Subject: Alternate Pilot Proficiency Check – Phased PPC
Issuing Office: | Civil Aviation, Standards |
---|---|
Document No.: | AC 700-062 |
File Classification No.: | Z 5000-34 |
Issue No.: | 01 |
RDIMS No.: | 17503755-V15 |
Effective Date: | 2021-12-10 |
Table of contents
- 1.0 Introduction
- 2.0 References and requirements
- 3.0 Background
- 4.0 General
- 5.0 Phase one (PPC)
- 6.0 Phase two (recurrent flight training)
- 7.0 Phase three (partial PPC)
- 8.0 Flight test report (FTR)
- 9.0 TCCA oversight
- 10.0 Information management
- 11.0 Document history
- 12.0 Contact us
- Appendix A — Enhanced ACP / Training Pilot Experience Requirements
- Appendix B — Frequently asked questions
1.0 Introduction
- (1) This Advisory Circular (AC) is provided for information and guidance purposes. It describes an example of an acceptable means, but not the only means, of demonstrating compliance with regulations and standards. This AC on its own does not change, create, amend or permit deviations from regulatory requirements, nor does it establish minimum standards.
1.1 Purpose
- (1) The purpose of this document is to describe an alternate means of conducting a recurrent Pilot Proficiency Check (PPC) under subparts 702, 703 and 704 of the Canadian Aviation Regulations (CARs).
1.2 Applicability
- (1) This document applies to all Transport Canada Civil Aviation (TCCA) employees who are involved in the oversight of air operator pilot training and checking and to individuals and organizations when they are exercising privileges granted to them under an External Ministerial Delegation of Authority. This information is also available to the aviation industry for information purposes.
1.3 Description of changes
- (1) Not applicable.
2.0 References and requirements
2.1 Reference documents
- (1) It is intended that the following reference materials be used in conjunction with this document:
- (a) Industry Communique, dated February 17, 2020 — Modernizing and Enhancing Pilot Training Regulations – RDIMS 16277656 (available through any regional TCCA office)
- (b) Industry Communique, dated September 1, 2020 — Update: Modernizing and Enhancing Pilot Training Regulations – RDIMS 16718100 (available through any regional TCCA office)
- (c) Risk Assessment – Phased PPC – RDIMS 17550081 (available through any regional TCCA office)
- (d) Transport Canada Publication, TP 6533 — Approved Check Pilot (ACP) Manual
- (e) Transport Canada Publication, TP 14727 — Pilot Proficiency Check and Aircraft Type Rating Flight Test Guide (Aeroplane)
- (f) Transport Canada Publication, TP 14728 — Pilot Proficiency Check and Aircraft Type Rating Flight Test Guide (Helicopter)
- (g) International Civil Aviation Organization (ICAO) Manual of Evidence-based Training (DOC 9995)
- (h) TCCA Advisory Circular (AC) 700-042 – Crew Resource Management (CRM)
2.2 Cancelled documents
- (1) Not applicable.
- (2) By default, it is understood that the publication of a new issue of a document automatically renders any earlier issues of the same document null and void.
2.3 Definitions and abbreviations
- (1) The following definitions are used in this document:
- (a) Advanced Qualification Program (AQP) – a voluntary program and alternative method of training, evaluating and qualifying flight crewmembers, instructors and Evaluators, which uses a systematic methodology for developing proficiency-based training and evaluation programs in lieu of traditional training programs.
- (b) Air Operator – a holder of a certificate under Part VII of the Canadian Aviation Regulations (CARs).
- (c) Approved Check Pilot (ACP) – a person holding an official authorization to conduct Pilot Proficiency Checks (PPCs) on behalf of the Minister of Transport pursuant to Part 1, Section 4.3(1) of the Aeronautics Act. In this AC, the ACP designation includes any Civil Aviation Safety Inspector (CASI) and any examiner in a foreign regulatory jurisdiction who holds an authorization to conduct PPCs on behalf of the Minister of Transport.
- (d) ACP/Training Center Evaluator (TCE) – an ACP who gains their qualification on the basis of their FAA (Part 142) training center evaluator qualification and experience.
- (e) Civil Aviation Safety Inspector (CASI) – a TCCA inspector who is trained and authorized to conduct flight checks in accordance with TCCA Staff Instruction 700-002.
- (f) Check Pilot – any ACP or CASI.
- (g) Evidence-based training (EBT) – a training and assessment program used by some global airline operators to conduct recurrent pilot training, which is based on operational data and develops and assesses the overall capability of a trainee across a range of core competencies rather than by measuring performance in individual events or manoeuvres.
- (h) Flight Check - a PPC conducted in a simulator or an aircraft.
- (i) Initial Pilot Proficiency Check (PPC) – a PPC conducted for the purpose of qualifying a pilot on an aircraft type when the pilot has never been qualified on that type, or is required to complete an initial type training course to regain qualifications after PPC expiry.
- (j) Pilot Proficiency Check (PPC) – a flight check conducted by an approved check pilot (ACP) or Civil Aviation Safety Inspector (CASI) in accordance with the appropriate PPC Schedule specified in Part VII CARs Standards.
- (k) Recurrent Pilot Proficiency Check (PPC) – a PPC conducted for the purpose of renewing qualification on an aircraft type when the pilot is already qualified on that type, or does not require a complete initial aircraft type training course to regain qualifications after PPC expiry.
- (l) Special Authorization/Specific Approval (SA) – an authorization issued by the Minister under subpart 604 or Part VII of the CARs that permit the carrying out of an activity in respect of which the Minister has established requirements. SA’s are included as part of the Operations Specifications. An authority granted to an air operator to use Lower than Standard Take-off Weather Minima is an example of an SA.
- (m) Training Pilot – a pilot who satisfies the qualifications and requirements stated in the CASS for a Training Pilot, or the requirements stated for a person who conducts flight crew training on a contract basis.
- (n) Upgrade Pilot Proficiency Check – a PPC conducted on a second-in-command (SIC) in order to qualify as a pilot-in-command (PIC).
- (2) The following abbreviations are used in this document:
- (a) ACP: Approved Check Pilot
- (b) CARs: Canadian Aviation Regulations
- (c) CASI: Civil Aviation Safety Inspector
- (d) CASS: Commercial Air Services Standard
- (e) COM: Company Operations Manual
- (f) FTG: Flight Test Guide
- (g) FTR: Flight Test Report
- (h) POI: Principal Operations Inspector
- (i) PPC: Pilot Proficiency Check
- (j) SA: Special Authorization / Specific Approval
- (k) SOP: Standard Operating Procedure
- (l) TCCA: Transport Canada Civil Aviation
- (m) TCE: Training Center Evaluator
3.0 Background
- (1) TCCA established a joint working group (WG) with industry in late 2020 to develop solutions to improve the relevance and effectiveness of pilot training and checking in CARs subparts 702, 703 and 704. Detailed information on this initiative is provided in references (a) and (b) listed in section 2.1. See Appendix B of this AC for details on the status of potential changes to training and checking in subpart 705.
- (2) One of the primary WG objectives was to develop checking practices that decreased the emphasis on checking to support an increased emphasis on training. In response, the WG developed an alternate means of conducting a PPC, labeled as a Phased PPC. The Phased PPC integrates training and checking in a manner that promotes learning over checking. It is a three-phased model that mirrors the assess – train – reassess concept embodied in advanced training programs such as Evidence-Based Training (EBT) and the Advanced Qualification Program (AQP).
4.0 General
- (1) The Phased PPC differs from traditional checking by providing a candidate with the opportunity to improve sub-standard performance before declaring the PPC unsuccessful. It is compliant with the CARs and Commercial Air Services Standard (CASS) and does not require a regulatory exemption. It is assessed and documented in the same manner as the existing PPC, except as noted in this AC.
- (2) A Phased PPC has three components, divided into three phases. The first phase is the PPC, which closely follows the existing PPC structure and has two possible outcomes – a successful PPC and an in-progress PPC. The PPC cannot be graded as unsuccessful during phase one.
- (3) The PPC is followed by recurrent flight training in phase two, which is a mandatory phase regardless of the outcome of phase one. Training is adjusted to emphasize training in areas performed below standard during the PPC. Training in areas of demonstrated strength can be reduced or eliminated.
- (4) Recurrent training is followed by a partial PPC in phase three, which is only applicable for a candidate who did not meet the successful PPC standard in phase one, and/or who requires the initial issuance of a Special Authorization/Specific Approval (SA).
- (5) All three phases can be conducted by the same person, if that person is a Training Pilot and Approved Check Pilot (ACP) and meets the Enhanced ACP / Training Pilot Experience Requirements stated in Appendix A of this AC. Conversely, an operator may choose to use different persons to conduct each phase, ensuring that proper coordination and communication occurs between the persons involved.
- (6) The Phased PPC is an optional checking model that does not replace or change the existing PPC model that is defined in the ACP Manual – TP 6533. An operator has the option of using the Phased PPC and/or the existing PPC to conduct a recurrent PPC and can freely use one or both models. An operator who incorporates the Phased PPC model in their training and checking program must inform their POI accordingly and satisfy the documentation requirements stated in section 6.2(3) of this AC.
- (7) The Phased PPC cannot be used for an Initial or Upgrade PPC or for the initial issuance of a rating or license.
- (8) This AC defines the structure and conduct of the Phased PPC and addresses all relevant details. It is the primary reference document for the conduct of the Phased PPC and must be used in conjunction with the ACP Manual and applicable Flight Test Guide (FTG) in the manner described in this AC. The questions and answers section in Appendix B provides supplemental information to support this program change.
4.1 Permitted uses
- (1) The Phased PPC can be used by any air operator who complies with this AC to conduct recurrent checking and flight training in CARs subparts 702, 703 or 704.
- (2) An air operator who conducts recurrent flight training in segments throughout the year can use the Phased PPC to check and train if recurrent training in phase two consists of 25% or more of the total hours allocated to the operator’s flight training program.
4.2 Excluded uses
- (1) The Phased PPC cannot be used for any of the following purposes:
- (a) Initial or Upgrade PPC or the new issuance of a rating or license;
- (b) A PPC that includes an initial qualification check on an area navigation (RNAV) system;
- (c) To check and train a person whose last valid PPC on-type has been expired for 12 months or more; and
- (d) To check and train a person if their previous PPC on-type, conducted under any PPC model, was unsuccessful and has not been followed by a successful PPC.
4.3 Persons assigned to check and train
- (1) One or more persons can be used to check and train during the Phased PPC, based on the following conditions:
- (a) Phases one and three (PPC and Partial PPC): Must be conducted by a check pilot who is an ACP or Civil Aviation Safety Inspector (CASI). All check pilots are eligible to use the Phased PPC and require no further training, certification or approval to do so. Phases one and three can be conducted by the same or different check pilot;
- (b) Phase two (Recurrent Flight Training): Must be conducted by a person who satisfies the qualifications and requirements stated in the CASS for a Training Pilot, or the requirements stated for a person who conducts flight crew training on a contract basis; and
- (c) Using one person to check and train: It is permissible to use one person to check and train the same candidate if the person is an ACP and a Training Pilot and is qualified in accordance with the Enhanced ACP / Training Pilot Experience Requirements stated in Appendix A of this AC. This could result in checking and training scenarios where the ACP conducts phases one and two, or conducts phases two and three, or conducts all three phases
- (2) When separate persons are used to conduct the different phases, coordination between these persons is essential to maintain the continuity of checking and training.
- (3) Air operators must maintain a list of persons who have company authorization to conduct training and checking on the same candidate. The list must be documented in company records and include persons who have held this authorization within the previous 24 months. The operator must provide their POI with the list before commencing the Phased PPC program and again whenever the list changes.
5.0 Phase one (PPC)
5.1 General
- (1) The PPC is conducted in accordance with the ACP Manual, except as noted below.
- (2) Technical and non-technical ground training and examinations must be valid before the conduct of phase one.
- (3) Given that the PPC is conducted before recurrent training, a ‘recommendation for a PPC’ is not required.
- (4) The candidate must present the check pilot with valid identification and a current pilot license and medical certificate prior to the PPC. Refer to Establishing Candidate’s Eligibility – PPC in section 6.0 of the ACP Manual for additional details on these items.
- (5) The check pilot must confirm that the exclusions listed in section 4.2 of this AC do not apply to the candidate.
- (6) The PPC in phase one cannot be used for the purpose of crew certification for the initial issuance of a Special Authorization / Specific Approval (SA). The initial issuance of an SA cannot occur until mandatory training for the SA has been completed. Once the required training has been completed during phase two, crew certification for the SA is conducted during a partial PPC in phase three. The foregoing limitation does not apply to the renewal of an SA, for which crew re-certification can occur during phase one.
- (7) In a case where the applicable PPC Schedule and/or Flight Test Guide provides an option to omit a flight test exercise from the PPC if the exercise is completed to a satisfactory level during recurrent training, the applicable exercise can be completed during the phase one PPC or during recurrent training in phase two, as determined by the air operator / check pilot.
5.2 Flight check briefing
- (1) Phase one commences with a Flight Check Briefing, which must include the following elements:
- (a) All briefing items specified in section 6.0 of the ACP Manual under the subject of Flight Check Briefing;
- (b) An explanation of the Phased PPC structure and flow, including the possible outcomes during each phase - (successful or in-progress); and
- (c) The contents of the Ground Assessment - PPC, as defined in section 6.0 of the ACP Manual.
5.3 Optional pre-flight warm-up
- (1) At the discretion of the air operator, it is permissible to provide each candidate with an optional warm-up prior to the PPC. The need or length of a warm-up will likely vary based on the type of flight platform, air operator’s expectations, length of recurrent training and degree of crew proficiency; however, the warm-up cannot extend beyond 30 minutes flying time per candidate to ensure that this activity does not evolve into ‘training to the PPC’.
- (2) Upon completion of the optional warm-up, the aircraft is re-positioned and configured as appropriate to commence the PPC.
5.4 Flight assessment
- (1) The flight assessment is conducted in accordance with the existing guidance in the ACP Manual, with the following exceptions:
- (a) The flight assessment is to be completed in entirety, without repeating any item(s), regardless of the candidate’s performance or the assessed grade of any item; and
- (b) The flight assessment should only be terminated if there is a risk to the safety of flight when administering the PPC in an aircraft, or if other circumstances prevent the completion of the PPC. If this occurs, refer to Incomplete Flight Check Attempt in section 6.0 of the ACP Manual for further guidance. If it is not possible or practical to resume the PPC, it is permissible for the candidate to proceed to recurrent training, followed by a full PPC in phase three.
5.5 Assessment and grading
- (1) Flight test exercises are assessed and graded in accordance with the existing PPC model, as stated in the Principles of Evaluation stated in section 5.0 of the ACP Manual.
- (2) The successful/unsuccessful standard for a Phased PPC is identical to the standard published in section 6.0 of the ACP Manual.
- (3) The PPC is graded as successful after the completion of phase one if the successful standard in the ACP Manual was met and there is no requirement to conduct crew certification for the initial issuance of an SA during phase three.
- (4) The PPC is graded as in-progress if the successful standard in the ACP Manual was not met during phase one and/or there is a requirement to conduct crew certification for the initial issuance of an SA during phase three.
- (5) There is no limit on the number of items that can be assessed with a grade of one or two during phase one.
- (6) Refer to section 8.0 of this AC for guidance on how to complete the Flight Test Report (FTR) (26-0249/26-0279) for a Phased PPC.
5.6 Flight check debriefing
- (1) Upon completion of the PPC in phase one, and before recurrent flight training commences, a debriefing must be conducted that includes the following items:
- (a) A debriefing on any item assessed with a grade of one or two; and
- (b) An explanation of how items will be re-trained during recurrent training in phase two, and re-assessed during the partial PPC re-test in phase three, if applicable.
- (2) After the completion of the debriefing, phase one is considered complete and the candidate proceeds to recurrent training in phase two.
6.0 Phase two (recurrent flight training)
6.1 General
- (1) Recurrent flight training can commence immediately after the completion of phase one and in no case later than the 14th day following the completion of phase one.
- (2) The flight training program and associated training hours must consist of the program documented in the air operator’s Company Operations Manual (COM), with the exception of the adjustments permitted below in section 6.2.
6.2 Training content
- (1) Any item assessed with a grade of three or four during the PPC satisfies flight training requirements specified in the CASS for the item, as applicable. Training on these items can be reduced or eliminated during recurrent flight training in accordance with the rationale provided in paragraph (2) (i) of Appendix B.
- (2) The above flexibility cannot be used to reduce the total hours that an air operator has allocated to recurrent flight training, as specified in the COM. Rather, it creates capacity to increase training in areas of weak performance, develop core competencies, address operational risks, conduct training on line-oriented manoeuvres that may not be part of normal recurrent training, and support the conduct of a partial PPC re-test, if applicable, subject to the limitations in sub-paragraph (6) below.
- (3) To the extent practical, the COM must provide general guidance on how spare capacity referred to in the above paragraph will be used during training. This could include reference to supplementary guidance that will be published by the company on an annual basis or set interval to identify themes and areas of focus that may change from year to year.
- (4) Within the normal flow of training, recurrent flight training must include training on any item assessed with a grade of one or two during the PPC, regardless of whether the PPC was assessed as successful or in-progress. The degree of re-training is at the discretion of the Training Pilot and could vary from an oral discussion to a partial or full repeat of an exercise.
- (5) Training conducted during phase two must be thoroughly and accurately documented in pilot training records. During audits or inspections, TCCA will refer to the Flight Test Report and training records to confirm that the manoeuvres and procedures conducted during phases one and two collectively meet mandatory training requirements specified in the CASS.
- (6) Up to 15% of the total hours allocated to recurrent flight training can be used towards the conduct of a partial PPC re-test. This latitude is intended to facilitate the completion of all three phases during the planned allocation of hours and reduce the need to reserve additional time in an aircraft or simulator, which can be difficult to acquire on short notice. An example of how this is applied is provided in paragraph (2) (d) of Appendix B.
6.3 Recommendation for a partial PPC
- (1) Upon completion of recurrent flight training, a candidate who requires a partial PPC for re-testing and/or crew certification of an SA must be recommended for the partial PPC by the Training Pilot.
7.0 Phase three (partial PPC)
7.1 General
- (1) A partial PPC is only required if there is a need to conduct either or both of the following actions:
- (a) To complete an in-progress PPC for a candidate who did not meet the successful PPC standard during phase one; and/or
- (b) To complete crew certification for the initial issuance of an SA.
- (2) For a two-crew PPC, a candidate who met the successful PPC standard in phase one may be requested to participate in a partial PPC for the other candidate. In such cases, the candidate cannot have their flight test results from phase one changed in any way. It is also permissible to use another qualified person as a ‘seat substitute’ to provide competent support to the candidate undergoing the partial PPC. In either case, refer to PPC Seat Substitutes in Section 6.0 of the ACP Manual for further guidance.
- (3) The partial PPC can occur immediately after the last recurrent training session, which could be the same day or as soon as possible thereafter. It must be completed no later than the 14th day following the completion of recurrent flight training.
- (4) Recurrent non-technical and technical ground training and written examinations must be valid prior to conducting the partial PPC.
7.2 Mandatory test items
- (1) If the partial PPC is conducted for the purposes of completing an in-progress PPC, all items that were assessed with a grade of one or two during phase one must be included in the partial PPC. These are the only items that are re-tested.
7.3 Briefing a partial PPC
- (1) Prior to the partial PPC, the check pilot must confirm that the candidate recalls and understands the contents of the Flight Check Briefing provided during phase one. As a minimum, the following elements must be briefed, as applicable:
- (a) A summary of the flight exercises that will be re-tested and the applicable flight test tolerances;
- (b) A summary of any SA that will be tested and the applicable flight test tolerances;
- (c) An overview of how the check will be conducted, including initial positioning of the aircraft, aircraft status (powered up or down), and required checks / checklists; and
- (d) Duties and expectations of a person who is acting as a crew member in support of the candidate undergoing the re-test.
7.4 Conducting a partial PPC
- (1) The check pilot has flexibility and discretion to conduct the re-test in a practical and efficient manner, which could include the use of pre-positioning and quick-start features in a simulator, as appropriate. The only limitation is to ensure that the exercise being re-tested is conducted in accordance with the guidance in the applicable FTG.
- (2) Items from phase one that are being re-tested can only be assessed once and are assigned a final grade of one to four, as applicable. Repeating the exercise a second time during the partial PPC is not permitted.
- (3) A test item for an SA that is not successfully completed on the first attempt can be repeated once if doing so is appropriate in accordance with the considerations stated in section 6.0 of the ACP Manual (Repeating a Flight Test Exercise). Given that the manoeuvre associated with the SA was not conducted during phase one, providing the opportunity to repeat the manoeuvre during the partial PPC is consistent with the logic that allows the re-testing of any manoeuvre that was performed below standard during phase one.
- (4) If any item is assessed with a grade of one, or if at any point the number of assigned two’s exceeds the maximum allowable for a successful PPC (as per the ACP Manual), the partial PPC is terminated and assessed as unsuccessful. The only exception is when an exercise for an SA is assessed with an initial grade of one. As stated in subparagraph (3) above, it is permissible to repeat the exercise.
- (5) Refer to section 8.0 of this AC for guidance on the completion of the FTR (26-0249/26-0279).
7.5 Unsuccessful partial PPC
- (1) If the partial PPC is unsuccessful, the Phased PPC cannot be used to conduct further training or checking on the candidate.
- (2) The candidate must complete any training that is required to address items assessed with a grade of one and two during the partial PPC. A full PPC is required after training is completed and it must be conducted by a check pilot who did not conduct the re-training. The PPC is conducted in accordance with the procedures stated in the ACP Manual.
- (3) If the candidate subsequently meets the successful PPC standard, the candidate is eligible to complete future recurrent training and checking sessions using the Phased PPC.
7.6 Debriefing a partial PPC
- (1) The debriefing is conducted in accordance with the Flight Check Debrief guidance in section 6.0 of the ACP Manual and should not include information already addressed during the Flight Check Debrief after phase one.
8.0 Flight test report (FTR)
- (1) The FTR (26-0249/26-0279) is completed in accordance with the guidance in section 7.0 of the ACP Manual, except as follows:
- (a) Insert the following statement in the comments section: “This PPC was conducted as a Phased PPC”. This practice can be discontinued once the digital on-line FTR is in effect, which will have a field for this purpose;
- (b) Complete the FTR to the extent possible after the completion of phase one. If the PPC is in-progress, do not insert a grade for any item that was assessed with a grade of one or two. The final grade for these items will be assigned during the partial PPC in phase three;
- (c) If there is no requirement for a partial PPC, the remainder of the FTR can be completed at the end of phase two after the check pilot has verified that the candidate has completed all flight training and that technical and non-technical training and examinations are valid. If a partial PPC is being conducted, the FTR is completed after phase three;
- (d) Insert the following statement in the comments section if a partial PPC was required to re-test any item(s): “(Name of Flight Test Exercise) was repeated and assessed with a final grade of (insert grade)”.
- (e) Responsibility for the submission of the FTR is as follows:
- (i) If phase three is not applicable (no partial PPC), the check pilot who conducted the PPC in phase one is responsible for completing and submitting the FTR; and
- (ii) If phase three is applicable, the check pilot who conducted the partial PPC in phase three is responsible for completing the remaining sections of the FTR and submitting the report. This person is also named as the check pilot on the FTR, regardless of whether a different check pilot conducted the PPC in phase one.
9.0 TCCA oversight
9.1 Monitoring a phased PPC
- (1) All phases of the Phased PPC are subject to surveillance by TCCA, which will most likely occur in conjunction with the conduct of an ACP Monitor Check. Surveillance of all three phases will be particularly important during the early implementation of this program change to assess its effectiveness and impact on training and checking.
9.2 ACP monitor check
- (1) The Phased PPC is suitable for the conduct of an initial or recurrent monitor check on an ACP. As a minimum, the ACP must be monitored while conducting the following elements:
- (a) Establishing the candidate’s eligibility for a Phased PPC;
- (b) Flight Check Briefing;
- (c) Flight Assessment in phase one;
- (d) Flight Check De-briefing; and
- (e) Partial or full completion of the FTR, as applicable, after the completion of phase one.
- (2) A monitor check that includes the above elements is considered complete.
- (3) The person conducting the monitor check has the discretion to observe and include the conduct of a partial PPC in the check, if this phase is applicable. This only applies if the ACP undergoing the monitor check has been scheduled to conduct the partial PPC.
10.0 Information management
- (1) Not applicable.
11.0 Document history
- (1) Not applicable.
12.0 Contact us
For more information, please contact:
Chief, Commercial Flight Standards (AARTF)
E-mail: AARTFinfo-InfoAARTF@tc.gc.ca
We invite suggestions for amendment to this document. Submit your comments to:
Standards Branch Documentation Services
E-mail: AARTDocServices-ServicesdocAART@tc.gc.ca
Original signed by
Félix Meunier
Director, Standards Branch
Civil Aviation
Appendix A — Enhanced ACP / Training Pilot Experience Requirements
- (1) Introduction
- (a) The enhanced experience requirements in this appendix are only applicable to an ACP who is also a Training Pilot and conducts both checking and training on the same candidate during a Phased PPC. This means that the requirements only apply to an ACP who is conducting phases one and two, or phases two and three, or all three phases.
- (b) These requirements do not apply to a Training Pilot who is only conducting training in phase two on a candidate and is not conducting a check on the same candidate during phases one or three during a Phased PPC.
- (c) These requirements reduce risks associated with removing the independent verification of competency and the likelihood of encountering a situation where a person who delivers poor and ineffective training is also the person who subsequently verifies the candidate’s competency.
- (2) Enhanced requirements
- (a) A person must meet the following minimum requirements in order to check and train the same candidate during a Phased PPC:
- (i) Must satisfy the qualifications and requirements stated in the CASS for a Training Pilot, or the requirements stated for a person who conducts flight crew training on a contract basis;
- (ii) Be an ACP who has undergone a minimum of one Recurrent Monitor Check and has conducted a minimum of eight PPCs; and
- (iii) Meet any one of the following requirements:
- (A) Must hold or have previously held a class 1, 2, or 3 Flight Instructor Rating issued by TCCA or any other regulatory authority; or
- (B) Conducted a minimum of twenty instructional flights/sessions as a Training Pilot under CARs Part VII; or
- (C) Completed the following requirements:
- (I) Initial course in instructional theory delivered by any training facility or ACP Course Provider that is a minimum of 8.0 hours;
- (II) An assessment flight(s) with the Chief Pilot or Lead Training Pilot to confirm instructional competency in the following areas, as applicable to the operation:
- VFR training manoeuvres;
- IFR training manoeuvres; and
- Night training manoeuvres.
- (III) The above assessment flights must be a minimum of 1.0 hour flight time in each applicable area.
- (a) A person must meet the following minimum requirements in order to check and train the same candidate during a Phased PPC:
- (3) Verification and documentation
- (a) The Flight Operations Manager or Chief Pilot of an air operator is responsible for verifying and documenting in company records that a check pilot meets the above requirements before permitting the person to check and train the same candidate during a Phased PPC. Documented proof needs to be sufficient to reasonably demonstrate that requirements have been met.
- (b) Improper use of this privilege could lead to the revocation of the ACP’s ministerial delegation and/or the removal of an air operator’s privilege to allow checking and training by the same person when using the Phased PPC model.
Appendix B — Frequently asked questions
- (1) Introduction
- (a) The questions and answers in this appendix are intended to address anticipated questions that industry and TCCA inspectors may have on the Phased PPC.
- (2) Questions and answers
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(a) Q1. Are the existing checking practices being replaced by the Phased PPC?
Answer: No, the existing checking practices and PPC model will remain in place. An air operator has the option of using the existing PPC or the Phased PPC to conduct a recurrent PPC.
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(b) Q2. Why is there a need to keep the existing PPC model in place?
Answer: Some air operators may prefer the existing practice of conducting recurrent training before the PPC is conducted. There are also situations where the use of the Phased PPC is not authorized, including activities such as initial checking for the issuance of a license or rating. In such cases, the candidate is learning new skills and there is an obvious need to deliver training before the PPC is conducted. The existing PPC model also provides an independent verification of competency, which is particularly important for checking associated with the initial issuance of a license or rating.
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(c) Q3. How will the Phased PPC benefit pilots, air operators and aviation safety?
Answer: The Phased PPC provides a pilot with the opportunity to improve sub-standard performance before the PPC is declared unsuccessful. This lowers the stress of the event and will likely reduce uncharacteristic performance errors. Even if the successful standard is not achieved during phase one, the likelihood of a PPC failure after the completion of all three phases is considerably less in comparison to current practices. Furthermore, with the completion of the PPC in phase one, recurrent training is likely to be more relaxed and focused on learning instead of ‘training to the PPC’. Collectively, the foregoing has the potential to enhance overall pilot competency, increase pilot confidence, and reduce training and checking costs.
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(d) Q4. The duration of the Phased PPC can vary based on the potential need to conduct a Partial PPC (phase three). Will this necessitate frequent last-minute changes to aircraft or simulator reservations?
Answer: The vast majority of pilots will likely meet the successful PPC standard during phase one, eliminating the need for a partial PPC. Additionally, up to 15% of the allocated recurrent flight training hours can be used towards re-testing during a partial PPC (see example below). If the partial PPC is conducted for the purpose of initial crew certification for a Special Authorization, this is a known requirement that will be factored into aircraft or simulator reservations. In most situations, the foregoing factors will facilitate the completion of the Phased PPC within the planned allocation of hours and aircraft/simulator reservations.
Example of 15% calculation:
Total hours specified in an air operator’s COM for recurrent flight training: 6.0 hours
15% of recurrent hours (for allocation towards a re-test): 0.9 hours
Hours remaining for recurrent training: 5.1 hours
In this example, up to 0.9 hours of the total recurrent training hours can be allocated towards the time required to conduct a partial PPC re-test on a single candidate, or two candidates. The allocation cannot be multiplied by two when two candidates are undergoing a partial PPC during a two-crew PPC. If there is no requirement to conduct a re-test, recurrent training is conducted in accordance with the total hours specified in the COM, which cannot be less than the applicable hour requirements stated in the CASS.
This permission only applies to the re-testing of flight test exercises that were not successfully completed during phase one. The 15% allocation cannot be used for the purposes of conducting an initial crew certification for a Special Authorization, which is a known requirement that should have been factored into aircraft or simulator reservations
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(e) Q5. An air operator who uses the Phased PPC may pursue an increase in the number of company ACPs, which will increase the need for monitor checks. How will TCCA manage this?
Answer: The ACP Type M program is being expanded to include all eligible air operators across all subparts. This will allow TCCA to leverage industry ACPs with the Type M designation to conduct recurrent monitor checks. Additionally, from an oversight and capacity perspective, TCCA must also carefully manage, and limit as necessary, the number of persons who receive an ACP delegation. Depending on ACP capacity within a company, it may not always be possible to use the same person to train and check a candidate when using the Phased PPC.
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(f) Q6. Why is an ACP permitted to check and train the same candidate, therefore removing an independent verification of competency?
Answer: From a conflict of interest perspective, an ACP is incentivized to remain objective during the Phased PPC given that a candidate has the opportunity to improve sub-standard performance before the PPC is declared unsuccessful. This reduces the likelihood that an ACP will intentionally overlook or incorrectly grade a performance error. In addition, a recurrent PPC is used to renew license privileges for which competency has been previously demonstrated – it is a verification of existing skills as opposed to an initial competency assessment, and therefore has less potential to adversely impact aviation safety. Lastly, the risk of potentially allowing a Training Pilot who delivers poor and ineffective training to also be the ACP who subsequently verifies the candidate’s competency is mitigated by requiring an ACP who checks and trains the same candidate to meet Enhanced ACP / Training Pilot Experience Requirements.
The foregoing factors, when combined, reduce the need and value of an independent verification of competency during a Phased PPC.
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(g) Q7. Can an air operator use a third-party training facility or a Training Pilot and/or an ACP who is not an employee of the air operator to conduct a Phased PPC?
Answer: Yes, contingent on meeting the requirements stated in section 4.3 of this AC.
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(h) Q8. Is there a requirement to complete recurrent ground training immediately prior to conducting phase one?
Answer: No, the only requirement is to ensure that annual technical and non-technical training are valid when phase one commences. The valid-to date of technical and non-technical ground training may differ from the valid-to date of flight training and the PPC. There is no regulatory requirement that ties the date of ground training to flight training or the PPC. Although many air operators conduct ground and flight training concurrently, this is not always the case and a person could have completed annual technical and non-technical training up to 12 months before flight training and the PPC are conducted.
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(i) Q9. Section 6.2 in this AC states that any item assessed with a grade of three or four during the PPC satisfies flight training requirements specified in the CASS for the item, as applicable. How is the regulatory requirement specified in the CASS being met?
Answer: The CASS specifies manoeuvres and procedures that must be included in an air operator’s flight training program. For recurrent training, in most cases there is no stated curriculum, performance objectives, or minimum training time associated with each manoeuvre or procedure.
The only measurable requirement is to confirm that the candidate has demonstrated a satisfactory level of performance on each item. In such cases, it is of no consequence from a regulatory perspective whether this confirmation of performance occurs during phase one, two or three of the Phased PPC – the regulatory requirement has been met.
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(j) Q10. Section 6.2 in the AC refers to the development of ‘core competencies’ during pilot training. What are these competencies and how are they best developed during training?
Answer: The International Civil Aviation Organization (ICAO) Manual of Evidence-Based Training (EBT) identifies the following core competencies that pilots require to operate safely and effectively: Aircraft Procedures, Communication, Management of Automated Flight, Management of Manual Flight, Leadership and Teamwork, Problem Solving and Decision Making, Situation Awareness, and Workload Management. AC 700-042, Crew Resource Management (CRM), defines similar competencies that are considered core elements of CRM training.
The use of scenario-based events that introduce opportunities to develop these core competencies is a very effective approach to enhance pilot development in these areas and beyond.
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(k) Q11. Will the Phased PPC be available in subpart 705 in the future?
Answer: The suitability and need for a Phased PPC in subpart 705 will be assessed by the subpart 705 Modernization of Training and Checking Working Group (WG), which will be established at a future date. This will include consideration of unique checking options that already exist in subpart 705, such as Training in-lieu of a PPC and AQP, and whether an additional option like the Phased PPC would be of benefit. EBT is also being considered as a future option for subpart 705, which is an additional factor that will likely influence the WG’s assessment and recommendations.
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