Differences training - changes?

[FlyingForFun]

I was discussing differences training with a colleague this morning, and downloaded the latest version of JAR FCL 1 to look up a fairly minor point.

I'm not sure of the exact date of the lastest version, because each page number has its own date on it, but some of the pages are labelled Ammendment 5, and dated 1/3/06, so it seems to have been ammended pretty recently.

The previous version listed, very clearly, the differences in SEPs which required differences training. It was less clear about the differences which require differences training on MEPs, and in fact this was exactly what we were trying to look up.

But, unless I am mistaken, the list of what requires differences training has been completely removed???

All we could find was JAR-FCL 1.215, which states that:

Class ratings for aeroplanes will be issued according with the associated administrative procedures accepted by the JAA. In order to change to another type or variant of the aeroplane within one class rating, differences or familiarisation training is required.

JAR-FCL 1.235 goes on to define "Differences training" as requiring training on the aircraft or a simulator, and "Familiarisation training" as being the acquisition of additional knowledge, which is nothing new.

So it seems now that, to fly any new type requires either familiarisation training (which might consist of just reading the POH) or differences training. But there is nothing which specifically requires differences training any more.

What this means is that, having completed a PPL on a C152, a PPL can now read the POH for, say, a tail-dragger, then jump in and go flying with no extra training.

Is this really correct? Or have we missed something???

FFF
----------------

[Rivet gun]

I suspect the reason for the change is to allow the national CAAs some flexibility in determining precicely under what circumstances differences training is required, or when just familiarisation training will suffice.

The problem with being too specific in the regulations is that it makes it difficult to respond appropriatly to new techonologies. I think the CAA will take a practical approach in requiring differences training where significant new skills can only be properly acquired through actual flight (or simulator) training.

For example, EFIS cockpits now require diffenences training, though this was not in the original JAR document.

New engines present further issues. The original JAA document specified differences training for turbo charged engines, but they had in mind engines with waste gate / boost controls etc. The modern turbo diesels (Wilksch and Centurion) and the Rotax turbocharged engines do not have cockpit controls asociated with the turbocharger and do not require differences training (i.e familiarisation training is sufficient).

However, consider the case when the turbo diesels are used for ab initio training. It will then be possible to get a PPL or CPL without ever encountering magnetos, mixture control or carb heat control. The pilot would then require differences training before operating conventional AVGAS engines.

[FlyingForFun]

I absolutely take your point, Rivet. Except for the bit that:

I suspect the reason for the change is to allow the national CAAs some flexibility in determining precicely under what circumstances differences training is required, or when just familiarisation training will suffice

With new technology being introduced all the time, surely it would make more sense to centralise the requirements for differences training? For example, rather than every single JAR state individually requiring differences training when converting from (to use one of your examples) a deisel to a conventional spark-ignition engine, wouldn't it make sense for JAR to continue to dicate the training required centrally, and then each member state's legislation to simply defer this to JAR? After all, member states have always had the ability to override JAR when they need to in any case.

If you are right, though, I would expect to find details on what requires differences training in the ANO. There was nothing in there the last time I looked, but that was before it was removed from JAR, so I shall download the latest version of the ANO and check there....

FFF
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[Charley]

Try this - does it have any bearing? On it's own, it would still suggest that (for example) tailwheel aircraft still require differences training, and that any MEP aircraft will required differences training from any other MEP aircraft.

There's a similar thread in another forum (clicky) where the same problem is looked at from a slightly different angle.

[FlyingForFun]

Charley,

That first link is to a piece of text which used to be in the JARs, but is not any longer. As far as I can see, it is not referenced by any legal document, therefore no longer has any weight in law. (This is quite aside from the fact that it is not clear what it means regarding multi-engines - I interpret it to mean that once you have had training on a multi-engine aircraft you are covered for any multi-engine aircraft without further training.)

The mystery deepens now that I have checked the ANO. The ANO now says, in Article 29:

The holder of a pilot's licence to which this article applies shall not be entitled to exercise the privileges of an aircraft rating contained in the licence on a flight unless -

(b) the holder has undertaken differences training in accordance with paragraph 1.235 of Section 1 of JAR-FCL 1 in the case of an aeroplane and paragraph 2.235 of Section 1 of JAR-FCL 2 in the case of a helicopter and has had particulars thereof entered in his personal flying log book in accordance with the relevant paragraph.

So what this seems to say is that, for any aircraft type, you must carry out differences training (which must include training on an aircraft or simulator, and a sign-off by an instructor) - which is the complete oposite to my earlier interpretation.

Or does it? My colleague interprets it differently; he says that the ANO says you must have differences training in accordance with the JARs, but the JARs, although they define differences training, don't mandate it, therefore it is not mandatory.



Whichever way you look at it, the list of differences which Charley refers to no longer appears in JAR FCL 1.

FFF
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[Charley]

Perhaps so, FFF. But the rule states:

Originally Posted by JAR-FCL 1

Class ratings for aeroplanes will
be issued according with the associated
administrative procedures accepted by the
JAA.

So couldn't that page form part of the 'associated administrative procedures'? Particularly since it the list was updated relatively recently (1st Feb) and in the absence of any other list?

Maybe there may be some pertinent stuff in the Licensing Administrative & Guidance Material, however I've not been able to find it online unless one pays the subscription for it.

Edited to add:

Originally Posted by FlyingForFun

This is quite aside from the fact that it is not clear what it means regarding multi-engines - I interpret it to mean that once you have had training on a multi-engine aircraft you are covered for any multi-engine aircraft without further training.)

Maybe it's unclear because key seems to have dropped off the list! (D) in column 3 denotes differences training required between variances in column 2. (HPA) denotes the high performance aircraft category that is referred to in, for example, JAR-FCL 1.251.

[DFC]

The list of Class Ratings, Type Ratings and associated requirements for differences training has been taken out of JAR-FCL 1 and placed in an admin document which is refered to by JAR-FCL 1. Makes sense not to have to amend JAR-FCL and follow the full NPA procedure just to add a new type.

There has not been any change in the requirements;

Differences trainng required to fly another single if it has VP prop, retractable gear, turbo etc as before. Once completed, differences training in SEP class aircraft does not expire.

Differences training is required to fly any other type of twin. If that type has not been flown in the past 2 years then differences training or proficiency check is required.

For the current list go to the JAA www.jaa.nl and then choose "licensing" and then from the list choose "Licensing class and type ratings - list of aeroplanes"

Regards,

DFC

[FlyingForFun]

The list of Class Ratings, Type Ratings and associated requirements for differences training has been taken out of JAR-FCL 1 and placed in an admin document which is refered to by JAR-FCL 1.

Thanks, DFC, that's exactly what I was looking for - but can you please quote me the place in JAR-FCL 1 where this document is referenced???

At the risk of going off-topic:

Differences training is required to fly any other type of twin

That would indeed be logical - but it's not the way I interpret the document. Column 2 describes the difference that requires differences training. For example, the sixth line down is "Single-engine piston (land) with Tail Wheel (TW)". Once differences training on this difference has been completed, a pilot can operate the privileges of his rating on any aircraft which has this difference.

Moving on to the second table, which is for MEPs, the only difference shown for land-planes in that table is "Multi-engine piston (land)". I can not see how this could be interpreted to mean that every multi-engine piston (land) type requires differences training; if you said that every MEP requires differences training, you would have to apply the same logic to SEP and say that every different tail-dragger type requires differences training, no?

FFF
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[DFC]

1.215 (b) is the reference.

Each multi engine type within the MEP class requires differences training. This is shown by the D in column 3 contained within horizontal lines above and below the MEP (Land) class.

If there was a requirement to complete differences training for each SEP tailwheel aircraft then the horizontal lines above and below would extend across column 3.

Regards,

DFC

[Rivet gun]

Originally Posted by FlyingForFun

I absolutely take your point, Rivet. Except for the bit that:With new technology being introduced all the time, surely it would make more sense to centralise the requirements for differences training? ----------------

Yes I agree differences trainining requirements should be centralised, but if EASA moves slowly in response to new technology, the CAA can still pre empt them with their own differences training requirements or reccomendations. See AIC (pink) 31/06 and 32/06 for examples.

My previous example of pilots qualifying ab initio on diesel engines has not yet arrisen, but when it does I am sure the CAA will respond with a AIC on the matter.

[Propellerhead]

From the CAA LASORS document :

Differences Training in aeroplanes within the SEP class
rating is valid indefinitely. If a type, or variant of a type,
within the SEP class rating, has not been flown for
some time, pilots must use their judgement to decide if
refresher training is warranted. However, it is
recommended that such re-training be undertaken
when the lay-off is more than two years.
If a type or variant, within any other class or type rating,
has not been flown within the preceding two years,
further Differences Training, recorded again in the
pilots logbook or a proficiency check, on that type or
variant, is required.Instructors must consider the contents of Section F