Variant differences versus a licence endorsement
An operator with an AOC for the ATR 72-500 is adding two ATR 72-600 aircraft on wet lease. Its FOO, A. Otieno, holds a KCAA FOO licence with an endorsement reading 'ATR 42/72'. The training file shows he completed a two-day manufacturer computer-based differences course on the -600 in Toulouse, but no simulator session and no supervised line dispatch, because no dispatch simulator exists for the type. The approved operations manual lists a differences programme of eight hours CBT plus three supervised dispatch releases for 'variant differences within the same type'. The first commercial flight, 68 passengers from Wilson to Kisumu, is scheduled in 36 hours. The Authority has been notified of the aircraft addition but has not yet issued an amended operations specification. The chief pilot asks whether Otieno can release the flight and whether his licence endorsement already covers it.
1. Does Otieno's licence endorsement, by itself, authorise him to dispatch the ATR 72-600?
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Not by itself. Three separate layers must be distinguished:
- Licence privilege: The endorsement 'ATR 42/72' may be drafted broadly enough to cover the family, but the licence does not describe every variant. The Authority's policy on variant groupings and differences must be checked. If the -600 is treated as a separate type or a variant requiring differences training, the endorsement wording alone does not complete the qualification.
- Operator authorisation: The operator must certify that the dispatcher has completed its approved differences programme and is competent on the variant. That authorisation is recorded in the training file and is what allows the person to be rostered.
- Operations specification: Commercial operation of a new aircraft type or variant requires the AOC and ops spec to cover it. Notification is not approval.
On the facts, the CBT is only part of the approved programme. The three supervised releases have not been done, so the operator cannot yet certify completion. The answer is therefore no, not on the current record, even if the endorsement is broad.
2. What must be completed before Otieno can release the first commercial flight, and who should authorise each step?
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A structured completion plan is needed:
- Confirm the licence scope: Ask the Authority, in writing, whether the 'ATR 42/72' endorsement covers the -600 and, if so, on what differences conditions. Keep the reply on file.
- Complete the approved differences syllabus: The CBT is done; the three supervised dispatch releases are not. The supervisor must be authorised, current on the -600 and acceptable to the operator. Each supervised release should be recorded with date, flight, route, tasks observed and supervisor signature.
- Competency sign-off: The nominated postholder or authorised examiner confirms the dispatcher can apply -600 performance, systems differences, MEL and fuel rules without supervision. A short oral or practical check may be added if the programme requires it.
- Operator authorisation: The training department updates the record and the postholder authorises rostering on the variant.
- Ops spec amendment: The Authority must issue the amended specification before commercial passenger operations begin. The chief pilot cannot waive this.
If the amendment will not arrive in 36 hours, the flight should be delayed, operated by the -500 or cancelled. The decision and the Authority correspondence should be documented.
3. The chief pilot argues that the aircraft is 'the same type' and that a CBT course is enough because no simulator exists. How should the postholder respond?
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The postholder should accept the technical point that the -500 and -600 share a type certificate and that no dispatch simulator exists, but reject the conclusion that CBT alone is sufficient. The controlling document is the approved differences programme, not the absence of a simulator. That programme specifies eight hours CBT plus three supervised releases; the operator cannot substitute its own judgement for the approved syllabus without Authority agreement.
The response should be in writing and should separate the issues:
- Same type certificate does not mean identical dispatch demands. Performance, systems, MEL and fuel/route planning can differ in ways that matter to a dispatcher.
- The approved programme is the compliance standard. Partial completion is not completion.
- Supervised releases can be arranged on non-commercial positioning, training or freighter flights if the ops spec does not yet cover passenger operations. That may preserve the schedule.
- If the operator believes the programme is excessive, it can propose an amendment to the Authority with a safety case. It cannot self-approve a shortcut.
Record the advice, the decision and the commercial pressure so that the judgement is auditable.