Update: Modernizing and Enhancing Pilot Training Regulations

September 1st 2020

On February 17, 2020 Transport Canada Civil Aviation (TCCA) released a communique that announced our intent to establish a working group (WG) with industry to collaborate and evolve pilot training and checking practices in commercial and general aviation.

Physical distancing and operational and regulatory impacts associated with the COVID-19 pandemic are challenging the ability of TCCA and industry to commence this initiative and conduct in-person collaboration. Although these challenges will likely exist for the foreseeable future, it is important to move forward and evolve training and checking to the extent possible. To this end, TCCA will leverage virtual and digital technology to commence efforts and convene a WG that is focused on commercial and private operations, accepting that WG participation and the pace of progress may be less than envisioned. Efforts to address general aviation will be announced separately in due course.

There is strong support amongst commercial and private operators for this initiative, as evidenced by the extensive list of training and checking pilots that volunteered to participate in the WG. To ensure the size and scope of the WG is manageable, and to ensure that sufficient capacity exists to maximize industry participation, industry volunteers will be divided amongst two separate working groups – one that is focused on CARs subparts 604, 702, 703 and 704, which all have a high degree of commonality in training and checking practices, and another that is focused on subpart 705, which has training and checking practices that are unique to this subpart, such as line checks, six-month recurrent training in lieu of a Pilot Proficiency Check (PPC), and the Advanced Qualification Program (AQP). The subpart 705 WG may also include representatives from subpart 604 and will assess the merits of adopting the Evidence Based Training (EBT) program as an alternate means of training and checking. EBT is not being considered for subparts 702, 703 and 704 at this time, which is consistent with ICAO recommendations.

TCCA’s immediate priority is to establish the WG to address training and checking in CARs subparts 604, 702, 703 and 704. The WG for subpart 705 will be established at a later date when TCCA has sufficient capacity to conduct both working groups concurrently. This approach will also ensure that this initiative is not a distraction for airline operators, who have been significantly impacted by the pandemic and are currently focused on restoring operational capacity.

To maximize industry inputs, TCCA representation in the working groups will be minimal and will only consist of headquarters representatives. Regional TCCA inspectors will have an opportunity to provide input and review the progress and ideas being considered by the WG. Regional coordination will be initiated by headquarters in the near future. TCCA regions will also be invited to participate in any Risk Assessments that may be necessary to assess specific practices and regulatory changes generated by the working groups.

The objectives, timelines and persons selected for the 604, 702, 703 and 704 WG are detailed in the Terms of Reference that are enclosed as Appendix A. The participants and Terms of Reference for the subpart 705 WG will be published prior to its commencement. Industry and TCCA persons that are not participating in the working groups are encouraged to submit ideas or comments to a WG representative or to TCCA headquarters at TC.ACPAQPProgram-ProgrammePVAPAQ.TC@tc.gc.ca. Industry will also have an opportunity to review and comment on any proposed regulatory changes, which will be published as a Notice of Proposed Amendment through the Canadian Aviation Regulatory Advisory Council (CARAC) process.

TCCA will contact WG representatives for subparts 604, 702, 703 and 704 in the near future to coordinate an introductory virtual meeting in October 2020. The WG representatives for subpart 705 will be contacted at a later date when TCCA and industry are ready to proceed with the subpart 705 WG.


Robert Sincennes
Director, Standards Branch
Civil Aviation

Appendix A

Terms of Reference

Modernizing Training and Checking

Subparts 604, 702, 703 and 704


Transport Canada Civil Aviation (TCCA) has initiated this working group (WG) to develop solutions to improve the relevance and effectiveness of training and checking in commercial aviation and amongst Private Operators. A key aim is to redesign the regulatory framework to emphasize training over checking, as advocated by the International Civil Aviation Organization (ICAO). This includes embracing principles contained in practices such as Competency-Based Training and Assessment (CBTA) and Evidence-Based Training (EBT). The WG will also evaluate options to enhance the development of core competencies during training and checking and consider regulatory changes to optimize the use of Flight Simulation Training Devices (FSTDs) across the subparts under review.

Areas under Review

All practices, regulations and standards that are relevant to training and checking in Canadian Aviation Regulations (CARs) Subparts 604, 702, 703 and 704 and the corresponding Commercial Air Service Standards (CASS) are subject to review by the WG.

Working Group Tasks

  1. Research training and checking models such as CBT, EBT, Training to Proficiency and any other model in use by other civil aviation regulatory authorities that is focused on developing core competencies and emphasizes training over checking;
  2. Develop proposed changes to the CARs and CASS and develop alternate training and checking models (if applicable) to achieve the following objectives:
    1. optimize the opportunity to learn during training while reducing the emphasis on checking;
    2. increase the focus on overall performance during a check/assessment, versus performance on individual manoeuvres;
    3. align training and checking to the extent possible with the roles and tasks performed by pilots in each subpart, to include consideration of how the incorporation of ‘line checks’ could potentially support this objective;
    4. facilitate the incorporation of core competencies identified in the ICAO EBT Manual during training and checking to the extent possible;
    5. align the training and assessment of a pilot-in-command and second-in- command with the competencies and skillsets that are unique to each role;
    6. enhance the qualification requirements, regulatory oversight and training for company training captains; and
    7. optimize the use of FSTDs, particularly in subparts where FSTDs are under-utilized, by maximizing the manoeuvers eligible for training and checking credits.


The working group team members named below offer a good balance of experience across the applicable CARs subparts and provide sufficient depth to maintain progress if a team member(s) leaves the team or is unavailable for an extended period because of operational obligations, health issues or other reasons.

All team members are expected to contribute to the tasks outlined above in accordance with guidance provided by the Team Leader. It is anticipated that WG activities will span a three-year period as outlined in the forecasted timeline below.

Team meetings and coordination will be conducted through distant communication such as virtual, teleconference and e-mail. In-person team meetings will not occur unless pandemic measures and restrictions are sufficiently relaxed and there is a need for an in-person meeting.

Forecasted Timelines

Task Target Date Remarks

Conduct introductory team meeting

October 2020

Team introductions and general discussion

Conduct individual research on methods of training and checking

Oct – Dec 2020

Review ICAO recommendations on EBT, CBTA and use of FSTDs and review training and checking practices in other countries

Develop concepts and identify areas of potential change in the CARs and CASS

Jan 2021 – Jun 2021

This effort will be facilitated by further guidance from the Team Leader

Develop a summary of proposed changes to the CARs and CASS

Jul 2021 – Dec 2021

This effort will consist of developing draft changes in sufficient detail to support the conduct of a Risk Assessment (RA), if necessary

Conduct internal TCCA Risk Assessments (if necessary) for proposed changes

Jan 2022 – Mar 2022

All proposed changes will be reviewed by the CFS Chief to determine whether an RA is warranted

Draft Notice of Proposed Amendments (NPAs) and any required ACs or TPs for alternate training programs. Circulate to TCCA regions for consultation

Apr 2022 – Oct 2022

This task will be completed by the Team Leader and will include a team review of all completed drafts before distributing for regional consultation

Distribute the NPAs, AC and/or TP to industry through CARAC for consultation.

Nov 2022 – Jun 2023

Coordinated by Team Leader

Publish regulatory changes and issue AC and/or TP as applicable

Jul 2023

Coordinated by Team Leader

Dissolve Working Group

Jul 2023

not applicablen/a

Team Composition

Team Member Organization Contact Info

John Smith (Team Leader)

TCCA, Commercial Flight Standards


Todd Coates

Provincial Airlines


Laurie Baker

Sunwest Aviation


John Jackson

Sunwest Aviation


Jonathon Lukca

Air Inuit


Laurence Appleford

Alkan Flight Academy


Tammy Schwarz

Flight Safety International


Rusmir Mujic

Flight Safety International


Mark Gallant



Merlin Preuss



Maximilian DeBruyn

Canadian Helicopters Offshore


Trevor Milne

Ornge EMS


Peter Koster

Independent Helicopter ACP


Denis Ventura

Aircrew Training Limited


Michel Bussières



Denis Fecteau

Canadian Helicopters Limited


Mario Leroux

Aircraft Services Division


Clayton Reid

Sky Helicopters


Stephen Harmer

Rangeland Helicopters


Responsible TCCA Person / Group

Director, Standards Branch

Financial Responsibility

TCCA is not providing financial support or reimbursement for this activity. Although it may be possible to conduct all working group activities through distant communication, should there be a future need for in-person meetings, costs incurred for travel, accommodation and any other associated cost will be the responsibility of each team participant or supporting organization.

Cancelling Participation

A team member who is unable to remain in the working group should inform the Team Leader at the earliest opportunity.