49588 Federal Register / Vol. 72, No. 166 / Tuesday, August 28, 2007 / Notices 

DEPARTMENT OF TRANSPORTATION 

Federal Aviation Administration 

[Docket Number FAA–2007–28498] 

Proposed Advisory Circular No. 120– 

53A, Crew Qualification and Pilot Type 

Rating Requirements for Transport 

Category Aircraft Operated Under 14 

CFR Part 121 

AGENCY: Federal Aviation 

Administration, DOT. 

ACTION: Notice of availability of a 

proposed advisory circular and request 

for comments. 

SUMMARY: This notice announces the 

availability of and requests comments 

on a proposed revision to Advisory 

Circular (AC) No. 120–53, Crew 

Qualification and Pilot Type Rating 

Requirements for Transport Category 

Aircraft Operated under 14 CFR part 

121. That AC provides the Federal 

Aviation Administration (FAA) 

guidance for the evaluation and 

approval of flight crew qualification 

programs and the issuance of pilot type 

ratings for flight crews operating under 

14 CFR part 121. The proposed AC 

streamlines the process described in AC 

120–53 for determining the level of 

differences between aircraft and the 

credits the FAA assigns between those 

aircraft for the purposes of training, 

checking, and recency of experience 

requirements. The applicability of the 

proposed AC would be limited to 

operations conducted under 14 CFR part 

121. 

DATES: Comments must be received on 

or before October 29, 2007. 

ADDRESSES: Send all comments on the 

proposed AC to Docket Number FAA– 

2007–28498, using any of the following 

methods: 

• DOT Docket Web site: Go to 

http://dms.dot.gov and follow the 

instructions for sending your comments 

electronically. 

• Government-wide rulemaking Web 

site: Go to http://www.regulations.gov 

and follow the instructions for sending 

your comments electronically. 

• Mail: Send comments to the Docket 

Management Facility; U.S. Department 

of Transportation, 1200 New Jersey 

Avenue, SE., West Building Ground 

Floor, Room W12–140, Washington, DC 

20590. 

• Fax: Fax comments to the Docket 

Management Facility at 202–493–2251. 

• Hand Delivery: Bring comments to 

the Docket Management Facility in 

Room W12–140 of the West Building 

Ground Floor at 1200 New Jersey 

Avenue, SE., Washington, DC, between 

9 a.m. and 5 p.m., Monday through 

Friday, except Federal holidays. 

FOR FURTHER INFORMATION CONTACT: Greg 

Kirkland, Air Transportation Division 

(AFS–220), Federal Aviation 

Administration, 800 Independence 

Avenue, SW., Washington, DC 20591; 

telephone: (202) 267–8166, e-mail 

Greg.Kirkland@faa.gov. 

SUPPLEMENTARY INFORMATION: 

Authority: 49 U.S.C. 106(g), 40113, 44701, 

44702, 44703. 

Comments Invited 

The proposed AC is published at the 

end of this notice. You may also receive 

an electronic copy of the proposed AC 

by accessing the FAA’s web page at 

http://www.faa.gov/ 

regulationslpolicies/rulemaking/ 

recentlylpublished. Interested parties 

are invited to submit comments on the 

proposed AC to Docket No. FAA–2007– 

28498. All communications received on 

or before the closing date for comments 

will be considered by the FAA before 

issuing the final AC. 

Advisory Circular (AC) NO. 120–53, 

‘‘Crew Qualification and Pilot Type 

Rating Requirements For Transport 

Category Aircraft Operated under 14 

CFR part 121.’’ 

On May 13, 1991, the FAA issued AC 

120–53 to provide guidance on the 

process the FAA uses when determining 

the level of flight crew training required 

to operate an aircraft under 14 CFR part 

121. The regulations establish 

requirements for training, checking, and 

recency of experience for flight crews 

operating an aircraft under part 121. 

Further, the AC provides guidance for 

determining the level of differences 

between comparative aircraft when a 

pair of aircraft have similar handling or 

flight characteristics. An applicant may 

submit documentation requesting the 

FAA consider the commonality in that 

pair of aircraft be sufficient to allow 

credits for that commonality, which 

may then reduce the amount of 

duplicative training and checking 

requirements and may also reduce, for 

some aircraft, the recency of experience 

required by 14 CFR 121.439 (a). After 

completion of the comparative process, 

if the FAA is convinced that the two 

aircraft types share sufficient common 

characteristics, then the FAA authorizes 

qualified flight crews to receive training, 

checking, and in some cases, recency of 

experience credits for that commonality. 

Advisory Circular 120–53 

standardizes the application process for 

applicants and explains the training and 

checking credits available when the 

system differences between related 

aircraft models are from Level A 

through D. For example, a difference 

that amounts to no more than a 

knowledge-based difference that can be 

addressed in pilot training by using a 

computer-based course of instruction 

(e.g., the B–757–200 and the B–767–200 

hydraulic systems), would be a Level B 

difference. On the other hand, a 

difference that involves full pilot task 

training (e.g., visual display and switch 

position requirements between the B– 

767–200 and the B–767–400) would be 

a Level D difference necessitating pilot 

training in a full task training device. 

The AC also explains the process for 

allowing full or partial credit for 

recency of experience that may be 

permitted when aircraft handling 

qualities are similar. For example, 

handling qualities for the Airbus A–320, 

A–330, and A–340 aircraft were found 

to be similar, therefore credit for 

recency of experience was allowed. 

If an additional series of related 

aircraft models having similar handling 

qualities and commonality of systems is 

type certificated, the FAA uses the 

guidance in AC 120–53 when deciding 

to allow credit for training, checking, 

and recency of experience. When 

difference levels between the aircraft 

models do not exceed Level D, credit is 

usually allowed. For example, 

evaluation of the differences in the 

flight deck configuration (e.g., visual 

displays and switch positions) of the B– 

767–400 determined that Level D 

differences existed between the B–767– 

400 and the B–767–200 and B–767–300 

series. Therefore, the FAA allows credit 

for training and checking for Level A 

through D differences between the B– 

767–200/300 and the B–767–400. 

These credits have been provided also 

within families of aircraft (same make 

but different models sharing 

commonality) with similar handling 

qualities and no greater than Level D 

system differences. Examples of 

programs that have taken advantage of 

these credits are: ‘‘Common Pilot Type 

Rating’’ used by Boeing and ‘‘Cross 

Crew Qualification’’ (CCQ) used by 

Airbus. 

Proposed Revisions to AC No. 120–53A 

In view of the success of the common 

pilot type rating and CCQ programs 

under AC 120–53, proposed AC 120– 

53A describes the same process as AC 

120–53 for evaluating the differences 

between comparative aircraft and 

determining the training, checking, and 

recency of experience requirements 

based on a commonality determination. 

Proposed AC 120–53A restates certain 

processes to make them more easily 

understood and applied by the FAA and 

industry in view of innovations and 


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Federal Register / Vol. 72, No. 166 / Tuesday, August 28, 2007 / Notices 49589 

advancements in technology and aircraft 

design that were not envisioned when 

AC 120–53 was written. 

This proposed AC: 

• Updates the guidance to reflect the 

increasing commonality evolving in 

contemporary transport category aircraft 

design. 

• Streamlines the process, with 

clearly defined tests, that permit an 

applicant to apply for, and the FAA to 

allow credit for demonstrating sufficient 

commonality between aircraft. The 

process is updated by incorporating 

elements of the T2 and T4 tests into the 

new T6 test. 

• Shifts the emphasis from 

documenting the commonalities to 

documenting the differences between 

aircraft types. 

• Makes definitional changes. 

‘‘Common type rating’’ is replaced by 

‘‘Common pilot type rating.’’ The term 

‘‘variant’’ has been eliminated and its 

meaning has been consolidated into one 

term, ‘‘related aircraft.’’ It also separates 

the terms ‘‘Currency’’ and ‘‘Recent 

experience.’’

• Introduces the term ‘‘Common 

Takeoff and Landing Credit’’ applicable 

to receiving credit for recency of 

experience. 

Updates the guidance to reflect the 

increasing commonality evolving in 

contemporary transport category 

aircraft design. 

Aircraft manufacturers are now 

designing more aircraft that share 

similar handling and flight 

characteristics. The use of common 

flight deck designs has also become 

prevalent. These commonalities 

improve the safety of aircraft operations 

and provide an opportunity in the 

proposed AC for the FAA to recognize 

this improvement in safety by reducing 

the need for some duplicative training. 

Streamlines the process, with clearly 

defined tests, that permit an applicant 

to apply for, and the FAA to allow credit 

for demonstrating sufficient 

commonality between aircraft. 

This proposed AC provides a 

systematic means with clearly defined 

tests that permit an applicant to apply 

for, and the FAA to allow credit for 

successfully demonstrating 

commonality between aircraft. For 

example, the T6 test criteria are clearly 

defined to give applicants more 

standardized, specific test criteria than 

the current T2 and T4 tests. The T6 test 

requires the applicant to show a 

commonality within a specific weight 

range, center of gravity range and 

maximum demonstrated crosswind for 

takeoff and landing. 

Shifts the emphasis from 

documenting the commonalities to 

documenting the differences between 

aircraft types. 

The proposed AC shifts the emphasis 

from documenting the commonalities to 

documenting the differences between 

aircraft types. The applicant would 

continue to show commonalities and 

the similarities in handling and flight 

characteristics by demonstrating the 

absence of differences. Where 

differences do exist, those differences 

would be addressed by the appropriate 

training, checking, and recency of 

experience requirements. In the 

proposed AC the FAA would continue 

to allow credit for aircraft shown to 

have commonality as in AC 120–53. 

Makes definitional changes. 

‘‘Common type rating’’ is replaced by 

‘‘Common pilot type rating’’ to show a 

clearer difference between a pilot type 

rating and a type certificated aircraft. 

The terms ‘‘variant’’ and ‘‘related 

aircraft’’ were used interchangeably in 

AC 120–53 causing some confusion. The 

term ‘‘variant’’ has been eliminated and 

its meaning has been consolidated into 

one term, ‘‘related aircraft.’’ For 

example, related aircraft would be two 

or more aircraft of the same make 

(Airbus), but not necessarily under the 

same type certificate (A–320, A–330 and 

A–340). 

The AC 120–53 definitions of 

‘‘currency’’ and ‘‘recent experience’’

were considered synonymous and used 

interchangeably. This interchangeable 

use ofterms has led to confusion. The 

proposed revision separates the terms to 

eliminate any further confusion. 

Introduces the defined term Common 

Takeoff and Landing Credit applicable 

to receiving credit for recency of 

experience. 

A Common Takeoff and Landing 

Credit (CTLC) allows recency of 

experience credit between related 

aircraft of the same make with different 

type certificates that can be 

demonstrated to have similar handling 

and flying characteristics. This credit is 

applied toward meeting the 

requirements of 14 CFR 121.439. 

Conclusion 

The concept of commonality and the 

use of credits can reduce unnecessary 

training costs while providing an 

acceptable method of compliance with 

the existing regulations. Only the FAA 

can make a determination of 

commonality; and while an applicant 

may ask the FAA for a finding of 

commonality, the FAA will only make 

such a finding after the FAA is satisfied 

that sufficient commonality exists to 

permit crediting. 

The history of safe operation of the B–

757 and B–767 with a common pilot 

type rating, and the successful use of 

similar programs (CCQ) with other 

aircraft models by European 

manufacturers demonstrates that the 

FAA can continue to safely allow credit 

for training, checking, and recency of 

experience between aircraft that have 

demonstrated commonality. The entire 

proposed AC is published with this 

Notice for the convenience of the reader 

as Attachment 1. 

Issued in Washington, DC, on August 14, 

2007. 

James J. Ballough, 

Director, Flight Standards Service. 

Attachment 1—Advisory Circular (AC) 

No. 120–53, Crew Qualification and 

Pilot Type Rating Requirements for 

Transport Category Aircraft Operated 

Under 14 CFR Part 121 

Advisory Circular 

Subject: Crew Qualification and Pilot 

Type Rating Requirements for Transport 

Category Aircraft Operated Under Part 

121. 

Date: MM/DD/YY. 

Initiated by: AFS–200. 

[AC No: 120–53A] 

This advisory circular (AC) provides 

an acceptable means, but not the only 

means, of compliance with the Code of 

Federal Aviation Regulations (CFRs) 

regarding qualification and type rating 

of flight crewmembers operating under 

Part 121 of the CFRs. Included are 

criteria for the determination and 

approval of training, checking, and 

currency necessary for the operation of 

aircraft. This AC also describes the 

process by which the Federal Aviation 

Administration (FAA) determines the 

qualification of the pilot-in-command 

(PIC) or second-in-command (SIC) of 

new or modified aircraft. Details of the 

systems, processes, and tests necessary 

to apply this AC are explained in the 

appendices. Provisions of this AC are 

intended to enhance safety by: 

• Providing a common method of 

assessing applicant programs. 

• Directly relating pilot training and 

qualification requirements to fleet 

characteristics, operating concepts, 

and pilot assignments. 

• Permitting better planning and 

management of fleets, pilot 

assignments, and training resources 

by outlining what FAA requirements 

apply, what training resources or 

devices are needed, and what 

alternatives are possible. 

• Permitting timely and consistent 

decisions about fleet acquisition, 

integration, modification, or phaseout 

associated with pilot qualification or 

pilot assignments. 


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• Permitting manufacturers to design 

aircraft that take advantage of new 

technology or their similarity with 

existing related aircraft, as 

appropriate to a particular operator‘s 

fleet. 

• Encouraging cockpit standardization 

by crediting commonality and 

identifying necessary constraints 

when differences exist. 

• Providing a framework for application 

of suitable credits or constraints to 

better address new technology and 

future safety enhancements. 

1. Focus. This AC addresses aircraft 

manufacturers or modifiers who design, 

test, and certificate aircraft as well as 

approved 14 CFR part 142 training 

centers. In addition, it applies to 

operators whose pilots operate several 

related aircraft of the same manufacturer 

in a mixed fleet and operators seeking 

credit for prior pilot experience with 

related aircraft of the same 

manufacturer. 

2. Cancellation. AC 120–53, Crew 

Qualification and Pilot Type Rating 

Requirements for Transport Category 

Aircraft Operated Under CFR Part 121, 

Dated May 13, 1991, Is Canceled. 

3. Discussion. 

a. A System for Pilot Qualification. 

The FAA specifies qualification criteria 

(minimum training, checking, and 

currency) for particular aircraft through 

Flight Standardization Board (FSB) 

evaluations and findings. FSB findings 

are described in reports for specific 

aircraft. The reports provide guidance to 

certificate-holding district offices 

(CHDO) for use by principal operations 

inspectors (POI) and other inspectors. 

FSB report provisions serve as a basis 

for the FAA to approve operators’

programs and for pilot certification. 

b. Changing Needs. Necessary support 

for the FSB process is provided by the 

industry. In the past, procedures varied 

by manufacturer, individual project, 

operator, and other factors including: 

(1) Introduction of new and related 

aircraft and increases in the significance 

of modifications to existing aircraft, 

particularly with regard to engines or 

avionics. 

(2) Integration of related fleets of 

aircraft following airline acquisitions or 

mergers. 

(3) Increased dependence on leased 

aircraft, many of which are configured 

differently than an operator’s basic fleet. 

(4) A wider variety of equipment 

options available in new or retrofit 

aircraft. 

(5) Introduction of new technology in 

cockpit enhancements. 

4. Summary of Revisions. This AC 

describes necessary revisions and 

enhancements to the FSB process to 

address uniform, systematic, timely, and 

comprehensive application of pertinent 

14 CFR parts in a changing and 

increasingly complex operational 

environment. This AC revision deletes 

master common requirements due to a 

lack of practical application. This AC 

recognizes the concept of reduced 

differences between related aircraft and 

defines the training, checking, currency, 

and recency of experience requirements. 

a. This AC revision clarifies and 

introduces new terms and concepts. 

These include: 

(1) Clarification of the terms ‘‘aircraft 

type certificate’’ and ‘‘related aircraft’’. 

(2) The difference between currency 

and recency of experience is defined. 

(3) A definition of ‘‘common pilot 

type rating’’ now including levels A 

through D for any aircraft of the same 

make but of different aircraft type 

certificates (TC). 

(4) Modified checking requirements to 

embrace the concept of checking only at 

the difference levels between related 

aircraft. 

(5) A new term, ‘‘common takeoff and 

landing credit’’ (CTLC). 

(6) An introduction of the T6 test to 

provide for CTLC (recency of 

experience) in mixed fleet flying 

between separate type-certificated 

aircraft with common takeoff and 

landing characteristics. The intent of the 

T6 test is to provide a comparison of 

aircraft that have not previously been 

evaluated for CTLC using the T2 test. 

(7) A means to identify and evaluate 

new technologies that may not be 

associated with an aircraft evaluation. 

(8) A distinction between supervised 

line flying (SLF) and operating 

experience (OE). 

b. Additional concepts are introduced 

to uniformly apply the 14 CFR parts 

applicable to pilot qualification and the 

differences. The AC’s main concepts are 

summarized as follows. 

(1) Master Difference Requirement 

(MDR). Master requirements are 

expressed in the form of MDRs. MDRs 

are requirements applicable to pilot 

qualification that pertain to differences 

between related aircraft. MDRs are 

specified by the FSB in terms of 

difference levels. 

(2) Difference Levels. Difference levels 

are formally designated levels of 

training methods or devices, checking 

methods, or currency methods that 

satisfy difference requirements between 

related aircraft. Difference levels specify 

FAA requirements proportionate to and 

corresponding with increasing 

differences between related aircraft. A 

range of five difference levels in order 

of increasing requirements, identified as 

A through E, are each specified for 

training, checking, and currency. 

(3) Operator Difference Requirement 

(ODR). Operators show compliance with 

the FAA MDRs through an operator’s 

specific ODR, which lists each 

operator‘s fleet differences and 

compliance methods. ODRs specify 

requirements uniquely applicable to a 

particular fleet and mixed flying 

situation and are based on the MDRs. 

ODRs are those operator-specific 

requirements necessary to address 

differences between a base aircraft and 

one or more related aircraft, when 

operating in mixed fleet flying or 

seeking credit in transition programs. 

ODRs include both a description of 

differences and a corresponding list of 

minimum training, checking, and 

currency compliance methods that 

address pertinent FSB requirements. 

Note: These and other concepts are more 

fully described in the appendices. 

5. Setting FAA Requirements. The 

FSB process is made up of proposal 

development, testing, draft requirement 

formulation, FSB final determinations 

and FAA approval. 

a. Applicants’ Proposals. Aircraft 

manufacturers or modifiers usually 

initiate proposals for formulation or 

amendment of FSB requirements. This 

is done in conjunction with application 

for aircraft type certification or 

supplemental type certification of an 

aircraft or system. The FAA, operators, 

and, in certain instances, other 

organizations or individuals, may 

initiate proposals or amendments. 

b. Standardized Tests. A main 

element of the requirements formulation 

process is the use of standardized 

testing to determine pilot qualification 

requirements. One or more of six tests 

are applied depending on the proposal’s 

degree of differences between related 

aircraft, difference levels sought, and 

the outcome of any previous tests. Only 

the necessary tests are used. Tests may 

be waived or difference levels may be 

assigned based on operational 

experience. 

c. FAA Formulation and 

Implementation of Requirements. 

Following testing and formulation of 

draft requirements, FSB requirement 

determinations are then made 

specifying MDRs and any necessary 

supporting information. Supporting 

information may pertain to operator 

certification, airmen certification, 

approval of devices and simulators, and 

other items necessary for proper 

application of MDRs. FSB reports will 

be used in the evaluation, certification, 

and approval of operators’ programs. 


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d. Revision of Requirements. FSB 

reports are periodically updated when 

new or modified aircraft are introduced, 

when requested by an applicant based 

on OE, or when the FAA determines it 

is necessary for safety reasons. 

e. Pilot Type Ratings. A new pilot 

type rating is typically assigned when 

level E training differences are 

determined between the candidate 

aircraft and the base aircraft. The pilot 

type rating determination and any 

training, checking, and currency 

specifications established under the 

testing process of this AC are 

determined by evaluating the handling 

qualities and core pilot skills related to 

the candidate aircraft. Systems such as 

heads-up display (HUD), Enhanced 

Vision Systems (EVS), or Synthetic 

Visions Systems (SVS) may require 

Level E training without requiring a new 

pilot type rating. The FSB, with the 

concurrence of the Air Transportation 

Division, AFS–200, will make this 

determination. 

f. Common Pilot Type Rating. A 

common pilot type rating is assigned 

when no greater than level D training 

differences are determined between 

aircraft of the same type with different 

aircraft TCs. 

g. Same Pilot Type Rating. A same 

pilot type rating is assigned when no 

greater than level D training differences 

are determined between aircraft with 

the same aircraft TCs (series). 

6. Operator Compliance with FAA 

Requirements. 

a. Obtaining FSB Information. 

Operators are advised of pertinent FSB 

information through FAA CHDOs and 

POIs. Operators may also obtain FSB 

information from aircraft manufacturers 

or modifiers, other operators, or other 

aviation organizations that maintain 

awareness of FAA policies, and the Web 

site http://www.opspecs.com. 

b. Certificated Operator Compliance 

with Mixed Fleet Flying. When aircraft 

are flown in mixed fleets, certificated 

operators will comply with MDRs and 

other FSB difference provisions. 

Certificated operators accomplish this 

by identifying a base aircraft, describing 

differences that exist between their base 

aircraft and the candidate aircraft, and 

by specifying particular means of 

compliance to satisfy MDRs. Sample 

FSB ODRs provide guidance for the 

approval of an operator’s mixed fleet 

flying program and specify necessary 

constraints or permissible credits. The 

description of specific differences and 

compliance methods are identified in 

the operator’s ODRs. Constraints or 

credits may relate to knowledge, skills, 

devices, simulators, maneuvers, checks, 

currency, or any other factors necessary 

for safe operations. Constraints or 

credits may be applied generally or only 

to specific aircraft or pilot positions. 

Once approved, the operator’s program 

must be conducted in accordance with 

(IAW) these approved ODRs. ODR 

proposals are provided to the FAA 

CHDO in a standard tabular format and 

are approved by POIs only if they meet 

MDRs and other pertinent FSB 

requirements. The operator must apply 

to amend the ODRs when changes occur 

in the base aircraft, comparison aircraft, 

and/or training devices that affect the 

approval basis of the ODRs. 

c. Credit between Programs. In 

addition to mixed fleet flying, ODRs 

may be used to permit credit between 

related aircraft in differences or 

transition training and checking 

programs, consistent with FSB 

provisions. 

7. FAA Approval of Operator 

Programs. 

a. POI Approval. FAA POIs approve 

operator programs when those programs 

comply with FSB provisions. If less 

restrictive programs are proposed, POIs 

advise the applicant that: 

(1) A request for change of the MDRs 

must be initiated; 

(2) The differences between related 

aircraft must be reduced or eliminated; 

or 

(3) An alternate approval must be 

sought. 

Note: An example of such a request is an 

exemption to the applicable requirement of 

the training section of the operational rule 

under which the operation is conducted. 

b. Limitations of POI Authority. When 

applicable, POIs may approve programs 

within provisions of the FSB report and this 

AC. AC provisions apply because other 

general constraints are identified such as a 

limitation on the number of different related 

aircraft that can be used in mixed fleet flying. 

POIs shall not approve programs outside the 

bounds of FSB or AC provisions without the 

authorization of AFS–200. Deviation from 

FSB or AC provisions will be approved by 

AFS–200, only when an equivalent level of 

safety can be demonstrated. 

8. Application of FSB Requirements 

to Airmen Certification. The evaluation 

items that FSB reports specify include 

the following: 

• Knowledge; 

• Skills; 

• Abilities; 

• Maneuvers; 

• Performance criteria; and 

• Other relevant items for proficiency 

checking or other checks/tests may be 

identified. This is appropriate to 

address any aircraft-specific factors 

affecting the safe operation of that 

aircraft operated under 14 CFR. 

9. Training Device and Simulator 

Approvals. 

a. Standard Devices or Simulators. 

Standardized training methods, devices, 

or simulators are associated with each of 

the training difference levels. Devices or 

simulators are approved for particular 

operators by their POIs, consistent with 

National Simulator Program (NSP) 

qualification and FSB master 

requirements. 

b. Special Criteria. In some instances, 

standard device or simulator criteria 

may not be appropriate for new 

technology. The FSB may specify 

additional criteria in FSB reports in 

these instances. 

10. Review and Approval. This is a 

process for review of FSB evaluations 

and approval of FSB reports. 

11. Appeal of FAA Decisions. The 

Director, Flight Standards Service, AFS–

1, assigns responsibility to resolve 

appeals of the FSB findings. 

James Ballough, 

Director, Flight Standards Service. 

APPENDIX 1.—DEFINITIONS AND 

REFERENCES 

Table of Contents 

1. Definitions 

2. References (current editions) 

Appendix 1.—Definitions and References 

1. Definitions. 

Note: Definitions provided in Appendix 1 

apply exclusively to this advisory circular 

(AC). 

Aircraft Evaluation Group (AEG). FAA 

organization that sets training, checking, 

currency, pilot type rating, Master Minimum 

Equipment List (MMEL), and maintenance 

standards Maintenance Review Board (MRB) 

for assigned certificated aircraft types. AEGs 

also address operational aspects of aircraft 

type certification and resolution of service 

difficulties. 

Applicant. For the purposes of this AC, an 

applicant may be a manufacturer, modifier, 

or operator. 

Base Aircraft. An aircraft designated by the 

applicant used as a reference to compare 

differences with another aircraft. 

Candidate Aircraft. The aircraft that will be 

subjected to the FSB evaluation process 

outlined in this AC for comparison purposes. 

Common Pilot Type Rating. A pilot license 

endorsement between separate typecertificated aircraft for the purposes of pilot 

type rating that passes the testing criteria of 

the T1 (equivalence) or the T2 (handling 

characteristics) and T3 (core pilot skills with 

no greater than level D differences). A 

common pilot type rating endorsement is 

issued after a pilot has received differences 

training and checking, where required, on the 

type-certificated aircraft for which there is a 

common pilot type rating designation. The 

pilot who is receiving the additional 

endorsement must be current and qualified 

in the base aircraft; since, the check is not a 

‘‘full’’ proficiency check as defined by Title 

14 of the Code of Federal Regulations (14 

CFR), but an abbreviated differences check 


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on the differences from the base to the 

candidate aircraft. The differences check, 

unless it includes the requirements for a 

recurrent check, cannot reset the ‘‘recurrent 

clock’’ (a pilot‘s base month for checking 

purposes). 

Common Takeoff and Landing Credit 

(CTLC). CTLC is a program/process that 

allows recency of experience credit between 

related aircraft (same make) with different 

type certificate data sheets (TCDS) that can 

be demonstrated to have the same handling 

and flying characteristics during the 

following: 

• Takeoff and initial climb; and 

• Approach and landing, including the 

establishment of final landing configuration. 

Note: The T6 test is used for aircraft that 

were not tested (T2) during the initial aircraft 

evaluation for pilot type rating designation. 

Configuration. Aircraft physical features, 

which are distinguishable by pilots, with 

respect to differences in systems, cockpit 

geometry, visual cutoff angles, controls, 

displays, aircraft geometry, and/or number of 

required pilots. 

Currency. Currency is the recent 

experience necessary for the safe operation of 

aircraft, equipment, and systems as 

designated by the Flight Standardization 

Board (FSB). 

Difference Levels. Difference levels are 

formally designated levels of training 

methods or devices, checking methods, or 

currency methods that satisfy differences 

requirements between related aircraft. A 

range of five difference levels in order of 

increasing requirements, identified as A 

through E, are specified for training, 

checking, and currency purposes. 

Differences Training. Training required 

before any person may serve as a required 

crewmember on an aircraft of a type for 

which differences training is included in the 

certificate holder‘s approved training 

program. 

Differences Check. A partial proficiency 

check of the qualification of a pilot at the 

difference levels between related aircraft. A 

differences check can be between series of 

the same aircraft type certificate (TC) or 

between aircraft of separate aircraft TCs of 

the same manufacturer. 

Flight Characteristics. Flight characteristics 

are handling characteristics or performance 

characteristics perceivable by a pilot. Flight 

characteristics relate to the natural 

aerodynamic response of an aircraft, 

particularly as affected by changes in 

configuration and/or flight path parameters 

(e.g., flight control use, flap extension/ 

retraction, airspeed change, etc.). 

Flight Operations Evaluation Board 

(FOEB). The FOEB is responsible for 

preparation and revision of MMELs. The 

board members are drawn from the FAA. 

Flight Standardization Board (FSB). The 

FSB is responsible for specification of 

minimum training, checking, currency, and 

pilot type rating requirements, if necessary, 

for U.S. certificated civil aircraft. The board 

members are drawn from the FAA (AEG, 

Headquarters, Flight Standards field offices 

operations personnel). 

Handling Characteristics. The manner in 

which the aircraft responds with respect to 

rate and magnitude of pilot initiated control 

inputs to the primary flight control surfaces 

(e.g., ailerons, elevator, rudder, spoilers, 

cyclic, collective, etc.). 

Line Oriented Simulation (LOS). Use of a 

simulator in place of the aircraft to reinforce 

the understanding of differences between 

related aircraft. LOS should not be confused 

with operating experience (OE), which is 

required by 14 CFR. 

Line Operational Flying (LOF). The LOF 

phase of the test is used at the discretion of 

the FSB during the T3 test to validate the 

proposed training and checking. The LOF 

fully assesses particular difference areas, 

examines implications of mixed fleet flying, 

assesses special circumstances such as 

minimum equipment list (MEL) effects, and 

evaluates the effects of pilot errors 

potentially associated with the differences. 

Master Difference Requirements (MDR). 

MDRs are those requirements applicable to 

pilot qualifications that pertains to 

differences between related aircraft. MDRs 

are specified by the FSB in terms of the 

minimum difference levels. MDRs form the 

basis for an operator to develop their operator 

differences requirements (ODR). 

Mixed Fleet Flying. Mixed fleet flying is the 

operation of a base aircraft and one or more 

related aircraft for which credit may be taken 

for training and/or checking events. The FSB 

process defines minimum training and 

checking difference levels between related 

aircraft. 

Operational Characteristics. As used with 

respect to aircraft, means those features that 

are distinguishable by limitations, flight 

characteristics, normal procedures, 

nonnormal procedures, alternate or 

supplementary procedures, or maneuvers. 

Operator Difference Requirements (ODR). 

If differences exist within an operator‘s fleet 

that affect pilot knowledge, skills, or abilities 

pertinent to systems or procedures, ODR 

tables provide a uniform means for operators 

to comprehensively manage difference 

programs and provide a basis for FAA 

approval of mixed fleet flying. 

Pilot Type Rating. A pilot type rating is a 

‘‘one time’’, permanent endorsement on a 

pilot certificate indicating that the holder of 

the certificate has completed the appropriate 

training and testing required for its issuance 

as determined by regulation and by the 

applicable FSB report. It is recorded by the 

FAA on the pilot‘s certificate indicating the 

make, model, and series of aircraft, if 

applicable. Title 14 CFR requires a pilot type 

rating to serve as pilot-in-command (PIC) and 

in some cases as second-in-command (SIC) of 

U.S. civil large or turbojet aircraft. 

Recency of Experience. With respect to 

flight experience as required by 14 CFR, 

means a pilot’s completion of the required 

number of takeoffs and landings as sole 

manipulator of the controls within the 

preceding 90 days. 

Related Aircraft. Related aircraft are any 

two or more aircraft of the same make that 

have been demonstrated and determined to 

have commonality to the extent that credit 

between those aircraft may be applied for 

training, checking, or currency, as 

documented through MDR and approved by 

the FSB. 

Same Pilot Type Rating. A pilot type rating 

assigned when no greater than a level D 

training difference is determined between 

aircraft with the same aircraft TCs (series). 

Series. Aircraft sharing the same aircraft 

type certification with specific variations that 

are usually defined by the manufacturer and 

usually result in an amended aircraft TC. 

Supplementary Procedures. Those 

procedures that are identified in the Flight 

Crew Operation Manual (FCOM) under the 

section ‘‘Supplementary Procedures’’

describing procedures not described under 

the ‘‘Normal Procedures’’ or ‘‘Nonnormal 

Procedures’’ sections. 

Supervised Line Flying (SLF). Supervised 

experience associated with the introduction 

of equipment or procedures requiring post 

qualification skill enhancement during 

which a pilot occupies a specific pilot 

position and performs particular assigned 

duties for that pilot position under the 

supervision of a qualified company instructor 

or check airman. 

Training Footprint. A training footprint is 

a summary description of a training program, 

usually in short tabular form, showing 

training subjects, modules, procedures, 

maneuvers or other program elements, which 

are planned for completion during each day 

or phase of training. 

2. References (Current Editions) 

• Title 14 CFR parts 1, 61, 91, 135, and 

121. 

• Order 8400.10, Air Transport Operations 

Inspector’s Handbook. 

• AC 61–89, Pilot Certificates, Aircraft 

Type Ratings. 

• AC 120–35, Line Operational 

Simulations: Line Oriented Flight Training, 

Special Purpose Operational Training, Line 

Operational Evaluation. 

• AC 120–40, Airplane Simulator 

Qualification. 

• AC 120–45, Airplane Flight Training 

Device Qualification. 

• AC 120–51, Crew Resource Management 

Training. 

• FAA–S–8081–5, Aircraft Type Rating 

Practical Test Standards for Airplane. 

APPENDIX 2.—PILOT 

QUALIFICATION AND PILOT RATING 

REQUIREMENTS 

Table of Contents 

1. Purpose 

2. Focus 

3. Introduction 

a. A Comprehensive System for Pilot 

Qualification 

b. Master Differences Requirements (MDR) 

Set by FAA 

c. Specifications of Constraints or Credits 

d. Recognition of Unique Operator 

Characteristics 

e. Basis for Requirements 

f. Relation to Other FAA Policies 

4. Concepts 

a. An Integrated System for Pilot 

Qualification 

b. MDRs 

c. Difference Levels 

d. Training Difference Levels 

e. Checking Difference Levels 

f. Currency Difference Levels 


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g. Operating Experience (OE) for Aircraft 

h. Supervised Line Flying (SLF) 

i. Recency of Experience 

j. Operator Difference Requirements (ODR) 

5. Formulation of FSB Reports, MDRS, and 

Designation of Pilot Type Ratings 

a. Requirements Formulation Process 

Overview 

b. Proposals for MDRs, Example ODRs, and 

Special Requirements 

c. Difference Level Tests 

d. FSB Assessments and Proposal 

Formulation 

e. Comments Solicited 

f. FSB Determinations and Findings 

g. FSB Report Preparation Distribution and 

FAA Application 

h. FSB Report Revision 

6. Operator’s Application of FSB Provisions, 

Preparations, Use, and Revision of ODRS 

a. General 

b. Application of MDRs and Preparation 

and Use of ODRs 

c. Selecting Base Aircraft 

d. Identification of Differences and the 

Analysis of Effects of Those Differences 

e. Identification of Compliance Methods 

f. When Proposed ODR Compliance 

Methods Do Not Meet MDRs 

g. Maximum Number of Related Aircraft 

h. Application, Review and Approval 

i. Implementation Provisions Transition 

Period 

j. ODR Revision 

7. FAA Review and Approval of Operator 

Programs 

a. General 

b. Operator’s Application of ODRs 

c. Base and Other Aircraft Identification 

d. Approval of ODRs 

e. POI Uncertainty Regarding Program 

Compliance 

f. Proposals That Do Not Comply With FSB 

Provisions 

g. FSB Revision of MDRs or Other FSB 

Provisions 

h. Proving Tests 

i. Line-Oriented Flight Training (LOFT), 

LOS, or SLF 

j. OE 

k. Limitations on the Total Number of 

Related Aircraft 

l. Compliance Checklist for CHDOs 

m. Implementation of FSB Provisions 

n. Aircraft That Do Not Have an FSB 

Report 

8. Application of Requirements to Airmen 

Certification 

a. General 

b. Checking Specifications 

c. Checks Regarding Complex Systems 

9. Training Device and Simulator Approval 

a. Training Device and Simulator 

Characteristics 

b. Aircraft/Simulator/Device Compatibility 

c. Simulator and Device Approvals 

10. Review and Approval 

11. Appeal of FAA Decisions 

Illustrations 

Figure 1 Master Difference Requirements 

(MDR) Table Example 

Figure 2 Difference Level Table 

Figure 3–1 Design Operator Differences 

Requirements Table Example 

Figure 3–2 Systems Operator Differences 

Requirements Table Example 

Figure 3–3 Maneuver Operator Difference 

Requirements Table Example 

Figure 4 Master Requirements Formulation 

Figure 5 Test Definitions 

Figure 6 ‘‘T’’ Tests 1 Thru 5 

Figure 7 Standard Method, Devices, and 

Simulators 

Figure 8 FSB Process 

APPENDIX 2.—PILOT QUALIFICATION 

AND PILOT RATING REQUIREMENTS 

1. Purpose 

This appendix provides a comprehensive 

description of the system for pilot 

qualifications outlined in this advisory 

circular (AC). It includes definitions, criteria, 

processes, tests, methods, and procedures 

necessary for uniform application of the 

system. 

2. Focus 

The appendix applies to and is used by: 

a. Aircraft manufacturers or modifiers who 

design, test, and certificate Title 14 of the 

Code of Federal Regulations (14 CFR) parts 

23, 25, 27, and 29 aircraft. 

b. Operators who operate under 14 CFR. 

c. Operator, manufacturer, or other training 

centers having programs approved for use 

under 14 CFR. 

d. Federal Aviation Administration (FAA) 

offices and inspectors administering 

programs under 14 CFR. 

3. Introduction 

a. A Comprehensive System for Pilot 

Qualification. This AC and its appendices 

provide a systematic means to address 

requirements for training, checking, and 

currency within applicable 14 CFR parts. 

Definitions, criteria, processes, procedures, 

tests, and methods are consistent with and 

clarify application of current rules in 

particular situations for specific aircraft. This 

AC provides a comprehensive system for the 

FAA and industry to describe, evaluate, and 

approve use of particular aircraft and 

operator programs. The respective roles of 

training, checking, currency and airmen 

certification are clarified. This includes 

defining the role and criteria for designation 

of pilot type ratings for existing, new, or 

modified aircraft. The system is particularly 

suited to addressing transition, differences 

programs, and mixed fleet flying. The system 

aids in assuring that pilots attain and 

maintain the knowledge, skills, and abilities 

needed to operate assigned aircraft safely. 

b. Master Differences Requirements (MDRs) 

Set by FAA. The FAA’s Flight 

Standardization Board (FSB) sets MDRs to 

address differences between related aircraft. 

c. Specification of Constraints or Credits. 

The system permits the specification of 

constraints or permissible credits. 

Constraints or credits may relate to 

knowledge, skills, abilities, devices, 

simulators, maneuvers, checks, currency, or 

any other such factors necessary for safe 

operations. Constraints or credits may apply 

generally to aircraft, particular pilot 

positions, or other situations or conditions. 

d. Recognition of Unique Operator 

Characteristics. The system recognizes the 

unique characteristics of individual operators 

while achieving uniformity in application of 

FAA safety standards. FAA MDRs determine 

uniform bounds to tailor individual 

operator’s unique requirements to a 

particular fleet and situation. Principal 

operations inspectors (POI) approve each 

operator’s unique requirements within FAA 

MDRs. Operator unique requirements 

accommodate particular combinations of 

related aircraft flown, pilot assignment 

policies, training methods and devices, and 

other factors that relate to the application of 

the FAA MDRs. Accordingly, the system 

preserves operator flexibility while 

standardizing the FAA’s role in review, 

approval, and monitoring of training, 

checking, and currency programs within 14 

CFR. 

e. Basis for Requirements. The 

determination of pilot type rating, minimum 

differences training, checking and currency 

requirements focus on basic operation of 

aircraft in the National Airspace System 

(NAS) under both instrument flight rules 

(IFRs) and visual flight rules (VFR). Included 

are all flight phases from preflight to 

shutdown under both normal and nonnormal 

conditions. 

f. Relationship to Other FAA Policies. 

Although this AC, and the FSB requirements 

in some instances, address particular types of 

operations or specific aircraft systems (e.g., 

use of flight guidance control systems for 

Category II/III instrument approaches, longrange navigation, etc.), other ACs address 

these issues more thoroughly. This AC and 

FSB requirements address such issues only to 

the extent necessary to assure that pilots are 

qualified to operate pertinent systems or 

equipment as part of initial or continuing 

qualification. 

4. Concepts 

a. An Integrated System for Pilot 

Qualification. 

(1) System Elements. An integrated FAA/ 

applicant system and process established to 

determine appropriate requirements, applies 

the requirements, and meets those 

requirements on a continuing basis, for 

uniform pilot qualification. 

(2) System Overview. The system uniformly 

applies FAA master requirements in a way 

that tailors a particular aircraft to any 

operator’s unique situation or fleet. The FAA 

approves unique operator and fleet 

requirements for each operator based on FAA 

master requirements. The system develops 

FAA master requirements based on objective 

criteria and tests, with applicants’ support for 

analysis and testing. FSB reports for related 

aircraft describe FAA master requirements. 

MDRs express FAA master requirements. 

Minimum acceptable difference levels 

between related aircraft articulate MDRs. An 

operator’s training program, checklist, 

operations manuals, pilot certification, CTLC 

programs, and other such approvals are byproducts of compliance with MDRs. 

Operators comply with MDRs using unique 

ODRs, tailored to that operator’s programs 

and approved by the FAA. ODRs, based on 

and in compliance with the MDRs, specify 

requirements uniquely applicable to a 

particular operator’s mixed fleet flying 

situation. An operator’s specific document 


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describes ODRs by identifying a base aircraft, 

differences between related aircraft, and that 

operator’s compliance methods for each 

related aircraft. Paragraph 4j describes ODRs. 

Paragraph 6 describes ODR preparation and 

use. Paragraph 7 describes FAA approval of 

ODRs. 

b. MDRs. 

(1) MDR Applicability. MDRs are those 

requirements applicable to pilot qualification 

that pertain to differences between related 

aircraft. MDRs specify the minimum 

acceptable difference levels between related 

aircraft that may be approved for operators. 

One related aircraft is selected by the 

applicant as a reference for comparison 

purposes and is considered a base aircraft. 

This is typically the first aircraft on which 

pilots are qualified, or is the aircraft of which 

an operator has the largest number. 

Difference levels between the base aircraft 

and other related aircraft then specify the 

minimum difference requirements to be met 

for pilot qualification. Major differences in a 

particular fleet are defined between groups of 

related aircraft rather than specifying 

differences between each possible 

configuration and combination of 

configurations between related aircraft. 

MDRs are specified in terms of training 

difference levels described in paragraph 4d 

and are shown on an MDR table. 

(2) MDR Content. MDRs specify the 

minimum training, checking, and currency 

acceptable to the FAA for pilot qualification 

regarding differences. 

(3) MDR Formulation, Description, and 

Revision. MDRs are formulated by the FAA 

FSB for each related aircraft. MDRs are 

originally specified when an aircraft is first 

type certificated. MDRs are formulated using 

standardized tests and evaluations in 

conjunction with the type certification or 

supplemental type certification process. 

MDRs are based on an applicant’s (usually an 

aircraft manufacturer) proposal, FAA 

evaluation of that proposal, OE, and test 

results when tests are necessary. FSB 

determinations also consider operator 

recommendations, safety history, and other 

relevant information. MDRs are described in 

provisions of an FSB report and may be 

revised if necessary. MDRs are revised when 

aircraft are developed or modified, tests or 

OE shows a need for revision, a revision is 

requested by an applicant and evidence 

indicates the need for revision, or rules or 

FAA policies change. MDRs are revised by a 

process similar to that used for initial 

formulation of requirements. 

(4) MDR Use. MDRs are applied to specific 

operators through formally described ODRs 

that are developed by and tailored to each 

operator. FAA field offices use the MDRs as 

the basis for approval of individual operator’s 

differences programs for approval of initial or 

transition programs where credit for previous 

training or experience with other related 

aircraft is sought. 

(5) The MDR Table. An example of typical 

MDRs for the B–737–200, –300, –400, –500, 

–600, –700, –800, and –900 is shown in 

Figure 1. MDR table requirements are shown 

for each pair of aircraft by notations in each 

element of corresponding columns and rows 

of the table. Each element of the table 

identifies the minimum differences training, 

checking, and currency requirements 

applicable to mixed fleet flying. The MDR 

table identifies a pertinent base aircraft and 

particular aircraft for which requirements are 

sought. Note the minimum difference levels 

that correspond to the pertinent column and 

row, and special requirements in footnotes, if 

applicable. 

(6) Use of Higher or Lower Difference 

Levels. Operators must satisfy difference 

requirements by using the methods 

acceptable for the specified level or a higher 

level. Lower level methods may be used in 

addition to the required levels but may not 

substitute for the required level or be used 

exclusively instead of the required level. 


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(7) Differences Within a Series. Differences 

may exist even within series shown on an 

MDR table, such as within the A–318/319/ 

320/321 series. MDR elements may show 

requirements from one series to another 

identified in the footnotes. Such 

requirements, however, apply only if 

pertinent differences exist between those 

aircraft. 

(8) More Than Two Related Aircraft. When 

pilot assignments apply to more than two 

related aircraft, such as the A–320, A–330, 

and A–340, each pertinent requirement of the 

MDR table applies. Applications of multiple 

requirements for flying two or more related 

aircraft and certain limits to flying large 

numbers of related aircraft are described in 

paragraph 7k. 

(9) Special Requirements. 

(10) MDR Footnotes. Footnotes can be used 

to credit, constrain, or set alternate levels 

when special situations apply. Use of 

footnotes permits accommodation of 

variations in installed equipment, options, 

pilot knowledge or experience on other 

aircraft, training methods or devices, or other 

factors that are not addressed by basic levels 

between aircraft. For example, a footnote may 

allow credit or apply constraints to the use 

of a particular flight guidance control system 

(FGCS), flight management system (FMS), or 

electronic flight instrument system (EFIS), 

which is installed on aircraft. Footnotes are 

an appropriate means to address 

requirements that relate to specific systems 

(e.g., flight director and FMS) rather than a 

particular aircraft. In such instances, generic 

knowledge or experience with the particular 

system may be readily transferable between 

related aircraft. Footnotes may also be used 

to set different requirements for initial 

training or checking rather than for recurrent 

training or checking. When necessary, 

footnotes are fully described in the body of 

the FSB report. 

(a) Other Limitations. Other limitations 

may occasionally be identified within a 

difference level (e.g., C*/C*/C). The asterisk 

following the difference level in such 

instances identifies a special requirement or 

limitation pertaining to a particular training 

method or device. Such notes typically relate 

to acceptable training device characteristics 

when the simulator evaluation and approval 

process or standard criteria of this AC are not 

available to address a particular situation 

appropriately. 

(11) MDRs for Aircraft With the Same or 

Common Pilot Type Ratings. A single FSB 

report and MDR table may apply to aircraft 

that are assigned the same pilot type rating 

(same aircraft TC). For example, a single 

MDR table may cover the A–318/319/320/321 

that have a same pilot type rating. A single 

FSB report and MDR table may also apply to 

aircraft that are assigned a common pilot type 

rating. For example, a single MDR table may 

cover both the B–767 and B–757 that have a 

common pilot type rating. When level E 

training is required for an aircraft with the 

same aircraft TC and an additional pilot type 

rating is assigned, such as the B–747 and B–


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747–400, a single MDR table for all series of 

a type-certificated aircraft still applies. 

(12) Minimum acceptable difference levels 

are assigned based on standard tests 

described in Appendix 3. 

c. Difference Levels. 

(1) General Description. Difference levels 

are formally designated levels of training 

methods or devices, checking methods, or 

means of maintaining currency that satisfy 

minimum difference requirements or pilot 

type rating requirements. Difference levels 

specify FAA requirements proportionate to 

and corresponding with increasing 

differences between related aircraft. A range 

of five difference levels in order of increasing 

requirements, identified as A through E, are 

each specified for training, checking, and 

currency. MDRs are specified in terms of 

difference levels. Difference levels are used 

to credit knowledge, skills, and abilities 

applicable to an aircraft for which a pilot is 

already qualified and current, during initial, 

transition or upgrade training for other 

related aircraft. Operators, who conduct 

mixed fleet flying where credit is sought, 

should apply difference levels and address 

all mixed fleet flying requirements to ensure 

compliance with FAA requirements 

necessary to assure safe operations. 

(2) Basis for Levels. Difference levels apply 

when a difference with potential to affect 

fight safety exists between related aircraft. 

Differences may also affect knowledge, skills, 

or abilities required of a pilot. If no 

differences exist or if differences exist but do 

not affect knowledge, skills, abilities or flight 

safety, then difference levels are not assigned 

or applicable to pilot qualification. When 

difference levels A through E apply, each 

difference level is based on a scale of 

differences in design features, systems, or 

maneuvers. In assessing the effects of 

differences, both flight characteristics and 

procedures are considered, since flight 

characteristics address handling qualities and 

performance, while procedures include 

normal and abnormal/nonnormal/emergency 

items. 

(3) Relationship Between Training, 

Checking, and Currency Levels. While 

particular aircraft are often assigned the same 

level (e.g., C/C/C) for training, checking, and 

currency, such assignment is not necessary. 

Levels may be assigned independently. For 

example, an aircraft may be assigned level C 

for training, level D for checking, and level 

C for currency (e.g., C/D/C). 

(4) Designation of a Pilot Type Rating. 

Candidate aircraft having the same TC are 

assigned the same pilot type rating if training 

differences are not greater than level D. 

Candidate aircraft having different TCs that 

have training differences no greater than 

level D may be assigned a common pilot type 

rating. A candidate aircraft is assigned a 

different pilot type rating when difference 

training level E is required. When different 

pilot type ratings are assigned because of one 

or more candidates requiring level E training, 

pilot type ratings may be assigned to related 

aircraft consistent with a logical grouping of 

the most similarly related aircraft. 

d. Training Difference Levels. 

(1) Level A Training. Level A difference 

training is that differences training between 

related aircraft that can adequately be 

addressed through self-instruction. Level A 

training represents a knowledge requirement 

that, once appropriate information is 

provided, understanding and compliance can 

be assumed. Level A compliance is achieved 

by such methods as issuance of operating 

manual page revisions, dissemination of 

operating bulletins, or differences handouts 

to describe minor differences in aircraft. 

Level A training is limited to the following 

situations: 

(a) A change that introduces a different 

version of a system/component for which the 

pilot has already shown the ability to 

understand and use (e.g., an updated version 

of an engine). 

(b) A change that results in minor or no 

procedural changes and does not adversely 

affect safety if the information is not 

reviewed or forgotten (e.g., a different 

vibration damping engine mount is installed, 

expect more vibration in descent; logo lights 

are installed, use is optional). 

(c) Information that highlights a difference, 

which is evident to the pilot, inherently 

obvious, and easily accommodated (e.g., 

different location of a communication radio 

panel, a different exhaust gas temperature 

limit that is placarded, or changes to 

nonnormal ‘‘read and do’’ procedures). 

(2) Level B Training. Level B difference 

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, emphasize 

issues, provide a standardized method of 

presenting material, or aid retention of 

material following training. Level B aided 

instruction can utilize slide/tape 

presentations, computer based tutorial 

instruction, stand-up lectures or video tapes. 

Situations not covered under the provisions 

of level A training may require level B (or 

higher levels) if certain tests described in 

later paragraphs fail. 

(3) Level C Training. Level C differences 

training can only be accomplished through 

use of devices that are capable of systems 

training. Level C differences training is 

applicable to related aircraft having part task 

differences that affect skills or abilities and 

knowledge. Training objectives focus on 

mastering individual systems, procedures, or 

tasks, as opposed to performing highly 

integrated flight operations and maneuvers in 

‘‘real time.’’ Level C may require selfinstruction or aided instruction, but cannot 

be adequately addressed by a knowledge 

requirement alone. Training devices are 

required to supplement instruction, ensure 

attainment or retention of pilot skills and 

abilities, and accomplish the more complex 

tasks, usually related to operation of 

particular aircraft systems. While level C 

systems knowledge or skills relate to specific 

rather than fully integrated tasks, 

performance of steps to accomplish normal, 

nonnormal, alternate, recall procedures, or 

maneuvers related to particular systems (e.g., 

flight guidance control systems/flight 

management systems) may be necessary. 

Typically, the minimum acceptable training 

media for level C training would be 

interactive computer-based training, cockpit 

systems simulators, cockpit procedure 

trainers or part task trainers (e.g., FMS or 

traffic collision avoidance system (TCAS)). 

(4) Level D Training. Level D training can 

only be accomplished with devices capable 

of performing flight maneuvers and 

addressing full task differences of knowledge, 

skills, and/or abilities. Devices capable of 

flight maneuvers address full task 

performance in a dynamic real time 

environment. The devices enable integration 

of knowledge, skills, and abilities in a 

simulated flight environment, involving 

combinations of operationally oriented tasks 

and realistic task loading for each relevant 

phase of flight. Level D training, knowledge, 

and skills to complete necessary normal, 

nonnormal, alternate, or recall procedures are 

fully addressed for each related aircraft. 

Level D differences 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. The differences are not so 

significant that a full transition training 

course is required. If demonstrating 

interrelationships between the systems is 

important, use of a series of separate devices 

for systems training will not suffice. Training 

for level D differences requires a training 

device that has accurate, high fidelity 

integration of systems and controls, and 

realistic instrument indications. Level D 

training may also require maneuvers, visual 

cues, motion cues, dynamics, control loading 

or specific environmental conditions. 

Weather phenomenon such as low visibility, 

CAT III, or windshear may or may not be 

incorporated. Where simplified or generic 

characteristics of an aircraft type are used in 

devices to satisfy difference level D training, 

significant negative training must not occur 

as a result of the simplification. Typically, 

the minimum acceptable training media for 

level D training would be flight training 

device level 6. 

(5) Level E Training. Level E training is 

applicable to candidate aircraft having such 

significant full task differences that require a 

‘‘high fidelity’’ environment to attain or 

maintain knowledge, skills, or abilities. 

Training at level E can only be satisfied by 

the use of a simulator qualified at level C or 

D consistent with FAA criteria. Level E 

training, if done in an aircraft, should be 

modified for safety reasons where maneuvers 

can result in a high degree of risk (i.e., an 

engine set at idle thrust to simulate an engine 

failure). As with other levels, when level E 

training is assigned, suitable credit or 

constraints may be applied for knowledge, 

skills, and/or abilities related to other 

pertinent related aircraft. Credits or 

constraints are specified for the subjects, 

procedures, or maneuvers shown in FSB 

reports and are applied through the ODR 

table. 

Note: Training differences levels specified 

by the FSB represent minimum requirements. 

Operators may use a device associated with 

a higher difference level to satisfy a training 

differences requirement. For example, if level 

C differences are assessed due to installation 

of a different FMS, operators may train pilots 

using the FMS installed in a full flight 

simulator (FFS) as a system trainer if a 


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dedicated part task FMS training device is 

not available. 

e. Checking Difference Levels. 

(1) Initial and Recurrent Checking. 

Difference checking addresses any pertinent 

pilot testing or certification that includes 

pilot type rating checks, proficiency checks, 

Advanced Qualification Program (AQP) 

evaluations, and any other checks specified 

by FSB reports. Initial and recurrent checking 

levels are the same unless otherwise 

specified by the FSB. In certain instances, it 

may be possible to satisfactorily accomplish 

recurrent checking objectives in devices that 

do not meet initial checking requirements. In 

such instances, the FSB may recommend 

certain devices that do not meet initial check 

requirements for use to administer recurring 

checks. The POI/Training Center Program 

Manager, in coordination with the FSB, may 

require checking in the initial level device 

when doubt exists regarding pilot 

competency or program adequacy. 

(2) Level A Checking. Level A checking 

indicates that no check related to differences 

is required at the time of differences training. 

A pilot is responsible for knowledge of each 

related aircraft flown. Differences items 

should be included as an integral part of 

subsequent recurring proficiency checks. 

(3) Level B Checking. Level B checking 

indicates that a ‘‘task’’ or ‘‘systems’’ check is 

required following transition and recurring 

differences training. Level B checking 

typically applies to particular tasks or 

systems such as FMS, TCAS, or other 

individual systems or related groups of 

systems. 

(4) Level C Checking. Level C checking 

requires a partial proficiency check using a 

device suitable for meeting level C (or higher) 

differences training requirements following 

transition and recurrent differences training. 

The partial check is conducted relative to 

particular maneuvers or systems designated 

by the FSB. Example of a level C check: 

Evaluation of a sequence of maneuvers 

demonstrating a pilot’s ability to use a FGCS 

or FMS. An acceptable scenario would 

include each relevant phase of flight that 

uses the FGCS or FMS. 

(5) Level D Checking. Level D checking 

requires a partial proficiency check for one 

or more related aircraft following both 

transition and recurrent training. The partial 

proficiency check covers the particular 

maneuvers, systems, or devices designated by 

the FSB. Level D checks are performed using 

scenarios representing a ‘‘real time’’ flight 

environment and devices permitted for level 

D differences training. A full proficiency 

check is typically conducted on the base 

aircraft, and a partial proficiency check on 

the related aircraft, covering all pertinent 

differences. 

(6) Level E Checking. Unless specified, 

level E checking requires that a full 

proficiency check be conducted in a level C 

or D FFS. As with other levels, when level 

E checking is assigned, suitable credit or 

constraints may be applied for knowledge, 

skills, and/or abilities related to other 

pertinent related aircraft. Credits or 

constraints are specified for the subjects, 

procedures, or maneuvers shown in FSB 

reports and are applied through the ODR 

table. 

Note: Assignment of level E checking 

requirements alone does not result in 

assignment of a separate pilot type rating. 

Only the assignment of level E training 

requirements may result in assignment of a 

separate pilot type rating. 

f. Currency Difference Levels. The term 

‘‘currency’’ as used in this AC addresses 

recent experience necessary for safe 

operation of aircraft as designated by the 

FSB. Currency issues not specified by the 

FSB are covered by regulation. 

(1) Level A Currency. Level A currency is 

considered common to each related aircraft. 

Thus, assessment or tracking of currency for 

separate related aircraft is not necessary or 

applicable. Maintenance of currency in any 

one related aircraft or a combination of 

related aircraft will suffice for any other 

related aircraft. 

(2) Level B Currency. Level B currency is 

‘‘knowledge related’’ currency, typically 

achieved through self-review by individual 

pilots for a particular aircraft. Self-review is 

usually accomplished by review of material 

provided by the operator to pilot. Such 

currency may be undertaken at an individual 

pilot‘s initiative; however, the operator must 

identify the material and the frequency or 

other situations in which the material should 

be reviewed. Self-review may be based on 

manual information, bulletins, aircraft 

placards, memos, class handouts, videotapes, 

or other memory aids that describe the 

differences, procedures, maneuvers, or limits 

for the pertinent aircraft that pilots are flying. 

Examples of acceptable compliance with 

level B currency are: 

(a) The issuance of a bulletin that directs 

pilots to review specific operating manual 

information before flying a related aircraft. 

Level B currency may be regained by review 

of pertinent information to include bulletins, 

if that related aircraft has not been flown 

within a specified period (e.g., fly that related 

aircraft or have completed a review of the 

differences in limitations and procedures 

within a specified number of days). 

(b) Pilot certification on a dispatch release 

that they have reviewed pertinent 

information for a particular related aircraft to 

be flown on that trip. Level B currency 

cannot, however, be achieved solely by 

review of class notes taken by and at the 

initiative of an individual pilot unless the 

adequacy of those notes is verified by the 

operator. 

(3) Level C Currency. Level C currency is 

applicable to one or more designated systems 

or procedures, and relates to both skill and 

knowledge requirements. An example would 

be establishment of FMS currency, flight 

guidance control system currency, or other 

particular currency that is necessary for safe 

operation of a related aircraft. Establishment 

of level C for a related aircraft with an FMS 

would typically require a pilot to fly that 

related aircraft within the specified period of 

time or re-establish currency. Currency 

constraints for level C are established by the 

FSB. When level C currency applies, 

pertinent level B currency must also be 

addressed. Examples of methods acceptable 

for addressing level C currency are: 

(a) Pilot scheduling practices resulting in a 

pilot being scheduled to fly a related aircraft 

with the pertinent system/procedure within 

the specified period of time; 

(b) Tracking of an individual pilot’s flying 

of related aircraft to ensure that the particular 

system/procedure has been flown within the 

specified period of time; 

(c) Use of a higher level method (level D 

or E currency); or 

(d) Other methods as designated or found 

acceptable by the FSB. 

(4) Re-establishing Level C Currency. When 

currency is lost, currency may be reestablished by completing required items 

using a device equal to or higher than that 

specified for level C differences training and 

checking. Other means to re-establish 

currency include flights with an 

appropriately qualified check airman/ 

instructor, completion of proficiency 

training, or a proficiency check. In some 

instances, a formal refamiliarization period 

in the actual aircraft with the applicable 

system operating while on the ground may be 

acceptable if permitted by the FSB. Such 

refamiliarization periods are completed using 

an operator-established procedure under the 

supervision of a pilot designated by the 

operator. In the case of a noncurrent SIC, a 

designated pilot-in-command (PIC) may be 

authorized to accompany a pilot to reestablish currency. 

(5) Level D Currency. Level D currency is 

related to designated maneuvers, and 

addresses knowledge and skills required for 

performing aircraft control tasks in real time, 

with integrated use of associated systems and 

procedures. Level D currency may also 

address certain differences in flight 

characteristics including performance of any 

required maneuvers and related normal/ 

abnormal/emergency procedures for a 

particular related aircraft. A typical 

application of level D currency is to specify 

selected maneuvers, such as takeoff, 

departure, arrival, approach, or landing, 

which are to be performed using a particular 

FGCS and instrument display system. Either 

a pilot must fly a related aircraft equipped 

with the FGCS and particular display system 

sufficiently often to retain familiarity and 

competence within the specified currency 

period, or currency must be re-established. 

Currency constraints for level D are 

established by the FSB. When level D 

currency applies, pertinent level B and level 

C currency must also be addressed. Examples 

of methods acceptable for addressing level D 

currency are: 

(a) Tracking of flights by a particular pilot 

in a particular related aircraft to assure 

experience within the specified currency 

period. 

(b) Tracking the completion of specific 

maneuvers based on logbook entries, Aircraft 

Communication Addressing and Reporting 

System (ACARS) data, or other reliable 

records to assure experience within the 

specified currency period. 

(c) Scheduling of aircraft or pilots to permit 

currency requirements to be met with 

verification that each pilot has actually 

accomplished the assigned or an equivalent 

schedule. 

(d) Completion of pilot certification, 

proficiency check, proficiency training, AQP 

evaluations, or other pertinent events in 


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which designated maneuvers are performed 

in a device or simulator acceptable for level 

D currency. 

(e) Use of a higher level method (level E 

currency). 

(f) Other methods as designated or found 

acceptable by the FSB. 

(6) Re-establishing Level D Currency. When 

currency is lost, currency may be reestablished by completing pertinent 

maneuvers using a device equal to or higher 

than that specified for level D differences 

training and checking. Other means to reestablish currency include flight with an 

appropriately qualified check airman during 

training or in line operations, completion of 

proficiency training, a proficiency check, or 

AQP proficiency evaluation. 

(7) Level E Currency. Level E currency may 

specify system, procedure, or maneuver 

currency item(s) necessary for safe 

operations, as identified by the FSB, to be 

accomplished in a Level C/D simulator for 

that related aircraft. FSB provisions related to 

takeoff and landing are applied in a way that 

addresses needed system or maneuver 

experience. For example, if FGCS, FMS, 

EFIS, navigation, or other system or 

maneuver experience is the basis for a 

currency requirement, approval of an 

operator’s program at level E includes the use 

of those systems in conjunction with 

satisfying takeoff and landing requirements. 

In this instance, making three simulator 

takeoffs and landings in VFR closed traffic 

without using the FGCS, EFIS, or FMS may 

not be sufficient to meet level E currency 

requirements. 

Note: Assignment of level E currency 

requirements does not result in assignment of 

a separate pilot type rating. Only the 

assignment of level E training requirements 

may result in assignment of a separate pilot 

type rating. 

(8) Re-establishing Level E Currency. When 

currency is lost, currency may be reestablished by completing pertinent 

maneuvers using a device specified for level 

E differences training and checking. Other 

means to re-establish currency include flight 

with an appropriately qualified check airman 

during training or in line operations, 

completion of proficiency training, a 

proficiency check, or AQP evaluation. 

(9) Competency Regarding Abnormal/ 

Nonnormal/Emergency Procedures. 

Competency for nonnormal maneuvers or 

procedures is generally addressed by 

checking requirements; however, in 

particular abnormal/nonnormal/emergency 

maneuvers or procedures may not be 

mandatory for checking or training. In this 

situation, it may be necessary to periodically 

practice or demonstrate those maneuvers or 

procedures even though it is not necessary to 

complete them during each check. In such 

instances, the FSB may specify a currency 

requirement for training or checking 

applicable to abnormal/nonnormal/ 

emergency maneuvers or procedures that are 

to be performed. This is to assure that 

extended periods of time do not elapse in a 

series of repeated training and checking 

events in which significant maneuvers or 

procedures may never be accomplished. 

When an abnormal/nonnormal/emergency 

maneuver or procedure is not mandatory and 

is not accomplished during each proficiency 

training or proficiency check, but is still 

important to occasionally practice or 

demonstrate, the FSB may establish a 

currency requirement. When designated by 

the FSB, these currency requirements 

identify each abnormal/nonnormal/ 

emergency maneuver or procedure, the 

currency level applicable, and an applicable 

time period or any other necessary/ 

appropriate constraints. 

(10) Difference Level Summary. Difference 

levels are summarized in Figure 2 below for 

training, checking, and currency. Complete 

descriptions of difference levels for training, 

checking and currency are given above. 

FIGURE 2.—DIFFERENCE LEVEL TABLE

Difference level Training Checking Currency 

A .......................................... Self instruction .................................. Not applicable (or integrated with

next proficiency check).

Not applicable. 

B .......................................... Aided instruction ............................... Task or system check ...................... Self review. 

C .......................................... Systems devices .............................. Partial check using device ............... Designated system. 

D .......................................... Maneuver devices * .......................... Partial proficiency check using device *.Designed maneuver(s). 

E .......................................... Simulator c/d or aircraft # ................ Proficiency check using simulator c/ 

d or aircraft *.

Designed maneuver(s) except takeoff and landings. 

# = New pilot type rating is normally assigned. 

* = FFS or aircraft may be used to accomplish specific maneuvers. 

g. Operating Experience (OE) for Aircraft. 

(1) Application of OE. Requirements for OE 

are consistent with provisions for OE 

specified under 14 CFR. 

(2) Credits or Constraints. OE must meet 

the applicable requirements of the CFR part 

under which operations are conducted, 

except that credit for applicable OE in other 

related aircraft may be permitted. When 

approved by the FAA, OE associated with 

differences may be accomplished as part of 

or in conjunction with line oriented 

simulation (LOS). 

h. Supervised Line Flying (SLF). 

Experience associated with the introduction 

of equipment or procedures requiring post 

qualification skill enhancement during 

which a pilot occupies a specific pilot 

position and performs particular assigned 

duties for that pilot position under the 

supervision of a pilot instructor or check 

airman qualified for the operator. One or 

more of the reasons described below may 

apply: 

(1) Introduction of new systems (e.g., Local 

Area Augmentation System (LAAS), 

Automatic Dependent Surveillance Broadcast 

(ADS–B), runway area advisory system 

(RAAS), etc). 

(2) Introduction of new operations (e.g., 

oceanic operations, Extended-Range 

Operations with Two-Engine Airplanes 

(ETOPS)). 

(3) Experience for a particular pilot 

position (e.g., PIC, SIC). 

(4) Special characteristics (e.g., effects of 

unique airports, mountainous areas, unusual 

weather, special air traffic control 

procedures, or nonstandard runway surfaces) 

on this aircraft. 

i. Recency of Experience. Credit towards 

the recency of experience requirements of 14 

CFR may be permitted for takeoffs and 

landings performed in related aircraft as 

provided by CTLC. CTLC must be validated 

through the FSB process and must be carried 

out in accordance with (IAW) the operator’s 

CTLC approved program. 

j. Operator Difference Requirements (ODR). 

(1) ODR Purpose. If differences exist within 

an operator’s fleet, which affect pilot 

knowledge, skills, or abilities pertinent to 

systems or procedures, ODR tables provide a 

uniform means for operators to 

comprehensively manage difference 

programs and provide a basis for FAA 

approval of mixed fleet flying. 

(2) ODR Content. ODRs identify a base 

aircraft, describe differences between aircraft, 

and show an operator’s methods of 

compliance with FAA requirements. The 

FAA approves an operator’s initial ODR and 

each subsequent revision for the following: 

(a) Base Aircraft. ODRs identify an aircraft 

or group of aircraft (aircraft of the same series 

with minor configuration differences) within 

an operator’s fleet as a base aircraft. The base 

aircraft serves as a reference for comparison 

with candidate aircraft. Selection criteria and 

characteristics of base aircraft are described 

in paragraphs 6c and 7c. 

(b) Candidate/Related Aircraft. ODRs 

identify particular aircraft flown by an 

operator within each fleet. ODRs consider 

only those aircraft and combinations of 

aircraft actually flown by that operator. ODRs 

describe differences within an operator’s fleet 

between the base aircraft and other related 

aircraft. 

(c) Significance of Differences. Differences 

are described in summary form and are 


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categorized by differences in design features, 

systems, and maneuvers. Differences are 

evaluated relative to their effect on either 

flight characteristics, pilot skills, and/or 

procedures. Procedures consider normal, 

nonnormal, alternate, and recall items. 

Limitations are considered in conjunction 

with normal procedures. 

(d) Compliance Methods. ODRs show how 

each operator’s program addresses 

differences, through description of training, 

checking, or currency methods for each fleet. 

ODRs describe the specific or unique 

constraints or credits applicable, and any 

precautions necessary to address differences 

between aircraft. ODRs must comply with 

and be just as or more restrictive than FAA 

MDRs and other FSB provisions. Constraints 

or credits may be applied to all aircraft in a 

fleet or only to certain aircraft. Constraints or 

credits may address training devices, 

simulators, checking and currency methods, 

knowledge, skills, procedure maneuvers, or 

any other factors that apply to or are 

necessary for safe operations. Training, 

checking, and currency compliance methods 

are proposed and revised by each operator 

consistent with ODR examples from a variety 

of sources that are acceptable to the FAA. 

ODR examples are found in FSB reports. 

(3) Standard ODR Format. ODRs are 

depicted in tables in summarized form. If 

necessary, any explanation of details about 

differences, constraints and credits, 

precautions or compliance methods are 

included in attachments or appendices to 

ODR tables or are cross referenced to other 

operator documents. Figure 3 shows the 

general format for ODR tables, including 

examples of design, systems, and maneuver 

differences. The far-left column lists design, 

system, or maneuver differences that are 

pertinent. The ‘‘Remarks’’ column 

summarizes specific areas or items of 

difference. The ‘‘Flight Characteristics’’ and 

‘‘Procedural Change’’ columns identify what 

(if any) difference effects are noted. The 

‘‘Compliance Methods’’ section of the table 

notes the particular operator’s approved 

means of compliance with FAA MDR 

provisions. The following abbreviations 

apply: 

ACFT—Aircraft. 

AFDS—Auto Flight Display System. 

AVT—Audio Visual Tapes. 

CBT—Computer Based Training. 

EFIS—Electronic Flight Instrument System. 

EICAS—Engine Indicating and Crew Alerting 

System. 

FBS—Fixed Base Simulator. 

FFS—Full Flight Simulator. 

FLT CHAR—Flight Characteristics. 

FMC—Flight Management Computer. 

FMS—Flight Management System. 

PROC CHNG—Procedural Changes. 

SU—Stand Up Instruction. 

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(4) ODR Approval, Distribution, and 

Availability. ODRs are approved for each 

fleet by an operator’s FAA POI in accordance 

with FSB report provisions. ODRs must be 

prepared, reviewed, approved and then used 

to govern training before start of operations. 

The operator retains approved ODRs with a 

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(5) ODR Revision. ODR tables are revised 

by operators and re-approved by the FAA 

when fleet characteristics change or when 

compliance methods change. Fleet 

characteristic changes include redesignation 

of base aircraft, modification of aircraft, 

addition of aircraft, change of aircraft, or 

phaseout of aircraft. Changes in compliance 

methods refer to introduction of new or 

different training methods, contracting for 

use of different devices or simulators, 

revision of checking or currency methods, or 

other such changes. Revisions to ODRs are 

also prepared, reviewed, and approved before 

operating. 

Note: Paragraph 6 describes the 

development, approval, and application of 

ODR tables to individual operators’

programs. Paragraph 7 describes FAA review 

and approval of programs by POIs. 

5. Formulation of FSB Reports, MDRS, and 

Designation of Pilot Type Ratings 

a. Requirements Formulation Process 

Overview. The process for FAA formulation 

and revision of training, checking, currency, 

and pilot type rating requirements is shown 

in Figure 4. 

(1) The process determines which 

information is required for an aircraft; it 

includes a proposal for requirements, tests, 

and evaluations of the proposed 

requirements; it then finalizes, applies, and 

implements the FSB requirements. 

Applicants propose MDRs, examples of 

ODRs, and any other FSB provisions that are 

necessary. Proposals for requirements are 

based on design objectives, analysis, 

evaluation of OE, other programs that have 

been proved acceptable to the FAA, or other 

methods. Setting of requirements is based on 

an objective set of tests and standards, 

analysis of results, and FAA judgments 

considering OE. The applicant and the FAA 

prepare and conduct standardized tests. The 

applicant provides test support, and the FSB 

conducts the evaluation. The FSB, in 

conjunction with the applicant, evaluates the 

results, and the FAA formulates proposed 

minimum requirements. The FSB sets final 

requirements by specifying MDRs and other 

FSB provisions. An FSB report that describes 

findings is disseminated to FAA field offices 

and posted on the operations specifications 

(OpSpecs) Web site for application to specific 

operators’ programs. The formulation and 

application process of FSB requirements 

starts at the time a new aircraft is proposed 

to the FAA and continues throughout the 

fleet life of that aircraft. For aircraft already 

in service the process may be initiated when 

significant modifications are proposed, a new 

piece of equipment (e.g., a HUD) requiring 

operational evaluation is introduced and 

requested by operators, or when mixed fleet 

flying takes place. The FAA addresses 

periodic revisions of requirements when 

necessary, and revisions are initiated by the 

FAA and applicants as needed. 

b. Proposals for MDRs, Example ODRs, and 

Special Requirements. 

(1) When Proposals Are Necessary. The 

FAA usually determines when proposals are 

necessary and advises the applicant what 

information is needed, in conjunction with 

aircraft type certification or supplemental 

certification programs. Necessary information 

may include MDRs for related aircraft or 

other elements of the FSB reports. The 

applicant considers existing MDRs and 

existing or proposed ODRs. 

(2) Proposal Formulation. The formulation 

of a proposal typically starts when a 

manufacturer proposes a new design or 

design modification. The applicant will then 

do the following: 

(a) Formulate necessary information for 

training, checking, and currency for the 

aircraft in proposals for MDRs and example 

ODRs. 

(b) Prepare example ODR tables for 

candidate aircraft to support development of 

a proposed MDR. These examples represent 

proposals for programs for those specific 

aircraft and configurations that the FAA 

could approve. 

(c) Identify related aircraft for the proposed 

MDR table. 

(d) Formulate any necessary tests to assess 

difference levels and associated training, 

checking, and currency requirements for 

incorporation in the MDR table. 

(e) Identify interpretations of possible test 

results. The FAA and the applicant will then 

reach an agreement on specific tests, devices, 

and schedules to be used for the test 

program. 

(f) The applicant submits proposals for the 

following items to the FAA, as necessary: 

• MDRs 

• Example ODRs 

• Tests and criteria to be used 

• Other supporting information associated 

with training, checking, or currency 

programs 

c. Difference Level Tests. A sequence of 

five standard tests, described in Appendix 3, 

is used to set MDRs, minimum acceptable 

training programs, other FSB provisions, and 

define pilot type rating requirements. One or 

more of these tests are applied depending on 

the difference level sought, and the success 

of any previous tests used in identifying 

MDRs. Only those tests needed are used to 

establish minimum requirements. The 

outcome of these tests, and any resulting 

difference levels that apply, establish 

minimum requirements for training, 

checking, currency, and pilot type ratings. 

The FAA will establish an additional pilot 

type rating if it is determined during this 

testing that the assignment of a level E 

differences training is required. 

Note: One additional test, the T6 test, can 

be used to establish CTLC between related 

aircraft, when not previously demonstrated 

in a T2 test. 

(1) Steps in the Testing Process. The 

typical steps of the testing process are as 

follows: 

(a) The applicant develops representative 

training programs, difference programs, and 

necessary supporting information, as needed. 

(b) The applicant identifies proposed 

MDRs and example ODRs. 

(c) The applicant proposes and the FAA 

determines which tests and criteria apply. 

(d) The applicant proposes and the FAA 

determines which aircraft, simulation 

devices, or analyses are needed to support 

testing. 

(e) The applicant makes a proposal to the 

FAA, and agreement is reached on test 

procedures, schedules, and specific 

interpretation of possible results. 

(f) Tests are conducted and results 

evaluated. 

(g) The FSB draft minimum requirements 

are formulated. 

Note: If the candidate aircraft is anticipated 

to have no greater than level A or B 

differences with the base aircraft and a same 

or common pilot type rating is the proposed 

assignment, then the FSB may elect to 

directly apply a T1 test for equivalency. 

(2) Test Purpose and Application. A 

summary of the purpose and application of 

each of the six difference tests is shown in 

Figure 5. 

(3) Test Relationships and Applications. 

The test process relationships, the sequence 

of conducting tests when more than one test 

is needed, and application of test outcomes 

are shown in Figure 6. The start of the 

process is shown at the top of Figure 6. 

Resulting difference levels are at the bottom. 

New aircraft, for which a new aircraft TC is 

sought, follow the testing path at the right of 

the diagram for a T5 test. At the end of the 

process the aircraft is assigned a new pilot 

type rating. For candidate aircraft seeking a 

same or common pilot type rating the test 

process follows a path at the left of Figure 6. 

A series of decisions or tests leads to 

assignment of one or more levels A through 

D and in some instances may lead to level 

E. If level E is assigned as a result of this 

path, then a separate pilot type rating is 

assigned. This process is followed whenever 

a new aircraft is proposed, when significant 

changes are proposed, or when revisions to 

existing requirements are needed as a result 

of requests for change or OE. 

(4) Test Failures and Retesting. Generally, 

failures do not have paths back to lower 

levels. T3 test failure at level C can lead to 

subsequent passage at C (after modification of 

the system, operational procedures, or 

training and retesting) or D. Similarly, failure 

at level D can subsequently lead to either D 

(after modification of the system, operational 

procedures, or training and retesting) or E, 

but not C. Failure at level E can only lead to 

retesting with increased programs, improved 

programs, or improved devices since there is 

no higher level. T5 failure paths do not lead 

back to level C or level D. However, 

subsequent new programs do not preclude 

making a proposal at a lower differences 

level if technology changes, aircraft redesign 

takes place, training methods significantly 

change, or device characteristics and 

effectiveness change. 

(5) Same and Common Pilot Type Rating 

Tests. Aircraft seeking same or common pilot 

type rating will follow the path in Figure 6 

from the top left of Figure 6 through T1 or 

T2 and T3 tests resulting in the assignment 

of level A, B, C, or D differences. 

(6) ‘‘Currency’’ Tests. Currency tests T4 are 

not shown in Figure 6 because they are 

necessary only when the applicant seeks 

relief from system, procedural, and maneuver 

currency requirements set by the FSB. 

(7) Detailed Test Specifications. A detailed 

specification for the evaluation process and 

tests to establish difference levels are 

described in Appendix 3. 


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d. FSB Assessments and Proposal 

Formulation. The FSB assesses the 

applicant’s proposals, test results, analysis, 

and any other relevant factors to formulate a 

draft FSB report, which includes MDRs and 

other pertinent training, checking, currency 

requirements. The FSB either validates the 

applicant’s proposed MDRs, training 

programs, and other information, or generates 

alternate requirements, which may include 

more stringent requirements, additional 

training, additional testing, etc. 

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FIGURE 5.—TEST DEFINITIONS

Test purpose Application 

T1 ............................... Establishes functional equivalence ...................................... Sets levels A/B. 

T2 ............................... Handling qualities comparison ............................................. Pass permits T3, and A/B/C/D; failure sets level E and requires T5. 

T3 ............................... Evaluate differences and sets training/checking requirements.Pass sets levels A/B/C/D; failure sets level E and requires 

T5. 

T4 ............................... Revises currency requirements ........................................... Used to adjust FSB requirements if needed. 

T5 ............................... Sets training/checking for new or ‘‘E’’ ACFT ....................... Sets level E. 

T6 ............................... Evaluation for CTLC ............................................................. Sets recency of experience requirements. 

Note: Expanded descriptions are contained in Appendix 3. 

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e. Comments Solicited. The FSB proposal 

is circulated with interested parties 

representing the manufacturer, operators, and 

other pertinent FAA organizations such as 

engineering, flight test, pilots’ associations, 

and other aviation representatives for 

comment, relevant information, and 

recommendations. 

f. FSB Final Determinations and Findings. 

(1) FSB Determinations. Any comments 

submitted to the FAA are reconciled, and 

final FSB determinations are made. 

Specification of MDRs, example ODRs, 

acceptable training programs, and other FSB 

provisions are completed. Any necessary 

pilot testing or currency provisions are 

identified. Assignment of any necessary pilot 

type rating(s) is made. 


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(2) Basis for FSB Judgments. FSB 

judgments are based on review of the 

applicant‘s supporting documentation, 

proposed ODR tables, test results, and any 

other pertinent information, such as FAA 

policies, OE, and results of other similar FSB 

evaluations. Specifically, FSB report 

provisions are based on the following: 

(a) Appropriate Data, Evaluation, or Tests. 

Testing may include aircraft demonstration, 

simulation tests, device testing, or analysis. 

(b) Direct Experience. The industry may 

have substantial experience with successful 

operational programs, which can be useful in 

the assignment of minimum difference level 

requirements. This experience may include 

particular training devices, training/ 

checking/currency requirements, and mixed 

fleet flying. 

(c) Indirect Experience. Applicable 

experience with foreign operators, military 

programs, or other programs that can 

establish the suitability of training, checking, 

or currency standards may be permitted as a 

means for FSBs to set MDR or ODR levels. 

(d) Applicant and Industry. FSB 

requirements are set following solicitation 

and review of comments. 

(3) Device or Simulator Characteristics. 

Minimum characteristics for devices or 

simulators for training, checking, or currency 

are noted using standard training device or 

simulator definitions. When standard criteria 

for methods, devices, or simulators are not 

appropriate for an aircraft, the FSB identifies 

suitable criteria to be applied and 

coordinates with the FAA National Simulator 

Evaluation Team (NSET). Standard devices 

and simulators applicable to each difference 

level are shown in Figure 7. 

FIGURE 7.—STANDARD METHOD, DEVICES, AND SIMULATORS

Difference level Difference level definition Methods Devices or simulators 1

A ................................ Self instruction ..................................... Bulletins, Manual revisions, Handout 

material.

B ................................ Aided instruction .................................. Slides/video tapes, Standup instruction, Computer-based training (CBT).

C ................................ System devices ................................... .............................................................. Training devices level 2/3/4/5 full task 

computer based instruction (CBI).2

D ................................ Maneuver devices ............................... .............................................................. Training devices level 6/7. 3

E ................................ Simulator C/D or aircraft ..................... .............................................................. Simulator C/D or aircraft. 

(1) Training level and simulator definitions are as specified by applicable ACs. 

(2) Training device levels 3/4/5 typically include cockpit procedure trainers, cockpit system simulators, and similar devices. 

(3) Training device 6/7 or simulator A/B typically includes fixed-base simulators or visual simulators. 

g. FSB Report Preparation Distribution and 

FAA Application. 

(1) Report Preparation and Approval. After 

MDRs are finalized, the FSB report is 

prepared and approved. Sufficient 

background or explanatory material is 

provided in the report to permit FAA 

personnel to properly administer FSB 

provisions. 

(2) FSB Report Distribution. The FSB report 

is posted on the OpSpecs Web site for 

implementation in approval of particular 

operators‘ programs. The FAA technical 

requirements described in FSB reports are 

primarily intended for the operators use to 

develop programs that will be approved by 

the FAA. 

(3) FSB Report Implementation. FSB 

requirements, recommendations, and 

guidance are provided to FAA field offices 

through FSB reports for each aircraft. These 

reports are directives to FAA offices to 

identify acceptable methods of applying 

pertinent 14 CFR parts to each specific 

operator. FSB provisions set acceptable 

standards by which FAA inspectors approve, 

review, correct, or limit individual operator‘s 

programs. The FSB report is the basis for 

approval of training, checking, and currency 

programs approved by each FAA office. The 

report is also the basis for pilot certification 

by FAA or operators and the surveillance of 

operators‘ programs. POIs may approve 

individual operator‘s programs that meet or 

exceed master requirements, but they cannot 

approve programs that are less than master 

requirements. Aviation safety inspectors 

(ASI), aircrew program managers (APM), 

aircrew program designees (APD), and 

designated pilot examiners (DPE) use the 

report as the basis for administration of oral 

examinations, simulator checks, flight 

checks, proficiency checks, and OE. 

Preparation and application of ODRs by 

operators is described in paragraph 6. Review 

and approval of ODRs by FAA POIs is 

covered in paragraph 7. 

h. FSB Report Revision. 

(1) General FSB Revision Process. A 

general revision process is established to 

update determinations and findings 

contained in FSB reports. Revisions may be 

needed annually for active fleets with 

numerous change requests. Revisions may be 

needed infrequently for aircraft not 

undergoing significant change. 

(2) Revisions for New Aircraft. When an 

applicant proposes to develop or add a series 

of a type-certificated aircraft, MDRs and other 

FSB provisions must be revised to address 

that series. If an applicant initiates this 

action, the procedures noted in paragraph 5 

regarding initial determination of minimum 

training, checking, currency, and pilot type 

rating requirements are followed. If an 

operator proposes to add an aircraft that is 

not covered within an existing FSB report 

(e.g., a foreign manufactured aircraft) POIs 

should consult with the pertinent Aircraft 

Evaluation Group (AEG). An FSB will 

determine the best method of addressing the 

development of the necessary FSB report. 

This is particularly important for older 

aircraft fleets in which differences may be 

significant, but manufacturer support is no 

longer available and aircraft imported into 

the United States that have been used only 

by foreign operators. 

(3) Revision for Aircraft Modified by 

Operators. When an aircraft is to be modified 

by an operator, the POI must determine if the 

change affects MDRs, example ODRs, or other 

FSB report provisions. The criteria for this 

assessment includes whether or not the 

difference affects pilot knowledge, skills, or 

abilities pertinent to flight safety. If a change 

meets the criteria, the operator should supply 

the POI with a difference description and 

analysis of the effects of the difference. The 

POI makes a preliminary estimate of the 

difference levels then advises the applicable 

AEG/FSB. The AEG/FSB may concur with 

the POI‘s assessment or require other action. 

If FSB action is required, the AEG will 

initiate that action through the FSB 

chairman. The FSB may require that 

additional information or analysis be 

provided or that the entire test process or 

parts thereof be applied. The AEG may 

authorize the POI to approve assignment of 

the difference level. Changes to the MDRs 

will be made through the normal FSB 

revision process. 

6. Operator’s Application of FSB Provisions, 

Preparation, Use, and Revision of ODRS 

a. General. 

(1) Process Overview. FSB reports contain 

MDRs and other provisions that are applied 

by FAA offices in approving operators’

programs. MDRs are applied through a 

particular method that identifies specific 

ODRs and compliance methods. Application 

of MDRs and other FSB provisions are one 

means to ensure pilot qualification for safe 

operations. This is necessary so that 

regardless of which aircraft is flown, uniform 

training, checking, and currency standards 

are met within the constraints of 14 CFR. 

Paragraph 6 describes operator application of 

MDRs and other FSB provisions for training, 

checking, and currency. This is done through 

operator preparation and FAA approval of 

ODRs for each operator. When aircraft are 

used in mixed fleet flying, this AC’s 

provisions and FSB provisions 

comprehensively address differences in 

training, checking, and currency 

requirements for each aircraft. In some 

instances, the FAA may limit the number of 

different aircraft permitted in mixed flying. 

ODRs are used to identify credits or 


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constraints between aircraft. These credits 

may also be applied to a related aircraft when 

transitioning to another related aircraft when 

those aircraft are intended for use in mixed 

or nonmixed fleet operation. The overall 

process for operator application of MDRs and 

development, approval, use, and revision of 

ODRs is shown in Figure 8. 

(2) Availability and Use of FSB 

Information. FSB requirements are made 

available to operators through FAA CHDOs, 

applicant, industry trade associations, posted 

on the OpSpecs Web site, or other sources. 

When preparing initial or difference 

programs for specific fleets, individual 

operators apply the requirements of the 

applicable FSB report. 

b. Application of MDRs and Preparation 

and Use of ODRs. 

(1) Need for ODRs. When operating a 

mixed fleet, operators prepare the necessary 

ODR table proposals to describe their 

particular fleet and show compliance 

methods. This is done to assess effects of 

differences, plan compliance methods, and 

obtain POI approval for that operator‘s 

specific program. ODR tables must be 

prepared and approved by the FAA for each 

fleet in which FSB requirements are 

established IAW FSB provisions. 

(2) Operator Responsibilities. The 

operator’s responsibilities include: 

(a) Specification of a base aircraft. 

(b) Identification of differences between 

the aircraft within a mixed fleet. 

(c) Preparation of proposed ODR tables. 

(d) Assessment and description of the 

effects of the differences on training, 

checking, and currency. 

(e) Proposal of training, checking, and 

currency methods consistent with MDRs and 

FSB provisions. 

(f) Presentation of proposed ODR tables 

with necessary supporting information to the 

FAA POI for approval. 

(g) Revision of ODR tables when aircraft 

are introduced, modified, phased out, 

devices change, or MDRs change. 

(3) Use of Standard ODR Format. A 

common format for ODR tables is used to 

facilitate preparation, review, use, 

comparison with MDRs, and ensure 

consistency of application and approval by 

POIs. The common format is used in all cases 

where ODR tables are required except when 

only a few minor differences exist and level 

A applies. In this event, letters between an 

operator and FAA containing the necessary 

information and approval may suffice if 

acceptable to the POI. 

(4) Minimum Threshold for ODR 

Preparation. Within the mixed fleet, a 

minimum threshold for preparation of ODR 

tables occurs when there are differences that 

potentially affect knowledge, skills, or 

abilities necessary for flight safety. 

Differences not related to this criterion need 

not be addressed in ODR tables. 

(5) ODR Description and Examples. ODRs 

are described in paragraph 4. Examples of 

acceptable ODR tables for a particular typecertificated aircraft are shown in each FSB 

report. 

(a) Systems Shown on the ODR Table of 

Figure 3. An example of several pages from 

an ODR table is shown in Figure 3. Figure 3 

shows the application of ODRs to address 

systems differences and compliance 

methods. In Figure 3 differences are grouped 

in the order associated with a typical 

operations manual. Air Transport 

Association (ATA) code numbers are shown 

for cross-reference. The ‘‘Remarks’’ column 

depicts differences and the ‘‘Flight 

Characteristics’’ and ‘‘Procedural Change’’

columns address effects of differences. 

(b) Maneuvers Shown on the ODR Table of 

Figure 3. The ‘‘Remarks’’ column depicts 

differences. The ‘‘Flight Characteristics’’ and 

‘‘Procedural Change’’ columns address effects 

of differences. The reference ‘‘SEE APP’’

refers you to an appendix to the table, which 

the operator prepares to more fully list and 

explain the particular procedural changes 

that pertain to the maneuver in the 

‘‘Procedural Change’’ column. 

(6) Other Use of ODRs. The ODR process 

may be used for other applications such as 

flight attendant or dispatcher qualification 

tracking, but such use is not required as part 

of this AC’s provisions. 

c. Selecting Base Aircraft. An operator 

chooses a base aircraft from one of the 

aircraft operated. Base aircraft are defined in 

Appendix 1. Additional information 

regarding base aircraft selection is in 

paragraph 7. 

d. Identification of Differences and the 

Analysis of Effects of Those Differences. 

Differences must be described between base 

aircraft and other related aircraft. This may 

be done from base to each other related 

aircraft. Differences may also be described 

from any related aircraft to each other related 

aircraft. All MDR requirements must be 

satisfied relative to the base aircraft so the 

pairing of aircraft not authorized to be flown 

in a mixed fleet environment by the FSB 

reports is avoided. As long as a complete and 

clear relationship can be drawn from the base 

aircraft to each other related aircraft and all 

MDR requirements are met from the base 

aircraft, to each other related aircraft, there is 

no need to describe each possible 

combination of aircraft. This permits a 

comprehensive identification of differences 

that exist in the fleet, determines the effects 

of those differences, and shows compliance 

methods. Differences are generally organized 

to follow an operations manual or flight 

manual to facilitate use and review, and 

should be categorized by design, systems, 

and maneuvers. Effects of differences are 

stated in terms of effects on flight 

characteristics and procedures. Procedures 

include normal, nonnormal, alternate, and 

recall procedures, as applicable. Since 

complete descriptions may be too lengthy for 

direct incorporation in ODR tables, 

appendices, or references to other operators’

documents may be used to describe 

differences or effects. Some differences or 

effects may be repeated in the analysis. For 

example, an FMS difference may be noted in 

both a navigation system section and 

maneuver section associated with preflight 

setup. The objective is to assure each 

difference that pertains to pilot training, 

checking, or currency is identified and 

addressed, so it is not necessary to limit 

difference descriptions to prevent overlap. 

e. Identification of Compliance Methods. 

Once differences and difference effects are 

described, methods of comprehensively 

addressing each difference (compliance 

methods) are shown. With the difference 

descriptions, redundancy may occur. The 

same training or checking compliance item 

shown for one item may also be associated 

with and credited for other items. The 

objective for description of compliance 

methods is to show that each difference is 

addressed in some appropriate way, to show 

that the method and level chosen is 

consistent with the FSB MDRs, and example 

ODRs at a level at least equal to that required 

by the MDRs. 

f. When Proposed ODR Compliance 

Methods Do Not Meet MDRs. If proposed 

ODR compliance methods do not satisfy 

MDRs or other FSB report constraints, the 

following alternatives exist: 

(1) Differences may be reduced or 

eliminated by modification of aircraft, 

systems, or procedures. 

(2) Other training methods or devices that 

fully comply with MDRs and other FSB 

provisions may be acquired, leased, or 

otherwise applied. 

(3) Pilot assignments may be separated for 

a fleet so that mixed flying of related aircraft 

does not occur. 

(4) MDR change proposals may be 

requested through FAA POIs to the FSB. If 

FSB authorized changes to the MDRs are 

made, the operator may then apply the 

revised criteria. 

g. Maximum Number of Related Aircraft. 

Comparative differences between related 

aircraft may comply with FSB provisions; 

other limitations may also constrain mixed 

fleet flying. To prevent cumulative effects of 

differences for multiple related aircraft from 

adversely affecting pilot performance, the 

FAA sets guidelines for the maximum 

number of related aircraft to be flown. At 

difference level A, the number of related 

aircraft is greater since differences are fewer 

and less significant, whereas at level D or 

level E the number of related aircraft that can 

be flown is fewer because the differences are 

greater. To accommodate an increase in the 

differences level, increasing limitations are 

placed on the number of related aircraft that 

may be flown at the higher levels. Paragraph 

7k contains specific guidance to POIs for 

approval of multiple related aircraft. 

h. Application, Review and Approval. 

Paragraph 7 describes the FAA review and 

approval process. The process is summarized 

here to facilitate ODR table preparation. An 

operator submits the proposed ODR tables 

and necessary supporting information to the 

POI to apply for differences program 

approval. The supporting information may 

include any appendices to the ODR tables 

necessary for evaluation of the proposal, a 

transition plan if needed, and a proposed 

schedule for implementation. POIs may also 

require review of such pertinent and 

additional information as copies of bulletins, 

manuals, or other training materials, before 

they approve proposed ODRs. If devices are 

proposed that are not approved by the POI, 

or evaluated by the NSET, a review and 

approval of those training devices may be 

necessary before ODR approval. Sufficient 

lead-time must be provided to the FAA for 

review. Lead-time depends on such factors as 


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the complexity of program, proposed 

difference levels, number of related aircraft, 

other operator precedents already set, and 

FAA experience with the proposed aircraft, 

training devices, and methods. Many 

noncontroversial level A changes can be 

reviewed and approved in a few days. 

Complex programs with many related aircraft 

can require months for review and approval. 

It is the operator’s responsibility to consult 

with the POI to ensure that sufficient leadtime is provided to review initial 

submissions or changes. At least 60 days 

notice is acceptable for most programs. After 

the operator submits the program proposal, 

POIs compare the proposed ODR with the 

FSB report provisions including the MDRs. 

POIs consult pertinent FAA policy directives 

(Handbook, notices, Safety Alerts for 

Operators (SAFO), etc.) for interpretations or 

guidance in accomplishing the review. In 

certain instances the POI must consult with 

the FSB before ODR approval. If ODRs are 

consistent with FAA policies and within the 

constraints of the MDRs and example ODRs, 

the POI will approve the operator’s ODR 

tables and its proposed differences program. 

When approved by the FAA, ODRs establish 

the basis for training, checking, and currency 

programs for a given fleet for that operator. 

i. Implementation Provisions Transition 

Period. In certain instances, a transitional 

period, agreed upon by the POI with FSB 

concurrence, may be necessary to permit 

operators to continue operations under 

previously approved programs until they are 

able to comply with FSB requirements. This 

is necessary when FSB provisions are 

initially set or revised and provisions require 

lead-time for program preparation, device 

acquisition, or to revise previously approved 

programs. Paragraph 7m and the individual 

FSB reports for each type-certificated aircraft 

discuss FAA approval of transition 

provisions. 

j. ODR Revision. ODR revisions are 

initiated when changes occur in an operator‘s 

fleet relating to differences, difference effects, 

or compliance methods. ODR revisions are 

appropriate when such changes affect pilot 

knowledge, skills, or abilities relevant to 

flight safety. Examples of program changes or 

factors that may require ODR revision 

include: 

(1) Addition or deletion of aircraft in a 

fleet; 

(2) Modification of base aircraft or 

comparison aircraft in a fleet; 

(3) Change of base aircraft; 

(4) Discontinuation of use, addition of new 

or modification of training devices referenced 

by ODRs; 

(5) Revision of training methods with a 

resulting change in compliance levels; 

(6) Changes in effects of differences such 

as revised procedures, performance, or flight 

characteristics; 

(7) FAA revision of MDRs or other FSB 

provisions; 

(8) Adverse OE or training and checking 

experience that dictates inadequacy of ODRs, 

MDRs, or other FSB provisions; 

(9) FAA surveillance results, enforcement 

actions, or failure of an operator to comply 

with provisions of their approved ODRs; and 

(10) Other factors as determined by the 

POI. 

Note: Revisions to ODRs are approved 

using the same procedures as for initial 

ODR’s approval. 

BILLING CODE 4910–13–P 


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7. FAA Review and Approval of Operator 

Programs 

a. General. 

(1) FAA Responsibilities. FAA has the 

responsibility for review, approval, and 

continuing surveillance of individual 

operator programs consistent with this AC 

and FSB provisions. Within a CHDO, POIs 

have the responsibility for program review 

and approval. In addition to review, 

approval, and continuing surveillance of 

operator programs, CHDO and other district 

offices manage pilot certification consistent 

with the criteria of this AC and FSB 

provisions. 

(2) Approval Basis. FAA approvals are 

based on FSB report findings and policy 

guidance included in FAA directives (e.g., 

Order 8400.10, Air Transportation 

Operations Inspector Handbook, notices, 

SAFOs, etc.). Except as provided for in 

transition plans, all preparations must be 

complete and provisions approved before 

conducting training, checking, or establishing 

currency under this AC and an FSB report. 

b. Operator Application of ODRs. 

(1) Operators Using Related Aircraft in 

Mixed fleet Flying. If FSB requirements are 

published, operators operating aircraft in 

mixed fleet flying must apply provisions of 

this AC and the FSB report. AC criteria and 

FSB MDRs must be applied anytime pilots 

operate mixed fleets between training and 

checking events. 

(2) Threshold Requiring ODR Preparation. 

Even though an operator has different 

configurations of aircraft used in mixed fleet 

flying, there is some threshold below which 

ODR tables and POI approval is not required. 

The threshold requiring AC and ODR 

application occurs when differences in 

related aircraft affect pilot knowledge, skills, 

and/or abilities pertinent to flight safety. If 

systems, controls, indications, procedures, or 

maneuvers are different and these differences 

have an effect that significantly relates to 

what the pilots needs to know or do for safe 

mixed fleet flight operation, then an operator 

must prepare ODR tables and seek FAA 

approval. Conversely, ODR tables would not 

need to be prepared in situations that do not 

affect flight safety. In such instances ODR 

tables are not needed even though pilots 

routinely operate several related aircraft. A 

minimum threshold is set to preclude 

unnecessary administrative assessment of 

mixed fleet flying, which has no safety 

implications. If changes to the fleet do not 

affect pilot knowledge, skills, or abilities 

affecting flight safety, then such changes 

need not be considered in addressing FSB or 

this AC provision. 


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(3) FAA Review of ODR Proposals. After 

preparation the carrier submits proposed 

ODR tables and supporting information to the 

CHDO and POI for review and approval. POIs 

evaluate the following: 

(a) The operator has made an appropriate 

identification of a base aircraft. 

(b) Operators have comprehensively 

identified differences in the particular fleet. 

This includes appropriate ODR table 

comparisons between the base aircraft and 

each related aircraft. 

(c) The operator‘s assessment of the affects 

of differences on flight characteristics and 

procedures for the base aircraft and each 

related aircraft are suitable and valid. 

(d) The compliance methods listed are 

consistent with the requirements of the MDR 

tables, footnotes, other pertinent FSB report 

provisions, FAA Order 8400.10, and 

associated advisory materials. 

(e) ODR provisions adequately address any 

‘‘subtle differences’’ between related aircraft 

that have a possibility of inducing potentially 

serious pilot errors. 

(f) Training materials, methods, devices, 

and simulators proposed are acceptable, 

approved by the NSET if necessary, or if FSB 

provisions apply, the ODR tables meet FSB 

constraints. 

(g) ASIs, APMs, and APDs are prepared to 

apply FSB report checking standards. 

(h) Implementation plans are adequate and 

consistent with FSB provisions and other 

FAA policy. 

(i) Other factors determined necessary by 

the POI are considered and any requirements 

met. 

(4) The POI uses the example ODR tables 

and the MDRs provided in the FSB report as 

a basis for evaluating the suitability of a 

particular operator‘s proposed ODR table. 

The MDR always remains the primary basis 

for comparison. The AEG should be 

consulted in the absence of conclusive 

guidance in making such judgments. 

Guidance for evaluation of specific system or 

maneuver items may be found by comparison 

of the proposal with the example ODR table 

shown in the FSB report and other approved 

ODR tables. The operator may use devices, 

techniques, or methods of an equal or higher 

difference level. Critical methods must be at 

least at the level specified by the FSB on the 

MDRs and shown in the example ODR table. 

Actual ODR tables proposed by the operator 

may show a variety of compliance methods 

to satisfy a particular item, ranging from level 

A through the level required by the MDRs. 

For example, if the MDR requirement is a 

minimum of level C, the operator may 

propose to use a combination of level A 

bulletins, level B slide tape presentations, 

and level C training devices to satisfy 

pertinent items. However, at least level C 

must be shown for critical items. The 

operator may choose to satisfy a level C MDR 

provision with level D or level E methods. 

(5) ODR Review Example. The following is 

an example of the process for review of a 

specific item on a proposed ODR table. For 

each proposed ODR item both the FSB 

example ODR table and MDRs are consulted 

and compared with the operator‘s proposal. 

If the MDRs specify that level C devices are 

needed for training, checking, and currency 

between the base aircraft and a related 

aircraft and the example ODR table shows 

applicable level C systems differences or 

maneuvers, then the POI should ensure that 

the proposed ODR table submitted also 

shows at least level C for those pertinent 

systems or maneuvers. 

c. Base and Other Aircraft Identification. 

(1) Selecting the Base Aircraft. Base aircraft 

are defined in Appendix 1. In general, base 

aircraft are used as reference for comparison 

of differences that affect, or could affect, pilot 

knowledge, skills, or abilities pertinent to 

flight safety. A base aircraft should typically 

be the aircraft that the operator trains to first, 

the aircraft that the operator has the largest 

number of, the aircraft most pilots fly 

frequently, or the aircraft that represents a 

configuration that the operator eventually 

will have as a standard. Another aircraft may 

be selected as a base aircraft when the 

previous base aircraft is being phased out, 

converted to a new configuration, or other 

such factors. A base aircraft may be 

redesignated at the discretion of the operator 

with FAA concurrence. A base aircraft is 

identified by make, type-certificated aircraft, 

model, and series or other distinguishing 

classifications. Classification should 

distinguish pertinent differences in 

configuration, handling characteristics, 

performance, procedures, limitations, 

controls, instruments, indicators, systems, 

installed equipment, options, or 

modifications. 

(2) Identifying Related Aircraft. A related 

aircraft is an aircraft or a group of aircraft 

with the same characteristics that have 

pertinent differences from a base aircraft. 

Pertinent differences are those that require 

different or additional pilot knowledge, 

skills, and/or abilities that affect flight safety. 

Differences considered pertinent are those 

relating to configuration, handling 

characteristics, performance, procedures, 

limitations, controls, instruments, indicators, 

systems, installed equipment, options, or 

modifications. Related aircraft can exist 

between different models, series or within a 

model/series. When designated in FSB 

reports, any aircraft included in a MDR table 

is considered a related aircraft. Like base 

aircraft, operators designate related aircraft 

by one of the following: 

(a) Model/series. 

(b) FAA registration ‘‘N number’’. 

(c) Operator tail number. 

(d) Any other classification that can 

uniquely distinguish pertinent differences 

between each related aircraft group and a 

base aircraft. 

(3) Accounting for Each Related Aircraft. 

The important factor in base and related 

aircraft identification and ODR table 

preparation is that regardless of the 

combination used, there should be direct and 

complete traceability of both differences and 

compliance methods. There must be a clear 

description showing the adequacy of 

compliance methods to assure proper 

training, checking, and currency to safely 

operate each aircraft assigned. 

d. Approval of ODRs. 

(1) Approval Method. Following review 

and determination that an operator‘s program 

meets pertinent FSB requirements, the POI 

approves that particular program by signing 

ODRs. ODR tables are approved for each 

applicable related aircraft. Signature of ODRs 

or revisions, together with other relevant 

documents such as training programs and 

OpSpecs, constitute approval by the POI of 

that operator’s differences training, checking, 

and currency program requirements. ODR 

tables are used for most programs. In 

instances where aircraft have only a few 

minor differences at level A, approval may 

take the form of a letter including necessary 

information in lieu of using tables. 

(2) POI Authority at level A and B. POIs 

have authority at A and B level to make 

determinations without AEG coordination if 

compliance methods are within the MDRs. 

This is important to provide timely response 

to minor differences requests. The results of 

these determinations are forwarded to the 

pertinent FSB for permanent retention, 

comparison, and future FSB evaluation. 

(3) POI Coordination Required at Level C 

and Above. At C, D, and E level the POIs may 

approve operator programs only if the 

programs are clearly within the requirements 

of the MDRs. If there is doubt whether or not 

an operator’s program meets the MDRs, the 

POI consults with the FSB well before the 

operator’s program approval date, to allow 

time for review and resolution of open issues. 

If the operator request is unclear or less strict 

than the MDRs requirements, the POI may 

not approve that program. 

(4) Initial and Final Approval. Like other 

training programs, POIs may authorize 

‘‘initial’’ approval for an assessment period to 

review program effectiveness. Final approval 

should be made after suitable experience is 

obtained (generally within 6 months) IAW 

criteria in FAA Order 8400.10. In situations 

where initial approval is completed but final 

approval is delayed because of continuous 

revision or that results are uncertain should 

be avoided. When operators propose to add 

aircraft, modify existing aircraft, change base 

aircraft, phase aircraft out, or take other 

actions, which make the applicability of 

ODRs unclear, then the ODR tables for that 

operator must be updated. For some 

operators a continuous series of ODR table 

modifications will occur as its fleet changes. 

Nevertheless, the ODR tables must be current 

at all times. ODR tables are used as a primary 

means for establishing regulatory compliance 

and managing surveillance of training, 

checking, and currency programs. 

e. POI Uncertainty Regarding Program 

Compliance. The POI must resolve any 

questions before approval if it is not clear 

that the operator’s proposal complies with 

the MDR table and other FSB provisions. 

When issues cannot be resolved to clearly 

establish compliance with MDRs or other 

FSB report provisions, the AEG/FSB should 

be consulted. Early in program development, 

POIs may need more consultation with FSB 

members. In mature programs, better 

examples will be available in FSB reports, 

other operator ODR, and the manufacturer‘s 

larger databases for operators. 

f. Proposals that do not Comply with FSB 

Provisions. If the operator proposes a 

program less restrictive than the 

requirements of the MDRs or other FSB 


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provisions, then options of paragraph 6h. 

apply. If an operator wishes to pursue a 

proposal less restrictive than the FSB report 

or MDRs, details of the proposal and 

supporting documentation should be 

presented to the POI for forwarding to the 

AEG/FSB. The POI will evaluate the carrier‘s 

proposal and, if justified, forward the 

proposal with recommendations for revision 

of MDRs. 

g. FSB Revision of MDRs or Other FSB 

Provisions. When requested by a POI, the 

FSB reviews an operator‘s proposals and if 

necessary modifies MDRs and other FSB 

provisions. If master requirements have been 

amended and the proposal meets the revised 

requirement, the POI may approve the 

proposal. Other operators can also apply for 

similar approval or reductions based on the 

revised FSB report. Major changes in the 

MDR table may require review by the full 

FSB. The FSB may consider minor changes 

or interpretations on an ad hoc basis between 

FSB meetings for that aircraft. For some 

requests changes can be made based on 

existing or the supplied information. 

Complex cases may require testing to be 

conducted by the applicant before the MDR 

table is changed. Should the MDRs be 

updated to accommodate a change request, 

the proposed ODR can be approved within 

the new MDRs. Proposals for revisions to 

levels C, D, or E must be forwarded to the 

FSB for resolution through the formal FSB 

process. Allow at least 60 days for FAA 

evaluation of such proposals. 

h. Proving Tests. When a related aircraft 

with difference levels C or greater is 

introduced by an applicant, proving runs 

may be needed. Proving runs are usually 

needed for levels D and E. At level E, 

regulatory provisions for proving runs must 

be met. Training flights, test flights, delivery 

flights, and demonstration flights may be 

credited toward levels C and D proving 

requirements if necessary operational 

experiences are demonstrated and the flights 

are IAW an FAA-approved plan. FAA Order 

8400.10 describes policies for FAA approval 

of proving tests. 

i. Line-Oriented Flight Training (LOFT), 

LOS, or SLF. When operators have LOFT/ 

LOS/SLF programs and additional related 

aircraft are approved, the POI must review 

those LOFT/LOS/SLF programs to assure 

applicability to each related aircraft. SLF in 

the aircraft, or in some instances simulator 

(as determined by the FSB), may be necessary 

IAW provisions of the FSB report and with 

the approval of the POI. 

j. OE. As described in this AC and FSB 

reports, OE is consistent with definitions and 

requirements of 14 CFR. OE credit, as 

provided by the FSB for experience with 

related aircraft, may be permitted with the 

approval of the POI. 

k. Limitations on the Total Number of 

Related Aircraft. 

(1) Mixed Flying of Multiple Related 

Aircraft. When mixed fleet flying involves 

pilots operating more than a base aircraft and 

a single additional related aircraft, additional 

constraints limiting the total number of 

aircraft may apply. Operation of multiple 

related aircraft requires a review by the POI 

to ensure that pilots can retain and properly 

apply necessary differences information or 

skills for each related aircraft without 

confusion. When more than two related 

aircraft are flown, POIs must specifically 

ensure that subtle or compounded 

differences between the various related 

aircraft do not result in confusion of 

procedures, maneuvers, or limitations. ODRs 

proposed for the overall combination of 

aircraft to be flown must be examined to 

ensure the following: 

(a) That multiple differences do not result 

in confusion of requirements or an excessive 

level of complexity for pilots to adjust to or 

retain important differences information; 

(b) That subtle variations in differences 

information are not mistakenly applied and 

lead to unsafe conditions; and 

(c) That the amount of differences 

information is not excessive, not applied to 

the wrong aircraft, or not forgotten. 

l. Compliance Checklist for CHDOs. FSB 

reports provide a CFR compliance checklist. 

The checklist identifies those 14 CFR parts, 

ACs, or other FAA requirements that are in 

compliance. Pertinent 14 CFR items not 

shown on the checklist or items shown but 

not reviewed by the AEG/FSB for compliance 

must be reviewed by the CHDO before POI 

approval of OpSpecs permitting those aircraft 

to be used under 14 CFR. Items found not 

compliant by the AEG/FSB must be 

reconciled and compliance established before 

operation. The compliance checklist is an aid 

to CHDOs used to show the status of those 

14 CFR items evaluated by the AEG/FSB, but 

does not comprehensively address all 

possible 14 CFR items and ACs that an 

operator may need to demonstrate 

compliance. OpSpecs, exemptions, 

deviations, or other factors, which the AEG/ 

FSB may not be aware of, may also apply and 

may modify compliance status or methods 

shown in the checklist. 

m. Implementation of FSB Provisions. 

These provisions are addressed in each typecertificated aircraft FSB report and must 

comply with any criteria shown in that 

report. POIs approve implementation 

provisions at the same time ODR tables or 

revisions are approved. Operators that do not 

elect to apply this AC or implement FSB 

provisions specified by the FSB report 

require approval by the Director, Flight 

Standards Service, AFS–1. 

n. Aircraft That Do Not Have an FSB 

Report. When an FSB report is not prepared 

for a given type-certificated aircraft, or when 

MDRs or other provisions are not shown, 

programs are approved IAW the 14 CFR, 

Order 8400.10, and other pertinent inspector 

guidance material. 

8. Application of Requirements to Airmen 

Certification 

a. General. In addition to master 

requirements, the FSB report contains 

specifications for administration of pilot type 

rating or proficiency checks by FAA 

inspectors or operator check airmen. FAA 

pilot certification inspectors, APMs, operator 

check airmen, APDs, and DPEs should be 

familiar with FSB provisions regarding the 

proper administration of any necessary 

checks or evaluations for type-certificated 

aircraft or their series covered by the FSB 

report. 

b. Checking Specifications. FAA pilot 

certification inspectors and APMs should 

assure proper application and administration 

of checks required by FSB reports as 

constrained by the MDR and specific ODR 

tables. FSB reports describe difference levels 

which constrain the various maneuvers, 

procedures, or unique factors to be 

considered by inspectors or check airmen 

when administering checks or observing OE. 

For example, certain nonnormal procedures 

may be required and others may be waived 

(for example no flap landings). Other unique 

procedures or maneuvers particular to an 

type-certificated aircraft may be necessary. 

Any unique configurations or failure 

conditions that should be observed while 

administering checks are described. 

c. Checks Regarding Complex Systems. 

(1) Partial proficiency checking is required 

for differences associated with systems that 

are determined to be at or greater than level 

C. 

(2) Complex systems checks include 

hands-on operation and ensure demonstrated 

procedural proficiency in each applicable 

mode or function. Specific items and flight 

phases to be checked are specified (e.g., 

initialization, takeoff, departure, cruise, 

arrival, approach, and pertinent nonnormals). 

The FSB may require additional training 

beyond that which is otherwise required by 

14 CFR to qualify in each type-certificated 

aircraft. This training may be in the form of 

LOFT, LOS, or SLF. 

9. Training Device and Simulator Approval 

a. Training Device and Simulator 

Characteristics. 

(1) Minimum Device and Simulator 

Characteristics. AC 120–40 and AC 120–45 

describe minimum acceptable characteristics 

and standards for flight training devices and 

simulators. The FSB directly applies these 

standards in difference level specifications. 

When applicable, the FSB specifies other 

device characteristics as the minimum 

acceptable for differences training, checking, 

or currency between certain related aircraft. 

The FSB reports identifies these 

characteristics. 

(2) Coordination with the FAA National 

Simulator Program (NSP). When the FSB 

specifies device characteristics, the FSB 

coordinates with the NSET to ensure 

simulator criteria compatibility and approval 

process definition. If device or simulator 

characteristics have not been previously 

recognized by the FAA as meeting the 

provisions of this AC, FSB, or the simulator 

evaluation and approval process, they must 

be evaluated by the NSET in consultation 

with the FSB before use in an approved 

program. 

b. Aircraft/Simulator/Device Compatibility. 

(1) Devices and Simulators to Match 

Aircraft. When pilots fly related aircraft in a 

mixed fleet, the combination of simulators 

and training devices used must satisfy MDR 

and ODR provisions specific to the aircraft 

flown by that operator. The POI, FSB, and the 

NSP must address the acceptability of 

differences between training devices, 

simulators, and aircraft operated as 

appropriate. The FSB, POI, and when 

necessary, the Air Transportation Division, 


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AFS–200, or the General Aviation and 

Commercial Division, AFS–800, as 

applicable, identify acceptable credit for 

simulators and training devices. 

(2) Differences Between Devices, 

Simulators, and Aircraft. When differences 

exist between related aircraft and the 

proposed training devices, or simulators to be 

used, then MDRs and ODRs may be used as 

guidance for acceptance and approval as is 

done between aircraft. The FSB, the NSP, and 

AFS–200 or AFS–800, as applicable, should 

be consulted when uncertainty exists 

regarding the use of MDRs and ODRs for 

acceptance or approval of these devices. The 

FSB will not recommend use or approval of 

devices that differ significantly from the 

actual operated aircraft. 

c. Simulator and Device Approvals. 

(1) NSP Representation to the FSB. An NSP 

member may serve as an advisor to the FSB 

or a member of the FSB, to address 

designation of and approval processes for 

devices and simulators at C, D, and E 

difference levels. 

(2) Coordination of NSP Criteria with the 

FSB. National simulator team development of 

criteria for training devices and approval test 

guides for new aircraft are coordinated with 

the FSB. This ensures compatibility of FSB/ 

NSP requirements and effective use of 

resources for development of approval test 

guides and determination of FSB 

requirements. 

10. Review and Approval 

FSB reports are approved as designated by 

AFS–1. In the event that revision of an FSB 

report is necessary, the FSB is provided with 

necessary policy guidance to implement 

applicable changes. 

11. Appeal of FAA Decisions 

When there is disagreement with 

provisions of an FSB report, that 

disagreement may be expressed to the FSB 

chairman for the pertinent type-certificated 

aircraft. If an issue cannot be resolved, the 

issue may then be addressed to AFS–200. 

Additional information, data, or analysis may 

be provided to support differing views 

regarding the FSB provisions in question. 

APPENDIX 3.—RATINGS AND LEVEL 

TESTS—PLANNING AND 

APPLICATIONS 

1. Preparation 

2. Pilot Type Rating Determination Through 

Analysis-Level A or B Training Only 

3. Function Equivalence-Level A or B Test 1 

(T1) 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Safety Pilot 

e. Successful Test 

f. Failure of Test 

4. Handling Qualities Comparison Between 

Aircraft-Test 2 (T2) 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Safety Pilot 

e. Successful Test 

f. Failure of Test 

5. System Differences Test and Validation of 

Training and Checking-Test 3 (T3) 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Successful Test 

e. Failure of Test 

6. Currency Validation-Test 4 (T4) 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Successful Test 

e. Failure of Test 

7. Initial or Transition Training/Checking 

Program Validation-Test 5 (T5). 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Successful Test 

e. Failure of Test 

8. Common Takeoff and Landing Credit 

(CTLC)-Test 6 (T6) 

a. Test Purpose 

b. Test Subjects 

c. Test Process 

d. Successful Test 

e. Failure of Test 

APPENDIX 3.—RATING AND LEVEL 

TESTS—PLANNING AND APPLICATION 

1. Preparation 

a. The pilot type rating, difference level 

definition, and test process are initiated 

when an applicant presents an aircraft for 

type certification. If the applicant presents a 

candidate aircraft to the Flight 

Standardization Board (FSB) as a new aircraft 

type certification with no anticipated 

application for pilot type rating credit for 

similarities with aircraft previously type 

certificated, then the FSB analyzes the 

training program requirements using test T5. 

The results of T5 will determine a separate 

pilot type rating and the minimum required 

training, checking, and currency standards as 

applicable to that type-certificated aircraft. If 

the applicant presents an aircraft seeking 

pilot training, checking, or currency credit, 

based on similarities with an aircraft 

previously type certificated, a series of 

possible tests (T1/T2/T3) are developed and 

used to determine its level of difference with 

the base aircraft of comparison. The results 

of these tests will determine whether the 

aircraft pilot type rating is a common pilot 

type rating between separate type-certificated 

aircraft; or the same pilot type rating of same 

type-certificated aircraft. The level of 

differences will determine the minimum 

required training, checking, and currency 

standards as applicable to the candidate 

aircraft. T6 comparisons may permit 

Common Takeoff and Landing Credit (CTLC) 

between different type-certificated aircraft. In 

Appendix 2 the details of these situations 

provide further amplification. 

b. To begin the evaluation process, the 

applicant identifies candidate aircraft. The 

aircraft are then assigned to logical aircraft 

groups to be described in Master Difference 

Requirements (MDR) tables and the FSB 

report. 

c. The applicant identifies major 

differences pertinent to the aircraft and 

makes comparisons with the proposed 

candidate aircraft. A differences document 

(i.e., an appropriate sample Operator 

Difference Requirement (ODR) table) 

summarizes the identified differences. Since 

combinations of related aircraft may be 

numerous and only typical differences are 

needed at this stage for test definition, the 

applicant may select representative ODRs for 

preparation. 

d. Based on the above analysis (including 

preliminary flight test results or flight 

simulation estimates, if available), the 

applicant proposes difference levels to be 

specified in each cell of the MDR table for 

the various aircraft combinations. 

e. The applicant proposes applicable 

elements of the test process (T1 through T5 

and T6 for CTLC) and a plan for validation 

of the intended difference levels. Specific 

aircraft, times, devices, etc. are identified to 

conduct the required tests for the candidate 

aircraft. Included in the proposal are any 

necessary interpretations of expected results 

using established standards. Any special, 

unique, or additional definitions of 

successful outcomes are also identified. 

f. The scope of T1 through T6 is keyed to 

basic visual flight rules (VFR) and instrument 

flight rules (IFR) operations in the National 

Airspace System (NAS). 

g. FAA/applicant agreement is reached on 

the grouping of aircraft, proposed tests, test 

plans, schedules, subjects, and interpretation 

of possible outcomes. 

h. Subject qualifications are addressed at 

the time of test specification when test 

agreement is reached with the applicant. Test 

subjects for all tests except T6 are drawn 

from the FAA. Subject selection considers 

the factors such as the following: 

(1) Needed background skills of candidates 

(previously qualified aircraft); 

(2) General flight experience and currency; 

(3) Test requirements such as location, 

short notice access, and skills needed for 

subjects; 

(4) Technical areas, qualifications, or 

experience that subjects should not have to 

avoid test prejudice; 

(5) Eventual FAA geographic or operator 

related distribution requirements for ASI, 

APM, and POI personnel; and 

(6) Other special experience as needed for 

a particular program. 

i. During preparation for testing and 

evaluation of results, appropriate Aircraft 

Certification Flight Test Branch coordination 

is accomplished so that flight characteristic 

issues and, in particular, special flight 

characteristics can be suitably identified and 

addressed. 

Note: Tests T1 and T2 must be conducted 

in the candidate aircraft for the 

determination of training, checking, and 

currency requirements. However, the FSB 

chairman may elect to use a simulator before 

its qualification by the National Simulator 

Evaluation Team (NSET). This may be done 

for selected FSB T-tests that involve partialtask evaluation of systems or components, 

which do not directly relate to aircraft 

handling qualities or core pilot skills. These 

types of tests would normally require only a 

training device with no visual or motion 

capabilities. 


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2. Pilot Type Rating Determination Through 

Analysis-Level A or B Training Only 

a. Typically, with the introduction of a 

new aircraft, or when training credit is 

sought in a comparison of a base and 

candidate aircraft, the T1 through T5 testing 

process determines pilot type rating. Not all 

changes or modifications to an aircraft or on 

occasion, the certification of a related aircraft 

may require flight-testing to assess their 

impact upon pilot type rating. Pilot type 

rating determination through analysis may be 

considered if the changes do not influence 

aircraft handling, introduce no significant 

change to systems operation or pilot 

procedures, and can be addressed at level A 

or B training. 

b. The analysis process can be used if the 

aircraft handling has not changed 

significantly. In most cases, it should be 

obvious that the change will not affect 

aircraft handling but if additional data is 

needed to make the determination, the 

information can be obtained from the 

assigned FAA Aircraft Certification Service 

(AIR) or through the applicant’s flight test 

data. Following is a list of typical changes 

evaluated through the analysis process: 

(1) Maximum operating weights (revised 

aircraft type certificate data sheet (TCDS)). 

(2) An engine type or thrust change that 

does not require significant design changes to 

aircraft flight controls. 

(3) Maximum passenger capacity (revised 

aircraft TCDS). 

(4) Avionic upgrades (Supplemental Type 

Certificate (STC) or manufacturer production 

line upgrade). 

(5) Proven electronic flight bag installation, 

(STC or manufacturer production line 

upgrade). 

(6) Passenger to cargo conversions. 

c. When the analysis process is completed, 

it is recorded as a revision to the training 

courseware and to the existing FSB report for 

the base and/or candidate aircraft. 

3. Functional Equivalence-Level A or B Test 

1 (T1) 

a. Test Purpose. The T1 test is conducted 

to determine if training level A or B is 

appropriate between the base and candidate 

aircraft. 

Note: If the applicant communicates that 

the training, checking and currency 

requirements for the candidate aircraft may 

exceed level B, the T1 test can be waived and 

the evaluation process then moves directly to 

the T2 test. By waiving the T1, the applicant 

acknowledges that differences exist between 

the base and candidate aircraft, and may 

demand that training, checking, and/or 

currency requirements up to but not 

exceeding level D are applied. 

b. Test Subjects. Test subjects are 

designated FAA FSB members, trained, 

experienced, and current on the base aircraft 

with no differences training for the candidate 

aircraft. The applicant may provide 

proficiency training to the designated FSB 

members before testing begins. 

c. Test Process. The applicant initiates the 

test process when they propose that the 

minimum training, checking, and currency 

requirements for the base and candidate 

aircraft are no greater than level B 

differences. At the discretion of the FSB 

chairman, the T1 test may be accomplished 

in a training device/simulator or airplane as 

appropriate. T1 is typically conducted using 

one group of test subjects. Subjects will 

initially be given a ‘‘no jeopardy’’ flight 

check for their base aircraft to calibrate 

performance before taking the pertinent flight 

check in the candidate aircraft being 

evaluated. The flight check undertaken in the 

candidate aircraft will address the differences 

between the base aircraft and candidate 

aircraft. The test may be administered or 

observed by more than one FSB member to 

ensure consistency and uniformity of test 

procedures and common understanding of 

subject performance and outcomes. 

d. Safety Pilot. A ‘‘safety pilot,’’ serving as 

PIC in the aircraft and functioning as pilot 

monitoring in either seat, will intervene to 

prevent damage to the aircraft or to limit 

maneuvers that endanger safety of flight. 

e. Successful Test. FSB members decide 

the outcome of the T1 test consistent with 

previously agreed upon criteria. The FSB 

determines the areas of differences training 

required and specifies necessary devices or 

training limitations. If the T1 test is passed, 

the pertinent aircraft pairs are assigned to 

level A or level B training differences. 

Successful completion of T1 results in 

awarding of the same or a common pilot type 

rating. 

f. Failure of Test. If the T1 test is failed and 

retesting is not considered, level A or B 

cannot be assigned. This generally requires 

completion of T2 and T3. If requesting 

training credit, the applicant may ask for and 

receive credit for those items passed in T1. 

T1 retesting may be considered at the 

discretion of the FSB. 

4. Handling Qualities Comparison Between 

Aircraft-Test 2 (T2) 

a. Test Purpose. The T2 test compares 

handling qualities between the base and 

candidate aircraft to determine whether 

training level B, C, or D is appropriate. At the 

discretion of the FSB chairman the T2 test 

may be completed through analysis, without 

requiring an aircraft flight. Determining if the 

analysis process can be used requires 

verification that the aircraft handling has not 

changed significantly as described in the 

‘‘test process’’. In most cases, it should be 

obvious that the change will not affect 

aircraft handling but if the determination 

requires additional data, the information is 

obtained from the assigned FAA Aircraft 

Certification Office or through the applicant’s 

flight test data. With FAA agreement, 

elements of T2 may be incorporated within 

the T3 test to verify that an advanced 

simulator or aircraft training is not needed to 

address handling qualities. 

Note: If T2 is conducted on an aircraft that 

is expected to require a separate pilot type 

rating with CTLC, credit will be validated by 

using the T6 process. 

b. Test Subjects. Test subjects are 

designated FAA FSB members, who are 

trained, experienced and current on the base 

aircraft with no differences training for the 

candidate aircraft. Training to proficiency 

may be provided to the designated FSB 

members by the applicant before the start of 

testing. 

c. Test Process. The applicant initiates the 

test process when they analyze available 

flight or simulation test data, and aircraft 

design or system differences, and determine 

that handling similarities exist between the 

base and candidate aircraft. From this 

determination the applicant makes their T2 

proposal. Before the test, representatives of 

the FSB review the T2 test profile to ensure 

that critical handling quality aspects of the 

candidate aircraft are examined. The flight 

evaluation consists of relevant parts of a 

proficiency check as determined by the FSB 

chairman. T2 consists of a comparison 

between selected pilot certification flight 

check maneuvers (normal and nonnormal) 

administered first in the base aircraft (using 

either the actual aircraft or a level C or D 

simulator) then in the candidate aircraft. 

Although T2 testing should always be 

accomplished in the candidate aircraft, some 

portions that significantly affect aircraft 

safety, such as flight control failures, may be 

conducted in a simulator suitable for the test. 

Subject pilots are evaluated on performance 

of required maneuvers consistent with 

standards set by 14 CFR and an assessment 

of the degree of difficulty in performing 

maneuvers in the candidate aircraft 

compared to the base aircraft. The test may 

be administered or observed by more than 

one FSB member to ensure consistency and 

uniformity of test procedures and common 

understanding of subject performance and 

outcomes. 

d. Safety Pilot. The safety pilot serving as 

PIC in the aircraft and functioning as pilot 

monitoring in either seat, will intervene to 

prevent damage to the aircraft or to limit 

maneuvers which endanger safety of flight. 

The safety pilot can only assist the subject 

pilot in areas unrelated to the handling 

qualities determination. For example, the 

safety pilot can remove impediments to 

progression of the test but cannot fly, coach, 

or train the subject on any aspect of the test 

related to handling, vision cues, or motion 

cues. The safety pilot may not actuate 

primary flight controls during the evaluation, 

or instruct, lead, or coach test subjects in any 

manner. The safety pilot may: 

(1) Perform all routine pilot monitoring 

duties. 

(2) Set up or adjust systems, including 

those normally operated by the pilot flying in 

accordance with pretest agreements. 

(3) Address or resolve procedural 

impediments. 

(4) Manage and satisfy checklists. 

(5) Make normal call outs. 

e. Successful Test. The FSB members 

decide T2 test outcome consistent with 

previously agreed upon criteria. Acceptable 

pilot performance in completion of 

designated maneuvers, without differences 

training, establishes that the candidate and 

base aircraft are sufficiently alike in handling 

characteristics to permit assignment of level 

B, C, or D. The test process can then advance 

to differences training and the T3 test. 

f. Failure of Test. Failure of T2 means that 

major handling differences exist during 

critical phases of flight or that numerous less 

critical differences were identified that 

warrant training in a full flight simulator or 

aircraft. Accordingly, level E differences will 


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be assigned and the FAA will issue a separate 

pilot type rating. With a T2 failure, the next 

step in the testing process is T5, to validate 

level E requirements and the proposed 

training course. Failure of the T2 does not 

necessarily mean that the base and candidate 

aircraft do not share a high degree of system 

and/or handling commonality. The applicant 

may elect to use the data collected during the 

T2 process to justify approval of a shortened 

pilot type rating course for pilots that are 

trained on the base aircraft and are 

transitioning to the candidate. 

5. System Differences Test and Validation of 

Training and Checking—Test 3 (T3) 

a. Test Purpose. Test 3 is used to evaluate 

the proposed differences training, checking, 

and training devices at levels B, C, or D. 

b. Test Subjects. Test subjects are 

designated FAA FSB members, trained, 

experienced, and current on the base aircraft 

with no differences training for the candidate 

aircraft. Training to proficiency may be 

provided to the designated FSB members by 

the applicant before the start of testing. 

c. Test Process. T3 is a system differences 

test and a validation of training and 

checking. It is used when the equivalent 

handling test (T2) is successfully completed 

or when T2 is being incorporated as part of 

T3. T3 is administered in two phases 

following differences training of a pilot in the 

candidate aircraft. 

(1) First Phase. The successful completion 

of a pilot certification flight check to assess 

pilot knowledge, skills, and abilities 

pertinent to operation of the aircraft being 

tested. If a full check is proposed, the tests 

are similar to those used for T1 as described 

in paragraph 2 above. If a partial check is 

used, the process is similar, but the FSB 

determines the test items based on the 

applicant‘s proposals. The first phase will 

include either a proficiency check as defined 

by 14 CFR, partial proficiency check, or 

individual aircraft system operation check 

administered to pilots in the simulator or 

candidate aircraft. The check is administered 

assuming currency in the base aircraft and 

completion of the proposed training in the 

candidate aircraft. 

(2) Second Phase. Line oriented flying 

(LOF) following completion of the flight 

check. The LOF phase of the test is used to 

validate the training and checking being 

proposed, fully assess particular difference 

areas, examine implications of mixed fleet 

flying, assess special circumstances such as 

minimum equipment list (MEL) effects, and 

identify the effects of pilot errors potentially 

related to the differences. The test is done in 

a real line flight environment that includes 

typical weather, routes, airports, air traffic 

control (ATC), and other factors that are 

characteristic of those in which that aircraft 

will be operated. LOF tests may be conducted 

in test aircraft, simulators, or with a 

combination of these in conjunction with 

function and reliability certification tests. 

The LOF portion of the test may be used to 

evaluate complex issues or issues that cannot 

be fully detailed in a brief flight check since 

a check only samples pilot knowledge and 

skills in a limited and highly structured 

environment. LOF is an integral part of T3 

and must be successfully completed before 

‘‘initial’’ assignment of difference levels. In 

developing and selecting scenarios for 

evaluation consider the following: 

(a) Likelihood of occurrence; 

(b) Possible consequences; and 

(c) The timeliness of pilot discovery and 

correction. 

d. Successful Test. The FSB members 

decide the outcome of the T3 consistent with 

previously agreed upon criteria and 

completion of LOF with appropriate pilot 

performance. Passing T3 leads to setting 

respective difference levels and validates 

differences training and checking at level B, 

C, or D between related aircraft. 

e. Failure of Test. Failure of T3 occurs with 

either failure of the check, agreed criteria, or 

unsatisfactory performance during the LOF 

portion of the test. In certain failure cases, T3 

can lead to assignment of level E and a 

separate pilot type rating. The following are 

examples that may lead to the assignment of 

level E differences: 

(1) T3 experience or difficulties that show 

the need for assignment of training levels 

approaching typical initial/transition levels. 

(2) T3 pilot performance that indicates that 

devices or methods associated with level D 

are not adequate to achieve training or 

checking objectives. 

(3) Repeated failures of attempts to pass T3 

test at level D training differences. In the case 

of retesting, new subjects may be required at 

the discretion of the FSB Chairman. 

Note: Repeated failure of test at level D 

differences by one or more subject’s (pilot) 

inadequate performance, that is not an 

individual subject’s failure due to sub-par or 

atypical personal performance as determined 

by the FSB, may lead to assignment of level 

E differences. 

6. Currency Validation—Test 4 (T4) 

a. Test Purpose. The T4 test is a currency 

test that can be used when an applicant seeks 

relief from existing FSB currency 

requirements. In the context of this AC, 

currency addresses system procedural and 

maneuver differences between related 

aircraft. T4 does not include takeoff and 

landing recency of experience. 

b. Test Subjects. Designated FAA FSB 

members. 

c. Test Process. If an applicant desires a 

change in the currency requirements, a T4 

test may be conducted. This test may be done 

before or after the aircraft enters into service. 

In the event the test cannot be done before 

entry into service, the FSB established limits 

apply. Criteria that may be used by the FSB 

to set level B, C, D differences for currency 

for initial FSB determinations include the 

following examples: 

(1) Complex flight critical systems affecting 

control or navigation. 

(2) Critical nonnormal maneuvers differing 

between related aircraft (e.g., V1 engine 

failure, emergency descent, etc.), requiring 

one acceptable demonstration/training or 

checking event (typically 6 months but 

demonstration period may also vary by pilot 

position). 

(3) Secondary systems (e.g., Oxygen or 

auxiliary power unit (APU)). 

d. Successful Test. The FSB members 

decide the outcome of T4 consistent with 

previously agreed upon criteria. A successful 

test validates that the proposed less 

restrictive currency provisions are accepted 

as a means of compliance with applicable 

rules, provisions of this AC, and/or currency 

provisions and provide an equivalent level of 

safety. 

e. Failure of Test. Failure indicates that the 

proposed less restrictive currency 

requirements do not provide an equivalent 

level of safety. At the discretion of the FSB, 

retesting may be appropriate. 

7. Initial or Transition Training/Checking 

Program Validation—Test 5 (T5) 

a. Test Purpose. T5 test validates the 

applicant’s training course(s) at level E (new 

pilot type rating). It is appropriate when: 

(1) A full initial or transition training/ 

checking program requires validation; 

(2) An applicant seeks training credits 

between two aircraft with different pilot type 

ratings (a typical goal under shortened 

training programs); or 

(3) T2 or T3 are failed. 

b. Test Subjects. Designated FAA FSB 

members. 

c. Test Process. There are two methods to 

accomplish the T5 test process: 

(1) Full Initial or Transition Training/ 

Checking Program Validation. This method 

is used when an applicant has developed an 

aircraft and seeks a new pilot type rating 

without any credit for commonality with any 

related aircraft. The applicant develops a 

training program to qualify and check pilots 

in the candidate aircraft at level E 

differences. Subjects are trained, given flight 

proficiency checks and complete LOF in a 

process similar to that described in paragraph 

5. 

(2) Shortened Transition Training/ 

Checking Program Validation. This method 

is used when an applicant has developed an 

aircraft and seeks a new pilot type rating and 

credit for commonality with related aircraft. 

The applicant conducts a handling-qualities 

evaluation based on the applicant’s proposed 

ODR tables (similar to T2), followed by 

training and checking program validation 

(similar to T3). Subjects are trained, given 

flight proficiency checks and complete LOF 

in a process similar to that described in 

paragraph 5. 

Note: When an aircraft is assigned level E 

differences because of a failure of T3 test at 

level D differences, credit for successfully 

passing individual elements of the T3 test 

may be used as justification for not 

duplicating those elements in the T5 test. 

d. Successful Test. The FSB members 

decide the T5 outcome consistent with 

previously agreed upon criteria. A successful 

outcome of T5 validates the proposed 

training and checking programs. 

e. Failure of Test. Failing T5 indicates the 

proposed training or checking programs 

require modification. A retest by mutual 

agreement between the FSB and applicant 

would normally be required. 

8. Common Takeoff and Landing Credit 

(CTLC)—Test 6 (T6) 

a. Test Purpose. The applicant uses T6 

when they seek credit between related 

aircraft toward the takeoff and landing 


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49620 Federal Register / Vol. 72, No. 166 / Tuesday, August 28, 2007 / Notices 

recency of experience requirements of the 

applicable 14 CFR parts. 

b. Test Subjects. The test should consist of 

a sufficient number of pilots not trained or 

qualified in the candidate aircraft. These 

subjects will be drawn from the 

manufacturer, industry and the FAA that the 

FSB determines will represent a statistically 

relevant cross-section of operational pilots. 

The participants’ experience levels, pilot 

type ratings and airplane currency should 

reflect the proficiency difference levels 

needed to validate testing assumptions. 

c. Test Process. Test subjects are first 

provided refresher training in the base 

aircraft to establish a baseline of proficiency, 

then placed in the candidate aircraft, without 

any training in it, and perform a minimum 

of three takeoffs and landings without use of 

the autopilot. It may not be practical to 

conduct some tests in an aircraft. A simulator 

may be used to conduct these tests. Test 

subjects should be evaluated on their ability 

to fly the aircraft manually through takeoff, 

initial climb, and approach and landing 

(including the establishment of final landing 

configuration). The applicant should 

consider the effects on the takeoff and 

landing maneuvers for the following factors 

when designing the T6 test: 

(1) Aircraft weights. 

(2) Aircraft center of gravity. 

(3) Takeoff and landing crosswinds. 

d. Successful Test. The FSB members 

decide the outcome of T6 consistent the FAA 

Practical Test Standards (PTS) demonstrating 

that an equivalent level of safety can be 

maintained when full or partial credit for 

takeoffs and landings is given between the 

related aircraft. 

e. Failure of Test. The test subjects’

performance relative to the FAA PTS 

demonstrates an equivalent level of safety 

cannot be maintained when either full or 

partial credit for takeoffs and landings is 

given between the related aircraft. 

[FR Doc. 07–4116 Filed 8–27–07; 8:45 am] 

BILLING CODE 4910–13–C 


rwilkins on PROD1PC63 with NOTICES3