Base Training for Type Rating endorsement
No doubt, the rules ask for the landings to be done within an ATO/TRTO. However, for not “airline type” operators without an integrated ATO/TRTO this is almost impossible to comply with. The problem for third party providers (CAE, FSI etc) is the fact that they are not able/willing to be held liable for training conducted on a multimillion dollar jet, which they are not in control of. This is one (of many) examples, how the rules are written for the big players and are almost impossible to be complied with for the rest of the aviation community.
Spain started a query amongst EASA member states related to this particular problem, last week. Interestingly, the practice to deal with this problem within the NAA’s varies from strictly enforcing the landings to be done within a TRTO/ATO to accepting the landings when completed with a JAR/EASA licensed TRI. However, all Authorities have the possibility to file a derogation in accordance with article 14 of the basic regulation and shall give reasons demonstrating the need to derogate from the rule concerned, as well as the conditions laid down to ensure that an equivalent level of protection is achieved. This is probably what’s going to happen once the NAA’s have agreed to a common procedure.
Cheers,
g5tom