| GAPL 2002-04 |
| 2002-07-19 |
Subject
Approval of Integrated Commercial Pilot Training Courses
Reference
Supersedes Policy Letter GA 2000-06.
Notices of Proposed Amendment (NPAs) 99-243 to 99-278.
Purpose
Standardization of the approval of integrated courses of pilot training.
Background
The Part IV Technical Committee on Personnel Licensing and Training of the Canadian Aviation Regulation Advisory Council (CARAC) agreed, at a meeting on December 13 and 14, 1999, on the regulatory framework for implementation of two Canadian integrated commercial pilot training courses, a CPL(A) course and a CPL(A)/IR course. Since September 2000, Transport Canada has been evaluating integrated courses against the provisions of the NPAs and approving the courses where they meet the requirements. Part of the process has required approval of operations manuals and review of the required training manuals. General Aviation Inspectors are spending a significant amount of time correcting manuals and documents submitted for approval, in effect providing a consultation service to the industry. The responsibility for manual development must reside with industry. It is not the mandate of the Minister to write manuals for the industry, but rather to review or approve them.
Policy
Office of Primary Interest (OPI)
Each Regional Superintendent, Flight Training shall establish an OPI for approval of integrated courses. The OPI shall review the documentation submitted by a Flight Training Unit (FTU), as well as liaise with the FTU, the Principal Operations Inspector, and the Regional Superintendent, Flight Training, throughout the authorization process.
Initial Inquiry
The following items shall be discussed with an applicant during an initial inquiry about obtaining authorization for an integrated commercial pilot course:
- CPL(A), CPL(A)/IR course requirements, as applicable;
- required contents for flight training operations manual;
- required contents for training manual;
- guidance information available;
- approval process, including normal service levels, fees, and requirements for an authorizing inspection.
Document Compliance
A FTU shall submit the following supporting documentation before the approval process can begin:
- Form 26-0344 Application for a Flight Training Unit Operator Certificate.
- Flight Training Operations Manual.
- Training Manual.
Flight Training Operations Manual
A flight training operations manual shall be submitted by the FTU seeking approval of an integrated course. Using the integrated course of commercial pilot training checklist, the manual will be assessed to ensure conformance with specific requirements of the standards before an integrated course can be authorized.
Training Manual
A training manual shall be submitted by the FTU seeking approval of an integrated course. Using the integrated course of commercial pilot training checklist, the manual shall be assessed to ensure conformance with the standards.
Note: When a manual requires operators to express a policy for which no regulatory standard applies (e.g. maximum student training times, procedure for changing instructors), the operators have discretion to express their own policies, provided they are clear and are not likely to adversely affect aviation safety. Where guidance material has been published, the operator can be directed to this guidance material to assist him. Where a regulatory standard exists (e.g. licensing requirements), the standard shall be met.
Unsatisfactory Items
At no time are inspectors to rewrite or add to a submitted manual or document. If there are any items in the manuals that do not meet the requirements, the review/approval process is stopped. In the case of a preliminary assessment, the process is stopped upon finding five significant errors. Significant errors shall be identified to the originator of the manual by quoting the Regulatory requirement and deficiency, e.g. "Section XX of the submitted manual does not meet the requirement of paragraph (x) of the Standard 426.xx in that it does not contain a list of effective pages".
If the originator then re-submits the manual and three significant errors are found, the manual is to be returned again to the originator for further action. Advise the applicant in writing that they must be corrected before the authorization process can be completed.
The Regional Manager, General Aviation may, under extenuating circumstances, authorize continuation of the approval process after significant errors have been found.
The industry should be encouraged to make use of available checklists, General Aviation Advisory Circulars, or other reference materials and should also be encouraged to seek professional assistance in preparing manuals for the Minister's approval.
Note: Significant errors to manuals are considered to be errors with respect to compliance with the Canadian Aviation Regulations (CARs). Significant errors are not spelling or formatting. However, poor organization or presentation of material is a significant error.
Amendments to Manuals
The Minister shall approve amendments to the flight training operations manuals with respect to information they contain that is required by the personnel licensing standards. For the training manual, copies of any amendments shall be provided to the Minister within 10 working days of the date of the amendment.
Authorizing Inspection
Once it has been determined that the application and associated documentation comply with the integrated course requirements, the FTU shall be inspected, using the appropriate checklist to ensure that it meets the requirements. Once the FTU has been issued authority to offer an integrated course, a post certification audit shall be conducted within the succeeding 12 months to ensure that all certification requirements continue to be met.
Authorization
Until the regulations and standards for integrated courses are published in the CARs, the authorization shall be issued as an Operations specification showing, as appropriate:
- CPL(A) Integrated Course
- CPL(A) / IR Integrated Course
NPAs 99-243 to 99-278 constitute the conditions for the specification. Once the regulations and standards are published, the integrated course authority will be shown as a type of authorized training.
Expiry
This policy is effective immediately and will expire with the appropriate amendments to the CARs, the General Aviation Inspection and Audit (Checklists) Manual, and the Flight Training Unit Certification Manual.
Manzur Huq
Director
General Aviation