +/- 2 ]0.1 to 0.2 %[ 5.6 442.2 ]0.05 to 0.1 %[ 2.8 221.1 VERY LOW IMPACT +/- 1 ]0.02 to 0.05 %[ 1.4 110.6 ]0 to 0.02 %[ 0.6 44.2 NEUTRAL 0 0.3 22.1 Case studies: Due to the complexity of the issue and the existence of different business models for operators30, it is difficult to represent all different models and analyse their impact. Therefore, it is suggested to illustrate the impact through examples of the impacts for the options mentioned above. Hence, there are two examples of operators who undertake EBT. One is a small size operator (with a small fleet and 100 pilots) and the other one is a medium/large operator (with a medium fleet and 1 000 pilots). For larger operators, the medium fleet/1 000 pilots can be easily extrapolated with simple maths (e.g. 1 000 pilots multiplied by 10 — 10 000 pilots). All assumptions regarding the type of the operators are presented below. Impacts analysed: The present RIA analysed the impacts considering several criteria: safety, social, economic. These criteria follow the main objectives of the Basic Regulation. The analysis of the ‘General aviation and proportionality issues’ is not kept as General Aviation is not affected as their aircraft types are not currently included in EBT. Therefore, General Aviation is not in the scope of this proposal31 and proportionality issues are analysed in the economic impacts. The proposed approach ensures that the impact is assessed only once, avoiding any risks of double counting. — In addition, it is important to note that each option was analysed separately, considering the baseline. The assessment of the impacts took into consideration potential costs and benefits having in mind the baseline scenario. However, as policy options 1 and 2 are very similar in terms of content (both bear the same elements and regulatory proposals), the differentiation 30 Point to point operator (P2P), Hub and Spoke operator (H&S), Operators running mainly long-haul and/or and short-haul flights or combination of them, etc. 31 RMT.0599 may study the extension of EBT to General Aviation in 2019. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 23 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) between them is mainly in the way EBT will be implemented by the stakeholders: in the first case on a voluntary basis, in the second case as a compulsory requirement. 3.6. What are the impacts 3.6.1. Safety impact Option 0 — No policy change Safety risks continue to exist as mentioned in the issue analysis. The exposure to the safety risks will remain and the current safety level will be maintained. Therefore, the safety level score is assessed as neutral (score 0). Option 1 — Voluntary EBT Due to the nature of EBT, it is difficult to assess its safety impact. However, there is evidence showing that the proper implementation of EBT will significantly improve aviation safety by strengthening the core competencies of flight crew and helping them to handle abnormal and unexpected situations safely. There have been several research studies as regards the development of the EBT concept and its implementation assessment. In the context of this RIA, it is worth mentioning the Man4Gen Study32, which showed the transferability of the core competencies between scenarios. This conclusion would reinforce the idea that training the flight crew in core competencies, rather than in executing specific manoeuvres, enables them to handle a wider range of scenarios with higher levels of resilience. In addition, the experience of operators that have implemented EBT or training methodologies with similar goals (i.e. ATQP, the Federal Aviation Administration Advanced Qualification Program – AQP) shows that flight crew are better prepared to take over highly-automated operations and to apply a more consistent and quick decision-making in those moments with high workload. These operators have also noticed the positive feedback from the flight crew being trained with those training methodologies, as they feel better prepared, especially with regard to the performance of the line- orientated evaluation (LOE). The data33 shows that the remedial training for flight crew who fail in the LPCs and OPCs is reduced by half (50 %) after the implementation of mixed EBT. Apart from a significant benefit from a safety perspective, this also has a positive economic implication. It is expected that the safety benefit of EBT would be demonstrated over time by continually improving a system targeted at focused learning34. The implementation of the programme should ensure a level of safety at least equivalent to that provided by compliance with ORO.FC.230 of Appendix 9 to Annex I (Part-FCL) to the Aircrew Regulation, by continuing to focus on legacy items of check, albeit within a different structure. Safety benefits should be expected through a qualitative approach, using core competencies to develop resilience by exposure to challenging situations. This option would have the potential to deliver a significant improvement in safety. An EBT programme is intended to identify operational risks by using multiple sources of operational data to determine the 32 www.man4gen.eu 33 Based on the feedback by operators who implemented full EBT worldwide, 2008-2015, EASA questionnaire 2016 34 IATA, Data Report for Evidence-based Training, 2013. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 24 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) prioritisation of training topics linked to a competency-based training framework. As examples35, the analysis of worldwide data revealed consistent and significant risks in the following areas: — Flight path — Manual aircraft control: Manual aircraft control skills of pilots can be expected to deteriorate over time as aircraft design improves and the use of automation increases unless supported by training to maintain and further develop these skills. — The unstable approach paradox: Despite the reduction in unstable approaches, the go-around remains a high-risk flight phase, and increased training focus on go-arounds mitigates this risk. — Crew resource management: According to the Data Report for EBT, flights where outstanding communication and leadership have been observed involve significantly less errors and undesired aircraft states than flights where poor leadership and communication have been observed. This reinforces the need for a continued focus on these skills. — Surprise: The effect of the current high levels of operational safety is that the effects of surprise may compound any event. Training to react and recover from surprise events forms a key part of the EBT programme. — Prioritisation of training topics: The prioritisation of training topics is the most important result from the data analysis of the EBT report. This process involves the assessment of inputs from multiple data sources and ranking of threats, errors and competencies, as well as causal factors from incidents and accidents. The process is a key part in translating data into useful training events and scenarios that can be used to assess and improve pilot performance in recurrent training programmes. The process used for the Data Report for EBT is transparent and repeatable and results in a list of prioritised training topics. Three levels of priority (A, B and C, with A having the highest priority) are used to determine the frequency of pilot exposure to the training topics within a 3-year rolling recurrent training programme. In addition to the improvement from an increased take-up of EBT, aircraft operators would be able to develop less complex training programmes, tailored to the identified risks, and to implement the principles of competency-based training in all training programmes. The overall result would be better training of the pilots involved and a lower flight-crew-related accident rate in the future. Although, the implementation of EBT within this option is voluntary, it is expected that a significant number of operators will apply EBT due to the benefits it renders. Hence, the safety impact of Option 1 is scored as +2 (low positive impact). 35 IATA, Data Report for Evidence-based Training, 2013 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 25 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Option 2 — Mandatory EBT This option would provide a higher level of safety as it would ensure that all flight crew training for AOC holders is conducted in a competency-based framework tailored to the risks identified in operations. It is therefore scored with +3 (medium positive safety impact). Based on the analysis above, the safety impact assessment is visualised as follows: Table 6: Safety impacts per option Criteria Option 0 Option 1 Option 2 No policy Voluntary EBT Mandatory EBT change Safety Improved safety (for the Safety will improve due to better training focused on the operator) operational risks. The flight crew would be better prepared to take over highly- automated operations and to apply a more consistent and quick decision-making in moments with high workload, leading to an expected decrease in the flight-crew-related accident rate in the Safety level future. is Safety maintained. Low positive Medium positive (for the For the EU industry: For the EU industry: industry) Due to the nature of Medium positive safety impact, the implementation (on because it would apply to the a voluntary basis), the whole industry. deployment of EBT may not encompass the whole market. 0 +2 +3 3.6.2. Environmental impact Not applicable. 3.6.3. Social impact Option 0 — No policy change No social impact is anticipated from Option 0. The social impact score is 0 (no impact/neutral). Option 1 — Voluntary EBT This option has the following social impacts: — Positive impact on consultancies and companies with EBT expertise: It is expected that the number of consultancies and companies with EBT expertise would increase as they would expand their business and might increase the number of employees. Positive effects would be TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 26 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) generated for the training developers and training providers because many aircraft operators would need to develop/build on expertise and extend knowledge in the field. — Positive impact on AOC holders and flight crew: The level of education and training of personnel of AOC holders is expected to be raised due to EBT. The EBT concept is designed to maximise learning and minimise formal checking. Where checking is required, it should evolve towards measuring the process of managing situations rather than only the outcome of this process. This will lead to a substantial change towards providing more learning opportunities, by recognising the expectation that professionals should continuously strive to learn and increase their capabilities, rather than only being focused on demonstrating performance according to minimum regulatory standards. The pilots will be assessed and their licences will be revalidated based on additional evidence from EBT evaluation modules. In addition, EBT is focused on the deployment of core competencies36 and on the process of using them to mitigate challenging situations, rather than on the measurement of simple outcomes in the performance of standard manoeuvres. Based on the improved skills and competencies, EBT might also have also a potential positive effect on the flight crew career development. Another positive impact lies within the proposed changes for revalidation of the flight crew licences. It is suggested that there would be separate processes for the administrative work for revalidation of the pilot licence and for the technical work for assessment of the pilot. The administrative work will be maintained and performed by the TREs, as the current system suggests. TREs will continue to revalidate the licence; however, not based on the simulator results, but based on evidence provided by EBT. This option guarantees that pilots will be assessed and their licences will be revalidated based on additional evidence from EBT evaluation modules. Therefore, the revalidation process would be more objective and that might result in additional positive social benefit for the flight crew. — Positive impact on TRIs/TREs: They would be positively affected by this option, because they will receive competency-based training that would improve their knowledge and skills. The line check of the flight crew (‘line evaluation’ in EBT terminology) will require an EBT instructor, while so far it is performed by a nominated person. That change would result in strengthening the role of the TRIs as they need to perform the line evaluation in EBT. — Negative impact on TREs: The workload and the volume and scope of the work performed by the TREs would be reduced as the revalidation of the licences will not be based on a single simulator session; it will be based on the evidence gained through the EBT system. The reduced workload might affect negatively the current role, position and the number of examiners. Although the amount of training in EBT remains unchanged, the role of the trainer will be now performed under the privileges of the TRI certificate, instead of the TRE certificate. — Positive impacts on competent authorities: The inspectors at the competed authority will be positively affected because they would improve their knowledge by following EBT training and/or participating in all phases of the implementation of EBT by the operator and by overseeing the training of TRIs/TREs. Based on the analysis above, the overall social impact of Option 1 is scored as +2 (low positive). 36 ‘Competency-based training is the approach used to deliver the content of EBT programmes’ (Doc 9995, Chapter 7) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 27 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Option 2 — Mandatory EBT The above-mentioned impacts are valid for Option 2 as well, but this option is expected to trigger much higher positive social impact (medium positive impact +3), because the benefits explained above will be reaped by all operators (higher population), flight crew, etc. In addition, it would result in more opportunities for development of the EBT developers and providers and thus positively affect employment. Table 7: Social impacts per option Criteria Option 0 Option 1 Option 2 No policy Voluntary EBT Mandatory EBT change Social No social Low positive Medium positive impact impacts Improvement in the skills, Same impacts for all knowledge of all stakeholders; more stakeholders as in Option 1, objective revalidation licence but for all AOC holders, flight process, based on evidence provided crew, EBT training by EBT. Some negative impacts for developers/providers, etc. TREs whose volume of work for Some negative impacts for licence revalidation will decrease. TREs whose volume of work for licence revalidation will decrease. 0 +2 +3 3.6.4. Economic impact 3.6.4.1 Option 0 — No policy change No impact. 3.6.4.2 Option 1 — Voluntary EBT The economic impacts are analysed for operators and for EASA Member States’ competent authorities. As mentioned in the methodological note, a CBA is performed to assess the costs and benefits of EBT implementation. 3.6.4.2.1 Economic impact for the operators The current section is based on two case studies: — Case study 1: Economic impacts for a medium/large operator — Case study 2: Economic impacts for a small operator. The current section explains in detail the assumptions and calculations for these case studies. Both case studies are prepared for operators that run legacy/prescriptive recurrent training and checking and need to go through the whole preparation process for EBT implementation. The cases do not analyse the transition costs for an operator who is currently running ATQP recurrent training to shift to EBT, because ATQP operators are much more advanced in the implementation of competency- based training and the efforts for them to deploy EBT would be much less in comparison to a legacy training operator. Therefore, the case studies refer to a situation that is much more common and would entail all types of costs (that could be quantified). It is assumed that the ATQP operator would TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 28 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) get benefit from the full CBA, which illustrates the type of compliance costs and expected economic benefits. Case study 1: Economic impacts for a medium/large operator This case study is conducted with the following assumptions: General assumptions — The airline is not a flight-time-limited airline (e.g. the pilots do not reach the maximum yearly flight time hours, i.e. 1 000 in 12 months according to ORO.FTL.210). — The airline is a day-duty-limited airline (e.g. the limitation of the pilots is by number of duty days available). — The airline is running both long-haul and short-haul flights. For simplicity reasons, the flight crew is assumed to carry out short-haul flights. — Number of pilots (captains and first officer): 1 000 — Number of instructors/examiners: 100, indicatively 10 % of the pilot population — Number of line checks per year: 600 line checks of all 1 000 pilots which are performed in 600 line check working days — Number of FSTD sessions (hereinafter referred as ‘simulator sessions’): 2 800 simulator sessions of OPC/LPC per year for all pilots at the company (500 crews, 4 sessions per crew which are in total 2 000 sessions per crew; a coefficient of 1.4 is applied to calculate the realistic number of simulator sessions due to the inefficiency in terms of number of pilots undertaking simulators, e.g. not always the captain and the first offers are coupled in the simulator session) — 1 FTE = 180 working days — The crew need to travel to the main base/headquarters, where the training is carried out. — Duration for the development and update of the training programme under the legacy training: 80 working days. — Fees and charges for approval of the recurrent training programme: EUR 8 400 (source UK CAA fee rate) — Refresher training for TRIs/TREs:1 working day. — The annual remuneration of a nominated person for crew training (training manager) is EUR 200 000 per year (full cost for the operator, including gross salary plus the social security contributions for the operator). — The annual remuneration of an instructor/examiner is estimated at EUR 200 000 (full cost for the operator, including gross salary plus the social security contributions for the operator). — The annual remuneration of a pilot is estimated at EUR 200 000 (full cost for the operator, including gross salary plus the social security contributions for the operator). It is calculated based on the average remuneration of a captain and a first officer per year. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 29 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) — The annual remuneration of a captain performing the line check is estimated at EUR 200 000 (full cost for the operator, including gross salary plus the social security contributions for the operator). — The annual remuneration of a trainer performing the ground training is estimated at EUR 100 000. Assumptions regarding the OPC and the LPC — There are 1 LPC and 2 OPC per year per crew and 1 training session per year per crew. In total, there are 4 sessions per year (equivalent to 4 working days). For 3 years, it is considered that the baseline operator provides 48 hours of simulator per crew. — The simulators are located at the operator’s main base/headquarters. There are costs for pilots travelling to the main base/headquarters. 50 % of pilots are travelling to the main base/headquarters for simulator exercise. A coefficient of 0.5 is considered to capture this assumption. For the sake of the exercise, it is assumed that the headquarters is in Spain. The per diem rate taken is for Spain (currently EUR 280 per day37). — TRIs/TREs perform OPC/LPC every 6 months (2.1 days). In total, they are engaged for 4.2 days per year per pilot, because TREs need to do right hand seat qualification or other type of courses. — Ideally, when OPC and LPC are rostered, one TRI/TRE conducts OPC and LPC in 2.1 days every 6 months (4 days in total per pilot). In reality, the flight crew are coupled for the OPC and LPC. If the people are coupled, within the same day two pilots undergo the OPC and LPC. Therefore, a coefficient of 0.6 is considered. — The cost for simulator per session is EUR 1 200 per crew. Assumptions regarding the ground training: — Ground training is 1 day per year per pilot. — A trainer conducting ground training is involved for 1 day for 4 pilots. For 1 000 pilots, trainers are engaged for 250 working days. — The per diems for travel to the main base for the ground training is 3 days per pilot per year (including 2 days for travelling per year per pilot and 1 day for training). 50 % of all pilots are travelling to the main base. A coefficient of 0.5 is used to capture that assumption. — Assumptions regarding remedial training: — Remedial training for OPC/LPC is provided to 2.6 % of the pilots/FO who failed in OPC and LPC checks, e.g. 26 pilots. — Remedial training for line check is provided to 0.25 % of the pilots/FO who failed in line checks, e.g. 2.5 pilots per 1 000 pilots. Since it is negligible, it is not considered in the analysis. — After the remedial training, the pilots pass OPC, LPC. — It is assumed that the pilots in remedial training need to fly to the main base to do the OPC/LPC. 37 https://ec.europa.eu/europeaid/sites/devco/files/perdiem-rate-20150318.pdf TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 30 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) STEP 1 — Estimation of the costs in implementing recurrent legacy/prescriptive training and checking (baseline scenario) The starting point in analysing the impacts of EBT implementation is defining the current costs in implementing legacy/prescriptive recurrent training and checking for flight crew. The table below illustrates the costs for an operator running such training and checking. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 31 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Table 8: Baseline scenario: costs for an operator to run legacy (prescriptive) recurrent training and checking for flight crew type of costs type of coe Baseline: Legacy training (calculated for a medium/large costs ffici operator/year) ent rate working FTE per unit cost total unit total cost for days per year EUR per cost (per the operator year year pilot/instruc (per year) in tor year) in EUR EUR (FTE* unit cost) 1. Update of the recurrent 80 0 200 000 88 889 88 889 recurrent training programme 1a.Approval of recurrent fixed, 8 400 8 400 training programme recurrent (fees and charges) 2. Costs for recurrent 1 0.01 200 000 1 111 111 111 instructors/examiners for refresher training (1 day per instructor/examiner) 3. OPC and LPC 3.1 Cost for OPC & LPC recurrent 4 0.02 200 000 4 444 4 444 444 (4 sessions per year in 4 days per pilot/ year) 3.2 Per diems for recurrent 0.5 8 280 2 240 112 000 travelling and doing OPC and LPC (4 days per pilot/year) 3.3 Costs for TRI/TRE recurrent 0.6 4 0.02 200 000 4 444 2 666 667 per year to conduct OPC and LPC (1 instructor/examiner for 2 days every 6 months, in total 4 days per year per pilot) 3.4 Cost for the recurrent 2 800 1 200 3 360 000 simulators (EUR 1 200 per session/crew) 2 800 sessions for 1 000 crew per year 4. Line check/Line evaluation of competence 4.1 Cost for line check recurrent 600 3.33 200 000 666 667 (1 day line check per pilot; 600 line checks for all 1 000 pilots) 5. Ground training 5.1 Cost for a trainer for recurrent 250 1.39 100 000 138 889 138 889 1 day ground training (250 days for all 1 000 pilots) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 32 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) type of costs type of coe Baseline: Legacy training (calculated for a medium/large costs ffici operator/year) ent rate working FTE per unit cost total unit total cost for days per year EUR per cost (per the operator year year pilot/instruc (per year) in tor year) in EUR EUR (FTE* unit cost) 5.2 Cost for ground recurrent 1 0.01 200 000 1 111 1 111 111 training per pilot (alternative occupancy for 1 day training) 5.3 Allowance/per diem recurrent 0.5 3 280 840 420 000 for travel of crew to the 0 main base/headquarters for ground training (the trip is 2 days per year per pilot/FO + 1 day for the training). 6. Remedial training 6.1 Cost per crew to do recurrent 115 556 OPC & LPC (4 sessions per year plus days for travelling to the simulator - 4 days in addition (one day before the simulator, 1 day after it is finished); in total 8 days 6.2 Per diem for the recurrent 2 912 pilot to do OPC & LPC (allowances for 8 days per pilot for travelling, stay, perform checks, back) 6.3 Costs for TRI/TRE recurrent 69 333 per year to conuct OPC and LPC (in total 5 days per year per pilot) 6.4 Cost for simulators recurrent 87 360 (EUR 1 200 per session/pilot; 4 sessions per pilot/year) Total costs 13 403 339 Turnover of the 4 567 000 000 operator with 1 000 pilots % of costs for recurrent 0.29 % training as regards the operator's turnover TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 33 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) STEP 2 — Estimation of the costs (one-off and recurrent) for the preparation and implementation of EBT As a second step, the costs for the preparation and implementation of EBT are calculated. These costs are incurred considering the following assumptions: — All general assumptions regarding the operator, explained in Step 1, are valid for EBT. — The implementation of EBT requires in most of the cases the same type of recurrent costs as for the legacy/prescriptive training. Therefore, the recurrent costs from the traditional model (e.g. for OPC, LPC) are kept with the same amounts and same origin in the EBT model. — In addition, there are supplementary costs for the preparation, adoption and implementation of EBT. These estimated costs are analysed as one-off and additional recurrent costs due to the deployment of EBT as follows:  The operator is using an external consultant for 20 days to help develop the EBT competency framework and EBT programme and to train the training manager.  The consultant trains instructors to deliver EBT: each instructor is trained for 3 working days. 1-day training for the consultant costs EUR 1 300. All 100 instructors are trained for 30 days.  The instructors/examiners are engaged for 4 days in EBT training (3 days training and 1 working day competency assessment (one-off costs). These days are calculated as part of the EBT costs, because they refer to the alternative occupancy of the TRI/TREs (instead of providing instructions/examining, they are engaged in training).  The operator’s training manager is conducting EBT training for 20 days (one-off cost).  The operator’s training manager is developing an EBT programme for all flight crew for 100 days (one-off cost).  The operator is purchasing an IT assessment tool to support the implementation of EBT. The tool will be used for electronic reporting/statistical analysis for EBT training, for safety reporting programmes, monitoring of pilot performance. It costs EUR 100 000 (one-off cost).  Costs for maintaining licences for IT tool are EUR 10 000 per year. — All other recurrent costs and assumptions, identified for the legacy training are valid for EBT (costs for OPC, LPC, line check, ground training, and remedial training). The table below illustrates the costs for the preparation and implementation of EBT (one-off costs and recurrent costs). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 34 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Table 9: Estimated costs for an operator to provide EBT recurrent training and checking for flight crew Type of estimated costs EBT estimated costs (calculated for a medium/large operator/year) type of working FTE per unit cost total unit cost total cost for costs days per year EUR per (per pilot/ the operator year year instructor/ (per year) in examiner/year) EUR in EUR (FTE* unit cost) 1. Preparatory costs 1a.External assistance in one-off 100 000 setting up the EBT framework to develop the competency framework and develop training programme 1b.Training of EBT project one-off 20 0.11 200 000 22 222 team (manager) 1c.Development of EBT one-off 100 0.56 200 000 111 111 programme by training manager 1d.Update of the recurrent recurrent 80 0.44 200 000 88 888 training programme same as for legacy training 1e.Approval of recurrent recurrent 8 400 training programme (fees same as for and charges) legacy training 1f.Costs for consultants to one-off 3 1 300 3 900 390 000 train instructors to deliver EBT training and assessment (10 classes for 10 instructors — 3 days per instructor) 1g.Training of instructors for one-off 4 0.02 200 000 4 444 444 444 EBT (3 days per instructor) alternative occupancy and 1 day competency assessment per TRI/TRE 1j.Costs for recurrent 1 0.01 200 000 1 111 111 111 instructors/examiners for same as for refresher training for EBT (1 legacy day per instructor/examiner) training 2. Purchase of equipment (IT one-off 200 000 tool: electronic reporting/statistical analysis) for EBT training (for safety reporting programmes, monitoring of pilot performance) 2a. Costs for maintaining recurrent 10 000 licences for IT tool new for EBT 3. OPC and LPC / EBT modules TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 35 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Type of estimated costs EBT estimated costs (calculated for a medium/large operator/year) type of working FTE per unit cost total unit cost total cost for costs days per year EUR per (per pilot/ the operator year year instructor/ (per year) in examiner/year) EUR in EUR (FTE* unit cost) 3.1 Cost for OPC & LPC (4 recurrent 4 444 444 sessions per year in 4 days same as for per pilot/ year) legacy training 3.2 Per diems for travelling recurrent 112 000 and doing OPC and LPC (4 same as for days per pilot/year) legacy training 3.3 Costs for TRI/TRE per year recurrent 2 666 666 to conduct OPC and LPC (1 same as for instructor/examiner for 2 legacy days every 6 months, in total training 4 days per year per pilot) 3.4 Cost for the simulators recurrent 3 360 000 (EUR 1 200 per session/crew) same as for 2 800 sessions for 1 000 crew legacy per year training 4. Line check/Line evaluation of competence 4.1 Cost for line check (1 day recurrent 666 666 line check per pilot; 600 line same as for checks for all 1 000 pilots) legacy training 5. Ground training 5.1 Cost for a trainer for 1 recurrent 138 888 day ground training (250 same as for days for all 1 000 pilots) legacy training 5.2 Cost for ground training recurrent 1 111 111 per pilot (alternative same as for occupancy for 1 day training) legacy training 5.3 Allowance/per diem for recurrent 420 000 travel of crew to the main same as for base/headquarters for legacy ground training (the trip is 2 training days per year per pilot/FO + 1 day for the training). 6. Remedial training 6.1 Cost per crew to do OPC & recurrent 115 555 LPC (4 sessions per year plus same as for days for travelling to the legacy simulator - 4 days in addition training (one day before the simulator, 1 day after it is finished); in total 8 days TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 36 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Type of estimated costs EBT estimated costs (calculated for a medium/large operator/year) type of working FTE per unit cost total unit cost total cost for costs days per year EUR per (per pilot/ the operator year year instructor/ (per year) in examiner/year) EUR in EUR (FTE* unit cost) 6.2 Per diem for the pilot to recurrent 2 912 do OPC & LPC (allowances for same as for 8 days per pilot for travelling, legacy stay, perform checks, back) training 6.3 Costs for TRI/TRE per year recurrent 69 333 to conduct OPC and LPC (in same as for total 5 days per year per legacy pilot) training 6.4 Cost for simulators (EUR recurrent 87 360 1 200 per session/pilot; 4 same as for sessions per pilot/year) legacy training Total 14 581 216 Average turnover of the 4 500 000 000 operator with 1 000 pilots % of costs for recurrent 0.32 % training as regards the operator's turnover STEP 3 — Calculation of the difference between costs for EBT recurrent training and checking and legacy recurrent training and checking (delta of EBT costs) As already illustrated in Step 1 and Step 2, there are many types of EBT recurrent costs that would be the same as for the legacy training. Therefore, a delta (difference) between the EBT one-off and recurrent costs and legacy training recurrent costs is made to exemplify the real impact in terms of additional costs for EBT implementation. The table below shows the difference (the delta). Table 10: Difference between costs for an operator when providing EBT and when providing legacy recurrent training and checking type of costs EBT costs Legacy training Difference (EUR/year) costs (EUR/year) 1. Preparatory costs 1a.External assistance in setting up the 100 000 100 000 EBT framework to develop the competency framework and develop training programme 1b.Training of EBT project team 22 222 22 222 (manager) 1c.Development of EBT programme by 111 111 111 111 training manager TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 37 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) type of costs EBT costs Legacy training Difference (EUR/year) costs (EUR/year) 1d.Update of the recurrent training 88 889 88 889 0 programme 1e.Approval of recurrent training 8 400 8 400 0 programme (fees and charges) 1f.Costs for consultants to train 390 000 390 000 instructors to deliver EBT training and assessment (10 classes for 10 instructors, 3 days per instructor) 1g.Training of instructors for EBT (3 days 444 444 444 444 per instructor) — alternative occupancy and 1 day competency assessment per TRI/TRE 1j.Costs for instructors/examiners for 111 111 111 111 0 refresher training for EBT (1 day per instructor/examiner) 2. Purchase of equipment (IT tool: 100 000 100 000 electronic reporting/statistical analysis) for EBT training (for safety reporting programmes, monitoring of pilot performance) 2a. Costs for maintaining licences for IT 10 000 10 000 tool 3. OPC and LPC / EBT modules 0 3.1 Cost for OPC & LPC (4 sessions per 4 444 444 4 444 444 0 year in 4 days per pilot/year) 3.2 Per diems for travelling and doing 112 000 112 000 0 OPC and LPC (4 days per pilot/year) 3.3 Costs for TRI/TRE per year to conduct 2 666 667 2 666 667 0 OPC and LPC (1 instructor/examiner for 2 days every 6 months, in total 4 days per year per pilot) 3.4 Cost for the simulators (EUR 1 200 per 3 360 000 3 360 000 0 session/crew) 2 800 sessions for 1 000 crew per year 4. Line check/Line evaluation of 0 competence 4.1 Cost for line check (1 day line check 666 667 666 667 0 per pilot; 600 line checks for all 1 000 pilots) 5. Ground training 0 5.1 Cost for a trainer for 1 day ground 138 889 138 889 0 training (250 days for all 1 000 pilots) 5.2 Cost for ground training per pilot 1 111 111 1 111 111 0 (alternative occupancy for 1 day training) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 38 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) type of costs EBT costs Legacy training Difference (EUR/year) costs (EUR/year) 5.3 Allowance/per diem for travel of crew 420 000 420 000 0 to the main base/headquarters for ground training (the trip is 2 days per year per pilot/FO + 1 day for the training). 6. Remedial training 0 6.1 Cost per crew to do OPC & LPC (4 115 556 115 556 0 sessions per year plus days for travelling to the simulator - 4 days in addition (one day before the simulator, 1 day after it is finished); in total 8 days 6.2 Per diem for the pilot to do OPC & LPC 2 912 2 912 0 (allowances for 8 days per pilot for travelling, stay, perform checks, back) 6.3 Costs for TRI/TRE per year to conduct 69 333 69 333 0 OPC and LPC (in total 5 days per year per pilot) 6.4 Cost for simulators (EUR 1 200 per 87 360 87 360 0 session/pilot; 4 sessions per pilot/year) Total 14 581 116 13 403 338.67 1 177 778 Incl. total one-off costs only for EBT 1 167 778 Incl. total recurrent costs only for EBT 10 000 Turnover of the operator with 1 000 4 567 000000 pilots % of costs from the operator's turnover 0.32 % 0.29 % 0.03 % Based on the data above, the one-off (initial investment costs) will be around 1,167 million euros and the recurrent costs will be around EUR 10 000. In total, the additional costs for an operator to prepare and implement EBT are estimated at 1,177 million euros, which represents a 0.03 % increase in comparison to the operator’s annual turnover. That increase has a very low negative impact, according to Table 5: Definition for the economic scale. STEP 4 — Distribution of the one-off and recurrent costs for EBT as well as recurrent costs for legacy training The above-mentioned costs are distributed unevenly within 1-2 years’ time depending on the business model of the operator. For the sake of the case study, it is assumed that: — There are 2 years for EBT preparation. The first preparatory year, the operator runs legacy training and starts EBT one-off costs (training of a manager to be EBT manager and consultancy to develop EBT framework and training programme). The second preparatory year, legacy TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 39 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) training is still running, while the rest of the EBT one-off costs are executed (development of EBT programme, purchase of assessment IT tool, and training of instructors for initial course of EBT). — The year when the EBT starts is year 3, after all the one-off costs for EBT are incurred. Every consecutive year (from year 4+), EBT is running as envisaged with the recurrent costs, explained above. — The model is prepared for a 10-year period. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 40 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Table 11: Costs for EBT implementation in a 10-year period years 1 2 3 4 5 6 7 8 9 10 Short description Baseline: Preparatory Preparatory First year of EBT Second year Third year of Fourth year Fifth year Sixth year of Seventh Eighth year Legacy year year: implementation of EBT EBT (all EBT of EBT (all of EBT (all EBT (all EBT year of EBT of EBT (all training — discontinue implementati costs EBT costs EBT costs costs (all EBT EBT costs legacy training, on — incurred) incurred) incurred) incurred) costs incurred) discontinue incurred) legacy training 1 Total costs 13 403 3 13 525 561 14 448 894 13 413 339 13 413 339 13 413 339 13 413 339 13 413 339 13 413 339 13 413 339 13 413 339 39 One-off investment costs for EBT 2 Training of a EBT 22 222 0 0 0 0 0 0 0 0 0 training manager (20 days to develop competency framework) (one-off) 3 Consultancy to train 100 000 0 0 0 0 0 0 0 0 0 the training manager and develop EBT framework and training programme (one-off) 4 Training of instructors 834 444 0 0 0 0 0 0 0 0 to deliver EBT (costs for consultants and daily wages of the instructors) (one-off) 5 Purchase of IT tool 100 000 0 0 0 0 0 0 0 (one-off) 6 Develop EBT recurrent 111 111 training programme by the training manager (one-off) Recurrent costs for legacy training/EBT 7 Legacy training 13 403 339 13 403 339 0 0 0 0 0 0 0 0 (recurrent costs) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 41 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) years 1 2 3 4 5 6 7 8 9 10 8 Update of EBT 0 0 88 889 88 889 88 889 88 889 88 889 88 889 88 889 88 889 recurrent training programme by the training manager (recurrent, same cost as for the legacy training) 9 Costs for 111 111 111 111 111 111 111 111 111 111 111 111 111 111 111 111 instructors/examiners for refresher training for EBT (1 day per instructor/examiner) (recurrent, same cost as for the legacy training) 10 Approval of the 8 400 8 400 8 400 8 400 8 400 8 400 8 400 8 400 changes in the recurrent training programme by the CA (recurrent, same cost as for the legacy training) 11 EBT modules (former 0 0 10 583 111 10 583 111 10 583 111 10 583 11 10 583 11 10 583 111 10 583 11 10 583 11 OPC and LPC) 1 1 1 1 (recurrent, same cost as for the legacy training) 12 EBT line check 0 0 666 667 666 667 666 667 666 667 666 667 666 667 666 667 666 667 (recurrent, same cost as for the legacy training) 13 EBT ground training 0 0 1 670 000 1 670 000 1 670 000 1 670 000 1 670 000 1 670 000 1 670 000 1 670 000 (recurrent, same cost as for the legacy training) 14 EBT remedial training 0 0 275 161 275 161 275 161 275 161 275 161 275 161 275 161 275 161 (recurrent, same cost as for the legacy training) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 42 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) years 1 2 3 4 5 6 7 8 9 10 15 Costs for maintaining 0 0 10 000 10 000 10 000 10 000 10 000 10 000 10 000 10 000 licences for IT tool (recurrent, new cost for EBT) 16 delta EBT costs in 122 222 1 045 556 10 000 10 000 10 000 10 000 10 000 10 000 10 000 10 000 comparison to legacy training costs Line 2-line 6 correspond to years 2017 and 2018 and line 7-line 15 for the other years) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 43 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) STEP 5 — Quantification and monetarisation of the economic benefits in EBT, e.g. alleviations, envisaged in the regulatory proposal for operators who might be granted with these privileges upon a competent authority decision. The implementation of EBT is expected to bring economic benefits as follows: — Line check: Two years after EBT implementation, an operator may be allowed to extend the line check, i.e. a pilot's line check requirement is reduced from 1 per year to 1 every two years. The benefit is that the operator is saving the costs it pays annually for the line check of all flight crew. — Ground training: A pilot's safety equipment procedure (SEP) training requirement is reduced from 1 per year to 1 every two years. The benefit is saving the daily wage of the flight crew. In addition, less CRM training is expected due to the integration of non-technical competencies in the EBT programme (1 day per pilot/year to 1 day per pilot/3 years). — Saving due to the decrease in percentage of pilots who fail in OPC/LPC: Saving in daily wages of flight crew for the time that they do not fly. — Indirect saving (flexibility): A reduction in pilot workload is expected due to the flexibility to run simulator sessions outside the peak flying months. The benefit is assumed to be circa 1 % of the annual wage of a pilot saved, multiplied by the number of the pilots who would be available to fly instead of going to simulator. Some of these economic benefits are already known and granted to the ATQP operators. Currently, the ATQP and its alleviations bring a return on investment in a period of about seven years38. These benefits may be granted to the operators after at least 2 years of EBT implementation upon the decision of the competent authority. The latter needs to approve the type and the timing of the alleviations. In the case study, it is assumed that: — The operator will fully reap the economic benefits (as mentioned above) 2 years after EBT implementation has been approved by the competent authority. This expectation is based on the historical data on granting alleviations to operators running ATQP. — 2 years after EBT implementation, there are less operators’ flight crew failures in OPC/LPC (20 % decrease in remedial training, e.g. 2.08 % of pilots fail in comparison to the level before EBT implementation (2.6 % failure rate in OPC/LPC). — 3 years after EBT implementation, there are 40 % less operators’ flight crew failures in OPC/LPC (e.g. 1.56 % of pilots fail in comparison to the level before EBT implementation (2.6 % failure rate in passing OPC/LPC)). — 4 years after EBT implementation, there are 50 % less operators’ flight crew failures in OPC/LPC (e.g. 1.3 % of pilots fail in comparison to the level before EBT implementation (2.6 % failure rate in passing OPC/LPC)). That level is kept until the end of the analysed 10-year period. — All general assumptions regarding the operator are kept in the model. 38 The return of investment depends on the complexity of operations, the type of aircraft, the approval process, etc. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 44 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Regarding the case study, the economic benefits are quantified as follows: — Savings due to decrease in percentage of pilots failing in OPC/LPC The benefit is calculated based on the difference between the costs for the operator on the remedial training (EUR 275 160.89) minus the actual costs for the operator due to the decreased percentage of pilots who fail in OPC/LPC (the operator pays remedial training only for 2.08 % of pilots, that is EUR 220 128.71). The difference of the two amounts is generated as a saving for the operator. — Line check: the costs for the line check are reduced by half (EUR 666 666.67/2= 333 333.33) — Ground training: the costs for the ground training for all pilots (alternative occupancy for 1 day training per pilot) are reduced by half (EUR 1 111 111.11/2 = 555 555.56) — Indirect saving (flexibility): although EBT requires a bigger volume of FSTD training per year, this training may be done when the production of the airline is less (outside peak seasons, such as in summer). This flexibility allows a saving of an estimated of 1 % of the annual wage of a pilot, multiplied by the number of the pilots who would be available to fly instead of going to simulator, e.g. (EUR 200 000*1 %*100= EUR 200 000) Based on these assumptions and explanations, the economic benefits are monetarised in the table below. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 45 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) Table 12: Economic benefits of EBT implementation in a 10-year period years 1 2 3 4 5 6 7 8 9 10 short description Base Preparatory Preparatory First year of Second year of Start of all Continued Continued all benefits all benefits all benefits line: year year EBT EBT benefits with benefits with benefits with as in the as in the as in the Lega implementation implementation, less failures less failures less failures previous previous previous cy — discontinue discontinue in OPC/LPC in OPC/LPC in OPC/LPC year year year train legacy training. legacy training. (2.08 % of (1.56 % of (1.3 % of ing No economic No economic pilots fail) pilots fail) pilots fail) benefits. Still benefits. Still high failure high failure rate rate of pilots of pilots (2.6% as (2.6 % as in in legacy legacy training) training) 17 TOTAL benefits 0 0 0 0 1 143 921 1 198 953 1 226 469 1 226 469 1 226 469 1 226 469 18 Saving due to decrease in 0 0 0 0 55 032 110 064 137 580 137 580 137 580 137 580 % of pilots failing in OPC/LPC: Saving in daily wage of flight crew for the time that they do not fly. 19 Line check: pilot's line 0 0 0 0 333 333 333 333 333 333 333 333 333 333 333 333 check requirement is reduced from 1 per year to 1 per 2 years 20 Ground training: Safety 0 0 0 0 555 556 555 556 555 556 555 556 555 556 555 556 equipment procedure (SEP) training: A pilot's SEP training requirement is reduced from 1 per year to 1 per 2 years. 21 Indirect saving (flexibility): 0 0 0 0 200 000 200 000 200 000 200 000 200 000 200 000 A reduction in pilot workload due to flexibility to run SIM outside the peak flying months. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 46 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) STEP 6 — Comparison of the economic benefits and costs for EBT. Calculation of cost-benefit ratio and year of return of investments in EBT. Table 13: Cost-benefit analysis of EBT implementation in a 10-year period39 years 1 2 3 4 5 6 7 8 9 10 No short description Preparatory Preparatory First year of EBT Second year of All EBT costs. All EBT costs. All EBT costs. All EBT costs All EBT costs All EBT costs year year implementation EBT Start of all Continued Continued and all and all and all — discontinue implementation, benefits with benefits with benefits with benefits as in benefits as in benefits as in legacy training. discontinue less failures in less failures in less failures in the previous the previous the previous No economic legacy training. OPC/LPC OPC/LPC OPC/LPC year year year benefits. Still No economic (2.08 % of (1.56 % of (1.3 % of high failure rate benefits. Still high pilots fail) pilots fail) pilots fail) of pilots (2.6 % failure rate of as in legacy pilots (2.6 % as in training) legacy training) 16 EBT costs 122 222 1 045 556 10 000 10 000 10 000 10 000 10 000 10 000 10 000 10 000 17 EBT benefits 0 0 0 0 1 143 921 1 198 953 1 226 469 1 226 469 1 226 469 1 226 469 NPV delta EBT costs 122 222 966 675 8 890 8 548 8 219 7 903 7 599 7 307 7 026 6 756 NPV EBT benefits 0 0 0 0 940 220 947 550 932 016 896 169 861 701 828 559 Cumulative NPV EBT 122 222 1 088 897 1 097 787 1 106 335 1 114 554 1 122 458 1 130 057 1 137 364 1 144 389 1 151 145 costs Cumulative NPV EBT 0 0 0 0 940 220 1 887 770 2 819 786 3 715 955 4 577 656 5 406 215 benefits Profitability indicators NPV EBT benefits - NPV -122 222 -966 675 -8 890 -8 548 932 000 939 647 924 417 888 862 854 675 821 803 EBT costs Saving per pilot per year 0 0 0 0 0 0 Portion of the net 0 0 0 0 1 2 2 3 4 5 benefits as % of the annual turnover Benefit/cost ratio 932 940 924 889 855 822 (cumulative NPV EBT 39 The discount rate for costs and benefits is 4 % (http://ec.europa.eu/regional_policy/sources/docgener/studies/pdf/cba_guide.pdf) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 47 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) years 1 2 3 4 5 6 7 8 9 10 benefits/cumulative NPV EBT costs) Years for return of 3-4 years for return of investment (break- investment after the even point, year when implementation of EBT cumulative costs = cumulative benefits) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 48 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) The CBA for a medium/large operator concludes that the implementation of EBT in recurrent training and checking of flight crew is a cost-effective solution. It is expected that the cost will be 0.03 % of the operator’s annual turnover, with one-off costs representing 9 % of the current expenditure of the operator for recurrent training and checking. In addition, the implementation of EBT has the potential to generate significant economic benefits and to introduce an estimated saving of EUR 900 per pilot (EUR 900 000 saving per year for the operator). The profitability indicators show that the return of investment is generated 3 years after EBT implementation, considering that competent authorities grant full economic alleviations to the operator. Case study 2: Economic impacts for a small operator That case study is prepared for an operator with the following assumptions: General assumptions regarding the baseline scenario (legacy training operator): — Volume of fleet: 10 aircraft — Number of pilots (captains and FO): 100 — Number of instructors/examiners: 10; indicatively 10 % of pilot population — Number of line checks per year for all pilots: 60 (performed in 60 working days) — Number of simulator sessions: 280 OPC/LPC sessions per year for all pilots (50 crews, 4 sessions per crew — in total, 200 sessions per crew with a coefficient of 1.4 due to the inefficiency). — Development and update of the training programme under the legacy training: 10 working days. — For 3 years, it is considered that the baseline operator provides 48 hours of simulator per crew. — All other assumptions, made under case study 1 are valid and apply in this case as well. Assumptions regarding EBT implementation: — The operator is using an external consultant to develop the EBT competency framework, training programme and to train the training manager and instructors for EBT — The training manager receives EBT training for 5 days (one-off cost) — Development of an EBT programme by the training manager: 10 days (one-off cost) — The operator is using an external consultant to train instructors/examiners to deliver EBT: each trainee/instructor is trained for 3 working days. 1 day training costs EUR 500 instructor/day (one-off cost). — The operator engages the instructors/examiners for 4 days in EBT training: 3 working days for training and 1 working day for competency assessment (one-off cost). — Recurrent costs are the same as for the legacy training. — Operator needs 1 year to prepare for EBT implementation. — EBT benefits are reaped 2 years after the EBT implementation, but progressively: 30 % in the third year, 60 % in the fourth year, 100 % in the fifth year, and for the following years under the analysis, all benefits are reaped. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 49 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) — The failure rate in OPC/LPC is decreased progressively. During the first 2 years of the EBT implementation, the failure rate remains the same as for the legacy training (2.6 % of the pilot population). As regards the following years, in year 3 after the EBT implementation, the failure rate is 2.08 %; in year 4 after the EBT implementation, the failure rate is 1.56 %; and in year 5 and after it, it reaches its maximum decrease (1.3 % of pilots). The CBA for the small operator is performed following the same methodology as in case study 140. The CBA for a small operator concludes that there are benefits for small operators in implementing EBT in recurrent training and checking of flight crew. Despite that, a small operator may encounter the following difficulties in EBT implementation: — EBT requires collecting and analysing the operator’s own and/or the general fleet data, as well as operation-specific data. The existence of high-quality robust operational data is a powerful tool by which training priorities are adjusted. In particular, said data provides the operator with the opportunity to tailor the training to its own identified issues and risks by reducing or increasing the frequency of delivering certain topics. Data collection and analysis therefore results in improvement of the training programme. Data collection is necessary for a detailed analysis of existing threats and the identification of potential weaknesses in the operator’s operational safety — for instance, inadequate flight crew performance. The costs for such data collection and assessment might be an obstacle to a small operator implementing EBT. These costs are not quantified in the CBA model (due to lack of reliable data). — A small operator needs to make initial costs (one-off) to deploy EBT (indicative amount: EUR 80 000) which represent 0.11 % of its annual turnover or 3.7 % more of its expenditure for running legacy recurrent training and checking for its pilots. There costs mainly refer to the necessary external expertise to train the operator’s staff in EBT, to train instructors, to deploy an IT tool that will support EBT, etc. — A small operator may need to make one-off costs to increase the number of simulators from 3 to 4 simulator sessions per year. This may cause additional increase in the total costs for EBT implementation. — Depending on the cost increase, these operators will decide whether to implement EBT. Nevertheless, Option 1 would not have a negative impact, because this option will be implemented on a voluntary basis. Furthermore, similarly for a medium operator, EBT has the potential to generate significant economic benefits and to introduce an estimated saving of EUR 1 000 per pilot, which represents around EUR 80 000-100 000 saving per year for the operator. The profitability indicators show that the return of investment is generated 5 years after the EBT implementation, considering that competent authorities grant economic alleviations to the operator. 3.6.4.2.2 Economic impact for the competent authorities The requirement for inspectors to be competent in the approval of and oversight over EBT programmes would result in increased costs for the competent authorities for staff training in the short term. According to the estimations of the competent authorities, the following would be the impact of EBT deployment for an operator: 40 For further details, please contact [email protected] TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 50 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) — The first 2 years after the EBT implementation, there would be certain workload for the competent authority: an additional 150-160 hours for initial training of the flight inspectors on EBT; approval of the development of the competency framework and approval of the training programme, evaluation of safety cases; an additional 40 hours for oversight of the training of the TRIs/TREs when an operator trains them. — Afterwards, the workload is expected to decrease to a level of 50-70 hours per operator for approval of the training programmes and regular oversight, because the scope of the work would be limited to regular approval of the training programmes and regular oversight. In addition, the workload and the relative costs for the competent authority is expected to decrease with the time, as there might be more AOC holders implementing EBT. As regards the oversight, the workload of the competent authority is not expected to increase, because the EBT implementation supports performance- and risk based oversight. Therefore, the overall impact on the competent authority is considered very low negative in the first years and neutral in the consecutive years. 3.6.4.2.3 Overall economic impact with Option 1 Overall, the economic impact for Option 1 is assessed low positive and is scored with +2. 3.6.4.3 Option 2 — Mandatory EBT for recurrent training and checking The assessment of the economic impacts for the stakeholders for this option is based on the analysis performed in Option 1. In fact, all costs and benefits are relevant for medium/large operators and competent authorities. Option 2, however, has some drawbacks in terms of proportionality issues and most predominantly on small operators. In this option, all airlines would need to invest in the development of EBT programmes. Despite the potential benefits identified in terms of safety and economy, there would be a negative impact on airlines that did not have the resources (in short-term plan) or expertise to develop EBT after the adoption of the rules. This impact would be most significant on smaller operators. It is expected that this option could undermine the commercial viability of many small airlines and air taxi operators. Overall, this option may potentially limit the accessibility to the market to some AOC holders and as a result, it is considered that it may generate a low negative impact. Therefore, Option 2 is considered to have a low negative economic impact (score -2). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 51 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) 3.6.4.4 Conclusion on the economic impacts per option Table 14: Economic impacts per option Criteria Option 0 Option 1 Option 2 No policy Voluntary EBT Mandatory EBT change Economic No impact Low positive impact Low negative impact impact Medium/large operator (1 000 pilots): Although the CBA shows that the EBT is One-off costs: 0.03 % of its turnover or beneficial for small operators, it is expected 9% more than the current operator that they may not be ready to implement it expenditure for recurrent training immediately after rules are adopted. In the Recurrent costs: 0.01 % increase in the short term, the proposal may affect current operator expenditure for negatively their business and undermine recurrent training their commercial viability. Net benefit: EUR 900 per pilot/year Return of investment >3 years after the EBT implementation Small operators (100 pilots) One-off costs: 0.11 % of its turnover or 3.7 % more than the current operator expenditure for recurrent training Recurrent costs: no Net benefit: EUR 1 000 per pilot/year Return of investment >4 years after EBT implementation 0 +2 -2 3.6.5. General Aviation and proportionality issues Not applicable. 3.7. Conclusion 3.7.1. Comparison of options The table below summarises the impacts of all options. Table 15: Assessment of all options Criteria Option 0 Option 1 Option 2 No policy change Voluntary EBT Mandatory EBT Safety 0 +2 +3 Social 0 +2 +3 Economic 0 +2 -2 TOTAL 0 +6 +4 The final results of the RIA demonstrate that Option 1 ‘Voluntary EBT’ is the preferred option for regulating the EBT implementation in recurrent training and checking of flight crew. It contributes to TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 52 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 3. Impact assessment (IA) maintaining a high level of aviation safety while providing a cost-efficient and socially acceptable framework. Question to stakeholders Stakeholders are also invited to comment on the RIA and to provide any other quantitative information they may find necessary to bring to the attention of EASA. As a result, the relevant parts of the RIA might be adjusted on a case-by-case basis. 3.7.2. Sensitivity analysis The current section analyses the effect of other assumptions (presented in the economic impacts section) on the results from the CBA. For instance, EASA assumes that there is a general practice of having 4 simulator sessions per year for the medium/large operator case study. For the medium/large operators that have 3 sessions per year before implementing EBT, the return of investment will be after 4 years due to the simulator cost increase (EBT requires 4 simulator sessions). Depending on the cost increase, these operators will decide whether to implement EBT. 3.8. Monitoring and evaluation Note: this section will be completed at the Opinion stage after the review of the comments provided to this NPA. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 53 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 4. Proposed actions to support implementation 4. Proposed actions to support implementation — Implementation and standardisation efforts regarding the proposed changes in Part-ARO, Part-ORO, Part-FCL and Part-ARA — A dedicated workshop with stakeholders at the EASA premises after the consultation of the NPA — Support to the stakeholders with the development of an EASA EBT manual — Support to the operators wishing to implement EBT and their competent authorities — one-day training (SPT.012) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 54 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 5. References 5. References 5.1. Affected regulations — Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311, 25.11.2011, p. 1) — Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) 5.2. Affected decisions — Decision N° 2012/015/Directorate R of the Executive Director of the Agency of 24th October 2012 on Acceptable Means of Compliance and Guidance Material to Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council ‘Guidance Material to Annex I – Definitions’ — Decision 2014/025/R of the Executive Director of the Agency of 28 July 2014 adopting Acceptable Means of Compliance and Guidance Material to Part-ARO of Commission Regulation (EU) No 965/2012 and repealing Decision 2014/014/R of the Executive Director of the Agency of 24 April 2014 ‘AMC and GM to Part-ARO — Issue 3’ — Decision 2014/017/R of the Executive Director of the Agency of 24 April 2014 adopting Acceptable Means of Compliance and Guidance Material to Part-ORO of Commission Regulation (EU) No 965/2012 and repealing Decision 2012/017/R of the Executive Director of the Agency of 24 October 2012 ‘AMC and GM to Part-ORO — Issue 2’ — Decision N° 2012/006/Directorate R of the Executive Director of the Agency of 19th April 2012 on Acceptable Means of Compliance and Guidance Material to Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council ‘Acceptable Means of Compliance and Guidance Material to Part-ARA’ — Decision N° 2011/016/R of the Executive Director of the European Aviation Safety Agency of 15 December 2011 on Acceptable Means of Compliance and Guidance Material to Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council ‘Acceptable Means of Compliance and Guidance Material to Part-FCL’ 5.3. Other reference documents — Decision No 2015/027/R of the Executive Director of the European Aviation Safety Agency of 16 December 2015 on guidance material to Part-ORO of Regulation (EU) No 965/2012 on the TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 55 of 56 An agency of the European Union European Aviation Safety Agency NPA 2018-07(A) 5. References implementation of evidence-based training (EBT) within the European regulatory framework (Mixed EBT) — ICAO Annex 1 to the Convention on International Civil Aviation ‘Personnel Licensing’, 11th Edition, July 2011 — ICAO Annex 6 to the Convention on International Civil Aviation ‘Operation of Aircraft’, 10th Edition, July 2016 — ICAO Doc 9868 ‘Procedures for air navigation services Training’ Second Edition, 2016 — ICAO Doc 9995 AN/497 ‘Manual of Evidence-based Training’ First edition - 2013 — ICAO Doc 10011 AN/506 ‘Manual on aeroplane upset prevention and recovery training’ First edition – 2014 — ICAO Doc 9841 AN/456 ‘Manual on the Approval of Training Organizations’ Second edition – 2012 — ICAO Doc 9379 AN/916 ‘Manual of Procedures for Establishment and Management of a State’s Personnel Licensing System’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 56 of 56 An agency of the European Union European Aviation Safety Agency Notice of Proposed Amendment 2018-07(B) Update of ORO.FC — evidence-based training subtask RMT.0599 EXECUTIVE SUMMARY The European Aviation Safety Agency (EASA) identified the need to ensure that aviation personnel have the right competencies and training methods to cope with new challenges. This is one of the most significant systemic issues in the European Plan for Aviation Safety (EPAS) 2018-2022. The objective of this notice of proposed amendment (NPA) is to update the flight crew training requirements to improve pilot competencies. At the same time, it provides additional efficiency in the field of flight crew training and achieves a smooth transition to competency-based training. The International Civil Aviation Organization (ICAO), in a joint effort with the International Air Transport Association (IATA), the International Federation of Air Line Pilots’ Associations (IFALPA) and other industry partners, developed a new paradigm for competency-based recurrent assessment and training of flight crew, which is based on evidence (evidence- based training (EBT)). The EBT project is a global safety initiative whose objective is to determine the relevance of existing pilot training according to aircraft generation. The EBT methodology identifies areas for improvement and allows the re- prioritisation of training topics. EBT is intended to enhance the confidence and capability of flight crews to operate the aircraft in all flight regimes and to be able to recognise and manage unexpected situations. This NPA is a second step in the European rulemaking actions that help competent authorities, commercial air transport (CAT) operators and approved training organisations (ATOs) to implement EBT. The first step was completed in 2015 with the publication of ED Decision 2015/027/R that provided guidance material to allow the implementation of 'mixed EBT’ which maintains the current operator proficiency check (OPC) and licence proficiency check (LPC). This NPA proposes further changes to the Air OPS and Air Crew Regulations to allow the full implementation of EBT, replacing OPC and LPC. This will allow a single philosophy of recurrent training within the airline. Further work is foreseen in rulemaking task (RMT).0599 to allow expansion of EBT to the operator conversion course and initial type rating, while expanding the EBT concept to other types of aircraft (e.g. helicopters and business jets). The impact assessment (IA) shows that the implementation of EBT on a voluntary basis by the operator is the preferred option in regulating recurrent training and checking of flight crew. It provides an opportunity for the air operator certificate (AOC) holders to implement EBT for recurrent training and checking of the flight crew. The IA illustrates that the proposed rules contribute to significant improvement in safety by strengthening the competencies of flight crews while providing a cost-efficient and socially acceptable framework. NPA 2018-07 is divided in two parts. The present sub-NPA(B) includes the proposed draft rules (implementing rules, acceptable means of compliance and guidance material. Sub-NPA(A) includes: — the presentation of the issue under discussion; — the impact assessment; and — the proposed actions to support implementation. Action area: Human factors and competence of personnel Affected rules: Definitions, Part-ARO and Part-ORO of the Air OPS Regulation, Part-FCL and Part-ARA of the Aircrew Regulation (and the associated AMC & GM) Affected stakeholders: Member States, pilots, instructors, examiners, ATOs and operators Driver: Safety Rulemaking group: Yes Impact assessment: Full Rulemaking Procedure: Standard 05.02.2016 27.07.2018 2019/Q3 2020/Q3 2020/Q3 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) Table of contents Table of contents 1. About this NPA ..................................................................................................................................... 3 1.1. How this NPA was developed ...................................................................................................................3 1.2. How to comment on this NPA...................................................................................................................4 1.3. The next steps ...........................................................................................................................................4 2. Proposed amendments and rationale in detail ...................................................................................... 5 2.1. Draft regulation (draft EASA opinion) .......................................................................................................5 2.2. Draft regulation, AMC & GM (draft EASA opinion and draft EASA decision) and rationale in detail .....14 TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 2 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 1. About this NPA 1. About this NPA 1.1. How this NPA was developed EASA developed this NPA in line with Regulation (EC) No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is included in the European Plan for Aviation Safety (EPAS) 2018-2022 under rulemaking task (RMT).0599. The text of this NPA has been developed by EASA based on the input of Rulemaking Group (RMG) RMT.0599. This group is divided in the: (a) Main Group3, which ensures consistency across the different tasks of RMT.0599. It also develops an aviation blended learning environment (ABLE) concept and deals with other updates of ORO.FC including interoperability solutions; (b) Evidence-based training (EBT) subgroup4, that is responsible for developing the EBT concept; and (c) Helicopter subgroup5 that is developing and updating the helicopter training requirements including EBT. This NPA is primarily based on the inputs provided by the EBT subgroup. Due to the novelty of the EBT concept, EASA also consulted the Main group RMT.0599 on a regular basis, organised a workshop6 with the participation of industry representatives in February 2017 and performed 4 rounds of focus consultation with: (1) the Netherlands Aerospace Centre (NLR)7 with regard to instructor concordance and grading; (2) the Spanish competent authority (AESA)8 and Iberia group9 for the implementation of the EBT programme; (3) the Italian competent authority (ENAC)10 and Alitalia11 with regard to equivalency of malfunctions; and (4) CAA Denmark (Trafik)12 and Thomas Cook Scandinavia13 on the oversight and follow-up of the EBT programme. 1 Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC) No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal- content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216). 2 EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management- board/decisions/easa-mb-decision-18-2015-rulemaking-procedure). 3 Chaired by Yann Renier (IATA) and Phill Adrian (AIA). Members: Enrique Monzón (AESA España), Rogier Leeflang (IACA), Ståle Rosland (CAA Norway), David Lord (GAMMA). Project management Francisco Arenas Alvariño EASA. 4 Chaired by Phil Cullen (UK CAA). Secretariat Ascanio Russo EASA. 5 Chaired by Tim Rolfe (Heli-offshore). 6 st 1 Workshop on the Implementation of the Evidence-based Training 7 Focal point: Frederik Mohrmann. 8 Focal point: Carlos Artiles and Enrique Monzón. 9 Focal point: Captain Ignacio Gallego Alemany and Jaime Salva Munar. 10 Focal point Mario Tortorici and Sandro Apolloni. 11 Focal point: Massimo Giavalisco and Fabio Polloni. 12 Focal point Lise-Lotte Olsen Deigaard 13 Focal point: Henrik Lyngse. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 3 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 1. About this NPA The text of this NPA is hereby submitted to all interested parties14 for consultation. 1.2. How to comment on this NPA Please submit your comments using the automated Comment-Response Tool (CRT) available at http://hub.easa.europa.eu/crt/15. The deadline for submission of comments is 31 October 2018. 1.3. The next steps Following the closing of the public commenting period, EASA will review all comments. Based on the comments received, EASA will develop an opinion containing the proposed amendments to Regulation (EU) No 965/201216 (hereinafter referred to as the ‘Air OPS Regulation’) and to Regulation (EU) No 1178/201117 (hereinafter referred to as the ‘Aircrew Regulation’). The opinion will be submitted to the European Commission, which will use it as a technical basis in order to prepare an EU regulation. Following the adoption of the regulation, EASA will issue a decision containing the related acceptable means of compliance (AMC) and guidance material (GM). The comments received and the EASA responses thereto will be reflected in a comment-response document (CRD). The CRD will be annexed to the opinion. The following future efforts in relation to EBT are foreseen: — Operator conversion course (OCC) and type rating training for CAT. This activity will ensure a single philosophy of training in the operator. An NPA pertaining to this activity is scheduled to be published in the course of 2021. — EBT for helicopters and non-commercial complex motor-powered aircraft (NCC). This activity will ensure a single philosophy of training across the industry. This may also allow training data exchange across the industry. An NPA pertaining to this activity is scheduled to be published in the course of 2021. 14 In accordance with Article 52 of Regulation (EC) No 216/2008 and Articles 6(3) and 7) of the Rulemaking Procedure. 15 In case of technical problems, please contact the CRT webmaster ([email protected]). 16 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) (http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32012R0965&rid=1). 17 Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311, 25.11.2011, p. 1) (https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1528301490110&uri=CELEX:32011R1178). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 4 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 2. Proposed amendments and rationale in detail The text of the amendment is arranged to show deleted text, new or amended text as shown below: — deleted text is struck through; — new or amended text is highlighted in grey; — an ellipsis ‘[…]’ indicates that the rest of the text is unchanged. Due to the volume of the explanatory notes for the proposed rules and the novelty of the EBT concept, the structure of the NPA is as follows: — Section 2.1 provides the set of implementing rules (IRs) only. — Section 2.2 provides the IRs, the associated AMC and GM as well as the rationale behind the proposed change. To differentiate them form the proposed rules, the font colour used for the explanatory notes is blue. 2.1. Draft regulation (draft EASA opinion) Annex I (Definitions) to Regulation (EU) No 965/2012 Definitions for terms used in Annexes II to VIII For the purpose of this Regulation, the following definitions shall apply: […] (23a) ‘competency’ means a dimension of human performance that is used to reliably predict successful performance on the job. A competency is manifested and observed through behaviours that mobilise the relevant knowledge, skills and attitudes to carry out activities or tasks under specified conditions; (23b) ‘competency-based training’ means assessment and training programmes that are characterised by a performance orientation, emphasis on standards of performance and their measurement and the development of training to the specified performance standards. (23c) ‘competency framework’ means a complete set of identified competencies, used in the operator’s EBT programme to develop, train and assess competencies utilising scenarios that are relevant to operations. The chosen competency framework should be wide enough to prepare flight crews for both known and unforeseen threats and errors. (42a) ‘EBT module’ means a combination of sessions in a qualified flight simulation training device as part of the 3-year period of recurrent assessment and training. (47a) ‘enrolment’ means the administrative act of being approved to participate in the EBT recurrent training programmes by the operator. (47b) ‘enrolled flight crew member’ means crew member participating in the EBT recurrent training programme. (47c) ‘equivalency of approaches’ (approach clustering) means all the approaches that place an additional demand on a proficient crew regardless whether they are used or not in the EBT modules. (47d) ‘equivalency of malfunctions’ (malfunction clustering) means all the malfunctions that put a significant demand on a proficient crew regardless whether they are used or not in the EBT modules. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 5 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (47e) ‘evaluation phase (EVAL)’ means one of the phases of an EBT module. The evaluation phase is a line- orientated flight scenario, representative of the operator’s environment during which there are one or more occurrences to evaluate key elements of the defined competency framework. The root cause rather than the symptoms in any deficiency should be identified, in order to determine training needs. (47f) ‘evidence-based training (EBT)’ means assessment and training based on operational data that is characterised by developing and assessing the overall capability of a trainee across a range of a competency framework rather than by measuring the performance in individual events or manoeuvres. (69a) ‘in-seat instruction (ISI)’ means part of the scenario-based training phase. ISI contains predetermined scripted scenarios within the scenario-based training phase where the instructors can: (a) provide confidentially simple instructions to one pilot; or (b) perform predetermined exercises acting, in a pilot seat, as pilot flying (PF) or pilot monitoring (PM) for the purposes of demonstration and of intervention by the other pilot. (76a) ‘manoeuvres training phase (MT)’ means one of the phases of an EBT module. During this phase, according to aircraft generation, crews have time to practise and improve performance in largely psychomotor skill-based exercises by achieving a prescribed flight path or performing a prescribed event to a prescribed outcome. These exercises or events should place a significant demand on a proficient flight crew. Flight path control may be accomplished by a variety of means including manual aircraft control and the use of auto flight systems. (98a) ‘proficient’ means demonstration of the necessary skills, knowledge and attitudes required to perform any defined tasks to the prescribed standard. (104a) ‘scenario-based training phase (SBT)’ means one of the phases of an EBT module. This phase is designed to focus on the development of competencies, whilst training to mitigate the most critical risks identified for the aircraft generation. It should include the management of specific operator’s threats and errors in a real-time line-orientated environment. Annex II (Part-ARO) to Regulation (EU) No 965/2012 ARO.OPS.226 Approval and oversight of evidence-based training programmes (a) Where a competent authority grants an approval for EBT programmes, inspectors must receive qualification and training in EBT principles, application, approval processes and continuing oversight. (b) The competent authority shall assess and oversee the EBT programme, together with the processes that support the implementation of the EBT programme. (c) Before approving an EBT programme, the competent authority shall: (1) ensure the resolution of significant findings in the areas that will support the application of the EBT programme; (2) assess the capability of the operator to support the implementation of the EBT programme. The following elements shall be considered as a minimum: (i) the maturity and capability of the operator’s management system, and this programme’s suitability; (ii) the operator’s ability to maintain reliable and accurate flight crew training records; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 6 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (iii) the suitability of the operator’s grading and assessment scheme; (iv) the experience of the relevant personnel, fundamentally of the flight crew instructors, in the use of the processes and procedures that support the implementation of the EBT programme; and (v) the operator’s implementation plan and a safety risk assessment supporting the EBT programme in order to demonstrate how an equivalent level of safety to that of the current training programme can be achieved; (d) The competent authority shall amend or revoke the approved EBT programme if continuing compliance is not ensured. Annex III (Part-ORO) to Regulation (EU) No 965/2012 ORO.FC.145 Provision of training (a) All the training required in this Subpart shall be conducted: (1) in accordance with the training programmes and syllabi established by the operator in the operations manual; (2) by appropriately qualified personnel. In the case of flight and flight simulation training and checking, the personnel providing the training and conducting the checks shall be qualified in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011; (3) in addition to the above, for an approved EBT programme: (i) personnel providing assessment and training shall hold an Annex I (Part-FCL) instructor or examiner certificate; and (ii) have completed the operator’s EBT instructor standardisation. Successful completion of the operator’s EBT standardisation will qualify the instructor to perform practical assessment in competencies. ORO.FC.231 Evidence-based training (a) EBT PROGRAMME (1) The operator may substitute the requirements of ORO.FC.230 by implementing an EBT programme approved by the competent authority. The operator shall demonstrate its capability to support the implementation and perform a safety risk assessment demonstrating how an equivalent level of safety is achieved. (2) Features of the operator’s approved EBT programme The operator’s approved EBT programme shall: (i) assess and develop the competencies required by flight crew members for safe, effective and efficient operations of aircraft; (ii) ensure flight crew members are exposed to assessment and training topics derived from a large-scale analysis of operational data, distributed across a 3-year period at a defined frequency relevant to the type or variant of aircraft on which they operate; (iii) consist of modules conducted in the following sequence: TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 7 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (A) evaluation phase, comprising a line-orientated flight scenario (or scenarios) to assess competencies and identify individual training needs; (B) manoeuvres training phase, comprising training to proficiency in certain defined manoeuvres; and (C) scenario-based training phase, a comprising line-orientated flight scenario (s) and in- seat instruction to develop competencies and address individual training needs; and (iv) be delivered by instructors trained and qualified to ensure the effectiveness of learning. (3) The operator shall ensure that each flight crew member: (i) is enrolled in the EBT programme; (ii) completes a minimum of 2 modules within the validity period of 12 months, separated by a period of not less than 3 months. The module is completed when: (A) the content of the approved EBT programme is completed for that module; and (B) an acceptable level of performance in all observed competencies has been demonstrated; and (C) will not continue line operations if during a module the performance observed was below the minimum acceptable level. The flight crew member continues line operations when a module is completed. (4) The operator shall establish an instructor concordance assurance programme. (iii) Relevant metrics must be used to support this programme. (iv) All instructors must be subject to this programme. (v) Sufficient instructor concordance must be demonstrated. (5) The operator shall include contingency procedures for unforeseen circumstances that may affect the delivery of the modules. It may include a different separation period between modules. (b) COMPETENCY FRAMEWORKS The operator shall use a competency framework for all aspects of assessment and training within an approved EBT programme. The competency framework shall: (1) include observable behaviours required for safe, effective and efficient operations; and (2) be comprehensive, accurate, and usable. (c) TRAINING SYSTEM PERFORMANCE (1) The EBT system performance shall be measured and evaluated through a feedback system in order to: (i) validate and refine the operator’s approved EBT programme; and (ii) ascertain that the operator’s approved EBT programme develops pilot competencies. (2) The feedback system shall be included in the operator’s management system. (d) GRADING SYSTEM TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 8 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (1) The operator shall use a grading system to assess flight crew, which ensures: (i) sufficient level of detail to enable accurate and useful measurements of individual performance; (ii) a performance scale for each competency, with a point on the scale which determines the minimum acceptable level to be achieved for the conduct of line operations; and (iii) data integrity. (2) The operator shall verify in regular intervals the accuracy of the grading system against a criterion-referenced system. (e) SUITABLE TRAINING DEVICES AND VOLUME TO COMPLETE THE OPERATOR’S APPROVED EBT PROGRAMME (1) Each EBT module shall be conducted in an FSTD with a qualification level adequate to complete proficiency check/training. (2) The operator shall provide sufficient volume of hours in a suitable training device for the pilot to complete the operator’s approved EBT programme. (f) EQUIVALENCY OF MALFUNCTIONS (1) Each flight crew member shall receive assessment and training in the management of aircraft system malfunctions. (2) Aircraft system malfunctions that place a significant demand on a proficient crew shall be organised by reference to the following characteristics: (i) immediacy; (ii) complexity; (iii) degradation of aircraft control; (iv) loss of instrumentation; and (v) management of consequences. (3) Crew shall be exposed to at least one malfunction for each characteristic at the frequency determined by the table of assessment and training topics. (4) Demonstrated proficiency in the management of one malfunction is considered equivalent to demonstrated proficiency in the management of other malfunctions with the same characteristics. (g) EQUIVALENCY OF APPROACHES RELEVANT TO OPERATIONS The operator shall ensure that flight crew members receive regular training in the conduct of approach types and approach methods relevant to operations that: (1) place an additional demand on a proficient crew. (2) require specific approval. (h) LINE EVALUATION OF COMPETENCE (1) Each enrolled flight crew member shall periodically undertake a line evaluation of competence in an aircraft in flight to demonstrate the safe, effective and efficient conduct of normal operations TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 9 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail specified in the operations manual. (2) The validity period of a line evaluation of competence shall be 12 months. The validity period shall be counted from the end of the month when the line evaluation of competence was undertaken. When the line evaluation of competence is undertaken within the last 6 months of the validity period, the new validity period shall be counted from the original expiry date. (3) The operator approved for EBT may, with the approval of the competent authority, extend the validity of the line evaluation of competence to: (i) 2 years; or (ii) 3 years, subject to a feedback system for the monitoring of line operations. (4) Evaluation of competencies during line operations shall be conducted by a suitably qualified commander nominated by the operator and trained in EBT concepts and the assessment of competencies. (5) For successful completion, each flight crew member shall demonstrate each competency at or above the minimum acceptable level of performance. (i) GROUND TRAINING (1) Each flight crew member shall undergo ground training and training on the location and use of all emergency and safety equipment carried on the aircraft at least every 12 calendar months. (2) The operator may, with the approval of the competent authority, extend the period of training on the location and use of all emergency and safety equipment carried on the aircraft to 24 months. Appendix II to Part-ORO of Regulation (EU) No 965/2012 APPENDIX II — EBT PROGRAMME The EBT programme shall ensure that flight crew members are exposed to assessment and training topics relevant to the type or variant of aircraft on which they operate. Aircraft types not included shall not apply EBT. Annex I (Part-FCL) to Regulation (EU) No 1178/2011 FCL.625 IR — Validity, revalidation and renewal (a) […] (b) […] (c) Renewal. If an IR has expired, in order to renew their privileges applicants shall: (1) go through refresher training at an ATO to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9 to this Part; and (2) complete a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part, in the relevant aircraft category. (d) […] TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 10 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail FCL.625.A IR(A) — Revalidation (a) Revalidation. Applicants for the revalidation of an IR(A): (1) when combined with the revalidation of a class or type rating, shall pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part; […] FCL.740 — Validity and renewal of class and type ratings (a) […] (b) Renewal. If a class or type rating has expired, the applicant shall: (1) take refresher training at an ATO, or an AOC approved for such refresher, when necessary to reach the level of proficiency necessary to safely operate the relevant class or type of aircraft; and (2) pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part. […] FCL.740.A — Revalidation of class and type ratings — aeroplanes (a) Revalidation of multi-engine class ratings and type ratings. For revalidation of multi-engine class ratings and type ratings, the applicant shall: (1) pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part in the relevant class or type of aeroplane or an FSTD representing that class or type, within the 3 months immediately preceding the expiry date of the rating; […] FCL.905.TRI TRI — Privileges and conditions (a) The privileges of a TRI are to instruct for: (a) (1) the revalidation and renewal of an EIR or an IR, provided the TRI holds a valid IR; […] (f) (6) in the case of the TRI for powered-lift aircraft: (1) (i) the issue, revalidation and renewal of powered-lift type ratings; (2) (ii) MCC training. (b) After successful completion of the operator’s EBT instructor standardisation in accordance with Part ORO, the TRI has additionally the privilege to conduct practical assessment in competencies. FCL.905.SFI SFI — Privileges and conditions (a) The privileges of an SFI are to carry out synthetic flight instruction, within the relevant aircraft category, for: (a) (1) the issue, revalidation and renewal of an IR, provided that he/she holds or has held an IR in the relevant aircraft category and has completed an IRI training course; and TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 11 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (b) (2) in the case of SFI for single-pilot aeroplanes: (1) (i) the issue, revalidation and renewal of type ratings for single-pilot high performance complex aeroplanes, when the applicant seeks privileges to operate in single-pilot operations. […] (d) (4) in the case of SFI for helicopters: (1) (i) the issue, revalidation and renewal of helicopter type ratings; (2) (ii) MCC training, when the SFI has privileges to instruct for multi-pilot helicopters. (b) After successful completion of the operator’s EBT instructor standardisation in accordance with Part ORO, the SFI has additionally the privilege to conduct practical assessment in competencies. Appendix 10 to Annex I (Part-FCL) to Regulation (EU) No 1178/2011 Appendix 10 — Proficiency check type ratings, and proficiency check for IRs when combined with type rating — Practical assessment in competencies A — General 1. The practical assessment in competencies within an approved EBT programme is equivalent to a proficiency check. 2. Appendix 10 only applies to: (a) an operator with an approved EBT programme that has: (1) an experience of at least 2 years conducting an EBT programme which may include mixed EBT; and (2) a nominated person for crew training (or the deputy(ies)) who is a current examiner in each of the type ratings for which Appendix 10 is applicable; or (b) an ATO on behalf of the operator that complies with paragraph (2)(a) above, under ORO.GEN.205 ‘Contracted activities’. 3. The nominated person for crew training must verify that the applicant complies with all the qualification, training and experience requirements in this Part for the revalidation of the rating for which the proficiency check is taken. 4. Applicants using Appendix 10 shall: (a) be enrolled flight crew members in the operator’s approved EBT programme; and (b) within the period of validity, complete the operator’s approved EBT programme. 5. The revalidation or renewal in accordance with Appendix 10 shall comprise: (a) continuous practical assessment in competencies within an approved EBT programme; (b) demonstration of an acceptable level of performance in all competencies; and (c) the administrative action of licence revalidation. (1) The nominated person for crew training (or the deputy(ies)) shall endorse the applicant’s licence or certificate with the new expiry date of the rating, if specifically authorised for TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 12 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail that purpose by the competent authority responsible for the applicant’s licence. Delegation of the nominated person’s for crew training (or the deputy(ies)) signature in order for the applicant’s licence to be signed, may be possible only if the operator has an approved procedure for such case. (2) The nominated person for crew training (or the deputy(ies)) shall ensure that the requirements in FCL.1030 ‘Conduct of skill tests, proficiency checks and assessments of competence’ are met. B — CONDUCT OF PRACTICAL ASSESSMENT IN COMPETENCIES 6. The practical assessment in competencies must be conducted in accordance with the operator’s approved EBT programme. 7. Applicants who fail to demonstrate an acceptable level of competence and are de-enrolled from the operator’s approved EBT programme shall not exercise the privileges of that type rating. Annex VI (Part-ARA) to Regulation (EU) No 1178/2011 ARA.FCL.200 Procedure for issue, revalidation or renewal of a licence, rating or certificate (a) Issue of licences and ratings. The competent authority shall issue a pilot licence and associated ratings, using the form as established in Appendix I to this Part. (b) Issue of instructor and examiner certificates. The competent authority shall issue an instructor or examiner certificate as: (1) an endorsement of the relevant privileges in the pilot licence as established in Appendix I to this Part; or (2) a separate document, in a form and manner specified by the competent authority. (c) Endorsement of licence by examiners. (1) bBefore specifically authorising certain examiners to revalidate or renew ratings or certificates, the competent authority shall develop appropriate procedures. (2) These appropriate procedures may include endorsement of licence under an approved EBT programme in accordance with Appendix 10. In such case, signature delegation to endorsement of licence may be allowed. (d) Endorsement of licence by instructors. Before specifically authorising certain instructors to revalidate a single-engine piston or TMG class rating, the competent authority shall develop appropriate procedures. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 13 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 2.2. Draft regulation, AMC & GM (draft EASA opinion and draft EASA decision) and rationale in detail Annex I (Definitions) to Regulation (EU) No 965/2012 Definitions for terms used in Annexes II to VIII For the purpose of this Regulation, the following definitions shall apply: […] (23a) ‘competency’ means a dimension of human performance that is used to reliably predict successful performance on the job. A competency is manifested and observed through behaviours that mobilise the relevant knowledge, skills and attitudes to carry out activities or tasks under specified conditions; (23b) ‘competency-based training’ means assessment and training programmes that are characterised by a performance orientation, emphasis on standards of performance and their measurement and the development of training to the specified performance standards. (23c) ‘competency framework’ means a complete set of identified competencies, used in the operator’s EBT programme to develop, train and assess competencies utilising scenarios that are relevant to operations. The chosen competency framework should be wide enough to prepare flight crews for both known and unforeseen threats and errors. (42a) ‘EBT module’ means a combination of sessions in a qualified flight simulation training device as part of the 3-year period of recurrent assessment and training. (47a) ‘enrolment’ means the administrative act of being approved to participate in the EBT recurrent training programmes by the operator. (47b) ‘enrolled flight crew member’ means crew member participating in the EBT recurrent training programme. (47c) ‘equivalency of approaches’ (approach clustering) means all the approaches that place an additional demand on a proficient crew regardless whether they are used or not in the EBT modules. (47d) ‘equivalency of malfunctions’ (malfunction clustering) means all the malfunctions that put a significant demand on a proficient crew regardless whether they are used or not in the EBT modules. (47e) ‘evaluation phase (EVAL)’ means one of the phases of an EBT module. The evaluation phase is a line- orientated flight scenario, representative of the operator’s environment during which there are one or more occurrences to evaluate key elements of the defined competency framework. The root cause rather than the symptoms in any deficiency should be identified, in order to determine training needs. (47f) ‘evidence-based training (EBT)’ means assessment and training based on operational data that is characterised by developing and assessing the overall capability of a trainee across a range of a competency framework rather than by measuring the performance in individual events or manoeuvres. (69a) ‘in-seat instruction (ISI)’ means part of the scenario-based training phase. ISI contains predetermined scripted scenarios within the scenario-based training phase where the instructors can: (c) provide confidentially simple instructions to one pilot; or TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 14 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (d) perform predetermined exercises acting, in a pilot seat, as pilot flying (PF) or pilot monitoring (PM) for the purposes of demonstration and of intervention by the other pilot. (76a) ‘manoeuvres training phase (MT)’ means one of the phases of an EBT module. During this phase, according to aircraft generation, crews have time to practise and improve performance in largely psychomotor skill-based exercises by achieving a prescribed flight path or performing a prescribed event to a prescribed outcome. These exercises or events should place a significant demand on a proficient flight crew. Flight path control may be accomplished by a variety of means including manual aircraft control and the use of auto flight systems. (98a) ‘proficient’ means demonstration of the necessary skills, knowledge and attitudes required to perform any defined tasks to the prescribed standard. (104a) ‘scenario-based training phase (SBT)’ means one of the phases of an EBT module. This phase is designed to focus on the development of competencies, whilst training to mitigate the most critical risks identified for the aircraft generation. It should include the management of specific operator’s threats and errors in a real-time line-orientated environment. competency-based training The definition proposed is transposed from Doc 9995: ‘Competency-based training. Training and assessment that are characterized by a performance orientation, emphasis on standards of performance and their measurement and the development of training to the specified performance standards.’ Competency-based training and EBT — use of the wording ‘assessment and training’ The proposed provision uses the wording ‘assessment and training’ instead of ‘training and assessment’ because it reflects better the model used in EBT. Currently, EBT is used for airline pilots, which are current on type. Therefore, the phases of EBT focus first on assessment, to then develop the competencies in the subsequent phases (training). The traditional use of the sentence ‘training and assessment’ is appropriate for initial type ratings and initial issues of licences where the pilots are not yet proficient, and they need to learn a new type rating. In these cases, the sequence of ‘training’ and then ‘assessment’ is appropriate. competency framework The term ‘identified competencies’ is used to refer to the competencies the operator must choose to develop a competency framework (e.g. the 9 competencies of EASA that include the 8 competencies of Doc 999518 plus ‘Application of Knowledge’). These competencies are also called ‘core competencies’. However, the use of the word ‘competencies’ in the sentence ‘train and assess competencies’ is referring to the scenarios themselves and the intent is to develop the complete set of competencies (core and non-core). ‘unforeseen threats and errors’ is used to link it to resilience. As described several times in this document, resilience is very important to aviation safety. The definition is based on the Doc 9995 definition of ‘core competencies’: 18 ICAO Doc 9995 AN/497 ‘Manual of Evidence-based Training’ first edition 2013. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 15 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ‘Core competencies. A group of related behaviours, based on job requirements, which describe how to effectively perform a job and what proficient performance looks like. They include the name of the competency, a description, and a list of behavioural indicators’. competency A competency is manifested and observed through behaviours that mobilise the relevant knowledge, skills and attitudes to carry out activities or tasks under specified conditions. Trainees successfully demonstrate competency by meeting the associated competency standard. The definition proposed in the NPA is created based on: — Amendment 175 to ICAO Annex 1 ‘Personal licensing’; and — Doc 9995. The Doc 9995 references used were:  ‘7.8.5.1 To be competent in any job, a person requires a certain amount of knowledge, an adequate level of skills, and a particular set of attitudes’.  ‘7.8.5.4 To be competent, a pilot requires capabilities across a range of knowledge, skills and attitudes (KSA)’. evidence-based training The definition is transposed from Doc 9995 evaluation phase The evaluation phase is a first assessment of competencies to identify individual training needs. On completion of the evaluation phase, any areas that do not meet the minimum competency standard will become the focus of the subsequent training. equivalency of malfunctions The definition has been created to clarify the rules of equivalency of malfunctions. It is a new definition, which is not included in Doc 9995 AN/497 ‘Manual of Evidence-based training’ first edition 2013. manoeuvres training phase This is not a real-time training but allows crews the time to practise and improve performance in largely psychomotor skill-based exercises. Repositioning of the flight simulation in order to focus training on the intended manoeuvres will be a commonly used FSTD feature for this phase. Scenario-based training phase The definition for SBT was based on the following ideas: — Wherever possible, consideration should be given towards variations in the types of scenario, times of occurrences and types of occurrences, so that the pilots do not become overly familiar with repetition of the same scenarios. — Variations should be the focus of EBT programme design, but not left to the discretion of individual instructors in order to preserve programme integrity and fairness. The definition was transposed from Doc 9995 Chapter 3.8: TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 16 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ‘c) Scenario-based training phase. This phase forms the largest phase in the EBT programme, and is designed to focus on the development of competencies, whilst training to mitigate the most critical risks identified for the aircraft generation. The phase will include the management of specific threats and errors in a real-time line orientated environment. The scenarios will include critical external and environmental threats, in addition to building effective crew interaction to identify and correct manage errors. A portion of the phase will also be directed towards the management of critical system malfunctions. For this programme to be fully effective, it is important to recognise that these predetermined scenarios are simply a means to develop competency, and not an end or ‘tick box’ exercise in themselves’. GM2 Annex I Definitions ABBREVIATIONS AND ACRONYMS APP approach APK application of procedures (EBT competency) CLB climb COM communication (EBT competency) CRZ cruise DES descent EBT evidence-based training EVAL evaluation phase FPA flight path management — automation (EBT competency) FPM flight path management — manual (EBT competency) GND ground ISI in-seat instruction KNO application of knowledge (EBT competency) LDG landing LOC-I loss of control in-flight LTW leadership and teamwork (EBT competency) OB observable behaviour PSD problem-solving & decision-making (EBT competency) SAW situation awareness (EBT competency) TO take-off UPRT upset prevention and recovery training WLM workload management (EBT competency) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 17 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail GM1X Annex I Definitions EVIDENCE-BASED TRAINING ‘Behaviour’ is the way a person responds, either overtly or covertly, to a specific set of conditions, and which is capable of being measured. ‘Concordance (inter-rater reliability)’ is the consistency or stability of scores between different EBT instructors. It gives a score (s) of how much homogeneity, or consensus, there is in the ratings given by instructors (raters). ‘Cycle’ is the combination of two modules where Cycle 1 comprises Modules 1 and 2, Cycle 2 comprises Modules 3 and 4, and Cycle 3 comprises Modules 5 and 6 of the 3-year EBT programme. ‘Evaluation phase (EVAL)’ is the phase where a first assessment of competencies is performed in order to identify individual training needs. On completion of the evaluation phase, any areas that do not meet the minimum competency standard will become the focus of the subsequent training. The evaluation phase comprises a complete mission as a crew. ‘Facilitation technique’ is an active training method, which uses effective questioning, listening and a non- judgmental approach, and is particularly effective in developing skills and attitudes, assisting trainees to develop insight and their own solutions and resulting in better understanding, retention and commitment. ‘Line-orientated flight scenario’ is the assessment and training involving a realistic, ‘real-time’, complete mission simulation of scenarios that are representative of line operations. ‘Monitoring’ is a cognitive process to compare an actual to an expected state. It requires knowledge, skills and attitudes to create a mental model and to take appropriate action when deviations are recognised. ‘Observable behaviour (OB)’ is a single role-related behaviour that can be observed and may or may not be measurable. ‘Performance criteria’ are statements used to assess whether the required levels of performance have been achieved for a competency. A performance criterion consists of an OB, a condition (s) and a competency standard. ‘Practical assessment (or practical assessment in competencies)’ is the primary method for assessing performance and should serve to verify the integrated performance of competencies. It takes place in either a simulated or an operational environment. A practical assessment in competencies is equivalent to a proficiency check and is performed under the instructor privilege in the context of proficiency check in accordance with Appendix 10 to Part-FCL. More information can be found in ICAO Doc 9868 ‘PANS-TRG’. ‘Line-orientated flight scenario(s)’ are comprised of scenario elements derived from the table of assessment and training topics. Scenario-based training phase (SBT)’ is the largest phase in the EBT programme. It is designed to maximise crew’s exposure to a variety of situations that develop and sustain a high level of competency and resilience. The scenario for this phase should include critical external and environmental threats, to build effective crew interaction to identify and manage errors. A portion of the phase will also be directed towards the management of critical system malfunctions. Scenario elements address the training topic and detail the threat and/or error that the crew are exposed to. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 18 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ‘Train-to-proficiency’ means approved training designed to achieve end-state performance objectives, providing sufficient assurances that the trained individual is capable to consistently carry out specific tasks safely and effectively. Note: In the context of this definition, ‘train-to-proficiency’ can be replaced by ‘training-to-proficiency’. Behaviour The definition is introduced to explain the definition of performance criteria. The definition is transposed from Doc 9995. Concordance The definition is transposed from the Doc 9995 definition of inter-rater reliability. Inter-rater reliability is a term not easily translated into all the languages of the European Union; therefore, a synonym for inter-rater reliability was used: ‘concordance’. In statistics, inter-rater reliability, inter-rater agreement, or concordance, is the degree of agreement among raters. Evaluation phase Further guidance is provided in this GM to complement the definition provided in the IR. Facilitation technique Primary technique that should be used for EBT and competency-based training. Monitoring Monitoring is the based fundament of threat and error management. Monitoring is embedded in the competency framework provided in ORO.FC.231, and its behaviour indicators are spread out in different competencies. Observable behaviour The definition is transposed from the ICAO Doc 9841 definition. ‘Performance criteria’ The definition is transposed from ICAO working papers for PANS-TRAINING and the new version of Doc 9995. Train-to-proficiency This text is based on GM15 Annex 1 definitions on UPRT and is referred to within the context of EBT. Practical assessment Although ICAO Doc 9995 follows an approach where summative assessment is performed at the end of the evaluation as follows: ‘3.6.2 The evaluation phase of each module will periodically be the focus of licence renewal or revalidation and may ultimately be the means by which Licensing Authorities continue to ensure that competence is maintained to hold a professional licence and type rating as applicable.’ The RMG decided to embrace the new philosophy of the draft ICAO Doc 9868 ‘PANS-TRG’ to be soon published. The new paragraph 4.4.1.2.2 is moving the summative assessment that otherwise would be made in the evaluation phase to the end of the module as provided in ORO.FC.231(a) ‘will not continue line TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 19 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail operations if during a module the performance observed was below the minimum acceptable level. The flight crew member continues line operations when a module is completed.’ Below an extract of ICAO Doc 9868 ‘PANS-TRG’ ‘4.4.1.2 Assessment methods 4.4.1.2.1 The primary method for assessing performance is the conduct of practical assessments, which should serve to verify the integrated performance of competencies. It may be necessary to supplement practical assessments with other forms of evaluation. The supplemental evaluations may be included as a result of regulatory requirements and/or a decision that these methods are necessary to confirm that competence has been achieved. 4.4.1.2.2 Practical assessments take place in either a simulated or operational environment. There are two types of practical assessment: formative assessments and summative assessments. Formative and summative assessments are conducted based on 4.6.6 and 4.6.7. 4.4.1.2.2.1 Formative assessments 4.4.1.2.2.1.1 Formative assessments are a part of the learning process. Instructors provide feedback to the trainee on how they are progressing toward the interim or final competency standard. This type of assessment enables the trainee to progressively build on competencies already acquired and should aid learning by identifying gaps as learning opportunities. If trainees receive feedback or are assessed only at the end of the training, they will have no opportunity to use that information to improve their performance. The frequency and number of formative assessments may vary depending on the duration of the training and the syllabus structure and its assessment plan (see 4.6). 4.4.1.2.2.1.2 Formative assessments should serve to: a) motivate trainees; b) identify strengths and weaknesses; and c) promote learning. 4.4.1.2.2.2 Summative assessments 4.4.1.2.2.2.1 Summative assessments provide a method that enables the instructor/assessor to work with a trainee to collect evidence of the competencies and performance criteria to be demonstrated with respect to the interim or final competency standard(s). Summative assessments are carried out at defined points during the training and/or at the end of training. During summative assessments, the decision is either ‘competent’ or ‘not competent’ with respect to the interim or final competency standard(s). However, this can be further developed into a more refined grading system with a scale of judgements to improve feedback for the trainee and training personnel. 4.4.4.1.2.2.2 Summative assessments that are conducted during the course to evaluate the progress of the trainee are typically carried out by the instructing team. It may be advantageous if the instructors conducting these assessments were different from the instructors who routinely work with the trainee. Summative assessments conducted at the end of training and that lead to the issue of a licence and/or rating have both legal and safety implications. Therefore, the personnel carrying out these assessments should have the necessary competencies to assess objectively and meet the authority’s requirements. Such personnel should be provided with the tools necessary to collect evidence in a systematic and reliable manner in order to ensure TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 20 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail inter-rater reliability. 4.4.1.2.3 The list of methods below that supplement practical assessments is not intended to be restrictive. Any suitable supplemental method for assessing competence may be used. Other methods may include projects and group assignments.’ Annex II (Part-ARO) to Regulation (EU) No 965/2012 ARO.OPS.226 Approval and oversight of evidence-based training programmes (a) Where a competent authority grants an approval for EBT programmes, inspectors must receive qualification and training in EBT principles, application, approval processes and continuing oversight. (b) The competent authority shall assess and oversee the EBT programme, together with the processes that support the implementation of the EBT programme. (c) Before approving an EBT programme, the competent authority shall: (1) ensure the resolution of significant findings in the areas that will support the application of the EBT programme; (2) assess the capability of the operator to support the implementation of the EBT programme. The following elements shall be considered as a minimum: (i) the maturity and capability of the operator’s management system, and this programme’s suitability; (ii) the operator’s ability to maintain reliable and accurate flight crew training records; (iii) the suitability of the operator’s grading and assessment scheme; (iv) the experience of the relevant personnel, fundamentally of the flight crew instructors, in the use of the processes and procedures that support the implementation of the EBT programme; and (v) the operator’s implementation plan and a safety risk assessment supporting the EBT programme in order to demonstrate how an equivalent level of safety to that of the current training programme can be achieved; (d) The competent authority shall amend or revoke the approved EBT programme if continuing compliance is not ensured. ARO.OPS.226 This provision contains the approval and the oversight provisions to ensure a safe EBT programme. The provisions follow the concept already described in: — Point (a)(2) of ARO.GEN.200 regarding the training and qualification of the inspectors (point (a) of ARO.OPS.226) and in the associated AMC2 ARO.GEN.200(a)(2) point (a)as regards the initial training programme for the instructors, and AMC4 ARO.GEN.200(a)(2) (applicable from 30 March 2019) with regard to inspector qualification for cat operations for CAT operations. The requirements of training in ARO.OPS.226 are further explained in AMC1 ARO.OPS.226(a). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 21 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail — The new proposed rule ARO.OPS.225 published in NPA 2016-06 (A) on fuel schemes for the general structure of the rule. ARO.OPS.226 point (c)(1) This provision may need further development through the development of AMC or GM by the review group or through the internal policy of the competent authority. Comments on whether this rule should be developed are welcome by the stakeholders. ARO.OPS.226 point (c)(2)(ii) EBT programmes require extensive use of data and suitable records systems. This is already required in the operator’s requirements ORO.GEN.220 and ORO.MLR.115; therefore, it has probably been overseen in the past. However, the competent authority should verify that the operator is compliant as EBT will increase the workload and usability of the record system; therefore, it may be a first indication of an operator’s maturity to implement EBT. ARO.OPS.226 point (c)(2)(iii) This provision allows the competent authority to access pilots grading results. This already applies today and EBT will not change the current situation. The competent authority is allowed to access the pilot records (ORO.GEN.140 access) to verify ‘the suitability of the operator’s grading and assessment scheme’. Furthermore, the access to records and grading data for the verification of the grading system is also recognised at ICAO level (see Doc 9379 ‘Manual of Procedures for Establishment and Management of a State's Personnel Licensing System’ (Part I: General principles and organization Chapter 2 - The Licensing Authority, paragraph 2.8 Record-keeping)). ARO.OPS.226 point (d) The periodic oversight plan follows the following principles: — A performance-based safety objective is provided in the IR. — A more detailed criterion is then provided in the associated AMC1 ARO.OPS.226(d) ‘Approval and oversight of EBT programmes OVERSIGHT PLAN — PERIODIC ASSESSMENT TO VERIFY COMPLIANCE OF THE APPROVED EBT PROGRAMME’ — Then, GM addressing an important criterion that competent authority should oversee is developed — GM1 to AMC1 ARO.OPS.226(d) ‘EFFECTIVENESS OF THE OPERATOR’S APPROVED EBT PROGRAMME’. The provision is linked to another IR (ARO.GEN.350) that provides a reference when continuing compliance is not ensured. ‘ARO.GEN.350 (1) In the case of level 1 findings the competent authority shall take immediate and appropriate action to prohibit or limit activities, and if appropriate, it shall take action to revoke the certificate, specialised operations authorisation or specific approval or to limit or suspend it in whole or in part, depending upon the extent of the level 1 finding, until successful corrective action has been taken by the organisation.’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 22 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The intent of this rule also includes the need for the competent authority to have periodic observations of the training session; however, this requirement was not included as AMC2 ARO.GEN.305(b) already provides for such requirement: ‘AMC2 ARO.GEN.305(b) Oversight programme PROCEDURES FOR OVERSIGHT OF OPERATIONS (…) (b) Audits and inspections, on a scale and frequency appropriate to the operation, should cover at least: (1) infrastructure, (2) manuals, (3) training, (…) (c) The following types of inspections should be envisaged, as part of the oversight programme: (1) flight inspection, (2) ground inspection (e.g. documents and records), (3) training inspection (e.g. ground, aircraft/FSTD, (…)’ Point (b) normally means a documentation exercised, and point (c) normally means visit/inspection; therefore, observation of the training session. ARO.OPS.226 point(d) wording ‘approved EBT programme’ The term ‘approved EBT programme’ is used instead of simply ‘EBT programme’. EBT programme is referred to in the AMC contained in ORO.FC.231 point (a) ‘EBT programme’: this is a generic programme in an aircraft generation while the ‘approved EBT programme’ is specific to a particular operator and it encompasses all the requirements contained in ORO.FC.231 from point (a) to (i). AMC1 ARO.OPS.226(a) Approval and oversight of evidence-based training programmes QUALIFICATION AND TRAINING — INSPECTORS — EVIDENCED-BASED TRAINING (a) For the initial approval and oversight of an operator’s EBT programme, the inspector of the competent authority should undertake EBT as part of their required technical training (see AMC2 ARO.GEN.200(a)(2)). At the conclusion of the inspector training, the inspector should: (1) know the principles of EBT, including the following underlying principles: (i) competency-based training; (ii) learning from positive performance; (iii) building resilience; and; (iv) data-driven training; (2) know the structure of an EBT module; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 23 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (3) know the method of training delivery for each phase of an EBT module; (4) know the principles of adult learning and how they relate to EBT; (5) recognise effective observations based on a competency framework, and document evidence of observed performance; (6) recognise and relate specific performance observations of competencies; (7) recognise trainee performance to determine competency-based training needs and recognise strengths; (8) understand methods for the evaluation of performance using a competency-based grading system; (9) recognise appropriate teaching styles during simulator training to accommodate trainee learning needs; (10) recognise and facilitate trainee learning, focusing on specific competency-based training needs; and (11) understand how to conduct a debrief using facilitation techniques. (b) The objective of such training is to: (1) attain the adequate level of knowledge in the principles of approval and oversight of the EBT programmes; and (2) acquire the ability to recognise the features of the EBT programme. AMC1 ARO.OPS.226(a) The intention of the RMG and EASA is not to substitute the existing requirements in AMC4 ARO.GEN.200(a)(2) regarding the qualification of the inspector for the EBT programmes. On the contrary, the EBT training requirements are additional to those contained in AMC4 ARO.GEN.200(a)(2). If stakeholders believe this is not clear in the proposed IR, EASA encourages them to place a relevant comment so that the review group addresses this issue through a new paragraph with the following approach: ‘In addition to the requirements of AMC4 ARO.GEN.200(a)(2)’ Only the EBT training course is required for inspectors and not the EBT assessment of competence (demonstration). This approach follows the concept already introduced in the regulation for the Fatigue Risk Management System course. Since the EBT paradigm is mainly under the supervision of the operator, including licencing issue, the inspector needs to have an acute understanding of the principles, philosophy and application of EBT concepts, in order to understand the performance of the operator The demonstration of the acceptable level of knowledge of the inspector can be achieved through an on the job training. AMC1 ARO.OPS.226(a) wording ‘technical training’ The use of the term ‘technical training’ is referring to AMC2 ARO.GEN.200(a)(2) point (a)(11) AMC2 ARO.GEN.200(a)(2) Management system QUALIFICATION AND TRAINING — INSPECTORS TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 24 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (a) Initial training programme: The initial training programme for inspectors should include, as appropriate to their role, current knowledge, experience and skills in at least all of the following: (…) (11) technical training, including training on aircraft-specific subjects, appropriate to the role and tasks of the inspector, in particular for those areas requiring approvals. GM1 to AMC1 ARO.OPS.226(a) Approval and oversight of evidence-based training programmes INSPECTOR’S EBT PROGRAMME — FEATURES OF AN OPERATOR’S EBT PROGRAMME In order to recognise and evaluate the features of an operator’s EBT programme, the inspector’s training programme may include those features as training objectives. AMC1 ORO.FC.231(a)(2) provides the list of minimum features that should be contained within an approved EBT programme. GM1 to AMC1 ARO.OPS.226(a) The GM provides further details on the learning objective number (b) (2) ‘acquire the ability to recognised the features of the EBT programme ’ contained in AMC1 ARO.OPS.226 (a) ‘Approval and oversight of Evidence- based training programmes’ TRAINING AND QUALIFICATION — EVIDENCED-BASED TRAINING AMC1 ARO.OPS.226(c) Approval and oversight of programmes INITIAL APPROVAL — VERIFICATION OF COMPLIANCE When approving an EBT programme, the competent authority should ensure that the operator fulfils all the applicable criteria of ORO.FC.231 and its associated AMC. In particular, it should recognise the features of the operator’s EBT programme (AMC1 ORO.FC.231(a)(2)). AMC1 ORO.OPS.226(c) This provision was introduced to guide the competent authority on the main characteristics of an EBT programme. This AMC may be used by the competent authority to develop checklists for audits. AMC1 ARO.OPS.226(d) Approval and oversight of evidence-based training programmes OVERSIGHT PLAN — PERIODIC ASSESSMENT TO VERIFY COMPLIANCE OF THE APPROVED EBT PROGRAMME (a) After issuing the approval of the operator’s EBT programme, the competent authority should have a process to verify the operator’s continuing compliance. (b) Each organisation to which an EBT approval has been issued should have an inspector assigned to it who is trained and qualified for EBT (see AMC1 ARO.OPS.226(a)). (c) Audits and inspections, on a scale and frequency appropriate to the operation, should cover at least: (1) management supervision of the EBT programme; (2) ongoing identification of operational risk and inclusion into the operator’s approved EBT programme; (3) relevance of the operator’s approved EBT programme to address its operational and training needs; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 25 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (4) effectiveness of the operator’s approved EBT programme to improve pilot competencies. When there is an ineffective programme, the competent authority should examine the operator processes which identify the lack of effective results; (5) compliance with all requirements of ORO.FC.231; (6) delivery of instructor training in accordance with AMC1 ORO.FC.145(a)(3), including inspections of the training delivery; (7) conduct of assessments of competence for EBT instructors, including periodic inspections of FSTD training; (8) maintenance of crew records; (9) administration of programme enrolment and compliance with the requirements of Annex I (Part-FCL) for licence revalidation and renewal; (10) continuing standardisation of EBT instructors, including inspections of the training delivery; and (11) verification that the operator fulfils the requirements detailed in AMC1 ORO.FC.231(a). AMC1 ARO.OPS.226(d) The list was derived by a read-through of ORO.FC.231 and all ARO.GEN, ARO.OPS requirements for approval and oversight. This list may be supported by a checklist similar to that developed by EASA for mixed EBT implementation. Readers are invited to comment on the necessity of this material. AMC1 ARO.OPS.226(d) points (b) and (c) The intent of the RMG when drafting points (b) and (c) was to ensure that the competent authority has sufficiently qualified inspectors to oversee the EBT programme. The RMG also provided the considerations and items to review in the periodic oversight plan so appropriate resources are planned. AMC1 ARO.OPS.226d(d) point (c)(1) Management supervision of the EBT programme. This means that the operator should demonstrate to the competent authority that it has a method to collect, analyse and act upon the data from the EBT programme. It is expected that this would normally be discussed in regular meetings (the training standards meetings or similar format). Minutes of the meeting should be kept. In the training standards meetings, the operator would review the data and revise the programme as necessary. This is also provided in ORO.GEN.200(a)(5) of the Air OPS Regulation. AMC1 ARO.OPS.226(d) point (c)(3) wording ‘relevance of the operator’s approved EBT programme’ Relevance means that an EBT programme both includes the features contained in AMC1 ORO.FC.231(a)(2) and continuously identifies the operator’s operational risks to feed the operator’s approved EBT programme. There was a discussion in EASA and the RMG whether clarifying ‘EBT effectiveness’ and ‘EBT relevance’ was necessary. These are important elements of the EBT programme (verifying performance output). Please provide comments on the necessity of GM to further explain relevance and effectiveness. AMC1 ARO.OPS.226(d) point (c)(8) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 26 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The competent authority should verify compliance with the provision of record-keeping under ORO.GEN.220 and ORO.MLR.115. Data collection and record-keeping are a key part of the EBT system. AMC1 ORO.OPS.226(d) point (c)(10) wording ‘Continuing standardisation of EBT instructors’ This provision includes training and concordance assurance of the instructor. Verifying concordance should be preferably a data-driven process. EASA may develop GM to expand on this to show how verification of concordance may occur, and how decay prevention should be addressed. Readers are invited to comment on the necessity of this GM. GM1 to AMC1 ARO.OPS.226(d) Approval and oversight of evidence-based training programmes EFFECTIVENESS OF THE OPERATOR’S APPROVED EBT PROGRAMME (a) This can be determined by periodic review of pilot competencies across several domains, such as role fleet (e.g. CPT/FO, A320, B737) and airline, so that the continuing improvement of the approved EBT programme is linked to an improvement of the pilot core competencies. (b) The analysis of the pilot competencies across the domains should also take into account the operator’s experience in the approved EBT programme and the level of difficulty contained within the scenario elements of the programme, which may result in variations of the grading results. GM1 to AMC1 ARO.OPS.226(d) point (b) This point is introduced to guide the competent authority to verify the results of the competencies. These grading results may have variations and those variations are acceptable. These variations occur for several reasons, for example, due to variations in the difficulty of the EBT programme. Therefore, the effectiveness of the EBT programme should be considered from a holistic view. For instance, a temporary decrease of pilot grading in core competencies does not necessarily mean a lack of effectiveness. Operators designing modules with numerous difficult events could end up in a decrease of the grading results of some competencies and vice versa. Annex III (Part-ORO) to Regulation (EU) No 965/2012 ORO.FC.145 Provision of training (a) All the training required in this Subpart shall be conducted: (1) in accordance with the training programmes and syllabi established by the operator in the operations manual; (2) by appropriately qualified personnel. In the case of flight and flight simulation training and checking, the personnel providing the training and conducting the checks shall be qualified in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011; (3) in addition to the above, for an approved EBT programme: (i) personnel providing assessment and training shall hold an Annex I (Part-FCL) instructor or examiner certificate; and (ii) have completed the operator’s EBT instructor standardisation. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 27 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Successful completion of the operator’s EBT standardisation will qualify the instructor to perform practical assessment in competencies. ORO.FC.145(a)(3) EBT is a paradigm shift and instructors play a key role in the delivery of the programme. The RMG found necessary to add an EBT course on top of the qualification required in the Aircrew Regulation. Doc 9995 requires this training as well: ‘6.3.2 Instructors should undergo suitable training in order to adapt to the needs of training within an EBT programme. Training should provide the framework for existing instructors to develop their competence to undertake EBT assessment and training’. ORO.FC.145(a)(3) wording ‘for an approved EBT programme’ This wording ‘for an approved EBT programme’ is used instead of ‘operator holding an approval for EBT’ or other wordings that could be possibly used in order to allow: — contracted activities under ORO.GEN.205; and — that other aspects of the training programme which are not linked to the EBT programme itself could be delivered by other personnel which are not EBT instructors. ORO.FC.145(a)(3) wording ‘hold an Annex I (Part-FCL) instructor or examiner certificate’ The proposed rule is restricting the possibility instructors holding a certificate issued by a third country to become EBT instructors. By using the wording ‘hold an Annex I (Part-FCL) instructor or examiner certificate’, only instructors or examiners holding a certificate issued in accordance with the EU regulatory framework can deliver EBT. The reasons for such a provision according to the RMG is the following: — The EBT programme based on competencies does not have the same prescriptive components as a task- based checking under Appendix 9 to Part-FCL. Therefore, the RMG, in an effort to ensure standardisation and integrity of the licence revalidation under EBT, wanted to put into place some level of control of instructor qualification. — To ensure alignment between Part-ORO of the Air OPS Regulation and Part-FCL of the Aircrew Regulation, the requirement of FCL.900 point (c) must be reproduced in Part-ORO. Therefore, only holders of European instructors’ certificates (with a European pilot licence or with a pilot licence issued by a third country but subject to FCL.900 (c)) are allowed to provide training to European licence holders. — The EBT concept is so new that a less restricted option could create issues in terms of standardisation as most of the non-European countries are not applying Doc 9995. — Furthermore, the situation where an instructor holding a pilot licence issued by a third country provides training, only occurs when the operator has subcontracted its training to an approved training organisation (ATO) under ORO.GEN.205. In this situation, the efforts of standardisation are already big. Considering that a small number of non-standardised data introduced in the EBT system can have big implication in the result of the programme, then only Part-FCL certificate holders should be allowed to provide EBT as they are standardised in EBT by the ATO. — The RMG was also concerned with the delivery of the EBT programme, as they believe that the quality of the delivery of the operator’s EBT programme could be compromised; since Europe is the first region TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 28 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail delivering full EBT, Part-FCL certified instructors may better guarantee the consistency and philosophy of EBT. This is particularly important as at a later stage, in the context of the activities of RMT.0599, initial type rating courses may be subject to EBT. Note: Individual European certified trainers with a European pilot licence are allowed to provide EBT even if they are not operator or ATO staff members. This is allowed under ORO.FC.205 contracted activities. ORO.FC.145 (a)(3) wording ‘the operator’s EBT instructor standardisation’ The wording used in the AMC1 ORO.FC.145(a)(2) for the instructor’s standardisation is using ‘EBT’ for each of the 2 parts ‘EBT instructor training’ and ‘EBT assessment of competence’ to ensure they are both specific for EBT. The use of ‘EBT assessment of competence’ is to ensure that the EBT instructor is allowed to revalidate the instructor certificate when the EBT assessment of competence and the assessment of competence for the revalidation of the instructor are combined. The RMG was reluctant to allow the EBT instructor to revalidate the EBT instructor certificate under an ATO not belonging to an airline, and therefore the requirements for the assessment are contained in the operators’ requirements. Hence, the revalidation of the EBT instructor certificate requires an operator. Following the concept already described in Subparts J and K of Part-FCL, the instructors should complete a course to become EBT instructors. This standardisation is composed of a training course and the assessment of competence, which follows the logic of Part-FCL. For example, FCL.930 ‘Training course’, FCL.935 ‘Assessment of competence’ and FCL.940.TRI TRI illustrate the situation for instructor courses and assessment: ‘FCL.940.TRI TRI — Revalidation and renewal (a) Revalidation (1) Aeroplanes. For revalidation of a TRI(A) certificate, the applicant shall, within the last 12 months preceding the expiry date of the certificate, fulfil one of the following 3 requirements: (i) conduct one of the following parts of a complete type rating training course: simulator session of at least 3hours or one air exercise of at least 1 hour comprising a minimum of 2 take-offs and landings; (ii) receive instructor refresher training as a TRI at an ATO; (iii) pass the assessment of competence in accordance with FCL.935. […]’ The RMG believes that it must be an operator EBT instructor training. Therefore, the instructor course is operator-specific. However, credits are foreseen in point (d) of the AMC1 ORO.FC.145(a)(3) when an instructor has experience in EBT, allowing for a shorter training course. ORO.FC.145 (a)(3)(ii) The sentence ‘Successful completion of the operator’s EBT standardisation will qualify the instructor to perform practical assessment in competencies’ was introduced because in the Aircrew Regulation the instructors do not have the privilege to perform practical assessment in competencies. For example, the current FCL.905.TRI.TRI only provides a privilege to ‘instruct for’: ‘FCL.905.TRI TRI — Privileges and conditions The privileges of a TRI are to instruct for […]’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 29 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail This provision introduces the link to Part-FCL for the EBT proficiency check in accordance with Appendix 10 (practical assessment of competencies), the wording ‘practical assessment in competencies’ provides the link to Appendix 10 point 6 ‘The practical assessment in competencies must be conducted in accordance with the operator’s approved EBT programme’. ORO.FC.145(a)(3)(ii) wording ‘practical assessment in competencies’ This wording is a transposition of the ICAO wording ‘practical assessment’ contained in PANS-TRAINING paragraph 4.4.1.2.2. Furthermore, practical assessment is defined in the new GM to definitions in Subpart ORO.FC. AMC1 ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — INITIAL STANDARDISATION (a) Before delivering the operator’s approved EBT programme, the instructor should successfully complete an EBT instructor initial standardisation composed of: (1) EBT instructor training; and (2) EBT assessment of competence. EBT INSTRUCTOR TRAINING (b) The EBT instructor training course should be delivered by a pilot who has already demonstrated proficiency to train the elements specified in point (b) below. (c) The EBT instructor training course should comprise theoretical and practical training. At the completion of EBT instructor training, the instructor should: (1) have knowledge of EBT, including the following underlying principles: (i) competency-based training; (ii) learning from positive performance; (iii) building resilience; and (iv) data-driven training; (2) demonstrate knowledge of the structure of an EBT module; (3) demonstrate knowledge of the method of training delivery for each phase of an EBT module; (4) demonstrate knowledge of the principles of adult learning and how they relate to EBT; (5) conduct objective observations based on a competency framework, and document evidence of observed performance; (6) relate specific performance observations of competencies; (7) analyse trainee performance to determine competency-based training needs and recognise strengths; (8) evaluate performance using a competency-based grading system; (9) apply appropriate teaching styles during simulator training to accommodate trainee learning needs; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 30 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (10) facilitate trainee learning, focusing on specific competency-based training needs; and (11) conduct a debrief using facilitation techniques. (d) An instructor may be given credits on the topics of point (c) if the instructor has previously demonstrated competencies in those topics. EBT ASSESSMENT OF COMPETENCE (e) Prior to conducting assessment and training within an EBT programme, the EBT instructor should complete an EBT assessment of competence where the EBT instructor delivers: (1) an evaluation phase and a manoeuvres training phase; or (2) a scenario-based training phase. (f) The assessment of competence has a validity period of 3 years. When the assessment of competence is conducted within the 12 months preceding the expiry date, the next assessment of competence should be completed within 36 calendar months of the original expiry date of the previous assessment. (g) The EBT assessment of competence should be conducted by a person nominated by the operator, who: (1) is qualified in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011 to conduct an assessment of competence; and (2) has completed the EBT instructor initial standardisation. (h) The EBT assessment of competence may be combined with the assessment of competence required in Annex I (Part-FCL) to Regulation (EU) No 1178/2011. AMC2 ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — RECURRENT STANDARDISATION (a) The EBT instructor should receive an annual recurrent standardisation. The recurrent standardisation should include: (1) refresher EBT training; and (2) concordance training. (b) The EBT instructor should conduct a complete EBT module within the last 12 months preceding the expiry date. (c) If the requirement of point (b) has not been fulfilled, before conducting training within an EBT programme, the EBT instructor should undergo an EBT assessment of competence. (d) The EBT instructor should undergo an EBT assessment of competence every 3 years. AMC1.ORO.FC.145(a)(3) points (b) and (c) wording ‘EBT instructor training’ The syllabus for the EBT instructor training has been taken from Doc 9995 and the IATA/ICAO/IFALPA EBT Implementation Guide. The volume of the EBT instructor initial standardisation course is addressed in the new GM1 ORO.FC.145(a)(3) point (e). AMC1 ORO.FC.145(a)(3) point (b) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 31 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Point (b) provides the prerequisite for the pilot who delivers the EBT instructor training (ground course). The only prerequisite is that this pilot has completed the EBT instructor training. This pilot does not need to be a qualified instructor under Part-FCL of the Aircrew Regulation. This requirement is less stringent than the one for the person who delivers the assessment of competence (see requirement AMC1 ORO.FC.145(a)(3) point (g)) who needs to receive an EBT instructor training and be a qualified examiner in accordance with Part-FCL of the Aircrew Regulation. AMC1.ORO.FC.145(a)(3) wording ‘EBT assessment of competence’ The wording ‘assessment of competence’ is used for consistency purposes between Part-ORO of the Air OPS Regulation and Part-FCL of the Aircrew Regulation and to allow a combined assessment of the revalidation of the EBT instructor in Part-ORO and the revalidation of instructor’s certificate in accordance with Part-FCL. AMC1 ORO.FC.231 (a)(3) point (f) validity period of 3 years This provision is transposed from the Aircrew Regulation: instructors and examiners validity period. Furthermore, this provision is also included Doc 9995 paragraph 6.3.5: ‘All instructors should receive annual refresher training, and be re-assessed in the competencies specified in 6.3.3 every three years.’ The 12 month-transition period to complete the assessment of competence is transposed from FCL.940.TRI TRI — ‘Revalidation and renewal’ of Regulation (EU) No 1178/2011. AMC1.ORO.FC.145(a)(3) Point (g) wording ‘nominated person for this purpose by the operator’ The intention is that the person in charge of this matter would be a person specialised in EBT and a current examiner. However, there was a discussion in the RMG whether this person should be a current examiner or not. If not, then the word ‘held’ could be used in the provision. The proposal to allow NON-current examiners would allow more flexibility. This is important when the EBT is introduced for the first time in the airline. This option is deviating from the concept of instructor course in Part-FCL of the Aircrew Regulation. EASA expects that most of the courses for EBT will be combined with Part-FCL instructor courses. Therefore, at the end the assessment of competence is expected to be performed by a current qualified examiner anyway. Thus, the option of NON-current examiner was discarded and EASA to be consistent between Part-FCL and Part-ORO, decided that only current examiners will conduct the EBT assessment of competence. AMC1 ORO.FC.145(a)(3) point (g)(1) The requirement proposed was originally transposed from the existing Doc 9995 and the explanatory note of the ED Decision 2015/027/R for mixed EBT. ‘A person nominated (refer to ICAO Doc 9995 AN/497 ‘Manual of Evidence-based training’ first edition 2013 paragraph 6.3.4) by the operator for the conduct of competency assessments of EBT examiners and instructors should be a person who holds a certificate equivalent to that being assessed, provided that he or she has completed the training and assessment indicated in ICAO Doc 9995 paragraph 6.3’. That’s why point (g) of this AMC uses ‘conducted by a person nominated by the operator.’ ‘ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 32 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail However, to be consistent with Part-FCL of the Aircrew Regulation and ORO.FC.145 (a)(3), a further clarification was introduced as the ICAO provision does not provide details. Therefore, the NPA will require an assessment of competence performed in the FSTD before receiving the EBT instructor qualification. To maintain legal consistency between the assessment of competence referred to in Part-FCL and the EBT assessment of competence proposed in this provision (OPS), EASA decided that only personnel holding a certificate with privileges to perform assessment of competence are allowed to perform such ‘test’. When revalidating an instructor or examiner licence in accordance with the Aircrew Regulation, the provision is already there. Therefore this requirement does not add an extra burden to the airlines. The only exception to such statement (no extra burden to the airlines) would be during the transition period from legacy training to EBT, where the instructor/examiner revalidation may not match with the assessment of competence of EBT required during the initial EBT course. After the transition phase, the airline will roster the instructor/examiner revalidation in combination with an EBT assessment of competence when required. AMC1 ORO.FC.145(a)(3) Point (g)(1) wording ‘is qualified in accordance with Annex I (Part-FCL) to Regulation (EU) No 1178/2011 to conduct an assessment of competence’ This provision is introduced to ensure an examiner will perform the EBT assessment of competence. This provision is already required in the assessment of competence for the instructor in Subpart J of Part-FCL of the Aircrew Regulation. The intention of the RMG is that the assessment of competence for EBT and the assessment of competence to revalidate instructor certificate will be combined (see AMC1.ORO.FC.145(a)(3) Provision of training, this provision does not add any further requirement or cost. AMC2 ORO.FC.145(a)(3) The wording used is based on the revalidation for instructors and examiners in accordance with Subparts J and K of Part-FCL of the Aircrew Regulation. The example is provided below: ‘FCL.940.TRI TRI — Revalidation and renewal (a) Revalidation (1) Aeroplanes. For revalidation of a TRI(A) certificate, the applicant shall, within the last 12 months preceding the expiry date of the certificate, fulfil one of the following 3 requirements: (i) conduct one of the following parts of a complete type rating training course: simulator session of at least 3 hours or one air exercise of at least 1 hour comprising a minimum of 2 take-offs and landings; (ii) receive instructor refresher training as a TRI at an ATO; (iii) pass the assessment of competence in accordance with FCL.935.’ Following the concept above, the revalidation for EBT instructor will be based on the completion of one full simulator of EBT every 12 months; that means the combination of evaluation plus manoeuvres training/validation (mixed EBT) and a scenario-based training, plus an assessment of competence every 3 years. Point (a) of AMC2 ORO.FC.145(a)(3) provides the requirement for EBT refresher training. This training may satisfy the requirement of FCL.940.TRI(a)(1)(ii) concerning instructor refresher training, if accepted by the competent authority. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 33 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail This requirement is proposed to ensure standardisation of the instructors. Furthermore, the need for concordance assurance was introduced considering Doc 9995 Attachment to Chapter 1 step 9. 9** Instructor training 4.1.1 and Instructor EBT programme standardisation, which should be a and standardization. formalized approach to ensure a consistent and standardised 6.3 of Part I approach to the EBT programme prior to implementation, including practical training reinforcing application of the assessment and grading system and maximising inter-rater reliability. GM1 ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — INITIAL STANDARDISATION (a) The intent of the practical training is to ensure that EBT instructors have exposure to assessment of performance and route cause identification within an EBT programme. (b) EBT instructors receive practical assistance and guidance during standardisation in order to apply the learning from EBT instructor training. In particular, the focus should be on assessment of performance and the determination of root cause for remediation, plus facilitated debriefing based on root cause as a learning objective. (c) The personnel providing the EBT training is selected by the operator to assess the instructor capability in delivering EBT and provide effective feedback in order that instructor practice meets the expectations of the operator. (d) Practical EBT training includes the learning objective ‘Evaluate performance using a competency-based grading system’. This may be done with videos and other multimedia. It means that EBT instructors are exposed: (1) to different levels of pilot performance. This enables EBT instructors to distinguish between pilots performing less than the minimum acceptable level of performance (e.g. grade 1) and those whose performance is at an acceptable level in all competencies (e.g. grade 2). This EBT training may also include other performance examples (e.g. 3, 4 and 5). (2) also to different scenarios (e.g. complex to less complex) so that the instructor has exposure to assessments of competency in varying EBT scenarios. (e) The EBT instructor training course may be a minimum of 14 hours (EBT instructor training) and the recommended length is between 21 to 24 hours (EBT instructor training plus assessment of competence). GM1 ORO.FC.145(a)(3) EBT programme The transition to EBT involves a paradigm shift in the focus of training. To maximise the safety benefits of the programme, EBT instructors should be mentored to ensure practice develops according to the expectations of the operator. EBT instructors delivering standardisation course should be carefully selected and trained so that the standardisation activity provides the maximum benefit. The syllabus described in the AMC1 ORO.FC.145(a)(3) provides enough granularity for a performance-based rule. Therefore, the RMG decided not to include a prescriptive requirement regarding the number of hours TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 34 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail needed to deliver the EBT instructor course and instead the information is provided in point (e) in this GM. If necessary, EASA may transfer this information to AMC depending on the feedback received. However, the RMG acknowledged the novelty of the EBT programme where instructor training course is a fundamental piece. Therefore, it was decided to provide GM that would include some references regarding the length of the EBT instructor course in order to promote a successful discussion between the operator and the competent authority where the focus is on the outcome of the course (provided at the level of the AMC) rather than on the prescription of 14/21/24 hours (provided at the level of GM). GM1 ORO.FC.145(a)(3) point (e) Given the paradigm shift in the philosophy of assessment and training of competencies, a nominal value of course duration was included as a standardisation element. In order to agree in a figure, the RMG reviewed the rules relating to qualification of instructors (e.g. FCL.930 TRI.TRI were consulted). The 14 hours were commensurate with those required for initial qualification of instructors. Furthermore, the IATA EBT implementation guide recommends at least a 3-day course in Appendix B. However, this appendix provides a range of duration for the course between 3 days and 5 days. If necessary EASA may transfer this information to AMC depending on the feedback received. GM2 ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — RECURRENT STANDARDISATION (a) Refresher EBT training The intent of this training is to provide the framework for existing instructors to develop their competence to conduct EBT. This may be conducted using media (distance learning); however, operators should be aware that this is subject to the acceptance of the competent authority. (b) Concordance training This training is one of the elements to assure concordance within the EBT instructor community. The operator will verify concordance for each individual EBT instructor at least once a year. Those EBT instructors who do not demonstrate concordance may require further training. EBT INSTRUCTOR CONCORDANCE TRAINING (c) During training the assessment of the instructor concordance may be verified by controlling the content to be assessed (e.g. a video or paper case), in order to compare variance between instructors. Concordance may not be inferred only from training data, as this implicitly assumes homogeneity of all EBT modules assessed, which may not be the case, as EBT allows for module variation (e.g. providing different modules depending of strength and weakness of a group of pilots (e.g. Senior first officer, first officers and cadet)). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 35 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (d) Individual Instructor concordance will be assessed for a wide envelope of assessment. This includes: (1) assessing all competencies (9 if following the EASA competency framework); (2) assessing all levels of performance (1 to 5); and (3) different flight scenarios. (e) Concordance training also includes the alignment of root-cause analyses between instructors. GM2 ORO.FC.145(a)(3) Provision of training This GM for the annual EBT instructor standardisation was developed to clarify the intent of the provision provided in the AMC. The text proposed provides certain criteria on how to perform the annual instructor standardisation; however, the criteria that may be provided by the competent authority is fundamental, as training is subject to approval under OM part D and revalidations and renewal of licences are performed within an approved EBT programme. The authority should exercise its oversight powers to ensure operators provide the right amount of training and concordance assurance to their instructors. GM2 ORO.FC.145(a)(3) point (a) Wording ‘media (distance learning)’ The wording used is consistent with Part-FCL of the Aircrew Regulation, used in AMC1 FCL.115; FCL.120, AMC1 FCL210;FCL215, AMC1 to Appendix 3 GM2 ORO.FC.145(a)(3) points (b), (c), (d), (e), (f) This provision was introduced following the IATA ‘Evidence-Based Training Implementation Guide’19 chapter 4.1 ‘The EBT instructor’. ‘The development of strong inter-rater reliability and consistency in the approach to EBT is of great importance and should not be underestimated either initially or as a focus for the continuous improvement of an EBT system. Establishing robust guidelines and thorough experience strengthens inter-rater reliability, provided that suitable mechanisms are put in place. Clear and concise instructions, accurate performance indicator descriptions and peer review all increase inter-rater reliability.’ GM2 ORO.FC.145(a)(3) points (c), (d) and (e) The GM provides guidance to the following concepts: (1) comparability of instructors requires controlled assessment material (video) (2) concordance should cover wide envelope of assessment (3) concordance should be safeguarded against standards drift (4) concordance should look at observation, but also at root-cause analyses. ORO.FC.230 Recurrent training and checking GM1 ORO.FC.230(a);(b);(f) Recurrent training and checking MIXED EVIDENCE-BASED RECURRENT TRAINING AND CHECKING OF FLIGHT CREW CONDUCTED IN FLIGHT SIMULATION TRAINING DEVICES (FSTDs) 19 st IATA Evidence-Based Training Implementation Guide July 2013 1 Edition. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 36 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ICAO developed Doc 9995 ‘Manual of Evidence-based Training’, followed by EASA EBT MANUAL, which is intended to provide guidance to civil aviation authorities, operators and approved training organisations in the recurrent assessment and training of pilots by establishing a new methodology for the development and conduct of a recurrent assessment and training and assessment programme, titled evidence-based training(EBT). ‘Evidence-based Training(EBT)’ means training and assessment based on operational data that is characterised by developing and assessing the overall capability of a trainee across a range of core competencies rather than by measuring the performance during individual events or manoeuvres. ICAO Doc 9995 and the EASA EBT manual are is the reference documents for operators seeking to implement EBT. The purpose of this guidance material (GM) is to enable the implementation of a mixed EBT according to the principles established in ICAO Doc 9995 taking into account the European regulatory framework. In the current regulatory framework, it is possible to achieve a mixed EBT implementation of EBT. Implementation of a mixed EBT programme means that some portion of the recurrent assessment and training is dedicated to the application of EBT. This includes the Licence Proficiency Check (LPC) and the Operator Proficiency Check (OPC). As it is possible to combine LPC and OPC in ORO.FC, this GM is applicable to both checks. Therefore, the EBT training programme described in this GM refers to the recurrent training and checking of flight crew, including LPCs and OPCs. The EBT training programme takes into account the differences between aircraft of different generations and the effect of these differences on training. The operator should acquire a thorough knowledge of ICAO Doc 9995 or the EASA EBT manual before implementing this GM. For applicability, see ICAO Doc 9995 Chapter 3 or EASA tables of applicable aeroplane/helicopter types by generation. Mixed EBT programme Within the current regulatory framework tThe operator may undertake an mixed implementation of the mixed EBT programme according to this GM. The ICAO baseline EBT programme is defined in ICAO Doc 9995 Chapter 4.3.1 and in Appendices 2 to 7; the EASA EBT programme is defined in AMC2 to AMC7 ORO.FC.231(a). The baseline EBT programme provides the flexibility to adapt programmes according to specific operator risks. Elements of the enhanced EBT programme may be implemented according to the definition and process described in ICAO Doc 9995 Chapter 5. The operator should contact the competent authority in order for them to assess the application of the process described in ICAO Doc 9995 including, where applicable, the results from data analyses to support the enhanced EBT programme. Personnel providing training and checking in EBT (Refers to AMC1 ORO.FC.230(d)) ICAO Doc 9995 Chapter 6, or EASA AMC1 and AMC2 ORO.FC.145(a)(3), which is additional to EU regulations, contains the guidance for the assessment and training and assessment of personnel involved in the conduct of EBT. Equivalency of malfunctions/Malfunction clustering (Refers to ICAO Doc 9995 Paragraph 3.8.3) According to the concept of EASA and ICAO Doc 9995 Chapter 3.8.3, major failures reduce the capability of the aircraft or the ability of the crew to cope with operating conditions to the extent that there would be a TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 37 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail significant reduction in functional capabilities, significant increase in crew workload or in conditions impairing crew efficiency. Clusters of major failures of aircraft systems are determined by reference to malfunction characteristics and the underlying elements of crew performance required to manage them. Malfunction clustering Equivalency of malfunction may be used to guide the operator towards the implementation of an a mixed EBT programme according to AMC1 ORO.FC.230(a)(4)(i)(A) and ORO.FC.145(d). Conduct of Licence and Operator Proficiency Checks The EASA EBT programme or ICAO EBT programme described in ICAO Doc 9995 contains modules with three phases: the evaluation phase, the manoeuvres training phase, and the scenario-based training phase. In order to comply with the existing regulatory framework, LPC and OPC requirements are fulfilled by a combination of the evaluation phase and the manoeuvres validation phase, which replaces the manoeuvres training phase described in EASA EBT programme or ICAO Doc 9995. The manoeuvres validation phase is defined in Section 3 below. This is a form of mixed EBT implementation, which is described as follows: 1. Evaluation phase: This includes check scenarios referred to in Part-FCL Appendix 9 within an accepted EBT programme. In order to facilitate the provision of simple and realistic scenarios in accordance with ICAO Doc 9995 Chapters 3.8 and 7.4, the evaluation phase is not intended to be a comprehensive assessment of all Part-FCL Appendix 9 items; nevertheless, the list below includes the items that should be included in the evaluation phase only. Part-FCL or Description Part-ORO reference A H The examiner may choose between different skill test or proficiency check scenarios containing simulated relevant operations developed and approved by E E the competent authority. Full-flight simulators and other training devices, when R L available, shall be used, as established in this Part. O I P C Part-FCL Appendix 9 L O Paragraph 6 A P N T E E S R S TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 38 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail A The test/check should be accomplished under instrument flight rules (IFRs), if Part-FCL Appendix 9 instrument rating (IR) is included, and as far as possible be accomplished in a E Paragraph 16 of simulated commercial air transport environment. An essential element to be R checked is the ability to plan and conduct the flight from routine briefing section B O material. P Use of checklist prior to starting engines, starting procedures, radio and Part-FCL Appendix 9 L navigation equipment check, selection and setting of navigation and Item 1.4 communication frequencies. A N Part-FCL Appendix 9 Before take-off checks. E Item1.6 S Adherence to departure and arrival routes and ATC instructions. Part-FCL Appendix 9 The starred item (*) shall be flown solely by reference to instruments. If this Item 3.9.1* condition is not met during the skill test or proficiency check, the type rating will be restricted to VFR only. H 2. In case of proficiency check for an IR the applicant shall pass section 5 of the proficiency check. Failure in more than three items will require the applicant to E Part-FCL Appendix 9 take the entire section 5 again. An applicant failing not more than three items L Paragraph 2 of section shall take the failed items again. Failure in any item of the re-check or failure in C I any other items of section 5 already passed will require the applicant to take the entire check again. C O Part-FCL Appendix 9 Starting procedures, radio and navigation equipment check, selection and P Item 1.3. setting of navigation and communication frequencies T Part-FCL Appendix 9 Taxiing/air taxiing in compliance with air traffic control instructions or with instructions E Item 1.4 of an instructor R Part-FCL Appendix 9 S Pre-take-off procedures and checks Item 1.5 Adherence to departure and arrival routes and ATC instructions Part-FCL Appendix 9 The starred item (*) shall be flown solely by reference to instruments. If this condition is Item 5.2* not met during the skill test or proficiency check, the type rating will be restricted to VFR only. 2. Manoeuvres validation phase: The purpose of the manoeuvres validation phase is to check the handling skills necessary to fly critical flight manoeuvres so that they are maintained to a defined level of proficiency. This replaces the manoeuvres training phase described in ICAO Doc 9995 Chapter 7.5 and ORO.FC.231(a)(2)(iii)(B). Manoeuvres in this context are not part of line-orientated flight scenario; they TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 39 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail are a sequence of deliberate actions to achieve a prescribed flight path or to perform a prescribed event to a prescribed outcome. All remaining items listed in Part-FCL Appendix 9, and not included in the evaluation phase, should be included here. The manoeuvres listed in Doc 9995 or EASA table of assessment and training topics for the manoeuvres training phase that do not form part of the Part-FCL Appendix 9 mandatory items may be trained after the manoeuvres validation phase. 3. Scenario-based training phase: The purpose of the scenario-based training phase is to further develop pilot core competencies in a learning environment. This does not form part of any LPC or OPC requirement. It should be noted that if the operator is following an alternative means of compliance to ORO.FC.230 (b) Operator Proficiency Check, the equivalence of using EBT evaluation and manoeuvres validation phases may no longer exist. Additional guidance on mixed EBT implementation is available in the EASA checklist ‘Oversight guidance for transition to EBT’. ORO.FC.231 Evidence-based training (a) EBT PROGRAMME (1) The operator may substitute the requirements of ORO.FC.230 by implementing an EBT programme approved by the competent authority. The operator shall demonstrate its capability to support the implementation and perform a safety risk assessment demonstrating how an equivalent level of safety is achieved. (2) Features of the operator’s approved EBT programme The operator’s approved EBT programme shall: (i) assess and develop the competencies required by flight crew members for safe, effective and efficient operations of aircraft; (ii) ensure flight crew members are exposed to assessment and training topics derived from a large-scale analysis of operational data, distributed across a 3-year period at a defined frequency relevant to the type or variant of aircraft on which they operate; (iii) consist of modules conducted in the following sequence: (A) evaluation phase, comprising a line-orientated flight scenario (or scenarios) to assess competencies and identify individual training needs; (B) manoeuvres training phase, comprising training to proficiency in certain defined manoeuvres; and (C) scenario-based training phase, a comprising line-orientated flight scenario (s) and in- seat instruction to develop competencies and address individual training needs; and (iv) be delivered by instructors trained and qualified to ensure the effectiveness of learning. (3) The operator shall ensure that each flight crew member: (i) is enrolled in the EBT programme; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 40 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (ii) completes a minimum of 2 modules within the validity period of 12 months, separated by a period of not less than 3 months. The module is completed when: (A) the content of the approved EBT programme is completed for that module; and (B) an acceptable level of performance in all observed competencies has been demonstrated; and (C) will not continue line operations if during a module the performance observed was below the minimum acceptable level. The flight crew member continues line operations when a module is completed. (4) The operator shall establish an instructor concordance assurance programme. (i) Relevant metrics must be used to support this programme. (ii) All instructors must be subject to this programme. (iii) Sufficient instructor concordance must be demonstrated. (5) The operator shall include contingency procedures for unforeseen circumstances that may affect the delivery of the modules. It may include a different separation period between modules. ORO.FC.231 The EBT programme and philosophy are intended to be applied as the means of assessing and training key areas of flight crew performance in a recurrent training system. This is referred to in ICAO Annex 6, Operation of Aircraft, Part I, International commercial Air Transport — Aeroplanes, SARP 9.3, Flight crew member training programmes, and 9.4.4, Pilot proficiency checks. In addition, it is also referred to in ICAO Annex 1, Personnel Licensing, 1.2.5, Validity of licenses. The EBT programme considers the differences between aeroplane generations by tailoring the recurrent training programme to the aeroplane generation. The paradigm shift proposed under the EBT programme is not simply to replace a set of critical events with a new set, but to use the events as a vehicle for assessing and developing crew performance across a range of competencies. In addition, EBT refocuses the instructor population onto analysis of the root causes to correct inappropriate actions, rather than simply asking a flight crew member to repeat a manoeuvre with no real understanding as to why it was not successfully flown in the first instance. Finally, it is acknowledged that in today’s high-fidelity simulator environment, very sophisticated training tools exist that are often not used effectively, as regulation focus much more towards checking. EBT seeks to redress the imbalance between training and checking. It recognises that an assessment of competence is necessary, but once completed, pilots learn more effectively when being trained by competent instructors to perform tasks and manage events measured according to a given set of OBs, while not under test conditions. The data analyses undertaken to support the EBT programme illustrate inadequacies in the perpetuation of historical airline flight training regimes and identify areas in which major change is necessary. They strongly support the implementation of such change in both the regulation and development of recurrent airline pilot assessment and training. Finally, they identify the areas for improvement, providing the prioritisation of relevant training topics to guide in the construction of suitable EBT programmes. ORO.FC.231 point (a)(2) wording ‘the features of the approved EBT programme’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 41 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(a)(2) provides a more detailed presentation of the features of an operator’s EBT approved programme. The term ‘features’ is used in the Air OPS Regulation (for example, in GM4 ORO.FC.220&230 on UPRT). The term ‘approved EBT programme’ is used instead of simply ‘EBT programme’. ‘EBT programme’ is referred in point (a) to ORO.FC.231 and related AMC. ‘EBT programme’ is generic to an aircraft generation while the ‘approved EBT programme’ is specific to the operator and fulfils all the requirements from point (a) to (i) in ORO.FC.231. ORO.FC.231 point (a)(2) wording ‘to assessment and training topics derived from a large-scale analysis of operational data’ The assessment and training topics are included in the ‘table of assessment and training topics’ (e.g. Appendix 2 to ICAO Doc 9995). The table defines also the frequency of training those topics. The programme is described at AMC level. This means that Alternative Means of compliance (AltMoC) can be also used to demonstrate compliance with the IR (in accordance with ORO.GEN.120 of the Air OPS Regulation). However, in order to seek for an approval, the operator should demonstrate that this change of the programme is subject to a proper study of the operational risks. Such a large study was conducted by a collaborative group (industry and the regulator) in the IATA data report for EBT. If operators would like to modify the ‘table of assessment and training topics’, a similar work must be carried out. ORO.FC.231point (a)(2)(ii) wording “3 year period” ‘3-year period’ instead of ‘3-year cycle’ as provided in Doc 9995 is used because: 1- The European rules generally use ‘period’ instead of cycle (see Part-ORO) 2- This NPA proposes the definition of ‘cycle’ that expresses the notion of one-year period. Therefore, if ‘3- year cycle’ is used, it may be confusing. ORO.FC.231 point (a)(2)(iii)(A) ‘evaluation’ The evaluation phase should consist of a line-orientated flight scenario during which there are one or more occurrences for evaluating one or more key elements of the required competencies. The root cause/contributing factor should be identified rather than the symptoms of any deficiency. This is not intended to be a comprehensive assessment of all areas of competency, nor a demonstration of all critical flight manoeuvres. During the evaluation phase, for any competency observed below minimum: — specific training needs should be determined; and — the subsequent SBT phase includes remediation and the flight crew member is not released to line flying until an acceptable level of performance is reached. ORO.FC.231 point (a)(2)(iii)(C) ‘in-seat instruction’ Effective monitoring and error detection are increasingly important when operating highly-reliable, automated aircraft. Multiple data sources illustrate substantial rates of undetected error. Error management is reported as a very significant countermeasure in current operations with one accident study espousing that it is the most significant tool available to pilots for the prevention of accidents. Furthermore, multiple data sources show that there is a high level of intentional non-compliance and so any error management strategy must TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 42 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail include greatly reducing its incidence. Error management skills are subject to decay. Error management currently does not form part of any strategy developed through the regulation of flight crew training so consequently it is lacking in most training programmes. It is a key topic and needs to be incorporated into training strategies in order to raise flight crew situation awareness and further develop the professional capabilities of pilots. When in training, flight crews are usually highly vigilant, and therefore the performance observed may not be representative of performance in normal routine operations. After extensive discussion, the worldwide international subject matter experts (SMEs) group that developed material for Doc 9995 concluded that an effective means to provide reliable exposure in FSTD training is to use a method called in-seat instruction (ISI). This is also an effective means to provide the recovery element of UPRT; data from LOC-I events regularly indicate a cognitive impairment of the pilot flying (PF) with the pilot monitoring (PM) often demonstrating a higher level of situational awareness (SA). When the PF does not immediately respond and act on monitoring calls, the PM takes control and recovers the aircraft. This approach is supported by both Airbus and Boeing in their guidance in recovery FSTD training, and has been integrated within the EBT programme. ORO.FC.231 point (a)(3)(ii) wording ‘by a period of not less than 3 months’ The RMG discussed the ICAO Annex 6 Part I Chapter 9 SARP 9.4.4 ‘Pilot proficiency checks’ where 2 checks a year are required, performed at least 4 months apart: ‘9.4.4 Pilot proficiency checks 9.4.4.1 The operator shall ensure that piloting technique and the ability to execute emergency procedures is checked in such a way as to demonstrate the pilot’s competence on each type or variant of a type of aeroplane. Where the operation may be conducted under instrument flight rules, the operator shall ensure that the pilot’s competence to comply with such rules is demonstrated to either a check pilot of the operator or to a representative of the State of the Operator. Such checks shall be performed twice within any period of one year. Any two such checks which are similar and which occur within a period of four consecutive months shall not alone satisfy this requirement.’ The RMG considers that these checks are not similar, as they are not repetitive training tasks or events, but evaluations in different scenarios. Therefore, a 3-month period is consistent with the European regulatory framework where the OPC in ATQP (ORO.FC.A.245) has a validity period of 6 months with the possibility to do it 3 months in advance. Furthermore, according to Doc 9995, this document is a means of compliance with the Annex 6 SARP under SARP 9.4.4. ‘This manual is intended to provide guidance to Civil Aviation Authorities, operators and approved training organizations in the recurrent assessment and training of pilots referred to in Annex 6 to the Convention on International Civil Aviation, Operation of Aircraft, Part I, International Commercial Air Transport — Aeroplanes, paragraphs 9.3, Flight crew member training programmes, and 9.4.4, Pilot proficiency checks.’ ORO.FC.231 point (a)(3)(iii) wording ‘line operations’ The use of the term ‘line operations’ allows for training flights. At the same time, it restricts line flying when a minimum performance is not achieved. EBT is an FSTD programme, therefore the recommendation is to provide such remedial training in the FSTD. However, the operator is allowed to conduct training flights and the pilot should be permitted to be trained in flight. This is especially relevant in small aircraft models, and although most of those models are not yet permitted in EBT, EASA has plans to incorporate them in the future. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 43 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The term ‘line operations’ is used in the Air OPS Regulation and although no definition is provided, its meaning is obvious. However, readers are invited to comment if a definition may be necessary. ORO.FC.231 point (a)(3)(iii) If a low performance is observed and there is no immediate opportunity for remedial training (e.g. unforeseen circumstances, sessions separated by several days apart with flight duty in the middle, etc.), the pilot should be removed from line operations until an acceptable level of performance can be achieved. ORO.FC.231 point (a)(4) ‘instructor concordance’ It is imperative that instructor concordance is regulated as a core aspect of an EBT programme, and should be held to high standards as it is one of the most critical drivers of data quality in an EBT programme. Concordance should be required to prevent a drift in instructor quality and concordance over time, especially in the non-technical competencies. AMC1 ORO.FC.231(a) Evidence-based training ASSESSMENT AND TRAINING TOPICS (a) The EBT programme is available to operators of the aeroplanes listed below. There is a table of assessment and training topics to support each generation listed, except Generation 1 (Jet). (b) Using the table, operators should develop a recurrent EBT programme. (c) Each table is specific to the aeroplane generation specified in the title. The component elements in the column headings of the matrix are as follows: (1) Assessment and training topic. A topic or grouping of topics derived from threats, errors or findings from data analysis, to be considered for assessment and mitigation by training. (2) Frequency. The priority of the topic to be considered in an EBT programme, according to evidence is linked to a recommended frequency. There are three levels of frequency: (i) A — assessment and training topic to be included with defined scenario elements during every EBT module; (ii) B — assessment and training topic to be included with defined scenario elements during every cycle; (iii) C — assessment and training topic to be included with defined scenario elements at least once in the three-year period of the EBT programme. (3) Flight phase for activation. The flight phase for the realisation of the critical threat or error in the assessment and training scenario. (4) Description (includes type of topic, being threat, error or focus). A description of the training topic. (5) Desired outcome (includes performance criteria or training outcome). Simple evaluative statements on the desired outcome. (6) Example scenario elements. The example scenario elements address the training topic and detail the threat and/or error that the crew are exposed to. Operators are encouraged to develop scenarios elements relevant to operations. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 44 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (7) Competency map. Competencies marked are those considered critical in managing the scenario. (d) The table of applicable aeroplane types by generation is provided in Appendix II. AMC1 ORO.FC.231 point (c)(2) ‘Frequency’ The explanation provided for frequency was not transposed from Doc 9995, because the document provides two different definitions in paragraphs 1.2.3 and 1.4.2 of Part II. The NPA provides a new definition for frequency using the new term ‘cycle’. This term is defined in Annex I (Definitions) to the Air OPS Regulation. The proposal reflects the intent of the provision of ICAO in regard to frequency. AMC2 ORO.FC.231(a) Evidence-based training GENERATION 4 (JET) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS The table of assessment and training topics applicable to Generation 4 (Jet) is provided in AMC2 to Appendix II — EBT programme. AMC3 ORO.FC.231(a) Evidence-based training GENERATION 3 (JET) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS The table of assessment and training topics applicable to Generation 3 (Jet) is provided in AMC3 to Appendix II — EBT programme. AMC4 ORO.FC.231(a) Evidence-based training GENERATION 3 (TURBOPROP) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS The table of assessment and training topics applicable to Generation 3 (turboprop) is provided in AMC4 to Appendix II — EBT programme AMC5 ORO.FC.231(a) Evidence-based training GENERATION 2 (JET) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS The table of assessment and training topics applicable to Generation 2 (Jet) is provided in AMC5 to Appendix II — EBT programme. AMC6 ORO.FC.231(a) Evidence-based training GENERATION 2 (TURBOPROP) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS The table of assessment and training topics applicable to Generation 2 (turboprop) is provided in AMC6 to Appendix II — EBT programme. AMC7 ORO.FC.231(a) Evidence-based training GENERATION 1 (JET) — EBT PROGRAMME — TABLE OF ASSESSMENT AND TRAINING TOPICS This AMC addresses the case of turbo-jet aeroplanes of the first generation. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 45 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Given the very small number of turbo-jet aeroplanes of the first generation in current use in commercial air transport operations and the lack of appropriate FSTD for recurrent training, it has not been deemed possible to provide a table of assessment and training topics for those aeroplanes and therefore it is not possible to apply EBT. AMC8 ORO.FC.231(a) Evidence-based training UPSET PREVENTION AND RECOVERY TRAINING (UPRT) FOR COMPLEX MOTOR-POWERED AEROPLANES WITH A MAXIMUM OPERATIONAL PASSENGER SEATING CONFIGURATION (MOPSC) OF MORE THAN 19 Operators approved for EBT should follow the provisions for upset prevention and recovery training (UPRT) contained in AMC1 ORO.FC.220&230 ‘Operator conversion training and checking & recurrent training and checking’. AMC8 ORO.FC.231(a) Although this NPA proposes to exempt operators implementing the EBT programme from ORO.FC.230 and its AMC, the UPRT provisions were reintroduced through this AMC8 ORO.FC.231(a) due to the importance of these provisions. Doc 9995 has not transposed the latest UPRT requirements of Doc 10011 AN/506 ‘Manual on aeroplanes upset prevention and recovery training’ first edition -2014. The first phase of RMT.0599 only addresses recurrent training and checking (ORO.FC.230); therefore, the requirements for the Operator Conversion course (ORO.FC.220) are not amended. AMC1 ORO.FC.220&230 is linked to both IRs ORO.FC.220 and ORO.FC.230; therefore, AMC8 ORO.FC.231(a) is just acknowledging the need to fulfil the UPRT provisions. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 46 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail SPT.012 — Safety promotion to ORO.FC.231(a) EBT programme (UPRT) UPSET PREVENTION AND RECOVERY TRAINING (UPRT) FOR COMPLEX MOTOR-POWERED AEROPLANES WITH A MAXIMUM OPERATIONAL PASSENGER SEATING CONFIGURATION (MOPSC) OF MORE THAN 19 The purpose of this table is to assist the operator in cross-mapping the requirements of UPRT in in ORO.FC.230 and how this objective is achieved in ORO.FC.231 EBT programmes. The example table is a compilation of the tables proposed by two different operators to their authorities. AMC1 ORO.FC.220&230 Operator conversion training and checking & recurrent training and checking UPSET PREVENTION AND RECOVERY TRAINING (UPRT) FOR COMPLEX MOTOR-POWERED AEROPLANES WITH A MAXIMUM OPERATIONAL PASSENGER SEATING CONFIGURATION (MOPSC) OF MORE THAN 19 SEATS Current provision in AMC1 ORO.FC.220&230 Means of compliance in ORO.FC.231 – Appendix II Rationale Upset prevention training should: Ground training requirements are unchanged. FSTD requirements are (1) consist of ground training and flight training in an FSTD or an aeroplane; included in the EBT programme (2) include upset prevention elements from Table 1 for the conversion training course; and Does not apply to recurrent training and checking Applicability for EBT is determined by aircraft types and variants (3) include upset prevention elements in Table 1 for the recurrent training programme listed in ORO.FC.231 at least every 12 calendar months, such that all the elements are covered over a period not and only for those for exceeding 3 years. Equivalent to the ‘B’ level within the EBT Programme, all items to be which a suitably completed within the 3-year programme and some elements of UPRT qualified FSTD is to be included every year. available (4) All trainings could be done as PF and PM (the ones involved in MANUAL AIRCRAFT CONTROL must be done as PF) b. Upset recovery training should: (1) consist of ground training and flight training in an FFS qualified for the Included in the EBT programme as upset recovery. training task; All exercises, but especially the ones in Table 2 RECOVERY FROM TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 47 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (2) be completed from each seat in which a pilot’s duties require him or her to operate; DEVELOPED UPSETS, must be trained as PF and PM and strongly and recommended in manoeuvres TRAINING. (3) include the recovery exercises in Table 2 for the recurrent training programme, such that all the exercises are covered over a period not exceeding 3 years. (4) All trainings must be done as PF and PM. AMC1 ORO.FC.220&230 ‘Operator conversion Ground FSTD ORO.FC.231 – Appendix II - Example – suggested training and checking & recurrent training and ORO.FC.231 EBT phase training training relevant EBT ‘training topic and description’ checking’ A. Aerodynamics 1. General aerodynamic characteristics • 2. Aeroplane certification and limitations • Automation management Scenario-based training Manual aircraft control 3. Aerodynamics (high and low altitudes) • • or Upset recovery In-seat instruction (recoveries at low and high altitude) Automation management Scenario-based training Manual aircraft control Aeroplane performance (high and low 4. • • or Upset recovery altitudes) In-seat instruction (handling at low and high altitude, including degraded control modes) 5. Angle of attack (AOA) and stall awareness • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset recovery (stall recoveries according to OEM recommendations at low and high altitudes) 6. Stick shaker or other stall-warning device • • or Scenario-based training Automation management Manual aircraft control TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 48 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.220&230 ‘Operator conversion Ground FSTD ORO.FC.231 – Appendix II - Example – suggested training and checking & recurrent training and ORO.FC.231 EBT phase training training relevant EBT ‘training topic and description’ checking’ activation (as applicable) In-seat instruction Upset recovery (stall recoveries according to OEM recommendations at low and high altitudes) 7. Stick pusher (as applicable) • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset Recovery (stall recoveries according to OEM recommendations at low and high altitudes) 8. Mach effects (if applicable to the aeroplane • • or Scenario-based training Automation management type) Manual aircraft control In-seat-instruction Upset recovery (handling at low and high altitude, including degraded control modes) 9. Aeroplane stability • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset recovery (envelope and protections if applicable) 10. Control surface fundamentals • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset recovery (upset recoveries according to OEM recommendations at low and high altitudes) 11. Use of trims • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset recovery (upset recoveries according to OEM recommendations at low and high altitudes) 12. Icing and contamination effects • • Evaluation Adverse weather Scenario-based training TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 49 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.220&230 ‘Operator conversion Ground FSTD ORO.FC.231 – Appendix II - Example – suggested training and checking & recurrent training and ORO.FC.231 EBT phase training training relevant EBT ‘training topic and description’ checking’ 13. Propeller slipstream (as applicable) • • or Scenario-based training Automation management Manual aircraft control In-seat instruction Upset recovery (upset recoveries according to OEM recommendations at low and high altitudes) B. Causes of and contributing factors to upsets Adverse weather (Thunderstorm, heavy rain, turbulence, ice build-up to Evaluation & scenario-based include de-icing issues, as well as high temperature 1. Environmental • • training conditions. The proper use of use of anti-ice and de-icing systems should be included generally in appropriate scenarios) Upset recovery (upset recovery according to OEM recommendations at low and high altitudes) Monitoring & error detection (Develop scripted role-play scenarios encompassing the need to monitor flight path excursions from the instructor pilot (PF), detect errors and make appropriate 2. Pilot-induced • • In-seat instruction interventions, either verbally or by taking control as applicable. The scenarios should be realistic and relevant, and are for the purpose of demonstration and reinforcement of effective flight path monitoring. Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training) Aircraft malfunctions (Equivalency of malfunctions-general) Evaluation & scenario-based 3. Mechanical (aeroplane systems) • • or Characteristics: Loss of Instrumentation and Degraded training Control, both incorporated in the evaluation and scenario-based training phases of an operator’s approved TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 50 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.220&230 ‘Operator conversion Ground FSTD ORO.FC.231 – Appendix II - Example – suggested training and checking & recurrent training and ORO.FC.231 EBT phase training training relevant EBT ‘training topic and description’ checking’ EBT programme) C. Safety review of accidents and incidents relating to aeroplane upsets Contributing factors to upsets in general should be incorporated with appropriate competency links to relevant training topics within the EBT programme. This Safety review of accidents and incidents 1. • • or can relate to any training topic as appropriate. Examples relating to aeroplane upsets ALL may be adverse weather, workload distraction pressure, operations- or type-specific, monitoring and error detection. AMC1 ORO.FC.220&230 ‘Operator conversion Ground FSTD ORO.FC.231 –Appendix II - Example — suggested relevant training and checking & recurrent training and ORO.FC.231 EBT phase training training EBT training topic and description checking’ D. G-load awareness and management Evaluation & scenario-based Manual aircraft control training Positive/negative/increasing/decreasing 1. • • or In-seat instruction Upset recovery g-loads (upset recoveries according to OEM recommendations at low and high altitudes — where there are indications of g- load, they can be included) 2 Lateral g awareness (sideslip) • • or Evaluation & scenario-based Upset prevention/recovery training (upset recoveries according to OEM recommendations at low and high altitudes — where there are indications of g- load, they can be included) In-seat instruction TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 51 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 3 g-load management • • or Evaluation & scenario-based Upset prevention/recovery training (upset recoveries according to OEM recommendations at low and high altitudes — where there are indications of g- In-seat instruction load, they can be included) E. Energy management 1. Kinetic energy vs potential energy vs • • Evaluation & scenario-based Manual aircraft control chemical energy (power) training F. Flight path management 1. Relationship between pitch, power and • • Evaluation & scenario-based Automation management performance training Manual aircraft control 2. Performance and effects of differing • • Evaluation & scenario-based Automation management power plants (if applicable) training Manual aircraft control 3. Manual and automation inputs for • • Evaluation & scenario-based Automation management guidance and control training Manual aircraft control 4. Type-specific characteristics • • Evaluation & scenario-based Automation management training Manual aircraft control 5. Management of go-arounds from • • Evaluation & scenario-based Automation management various stages during the approach training Manual aircraft control Upset prevention 6. Automation management • • Evaluation & scenario-based Automation management training Manual aircraft control TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 52 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 7. Proper use of rudder • • Manoeuvres training Upset prevention/recovery This training can be combined with the Table 2 exercises G. Recognition 1. Type-specific examples of physiological, • • Manoeuvres training Upset prevention/recovery visual and instrument clues during This training can be combined with the Table 2 exercises developing and developed upsets 2. Pitch/power/roll/yaw • • Manoeuvres training Upset prevention/recovery This training can be combined with the Table 2 exercises 3. Effective scanning (effective monitoring) • • Manoeuvres training Upset prevention/recovery This training can be combined with the Table 2 exercises 4. Type-specific stall protection systems • • Manoeuvres training Upset prevention/recovery and cues This training can be combined with the Table 2 exercises 5. Criteria for identifying stalls and upsets • • Manoeuvres training Upset prevention/recovery This training can be combined with the Table 2 exercises H. System malfunction (including immediate handling and subsequent operational considerations, as applicable) 1. Flight control defects • • Evaluation & scenario-based Automation management training Manual aircraft control Knowledge TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 53 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 2. Engine failure (partial or full) • • Evaluation & scenario-based Automation management training Manual aircraft control 3. Instrument failures • • Evaluation & scenario-based Automation management training Manual aircraft control 4. Loss of reliable airspeed • • Evaluation & scenario-based Automation management training Manual aircraft control 5. Automation failures • • Evaluation & scenario-based Automation management training Manual aircraft control 6. Fly-by-wire protection degradations • • Evaluation & scenario-based Automation management training Manual aircraft control Knowledge 7. Stall protection system failures including • • or Evaluation & scenario-based Automation management icing alerting systems Training Manual aircraft control Manoeuvres training Manual handling skills I. (no autopilot, no autothrust/autothrottle and, where possible, without flight directors) 1. Flight at different speeds, including slow - • Evaluation & scenario-based Automation management flight, and altitudes within the full normal Training Manual aircraft control flight envelope 2. Procedural instrument flying and - • Evaluation & scenario-based Automation management manoeuvring including instrument training departure and arrival TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 54 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 3. Visual approach - • Evaluation & scenario-based Manual aircraft control training 4. Go-arounds from various stages during the - • or Evaluation & scenario-based Automation management approach training Manual aircraft control Manoeuvres training Upset prevention 5. Steep turns - • Manoeuvres training TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 55 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Table 2: Exercises for upset recovery training A. Recovery from developed upsets 1. Timely and appropriate intervention • • Manoeuvres training Upset prevention/recovery Flight crew must be trained as PF and PM and (strongly recommended in manoeuvres TRAINING. Recovery from stall events in the following • • Manoeuvres training Upset prevention/recovery configurations: take-off configuration, clean Flight crew must be trained as PF and PM and (strongly configuration low altitude, clean recommended) in manoeuvres TRAINING. 2. configuration near maximum operating Due to the protections in flight envelope in the 4th altitude, and landing configuration during generation aircrafts, the take-off upsets can be trained as the approach phase. final APP stall/ Go around 3. Recovery from nose high at various bank • • Manoeuvres training Upset prevention/recovery angles Flight crew must be trained as PF and PM and (strongly recommended) in manoeuvres TRAINING. 4. Recovery from nose low at various bank • • Manoeuvres training Upset prevention/recovery angles Flight crew must be trained as PF and PM and strongly recommended in manoeuvres TRAINING. 5. Consolidated summary of airplane recovery • • Manoeuvres training Upset prevention/recovery techniques Flight crew must be trained as PF and PM and (strongly recommended) in manoeuvres TRAINING. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 56 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail GM1 ORO.FC.231(a) Evidence-based training RECURRENT CREW RESOURCE MANAGEMENT (CRM) Operators implementing EBT in accordance with ORO.FC.231 may demonstrate compliance with ORO.FC.115 by showing how the recurrent CRM requirements are integrated within the operator’s EBT programme. An example of how this may be done is provided in the safety promotion material of EASA (e.g. ‘Oversight guidance for transition to EBT Implementation’). AMC9 ORO.FC.231(a) Evidence-based training EBT PROGRAMME — SCENARIO ELEMENTS AND COMPETENCY MAPPING (a) The operator may develop scenario elements and a competency map that are more relevant to its operation. (b) When developing scenario elements, the operator should ensure there can be no negative training by asking pilots to induce their own errors. (c) Competencies mapped are those considered critical in managing the scenario. They are determined according to the following principles: (1) those competencies considered most critical to the successful management of the defined threat or error; or (2) those competencies most likely to be linked to the root cause of poor performance in the case of unsuccessful management of a defined threat or error. (d) The competency map may indicate scenarios or combinations of scenarios for development of particular competencies. (e) The competency map indicates the most critical competencies suggested by design, but the instructor should always assess all observed competencies. GM2 ORO.FC.231(a) Evidence-based training EBT PROGRAMME — COMPETENCY MAP PROCESS Note 1. The competency map process may be done in teams of instructors. Each instructor should use a scale 1 to 5 for each competency for each scenario element. Then the results are compared and reconciled by a small group of subject matter experts (SMEs). Note 2. It is always easy to map SAW or KNO as underlying competency, but there are almost invariably other competencies, especially when there is ineffective management, so the intent should be to balance the mapping of SAW or KNO and map the other predominant competencies within the scenario. AMC9 ORO.FC.231(a) EBT programme and GM2 ORO.FC.231(a) The purpose of AMC9 is to allow operators to develop their own scenario elements and competency map to better reflect their operational environment, while maintaining the integrity of the EBT programme. Therefore, the training topics and frequency as per the table of assessment and training topics should not be amended by the operator as they derive directly from the ‘Data report for Evidence-Based Training’20 (AMC2 20 st IATA Data Report for Evidence-Based Training August 2014 1 Edition. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 57 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail to AMC7), while the example scenario elements and their associated competency map may be adapted without using the AltMoC procedure (ORO.GEN.120). This provision is a transposition of the Doc 9995 Paragraph 1.2.8. Purpose To give an indication of the most likely critical competencies required for effective management of the scenario or manoeuvre (considering the management of a threat or combination of threats). Process The nominated person for crew training or EBT manager designs one or more example scenario elements, including a description and an outcome. The competency map process is as follows: The competency map process should be undertaken by subject matter experts (SMEs), who hold or have held a type rating on the aeroplane type. Steps of the competency map process: 1. Using the description of the scenario element, SME instructors determine the competencies most likely to be required for effective management of the scenario element. Generally, about 3 competencies may be selected. 2. SME instructors determine which competencies are most likely to be the root cause(s) of poor performance. Note 1. This was done in teams of instructors, and it is for mapping purposes only. If there is a desire to be more accurate, ask two groups of instructors to review and suggest the competencies following this methodology. Each instructor should use a scale (for example, 1 to 5) for each competency for each scenario element. The following instructors should perform the same analysis independently, and then the results are compared and reconciled by a small group of SME instructors training. Note 2. It is always easy to code (SAW) or knowledge (KNO) as underlying, but there are almost invariably other competencies, especially when there is ineffective management, so the intent should be to balance the mapping of SAW or KNO and map the other predominant competencies within the scenario. Note 3: A similar process is described in ‘equivalency of malfunctions’ (see Delphi). AMC9 ORO.FC.231(a) point (e) The intent of this provision is to highlight that the competency map should not drive the instructor’s observations; instead, the instructor should observe the simulator session with a neutral observation, without focusing on the particular competencies mapped and make neutral assessment of all competencies. For the instructors, the competency map is intended to guide them on what they should expect to observe; however, this does not mean that they should ignore useful learning points for other competencies not mapped within that example scenario. AMC1 ORO.FC.231(a)(1) Evidence-based training (a) MINIMUM EXPERIENCE TO SUBSTITUTE ORO.FC.230 The operator should have a minimum experience of 2 years of a mixed EBT programme (mixed EBT implementation). Note: More information on a mixed EBT programme is provided in GM1 ORO.FC.230(a);(b);(f) and in GM2 ORO.FC.A.245. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 58 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (b) SUBSTITUTION OF THE REQUIREMENTS OF ORO.FC.230 One complete EBT module substitutes a complete operator proficiency check (OPC). AMC1 ORO.FC.231(a)(1) point (a) EASA believes that the transition from legacy training to EBT requires experience in the use of data, competency framework, grading system and instructor concordance assurance. Furthermore, a clear baseline for the training system performance must be established before any alleviation or competency-based licence revalidation can be achieved. Finally, the competent authority must be able to transition and be able to observe changes in the operator processes that support EBT. This requires time. AMC1 ORO.FC.231(a)(1) point (b) This provision is introduced because other parts of the Regulation refer back to ‘proficiency check’. For example, in SPA.LVO.120 the low-visibility training provisions have a frequency of ‘every operator proficiency check’. Therefore, this provision is needed to indicate that a complete OPC is substituted by a complete EBT module, while an LPC is completed by at least two EBT modules as described in Appendix 10 to Part-FCL. Furthermore, this provision is introduced in order to provide clarity in FCL.740 point (a)(3) ‘A pilot working for a commercial air transport operator approved in accordance with the applicable air operations requirements who has passed the operators proficiency check combined with the proficiency check for the revalidation of the class or type rating shall be exempted from complying with the requirement in (2)’. The wording ‘complete’ is to ensure alignment with the current regulation — for example: ‘ORO.FC.230 Recurrent training and checking (a) Each flight crew member shall complete recurrent training and checking relevant to the type or variant of aircraft on which they operate. (b) Operator proficiency check (1) Each flight crew member shall complete operator proficiency checks as part of the normal crew complement to demonstrate competence in carrying out normal, abnormal and emergency procedures. […]’ AMC1 ORO.FC.231(a)(2) Evidence-based training EBT PROGRAMME FEATURES An operator’s approved EBT programme is one in which: (a) training is focused on development of competencies, rather than repetition of tasks; (b) the development of the programme is based on data-driven EBT training topics with a link to the operator’s competency framework; (c) training needs are addressed through training based on underlying competencies; (d) the programme includes: TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 59 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (1) an evaluation phase to identify training needs based on competencies and collect population- based data; and (2) a scenario-based training phase to focus on identified training needs based on competencies rather than repetition of tasks; (e) the programme includes the conduct of objective observations based on a competency framework, and documents evidence of the behaviour observed; (f) instructors grade competencies based on observable behaviour (OB); (g) instructors have sufficient concordance and completed EBT instructor standardisation; (h) analyses of trainee performance are used to determine competency-based training needs and recognise strengths; (i) performance is evaluated using a competency-based grading system; (j) there is a range of teaching styles during simulator training to accommodate trainee learning needs; and (k) facilitation techniques in debriefing are incorporated. AMC1 ORO.FC.231(a)(2) point (d) The evaluation phase is a first look to assess competencies, determined training system effectiveness and indicate individual training needs. On completion of the evaluation phase, any areas that do not meet the minimum competency standard will become the focus of the subsequent training. AMC1 ORO.FC.231(a)(2) point (g) EBT instructor standardisation refers to AMC1 ORO.FC.145(a)(2). AMC1 ORO.FC.231(a)(2) point (k) Facilitation is a very important part of EBT and therefore the RMG introduced this requirement. The authority requirements (Part-ARO) developed for the oversight of EBT provide a direct link to the features of the EBT programme. This is an approach similar to that applied for the oversight of CRM (AMC3 ARO.GEN.200(a)(2) provides a reference to CRM and the details such us ‘facilitation’ are provided in Part-ORO). Although CRM in Part-ORO already provides a reference to facilitation, it was introduced here to have all the information in one place. AMC1 ORO.FC.231(a)(2)(iv) Evidence-based training PERSONNEL PROVIDING ASSESSMENT AND TRAINING (a) Ground and refresher training should be provided by suitably qualified personnel. (b) Flight training should be provided by a flight instructor (FI), type rating instructor (TRI) or class rating instructor (CRI) or, in the case of the FSTD content, a synthetic flight instructor (SFI), providing that the FI, TRI, CRI or SFI satisfies the operator's standardisation, experience and knowledge requirements. (c) Emergency and safety equipment training should be provided by suitably qualified personnel. (d) CRM should be provided by EBT instructors or, for the classroom CRM training, one CRM trainer qualified as specified in AMC3 ORO.FC.115. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 60 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(a)(2)(iv) This provision is transposed from AMC1 ORO.FC.230 point (d) with the necessary amendments. It includes the provision to allow CRM training by EBT instructors as they have completed the EBT instructors standardisation. This provision must be read in conjunction with ORO.FC.145; therefore, when EBT training is delivered, instructors must be provided with an EBT standardisation course. When other training is provided which is not part of EBT, then only point (b) applies (no combination with ORO.FC.145). A classic example would be ‘aerodrome qualification’ category C, where a regular instructor would provide such training unless the qualification is delivered in conjunction with the EBT programme. AMC1 ORO.FC.230 point (d) reads as follows: ‘(d) Personnel providing training and checking Training and checking should be provided by the following personnel: (1) ground and refresher training by suitably qualified personnel; (2) flight training by a flight instructor (FI), type rating instructor (TRI) or class rating instructor (CRI) or, in the case of the FSTD content, a synthetic flight instructor (SFI), providing that the FI, TRI, CRI or SFI satisfies the operator's experience and knowledge requirements sufficient to instruct on the items specified in points (a)(1)(i)(A) and (B); (3) emergency and safety equipment training by suitably qualified personnel; (4) CRM: (i) integration of CRM elements into all the phases of the recurrent training by all the personnel conducting recurrent training. The operator should ensure that all personnel conducting recurrent training are suitably qualified to integrate elements of CRM into this training; (ii) classroom CRM training by at least one CRM trainer, qualified as specified in AMC3 ORO.FC.115 who may be assisted by experts in order to address specific areas’. GM1 ORO.FC.231(a)(2)(iii)(C) Evidence-based training EBT PROGRAMME — IN-SEAT INSTRUCTION (ISI) (a) Effective monitoring and error detection are increasingly important when operating highly-reliable automated aircraft. (b) In-seat instruction may be used as a valuable tool to maintain and develop training topics, including skills of monitoring, cross-checking, error management, and recognition of mismanaged aircraft state. GM1 ORO.FC.231(a)(2)(iii)(C) The explanatory note about ISI is provided for the IR. This GM clarifies and complements the table of assessment and training topics in regard to ISI. The RMG and EASA agreed that some elements in the ICAO baseline programme classified as frequency A in ISI and in regard to ‘example scenarios’ and ‘competency map’ are incorrect. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 61 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail In addition, with regard to the training topic ‘monitoring, cross checking, error management, and mismanaged aircraft state’, Doc 9995 titles the topic as in-seat instruction (ISI). EASA believes there is an inconsistency because ISI is a means to deliver a training topic and not a training topic (see definition of ISI). Therefore, ISI is removed from the training topics. Furthermore, the IATA Data report for EBT does not identify that the means and the only means to deliver such topic (monitoring, cross-checking, error management, mismanaged aircraft state) should be ISI. It also has to be noted that effective monitoring and error detection as well as error management, mismanaged aircraft state, compliance and cross-checking topics are also embedded in the observance of the behavioural indicators. This way, they are present in all of the EBT FTSD sessions, and any observance of deficiencies should be taken as a learning opportunity, identifying the root cause/contributing factor, and discussed during the subsequent ‘facilitated debriefing’. AMC1 ORO.FC.231(a)(3)(i) Evidence-based training EBT PROGRAMME — ENROLMENT (a) Enrolment is when a flight crew member commences the first EBT module. (b) A flight crew member is considered to be de-enrolled when the operator is no longer responsible for the administrative action for the flight crew’s licence revalidation under an approved EBT programme. (c) Applicants who fail to demonstrate an acceptable level of competence and are de-enrolled from the operator’s approved EBT programme should not exercise the privileges of that type rating. AMC1 ORO.FC.231(a)(3)(i) This requirement is to maintain the integrity of the EBT programme. The EBT programme will be the means to revalidate pilots’ licence: the revalidation will not be based on a single simulator event, but instead on multiple simulator events. This requires clarity as to when the pilot joined the EBT programme. Normally, this will occur in the operator conversion course where an EBT module (equivalent to an OPC) is planned. This provision also has relevance in the cases of long-term sickness or long leave of absence where the pilot discontinued the training programme. AMC1 ORO.FC.231(a)(4) Evidence-based training INSTRUCTOR CONCORDANCE ASSURANCE PROGRAMME (a) The concordance assurance programme must be able to identify areas of weak concordance in order to drive improvement in the quality and validity of the grading data. (b) The programme should identify good concordance and address those instructors who do not meet the standards required. AMC1 ORO.FC.231(a)(4) Point (a) provides a requirement from a systemic view (e.g. the programme must identify that instructors in a certain fleet have problems to grade non-technical competencies or that one competency is always graded too low. This may occur with ‘application of knowledge’ where instructors identify all the time ‘knowledge’ as the root cause for all pilot being deficient when they should not, leading thus to a low grading in ‘knowledge’). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 62 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Point (b) ensures that each individual instructor has the necessary concordance (e.g. my instructor Pepito Perez has problems to rate flight path management manual and therefore this has to be addressed). GM1 ORO.FC.231(a)(4) Evidence-based training INSTRUCTOR CONCORDANCE ASSURANCE PROGRAMME (a) The operator should have instructor concordance as a tool for continuous improvement of the EBT programme. (b) As the instructor plays a key role in the EBT programme, the quality and validity of the grading data must be guaranteed. Strong concordance ensures integrity of the EBT programme. (c) Minimum concordance standards are normally set by the operator; however, the competent authority may recommend certain criteria, especially when the revalidation of licences is performed under EBT. GM1 ORO.FC.231(a)(4) The use of the wording ’integrity of the EBT programme’ in point (b) means that: 1. the programme addresses the shortcomings of pilot performance in competencies; and 2. the training system performance ensures the improvement of the pilot is real. Safety promotion material — relevant metrics to support the programme EASA has planned a safety promotion task (SPT.012) to support the implementation of EBT. The following material has been developed to explain the intent of the wording used in the implementing rule ‘relevant metrics must be used to support this programme’, and other concepts used in this regulatory proposal: SPT.012 ORO.FC.231(a)(4) — safety promotion task 012 — safety material for EBT — CONCORDANCE RELEVANT METRICS MUST BE USED TO SUPPORT THIS PROGRAMME; Concordance must be analysed independently per competency, and, if possible, segregated between different levels of competency assessment. This serves to identify whether concordance varies between competencies or between levels of assessment, providing guidance that is more accurate in order to improve concordance. Assessing concordance between instructors should make use of statistical methods, gauging both individual instructor metrics as well as group instructor metrics. Different statistics may be appropriate for different types of measurement. Some options are: joint-probability of agreement, Cohen's kappa, Scott's pi and the related Fleiss' kappa, inter-rater correlation, concordance correlation coefficient, and intra-class correlation. Individual assessments should assess to what extent an individual aligns with predefined standards for the reference material (e.g. correlation analysis) and to what extent the individual’s ability to assess is improving or deteriorating over time (e.g. compared to previous concordance assessments). Group statistics may make use of group agreement (e.g. variance assessment) and group alignment (e.g. group averages compared to standards for the reference material). A high variance implies that a large number of instructors is not rating according to the standards set, and warrants investigation. Individual instructors that exhibit a large deviation from standards, consistent positive/negative bias or poor improvement/deterioration of their concordance with standards, must be considered for focused instructor training before re-engaged in EBT assessments. However, the investigation may determine that although an individual instructor exhibits a large deviation, the reason is not that this instructor is not standardised. The reason could be that the instructor is delivering a TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 63 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail different programme (e.g. always delivering a harder-than-usual EBT programme in preparation of command upgrades) or that the instructor is fundamentally conduct training to a specific group of pilots (e.g. those that require remedial training). Finally, when subcontracted instructors are used, the standardisation provided to them should be particularly considered. This group of instructors may not acquire the required concordance initially. In order to maintain the data integrity for instructor concordance, the operator should maintain data traceability for each group of instructors (airline and subcontracted) as the root cause for the good or bad performance of each group may be different as the background and environment of each group is different. Same principles may be necessary to be applied in other groups (e.g. mature instructors vs young instructors). CONTINUOUS IMPROVEMENT OF CONCORDANCE Metrics of instructor concordance must drive specific interventions in instructor training, the assessment framework used and/or the reference material developed. Instructor concordance must be submitted to a process of continuous improvement in order to safeguard against standards drift and concordance degradation. For this reason, these requirements do not specify statistical thresholds of minimum variance of concordance; however, improvement in concordance metrics should indicate whether the operator’s concordance programme is effective. Over time, as concordance improves, so will the reliability of EBT data. CONCORDANCE ASSURANCE AND EBT INSTRUCTOR RECURRENT STANDARDISATION (SEE GM2 ORO.FC.145(a)(3) point (c)) Instructor concordance may be verified by controlling the content to be assessed (reference material) such as flight recordings, scripted videos and/or case studies. Within each 3-year period, reference material should address every competency at a minimum of two levels per competency, such that concordance is assessed across the wide range of competency assessment that instructor must be proficient in. Reference materials may not be presented to the same instructor within 3 years in order to maintain true assessment of an instructor’s ability to assess accurately. Operators should strive to include a broad diversity of flight phases, situations and behaviours when developing reference material, and preferably integrate their own operations and SOPs. Reference material should be assessed using the same assessment framework used for actual EBT training delivery, and preferably assess not only the competency observation, but also the ability to assess root causes and identify subsequent training needs. Reference material should be supplemented with ‘correct’ ratings (i.e. answer sheet), such that instructor assessment can be compared against agreed-upon standards. The answer sheet should be composed by a core group of EBT instructors; preferably, rotating members to prevent standards drift and/or lasting bias. Instructor concordance may not be inferred from actual assessment data collected from EBT sessions when these sessions are not equivalent in terms of difficulty, competency distributions, etc. because this may not guarantee equal reference material between instructors. INSTRUCTOR CONCORDANCE The development of strong instructor concordance (inter-rater reliability) is critical for the validity of the EBT data collection. In a norm-referenced system, the operator must safeguard concordance between instructors. Minimum concordance standards are normally set by the operator; however, the competent authority may recommend certain criteria, especially when the revalidation of licences is performed under EBT. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 64 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Distribution of grades across the instructor community for the modules conducted should be recorded. This recording may be accessible to the instructors, normally a posteriori. Some airlines underweight the grading performed by an instructor with poor concordance to have accurate competency data. Underweight may only be needed in rare cases during mixed EBT; however, it should not happen during EBT baseline. However, this standard needs to be easy for the instructors allowing them to focus on the observation of the students and to provide training to them rather than crosschecking complicated criteria. AMC1 ORO.FC.231(a)(5) Evidence-based training CONTINGENCY PROCEDURES FOR UNFORESEEN FACTORS WHICH MAY AFFECT THE DELIVERY OF THE EBT PROGRAMME (a) The operator should detail in the EBT programme the contingency procedures in the event unforeseen factors occur which may affect the delivery of the operator’s approved EBT programme. (b) In case of unforeseen interruption of a module at any point, the missing parts of the module should be rescheduled. (1) The applicant may continue line flying until the expiry of the validity period unless the performance observed was below the minimum acceptable level. (2) If the interruption results in an instructor change, the operator must ensure that the instructor completing the module is provided with the details of the performance of the pilots. (c) In case the pilot misses modules and the pilot does not meet the requirements of recent experience (FCL.060): (1) when the pilot misses one module and has not completed 2 modules in the last 12 months, the evaluation phase of the missing module should be rescheduled before the pilot can resume line operations, and the manoeuvres and scenario-based training phases should be completed 30 days after the evaluation phase or before the expiry date whichever occurs first. (2) When the pilot misses one module in the preceding 12 months but the pilot’s rating is expired by less than 3 months, the missing module should be rescheduled before the pilot can resume line operations. (3) When the pilot misses one module in the preceding 12 months but the pilot’s rating is expired by longer than 3 months but shorter than 1 year, the missing module should be rescheduled using EBT instructor (s) with examiner privileges before the pilot can resume line operations. (4) When the pilot misses two modules and the pilot rating is valid: (i) one module should be rescheduled before line operations using EBT instructor(s) with examiner privileges; and (ii) the training topics B and C of the second module should be rescheduled before the expiry date. In such case, the 3-month separation requirement between modules may not apply. (5) When the pilot misses two modules and the pilot’s rating is expired by less than 1 year: (i) one module should be rescheduled using EBT instructor(s) with examiner privileges; and TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 65 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (ii) the training topics B and C of the second module before he/she can resume line operations. In such case, the period of 3-month separation between modules may not apply. (6) If the amount of time lapsed since the expiry of the rating is more than 1 year the pilot is de- enrolled AMC1 FCL.625(a) ‘IR — Validity, revalidation and renewal’ and AMC1 FCL.740(b)(1) ‘Validity and renewal of class and type ratings’ applies. (d) In the case of other situations not covered by points (b) or (c), point (a) applies. AMC1 ORO.FC.231(a)(5) point (b)(1) wording ‘unless the performance observed was below the minimum acceptable level’ The intent of the RMG is to allow line operations as long as the observed performance of the pilot was acceptable, provided the pilot was still in the validity period of the licence. However, if an unsafe performance was observed prior to an interruption, the candidate should not continue line operations until remedial training has been performed. There is a similar provision in Part-FCL where pilots shall not exercise the privileges of their licence if the LPC was failed even if their licence is still within the validity period. Description of ‘performance observed below the minimum acceptable level’ is provided in GM1 ORO.FC.231(d)(1) on GRADING SYSTEM – VENN. GM1 ORO.FC.231(a)(5) Evidence-based training EBT PROGRAMME — CONTINGENCY PROCEDURES — LICENCE REVALIDATION (a) The renewal of licences in EBT follows the Annex I (Part-FCL) to the Aircrew Regulation provisions ‘Renewal of class and type ratings’ (IRs and AMC) and it is complemented with the provisions covered in AMC1 ORO.FC.231(a)(5) for ‘contingency procedures for unforeseen factors’. The ATO or AOC will determine the amount of training following Part-FCL; however, as EBT combines assessment and training, the following guidance is applicable: (1) Expiry shorter than 3 months may not require additional training in Part-FCL. In EBT the missing module is rescheduled with an EBT instructor. Following that, the nominated person for crew training (or the deputy(ies)) for the type rating may renew the licence without extra training, as the EBT programme is now completed (at least 2 modules in the last 12 months). (2) In Part-FCL, when the expiry is longer than 3 months but shorter than 1 year, there need to be two training sessions. In EBT, there are be two cases: (i) One module is missing: the applicant must complete the missing module (2 simulator sessions) before line operations. Following that, the nominated person for crew training (or the deputy(ies)) for the type rating may renew the licence in accordance with Appendix 10 as the EBT programme is now completed (2 modules in the last 12 months). (ii) Two modules are missing: the applicant must complete one module (2 simulator sessions) and the training topics B and C (extra simulator session) with a total of 3 simulator sessions. Training data is gathered in a short time period; therefore, an EBT instructor with examiner privilege is introduced to ensure the proficiency of the pilot. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 66 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (b) In case of an expiry longer than 1 year, the requirements of (Annex I) Part-FCL will be followed and the proficiency checks will be performed in accordance with Appendix 9 as the EBT system may not have sufficient training data for the pilot: (1) Expiry longer than 1 year but shorter than 3 years: a minimum of three training sessions in which the most important malfunctions in the available system are covered plus a proficiency check in accordance with Appendix 9 to renew the licence. (2) Expiry longer than 3 years: the applicant should again undergo the training for the initial issue of the rating. GM1 ORO.FC.231(a)(5) The GM was drafted following AMC1 ORO.FC.231(a)(5) as proposed in this NPA and the existing AMC1 FCL.740(b)(1) ‘Validity and renewal of class and type ratings’. AMC1 FCL.625(c) IR — ‘Validity, revalidation and renewal’ was also considered. (b) COMPETENCY FRAMEWORKS The operator shall use a competency framework for all aspects of assessment and training within an approved EBT programme. The competency framework shall: (3) include observable behaviours required for safe, effective and efficient operations; and (4) be comprehensive, accurate, and usable. ORO.FC.231(b) Why is there a need to require a competency framework? Mastering a finite number of competencies should allow a pilot to manage situations in flight. The main benefit of a competency-based approach to training is its potential to encourage and enable individual aviation professionals to reach their highest level of operational capability while ensuring a basic level of competence as a minimum standard. PRINCIPLES OF A COMPETENCY FRAMEWORK — The purpose of competency-based assessment and training is to assess and train the capacity of an individual to perform at the standard expected in an organisational workplace. — There is an explicit link between competencies and training, required performance on the job, and assessment. — Competencies are formulated in a way that ensures they can be developed, observed and assessed consistently in a wide variety of work contexts for a given aviation profession or role. — Each stakeholder in the process including the trainee, instructor, training organisation, operator and regulator has a common understanding of the competency requirements. — Clear performance criteria are established for assessing competence. — Evidence of competent performance is valid and reliable. — Instructors’ and assessors’ judgments are calibrated to achieve a high degree of inter-rater reliability. — Assessment of competencies is based on multiple observations across multiple contexts. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 67 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail — Relevant competency framework is clearly defined for a particular role. — To be considered competent, an individual demonstrates an integrated performance of all the required competencies to a specified standard. ASSUMPTIONS — All tasks performed by aviation professionals require the application of a relevant set of competencies. — Aviation professionals apply the same set of competencies in a given role throughout their career but with different degrees of performance AMC1 ORO.FC.231(b) Evidence-based training COMPETENCY FRAMEWORK — GENERAL (a) The competency framework should include at least the following elements: (1) competencies; and (2) associated observable behaviours. RECOMMENDED COMPETENCY FRAMEWORK (b) The operator should include in their approved EBT programme a competency framework that, as a minimum, exhibits the following competencies: Application of procedures (APK) Competency description Identifies and applies procedures in accordance with published operating instructions and applicable regulations, using the appropriate knowledge. Observable behaviour Identifies the source of operating instructions. Follows SOPs unless a higher degree of safety dictates an appropriate deviation. Identifies and follows all operating instructions in a timely manner. Correctly operates aircraft systems and associated equipment. Complies with applicable regulations. Applies relevant procedural knowledge. Communication (COM) Competency description Demonstrates effective oral, non-verbal and written communications, in normal and non-normal situations. Observable behaviour Ensures the recipient is ready and able to receive the information. Selects appropriately what, when, how and with whom to communicate. Conveys messages clearly, accurately and concisely. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 68 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Confirms that the recipient correctly understands important information. Listens actively and demonstrates understanding when receiving information. Asks relevant and effective questions. Adheres to standard radiotelephone phraseology and procedures. Accurately reads and interprets required company and flight documentation. Accurately reads, interprets, constructs and responds to datalink messages. Completes accurate reports as required by operating procedures. Correctly interprets non-verbal communication. Uses eye contact, body movement and gestures that are consistent with and support verbal messages. Flight path management — automation (FPA) Competency description Controls the aircraft flight path through automation, including appropriate use of a flight management system (s) and guidance. Observable behaviour Controls the aircraft using automation with accuracy and smoothness as appropriate to the situation. Detects deviations from the desired aircraft trajectory and takes appropriate action. Contains the aircraft within the normal flight envelope. Manages the flight path to achieve optimum operational performance. Maintains the desired flight path during flight using automation whilst managing other tasks and distractions. Selects appropriate level and mode of automation in a timely manner considering phase of flight and workload. Effectively monitors automation, including engagement and automatic mode transitions. Flight path management ؅— manual control (FPM) Competency description Controls the aircraft flight path through manual flight, including appropriate use of a flight management system (s) and flight guidance systems. Observable behaviour Controls the aircraft manually with accuracy and smoothness as appropriate to the situation. Detects deviations from the desired aircraft trajectory and takes appropriate action. Contains the aircraft within the normal flight envelope. Controls the aircraft safely using only the relationship between aircraft attitude, speed and thrust. Manages the flight path to achieve optimum operational performance. Maintains the desired flight path during manual flight whilst managing other tasks and distractions. Selects appropriate level and mode of flight guidance systems in a timely manner considering phase of flight and workload. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 69 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Effectively monitors flight guidance systems including engagement and automatic mode transitions. Application of knowledge (KNO) Competency description Demonstrates knowledge and understanding of relevant information, operating instructions, aircraft systems and the operating environment. Demonstrates practical and applicable knowledge of limitations and systems and their interaction. Demonstrates required knowledge of published operating instructions. Demonstrates knowledge of the physical environment, the air traffic environment including routings, weather, airports and the operational infrastructure. Demonstrates appropriate knowledge of applicable legislation. Knows where to source required information. Demonstrates a positive interest in acquiring knowledge. Is able to apply knowledge effectively. Leadership and teamwork (LTW) Competency description Demonstrates effective leadership and team working. Observable behaviour Understands and agrees with the crew’s roles and objectives. Creates an atmosphere of open communication and encourages team participation. Uses initiative and gives directions when required. Admits mistakes and takes responsibility. Anticipates and responds appropriately to other crew members’ needs. Carries out instructions when directed. Communicates relevant concerns and intentions. Gives and receives feedback constructively. Confidently intervenes when important for safety. Demonstrates empathy and shows respect and tolerance for other people. Engages others in planning and allocates activities fairly and appropriately according to abilities. Addresses and resolves conflicts and disagreements in a constructive manner. Projects self-control in all situations. Problem-solving and decision-making (PSD) Competency description Accurately identifies risks and resolves problems. Uses the appropriate decision-making processes. Observable behaviour Seeks accurate and adequate information from appropriate sources. Identifies and verifies what and why things have gone wrong. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 70 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Employ(s) proper problem-solving strategies. Perseveres in working through problems without reducing safety. Uses appropriate and timely decision-making processes. Sets priorities appropriately. Identifies and considers options effectively. Monitors, reviews, and adapts decisions as required. Identifies and manages risks effectively. Improvises when faced with unforeseeable circumstances to achieve the safest outcome. Situation awareness (SAW) Competency description Perceives and comprehends all of the relevant information available and anticipates what could happen that may affect the operation. Observable behaviour Identifies and assesses accurately the state of the aircraft and its systems. Identifies and assesses accurately the aircraft’s vertical and lateral position, and its anticipated flight path. Identifies and assesses accurately the general environment as it may affect the operation. Keeps track of time and fuel. Maintains awareness of the people involved in or affected by the operation and their capacity to perform as expected. Anticipates accurately what could happen, plans and stays ahead of the situation. Develops effective contingency plans based upon potential threats. Identifies and manages threats to the safety of the aircraft and people. Recognises and effectively responds to indications of reduced situation awareness. Workload management (WLM) Competency description Manages available resources efficiently to prioritise and perform tasks in a timely manner under all circumstances. Observable behaviour Maintains self-control in all situations. Plans, prioritises and schedules tasks effectively. Manages time efficiently when carrying out tasks. Offers and accepts assistance, delegates when necessary and asks for help early. Reviews, monitors and cross-checks actions conscientiously. Verifies that tasks are completed to the expected outcome. Manages and recovers from interruptions, distractions, variations and failures effectively. AMC1 ORO.FC.231(b) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 71 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail This is an example of a competency framework that was developed for EBT by a large expert industry working group based upon systems tested and validated in operational use today. The availability of a worldwide- harmonised framework of competencies is of great value. An identical competency framework can be applied to both baseline and enhanced EBT programmes. Pilot core competencies were developed to support the EBT concept adopted by ICAO in 2013. An international industry working group was established in 2007. The EBT and Instructor Qualification group began work in early 2008. The Group was mostly comprised of expert practitioners in pilot training from almost 50 organisations worldwide. The group met every 2 months over a period from early 2008 until end of 2011. The group decided that the first and critical step in the development of EBT was to identify a complete framework of performance indicators, in the form of observable actions or behaviours, usable and relevant across the complete spectrum of pilot training for CAT operations. These competencies and performance indicators combine the technical and non-technical (CRM) knowledge, skills and attitudes that have been considered essential for pilots to operate aircraft safely, efficiently and effectively. The development of pilot core competencies was considered as the first important step towards the creation of the ‘total systems approach to training’. After extensive consultation and discussion, the framework of behaviours was developed, divided into 8 core competencies, each with observable performance indicators. The competencies were published in Doc 9995. The core competencies are primarily an assessment tool, offering a different approach from the evaluation of outcomes and manoeuvres, the purpose being to understand and remediate root causes of performance difficulties, rather than addressing only the symptoms. The purpose of these performance indicators is to underpin the creation of performance expectations at all stages of training in a pilot’s career. To complete the picture, a fair and usable system of grading performance is also required, and instructors using it should be trained and assessed themselves as competent in its use. The publication of Doc 9995 limits the applicability of EBT to recurrent training conducted in a qualified FSTD, but it has been always anticipated that the example framework of core competencies agreed should be applied to all aspects of initial and recurrent pilot training for CAT operations, including pilot selection and instructor pre-selection. A number of ‘behavioural marker’ systems were considered, and the group chose the most relevant and appropriate, and developed them further to include technical competencies and associated performance indicators. The behavioural marker system was the one published by the UK CAA in CAP 737 in 2005, in service across a wide range of cultures since 2002. The system has been validated through operational use. By far the most significant challenge for operators using these competency frameworks is the creation of an effective performance assessment and grading system, and subsequently the need for instructor training and the assurance of instructor concordance. Finally, the competency framework of EBT provides a good process for the training needs analysis. The competencies in EBT provide a hierarchy and they are linked between them. There are some competencies that the pilot cannot reach without having first other ones. For example, in order for the pilot to have a strong competency in ‘leadership and teamwork’, it is necessary to be good at ‘communications’, and probably good at ‘workload management’. At the same time, in order to be good at ‘workload management’, being good at ‘flight path management — automation’ or ‘flight path management — manual’, depending on the scenario, is as well TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 72 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail necessary. An example of a possible route cause analysis is shown below. Problem-solving & Leadership & teamwork decision-making Workload Communication Situation awareness management Application of Flight path management — Flight path management — procedures automation manual Application of knowledge AMC1 ORO.FC.231(b) ICAO will amend the EBT competency framework provided in Doc 9995. The new model is based on the ICAO competency framework for aeroplane pilots contained in Part II, Section 1, Chapter 1 of PANS-TRG (it may be approved in 2019 and it may be applicable in November 2020). The proposed model may be discussed by the review group and EASA may decide to include it in the final version of the EBT regulation. In the meantime, this model is included in the explanatory note for stakeholders’ awareness. See below the new competency map: ICAO competency Description Observable behaviour — Identifies where to find procedures and regulations — Applies relevant operating instructions, procedures and techniques in a timely Identifies and manner applies appropriate Application of procedures in — Follows SOPs unless a higher degree of safety procedures and accordance with dictates an appropriate deviation compliance with published operating regulations instructions and — Operates aeroplane systems and associated applicable equipment correctly regulations. — Monitors aircraft systems status — Complies with applicable regulations. — Applies relevant procedural knowledge TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 73 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ICAO competency Description Observable behaviour — Determines that the recipient is ready and able to receive information — Selects appropriately what, when, how and with whom to communicate — Conveys messages clearly, accurately and concisely — Confirms that the recipient demonstrates understanding of important information Communicates — Listens actively and demonstrates through appropriate means in the understanding when receiving information operational — Asks relevant and effective questions Communication environment, in both normal and — Uses appropriate escalation in non-normal communication to resolve identified situations deviations — Uses and interprets non-verbal communication in a manner appropriate to the organisational and social culture — Adheres to standard radiotelephone phraseology and procedures — Accurately reads, interprets, constructs and responds to datalink messages TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail ICAO competency Description Observable behaviour — Uses appropriate flight management, guidance systems and automation, as installed and applicable to the conditions (see Part I, Chapter 1, definitions) — Monitors and detects deviations from the intended flight path and takes appropriate action — Manages the flight path to achieve optimum Flight Path Controls the flight operational performance Management, path through Automation automation. — Maintains the intended flight path during flight using automation whilst managing other tasks and distractions — Selects appropriate level and mode of automation in a timely manner considering phase of flight and workload — Effectively monitors automation, including engagement and automatic mode transitions — Encourages team participation and open communication — Demonstrates initiative and provides direction when required — Engages others in planning — Considers inputs from others — Gives and receives feedback constructively Influences others to Leadership — Addresses and resolves conflicts and contribute to a shared purpose. disagreements in a constructive manner and Collaborates to — Exercises decisive leadership when required Teamwork accomplish the goals of the team. — Accepts responsibility for decisions and actions — Carries out instructions when directed — Applies effective intervention strategies to resolve identified deviations — Manages cultural and language challenges, as applicable TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail ICAO competency Description Observable behaviour — Identifies, assesses and manages threats and errors in a timely manner — Seeks accurate and adequate information from appropriate sources — Identifies and verifies what and why things have gone wrong, if appropriate — Perseveres in working through problems whilst prioritizing safety Identifies Problem Solving and precursors, — Identifies and considers appropriate options Decision Making mitigates problems; and makes decisions — Applies appropriate and timely decision- making techniques — Monitors, reviews and adapts decisions as required — Adapts when faced with situations where no guidance or procedure exists — Demonstrates resilience when encountering an unexpected event — Monitors and assesses the state of the aeroplane and its systems — Monitors and assesses the aeroplane’s energy state, and its anticipated flight path. — Monitors and assesses the general environment as it may affect the operation Perceives, — Validates the accuracy of information and comprehends and Situation awareness checks for gross errors manages and management of information and — Maintains awareness of the people involved information anticipates its effect on the operation. in or affected by the operation and their capacity to perform as expected — Develops effective contingency plans based upon potential risks associated with threats and errors — Responds to indications of reduced situation awareness TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail ICAO competency Description Observable behaviour — Exercises self-control in all situations — Plans, prioritizes and schedules appropriate tasks effectively — Manages time efficiently when carrying out tasks — Offers and gives assistance Maintain available — Delegates tasks workload capacity Workload by prioritizing and — Seeks and accepts assistance, when Management distributing tasks appropriate using appropriate resources — Monitors, reviews and cross-checks actions conscientiously — Verifies that tasks are completed to the expected outcome — Manages and recovers from interruptions, distractions, variations and failures effectively while performing tasks — Demonstrates practical and applicable knowledge of limitations and systems and their interaction. — Demonstrates required knowledge of published operating instructions. Demonstrates knowledge and — Demonstrates knowledge of the physical understanding of environment, the air traffic environment relevant Application of information, including routings, weather, airports and the Knowledge operating operational infrastructure. instructions, aircraft systems and the — Demonstrates appropriate knowledge of operating applicable legislation. environment. — Knows where to source required information. — Demonstrates a positive interest in acquiring knowledge. — Is able to apply knowledge effectively. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 77 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC2 ORO.FC.231(b) Evidence-based training ALTERNATIVE COMPETENCY FRAMEWORKS (a) An operator seeking to develop an alternative competency framework under ORO.GEN.120 should: (1) identify positive behaviours and use language that avoids ambiguity; and (2) demonstrate equivalence to the competency framework in AMC1 ORO.FC.231(g). (b) In order to demonstrate equivalence, the operator should map the competencies and observable behaviours to the recommended competency framework. (c) When the operator is translating AMC1 ORO.FC.231(g) into its common language, the application of ORO.GEN.120 may not be necessary. The translation may not be literal. AMC2 ORO.FC.231(b) Alternative competency frameworks EBT and competency-based training are based on the concept that competencies are transferable. In the design of a competency-based assessment and training programme, a limited number of competencies are defined. If an airline decides to add or remove a competency, there should be a clear and justifiable reason to do so. Operators may develop suitable equivalent frameworks to meet their needs. — A limited number of competencies involving knowledge, skills and attitudes should be defined. — These defined competencies should cover more than a single situation and be consistently observable across a wide variety of contexts. Short summary on how to develop an operator ‘COMPETENCY FRAMEWORK’ structure A rapid analysis of the training need and the local environment should answer the following questions: — What is to be trained? — What tasks does the trainee need to be able to perform by the end of the training? — What regulatory, technical and operational knowledge is required? — What skills are required? — What attitudes are required? — What are the specific conditions required for performance (i.e. level of complexity, specific requirements)? TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail IATA or other Operator’s Competency Framework used as reference Operator analysis Consider … The specific training conditions From the reference competency Basic framework of framework, the relevant competencies, indicators Select… competencies and performance and performance criteria criteria applicable Operator’s specific The defined specific operator’s competencies and Add… competencies and performance performance criteria criteria The Operator’s observable Operator’s specific underpinning indicators (KSAs) Identify… Observable behaviours to determine competency Conditions under which the competencies and performance Operator’s standards Determine... definition criteria must be demonstrated Operator’s Competency Framework AMC2 ORO.FC.231(b) point (c) The use of the term ‘common language’ refers to the common language used by the operator. An IR for such requirement is provided in the Air OPS Regulation Annex IV. ‘CAT.GEN.MPA.120 Common language The operator shall ensure that all crew members can communicate with each other in a common language’. GM1 to AMC2 ORO.FC.231(b) Evidence-based training ALTERNATIVE COMPETENCY FRAMEWORKS/POSITIVE OBSERVABLE BEHAVIOUR (a) OBs should describe behaviours that contribute to positive pilot performance. (b) The indicators should clearly describe how a competency is expected to be demonstrated by a crew member in the context of the operational environment. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 79 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (c) TRAINING SYSTEM PERFORMANCE (1) The EBT system performance shall be measured and evaluated through a feedback system in order to: (iii) validate and refine the operator’s approved EBT programme; and (iv) ascertain that the operator’s approved EBT programme develops pilot competencies. (2) The feedback system shall be included in the operator’s management system. ORO.FC.231(c) This requirement is transposed from Doc 9995 paragraphs 3.6.6 and 3.6.7 with the necessary amendments into the European regulatory system. ‘3.6.6 Quality management. The training system performance should be measured and evaluated in respect of the organizational objectives. Monitoring should include a feedback system to identify trends and ensure corrective action where necessary. The quality system of the operator or training organization, as defined in Doc 9841, the Manual on the Approval of Training Organizations, should monitor alignment with the EBT assessment and training guidelines recommended in this manual. 3.6.7 Feedback system. For the purpose of collecting data from an EBT programme, and making adjustments and continuous improvement to the training system, an operator should implement a performance feedback system utilising defined metrics (see paragraph 5.3)’. AMC1 ORO.FC.231(c) Evidence-based training TRAINING SYSTEM PERFORMANCE — FEEDBACK SYSTEM (a) The feedback system should use defined metrics to collect data in order to: (1) identify trends and ensure corrective action where necessary; (2) identify collective training needs; (3) review, adjust and continuously improve the training programme; (4) further develop the training system; and (5) standardise the instructors. (b) Alternatively, where a system for the measurement of training system performance already exists, the operator may use it and, if necessary, adapt it to meet the demands of EBT, for example in measuring performance throughout the range of competencies. AMC1 ORO.FC.231(c) point (a) This requirement is transposed from Doc 9995 paragraph 4.1.2 (d) and (e) with the necessary amendments to incorporate the ICAO proposal into the European regulatory framework. ‘4.1.2 There are various mechanisms for the implementation of EBT, which should be conducted in close consultation with the CAA and which include: a) the definition of an implementation and operations plan; b) the adaptation of the programmes defined in Appendices 2 to 7 to Part II according to the generation of aircraft (fleet) and type of operation for the operator; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 80 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail c) the EBT programme implementation (an initial limited trial phase should be considered by the CAA); d) the review of training effectiveness upon receipt of sufficient training system data; and e) the adjustment and continuous improvement of the training programme according to the training system feedback.’ AMC2 ORO.FC.231(c) Evidence-based training DATA PROTECTION — FEEDBACK SYSTEM — GRADING SYSTEM (a) The data access and security policy should restrict information access to authorised persons. (b) The procedure to prevent disclosure of crew identity should be written in a document, which should be signed by all parties involved (airline management and flight crew member representatives nominated either by the union or the flight crew themselves). AMC2 ORO.FC.231(c) EBT will collect an increased training data, however some provision must be made to protect individual data (data protection). ORO.AOC.130 ‘Flight data monitoring – aeroplanes’ already requires a system that provides such kind of protection (individual data protection) and at the same time it provides good information to operators and authorities. The details of such protection and scope is provided in AMC1 ORO.AOC.130 points (g) and (k). Point (a) of this AMC is transposed from AMC1 ORO.AOC.130 point (g). Point (b) of this AMC is transposed from AMC1 ORO.FC.130 point (k); however, some of the details were transferred to GM2 ORO.FC.231(b). This provision must be read in conjunction with ORO.GEN.140 the Air OPS Regulation where the competent authority has access to all records: ‘ORO.GEN.140 Access (a) For the purpose of determining compliance with the relevant requirements of Regulation (EC) No 216/2008 and its Implementing Rules, the operator shall grant access at any time to any facility, aircraft, document, records, data, procedures or any other material relevant to its activity subject to certification, SPO authorisation or declaration, whether it is contracted or not, to any person authorised by one of the following authorities: (…)’ GM1 ORO.FC.231(c) Evidence-based training TRAINING SYSTEM PERFORMANCE - FEEDBACK SYSTEM — METRICS (a) Training metrics within the feedback system are a valuable source of data. Typical metrics may include but are not limited to: (1) differences in success rates between aircraft types and training topics; (2) distribution of errors for various training scenarios and aircraft types; (3) distribution of level of performance within the range of competencies; (4) the trainee’s feedback, which provides a different perspective as to the quality and effectiveness of the training product; and TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 81 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (5) instructor concordance assurance: this system is important to measure the effectiveness of the instructor calibration process. However, it is essential to stress that the purpose of this system is not to spy on instructors or to pressure individuals to change their grading. (b) Training metrics are an invaluable component in supporting an EBT programme but they must be placed in the context of operational data, because only the latter can justify the importance of a specific skill within the real operation. GM1 ORO.FC.231(c) This requirement is transposed from Doc 9995 paragraph 5.3.1 with the necessary amendments to incorporate the ICAO proposal into the European regulatory framework: ‘5.3.1 Training metrics. The ‘inner loop’ within the training function is a valuable source of data. Taking full advantage of such data requires robust and well-calibrated training metrics. Typical metrics include: a) differences in success rates between aircraft types and training topics; b) distribution of errors for various training scenarios and aircraft types; c) skill retention capability versus skill type; d) the trainee’s feedback, which provides a different perspective as to the quality and effectiveness of the training product; and e) instructor tracking system: this system is important to measure the effectiveness of the instructor calibration process. However, it is essential to impress that the purpose of this system is not to spy on instructors or to pressure individuals to change their grading’. GM1 ORO.FC.231(c) point (b) This provision is a transposition from the Doc 9995 paragraph 5.3.2: ‘5.3.2 Training metrics are an invaluable component in supporting an EBT programme but they must be placed in the context of operational data, because only the latter can justify the importance of a specific skill within the real operation’. Furthermore, operational data is already required in ORO.AOC.130 and ORO.GEN.200 of the Air OPS Regulation. GM2 ORO.FC.231(c) Evidence-based training DATA PROTECTION — FEEDBACK SYSTEM — GRADING SYSTEM The procedure to prevent disclosure of crew identity may, as a minimum, define: (a) a data access and security policy that may restrict access to information to specifically authorised persons identified by their position. The required authorised person(s) does (do) not necessarily need to be the nominated person for crew training (or their deputy(ies)), but could be the EBT programme manager or a third party mutually acceptable to unions or staff and management. (Note: access to the last 12 months training data is required for the examiner that will revalidate the pilot licence); (b) the identified data retention policy and accountability, including the measures taken to ensure the security of the data; (c) the method to obtain de-identified crew feedback on those occasions that require specific follow-up; TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 82 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (d) the conditions under which advisory briefing or remedial training should take place. This should always be carried out in a constructive and non-punitive manner; (e) the conditions under which the confidentiality may be withdrawn for reasons of gross negligence or significant continuing safety concern; (f) the policy for publishing the findings resulting from the EBT programme. GM2 ORO.FC.231(c) This GM is transposed from AMC1 ORO.AOC.130 ‘Flight data monitoring – aeroplanes’ point (k): (…) ‘This procedure should, as a minimum, define: (1) the aim of the FDM programme; (2) a data access and security policy that should restrict access to information to specifically authorised persons identified by their position; (3) the method to obtain de-identified crew feedback on those occasions that require specific flight follow- up for contextual information; where such crew contact is required the authorised person(s) need not necessarily be the programme manager or safety manager, but could be a third party (broker) mutually acceptable to unions or staff and management; (4) the data retention policy and accountability, including the measures taken to ensure the security of the data; (5) the conditions under which advisory briefing or remedial training should take place; this should always be carried out in a constructive and non-punitive manner; (6) the conditions under which the confidentiality may be withdrawn for reasons of gross negligence or significant continuing safety concern; (7) the participation of flight crew member representative(s) in the assessment of the data, the action and review process and the consideration of recommendations; and (8) the policy for publishing the findings resulting from FDM.’ The use of the word ‘examiner’ in the note to the first point ‘Note: access to the last 12 months training data is required for the examiner that will revalidate the pilot licence’ is used to provide a generic term. (d) GRADING SYSTEM (3) The operator shall use a grading system to assess flight crew, which ensures: (i) sufficient level of detail to enable accurate and useful measurements of individual performance; (ii) a performance scale for each competency, with a point on the scale which determines the minimum acceptable level to be achieved for the conduct of line operations; and (iii) data integrity. (4) The operator shall verify in regular intervals the accuracy of the grading system against a criterion-referenced system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 83 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ORO.FC.231(d) The paradigm shift from legacy training and checking programmes is a move away from assessment against the execution of predefined manoeuvres and tasks, based on the quality of execution. Remediation in these cases often leads to simple task repetition without an understanding of the underlying causes of ineffective performance. To be consistent with the central philosophy of EBT, assessment should be completed at key points during the module, and performance evaluated against each of the defined competencies, using the most relevant OBs to the performance observed. The instructor should take an overview of everything observed during the phase, and using a methodology similar to that published, award grades in each competency only. The grading system should be used for crew assessment, in addition to providing quantifiable data for the measurement of the training system performance. It can range from a simple ‘acceptable/unacceptable’ grading performance system to a gradual relative measurement system. ORO.FC.231(d) wording ‘a grading system to assess flight crew’ The intent of the grading system ‘to assess flight crew’ is provided in the IR following the performance-based regulation model, where the objective is allocated in the rule. The provision is transposed from Doc 9995 paragraph 3.6.3: ‘3.6.3 Assessment and grading system. A full description of the competencies is provided in Appendix 1 to Part II. It is essential to note that an operator intending to use this framework should in addition develop a clear assessment and grading system for expected crew performance. Competencies are a fundamental component of the grading system. It is not the intention of this document to fully describe a grading system, but a grading system should be used for crew assessment, in addition to providing quantifiable data for the measurement of the training system performance. It can range from a simple ‘acceptable/unacceptable’ grading performance system to a graduated relative measurement system.’ ORO.FC.231(d) point (1)(iii) Data integrity is the maintenance of, and the assurance of the accuracy and consistency of, data over its entire life-cycle and is a critical aspect to the design, implementation and usage of any system which stores, processes, or retrieves data. Any unintended changes to data as the result of a storage, retrieval or processing operation, including malicious intent, unexpected hardware failure, and human error, is failure of data integrity. ORO.FC.231(d) point (2) Why do we need a verification of the grading system? The EBT grading system provides a norm-referenced system, although it contains some characteristics of a criterion-referenced system. Glasser (1963) formalised the concept of criterion-referenced testing (CRT). The development of a CRT entails, firstly, a statement of behavioural objectives and then a systematic generation of test items designed to unambiguously ascertain to what degree these objectives have been met. Standards of performance are set using minimal levels of competence before the test is applied. These characteristics are difficult to achieve in the EBT system for certain OBs and grading, especially as regards non-technical skills, associated OBs and their grading. For example, a grade 3 (‘The pilot TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 84 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail communicated adequately, by regularly demonstrating most of the OBs when required, which resulted in a safe operation’) in communication will require that all OBs are clearly and unambiguously defined. As an example, the OB ‘Uses eye contact, body movement and gestures that are consistent with and support verbal messages’ would require further criteria in the context of a particular scenario to reach the ‘unambiguously ascertain to what degree the objective have been met’ explained by Glasser (1963). These criteria could be: at least 20 seconds of eye contact along with a body movement of 3 gestures (e.g. indicating with the arm the side of the aircraft affected) that support the verbal message of the explanation of an engine problem to the cabin crew. Today the revalidation of licenses is based on a criterion-referenced system for the conduct of the training, tests and checks of Appendix 9 with regard to technical competencies (see FLIGHT TEST TOLERANCE, Appendix 9 to the Aircrew Regulation. For the non-technical competencies, a norm-referenced system may be provided (see ORO.FC.115 &215 of the Air OPS Regulation). Today, the European aviation system uses a criterion-referenced system for revalidation of pilot licences to ensure a level playing field (that is the aim in accordance with Article 2 of Basic Regulation). EBT proposes a norm-referenced system. In order to combine both methods, a feedback loop is proposed. This process is recommended in different scientific works. From all the scientific works, the RMG provided a reference to the book ‘Criterion-referenced and norm-referenced assessments: compatibility and complementarity’ author: Beatrice Lok, Carmel McNaught & Kenneth Young. An extract is provided to support the need of a verification of the grading system in EBT. The book proposed a yearly verification of the grading system; however, the RMG opposed to this proposal and instead EASA proposed a onetime feedback every three years. ‘Feedback loop: There is no need to choose between norm referencing and criterion referencing. They are both present. — Not only are they both present, but with the caveat about minor adjustments from year to year, they are consistent. Thus, it is possible both to define rubrics (criterion referencing) and to prescribe grade- distribution guidelines (norm referencing), provided the latter contains a degree of flexibility. — The presence of norm referencing and criterion referencing in a loop enables the generation of both useful feedback to learners and useful summative information to external stakeholders. — The use of criteria allows meaningful reference to higher-order learning outcomes. While these are inevitably ambiguous and even unknown to external stakeholders, the simultaneous use of norm referencing allows the interpretation of these criteria to be supported by norm comparisons, and to guard against grade inflation. — Since these steps are all in a loop, there is no need to argue which one comes first. — The entire approach is coherent with modern quality-assurance and fitness-for purpose concepts.’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 85 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(d)(1) Evidence-based training GRADING SYSTEM (a) The grading system should provide quantifiable data for the measurement of the training system performance. (b) The grading scale should be 1 to 5, where: (1) Level 1 determines that a minimum acceptable level of performance was NOT achieved for the conduct of line operations. An outcome of ADDITIONAL TRAINING REQUIRED should be recorded. (2) Levels 2 to 5 determine an outcome of COMPETENT for the competent authority. (3) Level 2 (below the norm) determines that the minimum acceptable level was achieved for the conduct of line operations. (4) Consistent Level 2 grading indicates a need for additional training to elevate performance to the norm. (5) Level 3 on a 5-point scale is the norm. (6) Level 4 determines that the pilot is above the norm. (7) Level 5 (exemplary) determines that the pilot is above the norm (enhanced safety, effectiveness and efficiency). AMC2 ORO.FC.231(d)(1) Evidence-based training GRADING SYSTEM — ALTERNATIVE SYSTEM (a) The grading system should provide quantifiable data for the measurement of the training system performance. (b) The grading scale for each competency should: (1) determine the grade at which the performance is considered: (i) NOT COMPETENT for the conduct of line operations. An outcome of ADDITIONAL TRAINING REQUIRED should be recorded; and TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 86 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (ii) COMPETENT for the conduct of line operations; and (2) determine for the pilot whose performance is considered competent for the conduct of line operations: (i) if the pilot needs additional training to elevate their performance to the operator specified norm. (ii) if the pilot is at the operator specified norm. (iii) if the pilot is above the norm (it can be one or more levels e.g. above the norm and exemplary). AMC1 ORO.FC.231(d)(1) This provision did not obtain a full consensus in the EBT subgroup RMT.0599. Whereas the need for guidance for the grading system was fully supported, there was disagreement regarding the regulatory level it should have —IR, AMC or GM (e.g. GM2 ORO.FC.231(d)). Airline associations represented in the EBT subgroup RMT.0599 believed the operators should have the choice to use their own grading system without any involvement of the competent authority. Other stakeholders believed there should be a prescriptive approach in order to ensure all pilots are assessed in the same way. Some of the arguments for such prescriptive approach are: — As this NPA allows the revalidation of licences based on the EBT system and therefore based on the rate obtained within the grading system, all pilots in Europe should be rated in the same way given that pilots with a valid type rating can join any airline in the European market. Therefore, level playing field should be considered. This argument is relevant for points 1 and 2 in the scale proposed in the NPA. — A standardised grading system of airlines will allow a standardised approach to grading and therefore to forms and paperwork. This may simplify bureaucracy in the competent authorities across Europe. In addition, the potential benefits this standardised approach to the grading system would bring to the oversight functions of the competent authorities were discussed. — Data exchange: EASA consulted some data experts whether a standardised approach to the grading system could bring benefits to all stakeholders21. The conclusion is that in order to facilitate the data exchange (which is of paramount importance nowadays), it is quite important to have a common grading system. Data preparation, normalisation and standardisation can take up to 90 % of the resources, while the actual data analysis may take only 10 %. A standardised approach to grading system, competency framework and OB could reduce the data preparation and normalisation close to 100 %. It could additionally increase data exchange between stakeholders (anonymity is ensured in accordance with the data protection regulations). Furthermore, platforms like the European Data4safety or the FAA Aviation safety information analysis and sharing (ASIAS) will largely benefit from a standardised approach. Taking into account the above, EASA decided to locate this provision at an intermediate regulatory level: AMC. This regulatory level allows an increased flexibility compared to IRs, whereby national authorities could approve deviations in accordance with AltMoC (ORO.GEN.120 of the Air OPS Regulation). Furthermore, an alternative grading system in AMC2 ORO.FC.231(d)(1) provides further flexibility to the operators. 21 The whole spectrum of stakeholders: airlines, competent authorities, accident and incident investigation authorities, safety analysts, etc. (there are plans to extend EBT to helicopters and business jets). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 87 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Note: As mentioned, data exchange will be done in accordance with the data protection regulations (European and national). Comments are welcome in this NPA if more guidance is necessary in regard to data management, exchange of data, etc. Flight data monitoring regulations may provide the basis of this new guidance. On the other hand, some operators believe that in order to fulfil the 1 to 5 grading requirement, they will need to change their IT tools. This may be expensive. According to the RIA, the price of this system is around EUR 100 000 (one-off expense) and the same amount is valid in recurrent basis (every year). For that reason, to avoid this one-off expense, the possibility for an alternative grading system was provided to allow those operators that already invest in a system to continue to do so. The grading provided in the AMC follows the principle described in the IATA Implementation guide, chapter 6.4: ‘1. Fairness and accuracy The grading system should allow the evaluation to be objective, fair, and relevant. It should be reliable, accurate, consistent and resistant to abuse, halo effects, instructor-evaluator laziness, ‘box ticking‟ and bias, both positive and negative. Finally, it should ensure that pilots who are unable to fulfil competency performance expectations are not released to line service. 2. Clarity The grading system should allow assessments to be transparent, clear, complete, unambiguous, and not subject to interpretation or confusion. It must also address the occasions where pilots do not have the opportunity to demonstrate a particular competency. 3. Usability The grading system should be simple, easy to use, understandable, practical, manageable, accessible, uncomplicated, and resistant to unintentional errors. It should not dominate any debrief and should be compatible with facilitation. Finally, it should be compatible with any media to be used, electronic or otherwise. 4. Ease of compliance The grading system should comply with both operator and CAA requirements. It should meet high-level regulations, allow auditing, and be traceable, explainable and long lasting. It should also ensure that any assessment is less liable to legal action. 5. Continuous improvement The grading system should provide evidence to enable improvements in both the training system and trainee performance, for the purpose of enhancing safety. It should be meaningful, deliver useful data, identify trends, aid analysis and address existing, future or potential problems in order to improve the training system. It should enable trainees to provide feedback on their assessment in order to help improve grading consistency and the grading system. It should also enable the continuous development of the trainee’s performance. 6. Motivating The grading system should be motivating, trustworthy, respectful, and easy to „sell‟, so that both trainers and trainees enjoy the experience without creating fear. It should also recognize exemplary performance and promote commitment by both trainers and trainees to the assessment process. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 88 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 7. Technical data management The grading system should provide a manageable quantity of good data, be media compatible, easy to record and produce electronic data, compatible with analysis and presentation tools. It should also maintain data protection and assure controlled access. 8. Adaptability The grading system should be adaptable, flexible and able to tailor to all facets of the operation, aircraft types and training objectives. 9. Implementation risk The grading system should provide robust defences against the risks of ineffective implementation. The system should be comprehensible for trainers, enable efficient trainer standardisation, strong inter-rater reliability, and facilitate the identification of trainer divergence. It should be familiar to all users, cost efficient and resistant to drift and mutation.’ However, the RMG provided further guidance to expand some of the characteristics as follows: — Fairness and accuracy: Identify evaluator divergence, facilitate instructor concordance, not repressive, is not open to abuse, avoids positive/negative bias — Usability: acceptable to evaluators, avoids unintentional mistakes, it is familiar and is not complicated — Safety improvement: compatible with facilitation, works towards excellence, is useful, identifies trends, is acceptable to operator, not costly, does not allow incompetent pass, improves system, continuous development — Adaptability: customisable, cross-cultural GM1 ORO.FC.231(d)(1) Evidence-based training GRADING SYSTEM — VENN (a) The VENN system is a methodology to ensure the maximum level of consistency and objectivity to assessments performed in an operator’s approved EBT programme. (b) Grading the performance of flight crew members during an EBT module may use the following methodology: (1) Observe performance. (2) Record details of effective and ineffective performance observed. (3) Classify observations against the OBs within the competency framework. (4) Assess performance by determining the root cause or causes according to the competencies measured. As a guide, this would also normally indicate the area of performance to be remediated in subsequent phases or modules. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 89 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (5) Evaluate performance by determining a grade in each competency using the VENN system and the following dimensions according to the observed behaviours related to the OB. At the conclusion of the evaluation phase and also at the end of the EBT module, the instructor may grade each flight crew member’s performance in each of the competencies by the following the steps below, and determining: (i) how well the flight crew member demonstrated the OB(s) when required; (ii) how often the flight crew member demonstrated the OB(s) when they were required; (iii) how many OBs the flight crew member demonstrated over the phase when they were required; (iv) what was the outcome of threat, error and undesired aircraft state management relating specifically to the competency being assessed. (6) The grades should reflect an overall assessment of the flight crew member’s performance during the phase. (c) Grades may be determined during each EBT module as follows: (1) Evaluation phase (EVAL) — grading at the end of the phase Note: Manoeuvres training — training to proficiency, no need to grade. (2) Scenario-based training phase (SBT) — grading at the end of the phase Note: In-seat instruction (ISI) should not be included in any assessment. (3) For each assigned grade: (i) the observed performance should be identified with one or more OBs; and (ii) the OB should simply link the observed performance to the competency; they are not to be used as a checklist. (4) At the completion of the module, grades should be assigned for each competency, based on the overall assessment of training during the SBT. (5) Where any competency is rated below the minimum acceptable level of performance (level 1 on a 5-point scale), an outcome of ADDITIONAL TRAINING REQUIRED should be recorded. (6) Where all competencies are determined at or above the minimum acceptable level of performance, (for example, level 2 on a 5-point scale) the outcome should be COMPETENT. Grades consistently below the norm (level 3 on a 5-point scale) may indicate a need for additional training to elevate performance to the norm (level 3 on a 5-point scale). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 90 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (d) Where any competency is determined below the minimum acceptable level of performance (for example, level 1 on a 5-point scale), the flight crew member may not be released to unsupervised line operations until each competency is demonstrated at or above the minimum acceptable level of performance, during a subsequent line evaluation of competence. (e) The word pictures below support a VENN system. The example system is based on a 5-point scale with 3 being the norm, 1 determining unacceptable performance and 2 being the minimum acceptable level of performance. A means of utilising this system may be to determine that at the EBT module: (1) Any competency rated 1 at the end of the module requires additional training prior to release to line flying. (2) Any competency rated 2 in two consecutive simulator sessions in different recurrent modules requires individual customised training within 3 months of the completion date of the EBT module. (1st Module SBT rated 2, 2nd Module EVAL rated 2, thus SBT should trigger an individual customised training). (3) Any competency rated 2 in three consecutive modules requires additional training at the end of the third module within three months (following the example in (2): 3rd Module EVAL is rated 2 again, the pilot should receive additional training). (4) Any evaluation simulator session with three or more competencies rated 2 requires individual customised training in the SBT phase. If at the end of the module the three competencies continue being rated 2, the pilot requires additional training. (5) Individual customised training: it means a simulator session tailored to the pilot’s individual training needs which may require a different programme. Normally, there is not an increase of FSTD volume (no extra simulator session). (6) Additional training: it means the simulator session is tailored to the pilot’s individual training needs and an extra simulator session. It normally happens after an individual customised training. (7) The word pictures are standardised according to the VENN system but may be simplified once instructors become familiar with the system. Word picture VENN system Application of procedures (APK) The pilot applied procedures in an exemplary manner, by always demonstrating all of the observable 5 behaviours to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot applied procedures effectively, by regularly demonstrating all of the observable behaviours 4 when required, which resulted in a safe operation The pilot applied procedures adequately, by regularly demonstrating most of the observable 3 behaviours when required, which resulted in a safe operation The pilot applied procedures at the minimum acceptable level, by only occasionally demonstrating 2 some of the observable behaviours when required, but which did not result in an unsafe situation The pilot applied procedures incorrectly, by rarely demonstrating any of the observable behaviours 1 when required, which resulted in an unsafe situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. 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Proposed amendments and rationale in detail Communication (COM) The pilot communicated in an exemplary manner, by always demonstrating all of the observable 5 behaviours to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot communicated effectively, by regularly demonstrating all of the observable behaviours when 4 required, which resulted in a safe operation The pilot communicated adequately, by regularly demonstrating most of the observable behaviours 3 when required, which resulted in a safe operation The pilot communicated at the minimum acceptable level, by only occasionally demonstrating some of 2 the observable behaviours when required, but which overall did not result in an unsafe situation The pilot communicated ineffectively, by rarely demonstrating any of the observable behaviours when 1 required, which resulted in an unsafe situation Flight path management — automation (FPA) The pilot managed the automation in an exemplary manner, by always demonstrating all of the 5 observable behaviours to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot managed the automation effectively, by regularly demonstrating all of the observable 4 behaviours when required, which resulted in a safe operation The pilot managed the automation adequately, by regularly demonstrating most of the observable 3 behaviours when required, which resulted in a safe operation The pilot managed the automation at the minimum acceptable level, by only occasionally 2 demonstrating some of the observable behaviours when required, but which did not result in an unsafe situation The pilot managed the automation ineffectively, by rarely demonstrating any of the observable 1 behaviours when required, which resulted in an unsafe situation Flight path management — manual (FPM) The pilot controlled the aircraft in an exemplary manner, by always demonstrating all of the 5 observable behaviours to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot controlled the aircraft effectively, by regularly demonstrating all of the observable behaviours 4 when required, which resulted in a safe operation The pilot controlled the aircraft adequately, by regularly demonstrating most of the observable 3 behaviours when required, which resulted in a safe operation The pilot controlled the aircraft at the minimum acceptable level, by only occasionally demonstrating 2 some of the observable behaviours when required, but which did not result in an unsafe situation The pilot controlled the aircraft ineffectively, by rarely demonstrating any of the observable 1 behaviours when required, which resulted in an unsafe situation Application of knowledge (KNO) The pilot showed exemplary knowledge, by always demonstrating all of the observable behaviours 5 when required, which significantly safety, effectiveness and efficiency The pilot showed adequate knowledge, by always demonstrating all of the observable behaviours 4 when required, which resulted in a safe operation TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail The pilot showed adequate knowledge, by regularly demonstrating most of the observable behaviours 3 when required, which resulted in a safe operation The pilot showed knowledge to a minimum acceptable level, by only occasionally demonstrating some 2 of the observable behaviours when required, but which did not result in an unsafe situation The pilot showed inadequate knowledge, by rarely demonstrating any of the observable behaviours 1 when required, which resulted in an unsafe situation Leadership & teamwork (LTW) The pilot led and worked as a team member in an exemplary manner, by always demonstrating all of 5 the observable behaviours to a high standard when required, which significantly enhanced safety, effectiveness and efficiency The pilot led and worked as a team member effectively, by regularly demonstrating all of the 4 observable behaviours when required, which enhanced safety The pilot led and worked as a team member adequately, by regularly demonstrating most of the 3 observable behaviours when required, which resulted in a safe operation The pilot led and worked as a team member at the minimum acceptable level, by only occasionally 2 demonstrating some of the observable behaviours when required, but which did not result in an unsafe situation The pilot led or worked as a team member ineffectively, by rarely demonstrating any of the observable 1 behaviours when required, which resulted in an unsafe situation Problem-solving & decision-making (PSD) The pilot solved problems and made decisions in an exemplary manner, by always demonstrating all of 5 the observable behaviours to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot solved problems and made decisions effectively, by regularly demonstrating all of the 4 observable behaviours when required, which resulted in a safe operation The pilot solved problems and made decisions adequately, by regularly demonstrating most of the 3 observable behaviours when required, which resulted in a safe operation The pilot solved problems and made decisions at the minimum acceptable level, by only occasionally 2 demonstrating some of the observable behaviours when required, but which did not result in an unsafe situation The pilot solved problems or made decisions ineffectively, by rarely demonstrating any of the observable 1 behaviours when required, which resulted in an unsafe situation Situation awareness (SAW) The pilot’s situation awareness was exemplary, by always demonstrating all of the observable behaviours 5 to a high standard when required, which enhanced safety, effectiveness and efficiency The pilot’s situation awareness was good, by regularly demonstrating all of the observable behaviours 4 when required, which resulted in a safe operation The pilot’s situation awareness was adequate, by regularly demonstrating most of the observable 3 behaviours when required, which resulted in a safe operation The pilot’s situation awareness was at the minimum acceptable level, by only occasionally demonstrating 2 some of the observable behaviours when required, but which did not result in an unsafe situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 93 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The pilot’s situation awareness was inadequate, by rarely demonstrating any of the observable 1 behaviours when required, which resulted in an unsafe situation Workload management (WLM) The pilot managed the workload in an exemplary manner, by always demonstrating all of the observable 5 behaviours to a high standard when required, which significantly safety, effectiveness and efficiency The pilot managed the workload effectively, by regularly demonstrating all of the observable behaviours 4 when required, which resulted in a safe operation The pilot managed the workload adequately, by regularly demonstrating most of the observable 3 behaviours when required, which resulted in a safe operation The pilot managed the workload at the minimum acceptable level, by only occasionally demonstrating 2 some of the observable behaviours when required, but which did not result in an unsafe situation The pilot managed the workload ineffectively, by rarely demonstrating any of the observable behaviours 1 when required, which resulted in an unsafe situation Grading OUTCOME (1) HOW MANY (2) HOW OFTEN (3) HOW WELL(4) 1 unsafe situation hardly any rarely ineffectively 2 not an unsafe situation some occasionally minimally acceptable 3 safe situation most regularly adequately 4 safe situation all regularly effectively enhanced safety, effectiveness and 5 all always in an exemplary manner efficiency Safety promotion material — Grading system EASA has planned a safety promotion task (SPT.012) to support the implementation of EBT. The following material was developed: SPT.012 — Safety promotion to ORO.FC.231(d) Grading system Although the regulation proposed in this NPA may provide enough material to develop a grading system, the operator may provide the instructors with further guidance in order to improve grading and instructor concordance. Grading should look at the entire simulator session (the whole scenario), and not only at a particular scenario element (e.g. one manoeuvre or a small scenario within the simulator). Sometimes raters tend to decide the grading of the simulator session based on one manoeuvre when the grading in EBT should look for the global assessment instead. An example of the kind of material the operator should develop is provided below. The example is based on the threat and error management (TEM) model: — Grading of a non-intentional non-compliance (an undetected error or mistake but corrected in a timely manner with a safe outcome). There are two types:  Non-intentional non-compliance without consequences — trap error TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 94 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail For instance, there is a mistake on the altitude selection, crew are busy with other tasks and do not recognise the mistake when it occurs and therefore they do not call ATC to confirm the altitude clearance. However, later and before the level bust, they initiate a dialogue and realise their possible mistake, or one of the pilots due to their awareness of the route altitudes realises a possible mistake which triggers a call to ATC to confirm the altitude and fix the error. For the competency identified as root cause, the grade will not be 1. The example provides a reference to grade 3; it may be graded 2 or 4 depending on the rest of the simulator session. The competency probably may not be grade 5. It should be noted that this does not prevent that other competencies could be graded 5 based on the evidence of this particular scenario element. APK may not be graded 5 because the pilot did not confirm with ATC when in doubt of an altitude clearance as required by the SOPs; however, they may be graded 5 in SWA because they realised that the altitude selected did not make sense with the safe altitude for the route.  Non-intentional non-compliance with consequences and provided the consequences were mitigated in a timely manner (e.g. mistake in the altitude selection followed by a level bust resolved by a call of ATC or a TCAS flown to a good standard, GPWS warning followed by an escape manoeuvre performed to a good standard, etc.). For the competency identified as root cause, the grade should not be 1 or 5. Reference grading is 2 as the situation may not be unsafe because the problem was resolved, however it may not be considered safe; depending on the rest of the simulator session, 3 may be possible and 4 is highly unlikely. — Intentional non-compliance but recognised and corrected in a timely manner with a safe outcome (e.g. unestablished approach followed by a go-around well below the stabilised gate) For the competency identified as root cause, the probable grading (reference grading) will be 2 and the maximum grading for the simulator may be 3. 2 is the probable grading because the situation was not unsafe as the pilot executed a go-around, but the pilot did it well below the stabilised gate (e.g. 100 feet). However, the situation cannot be consider safe because he should go-around close to the stabilised gate (about 500 feet). It should never be 4 or 5. It may trigger a 1 depending on the other exercises. Note: this guidance to grading is not to be used when there is a non-compliance because a higher degree of safety dictates otherwise. — Intentional non-compliance not corrected and continued to the end state (e.g. unestablished approach and maintained until landing) For the competency identified as root cause, the grade is 1 (failed) and the probable route cause is APK. No other competency of the pilot can be graded 5. Note: this guidance is not to be used when there is a non-compliance because a higher degree of safety dictates otherwise (e.g. unestablished approach maintained until landing due to uncontained fire or all engines flame out, etc.). The grading should as much as possible assess what has happened (be objective) and not what would have happened if. GM1 ORO.FC.231(d)(1) Assessment and grading are an integral part of the learning process. As part of the creation of EBT as a new approach to competency-based training, a pilot performance assessment and grading system is required to address the fundamental shift from previous systems which are ‘event-based’ and require the assessment of TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 95 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail the quality of the outcome of a manoeuvre or of the management of the event or threat. In certain previous systems, behavioural markers or competencies were used as assessment tools or reason codes for the outcome of the manoeuvre or of the management of the event or threat. The paradigm shift in EBT is to focus attention on the underlying area of flight crew member performance in order to determine training need or focus. EBT is a system designed to determine areas of focus for all flight crew members, and not just those whose performance is observed below a minimum acceptable level. The system is intended to fulfil the needs of operators and was created according to a structured design process. Rationale The assessment and grading system should meet the needs of the following stakeholders. — Civil aviation authority (CAA) — performance of assessments for the revalidation and renewal of flight crew licences and/or ratings — Operator — measurement of individual, crew, fleet and operator pilot performance and identification of development needs for both individuals and the system — Flight crew member — provision of information about performance measured during training, for the purpose of continuous development and improvement. The system was created considering the importance of a number of design criteria. After wide consultation, criteria were considered as follows: Fairness and accuracy, usability, continuous improvement, clarity, implementation risk, data management, adaptability, ease of compliance, motivation Following the criteria definition, the development process was segregated in the following steps, with agreed criteria being applied at each step to determine the optimum solution: System definition (what to grade: the whole event, parts of the event, individual actions or a combination with different granularity): to be consistent with the aims of EBT, this should be the competencies at predetermined points during the module. Grading scales (considering sensitivity and the need to identify unacceptable, minimum acceptable, norm and performance above the norm): a 5-point scale is commonly used with 1 point determined as below acceptable performance, the norm being 3; 2 being a minimum acceptable determination, and 4 and 5 above norm. There are many arguments for and against the number of points on a scale and this should be finally determined by the operator and approved by the competent authority under the operations manual part D. Word pictures: to assure the fulfilment of the criteria, in particular fairness, accuracy and clarity, grades are described by standardised word pictures. They describe the VENN dimensions in a standardised way, and this facilitates inter-rater reliability. The VENN system described in this GM is based on the following measurements at predetermined points during an EBT module: A= HOW WELL (e.g. The pilot communicate ineffectively…) B= HOW OFTEN (e.g. …by rarely demonstrating…) C= HOW MANY (e.g. … any of the performance indicators when required…) D= OUTCOME (e.g. … which resulted in an unsafe situation). In order to ensure consistency a grading system should also be employed for the line evaluation of competence, with information provided for remediation where performance is determined below the minimum acceptable level, which in the example system is 1 on a 5-point scale. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 96 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail GM1 ORO.FC.231(d)(1) point (c) The provisions of EBT regarding grading are more detailed that those ones provided for legacy training in ORO.FC.230 where there is no definition of what training may be required post LPC failure or OPC failure. Remediation may include FSTD training, LIFUS, or something else depending on the circumstances (e.g. virtual- reality training). GM1 ORO.FC.231(d) ‘Application of knowledge’ is a new competency not covered in Doc 9995. EASA is considering under SPT.012 to provide further safety material on this competency transposing some of the material provided by manufacturers. As an example of this, Airbus OTT 999.0012/17 provides the following reference: ‘In order to ensure that the required competencies are acquired and to perform the training on undesired aircraft state, the flight crew should be aware of the following items: - Causes and contributing factors of undesired aircraft state - Examples of incidents related to undesired aircraft state. In addition, the flight crew should review all of the following items: - The control and display systems (EFIS & ECAM): The flight crew should know the indications provided by the display units, but also their evolution over time in order to anticipate the flying conditions. - The flight controls systems, that include flight control laws and protections: The flight crew should know how to handle the aircraft. In addition, the flight crew should know how the protections work, their availability, and their limits. - The automation (Autopilot (AP), Flight Directors (FD) and Auto thrust (A/THR)): The flight crew should know how to use the automation, their availability and their limits. The flight crew should review the practices to engage the automatisms, as well as the takeover techniques and recommendations (Airbus golden rule n°4). - The energy management of the aircraft, that includes thrust settings: The flight crew should understand the acceleration and deceleration capabilities of the aircraft. - The flight envelope limitations: The flight crew should know the flight envelope of the aircraft, in order to keep the aircraft within the environmental and aerodynamic limits, and to know when the aircraft is out of these limits. - Aircraft capability related to flight control laws: The flight crew should know the capability of the aircraft in response to the related active flight control laws (normal, alternate and direct law). - Procedures and techniques related to undesired aircraft state: The flight crew should know the procedure and techniques for nose high and nose low recovery, stall recovery and unreliable airspeed.’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 97 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(d)(2) Evidence-based training VERIFICATION OF THE ACCURACY OF THE GRADING SYSTEM (a) Part-FCL Appendix 9 provides a valid criterion-referenced system to determine the accuracy of the grading system. (b) The operator should identify the mandatory exercises for the proficiency check for type rating and instrument rating in accordance with Part-FCL Appendix 9. Those exercises marked with the letter ‘M’ in the proficiency check column indicate a mandatory exercise or a choice where more than one exercise appears. (c) The operator should then design a single module where all the mandatory exercises are performed to assess the accuracy of the grading system. (d) Instructors should record for the purpose of data analysis if the pilots would have passed the proficiency check should they have taken the check in accordance with Appendix 9. Note: individual pilots are still graded and assessed according to the EBT grading system and Appendix 10; the result of the verification may not be used against the individual pilot. (e) This verification should be performed once every 3 years. (f) The verification will provide data for the training system performance and for the instructor standardisation concordance assurance. GM1 ORO.FC.231(d)(2) Evidence-based training VERIFICATION OF THE ACCURACY OF THE GRADING SYSTEM — FEEDBACK LOOP The verification of the accuracy of the grading system provides valuable data for the training system performance and the concordance assurance. Therefore, the verification is intended from a systemic point of view and not to measure individual pilot against Appendix 9. Concordance between instructors may be high (e.g. same grading in the videos displayed in the annual standardisation course, etc.); however, the whole community of instructors may be grading too low or too high. The statistical result of the verification against Appendix 9 in one single module can provide the operator with a criterion-referenced system in order to adjust the accuracy of the grading system. The verification does not require an examiner, and EBT instructors may provide the necessary data for the grading verification. Example 1: For the last 36 months the operator, has a rate of 3 % of pilots scoring 1 (assuming data is statistically relevant). In this example, the concordance of instructors is high in all competencies and the rate of 3 % of the pilots scoring 1 is maintained across all the technical competencies. When the operator performs a verification of the grading system against Appendix 9 criteria, the rate of failure would have been only 0,5 %. This may indicate that instructors are rating too low and therefore some of the pilots scoring 1 should have been rated at a higher score than 1. From a safety point of view, this situation is fine, although it may be economically negative for the operator. Operators may decide to implement higher standards for their operations. Example 2: The operator has an EBT programme with a negligible rate of pilots scoring 1, and has a statistically higher rate (1 %) of pilots scoring 2 in two consecutive recurrent modules. The verification of the technical competencies against Appendix 9 provides a rate of 5 % failure. Provided the data is statistically significant, the TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 98 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail nominated person for crew training should further investigate the reason of this mismatch between EBT and Appendix 9 in the technical competencies. There may be factors influencing this mismatch (e.g. the events in the EBT modules are too benign compared to the Appendix 9 requirements), which may lead to a corrective action (e.g. redesign of the EBT modules). If the difficulty of the EBT scenarios is equivalent to Appendix 9 and the concordance is high between instructors, then the discrepancy in outcomes might be because the community of instructors are rating too high in the technical competencies (they are rating 2 when they should have rated 1). Further instructor standardisation will be needed to address this. The implementation of mixed EBT following GM1 ORO.FC.230 (a);(b);(f) provides a good opportunity to fine tune and verify the accuracy of the grading system because an appendix 9 is carry out every year. The authority may not allow EBT baseline unless the accuracy of the grading system is demonstrated. More information on how to complete the transition from Appendix 9 to grading under an EBT programme can be found in the EASA safety material checklist ‘Oversight guidance for transition to EBT’. AMC1 ORO.FC.231(d)(2) and ORO.FC.231(d)(2) This NPA already provides explanation about this topic in the explanatory note to ORO.FC.231. The concept of this provision is transposed from the ‘Alternative training and qualification programme’ (ATQP). However, to adapt the concept to EBT, the requirement suffered a complete shift. Background In ATQP, it is required to have a criterion-referenced system to be able to measure the effectiveness of the training programme (see explanation of ATQP below). This criterion is set by the operator. A criterion-referenced system is set up by the regulator for legacy training in the LPC. Where Appendix 9 defines a set of manoeuvres (mandatory manoeuvres) and a set of targets (see Appendix 9 ‘conduct of the proficiency check — Flight tolerances’) which form a criterion-referenced system. ATQP also benefits from this criterion-referenced system of Appendix 9 because every year the ATQP pilots are required to complete an LPC (also see AMC1 ORO.FC.A.245 below point (a)(6)). The method for the assessment in ATQP follows: 1. A task and subtask analysis of each event; 2. Each event has one or more specific training targets/objectives, which require the performance of a specific manoeuvre; 3. For each event, the proficiency that is required to be achieved should be established; 4. The conditions pertaining to each event should also be established; 5. Each event should include a range of circumstances under which the crews’ performance is to be measured and evaluated; 6. The behaviour marker must be specified; and 7. The operator should measure and monitor the progression, and target must be achieved. ‘AMC1 ORO.FC.A.245 Alternative training and qualification programme COMPONENTS AND IMPLEMENTATION TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 99 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (a) Alternative training and qualification programme (ATQP) components The ATQP should comprise the following: (…) (6) A method for the assessment of flight crew during conversion and recurrent training and checking. The assessment process should include event-based assessment as part of the LOE. The assessment method should comply with ORO.FC.230. (i) The qualification and checking programmes should include at least the following elements: (A) a specified structure; (B) elements to be tested/examined; (C) targets and/or standards to be attained; (D) the specified technical and procedural knowledge and skills, and behavioural markers to be exhibited. (ii) An LOE event should comprise tasks and sub-tasks performed by the crew under a specified set of conditions. Each event has one or more specific training targets/objectives, which require the performance of a specific manoeuvre, the application of procedures, or the opportunity to practise cognitive, communication or other complex skills. For each event the proficiency that is required to be achieved should be established. Each event should include a range of circumstances under which the crews’ performance is to be measured and evaluated. The conditions pertaining to each event should also be established and they may include the prevailing meteorological conditions (ceiling, visibility, wind, turbulence, etc.), the operational environment (navigation aid inoperable, etc.), and the operational contingencies (non-normal operation, etc.). (iii) The markers specified under the operator’s ATQP should form one of the core elements in determining the required qualification standard. A typical set of markers is shown in the table below: EVENT MARKER 1. Monitors and reports changes in automation status Awareness of 2. Applies closed loop principle in all relevant situations aeroplane systems: 3. Uses all channels for updates 4. Is aware of remaining technical resources (iv) The topics/targets integrated into the curriculum should be measurable and progression on any training/course is only allowed if the targets are fulfilled.’ — EBT For the measurement of pilot performance, Doc 9995 does not provide a full measurement system. Doc 9995 provides a set of OBs; however, it does not provide a grading system. This was resolved by the EBT subgroup TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 100 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail RMT.0599 that provided a grading system (VENN) — included in this NPA. This allowed a full measurement system for EBT. This system is more of a norm-referenced system than a criterion-referenced system. — Why EBT needs a norm-referenced system instead of criterion-referenced system For many decades the industry has used as performance measurements the completion of manoeuvres like rejected take-off, engine failure between V1 and V2, go-around from minima with the critical engine inoperative and a clearly defined flight tolerance (e.g. – 5knots/+10 knots) to demonstrate the performance of the pilot. In this context, a pilot being able to demonstrate the ability to fly these often-repetitive manoeuvres within prescribed quantitative performance measurements and indicating an acceptable level of deviation from ideal criteria, is deemed to be ‘competent’. EBT is based on the premise that this concept is no longer appropriate as a simple indicator, due to the complexities of modern operations and automation systems, coupled with the significant attribution of serious incidents and accidents to human factors causes. The paradigm shift developed by EBT is that assessments, which are necessary during all forms of training and instruction, as well as evaluation and checking, should be determined according to performance in the defined areas of competency, and not simply by the achievement of a predetermined outcome in a specific manoeuvre. The EBT concept continues to require the completion of certain tasks, but competent flight crew members should be able to complete the tasks reasonably expected of them under achievable conditions. Tasks remain important, but only in so much as they establish a predefined norm according to the curriculum, which in the case of recurrent EBT should be achieved. The key distinction is that EBT envisages a system of competence measurement, which looks at the total performance across a wide range of activities that include some traditional tasks. Another reason why EBT needs a norm-referenced system is the way EBT evaluates pilots. Traditionally the pilot has been check, while EBT assesses pilots instead. EBT moves away from assessment against the execution of predefined manoeuvres and tasks based on the quality of execution (ATQP and traditional training and checking), to a use of the events as a vehicle for developing and assessing crew performance across a range of competencies. EBT also refocuses the instructor population onto analysis of the root causes to correct inappropriate actions, rather than simply asking a flight crew member to repeat a manoeuvre with no real understanding as to why it was not successfully flown in the first instance. For those reasons, the EBT subgroup RMT.0599 provided a competency-based grading system closer to a norm-referenced grading system, rather than a criterion-referenced system. In other words, although the EBT grading system provides a standardised methodology to pilot assessment, it is by definition a norm-referenced grading system (events do not have a set of conditions and the OBs linked to the events do not have a defined and unambiguous criterion). While the criterion-referenced system unambiguously ascertains to what degree the objectives of the manoeuvres have been met, this would mean that instructors would need to focus on the quality of execution of the manoeuvres rather than use the events as a vehicle to develop performance across a range of competencies. Note: A norm-referenced grading system is a type of assessment which yield an estimate of the position of the tested individual in a defined population. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 101 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Note2: A criterion-referenced system is a type of assessment where the behavioural objectives and the systematic generation of test items are designed to unambiguously ascertain to what degree the objectives have been met. — LICENCE REVALIDATION This NPA provides a set of rules to revalidate pilot licence under the EBT programme. A norm-referenced system, is subject to a defined population, thus is subject to the population of pilots of a particular operator. EASA, some authorities, and the pilots’ associations were concerned whether this would create a problem of level playing field for the licence revalidation. Please note that today licence revalidation provides a: — criterion-referenced system for the technical skills; and — norm-referenced system for the non-technical skills (e.g. CRM assessment). To resolve the issue, EASA launched a focused consultation22 in the 4th quarter of 2017 and the 1st quarter of 2018. The consultation concluded that a verification of the norm-referenced system was needed to re-assure the level playing field. (Further explanation is provided in the explanatory notes to ORO.FC.231(d) point (2), AMC1 ORO.FC.231(d)(2) and GM1 ORO.FC.231(d)(2)). A summary of this reasoning is as follows: — The EBT grading is a norm-referenced grading system. Therefore, it varies from operator to operator and it depends on several factors, e.g. company standards, the design of the programme, culture of the organisations, culture of the instructors, etc. — Within an operator a norm-referenced grading system varies throughout time. This happens because the EBT programme varies, the culture of the organisation varies, the culture of the instructors varies, the population of pilots changes, etc. Therefore, a norm-referenced grading system may provide different grading results for the same pilot performance throughout times (for example, as pilot population performance improves, better performance is needed to obtain the same grading result). — These situations occur while the concordance between instructors may be high. Because all instructors are varying their grading in the same direction, the population of pilots is moving to the right or to the left in the graph below, and thus is shifting the grading results of a particular performance to the right or to the left of the graph. Conclusion: Measuring competencies (especially non-technical competencies) using a norm-referenced grading may be more appropriate; however, we also need to verify the grading system against a criterion- referenced system in order to ensure legal assurance and level playing field in the revalidation of pilot licences. 22 EASA performed a focused consultation in 4Q2017 and 1Q2018 with several stakeholders outside the EBT subgroup RMT.0599. This consultation included the main group of RMT.0599 and other actors of the aviation industry such as the national aerospace centre of Holland (NLR), nominated person for crew training, inspectors and consultants. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 102 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail SUMMARY The current system provides for the LPC of the Aircrew Regulation a criterion-reference grading, which measures performance against a fixed set of predetermined criteria or learning standards established through the mandatory manoeuvres and criteria set in Appendix 9. It is necessary for the European aviation system to apply a criterion-referenced grading system for the rating issue and revalidation. In addition, it is necessary for the feedback on the effectiveness of training programme. Therefore, the following tables provide an example for the grading system proposed in this NPA (VENN 1 to 5): — The line between 1 and 2 should have the lowest variation possible between operators by a verification against a criterion-referenced system, while above grade 2, a norm-referenced system may be followed. This means that it may vary in the course of time and therefore the same performance may not obtain year 1 1 2 3 4 5 Norm-referenced system Not proficient proficient Criterion-referenced system the same grading results in the course of time. year 2 1 2 3 4 5 Norm-referenced system Not proficient proficient Criterion-referenced system Observe how the grading system in year 2 provides a grading of 5 to a lower pilot performance than year 1 and year 3. year 3 1 2 3 4 5 Norm-referenced system Not proficient proficient Criterion-referenced system AMC1 ORO.FC.231(d) The EASA EBT checklist for mixed EBT implementation provides the criteria to complete Appendix 9 (e.g. Element 3.6 may credit the item 3.4) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 103 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 3.4.0 to 3.4.14 (M) Normal and abnormal operations of systems. Minimum of 3 for the crew. 3.6.1 to 3.6.9 (M) Abnormal and emergency procedures. Minimum of 3 for the crew. (e) SUITABLE TRAINING DEVICES AND VOLUME TO COMPLETE THE OPERATOR’S APPROVED EBT PROGRAMME (1) Each EBT module shall be conducted in an FSTD with a qualification level adequate to complete proficiency check/training. (2) The operator shall provide sufficient volume of hours in a suitable training device for the pilot to complete the operator’s approved EBT programme. ORO.FC.231(e) point (1) EASA is currently updating the requirements for FSTD through RMT.0196 ‘Update of flight simulation training devices requirements’. More information about this RMT is available under https://www.easa.europa.eu/document-library/rulemaking-subjects/update-flight-simulation-training- devices-requirements. Currently Appendix 9 to the Aircrew Regulation requires the FSTD used to revalidate a type rating in the context of CAT to meet the standard required for ‘training to proficiency’. There was a consensus in the RMG to provide a similar requirement for the EBT programmes. However, the actual drafting of the text for this provision was agreed with EASA FSTD experts and members of RMT.0196. RMG RMT.0599 did not have experts in this subject and therefore the text was simply accepted with no further discussion. The reasoning behind the text proposed is related to the EASA certificate awarded to each FSTD. Each certificate (see EASA form 145 in Appendix IV to Annex VI (Part-ARA) to the Aircrew Regulation) contains a table in paragraph ‘L’ named ‘Guidance information for training, testing and checking considerations’. The line ‘Proficiency check YES/NO’ covers this item. Below are some of the considerations of the RMG for the actual and future development of FSTDs to maximise effectiveness when used as part of an EBT programme: TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 104 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (a) Environmental effects: (1) Weather (2) Real-time full environment simulation without limitations and demand on the instructor to code effects, layers of clouds, etc. repetitively during a session (3) Enhance the availability of cumulonimbus and storms with strong correlation to motion cues (4) Availability of multiple storms and CBs to create a more realistic and challenging weather profile (5) Greater variation in precipitation effects (6) Better-modelled ground effects, particular variations in friction caused by water, snow and ice (7) ATC (8) To maximise realism and the benefits of EBT, the ATC environment needs simulation with context-specific ATC interactions. Creating a normal, dynamic and distracting ATC environment is challenging for an instructor to achieve and is a diversion from the instructor’s primary task of observing flight crew members. (b) Aircraft effects (c) Greater accuracy in modelled engine malfunctions based on engine original equipment manufacturer (OEM) data with motion and sound effects that are more realistic. Finer adjustments when creating sensed and non-sensed malfunctions, so that the instructor can create realistic distractions that may not result in a complete failure of the system. For example, slow leaks of fluids able to be stopped and contained, variations in temperatures and pressures, intermittent cautions based on a condition being sensed momentarily, and then restored. Currently, EASA is working on a process to allow Blended Learning (ABLE) to support FSTD training. This will optimise the use of available FSTD time. When this process is in place as an approved AMC, the requirement for FSTD training may be replaced by requirements for training in any combination of devices supporting the specific tasks. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 105 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(e) Evidence-based training VOLUME AND FSTD (a) The EBT programme has been developed to include a notional exemplar of 48 FSTD hours over a 3-year programme for each flight crew member. (b) Subject to authority approval, the operator may reduce the number of FSTD hours provided an equivalent level of safety is achieved. The programme should never be less than 36 FSTD hours. (c) In addition, the EBT programme should be performed in a full-flight simulator (FFS) level C or D. AMC1 ORO.FC.231(e) point (a) The provision is transposed from Doc 9995 (Part II paragraph 1.1.1). ‘Appendices 2 to 7 form the basis for the construction of EBT recurrent assessment and training programmes. In order to address all assessment and training topics at the defined frequency, a training programme of 48 FSTD hours over a three-year cycle for each flight crew member has been assumed. This EBT recurrent assessment and training should be conducted in an FSTD qualified for the purpose’. Part I paragraph 3.6.1 ‘The EBT recurrent assessment and training of the competencies (contained in Appendix 1 to Part II) are considered over a three-year recurrent assessment and training cycle. For the purposes of the construction of model training programmes as listed in Appendices 2 to 7 to Part II, the programme has been developed to include a notional exemplar 48 hours for each crew member over a three-year period in a suitably qualified flight simulation training device (FSTD). The training programme is divided into modules. The three phases of a module (evaluation, manoeuvres training and scenario-based training) are described in Chapter 7 of Part I.’ (f) EQUIVALENCY OF MALFUNCTIONS (1) Each flight crew member shall receive assessment and training in the management of aircraft system malfunctions. (2) Aircraft system malfunctions that place a significant demand on a proficient crew shall be organised by reference to the following characteristics: (i) immediacy; (ii) complexity; (iii) degradation of aircraft control; (iv) loss of instrumentation; and (v) management of consequences. (3) Crew shall be exposed to at least one malfunction for each characteristic at the frequency determined by the table of assessment and training topics. (4) Demonstrated proficiency in the management of one malfunction is considered equivalent to demonstrated proficiency in the management of other malfunctions with the same characteristics. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 106 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(f) Evidence-based training EQUIVALENCY OF MALFUNCTIONS — PROCESS (a) The equivalency of malfunctions process should be undertaken by subject matter experts (SMEs) who hold or have held a type rating on the aeroplane type. (b) Steps of the equivalency of malfunctions: Step 1: Look (review) at all aircraft system malfunctions provided by the OEM. For example, FCOM, or AFM for other manufacturers is normally not an exhaustive list of malfunctions. Step 2: Determine and retain in a list only malfunctions that place a significant demand on a proficient crew, in isolation from an environmental or operational context. Step 3: For each retained malfunction, determine the applicable characteristic or characteristics. Step 4: Develop the EBT FSTD programme to incorporate malfunctions at the frequency specified in the table of assessment and training topics. (c) Malfunctions included in the equivalency of malfunctions but not included in the EBT FSTD programme require review and appropriate procedural knowledge training, conducted in suitable alternative environment (classroom, flight procedure training device, computer-based training, etc.). AMC1 ORO.FC.231(f) point (b) Step 1 Look (review) at all aircraft system malfunctions provided by the OEM instead of a more prescriptive wording such as flight crew operating manual, because each manufacturer has a different title for the document which contains the malfunctions relative to the aircraft (e.g. Airbus label this FCOM, Boeing FCOM and AFM – other manufacturers use AFM). The quick reference handbook (QRH) is normally not an exhaustive list of malfunctions. AMC1 ORO.FC.231(f) point (b) Steps 1 and 2 Steps 1 and 2 provide a similar concept to today’s AMC1 ORO.FC.230 (a)(4)(i)(A), where the list of major system malfunctions is selected (as per industry best practices) from the list of malfunctions of the real aircraft (not from the list of malfunctions provided by the FSTD). Then the operator selects the ones that are considered ‘major’ and covers them in a 3-year training period. The EBT malfunction clustering follows a similar approach where from the list of malfunctions of the real aircraft, the operator selects the one that put a significant demand on a proficient crew. GM1 ORO.FC.231(f) has been developed to illustrate the concept of significant demand on a proficient crew. Once the malfunction is determined as significant demand, this means that it will have one or more of the 5 characteristics included in GM2 ORO.FC.231(f). AMC1 ORO.FC.231(f) point (c) This point is introduced in the AMC as per Doc 9995 paragraph 3.8.2 which provides the following text: ‘3.8.2 Practical training in the management of aircraft system malfunctions. Aircraft system malfunctions to be considered for the evaluation and scenario-based training phases are those that place a significant demand on a proficient crew. All malfunctions not covered by this characteristic continue to require review and appropriate procedural knowledge training with different means than considered in the recurrent EBT training conducted in an FSTD.’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 107 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail and from Table I-3-1. ‘Malfunction characteristics and crew performance’ ‘Note — This refers to the case of recurrent training and assessment conducted in an FSTD qualified by the CAA at the appropriate level for recurrent training and assessment. Other malfunctions not covered by the characteristics detailed in 3.8.2 and 3.8.3 continue to require review and appropriate procedural knowledge training conducted in a less qualified but suitable environment (classroom, flight procedures training device, etc.), as an additional component of EBT. This is intended simply as a means of offloading the need to perform such training in a highly qualified FSTD, which has much greater potential benefit in other areas’. AMC1 ORO.FC.231(f) point (c) — wording ‘malfunctions included in the equivalency of malfunctions’ The wording proposed is related to the definition of ‘malfunction clustering’ proposed in Annex I to the Air OPS Regulation. AMC1 ORO.FC.231(f) point (c) — wording ‘Equivalency of malfunctions (malfunction clustering): Equivalency of Malfunctions contains all the malfunctions that put a significant demand on a proficient crew, regardless if they are included or not in the FSTD programme. Point (c) was transposed from Doc 9995, Paragraph 3.8.2, and table I-3-1 Note: ‘All malfunctions not covered by this characteristic continue to require review and appropriate procedural knowledge training with different means than considered in the recurrent EBT training conducted in an FSTD’ AMC1 ORO.FC.231(f) point (c) — wording ‘EBT FSTD programme’ This refers to the 3-year EBT FSTD programme. AMC1 ORO.FC.231(f)(3) Evidence-based training CREW EXPOSURE TO AT LEAST ONE MALFUNCTION FOR EACH CHARACTERISTIC Unless specified in the OSD, each crew member should be exposed to the characteristics of degraded control and loss of instrumentation in the role of pilot flying. AMC1 ORO.FC.231(f)(3) The RMG considered this provision an important safety objective; and therefore, originally this provision was at implementing rule level. However, in order to provide flexibility to operators when malfunction clustering has a limited amount of emergencies pertaining to degradation of aircraft control and loss of instrumentation (which varies from aircraft type to aircraft type), the RMG moved this provision to AMC level. The limitation explained before creates a burden and limits the construction of line-orientated scenarios (EVAL and SBT). This feedback derives from operators who have already implemented mixed EBT (e.g. Thomas Cook Scandinavia, Alitalia, Iberia, etc.). Having this provision at AMC level allows for AltMoC in accordance with ORO.GEN.120. GM1 ORO.FC.231(f) Evidence-based training EQUIVALENCY OF MALFUNCTIONS — SIGNIFICANT DEMAND ON A PROFICIENT CREW (a) A procedure for a malfunction (e.g. non-normal, abnormal, emergency) may be considered to place significant demand on a proficient crew member if it results in one or more of the following: (1) time criticality; (2) multiple paths within the procedures (e.g. decision trees); TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 108 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (3) multiple inoperative or degraded systems; (4) a high potential for undetected errors (e.g. removal of flight protections); and (5) significant increases of workload (e.g. removal of automation). (b) When a malfunction is placing a significant demand on a proficient crew, it means it has one or more of the characteristics (see more in GM2.ORO.FC.231(f)). GM1 ORO.FC.231(f) Once the malfunction is determined as a significant demand, this means that the malfunction has one or more of the characteristics determined in GM2 ORO.FC.231(f) – Immediacy, complexity, degradation of aircraft control, loss of instrumentation, and management of consequences. GM2 ORO.FC.231(f) Evidence-based training EQUIVALENCY OF MALFUNCTIONS — MALFUNCTION CHARACTERISTICS The following may be considered suitable definitions for each of the characteristics: (a) ‘Immediacy’: System malfunctions requiring immediate and urgent crew intervention or decision (e.g. malfunctions with memory items) (b) ‘Complexity’: System malfunctions requiring recovery procedures with multiple options to analyse and/or multiple decision paths to apply (c) ‘Degradation of aircraft control’: System malfunctions resulting in significant degradation of flight controls in combination with abnormal handling characteristics (d) ‘Loss of instrumentation’: System malfunctions that require monitoring and management of the flight path using degraded or alternative displays (e) ‘Management of consequences’: System malfunctions affecting significantly the flight crew standard task sharing and/or the workload management and/or the decision-making process during an extensive period Note: Equivalency of malfunctions may be undertaken in consultation with the aircraft OEM. The objective of the OEM consultation is to review the operator analysis regarding the OEM operational certification (e.g. OSD) documents and to the general OEM operation and training policy. GM3 ORO.FC.231(f) Evidence-based training EQUIVALENCY OF MALFUNCTIONS — ISOLATION FROM AN ENVIRONMENTAL OR OPERATIONAL CONTEXT When considering significant demand on a proficient crew, subject matter experts may consider that there are no significant environmental and operational threats. For example, the aircraft is close to a suitable aerodrome with environmental conditions permitting all published approaches to be made, with no pre-existing malfunctions and sufficient fuel for several hours (e.g. A320 or B737 overhead Ibiza - Spain, at FL350 with visible moisture at 30 000 ft, at the aerodrome wind calm, CAVOK, ISA). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 109 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail GM4 ORO.FC.231(f) Evidence-based training EQUIVALENCY OF MALFUNCTIONS PROCESS — DELPHI (a) The operator reviews/looks at aircraft system malfunctions provided in the official documentation of the OEM, for example for Airbus the FCOM, or AFM for other manufacturers. (b) Before launching the equivalency of malfunctions survey and when the aircraft system malfunctions list is very long, the operator may slightly shorten the list by removing the malfunctions that surely will not have a significant demand of a proficiency crew (see GM on SIGNIFICANT DEMAND ON A PROFICIENT CREW) (c) A group of EBT instructors statistically relevant will be selected to perform the equivalency of malfunctions survey. 50 % of the instructors’ community will be used as a reference. In small instructors’ communities, it may be necessary to refer to 100%. In operators with large instructors’ communities, the number of instructors statistically relevant may be less than 50 %. (d) The group of instructors selected in point (c) will rate each of the malfunctions listed in points (a) and (b) (1) Each instructor will rate each one of the 5 characteristics in each malfunction listed in point (b). (2) The rate will be 0 when the malfunction does not have the characteristic (the characteristic does not appear in the malfunction). (3) The rate will be 1 to 5 when the characteristic appears in the malfunction. Rating 1 when the characteristic is not relevant for the malfunction and rate 5 when the characteristic is very relevant. (4) The instructors will rate individually (e.g. home, classroom, etc.) to avoid exchange of opinions with other instructors. (e) An average rate of the whole instructors’ community as a result of point (d) will be calculated for each characteristic of each malfunction. (f) A second round of survey will be performed with the same instructors and the same list. This time the operator will provide the average calculated in point (e) and ask them if in light of the average they would like to change their rating. (g) When an instructor changes their rating, the old rate will be discarded. (h) A new average will be calculated for each characteristic of each malfunction at the end of the second survey. The final average will be rounded to the closest integer number. (i) The operator may select an average rate of the characteristics (e.g. rate 2 or 3) at which or above which the characteristic is considered to be present in the malfunction, thus it places a significant demand on a proficient crew. GM4 ORO.FC.231(f) The Delphi method is a structured communication technique or method, originally developed as a systematic, interactive forecasting method that relies on a panel of experts. The experts answer questionnaires in two or more rounds. After each round, a facilitator or change agent provides an anonymised summary of the experts' forecasts from the previous round as well as the reasons they provided for their judgements. Thus, experts are encouraged to revise their earlier answers in light of the replies of other members of their panel. It is believed TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 110 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail that during this process the range of the answers will decrease and the group will converge towards the ‘correct’ answer. Finally, the process is stopped after a predefined stop criterion (e.g. number of rounds, achievement of consensus, stability of results) and the mean or median scores of the final rounds determine the results. As a reference, the figure of 50 % of the instructor community was provided, for the following reasons: — The malfunction clustering should adjust to the level of training and culture of the company. Therefore, the number of instructors should be sufficient. — The EBT should include the instructors and examiners as much as possible and this community should participate as much as possible in the development of the programme. A high level of participation may indicate that instructors and examiners are committed to implementing EBT. — Minimise the errors: a large community of subject matter experts (50 % of instructors and examiners) are more likely to provide unbiased results, personal views, and biased opinions may be discarded by the average results. Safety promotion material — Equivalency of malfunctions (DELPHI) EASA has planned SPT.012 to support the implementation of EBT. The following material was developed: SPT.012 — safety promotion task 012 — safety material for EBT — EQUIVALENCY OF MALFUNCTIONS EQUIVALENCY OF MALFUNCTIONS PROCESS — DELPHI — CRITERIA ON ELABORATION OF MALFUNCTION CLUSTERING The analysis of the grouping of abnormal and emergency procedures should only be carried out by a TRI EBT/SFI EBT or TRE EBT/SFE EBT in possession of the type rating of the airplane to be analysed. Abnormal and emergencies should be considered in isolation from any environmental or operational context. However, the operator should establish a minimum standardisation guide for those instructors/examiners who are going to carry out the study, in which some guidance is provided to analyse the procedures depending on the flight phase or conditions present, because significant differences will appear at the time evaluation. For instance, an abnormal procedure AIR PACK 1+2 FAULT has not the same consequences below FL100 or at the maximum aircraft Flight Level. Standardisation guidance: — The subject matter experts developing the malfunction clustering should consider that the abnormal/emergency condition will remain when steps to fix the malfunction are included in the malfunction procedure (e.g. the failed engine will not restart, or the fuel pump remains failed after the reset, or the electric generator is not fixed after the reset, etc.). To this end, the operator should reproduce the malfunction in the FSTD programme in the same way (no restart of the engine, or successful reset of the fuel pump or electric generator) in order to meet the characteristics requirement. The operator may include successful resets or restart in addition to the malfunctions considered for the characteristics. When a reset puts a significant demand in a proficient crew, then both options should be included in the malfunction clustering and therefore the same malfunction should be evaluated for both cases: for successful reset/restart and for unsuccessful reset/restart. — Whenever the possibility of icing is specified in the abnormal/emergency procedure, then it is assumed that this meteorological condition is present (e.g. in case of ‘pitot heating’, it is assumed that the TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 111 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail conditions of icing are present). This case should follow the same principle of the previous paragraph, where the EBT FSTD programme should include the icing condition when triggering the pitot heating. — Other possibilities require proper analysis. Grading: — The grading varies from 1 to 5. 1 corresponds to the lowest level of malfunction characteristic. 5 corresponds to the highest. — The abnormal/emergency procedures to be graded are the standard malfunctions for the type of aircraft (e.g. the malfunctions of the FCOM in A320) approved for the EBT programme. — The other malfunctions of the different versions of the aircraft models in the operator’s fleet (e.g. A321 / 319 / 320B4S, etc.) will be subject to a later revision and will be included in the 3-year cycle within the EBT topic ‘Operation- or Type-specific’. Minimum criteria: A minimum of guidance is established when assigning a value to each of the characteristics of abnormal/emergency procedures for the standardisation purpose of the analysis. URGENCY: ‘Immediacy’: System malfunctions requiring immediate and urgent crew intervention or decision (e.g. malfunctions with memory items.) — If the caution or warning displays only crew awareness: minimum rating 1. — If it contains an amber land as soon as possible (ASAP) warning: minimum rating 2. — If it contains the red land as soon as possible (ASAP) notice: minimum rating 3. — If it is a procedure of memory steps: minimum rating 5. COMPLEXITY: ‘Complexity’: System malfunctions requiring recovery procedures with multiple options to analyse and/or multiple decision paths to apply ‘. — If the caution or warning displays only crew awareness: minimum rating 1. — If the caution or warning includes steps: minimum rating 2. — If the caution or warning contains or must be followed by a computer reset: minimum rating 2 (depending on the complexity of the reset). DEGRADATION OF CONTROL: ‘Degradation of aircraft control’: System malfunctions resulting in significant degradation of flight control in combination with abnormal handling characteristics. Any condition that implies an extra difficulty to fly the plane will be taken into account for the characteristic of degradation of control (which may not be limited to the flight control system). For instance, loss of flight laws protections, loss of power plant, etc. The following guidance applies: — Single engine flying (engine failure in multi-engine aircraft): minimum rating is 3 (except for some aircraft types with automatic yaw compensation in engine failures). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 112 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail — Alternative law flight (direct law with landing gear down): minimum rating 3/4. LOSS OF INSTRUMENTATION: ‘Loss of instrumentation’: System malfunctions that require monitoring and management of the flight path using degraded or alternative displays. The characteristic to be assessed is not solely due to loss of cockpit displays. Abnormal/emergency procedures that imply flying with loss of relevant information should also be assessed. This principle increases the number of malfunctions available for this characteristic. This allows a better design of EBT FSTD sessions. — Loss of display units: minimum rate 2. — Significant loss of primary information related to systems (characteristics speeds, flap or slat position, fuel figures, etc.): minimum rate 2. — Loss of information related to abnormal and emergency procedures (FWC 1 + 2 FAULT, SDAC 1 + 2 FAULT, etc.): minimum rate 3. — Loss of information due to single failure (1 ADR Fault, 1 IR Fault, discrepancy messages, etc.): minimum rate 2. — Loss of information due to double failures (1+2 ADR Fault, 1+2 IR Fault, disagree messages, etc.): minimum rate 3/4. — Total loss of information (ADR 1+2+3 Fault, IR 1+2+3 fault, unreliable speed indication, etc.): minimum rate 5. MANAGEMENT OF THE CONSEQUENCES: ‘Management of consequences’: System malfunctions affecting significantly the flight crew standard task sharing and/or the workload management and/or the decision-making process during an extensive period. — Consequences in the category of approach and landing or the required CAT II/III equipment: minimum rating 2. — Consequences in the minimum navigation requirements: minimum rating 2. — APP PROCEDURE in the STS: minimum rating 3. — Single engine landing: minimum rating 3. The operator, once the malfunction clustering analysis has been completed, may reflect in its training manual the maximum and minimum difficulty values of each one of the characteristics of the equivalency of malfunctions (malfunction clustering). Depending on the difficulty value, the malfunction will be included in the different phases of an evaluation session (LOE) and in a training session (LOFT) (e.g. maximum LOE value 20, while SBT accepts the maximum of 25 points). (g) EQUIVALENCY OF APPROACHES RELEVANT TO OPERATIONS The operator shall ensure that flight crew members receive regular training in the conduct of approach types and approach methods relevant to operations that: (1) place an additional demand on a proficient crew. (2) require specific approval. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 113 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC1 ORO.FC.231(g) Evidence-based training ADDITIONAL DEMAND ON A PROFICIENT CREW (a) In order to identify approaches that place an additional demand on a proficient crew, an operator should: (1) review its operational network; (2) select approaches with one or more of the following characteristics: (i) approach design; (ii) frequency of exposure; and (iii) degraded approach guidance; and (3) include the selected approaches at the frequency given in the EBT programme. Note: Only approaches listed within Section 2 of the EBT programme need to be selected by this process. (b) Demonstrated proficiency in the conduct of an approach with one characteristic is considered equivalent to demonstrated proficiency in the management of other approaches in the operational network with the same characteristics. AMC2 ORO.FC.231(g) Evidence-based training EQUIVALENCY OF APPROACHES RELEVANT TO OPERATIONS — SPECIFIC APPROVAL The operator may extend the interval for recurrent training and checking of approaches requiring specific approval to the frequency given in the EBT programme. GM1 ORO.FC.231(g) Evidence-based training EQUIVALENCY OF APPROACHES RELEVANT TO OPERATIONS — APPROACH CHARACTERISTICS The following may be considered suitable examples for each of the approach characteristics: (a) Design: (1) Unusual approach design feature — for example, offset final approach track (2) Unusual runway design feature — for example, non-standard lighting or marking (b) Frequency: (1) Infrequently visited airfields — for example, alternate airfields (2) Infrequently flown approaches at commonly visited airfields — for example, circling approach, CAT 2 (c) Degraded guidance: (1) Degraded internal guidance or aircraft equipment — for example, head-up display (HUD) failure (2) Degraded external guidance or ground equipment — for example, GPS signal failure TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 114 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail GM2 ORO.FC.231(g) Evidence-based training SELECTED APPROACHES AT THE FREQUENCY GIVEN IN THE EBT PROGRAMME The table of assessment and training topics of the EBT programme for each generation provides the type of approach and frequency. Include at least one approach of each type and method which has at least one characteristic at the frequency determined in the table of assessment and training topics. ORO.FC.231(g) and related AMC and GM The RMG developed a definition of the concept as follows: Equivalency of approaches refers to approaches relevant to operation determined by a defined method, leading to a reduced frequency of approaches with an increased focus on the operational relevance rather than just the conduct of an approach which is not realistic in the operational context. — Introduction Doc 9995 recommends approach clustering (‘equivalency of approach types’) as a way to avoid repetitive training on approaches that require the same actions by the pilot (‘underlying elements of flight crew performance to conduct them’). It also recommends avoiding those approaches that are typically flown during line operations (‘Frequency of training may be reduced for types of approaches that are conducted regularly in line operations.’). However, Doc 9995 does not explain how to carry out an ‘equivalency of approach types’ process. Additionally, the recurrent training requirements specified in Part-SPA do not reflect the reality of normal operations. For instance, the use of the HUD in Generation 3 and 4 aircraft types is usually mandated by the operator for all phases of flight, and therefore the requirement to carry out the approaches for recurrent training specified in Part-SPA does not reflect the EBT concept of incorporating approaches that are not conducted regularly in line operations. — Approach Types The industry has moved from essentially 3 different approach genres (non-precision, precision and low- visibility operations (LVOs)) to a multitude of different approaches utilising satellite- and ground-based enhancements. This has given way to the curved approaches and approaches with varying gradients. While an aircraft’s acquisition of the flight path has changed, the ‘underlying performance’ for crews to perform the approaches has changed little, as the OEMs have made the pilot interface with the autopilot and the displays very similar to conventional approaches (i.e. ILS). The main change from a pilot’s viewpoint is the introduction of HUD and emergency vision assurance system (EVAS). Essentially, ICAO Annex 6 has delineated the approach types as two-dimensional (2D) and three- dimensional (3D) approaches, and Type A and B in accordance with the ‘achieved’ minima. Most Generation 3 and 4 aircraft types have the same autopilot/pilot interface and displays for all 3D approach methods, irrespective of whether or not the approach is Type A or Type B. Variations do exist for the conduct of 2D methods depending on OEM. Doc 9995 groups aircraft into generations, with the biggest groups being the Generation 4 and 3 jets. The delineation between the two generations is based upon whether or not the aircraft has fly-by-wire and flight envelope protections. While this delineation is entirely relevant and useful to derive recurrent training programmes, it does not necessarily reflect the avionics capability or the pilots interface with TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 115 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail the autopilot. For example, the 747-8 sits in Generation 3 as it has conventional flight controls. Therefore, it would unnecessarily penalise some aircraft types by clustering them in accordance with the EBT Generation. — HUD and EVAS Generation 4 and Generation 3 aircraft types fitted with a HUD utilise it for all approaches, irrespective of whether or not they are Type A or Type B utilising 3D or 2D methods. This is the standard mode of operation. Similarly, the use of EVAS, although not currently fitted to Generation 3 and 4 aircraft types, is again the standard mode of operation and utilised for all approaches. For recurrent training, flying additional approaches to revalidate the use of the HUD is simply replicating normal line operations with a little benefit. The operator can assure themselves of pilot proficiency in the use of HUD and EVAS, if fitted, through the ‘line evaluation of competence’, when it will be used in the real operational context. — Go-around training Go-around training is not considered in this section because the go-around training frequency is defined by the table of assessment and training topics, and is in excess of that required by Part-SPA. — Approach clustering In the absence of guidance in Doc 9995, the principles used for malfunction clustering have been adopted to create a similar concept for approach clustering. Two principles in particular have been considered:  approaches that place an additional demand on a proficient crew; and  approaches should be selected according to certain characteristics. For the first principle, the emphasis has been changed from ‘significant demand’ to ‘additional demand’. This is because the approach will normally be flown at the end of a scenario within the SBT. That scenario will have included malfunctions and other training topics that have already added ‘significant demand’ on the crew. The approach chosen should therefore contain good training value and realism, without compromising the learning by adding workload on top of workload. For example, a scenario involving a significant malfunction has better value and realism if concluded with an autoland rather than a circling approach. For the second principle, the concept of approach characteristics has been adopted. Doc 9995 lists eight ‘parameters’ that can be used in a clustering process; however, many seem to be types of approaches rather than characteristics. Instead, it was determined that approach characteristics can be divided into three groups, which are listed in the AMC with examples given in the GM. — Types and frequency of approach training As stated earlier, the EBT Generation delineation of aircraft types is not useful when comparing avionics and pilot interface/display information. Many Generation 3 and 4 aircraft types have a single button push for all approaches, with little or no changes in the displayed information. It would seem therefore appropriate to analyse the aircraft in these Generations to review the appropriate types to develop an ‘approach generation/group’. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 116 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail A focus of EBT is to remove extraneous training for which there is little safety benefit, or evidence of need, and in particular, those approaches that are regularly performed in line operations. Additionally, an operator will seek a simple system that allows for the variation in the definition of training topics throughout the semester to cater for the trainees’ needs. Mandating repetitive approaches would not be beneficial to the operator or the trainee alike. Using the frequencies defined in Doc 9995, and applying the emphasis intended by EBT, the following has been derived. Type Flight method Phase Frequency A 3D EVAL & SBT B B 3D EVAL & SBT B A 2D MT B The operator’s policy generally defines which flight method should be used on line operations to conduct these kind of approaches. These recommendations should be followed by crews during LOE. During SBT or manoeuvres validation phase, it should be considered interesting to adapt the conduct of the selected approaches in order to develop specific competencies. There is no intention to define here that a pilot has to be PF for each approach; this is because it is part of the line-orientated scenarios. Any approach that is required to be flown in the PF role-specifically should be classified as ‘skills retention’; therefore, it should be trained in the manoeuvres training phase (MT). The above approaches should be flown simulating normal operations. EVS or HUDs should be utilised if required in normal operations. The allocation of the types of approaches into either the EVAL and SBT phases, or MT phase, was determined by the purpose of the exercise. For the 3D approaches, these are the most commonly flown in normal operations, and would therefore be the most relevant and realistic to be included in training scenarios. They will additionally be chosen to place an additional demand on a proficient crew. In contrast, a 2D approach is typically flown less frequently, and normally only if a 3D approach is unavailable due to aircraft or airport downgrade. For some modern aircraft types (e.g. A380, Boeing 787), it requires multiple, unrealistic failures before a 2D approach is required. Additionally, the flight crew procedures to fly a 2D approach typically demand more automation management skill than a 3D approach. The MT phase is precisely what this is for: to enable pilot skill retention in flying low- probability but higher-risk manoeuvres. The principle behind this type of training is skills retention. The B frequency was considered appropriate for two reasons. Firstly, to align with the malfunction clustering B frequency, and secondly to fit in with the requirements of EVAL and SBT. In a typical EBT programme, there will be eight to ten approaches in these phases per year. As noted earlier, it would be inappropriate to add approaches with additional workload to scenarios that already have significant demand for a proficient crew. Therefore, mandating at least two 3D approaches of different flight methods with additional demand per year was considered the correct number. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 117 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC2 ORO.FC.231(g) The rationale behind this AMC is that the operator has conducted a review of the approaches and taken them into account in placing a demand on a proficient crew and the characteristics. Therefore, more is done in terms of approaches within an operational context than is done today. EBT offers a frequency of B for specific approvals. Currently ATQP also offers a frequency B for specific approvals. (h) LINE EVALUATION OF COMPETENCE (1) Each enrolled flight crew member shall periodically undertake a line evaluation of competence in an aircraft in flight to demonstrate the safe, effective and efficient conduct of normal operations specified in the operations manual. (2) The validity period of a line evaluation of competence shall be 12 months. The validity period shall be counted from the end of the month when the line evaluation of competence was undertaken. When the line evaluation of competence is undertaken within the last 6 months of the validity period, the new validity period shall be counted from the original expiry date. (3) The operator approved for EBT may, with the approval of the competent authority, extend the validity of the line evaluation of competence to: (i) 2 years; or (ii) 3 years, subject to a feedback system for the monitoring of line operations. (4) Evaluation of competencies during line operations shall be conducted by a suitably qualified commander nominated by the operator and trained in EBT concepts and the assessment of competencies. (5) For successful completion, each flight crew member shall demonstrate each competency at or above the minimum acceptable level of performance. ORO.FC.231(h) wording ‘competence’ The heading of the rule is ‘line evaluation of competence’. The word ‘competence’ was selected instead of ‘competency’, because the RMG wanted to reflect that an assessment of the competencies must be made and the pilot has to reach a certain level of performance: ‘competence’. ORO.FC.231(h)(1) The safety objective is stated in the IR. The sentence ‘undertake a line evaluation in an aircraft in flight to ensure safe, effective and efficient conduct’ was transposed from Doc 9995, FOREWORD and in Part I, paragraph 1.6: ‘The aim of this programme is to develop and evaluate the identified competencies required to operate safely, effectively and efficiently in a commercial air transport environment’ ORO.FC.231(h)(1) wording ‘aircraft in flight’ The wording ‘aircraft in flight’ is used in this IR to remove any ambiguity as to where the line evaluation may be undertaken. The RMG noted that in GM1 ORO.FC.230 point (c) there is a mention of ‘line check and proficiency training and checking’ in an FSTD. This will not be transferred into GM1 ORO.FC.231. ORO.FC.231(h)(2) wording ‘period of validity’ The wording for ‘period of validity’ is similar to that used in ORO.FC.245 (d). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 118 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The validity window has been increased to 6 months; this is also in line with other periods of validity that exist in Part-FCL (e.g. revalidation of a rating). ORO.FC.231(h)(3)(i) The intent of this rule is to continue to permit those operators who had been conducting ATQPs for more than 24 months and can therefore continue to apply a 24-month Line Evaluation (Check under ATQP) periodicity when they transition to an EBT programme. It is worthy of note that this does not apply under the mixed EBT implementation phase. ORO.FC.230 & 245 remain applicable. Discretion exists under this IR for a competent authority to grant a 24-month validity period for line checks to those operators who had not previously conducted an ATQP programme. However, the competent authority shall ensure that the operator is fully conversant with a competency-based evaluation system prior to applying this rule. Further guidance will be issued in a safety promotion document – EASA EBT manual. The reason behind allowing extensions of validity periods in the line evaluation of competence (line check) is the following: — Legacy training requires 1 line check per year. — ATQP provides an alleviation of 1 line check every 2 years because it requires a line orientated evaluation per year. That means that 2 LOEs substitute 1 line check. — EBT provides more opportunities than ATQP for LOE, because in the evaluation and in the scenario- based training both scenarios are line-orientated flights and required twice per year (EBT requires 2 modules a year). ORO.FC.231(h)(4) The use of a suitably qualified commander, as required in AMC1 ORO.FC.230 (3)(v), has been retained under EBT. AMC1 ORO.FC.231(h) Evidence-based training LINE EVALUATION OF COMPETENCE (a) The purpose of the line evaluation of competence is to verify the capability of the flight crew member(s) to undertake line operations, including preflight and post-flight activities as specified in the operations manual. The route should be representative of typical sectors undertaken in normal operations. The commander, or any pilot who may be required to relieve the commander, should also demonstrate their competency in the role. (b) Each flight crew member should be assessed according to the competency framework and grading sytem approved for their operator’s approved EBT programme. (c) Flight crew members should be assessed in duties as pilot flying and pilot monitoring; they should be evaluated in each role. Therefore, they should be checked on one flight sector as pilot flying and on another flight sector as pilot monitoring. (d) The operator should inform the competent authority about the suitably qualified commander nominated to undertake line evaluations of competence. The commander should be trained following the applicable provisions contained in AMC1 ORO.FC.145 (a)(3) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 119 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (e) The person conducting the line evaluation of competence should occupy an observer’s seat. For aeroplanes, in the case of long-haul operations where additional operating flight crew members are carried, the person may fulfil the function of a cruise relief pilot and should not occupy either pilot’s seat during take-off, departure, initial cruise, descent, approach and landing. (f) Unless credit related to the line evaluation of competence is defined in the mandatory parts of the OSD for the relevant types or variant, the extension of the validity of line evaluation of competence is only achievable for operation of a single type or variant. AMC1 ORO.FC.231(h) The AMC was developed following the principles contained in the AMC1 ORO.FC.230 point (b)(3) on line check. For some of the points, there is almost a direct transposition with only minor amendments. For others, the amendments are extensive. AMC1 ORO.FC.231(h) point (a) The requirement is extracted from AMC1 ORO.FC.230 (b)(3)(i) with the proper modifications: ‘The commander, or any pilot who may be required to relieve the commander, should also demonstrate his/her ability to ‘manage’ the operation and take appropriate command decisions.’ AMC1 ORO.FC.231(h) point (f) The RMG following the principles contained in ORO.FC.240 agreed to not allow extension of validity of the line evaluation of competence further away than those allowed in ORO.FC.240. ORO.FC.240 and AMC1 ORO.FC.240 allows consecutive line checks; therefore, a check is required to performed every year; however, this is made alternatively in each type, so a check is performed for each single type every 2 years. This can be seen as an extension of the validity period of the line evaluation of competence. AMC2 ORO.FC.231(h)(3) Evidence-based training LINE EVALUATION OF COMPETENCE In order to extend the validity of the line evaluation of competence to: (a) 2 years, the operator should comply with the minimum experience to substitute ORO.FC.230 (AMC1 ORO.FC.231(a)(1)) and the majority of EBT instructors delivering the EBT modules should demonstrate their ability to efficiently complete the operator’s line evaluation of competence; (b) 3 years, in addition to point (1) above, the operator should have a feedback system for the monitoring of line operations (e.g. LOQE/FOQA), which: (1) identifies threats in the airline’s operating environment; (2) identifies threats within the airline’s operations; (3) assesses the degree of transference of training to the line operations; (4) checks the quality and usability of procedures; (5) identifies design problems in the human/machine interface; (6) understand pilots’ shortcuts and workarounds; and TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 120 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (7) assesses safety margins. AMC2 ORO.FC.231(h)(3) The 2–3-year extension of the line evaluation of competence (LEoC) provides a vehicle for operators who have ATQP to continue with the credits they have under an ATQP. The safety case is that an ATQP operator needs 2 years of ATQP before is approved for an extension of the line check. This requirement is mirrored here, as the operator will need 2 years of mixed EBT implementation to extend the LEoC. To encourage an operator to use line operations safety data programmes because they provide further safety enhancements, the 3-year extension is offered if the safety data programme is integrated within the EBT programme. The requirement of the safety data programme was transposed from FAA AC120-90 dated 27th April 2006 paragraph 5. AMC2 ORO.FC.231(h)(3) point (a) One of the purposes of a line check is to verify the ability of a pilot to undertake normal line operations in the real aircraft. The validity of the line evaluation of competence is extended with the condition that the pilot ability to undertake normal line operations is maintained. For that purpose, the majority of the EBT instructors who provide the EBT modules must be line pilots who completed a line evaluation of competence themselves as specified in the operations manual, in order to assess properly the ability of the pilots to undertake normal line operations. The requirements are related to ORO.FC.231: ‘(2) The features of the operator’s approved EBT programme shall: (i) assess and develop the competencies required by flight crew members for safe, effective and efficient operations of aircraft Operations in the context refers to normal, abnormal and emergency operations of aircraft’. GM1 ORO.FC.231(h) Evidence-based training LINE EVALUATION OF COMPETENCE (a) Line evaluation of competence, route and aerodrome knowledge, and recent experience requirements are intended to verify the capability of the flight crew member(s) to operate safely, effectively and efficiently under line operating conditions, including preflight and post-flight activities as specified in the operations manual, whereas other checks and emergency and safety equipment training are primarily intended to prepare flight crew members for abnormal/emergency procedures. (b) The line evaluation of competence is considered a particularly important factor in the development, maintenance and refinement of high operating standards, and can provide the operator with a valuable indication of the usefulness of its training policy and methods. GM1 ORO.FC.231(h) This text was inspired from the current regulatory material of AMC1 ORO.FC.230 and GM1 ORO.FC.230. However, the RMG proposed some small amendments. Some of them are explained below: The RMT noted GM1 ORO.FC.230 point (c). ‘(c) Proficiency training and checking TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 121 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail When an FSTD is used, the opportunity should be taken, where possible, to use LOFT’. The RMG decided to not transpose this provision into GM1 ORO.FC.231. GM1 ORO.FC.231(h) point (a) ‘Line operations’ is used instead of ‘normal line operation’ because ‘normal line operations’ will imply that if the crew face a failure in the aircraft, they may not be able to complete the line check. ‘including preflight and post-flight activities as specified in the operations manual’ is introduced (this wording is not present in AMC or GM to ORO.FC.230) to clarify the scope of the line evaluation of competence. The EBT subgroup RMT.0599 believes that the current regulation in regard to ‘line checks’ (ORO.FC.230) should also clarify this item. GM1 ORO.FC.231(h)(4) Evidence-based training SUITABLY QUALIFIED COMMANDER TRAINED IN EBT CONCEPTS AND THE ASSESSMENT OF COMPETENCIES (a) AMC1.ORO.FC.145(a)(3) ‘Provision of training’ provides under ‘EBT instructor training’ suitable learning objectives which may be used to qualify the commander nominated by the operator to perform line evaluation of competence. The course may comprise theoretical and practical training. At the completion, the commander should: (1) have knowledge of EBT, including the following underlying principles: (i) competency-based training; (ii) learning from positive performance; (iii) building resilience; and (iv) data-driven training; (2) conduct objective observations based on a competency framework, and document evidence of observed performance; (3) relate specific performance observations of competencies; (4) analyse trainee performance to determine competency-based training needs and recognise strengths; (5) evaluate performance using a competency-based grading system; (6) facilitate trainee learning, focusing on specific competency-based training needs; and (7) conduct a debrief using facilitation techniques. (b) Instructors may be given credits on the topics of point (c) if they have previously demonstrated competencies in those topics. New ORO.FC.231(i) (i) GROUND TRAINING (1) Each flight crew member shall undergo ground training and training on the location and use of all emergency and safety equipment carried on the aircraft at least every 12 calendar months. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 122 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (2) The operator may, with the approval of the competent authority, extend the period of training on the location and use of all emergency and safety equipment carried on the aircraft to 24 months. ORO.FC.231(i)(1) The provision was drafted as follows: The RMG: (a) transposed the existing ORO.FC.230 of the Air OPS Regulation: ‘(…) (d) Emergency and safety equipment training and checking Each flight crew member shall complete training and checking on the location and use of all emergency and safety equipment carried. The validity period of an emergency and safety equipment check shall be 12 calendar months. (…) (f) Each flight crew member shall undergo ground training and flight training in an FSTD or an aircraft, or a combination of FSTD and aircraft training, at least every 12 calendar months. (…)’ (b) combined the 2 points. (c) removed the word ‘check’ because in EBT the concept of checking is removed. Also in the industry, training and checking are combined; therefore, the text is intended to reflect industry’s practice. (d) finalised the provision by adjusting the text to the EBT regulation. ORO.FC.231 (i)(2) The provision is transposed from ORO.FC.A.245 of the Air OPS Regulation and reworded as appropriated. The alleviation is consistent with the existing alleviation provided for the ATQP. AMC1 ORO.FC.231(i) Evidence-based training GROUND TRAINING (a) Ground training (1) The ground training programme should include: (i) aircraft systems; (ii) operational procedures and requirements; and (iii) accident/incident and occurrence review. (2) Knowledge of the ground training should be verified by a questionnaire or other suitable methods. (3) When the ground training is conducted within 3 calendar months prior to the expiry of the 12- calendar-month-period, the next ground training should be completed within 12 calendar months of the original expiry date of the previous training. (b) Emergency and safety equipment training TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 123 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (1) Emergency and safety equipment training should be conducted in an aircraft or a suitable alternative training device. (2) Every year the emergency and safety equipment training programme should include the following: (i) actual donning of a life-jacket, where fitted; (ii) actual donning of protective breathing equipment, where fitted; (iii) actual handling of fire extinguishers of the type used; (iv) instruction on the location and use of all emergency and safety equipment carried on the aircraft; (v) instruction on the location and use of all types of exits; and (vi) security procedures. (3) Every 3 years the programme of training should include the following: (i) actual operation of all types of exits; (ii) demonstration of the method used to operate a slide where fitted; (iii) actual firefighting using equipment representative of that carried on the aircraft on an actual or simulated fire except that, with Halon extinguishers, an alternative extinguisher may be used; (iv) the effects of smoke in an enclosed area and actual use of all relevant equipment in a simulated smoke-filled environment; (v) actual handling of pyrotechnics, real or simulated, where applicable; (vi) demonstration in the use of the life rafts, where fitted; and (vii) particularly in the case where no cabin crew is required, first aid appropriate to the aircraft type, the kind of operation and the crew complement. (4) The successful resolution of aircraft emergencies requires interaction between flight crew and cabin/technical crew and emphasis should be placed on the importance of effective coordination and two-way communication between all crew members in various emergency situations. (5) Emergency and safety equipment training should include joint practice in aircraft evacuations so that all who are involved are aware of the duties other crew members should perform. When such practice is not possible, combined flight crew and cabin/technical crew training should include joint discussion of emergency scenarios. (6) Emergency and safety equipment training should, as far as practicable, take place in conjunction with cabin/technical crew undergoing similar training with emphasis on coordinated procedures and two-way communication between the flight crew compartment and the cabin. (7) Knowledge of the emergency and safety equipment training should be verified by a questionnaire or other suitable methods. (8) When the emergency and safety equipment training is conducted within 3 calendar months prior to the expiry of the 12-calendar-month-period, the next emergency and safety equipment TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 124 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail training should be completed within 12 calendar months of the original expiry date of the previous training. (c) Emergency and safety equipment training — Extension of period of training (1) The emergency and safety equipment training programme should establish and maintain at least an equivalent level of proficiency achieved by complying with the provisions of (b). The level of flight crew training proficiency shall be demonstrated prior to being granted approval to extend the period of training by the competent authority. (2) The operator applying for an approval to extend the period of emergency and safety equipment training should provide the competent authority with an implementation plan, including a description of the level of flight crew training proficiency to be achieved. The implementation plan should comprise the following: (i) A safety case, which should: (A) demonstrate that the required or equivalent level of training proficiency is maintained; (B) incorporate the programme of implementation, to include controls and validity checks; (C) minimise risk during all phases of the programme’s implementation and operation; and (D) include oversight, including review and audits. (ii) A feedback loop in order to validate and refine the programme, and to ascertain that the programme meets its proficiency objectives. The feedback should be used as a tool to validate that the programme is implemented; this enables substantiation of the programme, and that proficiency and training objectives have been met. The feedback loop should include data from the emergency and safety equipment training programme. In addition, the evaluation process should describe whether the overall targets/objectives of training are being achieved and should prescribe any corrective action that needs to be undertaken. (iii) Documentation that details the scope and requirements of the programme, including the following: (A) the operator’s training needs and established operational and training objectives; (B) a description of the process for designing and obtaining approval for the operator’s emergency and safety equipment training programmes. This should include quantified operational and training objectives identified by the operator’s internal monitoring programmes. External sources may also be used; and (C) a description of how the programme will develop a support and feedback process to form a self-correcting training system. (3) When the emergency and safety equipment training is conducted within 6 calendar months prior to the expiry of the 24-calendar-month-period, the next emergency and safety equipment TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 125 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail training should be completed within 24 calendar months of the original expiry date of the previous training. AMC1 ORO.FC.231(i) The proposed AMC points (a) and (b) is transposed from AMC1 ORO.FC.230. The proposed AMC point (c) is based on the principles established in ORO.FC.A.245 and AMC1 ORO.FC.A.245 ‘Alternative training and qualification programme’. AMC1 ORO.FC.231(i) point (a)(1)(ii) The provision is transposed from AMC1 ORO.FC.230 point (a)(1) ‘ground training’ point (i)(B), which states: ‘(B) operational procedures and requirements, including ground de-icing/anti-icing and pilot incapacitation;’ However, ‘de-icing/anti-icing and pilot incapacitation’ is deleted because it is already provided in the ‘table of assessment and training topics’ as a training topic. AMC1 ORO.FC.231(i) point (a)(3) ‘ground training’ The word used in AMC1 ORO.FC.230 is ‘ground and refresher training’; however, this wording will be modified in order to align with the title of the AMC and therefore avoid duplication and misunderstanding. AMC1 ORO.FC.231(i) point (b)(3)(iv) The provision is transposed from AMC1 ORO.FC.230 point (a)(2) ‘Emergency and safety equipment training’ point (iii)(F). However, the provisions for helicopters are deleted as currently EBT, in accordance with Doc 9995, is only provided for some types of aeroplanes. EASA is currently working on the development of an EBT data report for helicopters in order to allow first a mixed EBT implementation and in the future an EBT programme for helicopters. AMC1 ORO.FC.231(i) point (b)(7) As explained above, AMC1 ORO.FC.231(i) points (a) and (b) are transposed from AMC1 ORO.FC.230; however, the training elements and the checking elements are scattered across point (a) and point (b) of AMC1 ORO.FC.230. As in ORO.FC.231 both elements are combined in a single point, point (b)(7) is introduced; however, the wording is modified as in EBT the word ‘checking’ is not used. AMC1 ORO.FC.231(i) point (c) The requirement is transposed from the existing ATQP provision (see ORO.FC.A.245 of the Air OPS Regulation). The reason behind using the ATQP provisions is that emergency and safety equipment is out of the scope of EBT competencies; therefore, the ATQP provision is fit for purpose for the extension of validity. The maximum validity of 24 months is also transposed from ATQP. AMC1 ORO.FC.231(i) point (c)(1) This point is transposed from ORO.FC.245.A point (b) and adapted for the purposed of the AMC regarding ground training. This requirement provides the safety objective if an extension is requested, which is to achieve and maintain the level of proficiency set out in point (b) In ATQP, ORO.FC.245.A.245 point (b) is then reflected in AMC1 ORO.FC.A.245 point (a)(1)(i) ‘documentation’. However, the proposal for ground training under the EBT programme does not impose these requirements. This does not mean that the competent authority is not entitled to ask for it; however, as the scope of the TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 126 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ground training is limited and the safety objectives of the EBT are demonstrated elsewhere, the proposed regulation tries to avoid unnecessary burdens. AMC1 ORO.FC.231(i) point (c)(2)(iii) The provision is transposed from AMC1 ORO.FC.A.245.point (a)(1) ‘documentation’; however, the following adjustments have been made: Point (i) of AMC1 ORO.FC.A.245 is not included; Point (ii) of AMC1 ORO.FC.A.245 is transposed with no change; Point (iii) of AMC1 ORO.FC.A.245 is transposed with slight modifications; Point (iv) of AMC1 ORO.FC.A.245 — only the concept is transposed and provision is made to express the safety objective. Extract of AMC1 ORO.FC.A.245 ‘(1) Documentation that details the scope and requirements of the programme, including the following: (i) The programme should demonstrate that the operator is able to improve the training and qualification standards of flight crew to a level that exceeds the standards prescribed in ORO.FC and Subpart E of Annex V (SPA.LVO). (ii) The operator’s training needs and established operational and training objectives. (iii) A description of the process for designing and gaining approval for the operator’s flight crew qualification programmes. This should include quantified operational and training objectives identified by the operator’s internal monitoring programmes. External sources may also be used. (iv) A description of how the programme will: (A) enhance safety; (B) improve training and qualification standards of flight crew; (C) establish attainable training objectives; (D) integrate CRM in all aspects of training; (E) develop a support and feedback process to form a self-correcting training system; (F) institute a system of progressive evaluations of all training to enable consistent and uniform monitoring of the training undertaken by flight crew; (G) enable the operator to be able to respond to new aeroplane technologies and changes in the operational environment; (H) foster the use of innovative training methods and technology for flight crew instruction and the evaluation of training systems; and (I) make efficient use of training resources, specifically to match the use of training media to the training needs’. ORO.FC.240 Operation on more than one type or variant AMC1 ORO.FC.240 Operation on more than one type or variant GENERAL (a) Aeroplanes TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 127 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (1) When a flight crew member operates more than one aeroplane class, type or variant, as determined by the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for class-single pilot or type-single pilot, but not within a single licence endorsement, the operator should ensure that the flight crew member does not operate more than: (i) three reciprocating engine aeroplane types or variants; (ii) three turbo-propeller aeroplane types or variants; (iii) one turbo-propeller aeroplane type or variant and one reciprocating engine aeroplane type or variant; or (iv) one turbo-propeller aeroplane type or variant and any aeroplane within a particular class. (2) When a flight crew member operates more than one aeroplane type or variant within one or more licence endorsement, as determined by the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012, the operator should ensure that: (i) the minimum flight crew complement specified in the operations manual is the same for each type or variant to be operated; (ii) the flight crew member does not operate more than two aeroplane types or variants for which a separate licence endorsement is required, unless credits related to the training, checking, and recent experience requirements are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for the relevant types or variants; and (iii) only aeroplanes within one licence endorsement are flown in any one flight duty period, unless the operator has established procedures to ensure adequate time for preparation. (3) When a flight crew member operates more than one aeroplane type or variant as determined by the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for type-single pilot and type-multi pilot, but not within a single licence endorsement, the operator should comply with points (a)(2) and (4). (4) When a flight crew member operates more than one aeroplane type or variant as determined by the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for type multi-pilot, but not within a single licence endorsement, or combinations of aeroplane types or variants as determined by the operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for class single-pilot and type multi- pilot, the operator should comply with the following: (i) point (a)(2); (ii) before exercising the privileges of more than one licence endorsement: (A) flight crew members should have completed two consecutive operator proficiency checks OPCs and should have: — 500 hours in the relevant crew position in CAT operations with the same operator; or TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 128 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail — for IFR and VFR night operations with performance class B aeroplanes, 100 hours or flight sectors in the relevant crew position in CAT operations with the same operator, if at least one licence endorsement is related to a class. A check flight should be completed before the pilot is released for duties as commander; (B) in the case of a pilot having experience with an operator and exercising the privileges of more than one licence endorsement, and then being promoted to command with the same operator on one of those types, the required minimum experience as commander is 6 months and 300 hours, and the pilot should have completed two consecutive operator proficiency checks OPCs before again being eligible to exercise more than one licence endorsement; (iii) before commencing training for and operation of another type or variant, flight crew members should have completed 3 months and 150 hours flying on the base aeroplane, which should include at least one proficiency check, unless credits related to the training, checking and recent experience requirements are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for the relevant types or variants; (iv) after completion of the initial line check on the new type, 50 hours flying or 20 sectors should be achieved solely on aeroplanes of the new type rating, unless credits related to the training, checking and recent experience requirements are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for the relevant types or variants; (v) recent experience requirements established in Commission Regulation (EU) No 1178/2011 for each type operated; (vi) the period within which line flying experience is required on each type should be specified in the operations manual; (vii) when credits are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for the relevant type or variant, this should be reflected in the training required in ORO.FC.230 and: (A) ORO.FC.230 (b) requires two operator proficiency checks OPCs every year. When credits are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for operator proficiency checks OPCs to alternate between the types, each operator proficiency check OPC should revalidate the operator proficiency check OPC for the other type(s). The operator proficiency check OPC may be combined with the proficiency checks for revalidation or renewal of the aeroplane type rating or the instrument rating in accordance with Commission Regulation (EU) No 1178/2011. For approved EBT programmes, ORO.FC.231(a)(3) requires to complete a minimum of 2 modules of the EBT programme, separated by a period of more than 3 months, within a 12-month period, and is trained according to assessment and training topics distributed across a 3-year period at the defined frequency relevant to the type or variant of aircraft. When credits are defined in operational suitability data established in accordance with Commission Regulation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 129 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (EU) No 748/2012, EBT modules should alternate between types. The EBT modules may be combined for revalidation or renewal of the aeroplane type rating or the instrument rating in accordance with Commission Regulation (EU) No 1178/2011. When operating more than one type of different generation, the operator has to fulfil both generation base line programmes as per AMC2 ORO.FC.231(a). (B) ORO.FC.230 (c) requires one line check every year. When credits are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for line checks to alternate between types or variants, each line check should revalidate the line check for the other type or variant. For approved EBT programmes, ORO.FC.231(h) requires one line evaluation of competence every year. When credits are defined in operational suitability data established in accordance with Commission Regulation (EU) No 748/2012 for line evaluation of competence to alternate between types or variants, each line evaluation of competence should revalidate the line evaluation of competence for the other type or variant. (C) Annual emergency and safety equipment training and checking should cover all requirements for each type. For approved EBT programmes, ORO.FC.231(i) allows an operator, with the approval of the competent authority, to extend the period of training on the location and use of all emergency and safety equipment for each type to 24 months. (b) Helicopters […] AMC1 ORO.FC.240 The RMG developed the AMC and concluded: — ORO.FC.140 is applicable to EBT and does not require modification. ‘ORO.FC.140 Operation on more than one type or variant (a) Flight crew members operating more than one type or variant of aircraft shall: comply with the requirements prescribed in this Subpart for each type or variant, unless credits related to the training, checking, and recent experience requirements are defined in the mandatory part of the operational suitability data established in accordance with Regulation (EU) No 748/2012 for the relevant types or variants. (b) Appropriate procedures and/or operational restrictions shall be specified in the operations manual for any operation on more than one type or variant.’ — ORO.FC.240 is applicable to EBT and does not require modification. However, some minor modifications were needed in AMC1 ORO.FC.240. — Part-FCL of the Aircrew Regulation and AMC1 FCL.740 point (a) should specify that in case of operations on more than one type or variant, two modules shall be performed on each type or variant for revalidation. — The group discussed iwhether the simulators of the module should be performed in the same aircraft type or it is possible to perform the simulators in different aircraft types. The conclusion was that simulators should be performed in the same aircraft type. — Finally, the RMG concluded that in case of different generations of aircraft, the operator has to fulfil both generations’ EBT programme requirements as per AMC 2,3,4,5 to 6 ORO.FC.231(a). TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 130 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Appendix II to Part-ORO of Regulation (EU) No 965/2012 APPENDIX II — EBT PROGRAMME The EBT programme shall ensure that flight crew members are exposed to assessment and training topics relevant to the type or variant of aircraft on which they operate. Aircraft types not included shall not apply EBT. AMC1 to Appendix II — EBT programme AIRCRAFT TYPE BY GENERATIONS Generation 4 — Jet A318/A319/A320/A321 (including neo), A330, A340- AMC2 ORO.FC.231(a) 200/300, A340-500/600, B777, A380, B787, A350, Bombardier C Series, Embraer E170/E175/E190/E195 Generation 3 — Jet A310/A300-600, B737-300/400/500, B737-600/700/800 AMC3 ORO.FC.231(a) (NG), B737 MAX, B757, B767, B747-400, B747-8, B717, BAE 146, MD11, MD80, MD90, F70, F100, Bombardier CRJ Series, Embraer ERJ 135/145 Generation 3 — Turboprop ATR 42-600, ATR 72-600, Bombardier Dash 8-400, BAE AMC4 ORO.FC.231(a) ATP, Embraer 120, Saab 2000 Generation 2 — Jet A300 (except A300-600), BAC111, B727, B737-100/200, AMC5 ORO.FC.231(a) B747-100/200/300, DC9, DC10, F28, L1011 Generation 2 — Turboprop ATR 42, ATR 72 (all series except -600), BAE J-41, Fokker AMC6 ORO.FC.231(a) F27/50, Bombardier Dash 7 and Dash 8-100/200/300 Series, Convair 580-600 Series, Shorts 330 and 360, Saab 340 Generation 1 — Jet DC8, B707 AMC7 ORO.FC.231(a) GM1 to Appendix II — EBT programme FLIGHT PHASE FOR ACTIVATION Part I, 3.3.3 Abbreviation Flight phase Phase # Description ALL All All flight Any or all phases of flight phases GND Flight planning, Phase 1 and Ground phases up to when the crew increases thrust for preflight, engine Phase 8 taking-off. start and taxi-out Taxi-in, engine From the speed that permits the aircraft to be shut-down, post- manoeuvred by means of taxiing for arriving at a parking flight and flight area until the crew completes post-flight and flight closing TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 131 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Part I, 3.3.3 Abbreviation Flight phase Phase # Description closing duties. TO Take-off Phase 2 This phase begins when the crew increases the thrust for taking-off. It ends after the speed and configuration are established at a defined manoeuvring altitude or to continue the climb for cruise. CLB Climb Phase 3 This phase begins when the crew establishes the aircraft at a defined speed and configuration enabling the aircraft to increase altitude for the purpose of cruise. It ends with the aircraft established at a predetermined constant initial cruise altitude at a defined speed. CRZ Cruise Phase 4 The cruise phase begins when the crew establishes the aircraft at a defined speed and predetermined constant initial cruise altitude and proceeds in the direction of a destination. It ends with the beginning of descent for an approach. DES Descent Phase 5 This phase begins when the crew departs the cruise altitude for an approach at a particular destination. It ends when the crew initiates changes in aircraft configuration and/or speed to facilitate a landing on a particular runway. APP Approach Phase 6 This phase begins when the crew initiates changes in aircraft configuration and/or speeds enabling the aircraft to manoeuvre for landing on a particular runway. It ends when the aircraft is in the landing configuration and the crew is dedicated to land on a specific runway. It also includes go-around where the crew aborts the descent to the planned landing runway during the approach phase. Go-around ends after speed and configuration are established at a defined manoeuvring altitude or to continue the climb for cruise. LDG Landing Phase 7 This phase begins when the aircraft is in the landing configuration and the crew is dedicated to touchdown on a specific runway. It ends when the speed permits the aircraft to be manoeuvred by means of taxiing for arrival TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 132 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Part I, 3.3.3 Abbreviation Flight phase Phase # Description at a parking area. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 133 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC2 to Appendix II — EBT programme GENERATION 4 (JET) — TABLE OF ASSESSMENT AND TRAINING TOPICS REFERRED TO IN AMC2 ORO.FC.231(a) Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map Section 1 Engine failure after the application of Rejected take-off A TO From initiation of take-off to complete stop (or as applicable to procedure) x x take-off thrust and before reaching V1 Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised at engine between V1 & A TO before reaching V2 in lowest CAT I normal engine-out climb speed with the correct pitch and lateral control, in trim condition x x V2 visibility conditions and, as applicable, autopilot engagement Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised in a engine between V1 & B TO before reaching V2 in lowest CAT I x x V2 visibility conditions Demonstrate manual aircraft control clean configuration with engine-out procedures completed skills with smoothness and accuracy as Manoeuvres training phase Initiation of emergency descent from appropriate to the situation The manoeuvre is considered to be completed once the aircraft is stabilised in emergency Emergency descent C CRZ Detect deviations through instrument descent configuration (and profile) x x x normal cruise altitude scanning With a critical engine failed, manually Maintain spare mental capacity during This manoeuvre should be flown from intercept to centreline until acceleration after go- flown normal precision approach to DA, manual aircraft control around. The manoeuvre is considered to be complete at a point when aircraft is stabilised Engine-out approach A APP followed by manually flown go-around, Maintain the aircraft within the flight at normal engine-out climb speed with the correct pitch and lateral control, in trim x x & go-around the whole manoeuvre to be flown envelope condition and, as applicable, autopilot engagement (describe generally critical part of without visual reference Apply knowledge of the relationship manoeuvre) between aircraft attitude, speed and thrust High energy, initiation during the approach at 150 to 300 m (500 to 1 000 ft) below the APP Go-around, all engines operative x x x missed approach level-off altitude Go-around A Go-around, all engines operative APP Initiation of go-around from DA followed by visual circuit and landing x x x followed by visual circuit, manually flown APP Go-around, all engines operative During flare/rejected landing x x x Initiation in a stabilised engine-out configuration from not less than 3 NM final approach, Engine-out landing A LDG With a critical engine failed, normal landing x x until completion of roll-out Section 2 Equivalency of Approaches relevant to operations Approach type A or See equivalency of approaches B APP Approach type A or B flight method 3D See equivalency of approaches relevant to operations x x x x X B relevant to operations MT phase See equivalency of approaches Approach type A B APP Approach type A flight method 2D See equivalency of approaches relevant to operations x x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations TE.RPRO.00034-006 © European Aviation Safety Agency. 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Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map See equivalency of approaches Approach type A B APP Approach type A flight method 3D See equivalency of approaches relevant to operations x x x x x relevant to operations EVAL and SBT phases See equivalency of approaches X Approach type B B APP Approach type B flight method 3D See equivalency of approaches relevant to operations x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations Section 3 Training topics frequency (A) in alphabetical order. GND Predictive wind shear warning before take-off, as applicable x x x ALL Adverse-weather scenario, e.g. thunderstorm activity, precipitation, icing x x x x TO Wind shear encounter during take-off, not predictive x x x x TO Predictive wind shear warning during take-off x x x x TO Crosswinds with or without strong gusts on take-off x x CRZ Wind shear encounter scenario during cruise x x x x x APP Anticipate adverse weather Reactive wind shear warning during approach or go-around x x x x Thunderstorm, heavy rain, turbulence, Prepare for suspected adverse Evaluation and scenario-based training phases APP ice build-up to include de-icing issues, as Predictive wind shear warning during approach or go-around x x x x weather well as high- temperature conditions. Adverse weather A Recognise adverse weather APP The proper use of use of anti-ice and de- Thunderstorm encounter during approach or on missed approach x x x Take appropriate action icing systems should be included Apply appropriate procedure correctly APP generally in appropriate scenarios. Increasing tailwind on final (not reported) x x x x Assure aircraft control Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x downdrafts, gusts and crosswinds including shifting wind directions Non-precision approach in cold temperature conditions, requiring altitude compensation APP x x x for temperature, as applicable to type APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Reduced visibility even after acquiring the necessary visual reference during approach, APP x x x due to rain or fog TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 135 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map CLB CRZ ACAS warning, recovery and subsequent engagement of automation x x DES APP FMS tactical programming issues, e.g. step climb, runway changes, late clearances, ALL x x X destination re-programming, executing diversion Know how and when to use the flight CLB CRZ DES APP management system(s), guidance and Recoveries from TAWS, management of energy state to restore automated flight x x x automation CLB CRZ Demonstrate correct methods for Amendments to ATC cleared levels during altitude capture modes to force mode engagement and disengagement of awareness and intervention x x x DES APP Evaluation and scenario-based training phases the auto flight system(s) The purpose of this topic is to encourage TO Demonstrate appropriate use of flight Late ATC clearance to an altitude below acceleration altitude x x x and develop effective flight path guidance, auto thrust and other TO management through proficient and automation systems Engine-out special terrain procedures x x x APP appropriate use of the flight Maintain mode awareness of the auto management system(s), guidance and flight system(s), including engagement automation including transitions Forcing AP disconnect followed by re-engagement, recovery from low- or high-speed CRZ and automatic transitions x x x x between modes, monitoring, mode Automation Revert to different modes when events in cruise A awareness, vigilance and flexibility management appropriate CRZ needed to change from one mode to Engine failure in cruise to onset of descent using automation x x Detect deviations from the desired another. Included in this topic is the CRZ aircraft state (flight path, speed, Emergency descent x x X means of mitigating errors described as: attitude, thrust, etc.) and take mishandled auto flight systems, DES appropriate action. Managing high-energy descent capturing descent path from above (correlation with inappropriate mode selection, flight x x x X APP management system(s) and autopilot unstable approach training) Anticipate mishandled auto flight usage. APP system No ATC clearance received prior to commencement of approach or final descent x x x Recognise mishandled auto flight APP system. Reactive wind shear and recovery from the consequent high-energy state x x x Take appropriate action if necessary Restore correct auto flight state Non-precision or infrequently flown approaches using the maximum available level of APP x x X automation Identify and manage consequences APP Gear malfunction during approach x x x ATC clearances to waypoints beyond programmed descent point for a coded final descent APP point during an approach utilising a final descent that is commanded by the flight x x x X management system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 136 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map Communication: Demonstrate effective use of language, responsiveness to feedback and that plans are stated and ambiguities resolved. Leadership and teamwork: Use appropriate authority to ensure This encapsulates communication; APP focus on the task. Support others in GPS failure prior to commencement of approach associated with position drift and a x x x X leadership and teamwork; problem- terrain alert completing tasks. solving and decision-making; situation Problem-solving and decision-making: awareness and management of Detect deviations from the desired information; workload management. state, evaluate problems, identify risk, Competencies non- A consider alternatives and select the technical (CRM) Emphasis should be placed on the best course of action. Continuously development of leadership, shown by review progress and adjust plans. EBT data sources to be a highly effective Situation awareness and management competency in mitigating risk and of information: improving safety through pilot Cabin crew report of water noise below the forward galley indicating a possible toilet pipe DES Have an awareness of the aircraft x x x performance leak, with consequent avionics failures state in its environment; project and anticipate changes. CRZ Workload management: Smoke removal but combined with a diversion until landing completed. x x x x x X Evaluation and scenario-based training phases Prioritise, delegate and receive assistance to maximise focus on the ACAS warning immediately following a go-around, with a descent manoeuvre required. APP task. Continuously monitor the flight x x x x x progress Compliance failure. Consequences of not The following are examples of potential compliance failures, and not intended to be complying with operating instructions developed as scenarios as part of an EBT module: (e.g. SOPs). This is not intended to list scenarios, but Recognise that a compliance failure 1. Requesting flap beyond limit speed instructors should ensure that observed has occurred non-compliances are taken as learning Make a verbal announcement 2. Flaps or slats in the wrong position for phase of flight or approach Compliance A ALL Intentionally blank opportunities throughout the Take appropriate action if necessary programme. In all modules of the Restore safe flight path if necessary 3. Omitting an action as part of a procedure programme, the FSTD should as far as Manage consequences possible be treated like an aircraft, and 4. Failing to initiate or complete a checklist non-compliances should not be accepted simply for expediency. 5. Using the wrong checklist for the situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 137 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map APP Adverse-weather scenario leading to a reactive wind shear warning during approach x x x x Any threat or error that can result in Adverse-weather scenario leading to a predictive wind shear warning during approach or APP x x x x circumstances that require a decision to go-around perform go-around, in addition to the Adverse-weather scenario, e.g. thunderstorm activity, heavy precipitation or icing forcing APP execution of the go-around. Go-around x x x x decision at or close to DA/MDA Evaluation and scenario-based training phases scenarios should be fully developed to encourage effective leadership and DA with visual reference in heavy precipitation with doubt about runway surface braking APP teamwork, in addition to problem-solving x x x x capability and decision-making, plus execution APP using manual aircraft control or the Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x Go-around A flight management system(s) and management Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP automation as applicable. Design should x x x include the element of surprise and reported) scenario-based go-arounds should not be predictable and anticipated. This topic is Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x completely distinct from the go-around (50 ft) (not reported) manoeuvre listed in the manoeuvres Lost or difficult communications resulting in no approach clearance prior to APP training section that is intended only to x x x commencement of approach or final descent practise psychomotor skill and a simple APP application of the procedures Birds: large flocks of birds below DA once visual reference has been established x x x APP System malfunction, landing gear malfunction during the approach TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 138 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map CLB CRZ Flight with unreliable airspeed, which may be recoverable or not recoverable X x x x DES APP CLB CRZ Alternate flight control modes according to malfunction characteristics X x x x DES APP CLB CRZ ACAS RA to descend or ATC immediate descent x x x DES APP TAWS warning when deviating from planned descent routing, requiring immediate DES x x x response TO Scenario immediately after take-off which requires an immediate and overweight landing x x x x TO Adverse wind, crosswinds with or without strong gusts on take-off x x Evaluation and scenario-based training phases Adverse weather, wind shear, wind shear encounter during take-off, with or without TO x x x Desired competency outcome: reactive warnings Demonstrates manual aircraft control TO skills with smoothness and accuracy as Engine failure during initial climb, typically 30-60 m (100-200 ft) (autopilot off) x x x x appropriate to the situation Wind shear encounter scenario during cruise, significant and rapid change in wind speed CRZ Detects deviations through instrument x x x x x or down/updrafts, without wind shear warning scanning Manual aircraft Controls the flight path through manual A Maintains spare mental capacity Adverse weather, wind shear, wind shear encounter with or without warning during control APP control x x x x during manual aircraft control approach Maintains the aircraft within the normal flight envelope Adverse weather, deterioration in visibility or cloud base, or adverse wind, requiring a go- APP Applies knowledge of the relationship around from visual circling approach, during the visual segment x x x x x x x between aircraft attitude, speed and APP thrust Adverse wind, crosswinds with or without strong gusts on approach, final and landing x x x LDG (within and beyond limits) Adverse weather, adverse wind, approach and landing in demanding weather conditions, APP e.g. turbulence, up and downdrafts, gusts and crosswinds including shifting wind x x x LDG directions APP Circling approach at night in minimum in-flight visibility to ensure ground reference, LDG minimum environmental lighting and no glide slope guidance lights APP Runway incursion during approach, which can be triggered by ATC at various altitudes or x x x LDG by visual contact during the landing phase Adverse wind, visibility, type-specific, special consideration for long-bodied aircraft, LDG x x x x landing in minimum visibility for visual reference, with crosswind System malfunction, auto flight failure at DA during a low-visibility approach requiring a LDG x x x x go-around flown manually TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 139 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map APP Approach planned with autoland, followed by a failure below 1000 feet requiring a go- x x x x LDG around, and an immediate landing due to fuel shortage. ALL The scenarios should be realistic and Deviations from the flight path, in pitch attitude, speed, altitude, bank angle x x relevant, and should be used for the purpose of demonstration and In-seat instruction: reinforcement of effective flight path Simple automation errors (e.g. incorrect mode selection, attempted engagement without ALL monitoring. the necessary conditions, entering wrong altitude or speed, failure to execute the desired x x mode) culminating in a need for direct intervention from the PM, and where necessary Modules in the FSTD should be treated taking control. like those in an aircraft so that trainees Recognise mismanaged aircraft state. have the opportunity to develop Observe behaviour: how pilot is In-seat instruction: APP competency with the practice of the right mitigating errors, how pilot is Unstable approach or speed/path/vertical rate not congruent with required state for given x x x x techniques and attitudes related to these performing cross checking, how pilot is flight condition topics through pilot performance, and monitoring performance and dealing In-seat instruction: that instructors have the opportunity to with a mismanaged aircraft state, so Demonstration exercise — recovery from bounced landing, adverse wind, strong gusts assess and train these topics in a realistic the instructors should ensure that during landing phase, resulting in a bounce and necessitating recovery action from the PM Evaluation and scenario-based training phases environment. As shown by the EBT data observed deviations, errors and Monitoring, cross report, these topics are of key mistakes are taken as learning checking, error importance to improve safety in opportunities throughout the A management, operations. programme. mismanaged aircraft Monitor flight path excursions. state In addition, the operator may also use Detect errors and threats through these topics to develop scripted role- proper cross checking performance. playing scenarios in the form of ISI Make appropriate interventions either LDG training. These scenarios cater for the verbally or by taking control if x x x need to monitor flight path excursions applicable. from the instructor pilot (PF), detect Take appropriate action if necessary errors and make appropriate Restore desired aircraft state interventions, either verbally or by taking Identify and manage consequences control as applicable. Demonstration scenarios may also be used. Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training. DES ATC or terrain related environment creating a high-energy descent with the need to x x x APP capture the optimum profile to complete the approach in a stabilised configuration Reinforce stabilised approach philosophy DES and adherence to defined parameters. ATC or terrain related environment creating a high-energy descent leading to unstable Unstable Encourage go-arounds when crews are x x x A APP conditions and requiring a go-around approach outside these parameters. Develop and sustain competencies related to the Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x management of high-energy situations downdrafts, gusts and crosswinds including shifting wind directions APP Increasing tailwind on final (not reported) x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 140 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Section 3 Training topics frequency (B) per phase and in alphabetical order. Include upset prevention elements in See Table 1 in AMC1 ORO.FC.220&230: Elements and respective components of upset Evaluation ,manoeuvres training, and scenario- Table 1 for the recurrent training prevention training. based training phases programme at least every 12 calendar months, such that all the elements are Upset prevention Compliance with AMC1 or 2 covered over a period not exceeding 3 B N/A Intentionally blank training ORO.FC.220&230 years. TO Take-off with different crosswind/tailwind/gust conditions x x Evaluation and scenario-based training phases TO Take-off with unreported tailwind x x TO Crosswinds with or without strong gusts on take-off x x APP Increasing tailwind on final (not reported) x x x x Recognise adverse-wind conditions Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x Adverse wind/crosswind. This includes Observe limitations downdrafts, gusts and crosswind including shifting wind directions Adverse wind B tailwind but not ATC mis-reporting of the Apply appropriate procedures APP actual wind Maintain directional control and safe Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x flight path Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP x x x reported) Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x (50 ft) (not reported) APP Crosswind with or without strong gusts on approach, final and landing (within and beyond x x x LDG limits) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 141 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map For full details, see the Malfunction Equivalency methodology. At least one malfunction with each characteristic should be included every year. Combining characteristics should not reduce the number of malfunctions below 7 for each crew member every year. (i) System malfunctions requiring immediate and urgent crew intervention or decision, e.g. fire, smoke, loss of pressurisation at high altitude, failures during take-off, brake failure during landing. (ii) System malfunctions requiring complex procedures, e.g. multiple hydraulic system failures, smoke and fumes procedures, major dual system electrical. ALL (iii) System malfunctions resulting in significant degradation of flight controls in Intentionally blank combination with abnormal handling characteristics, e.g. jammed flight controls, certain Recognise system malfunction degradation of FBW control, Jammed horizontal stabiliser; Flaps and/or slats locked, other Take appropriate action including malfunctions resulting in degraded flight controls. correct stop/go decision (iv) System failures that require monitoring and management of the flight path using Evaluation and scenario-based training phases Any internal failure(s) apparent or not Apply appropriate procedure correctly degraded or alternative displays, unreliable primary flight path information, unreliable apparent to the crew Maintain aircraft control airspeed, e.g. flight with unreliable airspeed Manage consequences (v) System failures that require extensive management of their consequences Any item cleared by the MEL but having (independent of operation or environment), e.g. fuel leak. an impact upon flight operations. E.g. Apply crew operating procedure TO thrust reverser locked where necessary. MEL items with crew operating procedures applicable during take-off x X Aircraft system Respond appropriately to additional malfunctions, B TO Malfunctions to be considered should system abnormal associated with MEL Response to an additional factor that is affected by MEL item (e.g. system failure, runway x x x X including operations state) have one or more of the following dispatch under MEL characteristics: GND Malfunction during preflight preparation and prior to departure x x x  Immediacy Immediacy CLB  Complexity Complexity Malfunction after departure x x x X  Degradation of aircraft control Degradation of aircraft control  Loss of primary instrumentation Loss of primary instrumentation Malfunctions requiring immediate attention (e.g. bleed fault during engine start, hydraulic ALL  Management of consequences Management of consequences x x x failure during taxi) The operator should vary malfunctions CLB CRZ for each characteristic over the EBT Fuel leak (management of consequences) x x x X cycle. TO Take-off high speed below V1 x x x TO Take-off high speed above V1 x x TO Initial climb x x APP On approach x x x APP Go-around x x x LDG During landing x x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 142 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map This is not considered as a stand-alone See ‘compliance’ topic above. There are no defined scenarios, but the instructor should topic. It links with the topic focus on learning opportunities when system management non-compliances manifest ‘compliance’ themselves during other scenarios. Underpinning knowledge of systems and their Intentionally blank x Aircraft system Normal system operation according to B Where a system is not managed interactions should be developed and challenged, and not merely the application of management defined instructions according to normal or defined normal procedures CRZ APP procedures, this is determined as a Minimum fuel, caused by extended delays, weather...etc. where the crew would need to non-compliance x x x x LDG managed a minimum fuel situation. APP Recognise actual conditions Approach in poor visibility x x x x Evaluation and scenario-based training phases Observe aircraft and/or procedural limitations Approach in poor visibility with deteriorations necessitating a decision to perform go- Approach, visibility APP Any situation where visibility becomes a x x x B Apply appropriate procedure if around close to minimum threat applicable LDG Maintain directional control and safe Landing in poor visibility x x x flight path Pilots should have opportunities to practise landings in demanding situations at the defined frequency. Data indicates that landing problems have their roots in a variety of factors, including appropriate Landing in demanding environmental This topic should be combined with the adverse-weather topic, aircraft system Landing B LDG decision-making, in addition to manual conditions, with malfunctions as malfunctions topic or any topic that can provide exposure to a landing in demanding Intentionally blank aircraft control skills if difficult appropriate conditions environmental conditions exist. The purpose of this item is to ensure that pilots are exposed to this during the programme GND TO Planned anticipated hazardous conditions with dispatch information provided to facilitate Recognise hazardous runway condition planning and execution of appropriate procedures x x LDG Contamination or surface quality of the Observe limitations Runway or taxiway B GND TO runway, taxiway, or tarmac including Take appropriate action Unanticipated hazardous conditions, e.g. unexpected heavy rain resulting in flooded condition x x x LDG foreign objects Apply appropriate procedure correctly runway surface Assure aircraft control TO Stop/go decision in hazardous conditions x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 143 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map The data analysed during the development of this manual and of the EBT concept indicated substantial difficulties encountered by crews when faced with a threat or error, which was a surprise, or an unexpected event. The element of surprise should be distinguished from what is sometimes referred to as the ‘startle factor’, the Exposure to an unexpected event or latter being a physiological reaction. Surprise B ALL sequence of events at the defined Intentionally blank Intentionally blank Wherever possible, consideration should frequency be given towards variations in the types Evaluation and scenario-based training phases of scenario, times of occurrences and types of occurrence, so that pilots do not become overly familiar with repetitions of the same scenarios. Variations should be the focus of EBT programme design, and not left to the discretion of individual instructors, in order to preserve programme integrity and fairness ALL ATC clearance giving insufficient terrain clearance x x x X Anticipate terrain threats Prepare for terrain threats Demonstration of terrain avoidance warning systems (this scenario element may be done ALL Recognise unsafe terrain clearance x x x in an ISI.) Take appropriate action Terrain B TO CLB Alert, warning, or conflict Apply appropriate procedure correctly Engine failure where performance is marginal leading to TAWS warning x x x Maintain aircraft control Restore safe flight path ‘Virtual mountain’ meaning the surprise element of an unexpected warning. Care should DES Manage consequences be exercised in creating a level of realism, so this can best be achieved by an unusual and x x x unexpected change of route during the descent This is not considered a topic for specific attention on its own, but more as a reminder to programme developers to ensure that pilots are exposed to Manage available resources efficiently Workload, distraction, B ALL immersive training scenarios which to prioritise and perform tasks in a Intentionally blank Intentionally blank pressure expose them to manageable high timely manner under all circumstances workload and distractions during the course of the EBT programme, at the defined frequency TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 144 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map Section 3 Training topics frequency (C) per phase and in alphabetical order. See Table 2 in AMC1 ORO.FC.220&230: Elements and respective components of upset N/A Intentionally blank prevention training. Upset recognition: Demonstration of the defined normal flight envelope and any CLB CRZ associated changes in flight instruments, flight director systems, and protection systems. x x x x Evaluation, manoeuvres training and scenario-based training phases DES APP This should take the form of an instructor-led exercise to show the crew the points beyond which an upset condition could exist Compliance with AMC1 or 2 ORO.FC.220&230 Upset recognition and recovery — Severe wind shear or wake turbulence during take-off TO APP x x x x x or approach An aeroplane upset is defined as an undesired aeroplane state in flight Upset recognition and recovery — as applicable and relevant to aircraft type, CLB characterised by unintentional demonstration at a suitable intermediate level, with turbulence as appropriate; practise x x x DES divergences from parameters normally steep turns and note the relationship between bank angle, pitch and stalling speed experienced during line operations or Recognise upset condition training. An aeroplane upset may involve Upset recognition and recovery — at the maximum cruise flight level for current aircraft Take appropriate action CRZ pitch and/or bank angle divergences as weight, turbulence to trigger overspeed conditions (if FSTD capability exists, consider use x x x x x Upset Assure aircraft control C well as inappropriate airspeeds for the of vertical wind component to add realism) recovery Maintain or restore a safe flight path conditions. Assess consequential issues Upset recognition and recovery — at the maximum cruise flight level for current aircraft CRZ Manage outcomes weight, turbulence and significant temperature rise to trigger low-speed conditions (if x x x x The example scenario elements may be done in ISI, as non-ISI or a combination of FSTD capability exists, consider use of vertical wind component to add realism) both. Upset recognition and recovery — demonstration at a normal cruising altitude, set CRZ Include the recovery exercises in Table 2 conditions and disable aircraft systems as necessary to enable trainee to complete stall x x x for the recurrent training programme, recovery according to OEM instructions such that all the exercises are covered Upset recognition and recovery — demonstration at an intermediate altitude during early over a period not exceeding 3 years. APP stages of the approach, set conditions and disable aircraft systems as necessary to enable x x x trainee to complete stall recovery according to OEM instructions In-seat instruction: Recovery – Demonstration: the instructor should position the aircraft CLB within but close to the edge of the normal flight envelope before handing control to the x x x DES trainee to demonstrate the restoration of normal flight. Careful consideration should be given to flying within the normal flight envelope ALL ATC role-play: the instructor provides scripted instructions, as a distraction to the crew x x x ATC error. Omission, miscommunication, EVAL and SBT phases Respond to communications ALL garbled, poor quality transmission. All of appropriately Controller error, provided by the instructor according to a defined scripted scenario x x x x these act as distractions to be managed ALL Recognise, clarify and resolve any Frequency congestion, with multiple aircraft using the same frequency x by the crew. The scenarios should be ATC C ambiguities combined where possible with others of Refuse or question unsafe instructions. Poor quality transmissions the same or higher weighting, the Use standard phraseology whenever ALL principle reason being to create x possible distractions. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 145 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map TO Take-off low speed x x x x TO Any engine failure or malfunction, which Take-off high speed below V1 x x x x causes loss or degradation of thrust that TO impacts performance. This is distinct Recognise engine failure Take-off above V1 x x x x from the engine-out manoeuvres Take appropriate action Engine failure C TO described in the manoeuvres training Apply appropriate procedure correctly Initial climb x x x section above, which are intended only Maintain aircraft control APP for the practice of psychomotor skill and Manage consequences Engine malfunction x x x reinforcement of procedures in CRZ managing engine failures Engine failure in cruise (with autopilot) x x x LDG On landing x GND Fire in cargo or cabin/cockpit at gate x x x x GND Fire during taxi x x x x X Evaluation and scenario-based training phases GND Fire with no cockpit indication x x x x X TO Take-off low speed x x x x X TO Recognise fire, smoke or fumes Take-off high speed below V1 x x x x Take appropriate action Fire and smoke This includes engine, electric, pneumatic, C TO Apply appropriate procedure correctly Take-off high speed above V1 x x x management cargo fire, smoke or fumes Maintain aircraft control TO Manage consequences Initial climb x x x CRZ Cargo fire x x x APP Engine fire in approach (extinguishable) x x APP Engine fire in approach (non-extinguishable) x x x APP Flight deck or cabin fire x x x X GND Recognise loss of communications Loss of communications during ground manoeuvring x x Lost or difficult communications. Either Take appropriate action Loss of TO through pilot mis-selection or a failure Execute appropriate procedure as Loss of communications after take-off x x X C communications external to the aircraft. This could be for applicable a few seconds or a total loss. Use alternative ways to communicate X APP Loss of communications during approach phase, including go-around x x x x Manage consequences Anticipate the potential for errors in load/fuel/performance data This can be a demonstrated error, in that the crew may be instructed to deliberately insert A calculation error by one or more pilots, Managing loading, Recognise inconsistencies incorrect data, for example to take off from an intersection with full-length performance or someone involved with the process, or fuel, performance C ALL Manage/avoid distractions information. The crew will be asked to intervene when acceleration is sensed to be lower x x x the process itself, e.g. incorrect errors Make changes to paperwork/aircraft than normal, and this may be part of the operator procedures, especially when operating information on the load sheet system(s) to eliminate error mixed fleets with considerable variations in MTOM. Identify and manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 146 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 4 Jet — Recurrent assessment and training matrix Competency map Recognise a NAV degradation. External failure or a combination of external failures degrading aircraft navigation GND Take appropriate action x x x x External NAV failure. performance Execute appropriate procedure as Navigation C Loss of GPS satellite, ANP exceeding RNP, applicable loss of external NAV source(s) TO CLB Use alternative NAV guidance External failure or a combination of external failures degrading aircraft navigation x x x x APP LDG Manage consequences performance Operations- or C ALL Intentionally blank Intentionally blank Intentionally blank Intentionally blank type-specific The operator should comply with the Operations of special APP See equivalency of approaches relevant national qualification requirements Evaluation and scenario-based training phasess C Intentionally blank Intentionally blank airport approval LDG to operations. published in the Aeronautical Information Publication Recognise incapacitation X TO Take appropriate action including During take-off x x x x Consequences for the non-incapacitated correct stop/go decision Pilot incapacitation C pilot Apply appropriate procedure correctly Maintain aircraft control X APP During approach x x x Manage consequences Anticipate potential loss of separation Recognise loss of separation Traffic conflict. ACAS RA or TA, or visual CLB CRZ Take appropriate action Traffic C observation of conflict, which requires ACAS warning requiring crew intervention x x x x DES Apply appropriate procedure correctly evasive manoeuvring Maintain aircraft control Manage consequences TO Anticipate potential for wind shear Predictive wind shear warning during take-off x x Avoid known wind shear or prepare TO for suspected wind shear Wind shear encounter during take-off x x x With or without warnings including Recognise wind shear encounter TO predictive. A wind shear scenario is Take appropriate action Wind shear encounter after rotation x x Wind shear recovery C ideally combined into an adverse- Apply appropriate procedure correctly TO weather scenario containing other Assure aircraft control Predictive wind shear after rotation x x elements. Recognise out of wind shear condition APP Maintain or restore a safe flight path Predictive wind shear during approach x x x Assess consequential issues and APP manage outcomes Wind shear encounter during approach x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 147 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC3 to Appendix II — EBT programme GENERATION 3 (JET) — TABLE OF ASSESSMENT AND TRAINING TOPICS REFERRED TO IN AMC3 ORO.FC.231(a) Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map Section 1 Engine failure after the application of Rejected take-off A TO From initiation of take-off to complete stop (or as applicable to procedure) x x take-off thrust and before reaching V1 Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised at engine between V1 & A TO before reaching V2 in lowest CAT I normal engine-out climb speed with the correct pitch and lateral control, in trim condition x x V2 visibility conditions and, as applicable, autopilot engagement Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised in a engine between V1 & B TO before reaching V2 in lowest CAT I x x V2 visibility conditions Demonstrate manual aircraft control clean configuration with engine-out procedures completed skills with smoothness and accuracy as Manoeuvres training phase Initiation of emergency descent from appropriate to the situation The manoeuvre is considered to be completed once the aircraft is stabilised in emergency Emergency descent C CRZ Detect deviations through instrument descent configuration (and profile) x x x normal cruise altitude scanning With a critical engine failed, manually Maintain spare mental capacity during This manoeuvre should be flown from intercept to centreline until acceleration after go- flown normal precision approach to DA, manual aircraft control around. The manoeuvre is considered to be complete at a point when aircraft is stabilised Engine-out approach A APP followed by manually flown go-around, Maintain the aircraft within the flight at normal engine-out climb speed with the correct pitch and lateral control, in trim x x & go-around the whole manoeuvre to be flown envelope condition and, as applicable, autopilot engagement (describe generally critical part of without visual reference Apply knowledge of the relationship manoeuvre) between aircraft attitude, speed and thrust High energy, initiation during the approach at 150 to 300 m (500 to 1 000 ft) below the APP Go-around, all engines operative x x x missed approach level-off altitude Go-around A Go-around, all engines operative APP Initiation of go-around from DA followed by visual circuit and landing x x x followed by visual circuit, manually flown APP Go-around, all engines operative During flare/rejected landing x x x Initiation in a stabilised engine-out configuration from not less than 3 NM final approach, Engine-out landing A LDG With a critical engine failed, normal landing x x until completion of roll-out Section 2 Equivalency of Approaches relevant to operations Approach type A or See equivalency of approaches B APP Approach type A or B flight method 3D See equivalency of approaches relevant to operations x x x x X B relevant to operations MT phase See equivalency of approaches Approach type A B APP Approach type A flight method 2D See equivalency of approaches relevant to operations x x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 148 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map See equivalency of approaches Approach type A B APP Approach type A flight method 3D See equivalency of approaches relevant to operations x x x x x relevant to operations EVAL and SBT phases See equivalency of approaches X Approach typed B B APP Approach type B flight method 3D See equivalency of approaches relevant to operations x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. Section 3 Training topics frequency (A) in alphabetical order. GND Predictive wind shear warning before take-off, as applicable x x x ALL Adverse-weather scenario, e.g. thunderstorm activity, precipitation, icing x x x x TO Wind shear encounter during take-off, not predictive x x x x TO Predictive wind shear warning during take-off x x x x Evaluation and scenario-based training phases TO Crosswinds with or without strong gusts on take-off x x CRZ Wind shear encounter scenario during cruise x x x x x APP Anticipate adverse weather Reactive wind shear warning during approach or go-around x x x x Thunderstorm, heavy rain, turbulence, Prepare for suspected adverse APP ice build-up to include de-icing issues, as Predictive wind shear warning during approach or go-around x x x x weather well as high- temperature conditions. Adverse weather A Recognise adverse weather APP The proper use of use of anti-ice and de- Thunderstorm encounter during approach or on missed approach x x x Take appropriate action icing systems should be included Apply appropriate procedure correctly APP generally in appropriate scenarios. Increasing tailwind on final (not reported) x x x x Assure aircraft control Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x downdrafts, gusts and crosswinds including shifting wind directions Non-precision approach in cold temperature conditions, requiring altitude compensation APP x x x for temperature, as applicable to type APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Reduced visibility even after acquiring the necessary visual reference during approach, APP x x x due to rain or fog TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 149 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map CLB CRZ ACAS warning, recovery and subsequent engagement of automation x x DES APP FMS tactical programming issues, e.g. step climb, runway changes, late clearances, ALL x x X destination re-programming, executing diversion Know how and when to use the flight CLB CRZ DES APP management system(s), guidance and Recoveries from TAWS, management of energy state to restore automated flight x x x automation CLB CRZ Demonstrate correct methods for Amendments to ATC cleared levels during altitude capture modes to force mode engagement and disengagement of awareness and intervention x x x DES APP Evaluation and scenario-based training phases the auto flight system(s) The purpose of this topic is to encourage TO Demonstrate appropriate use of flight Late ATC clearance to an altitude below acceleration altitude x x x and develop effective flight path guidance, auto thrust and other TO management through proficient and automation systems Engine-out special terrain procedures x x x APP appropriate use of the flight Maintain mode awareness of the auto management system(s), guidance and flight system(s), including engagement automation including transitions Forcing AP disconnect followed by re-engagement, recovery from low- or high-speed CRZ and automatic transitions x x x x between modes, monitoring, mode Automation Revert to different modes when events in cruise A awareness, vigilance and flexibility management appropriate CRZ needed to change from one mode to Engine failure in cruise to onset of descent using automation x x Detect deviations from the desired another. Included in this topic is the CRZ aircraft state (flight path, speed, Emergency descent x x X means of mitigating errors described as: attitude, thrust, etc.) and take mishandled auto flight systems, DES appropriate action. Managing high-energy descent capturing descent path from above (correlation with inappropriate mode selection, flight x x x X APP management system(s) and autopilot unstable approach training) Anticipate mishandled auto flight usage. APP system No ATC clearance received prior to commencement of approach or final descent x x x Recognise mishandled auto flight APP system. Reactive wind shear and recovery from the consequent high-energy state x x x Take appropriate action if necessary Restore correct auto flight state Non-precision or infrequently flown approaches using the maximum available level of APP x x X automation Identify and manage consequences APP Gear malfunction during approach x x x ATC clearances to waypoints beyond programmed descent point for a coded final descent APP point during an approach utilising a final descent that is commanded by the flight x x x X management system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 150 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map Communication: Demonstrate effective use of language, responsiveness to feedback and that plans are stated and ambiguities resolved. Leadership and teamwork: Use appropriate authority to ensure This encapsulates communication; APP focus on the task. Support others in GPS failure prior to commencement of approach associated with position drift and a x x x X leadership and teamwork; problem- terrain alert completing tasks. solving and decision-making; situation Problem-solving and decision-making: awareness and management of Detect deviations from the desired information; workload management. Evaluation and scenario-based training phases state, evaluate problems, identify risk, Competencies non- A consider alternatives and select the technical (CRM) Emphasis should be placed on the best course of action. Continuously development of leadership, shown by review progress and adjust plans. EBT data sources to be a highly effective Situation awareness and management competency in mitigating risk and of information: improving safety through pilot Cabin crew report of water noise below the forward galley indicating a possible toilet pipe DES Have an awareness of the aircraft x x x performance leak, with consequent avionics failures state in its environment; project and anticipate changes. CRZ Workload management: Smoke removal but combined with a diversion until landing completed. x x x x x X Prioritise, delegate and receive assistance to maximise focus on the ACAS warning immediately following a go-around, with a descent manoeuvre required. APP task. Continuously monitor the flight x x x x x progress Compliance failure. Consequences of not The following are examples of potential compliance failures, and not intended to be complying with operating instructions developed as scenarios as part of an EBT module: (e.g. SOPs). This is not intended to list scenarios, but Recognise that a compliance failure 1. Requesting flap beyond limit speed instructors should ensure that observed has occurred non-compliances are taken as learning Make a verbal announcement 2. Flaps or slats in the wrong position for phase of flight or approach Compliance A ALL Intentionally blank opportunities throughout the Take appropriate action if necessary programme. In all modules of the Restore safe flight path if necessary 3. Omitting an action as part of a procedure programme, the FSTD should as far as Manage consequences possible be treated like an aircraft, and 4. Failing to initiate or complete a checklist non-compliances should not be accepted simply for expediency. 5. Using the wrong checklist for the situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 151 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map APP Adverse-weather scenario leading to a reactive wind shear warning during approach x x x x Any threat or error that can result in Adverse-weather scenario leading to a predictive wind shear warning during approach or APP x x x x circumstances that require a decision to go-around Evaluation and scenario-based training phases perform go-around, in addition to the Adverse-weather scenario, e.g. thunderstorm activity, heavy precipitation or icing forcing APP execution of the go-around. Go-around x x x x decision at or close to DA/MDA scenarios should be fully developed to encourage effective leadership and DA with visual reference in heavy precipitation with doubt about runway surface braking APP teamwork, in addition to problem-solving x x x x capability and decision-making, plus execution APP using manual aircraft control or the Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x Go-around A flight management system(s) and management Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP automation as applicable. Design should x x x include the element of surprise and reported) scenario-based go-arounds should not be predictable and anticipated. This topic is Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x completely distinct from the go-around (50 ft) (not reported) manoeuvre listed in the manoeuvres Lost or difficult communications resulting in no approach clearance prior to APP training section that is intended only to x x x commencement of approach or final descent practise psychomotor skill and a simple APP application of the procedures Birds: large flocks of birds below DA once visual reference has been established x x x APP System malfunction, landing gear malfunction during the approach TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 152 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map CLB CRZ Flight with unreliable airspeed, which may be recoverable or not recoverable X x x x DES APP CLB CRZ Alternate flight control modes according to malfunction characteristics X x x x DES APP CLB CRZ ACAS RA to descend or ATC immediate descent x x x DES APP TAWS warning when deviating from planned descent routing, requiring immediate DES x x x response TO Scenario immediately after take-off which requires an immediate and overweight landing x x x x TO Adverse wind, crosswinds with or without strong gusts on take-off x x Evaluation and scenario-based training phases Adverse weather, wind shear, wind shear encounter during take-off, with or without TO x x x Desired competency outcome: reactive warnings Demonstrates manual aircraft control TO skills with smoothness and accuracy as Engine failure during initial climb, typically 30-60 m (100-200 ft) (autopilot off) x x x x appropriate to the situation Wind shear encounter scenario during cruise, significant and rapid change in wind speed CRZ Detects deviations through instrument x x x x x or down/updrafts, without wind shear warning scanning Manual aircraft Controls the flight path through manual A Maintains spare mental capacity Adverse weather, wind shear, wind shear encounter with or without warning during control APP control x x x x during manual aircraft control approach Maintains the aircraft within the normal flight envelope Adverse weather, deterioration in visibility or cloud base, or adverse wind, requiring a go- APP Applies knowledge of the relationship around from visual circling approach, during the visual segment x x x x x x x between aircraft attitude, speed and APP thrust Adverse wind, crosswinds with or without strong gusts on approach, final and landing x x x LDG (within and beyond limits) Adverse weather, adverse wind, approach and landing in demanding weather conditions, APP e.g. turbulence, up and downdrafts, gusts and crosswinds including shifting wind x x x LDG directions APP Circling approach at night in minimum in-flight visibility to ensure ground reference, LDG minimum environmental lighting and no glide slope guidance lights APP Runway incursion during approach, which can be triggered by ATC at various altitudes or x x x LDG by visual contact during the landing phase Adverse wind, visibility, type-specific, special consideration for long-bodied aircraft, LDG x x x x landing in minimum visibility for visual reference, with crosswind System malfunction, auto flight failure at DA during a low-visibility approach requiring a LDG x x x x go-around flown manually TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 153 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map APP Approach planned with autoland, followed by a failure below 1000 feet requiring a go- x x x x LDG around, and an immediate landing due to fuel shortage. ALL The scenarios should be realistic and Deviations from the flight path, in pitch attitude, speed, altitude, bank angle x x relevant, and should be used for the purpose of demonstration and In-seat instruction: reinforcement of effective flight path Simple automation errors (e.g. incorrect mode selection, attempted engagement without ALL monitoring. the necessary conditions, entering wrong altitude or speed, failure to execute the desired x x mode) culminating in a need for direct intervention from the PM, and where necessary Modules in the FSTD should be treated taking control. like those in an aircraft so that trainees Recognise mismanaged aircraft state. have the opportunity to develop Observe behaviour: how pilot is In-seat instruction: APP competency with the practice of the right mitigating errors, how pilot is Unstable approach or speed/path/vertical rate not congruent with required state for given x x x x techniques and attitudes related to these performing cross checking, how pilot is flight condition topics through pilot performance, and monitoring performance and dealing In-seat instruction: that instructors have the opportunity to with a mismanaged aircraft state, so Demonstration exercise — recovery from bounced landing, adverse wind, strong gusts assess and train these topics in a realistic the instructors should ensure that during landing phase, resulting in a bounce and necessitating recovery action from the PM Evaluation and scenario-based training phases environment. As shown by the EBT data observed deviations, errors and Monitoring, cross report, these topics are of key mistakes are taken as learning checking, error importance to improve safety in opportunities throughout the A management, operations. programme. mismanaged aircraft Monitor flight path excursions. state In addition, the operator may also use Detect errors and threats through these topics to develop scripted role- proper cross checking performance. playing scenarios in the form of ISI Make appropriate interventions either LDG training. These scenarios cater for the verbally or by taking control if x x x need to monitor flight path excursions applicable. from the instructor pilot (PF), detect Take appropriate action if necessary errors and make appropriate Restore desired aircraft state interventions, either verbally or by taking Identify and manage consequences control as applicable. Demonstration scenarios may also be used. Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training. DES ATC or terrain related environment creating a high-energy descent with the need to x x x APP capture the optimum profile to complete the approach in a stabilised configuration Reinforce stabilised approach philosophy DES and adherence to defined parameters. ATC or terrain related environment creating a high-energy descent leading to unstable Unstable Encourage go-arounds when crews are x x x A APP conditions and requiring a go-around approach outside these parameters. Develop and sustain competencies related to the Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x management of high-energy situations downdrafts, gusts and crosswinds including shifting wind directions APP Increasing tailwind on final (not reported) x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 154 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Section 3 Training topics frequency (B) per phase and in alphabetical order. Evaluation ,manoeuvres training, and scenario- based training phases Include upset prevention elements in Table 1 for the recurrent training programme at least every 12 calendar Upset prevention Compliance with AMC1 or 2 See Table 1 in AMC1 ORO.FC.220&230: Elements and respective components of upset B N/A months, such that all the elements are Intentionally blank training ORO.FC.220&230 prevention training. covered over a period not exceeding 3 years. TO Take-off with different crosswind/tailwind/gust conditions x x Evaluation and scenario-based training phases TO Take-off with unreported tailwind x x TO Crosswinds with or without strong gusts on take-off x x APP Increasing tailwind on final (not reported) x x x x Recognise adverse-wind conditions Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x Adverse wind/crosswind. This includes Observe limitations downdrafts, gusts and crosswind including shifting wind directions Adverse wind B tailwind but not ATC mis-reporting of the Apply appropriate procedures APP actual wind Maintain directional control and safe Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x flight path Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP x x x reported) Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x (50 ft) (not reported) APP Crosswind with or without strong gusts on approach, final and landing (within and beyond x x x LDG limits) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 155 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map For full details, see the Malfunction Equivalency methodology. At least one malfunction with each characteristic should be included every year. Combining characteristics should not reduce the number of malfunctions below 7 for each crew member every year. (i) System malfunctions requiring immediate and urgent crew intervention or decision, e.g. fire, smoke, loss of pressurisation at high altitude, failures during take-off, brake failure during landing. (ii) System malfunctions requiring complex procedures, e.g. multiple hydraulic system failures, smoke and fumes procedures, major dual system electrical. ALL (iii) System malfunctions resulting in significant degradation of flight controls in Intentionally blank combination with abnormal handling characteristics, e.g. jammed flight controls, certain Recognise system malfunction degradation of FBW control, Jammed horizontal stabiliser; Flaps and/or slats locked, other Take appropriate action including malfunctions resulting in degraded flight controls. correct stop/go decision (iv) System failures that require monitoring and management of the flight path using Evaluation and scenario-based training phases Any internal failure(s) apparent or not Apply appropriate procedure correctly degraded or alternative displays, unreliable primary flight path information, unreliable apparent to the crew Maintain aircraft control airspeed, e.g. flight with unreliable airspeed Manage consequences (v) System failures that require extensive management of their consequences Any item cleared by the MEL but having (independent of operation or environment), e.g. fuel leak. an impact upon flight operations. E.g. Apply crew operating procedure TO thrust reverser locked where necessary. MEL items with crew operating procedures applicable during take-off x X Aircraft system Respond appropriately to additional malfunctions, B TO Malfunctions to be considered should system abnormal associated with MEL Response to an additional factor that is affected by MEL item (e.g. system failure, runway x x x X including operations state) have one or more of the following dispatch under MEL characteristics: GND Malfunction during preflight preparation and prior to departure x x x  Immediacy Immediacy CLB  Complexity Complexity Malfunction after departure x x x X  Degradation of aircraft control Degradation of aircraft control  Loss of primary instrumentation Loss of primary instrumentation Malfunctions requiring immediate attention (e.g. bleed fault during engine start, hydraulic ALL  Management of consequences Management of consequences x x x failure during taxi) The operator should vary malfunctions CLB CRZ for each characteristic over the EBT Fuel leak (management of consequences) x x x X cycle. TO Take-off high speed below V1 x x x TO Take-off high speed above V1 x x TO Initial climb x x APP On approach x x x APP Go-around x x x LDG During landing x x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 156 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map This is not considered as a stand-alone See ‘compliance’ topic above. There are no defined scenarios, but the instructor should topic. It links with the topic focus on learning opportunities when system management non-compliances manifest ‘compliance’ themselves during other scenarios. Underpinning KNO of systems and their interactions Intentionally blank x Aircraft system Normal system operation according to B Where a system is not managed should be developed and challenged, and not merely the application of normal management defined instructions according to normal or defined procedures Evaluation and scenario-based training phases CRZ APP procedures, this is determined as a Minimum fuel, caused by extended delays, weather...etc. where the crew would need to non-compliance x x x x LDG managed a minimum fuel situation. APP Recognise actual conditions Approach in poor visibility x x x x Observe aircraft and/or procedural limitations Approach in poor visibility with deteriorations necessitating a decision to perform go- Approach, visibility APP Any situation where visibility becomes a x x x B Apply appropriate procedure if around close to minimum threat applicable LDG Maintain directional control and safe Landing in poor visibility x x x flight path Pilots should have opportunities to practise LDGs in demanding situations at the defined frequency. Data indicates that LDG problems have their roots in a variety of factors, including appropriate Landing in demanding environmental This topic should be combined with the adverse-weather topic, aircraft system Landing B LDG decision-making, in addition to manual conditions, with malfunctions as malfunctions topic or any topic that can provide exposure to a landing in demanding Intentionally blank aircraft control skills if difficult appropriate conditions environmental conditions exist. The purpose of this item is to ensure that pilots are exposed to this during the programme TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 157 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map The data analysed during the development of this manual and of the Evaluation and scenario-based training phases EBT concept indicated substantial difficulties encountered by crews when faced with a threat or error, which was a surprise, or an unexpected event. The element of surprise should be distinguished from what is sometimes referred to as the ‘startle factor’, the Exposure to an unexpected event or latter being a physiological reaction. Surprise B ALL sequence of events at the defined Intentionally blank Intentionally blank Wherever possible, consideration should frequency be given towards variations in the types of scenario, times of occurrences and types of occurrence, so that pilots do not become overly familiar with repetitions of the same scenarios. Variations should be the focus of EBT programme design, and not left to the discretion of individual instructors, in order to preserve programme integrity and fairness TO Anticipate potential for wind shear Predictive wind shear warning during take-off x x Avoid known wind shear or prepare TO for suspected wind shear Wind shear encounter during take-off x x x Evaluation and scenario-based training phases With or without warnings including Recognise wind shear encounter TO predictive. A wind shear scenario is Take appropriate action Wind shear encounter after rotation x x Wind shear recovery B ideally combined into an adverse- Apply appropriate procedure correctly Predictive wind shear after rotation TO x x weather scenario containing other Assure aircraft control APP elements. Recognise out of wind shear condition Predictive wind shear during approach x x x Maintain or restore a safe flight path Assess consequential issues and APP Wind shear encounter during approach x x x manage outcomes This is not considered a topic for specific attention on its own, but more as a reminder to programme developers to ensure that pilots are exposed to Manage available resources efficiently Workload, distraction, B ALL immersive training scenarios which to prioritise and perform tasks in a Intentionally blank Intentionally blank pressure expose them to manageable high timely manner under all circumstances workload and distractions during the course of the EBT programme, at the defined frequency TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 158 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map Section 3 Training topics frequency (C) per phase and in alphabetical order. See Table 2 in AMC1 ORO.FC.220&230: Elements and respective components of upset N/A Intentionally blank prevention training. Upset recognition: Demonstration of the defined normal flight envelope and any CLB CRZ associated changes in flight instruments, flight director systems, and protection systems. x x x x Evaluation, manoeuvres training and scenario-based training phases DES APP This should take the form of an instructor-led exercise to show the crew the points beyond which an upset condition could exist Compliance with AMC1 or 2 ORO.FC.220&230 Upset recognition and recovery — Severe wind shear or wake turbulence during take-off TO APP x x x x x or approach An aeroplane upset is defined as an undesired aeroplane state in flight Upset recognition and recovery — as applicable and relevant to aircraft type, CLB characterised by unintentional demonstration at a suitable intermediate level, with turbulence as appropriate; practise x x x DES divergences from parameters normally steep turns and note the relationship between bank angle, pitch and stalling speed experienced during line operations or Recognise upset condition training. An aeroplane upset may involve Upset recognition and recovery — at the maximum cruise flight level for current aircraft Take appropriate action CRZ pitch and/or bank angle divergences as weight, turbulence to trigger overspeed conditions (if FSTD capability exists, consider use x x x x x Upset Assure aircraft control C well as inappropriate airspeeds for the of vertical wind component to add realism) recovery Maintain or restore a safe flight path conditions. Assess consequential issues Upset recognition and recovery — at the maximum cruise flight level for current aircraft CRZ Manage outcomes weight, turbulence and significant temperature rise to trigger low-speed conditions (if x x x x The example scenario elements may be done in ISI, as non-ISI or a combination of FSTD capability exists, consider use of vertical wind component to add realism) both. Upset recognition and recovery — demonstration at a normal cruising altitude, set CRZ Include the recovery exercises in Table 2 conditions and disable aircraft systems as necessary to enable trainee to complete stall x x x for the recurrent training programme, recovery according to OEM instructions such that all the exercises are covered Upset recognition and recovery — demonstration at an intermediate altitude during early over a period not exceeding 3 years. APP stages of the approach, set conditions and disable aircraft systems as necessary to enable x x x trainee to complete stall recovery according to OEM instructions In-seat instruction: Recovery – Demonstration: the instructor should position the aircraft CLB within but close to the edge of the normal flight envelope before handing control to the x x x DES trainee to demonstrate the restoration of normal flight. Careful consideration should be given to flying within the normal flight envelope ALL ATC role-play: the instructor provides scripted instructions, as a distraction to the crew x x x ATC error. Omission, miscommunication, EVAL and SBT phases Respond to communications ALL garbled, poor quality transmission. All of appropriately Controller error, provided by the instructor according to a defined scripted scenario x x x x these act as distractions to be managed ALL Recognise, clarify and resolve any Frequency congestion, with multiple aircraft using the same frequency x by the crew. The scenarios should be ATC C ambiguities combined where possible with others of Refuse or question unsafe instructions. Poor quality transmissions the same or higher weighting, the Use standard phraseology whenever ALL principle reason being to create x possible distractions. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 159 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map TO Take-off low speed x x x x TO Any engine failure or malfunction, which Take-off high speed below V1 x x x x causes loss or degradation of thrust that TO impacts performance. This is distinct Recognise engine failure Take-off above V1 x x x x from the engine-out manoeuvres Take appropriate action Engine failure C TO described in the manoeuvres training Apply appropriate procedure correctly Initial climb x x x section above, which are intended only Maintain aircraft control APP for the practice of psychomotor skill and Manage consequences Engine malfunction x x x reinforcement of procedures in CRZ managing engine failures Engine failure in cruise (with autopilot) x x x LDG On landing x GND Fire in cargo or cabin/cockpit at gate x x x x GND Fire during taxi x x x x X Evaluation and scenario-based training phases GND Fire with no cockpit indication x x x x X TO Take-off low speed x x x x X TO Recognise fire, smoke or fumes Take-off high speed below V1 x x x x Take appropriate action Fire and smoke This includes engine, electric, pneumatic, C TO Apply appropriate procedure correctly Take-off high speed above V1 x x x management cargo fire, smoke or fumes Maintain aircraft control TO Manage consequences Initial climb x x x CRZ Cargo fire x x x APP Engine fire in approach (extinguishable) x x APP Engine fire in approach (non-extinguishable) x x x APP Flight deck or cabin fire x x x X GND Recognise loss of communications Loss of communications during ground manoeuvring x x Lost or difficult communications. Either Take appropriate action Loss of TO through pilot mis-selection or a failure Execute appropriate procedure as Loss of communications after take-off x x X C communications external to the aircraft. This could be for applicable a few seconds or a total loss. Use alternative ways to communicate X APP Loss of communications during approach phase, including go-around x x x x Manage consequences Anticipate the potential for errors in load/fuel/performance data This can be a demonstrated error, in that the crew may be instructed to deliberately insert A calculation error by one or more pilots, Managing loading, Recognise inconsistencies incorrect data, for example to take off from an intersection with full-length performance or someone involved with the process, or fuel, performance C ALL Manage/avoid distractions information. The crew will be asked to intervene when acceleration is sensed to be lower x x x the process itself, e.g. incorrect errors Make changes to paperwork/aircraft than normal, and this may be part of the operator procedures, especially when operating information on the load sheet system(s) to eliminate error mixed fleets with considerable variations in MTOM. Identify and manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 160 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Jet — Recurrent assessment and training matrix Competency map Recognise a NAV degradation. External failure or a combination of external failures degrading aircraft navigation GND Take appropriate action x x x x External NAV failure. performance Evaluation and scenario-based training phases Execute appropriate procedure as Navigation C Loss of GPS satellite, ANP exceeding RNP, applicable loss of external NAV source(s) TO CLB Use alternative NAV guidance External failure or a combination of external failures degrading aircraft navigation x x x x APP LDG Manage consequences performance Operations- or C ALL Intentionally blank Intentionally blank Intentionally blank Intentionally blank type-specific The operator should comply with the Operations of special APP See equivalency of approaches relevant national qualification requirements C Intentionally blank Intentionally blank airport approval LDG to operations. published in the Aeronautical Information Publication Recognise incapacitation X TO Take appropriate action including During take-off x x x x Consequences for the non-incapacitated correct stop/go decision Pilot incapacitation C pilot Apply appropriate procedure correctly Maintain aircraft control X APP During approach x x x Manage consequences GND TO Planned anticipated hazardous conditions with dispatch information provided to facilitate X Recognise hazardous runway condition planning and execution of appropriate procedures x LDG Contamination or surface quality of the Observe limitations Runway or taxiway C GND TO runway, taxiway, or tarmac including Take appropriate action Unanticipated hazardous conditions, e.g. unexpected heavy rain resulting in flooded condition x x x Evaluation and scenario-based training phases LDG foreign objects Apply appropriate procedure correctly runway surface Assure aircraft control TO Stop/go decision in hazardous conditions x x x ALL ATC clearance giving insufficient terrain clearance x x x X Anticipate terrain threats Prepare for terrain threats Demonstration of terrain avoidance warning systems (this scenario element may be done ALL Recognise unsafe terrain clearance x x x in an ISI.) Take appropriate action Terrain C TO CLB Alert, warning, or conflict Apply appropriate procedure correctly Engine failure where performance is marginal leading to TAWS warning x x x Maintain aircraft control Restore safe flight path ‘Virtual mountain’ meaning the surprise element of an unexpected warning. Care should DES Manage consequences be exercised in creating a level of realism, so this can best be achieved by an unusual and x x x unexpected change of route during the descent Anticipate potential loss of separation Recognise loss of separation Traffic conflict. ACAS RA or TA, or visual CLB CRZ Take appropriate action Traffic C observation of conflict, which requires ACAS warning requiring crew intervention x x x x DES Apply appropriate procedure correctly evasive manoeuvring Maintain aircraft control Manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 161 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC4 to Appendix II — EBT programme GENERATION 3 (TURBOPROP) — TABLE OF ASSESSMENT AND TRAINING TOPICS REFERRED TO IN AMC4 ORO.FC.231(a) Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map Section 1 Engine failure after the application of Rejected take-off A TO From initiation of take-off to complete stop (or as applicable to procedure) x x take-off thrust and before reaching V1 Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised at engine between V1 & A TO before reaching V2 in lowest CAT I normal engine-out climb speed with the correct pitch and lateral control, in trim condition x x V2 visibility conditions and, as applicable, autopilot engagement Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised in a engine between V1 & B TO before reaching V2 in lowest CAT I x x V2 visibility conditions Demonstrate manual aircraft control clean configuration with engine-out procedures completed skills with smoothness and accuracy as Manoeuvres training phase Initiation of emergency descent from appropriate to the situation The manoeuvre is considered to be completed once the aircraft is stabilised in emergency Emergency descent C CRZ Detect deviations through instrument descent configuration (and profile) x x x normal cruise altitude scanning With a critical engine failed, manually Maintain spare mental capacity during This manoeuvre should be flown from intercept to centreline until acceleration after go- flown normal precision approach to DA, manual aircraft control around. The manoeuvre is considered to be complete at a point when aircraft is stabilised Engine-out approach A APP followed by manually flown go-around, Maintain the aircraft within the flight at normal engine-out climb speed with the correct pitch and lateral control, in trim x x & go-around the whole manoeuvre to be flown envelope condition and, as applicable, autopilot engagement (describe generally critical part of without visual reference Apply knowledge of the relationship manoeuvre) between aircraft attitude, speed and thrust High energy, initiation during the approach at 150 to 300 m (500 to 1 000 ft) below the APP Go-around, all engines operative x x x missed approach level-off altitude Go-around A Go-around, all engines operative APP Initiation of go-around from DA followed by visual circuit and landing x x x followed by visual circuit, manually flown APP Go-around, all engines operative During flare/rejected landing x x x Initiation in a stabilised engine-out configuration from not less than 3 NM final approach, Engine-out landing A LDG With a critical engine failed, normal landing x x until completion of roll-out Section 2 Equivalency of Approaches relevant to operations Approach type A or See equivalency of approaches B APP Approach type A or B flight method 3D See equivalency of approaches relevant to operations x x x x X B relevant to operations MT phase See equivalency of approaches Approach type A B APP Approach type A flight method 2D See equivalency of approaches relevant to operations x x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 162 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map See equivalency of approaches Approach type A B APP Approach type A flight method 3D See equivalency of approaches relevant to operations x x x x x relevant to operations EVAL and SBT phases See equivalency of approaches X Approach type B B APP Approach type B flight method 3D See equivalency of approaches relevant to operations x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. Section 3 Training topics frequency (A) in alphabetical order. GND Predictive wind shear warning before take-off, as applicable x x x ALL Adverse-weather scenario, e.g. thunderstorm activity, precipitation, icing x x x x TO Wind shear encounter during take-off, not predictive x x x x TO Predictive wind shear warning during take-off x x x x Evaluation and scenario-based training phases TO Crosswinds with or without strong gusts on take-off x x CRZ Wind shear encounter scenario during cruise x x x x x APP Anticipate adverse weather Reactive wind shear warning during approach or go-around x x x x Thunderstorm, heavy rain, turbulence, Prepare for suspected adverse APP ice build-up to include de-icing issues, as Predictive wind shear warning during approach or go-around x x x x weather well as high- temperature conditions. Adverse weather A Recognise adverse weather APP The proper use of use of anti-ice and de- Thunderstorm encounter during approach or on missed approach x x x Take appropriate action icing systems should be included Apply appropriate procedure correctly APP generally in appropriate scenarios. Increasing tailwind on final (not reported) x x x x Assure aircraft control Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x downdrafts, gusts and crosswinds including shifting wind directions Non-precision approach in cold temperature conditions, requiring altitude compensation APP x x x for temperature, as applicable to type APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Reduced visibility even after acquiring the necessary visual reference during approach, APP x x x due to rain or fog TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 163 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map CLB CRZ ACAS warning, recovery and subsequent engagement of automation x x DES APP FMS tactical programming issues, e.g. step climb, runway changes, late clearances, ALL x x X destination re-programming, executing diversion Know how and when to use the flight CLB CRZ DES APP management system(s), guidance and Recoveries from TAWS, management of energy state to restore automated flight x x x automation CLB CRZ Demonstrate correct methods for Amendments to ATC cleared levels during altitude capture modes to force mode engagement and disengagement of awareness and intervention x x x DES APP Evaluation and scenario-based training phases the auto flight system(s) The purpose of this topic is to encourage TO Demonstrate appropriate use of flight Late ATC clearance to an altitude below acceleration altitude x x x and develop effective flight path guidance, auto thrust and other TO management through proficient and automation systems Engine-out special terrain procedures x x x APP appropriate use of the flight Maintain mode awareness of the auto management system(s), guidance and flight system(s), including engagement automation including transitions Forcing AP disconnect followed by re-engagement, recovery from low- or high-speed CRZ and automatic transitions x x x x between modes, monitoring, mode Automation Revert to different modes when events in cruise A awareness, vigilance and flexibility management appropriate CRZ needed to change from one mode to Engine failure in cruise to onset of descent using automation x x Detect deviations from the desired another. Included in this topic is the CRZ aircraft state (flight path, speed, Emergency descent x x X means of mitigating errors described as: attitude, thrust, etc.) and take mishandled auto flight systems, DES appropriate action. Managing high-energy descent capturing descent path from above (correlation with inappropriate mode selection, flight x x x X APP management system(s) and autopilot unstable approach training) Anticipate mishandled auto flight usage. APP system No ATC clearance received prior to commencement of approach or final descent x x x Recognise mishandled auto flight APP system. Reactive wind shear and recovery from the consequent high-energy state x x x Take appropriate action if necessary Restore correct auto flight state Non-precision or infrequently flown approaches using the maximum available level of APP x x X automation Identify and manage consequences APP Gear malfunction during approach x x x ATC clearances to waypoints beyond programmed descent point for a coded final descent APP point during an approach utilising a final descent that is commanded by the flight x x x X management system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 164 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map Communication: Demonstrate effective use of language, responsiveness to feedback and that plans are stated and ambiguities resolved. Leadership and teamwork: Use appropriate authority to ensure This encapsulates communication; APP focus on the task. Support others in GPS failure prior to commencement of approach associated with position drift and a x x x X leadership and teamwork; problem- terrain alert completing tasks. solving and decision-making; situation Problem-solving and decision-making: awareness and management of Detect deviations from the desired information; workload management. Evaluation and scenario-based training phases state, evaluate problems, identify risk, Competencies non- A consider alternatives and select the technical (CRM) Emphasis should be placed on the best course of action. Continuously development of leadership, shown by review progress and adjust plans. EBT data sources to be a highly effective Situation awareness and management competency in mitigating risk and of information: improving safety through pilot Cabin crew report of water noise below the forward galley indicating a possible toilet pipe DES Have an awareness of the aircraft x x x performance leak, with consequent avionics failures state in its environment; project and anticipate changes. CRZ Workload management: Smoke removal but combined with a diversion until landing completed. x x x x x X Prioritise, delegate and receive assistance to maximise focus on the ACAS warning immediately following a go-around, with a descent manoeuvre required. APP task. Continuously monitor the flight x x x x x progress Compliance failure. Consequences of not The following are examples of potential compliance failures, and not intended to be complying with operating instructions developed as scenarios as part of an EBT module: (e.g. SOPs). This is not intended to list scenarios, but Recognise that a compliance failure 1. Requesting flap beyond limit speed instructors should ensure that observed has occurred non-compliances are taken as learning Make a verbal announcement 2. Flaps or slats in the wrong position for phase of flight or approach Compliance A ALL Intentionally blank opportunities throughout the Take appropriate action if necessary programme. In all modules of the Restore safe flight path if necessary 3. Omitting an action as part of a procedure programme, the FSTD should as far as Manage consequences possible be treated like an aircraft, and 4. Failing to initiate or complete a checklist non-compliances should not be accepted simply for expediency. 5. Using the wrong checklist for the situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 165 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map APP Adverse-weather scenario leading to a reactive wind shear warning during approach x x x x Any threat or error that can result in Adverse-weather scenario leading to a predictive wind shear warning during approach or APP x x x x circumstances that require a decision to go-around Evaluation and scenario-based training phases perform go-around, in addition to the Adverse-weather scenario, e.g. thunderstorm activity, heavy precipitation or icing forcing APP execution of the go-around. Go-around x x x x decision at or close to DA/MDA scenarios should be fully developed to encourage effective leadership and DA with visual reference in heavy precipitation with doubt about runway surface braking APP teamwork, in addition to problem-solving x x x x capability and decision-making, plus execution APP using manual aircraft control or the Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x Go-around A flight management system(s) and management Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP automation as applicable. Design should x x x include the element of surprise and reported) scenario-based go-arounds should not be predictable and anticipated. This topic is Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x completely distinct from the go-around (50 ft) (not reported) manoeuvre listed in the manoeuvres Lost or difficult communications resulting in no approach clearance prior to APP training section that is intended only to x x x commencement of approach or final descent practise psychomotor skill and a simple APP application of the procedures Birds: large flocks of birds below DA once visual reference has been established x x x APP System malfunction, landing gear malfunction during the approach TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 166 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map CLB CRZ Flight with unreliable airspeed, which may be recoverable or not recoverable X x x x DES APP CLB CRZ Alternate flight control modes according to malfunction characteristics X x x x DES APP CLB CRZ ACAS RA to descend or ATC immediate descent x x x DES APP TAWS warning when deviating from planned descent routing, requiring immediate DES x x x response TO Scenario immediately after take-off which requires an immediate and overweight landing x x x x TO Adverse wind, crosswinds with or without strong gusts on take-off x x Evaluation and scenario-based training phases Adverse weather, wind shear, wind shear encounter during take-off, with or without TO x x x Desired competency outcome: reactive warnings Demonstrates manual aircraft control TO skills with smoothness and accuracy as Engine failure during initial climb, typically 30-60 m (100-200 ft) (autopilot off) x x x x appropriate to the situation Wind shear encounter scenario during cruise, significant and rapid change in wind speed CRZ Detects deviations through instrument x x x x x or down/updrafts, without wind shear warning scanning Manual aircraft Controls the flight path through manual A Maintains spare mental capacity Adverse weather, wind shear, wind shear encounter with or without warning during control APP control x x x x during manual aircraft control approach Maintains the aircraft within the normal flight envelope Adverse weather, deterioration in visibility or cloud base, or adverse wind, requiring a go- APP Applies knowledge of the relationship around from visual circling approach, during the visual segment x x x x x x x between aircraft attitude, speed and APP thrust Adverse wind, crosswinds with or without strong gusts on approach, final and landing x x x LDG (within and beyond limits) Adverse weather, adverse wind, approach and landing in demanding weather conditions, APP e.g. turbulence, up and downdrafts, gusts and crosswinds including shifting wind x x x LDG directions APP Circling approach at night in minimum in-flight visibility to ensure ground reference, LDG minimum environmental lighting and no glide slope guidance lights APP Runway incursion during approach, which can be triggered by ATC at various altitudes or x x x LDG by visual contact during the landing phase Adverse wind, visibility, type-specific, special consideration for long-bodied aircraft, LDG x x x x landing in minimum visibility for visual reference, with crosswind System malfunction, auto flight failure at DA during a low-visibility approach requiring a LDG x x x x go-around flown manually TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 167 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map APP Approach planned with autoland, followed by a failure below 1000 feet requiring a go- x x x x LDG around, and an immediate landing due to fuel shortage. ALL The scenarios should be realistic and Deviations from the flight path, in pitch attitude, speed, altitude, bank angle x x relevant, and should be used for the purpose of demonstration and In-seat instruction: reinforcement of effective flight path Simple automation errors (e.g. incorrect mode selection, attempted engagement without ALL monitoring. the necessary conditions, entering wrong altitude or speed, failure to execute the desired x x mode) culminating in a need for direct intervention from the PM, and where necessary Modules in the FSTD should be treated taking control. like those in an aircraft so that trainees Recognise mismanaged aircraft state. have the opportunity to develop Observe behaviour: how pilot is In-seat instruction: APP competency with the practice of the right mitigating errors, how pilot is Unstable approach or speed/path/vertical rate not congruent with required state for given x x x x techniques and attitudes related to these performing cross checking, how pilot is flight condition topics through pilot performance, and monitoring performance and dealing In-seat instruction: that instructors have the opportunity to with a mismanaged aircraft state, so Demonstration exercise — recovery from bounced landing, adverse wind, strong gusts assess and train these topics in a realistic the instructors should ensure that during landing phase, resulting in a bounce and necessitating recovery action from the PM Evaluation and scenario-based training phases environment. As shown by the EBT data observed deviations, errors and Monitoring, cross report, these topics are of key mistakes are taken as learning checking, error importance to improve safety in opportunities throughout the A management, operations. programme. mismanaged aircraft Monitor flight path excursions. state In addition, the operator may also use Detect errors and threats through these topics to develop scripted role- proper cross checking performance. playing scenarios in the form of ISI Make appropriate interventions either LDG training. These scenarios cater for the verbally or by taking control if x x x need to monitor flight path excursions applicable. from the instructor pilot (PF), detect Take appropriate action if necessary errors and make appropriate Restore desired aircraft state interventions, either verbally or by taking Identify and manage consequences control as applicable. Demonstration scenarios may also be used. Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training. DES ATC or terrain related environment creating a high-energy descent with the need to x x x APP capture the optimum profile to complete the approach in a stabilised configuration Reinforce stabilised approach philosophy DES and adherence to defined parameters. ATC or terrain related environment creating a high-energy descent leading to unstable Unstable Encourage go-arounds when crews are x x x A APP conditions and requiring a go-around approach outside these parameters. Develop and sustain competencies related to the Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x management of high-energy situations downdrafts, gusts and crosswinds including shifting wind directions APP Increasing tailwind on final (not reported) x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 168 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Section 3 Training topics frequency (B) per phase and in alphabetical order. Evaluation ,manoeuvres Include upset prevention elements in See Table 1 in AMC1 ORO.FC.220&230: Elements and respective components of upset training, and scenario- based training phases Table 1 for the recurrent training prevention training. programme at least every 12 calendar months, such that all the elements are Upset prevention Compliance with AMC1 or 2 B N/A covered over a period not exceeding 3 Intentionally blank training ORO.FC.220&230 years. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 169 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map For full details, see the Malfunction Equivalency methodology. At least one malfunction with each characteristic should be included every year. Combining characteristics should not reduce the number of malfunctions below 7 for each crew member every year. (i) System malfunctions requiring immediate and urgent crew intervention or decision, e.g. fire, smoke, loss of pressurisation at high altitude, failures during take-off, brake failure during landing. (ii) System malfunctions requiring complex procedures, e.g. multiple hydraulic system failures, smoke and fumes procedures, major dual system electrical. ALL (iii) System malfunctions resulting in significant degradation of flight controls in Intentionally blank combination with abnormal handling characteristics, e.g. jammed flight controls, certain Recognise system malfunction degradation of FBW control, Jammed horizontal stabiliser; Flaps and/or slats locked, other Take appropriate action including malfunctions resulting in degraded flight controls. correct stop/go decision (iv) System failures that require monitoring and management of the flight path using Evaluation and scenario-based training phases Any internal failure(s) apparent or not Apply appropriate procedure correctly degraded or alternative displays, unreliable primary flight path information, unreliable apparent to the crew Maintain aircraft control airspeed, e.g. flight with unreliable airspeed Manage consequences (v) System failures that require extensive management of their consequences Any item cleared by the MEL but having (independent of operation or environment), e.g. fuel leak. an impact upon flight operations. E.g. Apply crew operating procedure TO thrust reverser locked where necessary. MEL items with crew operating procedures applicable during take-off x X Aircraft system Respond appropriately to additional malfunctions, B TO Malfunctions to be considered should system abnormal associated with MEL Response to an additional factor that is affected by MEL item (e.g. system failure, runway x x x X including operations state) have one or more of the following dispatch under MEL characteristics: GND Malfunction during preflight preparation and prior to departure x x x  Immediacy Immediacy CLB  Complexity Complexity Malfunction after departure x x x X  Degradation of aircraft control Degradation of aircraft control  Loss of primary instrumentation Loss of primary instrumentation Malfunctions requiring immediate attention (e.g. bleed fault during engine start, hydraulic ALL  Management of consequences Management of consequences x x x failure during taxi) The operator should vary malfunctions CLB CRZ for each characteristic over the EBT Fuel leak (management of consequences) x x x X cycle. TO Take-off high speed below V1 x x x TO Take-off high speed above V1 x x TO Initial climb x x APP On approach x x x APP Go-around x x x LDG During landing x x x x x This is not considered as a stand-alone See ‘compliance’ topic above. There are no defined scenarios, but the instructor should scenario- Evaluatio training topic. It links with the topic focus on learning opportunities when system management non-compliances manifest phases based n and Aircraft system Normal system operation according to B ‘compliance’ themselves during other scenarios. Underpinning KNO of systems and their interactions Intentionally blank x management defined instructions Where a system is not managed should be developed and challenged, and not merely the application of normal according to normal or defined procedures TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 170 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map CRZ APP procedures, this is determined as a Minimum fuel, caused by extended delays, weather...etc. where the crew would need to x x x x LDG non-compliance managed a minimum fuel situation. APP Recognise actual conditions Approach in poor visibility x x x x Observe aircraft and/or procedural limitations Approach in poor visibility with deteriorations necessitating a decision to perform go- Approach, visibility APP Any situation where visibility becomes a x x x B Apply appropriate procedure if around close to minimum threat applicable LDG Maintain directional control and safe Landing in poor visibility x x x flight path Pilots should have opportunities to practise LDGs in demanding situations at the defined frequency. Data indicates that LDG problems have their roots in a variety of factors, including appropriate Landing in demanding environmental This topic should be combined with the adverse-weather topic, aircraft system Landing B LDG decision-making, in addition to manual conditions, with malfunctions as malfunctions topic or any topic that can provide exposure to a landing in demanding Intentionally blank aircraft control skills if difficult appropriate conditions environmental conditions exist. The purpose of this item is to ensure that pilots are exposed to this during the programme The data analysed during the development of this manual and of the Evaluation and scenario-based training phases EBT concept indicated substantial difficulties encountered by crews when faced with a threat or error, which was a surprise, or an unexpected event. The element of surprise should be distinguished from what is sometimes referred to as the ‘startle factor’, the Exposure to an unexpected event or latter being a physiological reaction. Surprise B ALL sequence of events at the defined Intentionally blank Intentionally blank Wherever possible, consideration should frequency be given towards variations in the types of scenario, times of occurrences and types of occurrence, so that pilots do not become overly familiar with repetitions of the same scenarios. Variations should be the focus of EBT programme design, and not left to the discretion of individual instructors, in order to preserve programme integrity and fairness ALL Anticipate terrain threats ATC clearance giving insufficient terrain clearance x x x X scenar trainin Evalua phase based tion and B io- Terrain Alert, warning, or conflict Prepare for terrain threats g s Demonstration of terrain avoidance warning systems (this scenario element may be done ALL Recognise unsafe terrain clearance x x x in an ISI.) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 171 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map TO CLB Take appropriate action Engine failure where performance is marginal leading to TAWS warning x x x Apply appropriate procedure correctly Maintain aircraft control ‘Virtual mountain’ meaning the surprise element of an unexpected warning. Care should DES Restore safe flight path be exercised in creating a level of realism, so this can best be achieved by an unusual and x x x Manage consequences unexpected change of route during the descent TO Anticipate potential for wind shear Predictive wind shear warning during take-off x x Avoid known wind shear or prepare TO for suspected wind shear Wind shear encounter during take-off x x x With or without warnings including Recognise wind shear encounter TO predictive. A wind shear scenario is Take appropriate action Wind shear encounter after rotation x x Wind shear recovery B ideally combined into an adverse- Apply appropriate procedure correctly Predictive wind shear after rotation TO x x weather scenario containing other Assure aircraft control APP elements. Recognise out of wind shear condition Predictive wind shear during approach x x x Maintain or restore a safe flight path Assess consequential issues and APP Wind shear encounter during approach x x x manage outcomes This is not considered a topic for specific attention on its own, but more as a reminder to programme developers to ensure that pilots are exposed to Manage available resources efficiently Workload, B ALL immersive training scenarios which to prioritise and perform tasks in a Intentionally blank Intentionally blank distraction, pressure expose them to manageable high timely manner under all circumstances workload and distractions during the course of the EBT programme, at the defined frequency TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 172 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map Section 3 Training topics frequency (C) per phase and in alphabetical order. See Table 2 in AMC1 ORO.FC.220&230: Elements and respective components of upset N/A Intentionally blank prevention training. Upset recognition: Demonstration of the defined normal flight envelope and any CLB CRZ associated changes in flight instruments, flight director systems, and protection systems. x x x x Evaluation, manoeuvres training and scenario-based training phases DES APP This should take the form of an instructor-led exercise to show the crew the points beyond which an upset condition could exist Compliance with AMC1 or 2 ORO.FC.220&230 Upset recognition and recovery — Severe wind shear or wake turbulence during TO or TO APP x x x x x APP An aeroplane upset is defined as an undesired aeroplane state in flight Upset recognition and recovery — as applicable and relevant to aircraft type, CLB characterised by unintentional demonstration at a suitable intermediate level, with turbulence as appropriate; practise x x x DES divergences from parameters normally steep turns and note the relationship between bank angle, pitch and stalling speed experienced during line operations or Recognise upset condition training. An aeroplane upset may involve Upset recognition and recovery — at the maximum cruise flight level for current aircraft Take appropriate action CRZ pitch and/or bank angle divergences as weight, turbulence to trigger overspeed conditions (if FSTD capability exists, consider use x x x x x Upset Assure aircraft control C well as inappropriate airspeeds for the of vertical wind component to add realism) recovery Maintain or restore a safe flight path conditions. Assess consequential issues Upset recognition and recovery — at the maximum cruise flight level for current aircraft CRZ Manage outcomes weight, turbulence and significant temperature rise to trigger low-speed conditions (if x x x x The example scenario elements may be done in ISI, as non-ISI or a combination of FSTD capability exists, consider use of vertical wind component to add realism) both. Upset recognition and recovery — demonstration at a normal cruising altitude, set CRZ Include the recovery exercises in Table 2 conditions and disable aircraft systems as necessary to enable trainee to complete stall x x x for the recurrent training programme, recovery according to OEM instructions such that all the exercises are covered Upset recognition and recovery — demonstration at an intermediate altitude during early over a period not exceeding 3 years. APP stages of the approach, set conditions and disable aircraft systems as necessary to enable x x x trainee to complete stall recovery according to OEM instructions ISI: Recovery – Demonstration: the instructor should position the acft within but close to CLB the edge of the normal flight envelope before handing control to the trainee to x x x DES demonstrate the restoration of normal flight. It should be flown within the normal flight envelope TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 173 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map TO Take-off with different crosswind/tailwind/gust conditions x x TO Take-off with unreported tailwind x x TO Crosswinds with or without strong gusts on take-off x x APP Increasing tailwind on final (not reported) x x x x EVAL and SBT phases Recognise adverse-wind conditions Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x Adverse wind/crosswind. This includes Observe limitations downdrafts, gusts and crosswind including shifting wind directions Adverse wind C tailwind but not ATC mis-reporting of the Apply appropriate procedures APP actual wind Maintain directional control and safe Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x flight path Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP x x x reported) Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x (50 ft) (not reported) APP Crosswind with or without strong gusts on APP, final and LDG (within and beyond limits) x x x LDG TO Take-off low speed x x x x TO Any engine failure or malfunction, which Take-off high speed below V1 x x x x EVAL and SBT phases causes loss or degradation of thrust that TO impacts performance. This is distinct Recognise engine failure Take-off above V1 x x x x from the engine-out manoeuvres Take appropriate action Engine failure C TO described in the manoeuvres training Apply appropriate procedure correctly Initial climb x x x section above, which are intended only Maintain aircraft control APP for the practice of psychomotor skill and Manage consequences Engine malfunction x x x reinforcement of procedures in CRZ managing engine failures Engine failure in cruise (with autopilot) x x x LDG On landing x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 174 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map GND Fire in cargo or cabin/cockpit at gate x x x x GND Fire during taxi x x x x X GND Fire with no cockpit indication x x x x X Evaluation and scenario-based training phases TO Take-off low speed x x x x X TO Recognise fire, smoke or fumes Take-off high speed below V1 x x x x Take appropriate action Fire and smoke This includes engine, electric, pneumatic, C TO Apply appropriate procedure correctly Take-off high speed above V1 x x x management cargo fire, smoke or fumes Maintain aircraft control TO Manage consequences Initial climb x x x CRZ Cargo fire x x x APP Engine fire in approach (extinguishable) x x APP Engine fire in approach (non-extinguishable) x x x APP Flight deck or cabin fire x x x X GND Recognise loss of communications Loss of communications during ground manoeuvring x x Lost or difficult communications. Either Take appropriate action Loss of TO through pilot mis-selection or a failure Execute appropriate procedure as Loss of communications after take-off x x X C communications external to the aircraft. This could be for applicable a few seconds or a total loss. Use alternative ways to communicate X APP Manage consequences Loss of communications during approach phase, including go-around x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 175 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 3 Turboprop — Recurrent assessment and training matrix Competency map Anticipate the potential for errors in load/fuel/performance data This can be a demonstrated error, in that the crew may be instructed to deliberately insert A calculation error by one or more pilots, Managing loading, Recognise inconsistencies incorrect data, for example to take off from an intersection with full-length performance or someone involved with the process, or fuel, performance C ALL Manage/avoid distractions information. The crew will be asked to intervene when acceleration is sensed to be lower x x x Evaluation and scenario-based training phases the process itself, e.g. incorrect errors Make changes to paperwork/aircraft than normal, and this may be part of the operator procedures, especially when operating information on the load sheet system(s) to eliminate error mixed fleets with considerable variations in MTOM. Identify and manage consequences Recognise a NAV degradation. External failure or a combination of external failures degrading aircraft navigation GND x x x x Take appropriate action performance External NAV failure. Execute appropriate procedure as Navigation C Loss of GPS satellite, ANP exceeding RNP, TO CLB loss of external NAV source(s) applicable External failure or a combination of external failures degrading aircraft navigation Use alternative NAV guidance x x x x APP LDG performance Manage consequences Operations- or C ALL Intentionally blank Intentionally blank Intentionally blank Intentionally blank type-specific The operator should comply with the Operations of special APP See equivalency of approaches relevant national qualification requirements C Intentionally blank Intentionally blank airport approval LDG to operations. published in the Aeronautical Information Publication Recognise incapacitation TO Take appropriate action including During take-off x x x x X Consequences for the non-incapacitated correct stop/go decision Evaluation and scenario-based training phases Pilot incapacitation C pilot Apply appropriate procedure correctly APP Maintain aircraft control During approach x x x X Manage consequences GND TO Planned anticipated hazardous conditions with dispatch information provided to facilitate x LDG Recognise hazardous runway condition planning and execution of appropriate procedures Contamination or surface quality of the Observe limitations Runway or taxiway GND TO runway, taxiway, or tarmac including Take appropriate action Unanticipated hazardous conditions, e.g. unexpected heavy rain resulting in flooded C x x x condition LDG foreign objects Apply appropriate procedure correctly runway surface Assure aircraft control TO Stop/go decision in hazardous conditions x x x Anticipate potential loss of separation Recognise loss of separation Traffic conflict. ACAS RA or TA, or visual CLB CRZ Take appropriate action Traffic C observation of conflict, which requires ACAS warning requiring crew intervention x x x x DES Apply appropriate procedure correctly evasive manoeuvring Maintain aircraft control Manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 176 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC5 to Appendix II — EBT programme GENERATION 2 (JET) — TABLE OF ASSESSMENT AND TRAINING TOPICS REFERRED TO IN AMC5 ORO.FC.231(a) Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Section 1 Engine failure after the application of Rejected take-off A TO From initiation of take-off to complete stop (or as applicable to procedure) x x take-off thrust and before reaching V1 Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised at engine between V1 & A TO before reaching V2 in lowest CAT I normal engine-out climb speed with the correct pitch and lateral control, in trim condition x x V2 visibility conditions and, as applicable, autopilot engagement Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised in a engine between V1 & B TO before reaching V2 in lowest CAT I x x V2 visibility conditions Demonstrate manual aircraft control clean configuration with engine-out procedures completed skills with smoothness and accuracy as Manoeuvres training phase Initiation of emergency descent from appropriate to the situation The manoeuvre is considered to be completed once the aircraft is stabilised in emergency Emergency descent C CRZ Detect deviations through instrument descent configuration (and profile) x x x normal cruise altitude scanning With a critical engine failed, manually Maintain spare mental capacity during This manoeuvre should be flown from intercept to centreline until acceleration after go- flown normal precision approach to DA, manual aircraft control around. The manoeuvre is considered to be complete at a point when aircraft is stabilised Engine-out approach A APP followed by manually flown go-around, Maintain the aircraft within the flight at normal engine-out climb speed with the correct pitch and lateral control, in trim x x & go-around the whole manoeuvre to be flown envelope condition and, as applicable, autopilot engagement (describe generally critical part of without visual reference Apply knowledge of the relationship manoeuvre) between aircraft attitude, speed and thrust High energy, initiation during the approach at 150 to 300 m (500 to 1 000 ft) below the APP Go-around, all engines operative x x x missed approach level-off altitude Go-around A Go-around, all engines operative APP Initiation of go-around from DA followed by visual circuit and landing x x x followed by visual circuit, manually flown APP Go-around, all engines operative During flare/rejected landing x x x Initiation in a stabilised engine-out configuration from not less than 3 NM final approach, Engine-out landing A LDG With a critical engine failed, normal landing x x until completion of roll-out Section 2 Equivalency of Approaches relevant to operations Approach type A or See equivalency of approaches B APP Approach type A or B flight method 3D See equivalency of approaches relevant to operations x x x x X B relevant to operations MT phase See equivalency of approaches Approach type A B APP Approach type A flight method 2D See equivalency of approaches relevant to operations x x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 177 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map See equivalency of approaches Approach type A B APP Approach type A flight method 3D See equivalency of approaches relevant to operations x x x x x relevant to operations EVAL and SBT phases See equivalency of approaches X Approach type B B APP Approach type B flight method 3D See equivalency of approaches relevant to operations x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. Section 3 Training topics frequency (A) in alphabetical order. GND Predictive wind shear warning before take-off, as applicable x x x ALL Adverse-weather scenario, e.g. thunderstorm activity, precipitation, icing x x x x TO Wind shear encounter during take-off, not predictive x x x x TO Predictive wind shear warning during take-off x x x x Evaluation and scenario-based training phases TO Crosswinds with or without strong gusts on take-off x x CRZ Wind shear encounter scenario during cruise x x x x x APP Anticipate adverse weather Reactive wind shear warning during approach or go-around x x x x Thunderstorm, heavy rain, turbulence, Prepare for suspected adverse APP ice build-up to include de-icing issues, as Predictive wind shear warning during approach or go-around x x x x weather well as high- temperature conditions. Adverse weather A Recognise adverse weather APP The proper use of use of anti-ice and de- Thunderstorm encounter during approach or on missed approach x x x Take appropriate action icing systems should be included Apply appropriate procedure correctly APP generally in appropriate scenarios. Increasing tailwind on final (not reported) x x x x Assure aircraft control Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x downdrafts, gusts and crosswinds including shifting wind directions Non-precision approach in cold temperature conditions, requiring altitude compensation APP x x x for temperature, as applicable to type APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Reduced visibility even after acquiring the necessary visual reference during approach, APP x x x due to rain or fog TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 178 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map APP Recognise actual conditions Approach in poor visibility x x x x Observe aircraft and/or procedural EVAL and SBT limitations Approach in poor visibility with deteriorations necessitating a decision to perform go- Approach, visibility APP Any situation where visibility becomes a x x x A Apply appropriate procedure if around close to minimum threat applicable LDG Maintain directional control and safe Landing in poor visibility x x x flight path CLB CRZ ACAS warning, recovery and subsequent engagement of automation x x DES APP FMS tactical programming issues, e.g. step climb, runway changes, late clearances, ALL x x X destination re-programming, executing diversion Know how and when to use the flight CLB CRZ management system(s), guidance and Recoveries from TAWS, management of energy state to restore automated flight x x x DES APP automation CLB CRZ Demonstrate correct methods for Amendments to ATC cleared levels during altitude capture modes to force mode engagement and disengagement of x x x DES APP awareness and intervention Evaluation and scenario-based training phases the auto flight system(s) The purpose of this topic is to encourage TO Demonstrate appropriate use of flight Late ATC clearance to an altitude below acceleration altitude x x x and develop effective flight path guidance, auto thrust and other TO management through proficient and automation systems Engine-out special terrain procedures x x x APP appropriate use of the flight Maintain mode awareness of the auto management system(s), guidance and flight system(s), including engagement automation including transitions Forcing AP disconnect followed by re-engagement, recovery from low- or high-speed CRZ and automatic transitions x x x x between modes, monitoring, mode events in cruise Automation Revert to different modes when A awareness, vigilance and flexibility management appropriate CRZ needed to change from one mode to Engine failure in cruise to onset of descent using automation x x Detect deviations from the desired another. Included in this topic is the CRZ aircraft state (flight path, speed, Emergency descent x x X means of mitigating errors described as: attitude, thrust, etc.) and take mishandled auto flight systems, DES appropriate action. Managing high-energy descent capturing descent path from above (correlation with inappropriate mode selection, flight x x x X APP management system(s) and autopilot unstable approach training) Anticipate mishandled auto flight APP usage. No ATC clearance received prior to commencement of approach or final descent x x x system Recognise mishandled auto flight APP system. Reactive wind shear and recovery from the consequent high-energy state x x x Take appropriate action if necessary Non-precision or infrequently flown approaches using the maximum available level of APP Restore correct auto flight state x x X Identify and manage consequences automation APP Gear malfunction during approach x x x ATC clearances to waypoints beyond programmed descent point for a coded final descent APP point during an approach utilising a final descent that is commanded by the flight x x x X management system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 179 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Communication: Demonstrate effective use of language, responsiveness to feedback and that plans are stated and ambiguities Evaluation and scenario-based training phases resolved. Leadership and teamwork: Use This encapsulates communication; appropriate authority to ensure focus leadership and teamwork; problem- on the task. Support others in GPS failure prior to commencement of approach associated with position drift and a X APP x x x solving and decision-making; situation completing tasks. terrain alert awareness and management of Problem-solving and decision-making: information; workload management. Detect deviations from the desired Competencies non- state, evaluate problems, identify risk, A technical (CRM) Emphasis should be placed on the consider alternatives and select the development of leadership, shown by best course of action. Continuously EBT data sources to be a highly effective review progress and adjust plans. competency in mitigating risk and Situation awareness and management improving safety through pilot of information: Have an awareness of Cabin crew report of water noise below the forward galley indicating a possible toilet pipe DES performance the acft state in its environment; x x x leak, with consequent avionics failures project and anticipate changes. Workload management: Prioritise, CRZ delegate and receive assistance to Smoke removal but combined with a diversion until landing completed. x x x x x X maximise focus on the task. Continuously monitor the flight ACAS warning immediately following a go-around, with a descent manoeuvre required. APP x x x x x progress APP Adverse-weather scenario leading to a reactive wind shear warning during approach x x x x Any threat or error that can result in APP circumstances that require a decision to Adverse-weather scenario leading to a predictive wind shear warning during APP or G/A x x x x perform go-around, in addition to the Evaluation and scenario-based training phases execution of the go-around. Go-around Adverse-weather scenario, e.g. thunderstorm activity, heavy precipitation or icing forcing APP x x x x scenarios should be fully developed to decision at or close to DA/MDA encourage effective leadership and teamwork, in addition to problem-solving DA with visual reference in heavy precipitation with doubt about runway surface braking APP x x x x and decision-making, plus execution capability using manual aircraft control or the Go-around APP Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x A flight management system(s) and management automation as applicable. Design should Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP include the element of surprise and x x x (50 ft) (not reported) scenario-based go-arounds should not be predictable and anticipated. This topic is Adverse-wind scenario, strong gusts and/or crosswind out of limits below DA (not APP completely distinct from the go-around x x x reported) manoeuvre listed in the manoeuvres training section that is intended only to Lost or difficult communications resulting in no approach clearance prior to APP practise psychomotor skill and a simple x x x commencement of approach or final descent application of the procedures APP Birds: large flocks of birds below DA once visual reference has been established x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 180 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map APP System malfunction, landing gear malfunction during the approach TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 181 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map CLB CRZ Flight with unreliable airspeed, which may be recoverable or not recoverable X x x x DES APP CLB CRZ Alternate flight control modes according to malfunction characteristics X x x x DES APP CLB CRZ ACAS RA to descend or ATC immediate descent x x x DES APP TAWS warning when deviating from planned descent routing, requiring immediate DES x x x response TO Scenario immediately after take-off which requires an immediate and overweight landing x x x x TO Adverse wind, crosswinds with or without strong gusts on take-off x x Evaluation and scenario-based training phases Adverse weather, wind shear, wind shear encounter during take-off, with or without TO x x x Desired competency outcome: reactive warnings Demonstrates manual aircraft control TO skills with smoothness and accuracy as Engine failure during initial climb, typically 30-60 m (100-200 ft) (autopilot off) x x x x appropriate to the situation Wind shear encounter scenario during cruise, significant and rapid change in wind speed CRZ Detects deviations through instrument x x x x x or down/updrafts, without wind shear warning scanning Manual aircraft Controls the flight path through manual A Maintains spare mental capacity Adverse weather, wind shear, wind shear encounter with or without warning during control APP control x x x x during manual aircraft control approach Maintains the aircraft within the normal flight envelope Adverse weather, deterioration in visibility or cloud base, or adverse wind, requiring a go- APP Applies knowledge of the relationship around from visual circling approach, during the visual segment x x x x x x x between aircraft attitude, speed and APP thrust Adverse wind, crosswinds with or without strong gusts on approach, final and landing x x x LDG (within and beyond limits) Adverse weather, adverse wind, approach and landing in demanding weather conditions, APP e.g. turbulence, up and downdrafts, gusts and crosswinds including shifting wind x x x LDG directions APP Circling approach at night in minimum in-flight visibility to ensure ground reference, LDG minimum environmental lighting and no glide slope guidance lights APP Runway incursion during approach, which can be triggered by ATC at various altitudes or x x x LDG by visual contact during the landing phase Adverse wind, visibility, type-specific, special consideration for long-bodied aircraft, LDG x x x x landing in minimum visibility for visual reference, with crosswind System malfunction, auto flight failure at DA during a low-visibility approach requiring a LDG x x x x go-around flown manually TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 182 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map APP Approach planned with autoland, followed by a failure below 1000 feet requiring a go- x x x x LDG around, and an immediate landing due to fuel shortage. ALL The scenarios should be realistic and Deviations from the flight path, in pitch attitude, speed, altitude, bank angle x x relevant, and should be used for the purpose of demonstration and In-seat instruction: reinforcement of effective flight path Simple automation errors (e.g. incorrect mode selection, attempted engagement without ALL monitoring. the necessary conditions, entering wrong altitude or speed, failure to execute the desired x x mode) culminating in a need for direct intervention from the PM, and where necessary Modules in the FSTD should be treated taking control. like those in an aircraft so that trainees Recognise mismanaged aircraft state. have the opportunity to develop Observe behaviour: how pilot is In-seat instruction: APP competency with the practice of the right mitigating errors, how pilot is Unstable approach or speed/path/vertical rate not congruent with required state for given x x x x techniques and attitudes related to these performing cross checking, how pilot is flight condition topics through pilot performance, and monitoring performance and dealing In-seat instruction: that instructors have the opportunity to with a mismanaged aircraft state, so Demonstration exercise — recovery from bounced landing, adverse wind, strong gusts assess and train these topics in a realistic the instructors should ensure that during landing phase, resulting in a bounce and necessitating recovery action from the PM Evaluation and scenario-based training phases environment. As shown by the EBT data observed deviations, errors and Monitoring, cross report, these topics are of key mistakes are taken as learning checking, error importance to improve safety in opportunities throughout the A management, operations. programme. mismanaged aircraft Monitor flight path excursions. state In addition, the operator may also use Detect errors and threats through these topics to develop scripted role- proper cross checking performance. playing scenarios in the form of ISI Make appropriate interventions either LDG training. These scenarios cater for the verbally or by taking control if x x x need to monitor flight path excursions applicable. from the instructor pilot (PF), detect Take appropriate action if necessary errors and make appropriate Restore desired aircraft state interventions, either verbally or by taking Identify and manage consequences control as applicable. Demonstration scenarios may also be used. Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training. DES ATC or terrain related environment creating a high-energy descent with the need to x x x APP capture the optimum profile to complete the approach in a stabilised configuration Reinforce stabilised approach philosophy DES and adherence to defined parameters. ATC or terrain related environment creating a high-energy descent leading to unstable Unstable Encourage go-arounds when crews are x x x A APP conditions and requiring a go-around approach outside these parameters. Develop and sustain competencies related to the Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x management of high-energy situations downdrafts, gusts and crosswinds including shifting wind directions APP Increasing tailwind on final (not reported) x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 183 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Section 3 Training topics frequency (B) per phase and in alphabetical order. Evaluation ,manoeuvres Include upset prevention elements in See Table 1 in AMC1 ORO.FC.220&230: Elements and respective components of upset training, and scenario- based training phases Table 1 for the recurrent training prevention training. programme at least every 12 calendar months, such that all the elements are Upset prevention Compliance with AMC1 or 2 B N/A covered over a period not exceeding 3 Intentionally blank training ORO.FC.220&230 years. TO Take-off with different crosswind/tailwind/gust conditions x x Evaluation and scenario-based training phases TO Take-off with unreported tailwind x x TO Crosswinds with or without strong gusts on take-off x x APP Increasing tailwind on final (not reported) x x x x Recognise adverse-wind conditions Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x Adverse wind/crosswind. This includes Observe limitations downdrafts, gusts and crosswind including shifting wind directions Adverse wind B tailwind but not ATC mis-reporting of the Apply appropriate procedures APP actual wind Maintain directional control and safe Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x flight path Adverse-wind scenario including strong gusts and/or crosswind out of limits below DA (not APP x x x reported) Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x (50 ft) (not reported) APP Crosswind with or without strong gusts on approach, final and landing (within and beyond x x x LDG limits) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 184 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map For full details, see the Malfunction Equivalency methodology. At least one malfunction with each characteristic should be included every year. Combining characteristics should not reduce the number of malfunctions below 7 for each crew member every year. (i) System malfunctions requiring immediate and urgent crew intervention or decision, e.g. fire, smoke, loss of pressurisation at high altitude, failures during take-off, brake failure during landing. (ii) System malfunctions requiring complex procedures, e.g. multiple hydraulic system failures, smoke and fumes procedures, major dual system electrical. ALL (iii) System malfunctions resulting in significant degradation of flight controls in Intentionally blank combination with abnormal handling characteristics, e.g. jammed flight controls, certain Recognise system malfunction degradation of FBW control, Jammed horizontal stabiliser; Flaps and/or slats locked, other Take appropriate action including malfunctions resulting in degraded flight controls. correct stop/go decision (iv) System failures that require monitoring and management of the flight path using Evaluation and scenario-based training phases Any internal failure(s) apparent or not Apply appropriate procedure correctly degraded or alternative displays, unreliable primary flight path information, unreliable apparent to the crew Maintain aircraft control airspeed, e.g. flight with unreliable airspeed Manage consequences (v) System failures that require extensive management of their consequences Any item cleared by the MEL but having (independent of operation or environment), e.g. fuel leak. an impact upon flight operations. E.g. Apply crew operating procedure TO thrust reverser locked where necessary. MEL items with crew operating procedures applicable during take-off x X Aircraft system Respond appropriately to additional malfunctions, B TO Malfunctions to be considered should system abnormal associated with MEL Response to an additional factor that is affected by MEL item (e.g. system failure, runway x x x X including operations state) have one or more of the following dispatch under MEL characteristics: GND Malfunction during preflight preparation and prior to departure x x x  Immediacy Immediacy CLB  Complexity Complexity Malfunction after departure x x x X  Degradation of aircraft control Degradation of aircraft control  Loss of primary instrumentation Loss of primary instrumentation Malfunctions requiring immediate attention (e.g. bleed fault during engine start, hydraulic ALL  Management of consequences Management of consequences x x x failure during taxi) The operator should vary malfunctions CLB CRZ for each characteristic over the EBT Fuel leak (management of consequences) x x x X cycle. TO Take-off high speed below V1 x x x TO Take-off high speed above V1 x x TO Initial climb x x APP On approach x x x APP Go-around x x x LDG During landing x x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 185 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Compliance failure. Consequences of not The following are examples of potential compliance failures, and not intended to be complying with operating instructions developed as scenarios as part of an EBT module: (e.g. SOPs). This is not intended to list scenarios, but Recognise that a compliance failure 1. Requesting flap beyond limit speed Evaluation and scenario-based training phases instructors should ensure that observed has occurred non-compliances are taken as learning Make a verbal announcement 2. Flaps or slats in the wrong position for phase of flight or approach Compliance B ALL Intentionally blank opportunities throughout the Take appropriate action if necessary programme. In all modules of the Restore safe flight path if necessary 3. Omitting an action as part of a procedure programme, the FSTD should as far as Manage consequences possible be treated like an aircraft, and 4. Failing to initiate or complete a checklist non-compliances should not be accepted simply for expediency. 5. Using the wrong checklist for the situation TO Take-off low speed x x x x TO Any engine failure or malfunction, which Take-off high speed below V1 x x x x causes loss or degradation of thrust that TO impacts performance. This is distinct Recognise engine failure Take-off above V1 x x x x from the engine-out manoeuvres Take appropriate action Engine failure B TO described in the manoeuvres training Apply appropriate procedure correctly Initial climb x x x section above, which are intended only Maintain aircraft control APP for the practice of psychomotor skill and Manage consequences Engine malfunction x x x reinforcement of procedures in CRZ managing engine failures Engine failure in cruise (with autopilot) x x x LDG On landing x GND Fire in cargo or cabin/cockpit at gate x x x x Evaluation and scenario-based training phases GND Fire during taxi x x x x X GND Fire with no cockpit indication x x x x X TO Take-off low speed x x x x X TO Recognise fire, smoke or fumes Take-off high speed below V1 x x x x Take appropriate action Fire and smoke This includes engine, electric, pneumatic, B TO Apply appropriate procedure correctly Take-off high speed above V1 x x x management cargo fire, smoke or fumes Maintain aircraft control TO Manage consequences Initial climb x x x CRZ Cargo fire x x x APP Engine fire in approach (extinguishable) x x APP Engine fire in approach (non-extinguishable) x x x APP Flight deck or cabin fire x x x X TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 186 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Pilots should have opportunities to practise LDGs in demanding situations at the defined frequency. Data indicates that LDG problems have their roots in a variety of factors, including appropriate Landing in demanding environmental This topic should be combined with the adverse-weather topic, aircraft system Landing B LDG decision-making, in addition to manual conditions, with malfunctions as malfunctions topic or any topic that can provide exposure to a landing in demanding Intentionally blank aircraft control skills if difficult appropriate conditions environmental conditions exist. The purpose of this item is to ensure that pilots are exposed to this during the programme The data analysed during the development of this manual and of the Evaluation and scenario-based training phases EBT concept indicated substantial difficulties encountered by crews when faced with a threat or error, which was a surprise, or an unexpected event. The element of surprise should be distinguished from what is sometimes referred to as the ‘startle factor’, the Exposure to an unexpected event or latter being a physiological reaction. Surprise B ALL sequence of events at the defined Intentionally blank Intentionally blank Wherever possible, consideration should frequency be given towards variations in the types of scenario, times of occurrences and types of occurrence, so that pilots do not become overly familiar with repetitions of the same scenarios. Variations should be the focus of EBT programme design, and not left to the discretion of individual instructors, in order to preserve programme integrity and fairness TO Anticipate potential for wind shear Predictive wind shear warning during take-off x x Avoid known wind shear or prepare TO for suspected wind shear Wind shear encounter during take-off x x x With or without warnings including Recognise wind shear encounter TO predictive. A wind shear scenario is Take appropriate action Wind shear encounter after rotation x x Wind shear recovery B ideally combined into an adverse- Apply appropriate procedure correctly TO Predictive wind shear after rotation x x weather scenario containing other Assure aircraft control APP elements. Recognise out of wind shear condition Predictive wind shear during approach x x x Maintain or restore a safe flight path Assess consequential issues and APP Wind shear encounter during approach x x x manage outcomes TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 187 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Section 3 Training topics frequency (C) per phase and in alphabetical order. See Table 2 in AMC1 ORO.FC.220&230: Elements and respective components of upset N/A Intentionally blank prevention training. Upset recognition: Demonstration of the defined normal flight envelope and any CLB CRZ associated changes in flight instruments, flight director systems, and protection systems. x x x x Evaluation, manoeuvres training and scenario-based training phases DES APP This should take the form of an instructor-led exercise to show the crew the points beyond which an upset condition could exist Compliance with AMC1 or 2 ORO.FC.220&230 Upset recognition and recovery — Severe wind shear or wake turbulence during take-off TO APP x x x x x or approach An aeroplane upset is defined as an undesired aeroplane state in flight Upset recognition and recovery — as applicable and relevant to aircraft type, CLB characterised by unintentional demonstration at a suitable intermediate level, with turbulence as appropriate; practise x x x DES divergences from parameters normally steep turns and note the relationship between bank angle, pitch and stalling speed experienced during line operations or Recognise upset condition training. An aeroplane upset may involve Upset recognition and recovery — at the maximum cruise flight level for current aircraft Take appropriate action CRZ pitch and/or bank angle divergences as weight, turbulence to trigger overspeed conditions (if FSTD capability exists, consider use x x x x x Upset Assure aircraft control C well as inappropriate airspeeds for the of vertical wind component to add realism) recovery Maintain or restore a safe flight path conditions. Assess consequential issues Upset recognition and recovery — at the maximum cruise flight level for current aircraft CRZ Manage outcomes weight, turbulence and significant temperature rise to trigger low-speed conditions (if x x x x The example scenario elements may be done in ISI, as non-ISI or a combination of FSTD capability exists, consider use of vertical wind component to add realism) both. Upset recognition and recovery — demonstration at a normal cruising altitude, set CRZ Include the recovery exercises in Table 2 conditions and disable aircraft systems as necessary to enable trainee to complete stall x x x for the recurrent training programme, recovery according to OEM instructions such that all the exercises are covered Upset recognition and recovery — demonstration at an intermediate altitude during early over a period not exceeding 3 years. APP stages of the approach, set conditions and disable aircraft systems as necessary to enable x x x trainee to complete stall recovery according to OEM instructions In-seat instruction: Recovery – Demonstration: the instructor should position the aircraft CLB within but close to the edge of the normal flight envelope before handing control to the x x x DES trainee to demonstrate the restoration of normal flight. Careful consideration should be given to flying within the normal flight envelope GND Recognise loss of communications Loss of communications during ground manoeuvring x x EVAL and SBT Lost or difficult communications. Either Take appropriate action phase Loss of TO through pilot mis-selection or a failure Execute appropriate procedure as Loss of communications after take-off x x X C communications external to the aircraft. This could be for applicable a few seconds or a total loss. Use alternative ways to communicate X APP Loss of communications during approach phase, including go-around x x x x Manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 188 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Anticipate the potential for errors in load/fuel/performance data This can be a demonstrated error, in that the crew may be instructed to deliberately insert A calculation error by one or more pilots, Managing loading, Recognise inconsistencies incorrect data, for example to take off from an intersection with full-length performance or someone involved with the process, or fuel, performance C ALL Manage/avoid distractions information. The crew will be asked to intervene when acceleration is sensed to be lower x x x the process itself, e.g. incorrect errors Make changes to paperwork/aircraft than normal, and this may be part of the operator procedures, especially when operating information on the load sheet system(s) to eliminate error mixed fleets with considerable variations in MTOM. EVAL and SBT phase Identify and manage consequences Recognise a NAV degradation. External failure or a combination of external failures degrading aircraft navigation GND x x x x Take appropriate action performance External NAV failure. Execute appropriate procedure as Navigation C Loss of GPS satellite, ANP exceeding RNP, TO CLB loss of external NAV source(s) applicable External failure or a combination of external failures degrading aircraft navigation Use alternative NAV guidance x x x x APP LDG performance Manage consequences Operations- or C ALL Intentionally blank Intentionally blank Intentionally blank Intentionally blank type-specific The operator should comply with the Operations of special APP See equivalency of approaches relevant national qualification requirements C Intentionally blank Intentionally blank airport approval LDG to operations. published in the Aeronautical Information Publication Recognise incapacitation X TO Take appropriate action including During take-off x x x x Consequences for the non-incapacitated correct stop/go decision Pilot incapacitation C pilot Apply appropriate procedure correctly X APP Maintain aircraft control During approach x x x Manage consequences GND TO Planned anticipated hazardous conditions with dispatch information provided to facilitate X Recognise hazardous runway condition planning and execution of appropriate procedures x LDG Evaluation and scenario-based training Contamination or surface quality of the Observe limitations Runway or taxiway C GND TO runway, taxiway, or tarmac including Take appropriate action Unanticipated hazardous conditions, e.g. unexpected heavy rain resulting in flooded condition x x x LDG foreign objects Apply appropriate procedure correctly runway surface Assure aircraft control TO Stop/go decision in hazardous conditions x x x phases ALL ATC clearance giving insufficient terrain clearance x x x X Anticipate terrain threats Prepare for terrain threats Demonstration of terrain avoidance warning systems (this scenario element may be done ALL Recognise unsafe terrain clearance x x x in an ISI.) Take appropriate action Terrain C TO CLB Alert, warning, or conflict Apply appropriate procedure correctly Engine failure where performance is marginal leading to TAWS warning x x x Maintain aircraft control Restore safe flight path ‘Virtual mountain’ meaning the surprise element of an unexpected warning. Care should DES Manage consequences be exercised in creating a level of realism, so this can best be achieved by an unusual and x x x unexpected change of route during the descent TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 189 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Jet — Recurrent assessment and training matrix Competency map Anticipate potential loss of separation Recognise loss of separation Traffic conflict. ACAS RA or TA, or visual CLB CRZ Take appropriate action Traffic C observation of conflict, which requires ACAS warning requiring crew intervention x x x x DES Apply appropriate procedure correctly evasive manoeuvring Maintain aircraft control Manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 190 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC6 to Appendix II — EBT programme GENERATION 2 (TURBOPROP) — TABLE OF ASSESSMENT AND TRAINING TOPICS Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map Section 1 Engine failure after the application of Rejected take-off A TO From initiation of take-off to complete stop (or as applicable to procedure) x x take-off thrust and before reaching V1 Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised at engine between V1 & A TO before reaching V2 in lowest CAT I normal engine-out climb speed with the correct pitch and lateral control, in trim condition x x V2 visibility conditions and, as applicable, autopilot engagement Failure of critical Failure of a critical engine from V1 and The manoeuvre is considered to be complete at a point when aircraft is stabilised in a engine between V1 & B TO before reaching V2 in lowest CAT I x x V2 visibility conditions Demonstrate manual aircraft control clean configuration with engine-out procedures completed skills with smoothness and accuracy as Manoeuvres training phase Initiation of emergency descent from appropriate to the situation The manoeuvre is considered to be completed once the aircraft is stabilised in emergency Emergency descent C CRZ Detect deviations through instrument descent configuration (and profile) x x x normal cruise altitude scanning With a critical engine failed, manually Maintain spare mental capacity during This manoeuvre should be flown from intercept to centreline until acceleration after go- flown normal precision approach to DA, manual aircraft control around. The manoeuvre is considered to be complete at a point when aircraft is stabilised Engine-out approach A APP followed by manually flown go-around, Maintain the aircraft within the flight at normal engine-out climb speed with the correct pitch and lateral control, in trim x x & go-around the whole manoeuvre to be flown envelope condition and, as applicable, autopilot engagement (describe generally critical part of without visual reference Apply knowledge of the relationship manoeuvre) between aircraft attitude, speed and thrust High energy, initiation during the approach at 150 to 300 m (500 to 1 000 ft) below the APP Go-around, all engines operative x x x missed approach level-off altitude Go-around A Go-around, all engines operative APP Initiation of go-around from DA followed by visual circuit and landing x x x followed by visual circuit, manually flown APP Go-around, all engines operative During flare/rejected landing x x x Initiation in a stabilised engine-out configuration from not less than 3 NM final approach, Engine-out landing A LDG With a critical engine failed, normal landing x x until completion of roll-out Section 2 Equivalency of Approaches relevant to operations Approach type A or See equivalency of approaches B APP Approach type A or B flight method 3D See equivalency of approaches relevant to operations x x x x X B relevant to operations MT phase See equivalency of approaches Approach type A B APP Approach type A flight method 2D See equivalency of approaches relevant to operations x x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 191 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map See equivalency of approaches Approach type A B APP Approach type A flight method 3D See equivalency of approaches relevant to operations x x x x x relevant to operations EVAL and SBT phases See equivalency of approaches X Approach type B B APP Approach type B flight method 3D See equivalency of approaches relevant to operations x x x x relevant to operations See equivalency of approaches SPA approach(es) B APP Approach requiring specific approval Approaches flown from FAF to landing or go around x x x relevant to operations. Section 3 Training topics frequency (A) in alphabetical order. GND Predictive wind shear warning before take-off, as applicable x x x ALL Adverse-weather scenario, e.g. thunderstorm activity, precipitation, icing x x x x TO Wind shear encounter during take-off, not predictive x x x x TO Predictive wind shear warning during take-off x x x x Evaluation and scenario-based training phases TO Crosswinds with or without strong gusts on take-off x x CRZ Wind shear encounter scenario during cruise x x x x x APP Anticipate adverse weather Reactive wind shear warning during approach or go-around x x x x Thunderstorm, heavy rain, turbulence, Prepare for suspected adverse APP ice build-up to include de-icing issues, as Predictive wind shear warning during approach or go-around x x x x weather well as high- temperature conditions. Adverse weather A Recognise adverse weather APP The proper use of use of anti-ice and de- Thunderstorm encounter during approach or on missed approach x x x Take appropriate action icing systems should be included Apply appropriate procedure correctly APP generally in appropriate scenarios. Increasing tailwind on final (not reported) x x x x Assure aircraft control Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x downdrafts, gusts and crosswinds including shifting wind directions Non-precision approach in cold temperature conditions, requiring altitude compensation APP x x x for temperature, as applicable to type APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Reduced visibility even after acquiring the necessary visual reference during approach, APP x x x due to rain or fog TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 192 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map See ‘compliance’ topic above. There are no defined scenarios, but the instructor should This is not considered as a stand-alone focus on learning opportunities when system management non-compliances manifest topic. It links with the topic themselves during other scenarios. Underpinning KNO of systems and their interactions x x EVAL and SBT ‘compliance’ Aircraft system Normal system operation according to should be developed and challenged, and not merely the application of normal A Where a system is not managed management defined instructions procedures according to normal or defined CRZ APP procedures, this is determined as a Minimum fuel, caused by extended delays, weather...etc. where the crew would need to non-compliance x x x x LDG managed a minimum fuel situation. CLB CRZ ACAS warning, recovery and subsequent engagement of automation x x DES APP FMS tactical programming issues, e.g. step climb, runway changes, late clearances, ALL x x X destination re-programming, executing diversion CLB CRZ Know how and when to use the flight management system(s), guidance and Recoveries from TAWS, management of energy state to restore automated flight x x x DES APP automation CLB CRZ Demonstrate correct methods for Amendments to ATC cleared levels during altitude capture modes to force mode engagement and disengagement of x x x DES APP awareness and intervention Evaluation and scenario-based training phases the auto flight system(s) The purpose of this topic is to encourage TO Demonstrate appropriate use of flight Late ATC clearance to an altitude below acceleration altitude x x x and develop effective flight path guidance, auto thrust and other TO management through proficient and automation systems Engine-out special terrain procedures x x x APP appropriate use of the flight Maintain mode awareness of the auto management system(s), guidance and flight system(s), including engagement automation including transitions Forcing AP disconnect followed by re-engagement, recovery from low- or high-speed CRZ and automatic transitions x x x x between modes, monitoring, mode events in cruise Automation Revert to different modes when A awareness, vigilance and flexibility management appropriate CRZ needed to change from one mode to Engine failure in cruise to onset of descent using automation x x Detect deviations from the desired another. Included in this topic is the CRZ aircraft state (flight path, speed, Emergency descent x x X means of mitigating errors described as: attitude, thrust, etc.) and take mishandled auto flight systems, DES appropriate action. Managing high-energy descent capturing descent path from above (correlation with inappropriate mode selection, flight x x x X APP management system(s) and autopilot unstable approach training) Anticipate mishandled auto flight usage. APP system No ATC clearance received prior to commencement of approach or final descent x x x Recognise mishandled auto flight APP system. Reactive wind shear and recovery from the consequent high-energy state x x x Take appropriate action if necessary Non-precision or infrequently flown approaches using the maximum available level of APP Restore correct auto flight state x x X automation Identify and manage consequences APP Gear malfunction during approach x x x ATC clearances to waypoints beyond programmed descent point for a coded final descent APP point during an approach utilising a final descent that is commanded by the flight x x x X management system. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 193 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map Communication: Demonstrate effective use of language, responsiveness to feedback and that plans are stated and ambiguities resolved. Leadership and teamwork: Use This encapsulates communication; appropriate authority to ensure focus leadership and teamwork; problem- on the task. Support others in GPS failure prior to commencement of approach associated with position drift and a X APP x x x solving and decision-making; situation completing tasks. terrain alert awareness and management of Problem-solving and decision-making: information; workload management. Detect deviations from the desired Evaluation and scenario-based training phases Competencies non- state, evaluate problems, identify risk, A technical (CRM) Emphasis should be placed on the consider alternatives and select the development of leadership, shown by best course of action. Continuously EBT data sources to be a highly effective review progress and adjust plans. competency in mitigating risk and Situation awareness and management improving safety through pilot of information: Have an awareness of Cabin crew report of water noise below the forward galley indicating a possible toilet pipe DES performance the acft state in its environment; x x x leak, with consequent avionics failures project and anticipate changes. Workload management: Prioritise, CRZ delegate and receive assistance to Smoke removal but combined with a diversion until landing completed. x x x x x X maximise focus on the task. Continuously monitor the flight ACAS warning immediately following a go-around, with a descent manoeuvre required. APP x x x x x progress Compliance failure. Consequences of not The following are examples of potential compliance failures, and not intended to be complying with operating instructions developed as scenarios as part of an EBT module: (e.g. SOPs). This is not intended to list scenarios, but Recognise that a compliance failure 1. Requesting flap beyond limit speed instructors should ensure that observed has occurred non-compliances are taken as learning Make a verbal announcement 2. Flaps or slats in the wrong position for phase of flight or approach Compliance A ALL Intentionally blank opportunities throughout the Take appropriate action if necessary programme. In all modules of the Restore safe flight path if necessary 3. Omitting an action as part of a procedure programme, the FSTD should as far as Manage consequences possible be treated like an aircraft, and 4. Failing to initiate or complete a checklist non-compliances should not be accepted simply for expediency. 5. Using the wrong checklist for the situation TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 194 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map APP Adverse-weather scenario leading to a reactive wind shear warning during approach x x x x APP Any threat or error that can result in Adverse-weather scenario leading to a predictive wind shear warning during APP or G/A x x x x circumstances that require a decision to perform go-around, in addition to the Adverse-weather scenario, e.g. thunderstorm activity, heavy precipitation or icing forcing APP execution of the go-around. Go-around x x x x decision at or close to DA/MDA Evaluation and scenario-based training phases scenarios should be fully developed to encourage effective leadership and DA with visual reference in heavy precipitation with doubt about runway surface braking APP x x x x teamwork, in addition to problem-solving capability and decision-making, plus execution APP using manual aircraft control or the Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x Go-around A flight management system(s) and management Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP automation as applicable. Design should x x x (50 ft) (not reported) include the element of surprise and scenario-based go-arounds should not be Adverse-wind scenario, strong gusts and/or crosswind out of limits below DA (not APP predictable and anticipated. This topic is x x x reported) completely distinct from the go-around manoeuvre listed in the manoeuvres Lost or difficult communications resulting in no approach clearance prior to APP training section that is intended only to x x x commencement of approach or final descent practise psychomotor skill and a simple APP application of the procedures Birds: large flocks of birds below DA once visual reference has been established x x x APP System malfunction, landing gear malfunction during the approach TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 195 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map CLB CRZ Flight with unreliable airspeed, which may be recoverable or not recoverable X x x x DES APP CLB CRZ Alternate flight control modes according to malfunction characteristics X x x x DES APP CLB CRZ ACAS RA to descend or ATC immediate descent x x x DES APP TAWS warning when deviating from planned descent routing, requiring immediate DES x x x response TO Scenario immediately after take-off which requires an immediate and overweight landing x x x x TO Adverse wind, crosswinds with or without strong gusts on take-off x x Evaluation and scenario-based training phases Adverse weather, wind shear, wind shear encounter during take-off, with or without TO x x x Desired competency outcome: reactive warnings Demonstrates manual aircraft control TO skills with smoothness and accuracy as Engine failure during initial climb, typically 30-60 m (100-200 ft) (autopilot off) x x x x appropriate to the situation Wind shear encounter scenario during cruise, significant and rapid change in wind speed CRZ Detects deviations through instrument x x x x x or down/updrafts, without wind shear warning scanning Manual aircraft Controls the flight path through manual A Maintains spare mental capacity Adverse weather, wind shear, wind shear encounter with or without warning during control APP control x x x x during manual aircraft control approach Maintains the aircraft within the normal flight envelope Adverse weather, deterioration in visibility or cloud base, or adverse wind, requiring a go- APP Applies knowledge of the relationship around from visual circling approach, during the visual segment x x x x x x x between aircraft attitude, speed and APP thrust Adverse wind, crosswinds with or without strong gusts on approach, final and landing x x x LDG (within and beyond limits) Adverse weather, adverse wind, approach and landing in demanding weather conditions, APP e.g. turbulence, up and downdrafts, gusts and crosswinds including shifting wind x x x LDG directions APP Circling approach at night in minimum in-flight visibility to ensure ground reference, LDG minimum environmental lighting and no glide slope guidance lights APP Runway incursion during approach, which can be triggered by ATC at various altitudes or x x x LDG by visual contact during the landing phase Adverse wind, visibility, type-specific, special consideration for long-bodied aircraft, LDG x x x x landing in minimum visibility for visual reference, with crosswind System malfunction, auto flight failure at DA during a low-visibility approach requiring a LDG x x x x go-around flown manually TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 196 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map APP Approach planned with autoland, followed by a failure below 1000 feet requiring a go- x x x x LDG around, and an immediate landing due to fuel shortage. The scenarios should be realistic and relevant, and should be used for the ALL purpose of demonstration and Deviations from the flight path, in pitch attitude, speed, altitude, bank angle x x reinforcement of effective flight path monitoring. In-seat instruction: Modules in the FSTD should be treated Simple automation errors (e.g. incorrect mode selection, attempted engagement without like those in an aircraft so that trainees Recognise mismanaged aircraft state. the necessary conditions, entering wrong altitude or speed, failure to execute the desired have the opportunity to develop Observe behaviour: how pilot is mode) culminating in a need for direct intervention from the PM, and where necessary ALL competency with the practice of the right mitigating errors, how pilot is x x taking control. techniques and attitudes related to these performing cross checking, how pilot is topics through pilot performance, and monitoring performance and dealing that instructors have the opportunity to with a mismanaged aircraft state, so assess and train these topics in a realistic the instructors should ensure that Evaluation and scenario-based training phases environment. As shown by the EBT data observed deviations, errors and In-seat instruction: Monitoring, cross report, these topics are of key mistakes are taken as learning Unstable approach or speed/path/vertical rate not congruent with required state for given checking, error importance to improve safety in opportunities throughout the A flight condition management, operations. programme. mismanaged aircraft APP Monitor flight path excursions. x x x x state In addition, the operator may also use Detect errors and threats through these topics to develop scripted role- proper cross checking performance. playing scenarios in the form of ISI Make appropriate interventions either training. These scenarios cater for the verbally or by taking control if need to monitor flight path excursions applicable. from the instructor pilot (PF), detect Take appropriate action if necessary In-seat instruction: errors and make appropriate Restore desired aircraft state Demonstration exercise — recovery from bounced landing, adverse wind, strong gusts interventions, either verbally or by taking Identify and manage consequences during landing phase, resulting in a bounce and necessitating recovery action from the PM control as applicable. Demonstration scenarios may also be used. LDG x x x Demonstrated role-play should contain realistic and not gross errors, leading at times to a mismanaged aircraft state, which can also be combined with upset management training. DES ATC or terrain related environment creating a high-energy descent with the need to x x x APP capture the optimum profile to complete the approach in a stabilised configuration Reinforce stabilised approach philosophy DES and adherence to defined parameters. ATC or terrain related environment creating a high-energy descent leading to unstable Unstable Encourage go-arounds when crews are x x x A APP conditions and requiring a go-around approach outside these parameters. Develop and sustain competencies related to the Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x management of high-energy situations downdrafts, gusts and crosswinds including shifting wind directions APP Increasing tailwind on final (not reported) x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 197 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map APP Crosswinds with or without strong gusts on approach, final and landing (within and x x x LDG beyond limits) Section 3 Training topics frequency (B) per phase and in alphabetical order. Evaluation ,manoeuvres Include upset prevention elements in See Table 1 in AMC1 ORO.FC.220&230: Elements and respective components of upset training, and scenario- based training phases Table 1 for the recurrent training prevention training. programme at least every 12 calendar months, such that all the elements are Upset prevention Compliance with AMC1 or 2 B N/A covered over a period not exceeding 3 Intentionally blank training ORO.FC.220&230 years. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 198 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map For full details, see the Malfunction Equivalency methodology. At least one malfunction with each characteristic should be included every year. Combining characteristics should not reduce the number of malfunctions below 7 for each crew member every year. (i) System malfunctions requiring immediate and urgent crew intervention or decision, e.g. fire, smoke, loss of pressurisation at high altitude, failures during take-off, brake failure during landing. (ii) System malfunctions requiring complex procedures, e.g. multiple hydraulic system failures, smoke and fumes procedures, major dual system electrical. ALL (iii) System malfunctions resulting in significant degradation of flight controls in Intentionally blank combination with abnormal handling characteristics, e.g. jammed flight controls, certain Recognise system malfunction degradation of FBW control, Jammed horizontal stabiliser; Flaps and/or slats locked, other Take appropriate action including malfunctions resulting in degraded flight controls. correct stop/go decision (iv) System failures that require monitoring and management of the flight path using Evaluation and scenario-based training phases Any internal failure(s) apparent or not Apply appropriate procedure correctly degraded or alternative displays, unreliable primary flight path information, unreliable apparent to the crew Maintain aircraft control airspeed, e.g. flight with unreliable airspeed Manage consequences (v) System failures that require extensive management of their consequences Any item cleared by the MEL but having (independent of operation or environment), e.g. fuel leak. an impact upon flight operations. E.g. Apply crew operating procedure TO thrust reverser locked where necessary. MEL items with crew operating procedures applicable during take-off x X Aircraft system Respond appropriately to additional malfunctions, B TO Malfunctions to be considered should system abnormal associated with MEL Response to an additional factor that is affected by MEL item (e.g. system failure, runway x x x X including operations state) have one or more of the following dispatch under MEL characteristics: GND Malfunction during preflight preparation and prior to departure x x x  Immediacy Immediacy CLB  Complexity Complexity Malfunction after departure x x x X  Degradation of aircraft control Degradation of aircraft control  Loss of primary instrumentation Loss of primary instrumentation Malfunctions requiring immediate attention (e.g. bleed fault during engine start, hydraulic ALL  Management of consequences Management of consequences x x x failure during taxi) The operator should vary malfunctions CLB CRZ for each characteristic over the EBT Fuel leak (management of consequences) x x x X cycle. TO Take-off high speed below V1 x x x TO Take-off high speed above V1 x x TO Initial climb x x APP On approach x x x APP Go-around x x x LDG During landing x x x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 199 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map TO Take-off low speed x x x x TO Any engine failure or malfunction, which Take-off high speed below V1 x x x x causes loss or degradation of thrust that impacts performance. This is distinct Recognise engine failure x x EVAL and SBT phases TO Take-off above V1 x x from the engine-out manoeuvres Take appropriate action Engine failure B TO described in the manoeuvres training Apply appropriate procedure correctly Initial climb x x x section above, which are intended only Maintain aircraft control APP for the practice of psychomotor skill and Manage consequences Engine malfunction x x x reinforcement of procedures in CRZ managing engine failures Engine failure in cruise (with autopilot) x x x LDG On landing x Pilots should have opportunities to practise LDGs in demanding situations at the defined frequency. Data indicates that LDG problems have their roots in a variety of factors, including appropriate Landing in demanding environmental This topic should be combined with the adverse-weather topic, aircraft system Landing B LDG decision-making, in addition to manual conditions, with malfunctions as malfunctions topic or any topic that can provide exposure to a landing in demanding Intentionally blank aircraft control skills if difficult appropriate conditions environmental conditions exist. The Evaluation and scenario-based training phases purpose of this item is to ensure that pilots are exposed to this during the programme The data analysed during the development of this manual and of the EBT concept indicated substantial difficulties encountered by crews when faced with a threat or error, which was a surprise, or an unexpected event. The element of surprise should be distinguished from what is sometimes referred to as the ‘startle factor’, the Exposure to an unexpected event or latter being a physiological reaction. Surprise B ALL sequence of events at the defined Intentionally blank Intentionally blank Wherever possible, consideration should frequency be given towards variations in the types of scenario, times of occurrences and types of occurrence, so that pilots do not become overly familiar with repetitions of the same scenarios. Variations should be the focus of EBT programme design, and not left to the discretion of individual instructors, in order to preserve programme integrity and fairness TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 200 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map ALL ATC clearance giving insufficient terrain clearance x x x X Anticipate terrain threats Prepare for terrain threats Demonstration of terrain avoidance warning systems (this scenario element may be done ALL Recognise unsafe terrain clearance x x x in an ISI.) Take appropriate action Terrain B TO CLB Alert, warning, or conflict Apply appropriate procedure correctly Engine failure where performance is marginal leading to TAWS warning x x x EVAL and SBT phases Maintain aircraft control Restore safe flight path ‘Virtual mountain’ meaning the surprise element of an unexpected warning. Care should DES Manage consequences be exercised in creating a level of realism, so this can best be achieved by an unusual and x x x unexpected change of route during the descent This is not considered a topic for specific attention on its own, but more as a reminder to programme developers to ensure that pilots Manage available resources efficiently to Workload, distraction, B are exposed to immersive training scenarios prioritize and perform tasks in a timely Intentionally blank Intentionally blank pressure which expose them to manageable high manner under all circumstances workload and distractions during the course of the EBT programme, at the defined frequency TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 201 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map Section 3 Training topics frequency (C) per phase and in alphabetical order. See Table 2 in AMC1 ORO.FC.220&230: Elements and respective components of upset N/A Intentionally blank prevention training. Upset recognition: Demonstration of the defined normal flight envelope and any CLB CRZ associated changes in flight instruments, flight director systems, and protection systems. x x x x Evaluation, manoeuvres training and scenario-based training phases DES APP This should take the form of an instructor-led exercise to show the crew the points beyond which an upset condition could exist Compliance with AMC1 or 2 ORO.FC.220&230 Upset recognition and recovery — Severe wind shear or wake turbulence during take-off TO APP x x x x x or approach An aeroplane upset is defined as an undesired aeroplane state in flight Upset recognition and recovery — as applicable and relevant to aircraft type, CLB characterised by unintentional demonstration at a suitable intermediate level, with turbulence as appropriate; practise x x x DES divergences from parameters normally steep turns and note the relationship between bank angle, pitch and stalling speed experienced during line operations or Recognise upset condition training. An aeroplane upset may involve Upset recognition and recovery — at the maximum cruise flight level for current aircraft Take appropriate action CRZ pitch and/or bank angle divergences as weight, turbulence to trigger overspeed conditions (if FSTD capability exists, consider use x x x x x Upset Assure aircraft control C well as inappropriate airspeeds for the of vertical wind component to add realism) recovery Maintain or restore a safe flight path conditions. Assess consequential issues Upset recognition and recovery — at the maximum cruise flight level for current aircraft CRZ Manage outcomes weight, turbulence and significant temperature rise to trigger low-speed conditions (if x x x x The example scenario elements may be done in ISI, as non-ISI or a combination of FSTD capability exists, consider use of vertical wind component to add realism) both. Upset recognition and recovery — demonstration at a normal cruising altitude, set CRZ Include the recovery exercises in Table 2 conditions and disable aircraft systems as necessary to enable trainee to complete stall x x x for the recurrent training programme, recovery according to OEM instructions such that all the exercises are covered Upset recognition and recovery — demonstration at an intermediate altitude during early over a period not exceeding 3 years. APP stages of the approach, set conditions and disable aircraft systems as necessary to enable x x x trainee to complete stall recovery according to OEM instructions In-seat instruction: Recovery – Demonstration: the instructor should position the aircraft CLB within but close to the edge of the normal flight envelope before handing control to the x x x DES trainee to demonstrate the restoration of normal flight. Careful consideration should be given to flying within the normal flight envelope TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 202 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map TO Take-off with different crosswind/tailwind/gust conditions x x TO Take-off with unreported tailwind x x Evaluation and scenario-based training phases TO Crosswinds with or without strong gusts on take-off x x APP Increasing tailwind on final (not reported) x x x x Recognise adverse-wind conditions Approach and landing in demanding weather conditions, e.g. turbulence, up and APP x x x Adverse wind/crosswind. This includes Observe limitations downdrafts, gusts and crosswind including shifting wind directions Adverse wind C tailwind but not ATC mis-reporting of the Apply appropriate procedures APP actual wind Maintain directional control and safe Adverse-wind scenario resulting in increasing tailwind below DA (not reported) x x x flight path Adverse-wind scenario including strong gusts and/or crosswind out of limits below 15 m APP x x x (50 ft) (not reported) Adverse-wind scenario, strong gusts and/or crosswind out of limits below DA (not APP x x x reported) Crosswind with or without strong gusts on APP, final and landing (within and beyond APP LDG x x x limits) APP Recognise actual conditions Approach in poor visibility x x x x Observe aircraft and/or procedural limitations Approach in poor visibility with deteriorations necessitating a decision to perform go- Approach, visibility APP Any situation where visibility becomes a x x x c Apply appropriate procedure if around close to minimum threat applicable Maintain directional control and safe Landing in poor visibility LDG flight path x x x GND Fire in cargo or cabin/cockpit at gate x x x x GND Fire during taxi x x x x X EVAL and SBT phase GND Recognise fire, smoke or fumes Fire with no cockpit indication x x x x X Take appropriate action Fire and smoke This includes engine, electric, pneumatic, C TO Apply appropriate procedure correctly Take-off low speed x x x x X management cargo fire, smoke or fumes Maintain aircraft control TO Manage consequences Take-off high speed below V1 x x x x TO Take-off high speed above V1 x x x TO Initial climb x x x TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 203 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map CRZ Cargo fire x x x APP Engine fire in approach (extinguishable) x x APP Engine fire in approach (non-extinguishable) x x x APP Flight deck or cabin fire x x x X GND Recognise loss of communications Loss of communications during ground manoeuvring x x EVAL and SBT Lost or difficult communications. Either Take appropriate action phase Loss of TO through pilot mis-selection or a failure Execute appropriate procedure as Loss of communications after take-off x x X C communications external to the aircraft. This could be for applicable a few seconds or a total loss. Use alternative ways to communicate X APP Loss of communications during approach phase, including go-around x x x x Manage consequences Anticipate the potential for errors in load/fuel/performance data This can be a demonstrated error, in that the crew may be instructed to deliberately insert A calculation error by one or more pilots, Managing loading, Recognise inconsistencies incorrect data, for example to take off from an intersection with full-length performance or someone involved with the process, or fuel, performance C ALL Manage/avoid distractions information. The crew will be asked to intervene when acceleration is sensed to be lower x x x the process itself, e.g. incorrect errors Make changes to paperwork/aircraft than normal, and this may be part of the operator procedures, especially when operating information on the load sheet system(s) to eliminate error mixed fleets with considerable variations in MTOM. EVAL and SBT phase Identify and manage consequences Recognise a NAV degradation. External failure or a combination of external failures degrading aircraft navigation GND x x x x Take appropriate action performance External NAV failure. Execute appropriate procedure as Navigation C Loss of GPS satellite, ANP exceeding RNP, TO CLB loss of external NAV source(s) applicable External failure or a combination of external failures degrading aircraft navigation Use alternative NAV guidance x x x x APP LDG performance Manage consequences Operations- or C ALL Intentionally blank Intentionally blank Intentionally blank Intentionally blank type-specific The operator should comply with the Operations of special APP See equivalency of approaches relevant national qualification requirements C Intentionally blank Intentionally blank airport approval LDG to operations. published in the Aeronautical Information Publication Recognise incapacitation TO Take appropriate action including During take-off x x x x X Consequences for the non-incapacitated correct stop/go decision Pilot incapacitation C pilot Apply appropriate procedure correctly APP Maintain aircraft control During approach x x x X Manage consequences TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 204 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Flight phase for activation Frequency Description (includes type of topic, Desired outcome Assessment and being threat, error (includes performance criteria OR Guidance material (GM) WLM COM SAW FPM KNO LTW APK PSD FPA training topic or focus) training outcome) Example scenario elements Generation 2 Turboprop — Recurrent assessment and training matrix Competency map GND TO Planned anticipated hazardous conditions with dispatch information provided to facilitate X Recognise hazardous runway condition planning and execution of appropriate procedures x LDG Contamination or surface quality of the Observe limitations Runway or taxiway C GND TO runway, taxiway, or tarmac including Take appropriate action Unanticipated hazardous conditions, e.g. unexpected heavy rain resulting in flooded condition x x x LDG foreign objects Apply appropriate procedure correctly runway surface Evaluation and scenario-based training phases Assure aircraft control TO Stop/go decision in hazardous conditions x x x Anticipate potential loss of separation Recognise loss of separation Traffic conflict. ACAS RA or TA, or visual CLB CRZ Take appropriate action Traffic C observation of conflict, which requires ACAS warning requiring crew intervention x x x x DES Apply appropriate procedure correctly evasive manoeuvring Maintain aircraft control Manage consequences TO Anticipate potential for wind shear Predictive wind shear warning during take-off x x Avoid known wind shear or prepare TO for suspected wind shear Wind shear encounter during take-off x x x With or without warnings including Recognise wind shear encounter TO predictive. A wind shear scenario is Take appropriate action Wind shear encounter after rotation x x Wind shear recovery C ideally combined into an adverse- Apply appropriate procedure correctly TO Predictive wind shear after rotation x x weather scenario containing other Assure aircraft control APP elements. Recognise out of wind shear condition Predictive wind shear during approach x x x Maintain or restore a safe flight path Assess consequential issues and APP Wind shear encounter during approach x x x manage outcomes TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 205 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Appendices 2 to 6 Summary of amendments to Appendices 2 to 6 to Doc 9995: — The competency KNO is introduced and its competency map. — The wording ‘Guidance material’ is introduced in the ‘example scenario element column’ to indicate that this column is GM. — The 3 go-arounds in the assessment and training topic of the manoeuvres training phase are merged because it was confusing for the operators. Frequencies are also merged. — Training topic ‘adverse weather’ — example scenario element ‘adverse-weather scenario’ e.g. thunderstorm activity, precipitation, icing, flight phase activation amend from take-off (TO) to all phases of flight (ALL). — Training topic ‘automation management’ — for 3 example scenario elements, the flight phase activation has changed from ALL to CLB, CRZ, DES, APP, as those example scenario elements cannot be triggered on ground (e.g. recoveries from TAWS, ACAS warnings, recovery and subsequent engagement of automation). — Same as above in training topic ‘manual aircraft control’ (e.g. ACAS RA to descend or ATC […]). — Training topic ‘competencies non-technical (CRM)’ — example scenario element ‘ACAS warning immediately following a go-around, with a descent manoeuvre required’, the activation phase is changed from CRZ to APP. — Training topic ‘manual aircraft control’ — a new example scenario element and its competency map were introduced (Approach planned with autoland, followed by a failure below 1 000 feet […]). — Training topic ‘monitoring, cross checking, error management, and mismanagement aircraft state’ — the term ‘in-seat instruction’ is deleted. Feedback from operators implementing mixed EBT implementation has highlighted that ISI is not the only means of training this operational risk; therefore, an increase flexibility in regard to the means to deliver this training topic was introduced. Furthermore, the ‘Data Report for Evidence-Based Training’23 DOES NOT make any reference to in-seat instruction. — Training topic ‘upset prevention training’ — extensive amendments are introduced. Doc 9995 was published before Doc 10011 ‘UPRT manual’, and therefore Doc 9995 does not provide the latest training exercises for UPRT. The new provision proposed in AMC8 ORO.FC.231 point (a) requires compliance with AMC1&2 ORO.FC.220&230. The new text allows to train this topic in all phases of the modules to allow more flexibility. — Training topic ‘aircraft system malfunctions, including operations under MEL’ — a new example scenario element and its competency map were introduced (fuel leak (management of consequences)). — Training topic ‘terrain’ — the example scenario element of demonstration of TAWS is amended to allow operators to train this exercise with ISI in order to avoid negative training for pilots. — A new training topic (operations of special airport approval) was introduced with a frequency of ‘C’. — Training topic ‘upset recovery training’ was extensively amended. Doc 9995 was published before Doc 10011 ‘UPRT manual’, and therefore Doc 9995 does not provide the latest training exercises for UPRT. The new text requires compliance with AMC1&2 ORO.FC.220&230. The new text allows to train this topic in all phases of the modules to allow more flexibility. 23 st IATA Data Report for Evidence-Based Training August 2014 1 Edition. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 206 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Annex I (Part-FCL) to Regulation (EU) No 1178/2011 Concept of revalidation within an EBT programme Background of licence revalidation: — The current revalidation process has four components: (a) the applicant (b) the examiner (c) the technical assessment carried out in the simulator or the aircraft (d) the administrative procedure that includes the completion of Appendix 9, and the rest of administrative procedures in Part-FCL FCL.1030 point (b), (c) and (d) that includes the licence endorsements. This process is carried out by the same person (examiner) who performs the technical assessment and the administrative procedure, at the same ‘location’ (simulator or aircraft) and at the same time (the date and time of the proficiency check). Note: Although most of the LPCs are carried out by a single examiner, the possibility of having several examiners for the same check already exists. — The EBT philosophy should provide a different approach, where training is maximised and therefore checks disappear (assessment is introduced) and the pilot is trained in NON-jeopardy environment. Furthermore, the continuous training evidences of the pilot (data) should provide a better assessment of the competence of the pilot. Therefore: (a) the EBT technical assessment has several events (simulator sessions) instead of one, (b) there are several assessors of pilot performance (EBT instructors) instead of just one (examiner); however, the nominated person for crew training who is an examiner designated to provide a final assessment of the data collected; and (c) the administrative procedure should be maintained; however, due to the several people involved in the technical assessment, the administrative procedures involve the nominated person for crew training who carries the responsibility of the licence revalidation and a designated person who will endorse the licence. Concept of licence revalidation in the context of an operator’s approved EBT programme The revalidation process proposed has the following components: (a) the applicant; (b) the people involved in the revalidation of the pilot licence: (1) the nominated person for crew training (or the deputy(ies)) who is an examiner responsible for the operator’s approved EBT programme, (ensuring that the manoeuvres assessed are of a good training value and that the applicant completed those manoeuvres). The nominated person will be mostly responsible for the completion of Appendix 10. This person (or the deputy(ies)) also has the overall picture of the pilot training data for the period of validity (as shown by the evidence provided by the EBT programme); TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 207 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (2) the designated person who has the signature delegation from the nominated person to endorse the licence and complete Appendix 10; and (3) the EBT instructors who delivered each of the technical assessments that provide data to the EBT grading system and the training system performance; (c) the several technical assessments carried out in the simulators which provide the necessary evidence to ensure the pilot has an acceptable level of performance; and (d) the administrative procedure which includes the completion of Appendix 10 and the rest of administrative procedures provided in FCL.1030. FCL.625 IR — Validity, revalidation and renewal (a) […] (b) […] (c) Renewal. If an IR has expired, in order to renew their privileges applicants shall: (1) go through refresher training at an ATO to reach the level of proficiency needed to pass the instrument element of the skill test in accordance with Appendix 9 to this Part; and (2) complete a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part, in the relevant aircraft category. (d) […] FCL.625.A IR(A) — Revalidation (a) Revalidation. Applicants for the revalidation of an IR(A): (2) when combined with the revalidation of a class or type rating, shall pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part; […] FCL.740 — Validity and renewal of class and type ratings (a) […] (b) Renewal. If a class or type rating has expired, the applicant shall: (1) take refresher training at an ATO, or an AOC approved for such refresher, when necessary to reach the level of proficiency necessary to safely operate the relevant class or type of aircraft; and (2) pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part. […] AMC1 FCL.740(b)(1) Validity and renewal of class and type ratings RENEWAL OF CLASS AND TYPE RATINGS: REFRESHER TRAINING — ATO (a) Paragraph (b)(1) of FCL.740 determines that if a class or type rating has lapsed, the applicant shall take refresher training at an ATO. The objective of the training is to reach the level of proficiency necessary to safely operate the relevant type or class of aircraft. The amount of refresher training needed should be determined on a case-by-case basis by the ATO, taking into account the following factors: […] TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 208 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC2 FCL.740(b)(1) Validity and renewal of class and type ratings RENEWAL OF CLASS AND TYPE RATINGS: REFRESHER TRAINING — AOC Point (b)(1) of FCL.740 determines that if a class or type rating has lapsed, the applicant shall take refresher training. An AOC approved for such purpose can provide such training only for their own pilots when enrolled under an approved EBT programme. The maximum amount of time elapsed since the expiry of the validity period of the rating should be no more than one year. If more than 1 year has elapsed, the training should be performed in an ATO and AMC1 FCL.740(b)(1) applies. FCL.740.A — Revalidation of class and type ratings — aeroplanes (b) Revalidation of multi-engine class ratings and type ratings. For revalidation of multi-engine class ratings and type ratings, the applicant shall: (2) pass a proficiency check in accordance with Appendix 9 or Appendix 10 to this Part in the relevant class or type of aeroplane or an FSTD representing that class or type, within the 3 months immediately preceding the expiry date of the rating; […] FCL.905.TRI TRI — Privileges and conditions (a) The privileges of a TRI are to instruct for: (a) (1) the revalidation and renewal of an EIR or an IR, provided the TRI holds a valid IR; […] (f) (6) in the case of the TRI for powered-lift aircraft: (1) (i) the issue, revalidation and renewal of powered-lift type ratings; (2) (ii) MCC training. (b) After successful completion of the operator’s EBT instructor standardisation in accordance with Part ORO, the TRI has additionally the privilege to conduct practical assessment in competencies. FCL.905.SFI SFI — Privileges and conditions (a) The privileges of an SFI are to carry out synthetic flight instruction, within the relevant aircraft category, for: (a) (1) the issue, revalidation and renewal of an IR, provided that he/she holds or has held an IR in the relevant aircraft category and has completed an IRI training course; and (b) (2) in the case of SFI for single-pilot aeroplanes: (1) (i) the issue, revalidation and renewal of type ratings for single-pilot high performance complex aeroplanes, when the applicant seeks privileges to operate in single-pilot operations. […] (d) (4) in the case of SFI for helicopters: (1) (i) the issue, revalidation and renewal of helicopter type ratings; (2) (ii) MCC training, when the SFI has privileges to instruct for multi-pilot helicopters. (b) After successful completion of the operator’s EBT instructor standardisation in accordance with Part ORO, the SFI has additionally the privilege to conduct practical assessment in competencies. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 209 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail FCL.1025 Validity, revalidation and renewal of examiner certificates (a) Validity. An examiner certificate shall be valid for 3 years. (b) Revalidation. An examiner certificate shall be revalidated when the holder has, during the validity period of the certificate: (1) conducted at least 2 skill tests, proficiency checks or assessments of competence every year; […] GM1 FCL.1025(b)(1) Validity, revalidation and renewal of examiner certificates REVALIDATION OF EXAMINERS UNDER AN APPROVED EBT PROGRAMME FCL.1025 requires for the revalidation of the examiner certificate at least two proficiency checks or assessments of competence every year. A practical assessment in competencies is equivalent to a proficiency check; however, the EBT programme uses two practical assessments in competencies to complete the proficiency check, therefore the examiner under EBT revalidates with four practical assessments of competencies, which complete two proficiency checks. The practical assessment in competencies within an approved EBT programme is equivalent to a proficiency check. FCL.1030 Conduct of skill tests, proficiency checks and assessments of competence AMC1 FCL.1030(b)(3) Conduct of skill tests, proficiency checks and assessments of competence OBLIGATIONS FOR EXAMINERS APPLICATION AND REPORT FORMS […] (b) For training, skill tests or proficiency checks for ATPL, MPL or class and type ratings, in AMC1 to Appendix 9 or AMC1 to Appendix 10; GM1 FCL.1030(b)(3)(ii) Revalidation of class and type ratings — aeroplanes REQUIRED MANOEUVRES AND EXERCISES FOR APPENDIX 10 The confirmation that all the required manoeuvres and exercises have been completed, means that during the period of validity the applicant has completed the operator’s approved EBT programme corresponding to that period of validity as declared by the nominated person for crew training. GM1 FCL.1030(b)(3)(ii) This GM is developed to clarify the responsibility of the TRE as regards ‘the required manoeuvres and exercises’. See FCL.1030 of the Aircrew Regulation below: ‘FCL.1030 (…) (ii) confirmation that all the required manoeuvres and exercises have been completed, as well as information on the verbal theoretical knowledge examination, when applicable. If an item has been failed, the examiner shall record the reasons for this assessment;’ TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 210 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Appendix 10 to Annex I (Part-FCL) to Regulation (EU) No 1178/2011 Appendix 10 — Proficiency check type ratings, and proficiency check for IRs when combined with type rating — Practical assessment in competencies A — General 1. The practical assessment in competencies within an approved EBT programme is equivalent to a proficiency check. 2. Appendix 10 only applies to: (a) an operator with an approved EBT programme that has: (1) an experience of at least 2 years conducting an EBT programme which may include mixed EBT; and (2) a nominated person for crew training (or the deputy(ies)) who is a current examiner in each of the type ratings for which Appendix 10 is applicable; or (b) an ATO on behalf of the operator that complies with paragraph (2)(a) above, under ORO.GEN.205 ‘Contracted activities’. 3. The nominated person for crew training must verify that the applicant complies with all the qualification, training and experience requirements in this Part for the revalidation of the rating for which the proficiency check is taken. 4. Applicants using Appendix 10 shall: (a) be enrolled flight crew members in the operator’s approved EBT programme; and (b) within the period of validity, complete the operator’s approved EBT programme. 5. The revalidation or renewal in accordance with Appendix 10 shall comprise: (a) continuous practical assessment in competencies within an approved EBT programme; (b) demonstration of an acceptable level of performance in all competencies; and (c) the administrative action of licence revalidation. (1) The nominated person for crew training (or the deputy(ies)) shall endorse the applicant’s licence or certificate with the new expiry date of the rating, if specifically authorised for that purpose by the competent authority responsible for the applicant’s licence. Delegation of the nominated person’s for crew training (or the deputy(ies)) signature in order for the applicant’s licence to be signed, may be possible only if the operator has an approved procedure for such case. (2) The nominated person for crew training (or the deputy(ies)) shall ensure that the requirements in FCL.1030 ‘Conduct of skill tests, proficiency checks and assessments of competence’ are met. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 211 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail B — CONDUCT OF PRACTICAL ASSESSMENT IN COMPETENCIES 6. The practical assessment in competencies must be conducted in accordance with the operator’s approved EBT programme. 7. Applicants who fail to demonstrate an acceptable level of competence and are de-enrolled from the operator’s approved EBT programme shall not exercise the privileges of that type rating. Appendix 10 Under the existing Part-FCL Appendix 9, proficiency check has 2 components: 1. the technical assessment in the FSTD or aircraft; and 2. the administrative action This is based on a single event taking place. Unlike that, the EBT philosophy dictates that a candidate is continuously assessed throughout the programme. This is achieved through a practical assessment in competencies within each module. Appendix 10 is therefore created to cater for the needs (not only a single event is taking place) of licence revalidation within an EBT programme. The completion of Appendix 10 proficiency check is based on multiple data obtained through the EBT programme regarding an enrolled flight crew member. It is therefore not based on a single event. Instead, Appendix 10 requires a continuous assessment and training of the pilot where each competency is demonstrated at or above the minimum acceptable level of performance. This may take place in a simulated environment. Appendix 10 paragraphs 1 and 5 A practical assessment in competencies within an approved EBT programme is equivalent to a proficiency check. However, to legally complete a proficiency check and revalidate the pilot’s licence, paragraph 5 details the requirements, including several practical assessments in competencies. Appendix 10 paragraphs 4 point (b) Safety promotion material – completion of the operator’s approved EBT programme. EASA has planned SPT.012 to support the implementation of EBT. The following material was developed: SPT.012 — safety promotion task 012 — safety material for EBT — COMPLETION OF THE OPERATOR’S APPROVED EBT PROGRAMME WITHIN THE PERIOD OF VALIDITY (SEE FCL.1030 (b)(3)(ii) AND APPENDIX 10 PARAGRAPH 4(b). APPLICANTS USING APPENDIX 10 SHALL, WITHIN THE PERIOD OF VALIDITY, COMPLETE THE OPERATOR’S APPROVED EBT PROGRAMME (a) The applicant shall complete the operator’s approved EBT programme applicable to the period of validity. Normally, the rating validity is 1 year; therefore, it refers to the modules and training planned for that period of time. (b) When the applicant is enrolled part-way through the period of validity of the rating (e.g. when pilots join a new airline, or they change aircraft types), the applicant is only required to complete the elements of the operator’s approved EBT programme for the remaining period of validity. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 212 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail To ‘complete the operator’s approved EBT programme’ means to complete the EBT modules and any other additional training (ground, FSTD, airplane) or evaluation in the programme (e.g. line evaluation of competence, etc.). However, only the modules will be considered for the purpose of the PRACTICAL ASSESSMENT IN COMPETENCIES to revalidate the licence in accordance with Appendix 10. Appendix 10 paragraph 5 point (c)(1) — Delegation of signature It should be noted that the intent of the RMG and EASA for the delegation of signature proposed in this NPA, is that the responsibility remains with the nominated person for crew training and it is not transferred to the person actually signing the licence. EASA may provide further guidance on the procedure to delegate the signature if found necessary during the consultation of the NPA. Readers are invited to provide comments in this regard. AMC1 to Appendix 10 — Proficiency check type ratings, and proficiency check for IRs when combined with type rating — Practical assessment in competencies APPLICATION AND REPORT FORM Minimum information provided in the form for Appendix 10. Applicant’s last name(s): Applicant’s first name(s): Signature of applicant: Valid medical _____yes/no Type of licence held: Licence number: Type rating: State of licence issue: FSTD (aircraft type): Session 1……..Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session 2……..Name of the instructor:____________________________________________, EBT module 1 Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session X…...Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Completion ___________________________________________date / signature of the module: (nominated person for crew training) Session 1……..Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session 2……..Name of the instructor:____________________________________________, EBT module 2 Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session X…...Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Completion ___________________________________________date / signature of the module: (nominated person for crew training) (…) TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 213 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Session X…..Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session Y……..Name of the instructor:____________________________________________, EBT module X Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Session Z…...Name of the instructor:____________________________________________, Type and number of licence:___________________________________________________ Location, date and time: ____________________ FSTD ID code:______________________ Completion ____________________________________________date / signature of the module: (nominated person for crew training) Completion of the operator’s approved EBT __________________________________date / signature programme from____(date) to ____(date) (nominated person for crew training) Signature of examiner ______________________ Licence endorsed by______________________ Name(s) in capital letters: Examiner certificate number: Date: Type and number of licence: Delegation of signature for licence endorsement: Name: Signature Position in the operator: Date: GM1 to Appendix 10 — Proficiency check type ratings, and proficiency check for IRs when combined with type rating — Practical assessment in competencies REVALIDATION OF LICENCES — ADMINISTRATIVE PROCEDURES For the purpose of revalidation, the Examiner Differences Document applies to the nominated person for crew training or the deputy(ies). GM2 to Appendix 10 — Proficiency check type ratings, and proficiency check for IRs when combined with type rating — Practical assessment in competencies PRACTICAL ASSESSMENT IN COMPETENCIES — PROFICIENCY CHECK Practical assessment (or practical assessment in competencies): is the primary method for assessing performance and should serve to verify the integrated performance of competencies. It takes place in either a simulated or an operational environment. The practical assessment in competencies is equivalent to a proficiency check and is performed under the instructor privilege in the context of proficiency check in accordance with Appendix 10 to Part-FCL. More information can be found in ICAO Doc 9868 ‘PANS-TRG’. The demonstration of skills to revalidate or renew referred to in the definition of proficiency check in FCL.010 is equivalent to the several practical assessments in competencies conducted in the EBT programme and the final review of the examiner. In fact, one single practical assessment in competencies demonstrates the necessary skills performed in legacy training; however, EBT goes one step further — to revalidate or renew, the pilot performs at least two demonstrations of skills/practical assessments in competencies, corresponding to at least two EBT modules. GM2 to Appendix 10 The GM transposed a definition from Part-ORO into Part-FCL and explains how EBT provides a demonstration of skills equivalent to the traditional proficiency check. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 214 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail The definition of proficiency check is already provided in FCL.010; therefore, it is not included in this GM. “‘Proficiency check’ means the demonstration of skill to revalidate or renew ratings, and including such oral examination as may be required.” In legacy training, such demonstration is performed in a single event (following Appendix 9). Although a practical assessment in competencies is equivalent to a proficiency check and demonstrates the necessary skills to revalidate or renew ratings, EBT goes one step further and this demonstration is performed at least twice a year in each of the EBT modules, to complete the revalidation process. The demonstration of equivalency between Appendix 9 and the EBT module is performed at least once every 3 years as required under the several provisions (IR + AMC + GM) of ‘verification of the accuracy of the grading system’. To conclude this explanatory note, the definition of ‘competency’ in Annex I to the Air OPS Regulation is provided below where the term ‘skills’ is included. ‘competency’ means a dimension of human performance that is used to reliably predict successful performance on the job. A competency is manifested and observed through behaviours that mobilise the relevant knowledge, skills and attitudes to carry out activities or tasks under specified conditions; Rationale behind the equivalence between OPC, LPC and the EBT programme The EBT programme is aligned with the existing approach to OPC contained in ORO.FC.130, ORO.FC.230 and AMC1 ORO.FC.230 point (b): Authorities EASA AMC2 Doc 9995 OPS FCL Remarks comments ORO.FC.230 (a) 1.4 Use of covered by LOE covered by Part-FCL Appendix 9 item checklist prior and SBT under LOE and SBT 1.4 may be assessed as (M) to starting compliance under crew actions during a engines, compliance single preflight cockpit frequency A starting preparation. procedures, radio and frequency A navigation the expected added value (…). of EBT is to develop and enhance the competency application of procedure versus isolated task application TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 215 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail 1.6 Before take- covered by LOE covered by Part-FCL Appendix 9 item off checks and SBT under LOE and SBT 1.6 may be assessed as (M) compliance under crew actions during a compliance single before take-off frequency A procedure. frequency A The expected added value of EBT is to develop and enhance the competency application of procedure versus isolated task application B 2.5.2 Take-off with covered by the covered by The failure should be engine failure manoeuvres the inserted between V1 and (M) between V1 training phase manoeuvres V2 to create the need for and V2 (take- training phase asymmetric handling. It is failure of critical off safety possible to include engine between failure of speed) additional failures in order V1 & V2 critical engine to comply with 3.6.1, between V1 & frequency B which should be added V2 after item 2.5.2. two different During the manoeuvres frequencies validation phase, this item are requested should commence from frequency A the initiation of the failure for initial until: control of the establishment of the final aircraft configuration or frequency B completion of the until clean abnormal checklist if an configuration. item from 3.6.1 or 3.6.3 is combined. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 216 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail A 2.6 Rejected take- covered by the covered by The rejected take-off is off at a manoeuvres the considered as a crew item (M) reasonable training phase manoeuvres and may be combined speed before training phase with the rejected take-off reaching V1. for operators (LVOs) rejected take off In the manoeuvres rejected take frequency A validation phase, this item off should commence from frequency A the initiation of the failure until: full stop and completion of the abnormal checklist initial actions; or full stop and completion of abnormal checklist where items 3.6.1, 3.6.7 or 3.6.8 are combined. 3.4.0 Normal and LOE and SBT An exercise may validate abnormal several Part-FCL items to aircraft idem operations of malfunctions In order to facilitate the 3.4.14 systems. provision of simple and (M) Minimum of 3 realistic scenarios in for the crew example accordance with Doc 9995 scenario: Chapters 3.8 and 7.4, the ‘at least one evaluation phase is not malfunction for intended to be a each comprehensive characteristic assessment of all Part-FCL, should be Appendix 9. included an Pre-existing technical every 12-month deviations and associated period’ operational instructions should not be taken into account as 3.4.0 to 3.4.14 items. 3.6.1 Abnormal and proposal to add emergency in fire and smoke to procedures. management 3.6.9 Minimum of 3 No evacuation is for the crew clearly stated TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 217 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail (M) when it is in FCL 3.9.1* Adherence to no reference in The crew would be departure and table of assessed when required to (M) arrival routes assessment and follow a clearance, or and ATC training topics comply with a SID or STAR. instructions. C 3.9.3.4 Manually, manoeuvres with one training phase * (M) engine engine out simulated approach & go inoperative; around engine failure has to be simulated frequency A during final approach before passing 1 000 ft above aerodrome level until touch down or through the complete missed approach procedure. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 218 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail D 3.9.4 2D operations manoeuvres no reference in This item should be down to training phase Doc 9995 but completed under * (M) MDH/A. equivalency of conditions described in approaches the relevant operations TYPE A 2D applies, (refer manual. approach to 3.8.4) RNAV/GNSS approaches validate OPS – (D) item and Part-FCL 3.9.4 item. During the manoeuvres validation phase, this item should commence when intercepting the final approach and end when reaching the prescribed DA/H. E 4.3* Manual go- manoeuvres manoeuvres During the manoeuvres around with training phase training phase validation phase, this item (M) the critical may commence engine approaching DA and end simulated engine out engine out once the aircraft is inoperative approach & go approach & established in a clean or after an around go around defined normal instrument frequency B frequency A manoeuvring approach on configuration. reaching DH MDH or MAPt. F 5.5 Landing with manoeuvres manoeuvres In the manoeuvres critical engine training phase training phase validation phase, this item (M) simulated may start passing the final Engine out Engine out inoperative. approach fix (FAF) and end landing landing when the aircraft reaches frequency B frequency A normal taxi speed. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 219 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Annex VI (Part-ARA) to Regulation (EU) No 1178/2011 ARA.GEN.315 Procedure for issue, revalidation, renewal or change of licences, rating or certificates — persons AMC2 ARA.GEN.315(a) Procedure for issue, revalidation, renewal or change of licences, rating or certificates — persons VERIFICATION OF COMPLIANCE OF THE EBT PROGRAMME In order to verify that the applicant meets the requirements for revalidation or renewal of ratings within an approved EBT programme, the competent authority should in addition to the requirements in AMC1 ARA.GEN.315(a) verify that: (a) the nominated person for crew training (or the deputy(ies) is a current examiner in the type rating filled in in Appendix 10; (b) when the nominated person for crew training (or the deputy(ies)) delegates their signature to endorse the licence of the applicant: (1) the delegation of signature should follow the operator’s approved procedure for such purpose; and (2) the person signing the licence should be nominated and indicated in Appendix 10; (c) the nominated person for crew training of the operator in which the applicant is enrolled ensures that the applicant has completed the EBT programme; (d) the nominated person for crew training of the operator in which the applicant is enrolled ensures that instructors that conduct the training to the applicant are standardised; (e) the operator performs a verification of the grading system once every three years; and (f) the nominated person for crew training ensures the integrity of the pilot training data. AMC2 ARA.GEN.315(a) The EBT system integrates into a single concept the provisions for revalidation of licence in Part-FCL and those for recurrent training and checking in Part-ORO. Most of the requirements for the oversight in this NPA are proposed in Part-ARO and then refer back to Part-FCL. See below. AMC1 ARO.OPS.226(d) Approval and oversight of evidence-based training programmes OVERSIGHT PLAN — PERIODIC ASSESSMENT TO VERIFY COMPLIANCE OF THE APPROVED EBT PROGRAMME (a) Audits and inspections, on a scale and frequency appropriate to the operation, should cover at least (…) (9) administration of programme enrolment and compliance with the requirements of Annex I (Part-FCL) for licence revalidation and renewal; AMC2 ARA.GEN.315(a) further explains that the licensing competent authority should verify that the relevant requirements of Part-FCL are met. The intent of the RMG was that the verification could be completed by looking at the records. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 220 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail AMC2 ARA.GEN.315(a) point (c) The intent of this provision is that the competent authority verifies the training records to ensure that the applicant has completed the approved EBT programme. Appendix 10 covers this item: ‘Completion of the operator’s approved EBT programme _______signature/date (nominated person for crew training)’ AMC2 ARA.GEN.315(a) point (d) This provision refers to AMC1 ORO.FC.145(a)(3) and AMC2 ORO.FC.145(a)(3). Oversight of this provision falls under the jurisdiction of the competent authority issuing EBT approval; however, the licensing authority may at its own discretion inspect the training records of the instructors, pertaining to revalidation of licences. AMC1.ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — INITIAL STANDARDISATION […] (c) Before delivering the operator’s approved EBT programme, the instructor should successfully complete an EBT instructor initial standardisation composed of: (1) EBT instructor training; and (2) EBT assessment of competence. […] AMC2.ORO.FC.145(a)(3) Provision of training EBT INSTRUCTOR — RECURRENT STANDARDISATION (a) The EBT instructor should receive an annual recurrent standardisation. It includes: (1) refresher EBT training; and (2) concordance training. (b) The EBT instructor should conduct a complete EBT module within the last 12 months preceding the expiry date. (c) If the requirement of point (b) has not been fulfilled, before conducting training within an EBT programme, the EBT instructor should undergo an EBT assessment of competence. (d) The EBT instructor should undergo an EBT assessment of competence every 3 years. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 221 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail ARA.FCL.200 Procedure for issue, revalidation or renewal of a licence, rating or certificate (e) Issue of licences and ratings. The competent authority shall issue a pilot licence and associated ratings, using the form as established in Appendix I to this Part. (f) Issue of instructor and examiner certificates. The competent authority shall issue an instructor or examiner certificate as: (1) an endorsement of the relevant privileges in the pilot licence as established in Appendix I to this Part; or (2) a separate document, in a form and manner specified by the competent authority. (g) Endorsement of licence by examiners. (1) bBefore specifically authorising certain examiners to revalidate or renew ratings or certificates, the competent authority shall develop appropriate procedures. (2) These appropriate procedures may include endorsement of licence under an approved EBT programme in accordance with Appendix 10. In such case, signature delegation to endorsement of licence may be allowed. (h) Endorsement of licence by instructors. Before specifically authorising certain instructors to revalidate a single-engine piston or TMG class rating, the competent authority shall develop appropriate procedures. ARA.FCL.205 Monitoring of examiners AMC2 ARA.FCL.205 Monitoring of examiners EBT PROGRAMME (a) Where a competent authority has granted examiners certified by other competent authorities the right to exercise their privilege within an EBT programme, the monitoring of examiners includes the nominated person for crew training and the deputy(ies). (b) At the discretion of the competent authority, this may also include an inspection of training delivery by the EBT instructor within an approved EBT programme. GM1 to AMC2 ARA.FCL.205(b) Monitoring of examiners EBT PROGRAMME — INSPECTION OF TRAINING DELIVERY Where the inspection of training delivery is to be conducted, the inspector of the competent authority should ideally meet the requirements laid down in AMC1 ARO.OPS.226 (a). This inspection may be combined with the oversight required in ARO.OPS.226. AMC2 ARA.FCL.205 The purpose of this AMC is to clarify how a competent authority may conduct oversight of examiners where those examiners are revalidating licences as part of an operator's approved EBT programme. This is because the delivery of an EBT module is performed by instructors on behalf of the nominated person for crew training who maintains ultimate responsibility for the programme and who is an examiner. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 222 of 223 An agency of the European Union European Aviation Safety Agency NPA 2018-07(B) 3. Proposed amendments and rationale in detail Member States provide a briefing within the Examiners Differences Document (https://www.easa.europa.eu/sites/default/files/dfu/Examiner%20Differences%20Document_version_09_201 7_ORA_Final_0.pdf for use by examiners with a Part-FCL examiner certificate conducting a proficiency check licence holder whose licence was issued by a competent authority (CA) other than their own. As an assessment in competencies is equivalent to a proficiency check (see Appendix 10), then the procedures for the proficiency check for the purpose of the Examiner Differences Document should be followed. GM1 to AMC2 ARA.FCL.205(b) The vehicle to allow the licensing competent authority to inspect the training also had to be provided to be in line with existing oversight responsibilities. The principle described in the GM1 to AMC2, ‘Where this inspection of training delivery is to be conducted, the inspector of the competent authority should ideally meet the requirements’, is transposed and adapted from the existing AMC1 ARA.FCL.205, to ensure that any oversight is preferably done by appropriately trained and qualified inspectors. TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 223 of 223 An agency of the European Union
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