A shortened Part-147 difference course and the first helicopter type rating
A Part-147 maintenance training organisation is asked to run a B1.1 to B1.3 'difference' type course for a candidate with 12 years of experience on large aeroplanes and a current B1.1 licence. The candidate needs the B1.3 endorsement to certify a helicopter type. The training manager proposes a 10-working-day course: 8 days of distance learning with online multiple-choice tests, 2 days of practical training on a non-airworthy helicopter mock-up, and no practical assessment, arguing that the candidate's experience substitutes for it. The course is not in the organisation's approved training syllabus; the manager plans to add it as a 'local variant' and notify the competent authority afterwards. The candidate also asks whether the course will count toward the 'first type rating' on helicopters, given that he has never held a helicopter type rating.
1. Is the proposed course acceptable under Part-147? Address the syllabus approval, distance learning, duration and practical elements.
Read the worked answer
No. The course is not in the approved syllabus, and a 'local variant' added without approval is not permitted. Part-147 requires the training organisation to have approved syllabi and to obtain approval for changes. Type training must contain theoretical and practical elements and an assessment of the candidate. Distance learning may support the theoretical part, but eight days of online multiple-choice tests are unlikely to satisfy the practical objectives. The 10-day duration and the use of a mock-up must be justified and approved; the organisation cannot simply declare the course equivalent. The competent authority must approve the syllabus before it is delivered.
2. Can the practical assessment be waived because the candidate has 12 years of experience?
Read the worked answer
No. A practical assessment is a required element of an approved type course; experience can justify a shorter course, but it cannot replace the assessment. The candidate must demonstrate practical competence on the type, including tasks, inspection and use of documentation. The organisation should design an appropriate practical assessment and record the result. If the mock-up is not representative, the assessment should be done on an aircraft or an approved device.
3. Does the 'first type rating' issue affect the candidate, and what else is needed before the B1.3 endorsement can be sought?
Read the worked answer
Yes. The candidate has no helicopter type rating, so this is his first type rating in that category. Part-66 requires on-the-job training, or an approved equivalent, for the first type rating in addition to the type course, before the licence endorsement can be sought. The exact duration and content must meet the applicable Part-66 appendix and be accepted by the competent authority. The Part-147 course alone, especially a shortened one, is not enough; the candidate should plan OJT with a maintenance organisation and record it.