Part-147 organisation asked to add an ATR 72-600 type course in seven weeks
Horizon Training is a Part-147 maintenance training organisation approved for basic training and for B1.1 type training on the Airbus A320 family. A regional operator asks it to deliver a B1.1 type training course on the ATR 72-600 starting in seven weeks. Horizon has one instructor who spent three years as a line engineer on ATR 72-500 aircraft but has never taught; it has a classroom with A320 mock-ups and no ATR training device. The operator offers its own ATR 72-600 for two days during the course and offers two of its Part-145 certifying engineers to act as practical assessors. Horizon proposes a course of five days of theory plus two days of practical training, followed by a 20-question multiple-choice examination with a pass mark of 70%.
1. What must Horizon do before it can run this course? Address the Part-147 approval and the Part-66 type-training requirements.
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Horizon cannot start on the strength of the customer request. Its Part-147 approval defines its scope: basic training plus B1.1 type training on the A320 family. An ATR 72-600 type course lies outside that scope until the competent authority has approved an extension.
To obtain the extension it must submit, in the form the authority requires:
- A syllabus built to the Part-66 Appendix III type-training standard and matched to the ATR 72 type rating as listed in Part-66 Appendix I, with theoretical and practical content covering airframe, systems, structures, powerplant, propellers and avionics at B1.1 depth;
- Evidence of instructor competence for the type - knowledge of the 72-600, not only the 72-500 - plus instructional technique and assessment competence;
- Facilities and equipment, including reliable access to an aircraft or an approved training device for the practical element;
- Examination material and a marking and re-sit policy;
- Quality-system arrangements for course control, records and corrective action.
The authority will normally inspect before granting the extension, and the approval certificate and MTOE must be amended. Running the course first and seeking approval afterwards would leave the trainees with a certificate from an unapproved course that cannot support a licence endorsement.
2. Assess the proposed duration and examination against the requirements.
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The proposal falls well short.
Duration. Part-66 Appendix III sets minimum content and duration for type training: for a full B1 type course, the theoretical element runs to about two weeks and the practical element a further two weeks, with reductions permitted only for properly justified differences training between variants of a type already held - not for a first type on a new aircraft. Five days of theory plus two days of practical on one aircraft cannot take a mechanic to B1 depth on the ATR 72-600, and Horizon has no ATR training device of its own, so the practical element rests entirely on the operator's aircraft being available on the day. That is a fragile basis for an approved course.
Examination. The pass mark is 75%, not 70%, and the number of questions must be proportionate to the course content. A 20-question paper cannot sample a type course; the written examination must cover all systems with a defined number of questions per section, defined marking, and a re-sit policy consistent with the MTO's procedures. Practical assessment must be against defined criteria with a record per trainee.
Conclusion: the course must be redesigned to meet the minimum durations, the practical element resourced, and the examination rewritten and validated before submission to the authority.
3. Can the operator's certifying engineers act as practical assessors, and what must Horizon do about its own instructor?
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Operator's engineers. Instructors and assessors used by a Part-147 must sit inside the MTO's organisation and competence system: recorded type knowledge, instructional competence, assessment standard, and acceptance by the competent authority as part of the approved scope. Using them is possible - contracted or seconded personnel are permitted - but only after Horizon has assessed them against its own instructor and assessor criteria, familiarised them with its procedures and examination standards, and documented them. They cannot simply deliver or mark to the operator's own habits, and each trainee's practical assessment needs a defined standard and a written record.
The in-house instructor. Three years on the ATR 72-500 is relevant engineering experience but does not make him an instructor, and it does not cover the 72-600 differences. Before he teaches he needs instructor training and an assessment of instructional competence, type differences training for the 72-600, and supervision or mentoring for his first courses. Horizon should also confirm that the person marking the theoretical examination is not simply the person who delivered the training, or that marking is independently verified, and that all instructor and examiner records will be available for the authority's inspection.