Crewing of inexperienced flight crew members | easa

[C212-100]

Dear all,

Taking into account EASA ORO.FC.200 Composition of Flight Crew and the reference to crewing of inexperienced flight crew, EASA’s definition of inexperienced flight crew member is, to my understanding, not clear and a clarification on it would be very helpful. With reference to the writings in your own OM (Part A and D) and referring also to your previous experience from your NAAs what would be your answer to questions below:

1) Would you consider a PIC rated and qualified as TRI on a Bombardier Challenger 850 as inexperienced on completion of his type-rating course on the Bombardier Challenger 604/605?

2) Would you consider a PIC previously rated on the Challenger 604/605 (but not current) as inexperienced on completion of a new type-rating course on the Challenger 604/605?

Hope this two questions and respective answers will help on your assistance.

Thank you for your help and clarification.

[Albus_Dumbledore]

Dear C212,

I think it is clear enough tbh.

1) Yes he is considered inexperienced. IF, it is a new type to an AOC/Introduction of a new type, then your NAA has the right under EASA to present a safety case as experienced, to provide crew training/operations. For example, I was a LTC on the Falcon 2000 series, and was nominated as an experienced LTC from completion of type rating to complete all the flight crew training.

2) No, he would not be considered as inexperienced, provided he had completed enough hours to meet the experienced requirement, prior to his renewal. This is best managed through your OM-D in terms of his previous experience and also your requirements for Line Training to get said crew member back up to speed.

Feel free to get in touch with any other Q's.

Albus

[C212-100]

Dear Albus,

Thank you very much for your reply.

Regarding 1), being that we've done our own Operational Risk Assessment with mitigation measures to compensate for the (slight) differences in procedures on the CL650, when compared with the CL850 we've assessed the need for at least 10 LIFUS sectors to be performed by that PIC under an EASA rated TRI supervision. The TRI report on pilot's performance was that he was above average and very comfortable with the aircraft and SOPs. They are, basically, the same, to be honest.

Regarding 2), the PIC in case has logged more than 1,300 hours on type between 2007 and 2010. He lost his currency on the aircraft in 2010 when he moved to the CRJ 100/200. He now went again through a full TR on the CL604/605. Nevertheless, he has gone through 6 LIFUS Sectors with and EASA TRI as a way to make sure he was up to speed on the aircraft and in fact he proved to be an above average pilot.

Our current OM(D) says nothing about Line Training requirements apart from the regular EASA requirements. I am in the process of reviewing it with our Training Manager to have a decent OM(D) covering all training needs.

Taken the description on 1) above would you still say that after the training and LIFUS the pilot as carried he would still be considered as inexperienced.

I understand EASA drafts common rules in the domain of Air Ops and the implementation of those rules is the exclusive prerogative of each EU Member State through the NAA.

Unfortunately, our NAA is not up to speed with regulations and therefore taking a very conservative approach to Regulations. In this particular case they are requesting each pilot to conduct 100 flight hours and 40 sectors as per AMC1 ORO.FC.200 (a).

Your thoughts on the above are very much appreciated. Just as means of brainstorming as currently what we're facing is the above requirement. On Business Aviation to have a pilot undergo 100 flight hours and 40 sectors under supervision of a TRI before being considered experienced, even when said pilot is a CL850 (same manufacturer and same model as per EASA TCDS IM.A.023 relating to Bombardier CL-600) qualified PIC and TRI, sounds a bit too much and putting at stake the operational feasibility of operations.

Kind regards,
C212

[BizJetJock]

Two points to bring up with your NAA:
LIFUS does not have to be done with a TRI. You can nominate Line Trainers if you have other suitably experineced Captains.
For the inexperienced crew criteria, AMC1 ORO.FC.200 (a) paragraph (b) says:
(b) A lesser number of flight hours or sectors, subject to any other conditions that the competent authority may impose, may be acceptable to the competent authority when one of the following applies:
...
(5) the aeroplane has a maximum take-off mass of less than 10 tonnes or a maximum operational passenger seating configuration (MOPSC) of less than 20.
I know of operators who have got their Part D approved with the 10 sectors and no hours requirement under this provision.