Working Group Optimum Part66 Type Qualification Status Report

Working Group „Optimum Part-66 Type Qualification“ Status Report Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 1

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 2

EAMTC Working Group „Optimum Part-66 Type Qualification“ Review Group Members: Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 Frank Kabuth Hans Uhl Juan Mateos Pierre Liege Thomas Jobs Tom Aasheim 3 LTT AI IB AF SAS

EAMTC Working Group „Optimum Part-66 Type Qualification“ Review Goal of the task group Q The Optimum JAR 66 Type Qualification for B 1/B 2 (Generic Aircraft) ÄTraining Syllabus ÄGuide for the Aircraft Type Examination ÄPractical Training Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 4

EAMTC Working Group „Optimum Part-66 Type Qualification“ Review Sevilla QThe last EAMTC meeting took place in Sevilla/Spain in September last year QIn October TGL 40 was published in it´s final version (Draft 6) QThe former Drafts were also discussed with JAA by EAMTC Äremember - the matrix of TGL 40 is a result of the working group QFirst drafts of ECAR´s appeared followed by associated AMC´s Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 5

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 6

EAMTC Working Group „Optimum Part-66 Type Qualification“ Legal Situation 2002 Aug 2002 Oct 2002 2003 Jan 2003 2004 Mar 2003 Jul 2003 Sep 2003 JAR §§ > Part §§ JAA IEM + AMC´s > EASA AMC´s Freeze Phase EU Commission In Force Legal Review In Force EASA TGL 40 Normally active until Oct 2004 Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 7

EAMTC Working Group „Optimum Part-66 Type Qualification“ Relationship between TGL 40 and Part 66 Appendix 3 2002 Aug 2002 Oct 2002 2003 Jan 2003 Mar 2003 2004 Jul 2003 Sep 2003 JAR §§ > Part 66 JAA Part 66 Appendix 3 Type Training EU Commission Partially Legal Review In Force EASA TGL 40 Normally active until Oct 2004 Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 8

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 9

EAMTC Working Group „Optimum Part-66 Type Qualification“ WG - Action From Sevilla until Now The working group held four 2 -days meetings in 2003 QFrankfurt January 2003 QMadrid February 2003 QOslo March 2003 QParis July 2003 Plus one meeting with JAA May 15 th 2003 in Amsterdam Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 10

EAMTC Working Group „Optimum Part-66 Type Qualification“ WG - Action Meetings Due to the legal situation we made following decisions QThe basis for all our work and comments to the JAA is TGL 40, disregarding the ECAR draft, because it would be too much to concentrate on both documents QFirst we started with theoretical and exam parts QFollowed by the practical part QWith our comments we don´t want to wait until the next EAMTC meeting, due to short time left Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 11

EAMTC Working Group „Optimum Part-66 Type Qualification“ WG - Action Meetings QAll decisions were put down in the minutes for every meeting QThe minutes were summarised in a presentation QThe presentation was held at JAA headquarter Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 12

EAMTC Working Group „Optimum Part-66 Type Qualification“ WG - Action Presentation Highlights QReferences to basic training QSynthetic training devices QPractical training duration The meeting with JAA took place May 15 th in Amsterdam. EAMTC delegates: Daniel Mendes TAP Gerard Galea AF Frank Kabuth LHT and Mr. Jean-Mark Cluzeau from JAA Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 13

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 14

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA How to read the following pages: The text of TGL 40 is written in grey. If there any parts of the text which are followed by a comment or proposal they are highlighted in green. All proposals or comments from the working group are in pink. Results of the meeting in documentation or minutes like “agreed by JAA”or “see AMC 66. A. 45(d) intermission 3” are in blue. Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 15

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA § 8. 2 The course should also take into account the following: a) In service experience on the aircraft type. b) Feedback from in service difficulties/occurrence reporting etc. c) Significant Airworthiness Directives and/or Service Bulletins. The basic elements of JAR 66 are not required-only those elements appropriate for the rating being sought are required. Shouldn't the paragraph 8. 2 (a) read: In service experience of the aircraft type? Delete last sentence, because it refers to basic training agreed by JAA - no references to basics Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 16

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA 8. 5 The theoretical training syllabus should be supplemented by training aids such as: The review of aircraft or system hardware including the use of training aids e. g. aircraft system components. Ground simulator time, engine ground running and computer based training (CBT) etc may also be utilised. When the intention of this paragraph 8. 5 is to address and name training aids, it should better read: The theoretical as well as the practical training may be supplemented by the use of training aids, such as: Aircraft or aircraft components, synthetic training devices, computer based training devices, etc. Refer to terms used in JAR 147. 45 (a) & (d) and IEM 147. 45(a). agreed by JAA(agency) - see AMC 66. A. 45(d) intermission 3 Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 17

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA 9. Practical elements of the B 1 and B 2 type training. 9. 1 In addition to theoretical elements specified in AMC 66. 45(b)(1)(2) and (3) it should be noted that the practical element forms part of the particular aircraft type training as detailed in AMC 66. 45(b) (4). However, it is acceptable that the performance of such training, including the assessment of trainees, be performed directly by the JAR 145 approved maintenance organisation. In this case the JAR 145 approved maintenance organisation must confirm to the JAA-NAA that the trainee has been assessed and has successfully completed the practical elements of the training course to satisfy the requirements of JAR 66. 45(b)(5). The JAA/NAA will have to agree how the practical elements are assessed, for example under a procedure as agreed by the Authority or on a case by case basis. Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 18

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA. . . The working group comes to the conclusion that in respect to practical training the AMC 66. 45 (b)4 and 5 could be misinterpret due to unclear wording. Therefore th WG has the following proposal: AMC 66. 45(b) 4 should read: „The practical training should last a minimum of 2 weeks for certifying staff with recent recorded experience on aircrafts within the same JAR 66 sub-category. For personel without this practical experience a period of up to 4 month is required. This period may be performed before attending the type course. “ We very much appreciate a clear definition of the terms „Practical Training“ as well as „OJT“. . . Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 19

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA. . . We ask the EASA to define these Terms in the new ECAR 66 Notwithstanding the WG proposal concerning the rewording of AMC 66. 45 (b) 4 and 5 it should be possible to reduce these 2 weeks (10 days? ) when agreed by NAA. There will be no further definition of practical training and OJT. The current terms allow the conduction of the practical part by means of “practical training”, “structured OJT” or “OJT”. Some parts of AMC 66. 45(b) are included in the new AMC to ECAR 66. 45(d). There will be no change to the current wording. No change from “comparable construction and systems including the engines” to “. . . within the same JAR 66 sub-category”. Practical training should cover new technologies and skills. Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 20

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA § 9. 3. 1 point 5. The minimum two weeks practical training is normally required for all type training courses. This includes the addition of similar type ratings on a JAR 66 Licence (differences courses). There may be cases where the practical differences training required is less than two weeks for example an Engineer with a JAR 66 type license in category B 2 on an Airbus A 330 with PW 4000 engines who takes a differences course to an Airbus A 330 with Rolls Royce Trent engines. General proposal: Point five should be a note or full text, because there is no reason why point 5 should lead to any reduction of the four month Change ”B 2” to ”B 1” Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 see next slide. . . !! 21

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA AMC 66. B. 115 “In the case of difference training for a similar type, the competent authority should be satisfied that the candidates previous qualification supplemented by the difference training is acceptable as regards the type endorsement. ” Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 22

EAMTC Working Group „Optimum Part-66 Type Qualification“ Meeting with JAA Further Highlights There were some additional points, which should be changed through NPA process. QPractical Training less than 10 days QNumber of questions for theoretical exam. QThe strong need to stay with the ATA chapters and their titles QAdding of new ATA chapters (44, 46, 50) Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 23

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 24

EAMTC Working Group „Optimum Part-66 Type Qualification“ Implementing Rules Further Highlights Comments on the above points were done by Frank Kabuth on behalf of the working group and also distributed to all other EAMTC members to sent these comments from their companies also to the JAA. Until now there is no feedback or response from JAA Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 25

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 26

EAMTC Working Group „Optimum Part-66 Type Qualification“ Future Actions Back in Sevilla In Sevilla we were ask by the EAMTC members to extend the scope of the WG to include CAT “A” and CAT “C” type training. The members of the working group decided to finish what we have started. So we tried to finish our job on type training for B 1 and B 2. We will start our work with CAT “A” in the near future (if you agree!? ) Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 27

EAMTC Working Group „Optimum Part-66 Type Qualification“ Agenda Review Rückblick Legal Situation WF/Q 2001 bis Working Group Action Meeting with JAA Implementing Rules Future Action Conclusion Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 28

EAMTC Working Group „Optimum Part-66 Type Qualification“ Conclusion Q WG syllabus for B 1 / B 2 type training found in Part 66 appendix 3 (90%) Ä small changes addressed by WG Q WG recommendations concerning exam questions mostly found in “Guidance to 66. B. 125” Ä WG comment (IR) regarding number of questions in progress Q Practical Training: From our point of view the door is opened to reduce the duration below 10 days (AMC 66. B. 115) Ä WG comment (IR) regarding duration of practical in progress Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 29

EAMTC Working Group „Optimum Part-66 Type Qualification“ Conclusion Goal of the task group Q The Optimum JAR 66 Type Qualification for B 1/B 2 (Generic Aircraft) Ä Training Syllabus Ä Guide for the Aircraft Type Examination Ä Practical Training Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 30

Thank you very much for your attention Frank Kabuth Lufthansa Technical Training AG OCTOBER 2003 31