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5/13/91 AC 120- 53
Appendix 1

ATTACHMENT 4 -

TYPE RATING AND DIFFERENCE LEVEL TESTS - PLANNING AND APPLICATION

SECTION 1. Preparation.

1.1. The type rating, difference level definition, and test process are
initiated when a manufacturer or modifier presents an aircraft for type
certification as a “new type,” “derivative“ of an existing type, or for a type
rating ‘*common” with an existing type. If the manufacturer presents an
aircraft as a new type, then type rating and training program requirements are
analyzed as previously established, except that T5 is now formally used as the
means to set FAR Part 121 required training, checking and currency standards
as applicable to that type, For aircraft in which a common type rating is
sought, the process described below, primarily using Tl, is applied. Special
“common type” cases may occur where T2, T3, or T4 are needed. Details of
these situations require further amplification z&i are provided in the
AC/Appendix itself. If the manufacturer proposes a derivative aircraft, the
following process applies starting with Tl. In any event, type rating and
crew qualification requirements must be set prior to TC/STC and before an
aircraft enters Part 121 service.

1.2. To begin the evaluation process, the manufacturer or modifier identifies

models and general variations of models existing in that particular fleet.
The model variants are then assigned to logical groups to be described in MDR
tables and the FSB report.

l.3. Major differences pertinent to the various models are identified and
comparisons are made with the proposed new model. These differences are
summarized in a differences document which include appropriate sample operator
difference requirements (ODR) tables. Since combinations of all approved
model configurations may be numerous, some combinations will never actually be
flown, and only typical differences are needed at this stage for test
definition, the applicant may select representative ODR for preparation.
Similar models are then included in the groups as noted in paragraph 1.2 above
for analysis and testing to set the MDR table and FSB requirements.

1.4. Based on the above analysis (including preliminary flight test results
or flight simulation estimates if available), the manufacturer proposes
probable “difference levels” to be specified in each “cell” of the master
difference requirements table for the various model pairs.

1.5. The manufacturer proposes applicable elements of the test process (Tl -
T5) and a plan for validation of the intended difference levels. Specific
aircraft, times, devices, etc. are identified to conduct the required tests
for the pertinent model pairs. Included in the proposal are any necessary
interpretations of expected results using advisory circular or established

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practical test standards (PTS). Any special, unique ! or additional

definitions of successful outcomes are also identified.

1.6. The scope of Tl - T5 is keyed to basic VFR and .IFR operations in the
NAS. For IFR operations, consideration is given and standard operating
procedures apply in cases such as takeoff noise abatement procedures, SIDs,
STARS, ILS, VOR, and NDB approaches. Routine “line” situations of inoperative
equipment, operations in various types and densities of airspace, adverse
weather, etc., are incorporated. However I investigation of special or unique
systems or operations such as oceanic navigation in minimum navigation
performance specifications (MNPS) airspace, extended range operations (EROP),
or category III, are considered only to the extent that crews demonstrate
proper basic operation of systems which are integral to the overall operation
of the aircraft (e.g., alignment of inertial reference unit (IRU), programming
of fliqht management system (FMS) r correct use of the automated flight control
system” (AFCS) including autoland, interpretation of electronic centralized
aircraft monitoring (ECAM), engine indicating and crew alerting system
(EICAS), or other types of annunciation, etc.). Any of the above special or
uniqlue issues may, when appropriate, be incorporated in MDR tables, footnotes,
or ODR example tables when consistent with pretest applicant/FAA agreement.
Although MDR/FSB evaluation may not in certain cases specifically include
certain differences (e.g., HF radio), individual air carrier ODR’s for
particular aircraft will identify, evaluate, and address compliance for these
items.
1.7. FAA/manufacturer agreement is reached on the grouping of models,
proposed tests, test plans, schedules, subjects, and interpretation of
possible outcomes.

1.8. Test subjects for all tests except for “extended T3“ (if extended T3 is
needed) are drawn from the FAA FSB. Subiect
c selection considers the factors
such as follows:

(a) Needed bac k ground skills of candidates (previously qualified types);

(b) General flight experience and currency;

(c) Test requirements such as location, short notice access, and skills
needed for subjects;.

(d) Technical areas, qualifications, or experience that subjects should

not have in order to avoid test prejudice;

(e) Eventual FAA geographic or operator related distribution requirements

for ACI, APM, and principal inspector personnel;

(f) Other special experience as needed for a particular program.

Subiect
M qualifications are addressed at the time of test specification when

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test agreement is reached with the applicant.

1.9 Flight Test Branch Coordination. During preparation for testing and
evaluation of results, appropriate Aircraft Certification Flight Test Branch
coordination is accomplished so that flight characteristics issues and, in
particular, special flight characteristics can be suitably identified and
addressed.

SECTION 2. Functional Equivalence - Level A or B - TEST 1 (Tl)

2.1 Tl is conducted to establish that two variations of the same type

aircraft are functionally equivalent and may be assigned difference level A or
B The test is also the first test performed if the manufacturer is seeking a
Gammon type rating.” If analysis shows that the differences between aircraft
are relatively minor and level B at most can cover difference training,
checking, or currency requirements, test Tl is appropriate. If differences
are projected to be major, requiring level C, D, or E, Tl may be waived and T2
and T3 directly applied. In this event the FAA must agree to the waiver of
Tl, and the applicant must agree that the aircraft pair will at least be
classed as a level C or higher.

2.2 Tl is typically conducted using two groups of test subjects. Each group
is trained in one aircraft, given a “no jeopardy” test to establish a baseline
on their primary aircraft, and then they are given a similar “no jeopardy”
test on the other aircraft. The symmetry of the test, from a subject sample
size and base aircraft qualification point of view, is determined by the
particular test to be administered. Symmetry and sample size may vary
depending on information already known, expected outcome of the test,
criticality of the test, or anticipated need for consideration of that pair of
aircraft in the MDR’s.

2.3 The test consists of a Part 61, Appendix A type rating flight test or
Part 121, Appendix F proficiency check. A subset of FSB members review the
candidate test to be administered to be sure it examines critical aspects of
the pertinent aircraft pairs. The tests 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.

2.4 For Tl a “safety pilot,” serving as first officer for the test, may
intervene to prevent damage to the aircraft or to limit maneuvers which
endanger safety of flight.

2.5 Test outcomes are documented by maneuver or procedure including

successes, problems, and failures.

2.6 Subjects for Tl are chosen from FAA FSB members. Outcomes of Tl are
decided by FSB members and are consistent with previously agreed upon
criteria.

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2.7 If both groups of subjects clearly pass, the pertinent aircraft pairs may
be assigned level A or level B.

2.8 If either group of subjects clearly fail the test, level A or B may not
be assigned for that particular aircraft model pair. T2, and if appropriate
T3, are then conducted for that pair.

2.9 When Tl is passed a level A or B determination is made. If issues

warrant training beyond level A described below, then level B is assigned.
The FSB determines the areas of differences training required and specifies
necessary devices or training limitations.

2.10 Use of level A is limited to situations where the knowledge requirement

is such that understanding and compliance can be assumed to take place. Level
A is accordingly limited to situations such as the following:

(a) The change introduces a different version of a system/component for

which the flightcrew has already shown the ability to understand and use
kg. t an updated version of an engine);

(b) The change results in minor or no procedural changes and does not
result in adverse safety effects if the information is not reviewed or is
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 which highlights a difference which once called to the

attention of a crew is self-evident, inherently obvious, and easily
accommodated (e.g., different location of a communication radio panel, a
different EGT limit which is placarded, or changes to non-normal “read and do”
procedures).

2.11 Differences which cannot be accommodated by one of the above categories

as an upper limit are assigned level B. Typically for level B, the
differences information is more complex or it.may require.a more formal means
to assure standardization. .Additional considerations for level B may be the
need to assure attention, understanding, or emphasis, during training, or
retention after training. Level B training is achieved by aided instruction
such as use of slide tape presentations, CBT training, or other similar
techniques.

SECTION 3. Handling Qualities Comparison - TEST 2 (T2)

3.1 T2 identifies handling quality differences that warrant use of advanced

simulation (phase II/III simulators) or aircraft training. It considers
needed motion cues, critical visual cues, and significant differences in
handling characteristics that potentially affect training, checking, or
currency or devices needed in their accomplishment.

3.2 Passing T2 is interpreted as meaning that the “base aircraft” and

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‘*subject aircraft” are sufficiently similar in handling characteristics so

that separate aircraft or advanced simulator training, checking, or currency
are not needed with respect to handling.

3.3 Failure of T2 means that handling differences are great enough that
separate advanced simulation or aircraft training or checkingis required for
certain paris of models tested. Accordingly, level E is applied, and the FAA
assigns a separate pilot type rating for pertinent models within the fleet.

3.4 A partial test success may result in a requirement that only certain
maneuvers be done in the same advanced simulator or the aircraft.

3.5 The procedure for application of T2 is as follows:

(a) The manufacturer or modifier analyzes design or system differences

which could affect handling qualities. A comparison is made of available
flight or simulation test data to make a preliminary estimate of the outcome
of and need for T2;

(b) The proposed model is then compared with existing aircraft simulator
approval test guides (ATG’s) or flight test data, and differences are noted:

(c) From this list differences which could affect handling

characteristics, motion cues or visual cues are identified:

(d) The resulting handling quality related events, maneuvers, or

conditions which could require training, checking, or currency in either an
aircraft or simulator are identified.

3.6 If the analysis shows T2 is very unlikely to be failed, then T2 may be

incorporated, with FAA agreement, in T3 for purposes of verification that an
advanced simulator or aircraft training is not needed to address handling
qualities.

3.7 In T2, subjects trained only in their “base aircraft” fly the other
aircraft under the supervision of a trained safety pilot. The safety pilot
can only provide assistance to 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.

3.8 The safety pilot may:

(a) perform all routine pilot-not-flying (PNF) duties:

(b) may set up or adjust systems including those normally operated by

the pilot-flying (PF) in accordance with pretest agreements:

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(c > may address or resolve procedural impediments;

(d) manage and satisfy checklists;

(e) make normal call outs.

3.9 The safety pilot may not:

(a) actuate primary flight controls during the evaluation:

(b) instruct, lead, or coach test subject in any manner;

(c) describe or interpret instrument indications in a manner which is

perceived as coaching.

3.10 Prior training of subjects in the variant under evaluation is not

permitted. Subjects will be given a flight check in their “base aircraft”
initially to calibrate performance prior to taking the pertinent “check’ in
the variant being evaluated. Special provisions may be required when primary
flight instrument symbology or concepts alone could mask proper evaluation of
similarities or differences in handling characteristics.

3.11 The T2 process is the same as described in section 2 above. T2 is

typically conducted using two groups of FAA subject pilots. Each group is
trained on one aircraft only, given a ‘no jeopardy’ check to establish a
baseline on their primary aircraft, and then given a similar ‘no jeopardy’
check in the other aircraft.

3.12 The symmetry of the check from a subject sample size and base aircraft
qualification point of view is determined by the particular tasks or maneuvers
to be evaluated. Symmetry and sample size may vary depending on information
already known, expected outcome of the evaluation, criticality of the task, or
anticipated need for consideration of that pair of aircraft in the MDR’s.

3.13 The evaluation consists of relevant parts of a Part 61, Appendix A, type
rating flight check or Part 121, Appendix F proficiency check. A subset of
FSB members review the required maneuvers to be evaluated to be sure they
examine critical handling quality aspects of the pertinent aircraft pairs.
Subject pilots will be evaluated on performance of required maneuvers
consistent with practical test standards (PTS), as well as a qualitative
assessment of ease or difficulty of performance of maneuvers compared with the
base aircraft. A comparison to the base aircraft will be made for each
required maneuver. Subject pilots for T2 are selected from FSB members.

3.14 The evaluation is observed by more than one FSB member to ensure
consistency and uniformity of procedure and assessment of outcomes.

3.15 If T2 is failed, level E applies, and flight training must be conducted

in the aircraft, a different advanced similiter, or an advanced simulator that

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can model the handling and systems of each respective model. With a T2
failure, the next step in the testing process is T5, to validate level E
program requirements and training footprints. T3 is not appropriate, and
levels C or D may not be assigned.
4.1 T3 is a systems differences test which has multiple functions. T3
identifies master difference requirements (MDR’s) at C and D levels, validates
training profiles, methods, devices, and checking necessary or appropriate at
level C or D. In certain critical failure cases T3 can lead to assignment of
level E and a separate type rating (see paragraph 4.10). T3 is used only when
the equivalent handling test (T2) has been successfully completed or when T2
is being incorporated as part of T3. T3 (and similar T!?) is fundamentally
different than Tl and T2 in that proposed or typical training is permitted
prior to conducting the test. Training is based on methods, times, devices,
and footprints to be designated as the minimum when later specified in the MDR
table. In Tl and T2, training is not appropriate or permitted, but in T3
training is integral to the test. T3 training footprints should provide for
adequate training, considering typical experience of Part 121 crews, and need
not compensate for or assume air carrier entry level skills. Conversely, T3
training should not require unusual or extraordinary skills or efforts of
subjects to augment or compensate for minimum training in order to pass T3.

4.2 T3 is a two-part test consisting of:

(a) A Part 61, Appendix A ATPC type rating check: Part 121, Appendix F
proficiency check; partial proficiency check; or proposed system check
administered to subjects in the test aircraft. The check is administered
assuming currency in the base aircraft and completion of the proposed training
in the differences aircraft. If a full check is proposed, the tests are
similar to those used for Tl or T2 as described in section 2 above. If a
partial check is used, the process is similar, but the test items are
determined by the FSB considering or based on manufacturer and/or air carrier
proposals.

(b) A line oriented flying (LOF) test is then conducted to verify that
the difference aircraft can be safely operated in a line environment and to
evaluate application of the proposed training and checking in typical line
scenarios and operations. The LOF may focus on special situations particular
to certain model pairs, verification of overall adequacy of training or
checking, the potential of negative transfer from one model to another, or
unique fleet related issues.
4.2.1 LOF may also consider scenarios where crews potentially could make
subtle or inadvertent errors that could place either the base or difference
aircraft in jeopardy. For this analysis or evaluation, recall as well as less
time dependent written procedures are considered.

4.2.2 In developing and selecting scenarios for evaluation the following are
considered: likelihood of occurrence, possible consequences, and opportunity .

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for crew discovery and correction are considered.

4.2.3 LOF may be done in an aircraft, in a simulator, or both per pretest

agreement, LOF in some instances may require actual demonstration of mixed
fleet flying by alternating between base and differences aircraft.

4.2.4 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 crew knowledge and skills in a limited and highly structured
environment. LOF is an integral part of T3 and must be successfully completed
prior to “initial’* assignment of difference levels (extended T3, if used, need
only be completed prior to final level approval).

4.4 As in Tl and T2, subjects for T3 are chosen from the FAA FSB. Following
completion of LOF and setting of the initial MDR’s at the time of TC/STC, an
expended T3 process may be proposed. This is done to get additional line
experience and level verification. If an extended T3 phase is used, certain
non-FAA pilots (from the manufacturer or air carriers) may be included in
order to get a larger statistical sample for assessing training, checking, or
currency levels and device effectiveness. When non-FAA personnel are included
as subjects in an extended T3 process, the FAA and applicant must agree on
subject group composition before the test. Checks in the extended T3 process
are administered by FAA FSB members. Non-FAA pilot participation is limited
to serving as a subject for extended T3 checks or serving as an extended T3
LOF subject.

4.5 Non-FAA subjects are only included in an extended T3 process following

initial approval of differences levels by the FSB and during the period when
air carriers implement their individual programs. During this phase FSB
representatives observe crew performance during training, administer a
sampling of checks, and observe line performance. Information from this phase
is considered during the first FSB meeting following TC, usually occurring six
months later when final levels are set.

4.6 Outcomes of T3 and extended T3 are decided by FSB members, consistent

with previously agreed upon criteria. FAA practical test standards form the
basis for T3 evaluation criteria.

4.7 A successful outcome of T3 includes passing all or a previously agreed

upon sample of checks and completion of LOF with appropriate crew performance.
4.8 Failure of T3 occurs with either failure of a series of checks or a pre-
agreed critical check, or unsatisfactory performance during the LOF portion of
the test. In the event of a failure, more comprehensive programs may be
proposed and retested within the same level or at a higher training or
checking level. Additional devices may be proposed or time increases made to
proposed differences level. In the case of retesting, new subjects may be
required if program effectiveness cannot be established with subjects who
already have been partially trained at the failed level.

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4.9 When the test outcome is satisfactory, the FSB sets the minimum
difference level at level C or D as appropriate. Documentation for the
difference level specified may include training objectives, methods, minimum
devices considered acceptable, times, training footprints, checks or currency
constraints.

4.10 During T3 level D tests, certain critical situations, problems, or

failures may require assignment of level E rather than level D. Assignment of
level E may be required in the event of:

(a) T3 experience or difficulties which show the need for assignment of

training levels approaching typical initial/transition levels, or

(b) T3 crew performance which indicates that devices or methods

associated with level D are not adequate to achieve training or checking
objectives, or

(c) repeated failures of attempts to pass test 3 at level D.

4.10.1 Repeated failure at level D refers to failures of T3 due to one or

more subject’s inadequate knowledge, skill, or ability due to variant
differences or the limited success of training programs or devices, rather
than individual subject failure due to sub-par or atypical personal
performance. Sequential increases of training times, footprints, or other
program requirements due to failures, to a value approaching typical initial
or transition qualification levels, or marginal or uncertain performance of
subjects following programs proposed at or slightly less than
initial/transition levels may also require level E. Values slightly less than
or approaching typical initial transition levels are decided before T3 starts,
on a case by case basis, using some appropriate criteria or measure suited to
the applicant’s proposed program (academic subjects, maneuvers, times,
simulator periods, student behavioral objectives (SBO), crew performance
objectives (CPO)) etc.). In cases of marginal performance or where test
failures show the need for training using a high fidelity environment (phase
II/III simulation) to attain program objectives, then the FSB may assign level
E l

4.11 The threshold for assignment of level E in the above situations depends
on the nature of the failure or limitations encountered in T3 and is not keyed
or triggered by a checking or currency requirement alone. Contingencies
related to paragraph 4.10 above should be assessed by the applicant and
agreement reached on appropriate interpretation of possible failures prior to
T3 0

SECTION 5. Currency Validation - TEST 4 (T4) - (Done as needed.)

5.1 Currency requirements are conservatively set by the FSB using best
judgement based on Tl, T2, or T3 outcomes. In the context of the AC appendix.,

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currency addresses both the regulatory requirements referenced in Part 121 and
extends the currency concept to include difference level specification of
particular currency needed between variant aircraft. Currency limits of
times, cycles, flights, legs, or other parameters may be set by the FSB for
systems, procedures, or maneuvers.

5.2 Further various means to assure currency are permitted including

operators recording and tracking individual crewmember performance of the
currency items, construction of bid lines to assure that each crewmember
operates each variant within specified times, or the recording and tracking of
events which implicitly assure performance of the particular currency item.

5.3 In the event that the manufacturer or air carriers desire that less
conservative currency requirements apply, T4 tests may be conducted. These
tests may be done prior to Part 121 service. In the event tests cannot be
done before TC/STC, the aircraft may enter service using the FSB conservative
limits until results on T4 establish that less conservative currency
requirements can apply.

5.4 After the aircraft enters service, the currency requirements are also
validated by enroute inspection and may be adjusted by the FSB on the
recommendation of principal inspectors.

5.5 Typical criteria used by the FSB to set level B, C, D, or E currency for
initial FSB determinations include the following:

(a) Complex flight critical systems affecting control or navigation

(EFIS, FSM, FGCS) - three segments/30 days;

(b) Critical normal maneuvers differing between variants

(takeoffs/landings) - three cycles/90 days:

(c) Critical non-normal maneuvers differing between variants (Vl cut,

emergency descent) - one acceptable demonstration/training or checking event
(typically six months but demonstration period may also vary by crew
position) ;

(d) Secondary systems (oxygen, APU) - one cycle/l2 months.

5.5.1 At level E a specification is made for acceptable methods of compliance
with Part 121 takeoff and landing currtr;cy.

SECTION 6. Initial or Transition Training/Checking Program Validation - Test

5 (T5) - (Applicable to a new aircraft type or to a derivative aircraft when
level E is assigned).

6.1 When a new aircraft type is introduced or major handling differences are
found as a result of a prospective derivative aircraft failing T2, T5 is
required. T5 is analogous to T3 but is used to define training and checking

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requirements for level E rather than levels C or D.

6.2 The manufacturer develops a training program to qualify and check

crewmembers in the level E new or derivative aircraft. Subjects are trained,
given flight checks per Part 61, Appendix A, and complete LOF in a process
similar to the one described in section 4.

6..3 LOF evaluations address pertinent factors as those described in section 4

of this attachment.

6.4 When an aircraft is assigned level E as a result of a failure of T3 at

level D, credit for documentation, testing and previously identified
requirements may be made so that T5 need not repeat elements of T3. In the
event T3 outcomes are not certain, agreement on T3 failure credits for T5
should be made prior to conduct of T3.

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* U.S. G.P.0.:1993-343-120:85809
Q U.S. GOVERNMENT PRINTING OFFICE:1 9910517-000/46023