CS FCD.415 Difference levels -- Training, checking, and currency

• ED Decision 2021/012/R found in: CS-FCD Issue 2 - Flight Crew Data (Jun 2023)

CS FCD.415 Difference levels — Training, checking, and currency ED Decision 2021/012/R (a) Difference levels are summarised in the table below regarding training, checking, and currency: <table border="1" cellpadding="0" cellspacing="0" width="567"><tr><td valign="top" width="85"><p><b>DIFFERENCE LEVEL</b></p></td><td valign="top" width="161"><p><b>TRAINING</b></p></td><td valign="top" width="161"><p><b>CHECKING</b></p></td><td valign="top" width="161"><p><b>CURRENCY</b></p></td></tr><tr><td valign="top" width="85"><p><b>A</b></p></td><td valign="top" width="161"><p>— Self-instruction</p></td><td valign="top" width="161"><p>Not applicable or integrated with the next proficiency check</p></td><td valign="top" width="161"><p>Not applicable</p></td></tr><tr><td valign="top" width="85"><p><b>B</b></p></td><td valign="top" width="161"><p>— Aided instruction</p></td><td valign="top" width="161"><p>Task or system check</p></td><td valign="top" width="161"><p>Self-review</p></td></tr><tr><td valign="top" width="85"><p><b>C</b></p></td><td valign="top" width="161"><p>— System devices </p></td><td valign="top" width="161"><p>Partial proficiency check that uses a qualified device</p></td><td valign="top" width="161"><p>Designated systems and procedures that use system devices or aircraft</p></td></tr><tr><td valign="top" width="85"><p><b>D</b></p></td><td valign="top" width="161"><p>FSTDs1 or aircraft to execute specific manoeuvres</p></td><td valign="top" width="161"><p>Partial proficiency check that uses a qualified device1</p></td><td valign="top" width="161"><p>Designated manoeuvre(s) that use FSTDs1 or aircraft</p></td></tr><tr><td valign="top" width="85"><p><b>E</b></p></td><td valign="top" width="161"><p>FSTDs2 or aircraft</p></td><td valign="top" width="161"><p>Proficiency check using FSTDs3 or aircraft</p></td></tr></table> Footnote 1: (1) aeroplanes: (i) FFS level D, or (ii) FSTD with an FCS at least equal to FTD level B as defined in CS-FSTD(A) Issue 3 [[3]](#_ftn3). (2) helicopters: (i) FTD Levels 2 and 3, or (ii) FFS. Footnote 2: (1) aeroplanes: FSTDs that meet the training objectives and requirements provided for in the Aircrew Regulation. (2) helicopters: FSTDs that have dual qualification: FFS Level B and FTD Level 3, or FFS Level C or D. Footnote 3: (1) aeroplanes: (i) FFS level D, or (ii) FSTDs that have at least fidelity level S (Specific) for the following features: (A) flight deck layout and structure, (B) flight model, (C) ground reaction and handling qualities, and (D) flight controls and forces. (2) helicopters: (i) FTD Levels 2 and 3, or (ii) FFS. (b) Difference level — Training The training differences levels specified represent the minimum requirements. Devices associated with a higher difference level may be used to satisfy a training differences requirement. (1) Level A training Level A differences training is applicable to aircraft with differences that can adequately be addressed through self-instruction. Level A training represents a knowledge requirement such that once appropriate information is provided, understanding and compliance can be assumed to be demonstrated. Training needs not covered by level A training may require level B training, or higher, depending on the outcome of the evaluations in the aircraft evaluation process described in [CS FCD.420](#_DxCrossRefBm1036031405). (2) Level B training Level B differences training is applicable to aircraft with system or procedure differences that can adequately be addressed through aided instruction. At level B aided instruction is appropriate to ensure pilot understanding, emphasise issues, provide a standardised method of presentation of material, or to aid retention of material following training. (3) Level C training Level C differences training can only be accomplished through the use of devices capable of systems training. Level C difference training is applicable when cockpit design differences exist, and affect skills or abilities, as well as knowledge. Training objectives focus on mastering individual systems, procedures, or tasks, as opposed to performing highly integrated flight operations and manoeuvres in ‘real time’. Level C may also require self-instruction or aided instruction of a pilot, but cannot be adequately addressed by a knowledge requirement alone. Training devices are required to supplement instruction to ensure attainment or retention of pilot skills and abilities to accomplish the more complex tasks, usually related to operation of particular aircraft systems. The minimum acceptable training media for level C is interactive computer-based training, cockpit systems simulators, cockpit procedure trainers, part task trainers or similar devices. (4) Level D training Level D difference training can only be accomplished with devices capable of performing flight manoeuvres and addressing the full task differences affecting knowledge, skills, and/or abilities. FSTDs capable of flight manoeuvres replicate the aircraft in a dynamic ‘real time’ simulation flight environment, enabling the integration of knowledge, skills, and abilities by combining operationally oriented tasks and realistic task workloads for each relevant phase of flight. At level D, the knowledge and skills to complete necessary normal, non-normal, and emergency procedures are fully addressed for each type or variant. Level D difference training requires mastery of interrelated skills that cannot be adequately addressed by separate acquisition of a series of knowledge areas or skills that are interrelated. However, the differences are not so significant that a full type rating training course is required. Training for level D differences requires an FSTD that has accurate, high fidelity integration of systems and controls and realistic instrument indications. Level D training may also require manoeuvring visual cues, dynamics, control loading or specific environmental conditions. Weather phenomena such as low visibility operations or wind shear may or may not be incorporated. The applicant needs to propose the features that define the FSTD capability that is required to meet the training objectives among those identified in the table of paragraph (a). Where simplified or generic characteristics of an aircraft type are used in devices to satisfy level D difference training, significant negative training cannot occur as a result of the simplification. The appropriate devices, as described in [CS FCD.415(a)](https://dxweb.easa.europa.eu/dx4/Topics/csFCDtopic_11.docx), which satisfy level D difference training, are those which incorporate relevant elements of aircraft flight manoeuvring, performance, and handling qualities (5) Level E training Level E difference training is applicable to a candidate aircraft having such significant differences that a full type rating training course or a type rating training course with credit for previous experience on similar aircraft types is required to meet the training objectives. The training requires a ‘high fidelity’ environment to attain or maintain knowledge, skills, and/or abilities that can only be satisfied by the use of FSTDs or the aircraft itself, as mentioned in [CS FCD.415(a)](https://dxweb.easa.europa.eu/dx4/Topics/csFCDtopic_11.docx). Level E training, if done in an aircraft, should be modified for safety reasons for manoeuvres with a high degree of risk. When level E difference training is assigned, as well as for any initial type rating training, the experience requirements and prerequisites for the issuance of the relevant rating may be approved based on the requirements of points FCL.720.A and FCL.720.H of Part FCL of the Aircrew Regulation. Recurrent training credit for operations on more than one type may be approved based on the requirements of Part-ORO of the Air OPS Regulation. (c) Difference level — Checking Differences checking addresses any pertinent pilot testing or checking. Initial and recurrent checking levels are the same unless otherwise specified. It may be possible to satisfactorily accomplish recurrent checking objectives in devices not meeting initial checking requirements. In such instances the applicant may propose for revalidation checks the use of certain devices not meeting the initial check requirements. (1) Level A checking Level A differences checking indicates that no check related to differences is required at the time of differences training. However, a pilot is responsible for knowledge of each variant flown. (2) Level B checking Level B differences checking indicates that a ‘task’ or ‘systems’ check is required following initial and recurring training. (3) Level C checking Level C difference checking requires a partial check using a suitable FSTD. A partial check is conducted relative to particular manoeuvres or systems and equipment. (4) Level D checking Level D difference checking indicates that a partial proficiency check is required following both initial and recurrent training. In conducting the partial proficiency check, manoeuvres common to each variant may be credited and need not be repeated. The partial proficiency check covers the specified particular manoeuvres, systems, or equipment. Level D checking is performed using scenarios that represent a ‘real time’ flight environment, and uses FSTDs capable of level D or higher-level training. (5) Level E checking Level E difference checking requires that a full skill test be conducted in FSTDs or in an aircraft, as mentioned in [CS FCD.415(a)](https://dxweb.easa.europa.eu/dx4/Topics/csFCDtopic_11.docx), following both initial and recurrent training. If appropriate, alternating recurrent checking between the relevant aircraft types is possible, and credit may be defined for procedures or manoeuvres based on commonality. The assignment of level E checking requirements alone, or in conjunction with level E currency, does not necessarily result in the assignment of a separate type rating. (d) Difference level — Currency Currency differences address any currency and recurrent training difference levels. Initial and recurrent currency levels are the same, unless otherwise specified. (1) Level A currency Level A currency is common to each aircraft and does not require separate tracking. Maintenance of currency in any aircraft suffices for any other variant within the same type rating. (2) Level B currency Level B currency is ‘knowledge-related’ currency, typically achieved through self-review of material by individual pilots. (3) Level C currency (i) Level C currency is applicable to one or more designated systems, equipment, or procedures, and relates to both skill and knowledge requirements. When level C currency applies, any pertinent lower-level currency is also to be addressed. (ii) Re-establishing level C currency When currency is lost, it may be re-established by completing the required items using a device with capabilities equal to or greater than those specified for level C training and checking. (4) Level D currency (i) Level D currency is related to designated manoeuvres and addresses the knowledge and skills that are required for performing aircraft control tasks in real time with integrated use of the associated systems, equipment, and procedures. Level D currency may also address certain differences in flight characteristics, including the performance of any required manoeuvres and the related normal, non-normal, and emergency procedures. When level D is necessary, any pertinent lower-level currency is also to be addressed. (ii) Re-establishing level D currency When currency is lost, currency may be re-established by completing pertinent manoeuvres using a device equal to or higher than that specified for level D differences training and checking. (5) Level E currency (iii) Level E currency requires that recent experience requirements of Part-FCL and operational requirements be complied with in each aircraft separately. Level E currency may also specify other system, procedure, or manoeuvre currency item(s) necessary for safe operations, and requires procedures or manoeuvres to be accomplished in FSTDs or in an aircraft as mentioned in [CS FCD.415(a)](https://dxweb.easa.europa.eu/dx4/Topics/csFCDtopic_11.docx). Provisions are applied in a way which addresses the required system or manoeuvre experience. When level E is assigned between aircraft of common characteristics, credit may be permitted. Assignment of level E currency requirements does not automatically lead to a determination on same or separate type rating. Level E currency is tracked by a means that is acceptable to the competent authority. When CTLC is permitted, any credit or constraints applicable to using FSTDs as mentioned in [CS FCD.415(a)](https://dxweb.easa.europa.eu/dx4/Topics/csFCDtopic_11.docx) are also to be determined. (ii) Re-establishing level E currency When currency is lost, currency may be re-established by completing pertinent manoeuvres using a device specified for level E differences training and checking. (e) Competency regarding non-normal and emergency procedures — Currency Competency for non-normal and emergency manoeuvres or procedures is generally addressed by checking requirements. Particular non-normal and emergency manoeuvres or procedures may not be considered mandatory for checking or training. In this situation it may be necessary to periodically practice or demonstrate those manoeuvres or procedures specifying currency requirements for those manoeuvres or procedures. [Issue No: FCD/2] --- [[3]](#_ftnref3) The related NPA is under preparation.