Booz & Company Beijing, 25 September 2009

General Aviation Implementation Support (GAIS)

Flight Standards Module (Revised)

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Revision: October, 2010 Final Revision: October, 2011

This document is confidential and is intended solely for the use and information of the client to whom it is addressed.

Booz & Company

Purpose of Document

 The intent of this document is to provide a detailed handover of all analysis and materials relating to regulatory gap studies on

Flight Standards Module

as part of deliverables for General Aviation Implementation Support (GAIS) project funded by the US Trade Development Administration (USTDA)  The study focuses on drawing general aviation (GA) regulatory experience and insights from the U.S. because: – The U.S. has the most established and successful GA industry with a mature regulatory system that increases GA capacity and efficiency while maintaining safety – ACP is an U.S. organization with its members consisting of FAA and key GA aircraft and equipment manufacturers with global presence. ACP member firms are best able to share GA regulatory, management, technological and operational experiences from the U.S.  Analysis has been conducted and completed by Booz & Company with active contribution from Civil Aviation Administration of China (CAAC), Development Research Center of the State Council (DRC), Aviation Industry Corporation of China (AVIC), ACP members and other key stakeholders  For further information please contact: – Mr. Paul Fiduccia ([email protected]) – Mr. Frank Yu ([email protected]) – Mr. Kevin Wu ([email protected]) – Dr. Edward Tse ([email protected]) – Mr. Yang Guang ([email protected]) – Mr. Timothy Wong ([email protected]) Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 1

This is one of the seven sets of deliverables developed for ACP GAIS project

1 Safety Module ACP General Aviation Implementation Support (GAIS) List of Deliverables Executive Summary 5 2 General Aviation Airport Module 3 Airworthiness Module 4 Flight Standards Module Operators Module GA Safety Regulation Safety culture and promotion GA Airport Regulations Safety Oversight Organizational Structure Safety Performance Measurement GA Airport Planning & Design GA Airport Funding Airworthiness Regulations Type and Production Certifications Aircraft Registration and Certification Flight Standards Regulations Mechanics Pilots Regulatory Constraints for Operators GA Aircraft Ownership GA Operating Cost 6 GA Associations Module Roles of GA Associations Case Studies

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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In China, GA refers to all civil aircrafts activities other than public aircraft transportation activities

NON EXHAUSTIVE Definition of General Aviation Three Main Categories of General Aviation Flight Activities* General Aviation China:

General Aviation refers to all civil aircrafts activities other than public aircraft transportation activities. Including flight operations associated with industrial, agricultural, forestry, fishery and construction, and other purpose operations such as medical and sanitation, emergency rescue, Meteorological sounding, ocean monitoring, scientific experiments, education and training, culture and sports etc.

FAA:

General aviation (GA) refers to all flights other than military and scheduled airline flights, both private and commercial.

Public Service Agriculture Forestry Meteorology Economic Construction Aerial Photography Mine Exploration Petroleum Services Consumer Aviation Training and Sports Tourism Business Travel Disaster Relief Others 2

ICAO:

General aviation comprises all aircraft that are not operated by commercial aviation or by the military.

Others 1 Private Use Non scheduled commercial operations 3 (*) (1) (2) CAAC categorization Others include aircraft seeding, pest control, farming and emergency rescue Others include remote sensing, power line services and industrial associated applications (3) Non scheduled commercial operations include air taxi and air charter operations Source: Committee of General Aviation Specialist of China Aviation Industrial Base (CAIB), CAAC and Booz Allen analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 3

Flight Standards Module aims to identify opportunities to further improve general aviation mechanics and pilot regulatory systems in China

 The objectives of Flight Standards Module are to conduct regulatory and practical gap analysis to identify opportunities to train more mechanics and pilots in general aviation (GA) in China and to gradually improve their capabilities, thereby stimulating the development of GA industry. Future growth areas include transportation uses of GA including personal, business, corporate and air taxi  The scope of this module is as below: – Review regulation and implementation regarding mechanics and pilots and conduct comparison with the US – Identify future improvement areas for mechanics certification and pilots certification – Recommend next steps to improve current situation Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 4

Flight Standards involves regulatory requirements and oversight of civil aviation airmen

Various Types of Airmen for Civil Aviation Airmen

Pilots Flight instructors Ground instructors Mechanics Repairmen Air-traffic control tower operators Aircraft dispatchers Parachute riggers Flight crewmembers Scope of ACP GAIS Project Flight Standards Module Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 5

Summary of observations and recommendations for Module 4: Flight Standards (1/3)

Key Areas

 Overall Flight Standards Regulations  

U.S. (FAA) Observations Module 4: Flight Standards China (CAAC) Observations

FAA also has more specific requirements on recreational and sport pilot sections under 14CFR Part 61 than CAAC – The regulations prescribe less stringent certification requirements but impose some operational constraints FAA makes special provisions for GA segment   CAAC and FAA share very similar flight standards related regulatory system However, there is no specific requirement on the level of airmen and maintenance/inspection staff for GA segment as it would be in the U.S. 

Recommendations

Review current mechanic training curriculum to simplify course structures and adjust time requirement Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 6

Summary of observations and recommendations for Module 4: Flight Standards (2/3)



Key Areas

Mechanic Certification    

U.S. (FAA) Observations

The US has a much simpler aircraft maintenance personnel certification system than China Key ratings are: Airframe, Powerplant, Airframe and Powerplant (A&P), Avionics Technicians and Inspection Authorization The holder of a mechanic certificate is relatively unrestricted as to working on any particular type of aircraft or to specialized maintenance functions The US has set codes for every types of professional mechanics and technician serving various kinds of military. Military-to-civil conversion can refer to these codes which greatly simplifies the process of conversion and enlarges the sources of mechanics for the civil aviation including GA  

Module 4: Flight Standards China (CAAC) Observations

CAAC has a two-stage aircraft maintenance personnel licensing system with different disciplines and aircraft type ratings Compared to FAA, CAAC maintenance licensing system has the following restrictions*: – Capability is limited to specific type of aircraft or function - different types under same category still requires for separate qualification – Longer duration and on the job training requirements to become CAAC certified mechanics as compared with the U.S.

– Lack of clear military-to-civil conversion system for maintenance personnel – No big difference to obtain licenses between GA and air carrier mechanics – more choose air carrier maintenance for better career development   

Recommendations

Review current mechanic training curriculum to simplify course structures and adjust time requirement Explore possibilities of new mechanic certification standards to enable mechanics to work on a group or similar types of GA aircraft Investigate the procedures and standards to better facilitate the military-to-civil conversion Note ： 1) Separate qualification requirements for different types under same category align with EASA practices. CAAC monitors EASA closely and adjust requirements as appropriate 2) Longer duration and on the job training requirements also aligns with EASA standards (COMMISSION REGULATION (EC) No 2042/2003). Applicants with secondary school education and above needs 2 years on the job training, while those without needs 3 years on the job training duration in order to qualify as a certified mechanics 3) CAAC Advisory Circular (AC-66R1-01 Clause No.6) recognizes non civilian aircraft maintenance experience. However since both civilian and military maintenance scope and requirements differ, there is a need for mechanics to be reassessed and recertified 4) Maintenance licensing requirements for both general aviation and commercial aviation follow similar guiding principles. However, CAAC differentiate piston helicopter, piston aircraft, turbo helicopter and turbo aircraft (similar to EASA). There is a need to reapply for license for individuals who transfer from GA to commercial aircraft maintenance. Due to better compensation and career prospects, more mechanics choose air carrier maintenance instead of GA maintenance Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 7

Summary of observations and recommendations for Module 4: Flight Standards (3/3)



Key Areas

Pilot, Flight School and Instructor Certification    

U.S. (FAA) Observations

The US has a wider pilot category dedicated for GA enthusiasts and activities: – Sport pilot – Recreational pilot – Private pilot – Commercial pilot The ‘Sport’ and ‘Recreational’ licenses are relatively easy to obtain in terms of hours required and cost Part 141 and 61 regulates flight schools in the U.S. with the later requires less stringent certification requirements As for flight instructors, the US has rating targeted at GA, e.g. Flight Instructors with a Sport Pilot Rating only needs to have sport pilot certificate (commercial pilot or airline transport pilot certificate not required)     

Module 4: Flight Standards China (CAAC) Observations

CAAC61 stipulates clear requirements for GA certification requirements Differing from the US, China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots Current flight school and instructor certification requirements are similar to the US The US sport pilot license has made private flying more accessible as it does not different for private or commercial use. While in China, CAAC differentiates private and commercial pilot license for primary category airplane, gliders, balloons and rotorcraft Medical eligibility for private and commercial licenses for primary category airplane, gliders, balloons and rotorcraft in China is also more stringent than the US    

Recommendations

Together with key stakeholders, explore ways to encourage the production of more GA pilots, including by subsidizing their flying instruction." For GA pilots, simplify the curriculum and adjust time requirement Conduct feasibility of merging private and commercial pilot licensing requirements for primary category airplanes, gliders, balloons and rotorcraft to form sports pilot license. In addition, also consider the feasibility of sport instructor certification Review medical eligibility/ criteria to make flying more accessible to public Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 8

Executive summary

Flight standards regulations Mechanics Pilot

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 9

GA stakeholders have highlighted several issues related to GA mechanic and pilot

  Mechanic – GA mechanics undergo similar training scope and duration as air transport mechanics – Mechanics are not able to work on multiple type of GA aircraft – Currently there is no mechanic trained to maintain advanced, new generation of GA aircraft with more complex avionics – China lacks equivalent military mechanic qualification system to allow easier conversion from military to civil aviation mechanics Pilot, Flight Schools and Instructors – Current pilot certification system caters more for the training of airline pilots – Flight instructors are the most lacking resources in pilot school certification Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 10

We have identified differences in below areas which have impacted the effectiveness of current regulatory system

Key Areas 1 Restrictive Maintenance Training and Certification System Key Differences Impact

  Longer duration and on the job training requirements to become CAAC certified mechanics as compared with the U.S.

Inability for mechanics to work on multiple type of new generation GA aircraft with advanced technology  It’s common for GA companies to lose mechanics to air carriers

2 Pilot Training Systems

 Current China pilot training systems follows closely with those in the US, differences are not obvious   In the US, independent flight instructors assume similar roles as flight schools, and have more flexibility in tailoring and providing flight instructions to students In China, flight instructors under CCAR 61 are not required to provide flight instructions to students through CCAR 141 certified flights schools. In all cases, all CCAR 61 or 141 flight instructors must adhere to CCAR 91 requirements to ensure safety  Due to better compensation/ career prospects, most qualified flights instructors in China focus on providing commercial pilot training than private GA training Source: Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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We recommend two initiatives that will improve the effectiveness and efficiency of the current GA regulatory system

Key Areas 1 Restrictive Maintenance Training and Certification System Key Recommendations

 Review current mechanic training curriculum to simplify course structures and adjust time requirement Explore possibilities to improve mechanic certification standards - to enable mechanics to work on a group or similar types of GA aircraft

Expected Benefits

 Increase GA dedicated mechanics numbers and job opportunities

2 Lack of plans that help stimulate growth of GA flight instructors and GA pilots

Develop plans that will stimulate the increase in GA flight instructors and GA pilots  Increase the number of GA flight instructors and pilots Source: Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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1.1

We have also drawn up high level descriptions of necessary tasks for each of the recommended initiatives (1/2)

Initiative (1.1) Review current mechanic training curriculum to simplify course structures and adjust time requirement Initiative Key Objectives

  Review current mechanic training curriculum to simplify course structures and adjust time requirement Explore possibilities to improve mechanic certification standards (alternative)    Baseline current mechanic training curriculum Study the FAA training curriculum in detail - engage FAA help if necessary Seek new opportunities to certify GA mechanics - make GA mechanic certification easier (alternative)

Task 1: Baseline Current Curriculum

   Review current mechanic certification system Work with industry experts to identify areas where the certification methodology can be streamlined Get the draft document ready

Task 2: Reference the FAA Material

    Study the FAA mechanic training curriculum in detail Identify areas where it can be learnt by the CAAC Revise the draft document based on new findings Issue public consultation

Alternative: Seek New Opportunities

  The US has industry associations who can certify mechanics Without changing current regulations, CAAC can learn the US example and have a separate body qualify mechanics for GA

Stakeholders and Experts to be Consulted

     Mechanics from GA and airlines FAA GA manufacturers and AVIC GA companies Industry associations and experts

Expected Benefits

 Increase GA dedicated mechanics numbers and job opportunities Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP

Next Steps/Follow-up

  Set up steering committees/work groups for each task Draft detailed scope and work plan 13

2.1

We have also drawn up high level descriptions of necessary tasks for each of the recommended initiatives (2/2)

Initiative (2.1) Develop plans that will stimulate the growth of GA flight instructors and GA pilots Initiative

 Develop plans that will stimulate the growth of GA flight instructors and GA pilots

Key Objectives

   Introduce new pilot certification categories similar to the US Set up relevant supporting policies and regulations for the new category Set up GA relevant requirements - particularly for the pilot certification and flight instructor certification

Task 1: Develop Supporting Policies

  Identify plans and initiatives that will stimulate the growth of GA flight instructors and GA pilots Work closely with established GA associations to develop financing initiatives to make GA flight training more affordable to public (e.g. China General Aviation Association)

Task 2: Review Flight Instructors and Pilots



Licensing

Conduct feasibility of merging private and commercial pilot licensing requirements for primary category airplanes, gliders, balloons and rotorcraft to form sports pilot license. In addition, also consider the feasibility of sport instructor certification    

Stakeholders and Experts to be Consulted

Pilots from GA and airlines Industry associations and experts FAA, AOPA and EAA China General Aviation Association Booz & Company

Expected Benefits

   Make pilot training more accessible to individuals using small GA aircraft for personal or business usage Increase the support for all GA activities: manufacturing, maintenance and others Increase the number of flight instructors and pilot schools / flying clubs ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP

Task 3: Review Medical Eligibility

 Review medical eligibility/ criteria to make flying more accessible to public  

Next Steps/Follow-up

Set up steering committees/work groups for each task Draft detailed scope and work plan 14

Executive summary

Flight standards regulations

Mechanics Pilot

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 15

FAA Flight Standards Service sets the standards for certification and oversight of airmen and maintenance requirements

FOCUS

Set policy and regulations for GA, including flight training and GA operations

FAA Flight Standards Service Organization Flight Standards Service Regional Divisions General Aviation & Commercial Division Air Transportation Division Civil Aviation Registry International Programs & Policy Organizational Resources & Program Mgnt Certification and Surveillance Division Aircraft Maintenance Division Flight Tech & Procedures Division Regulatory Support Division Flight Standards Training Division Flight Program Office Air Carrier Maintenance Branch General Aviation & Avionics Branch Program Management & Information Branch Repair Station Branch Special Programs Branch FOCUS

Regulatory and procedural compliance of mechanic training and maintenance organizations

GARA II Study Scope

Source: FAA Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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CAAC and FAA share very similar flight standards related regulatory system

General Aviation Related Flight Standard Regulations (FAA)

 

Type

Aircraft maintenance Airmen training and certification  Schools and Other Certificated Agencies 

CCAR Part #

Part 43 维修和改装一般规则 (MRO and alteration)            Part 60 飞行模拟设备的鉴定和使用规则 qualification and use) (flight simulation device Part 61 民用航空器驾驶员、飞行教员和地面教员合格审定规则 (pilots, flight instruction and ground instructors) Part 63 民用航空器领航员、飞行机械员、飞行通信员合格审定规则 (flight crewmembers other than pilots) Part 65 民用航空签派员执照管理规则 ; 民用航空情报员执照管理规则 ; 民用航空气象人员执照管理规则 ; 民用航空电信人员执照管理规则 ; 民 用航空航行情报人员岗位培训管理规定 (airmen)   Part 66-R1 民用航空器维修人员执照管理规则 mechanics certification) (civilian aircraft Part 67 中国民用航空人员医学标准和体检合格证管理规则 standards and certification) (medical     Part 141 Part 142 Part 145 民用航空器驾驶员学校合格审定规则 飞行训练中心合格审定规则 (training center) 民用航空器维修单位合格审定规定 maintenance technician schools) (pilot school) (repair station) Part 147 民用航空器维修培训机构合格审定规定 (aviation    

Compatibility to the US Part # (FAR)

43/ Maintenance, Preventive Maintenance, Rebuilding, and Alteration 60/ Flight Simulation Training Device Initial and Continuing Qualification and Use 61/ Certification: Pilots, Flight Instructors, and Ground Instructors 63/ Certification: Flight Crewmembers Other Than Pilots 65/ Certification: Airmen Other Than Flight Crewmembers Nil - this is part of 14CFR Part 65 (see above) 67/ Medical Standards and Certification 141/ Pilot Schools 142/ Training Centers 145/ Repair Stations 147/ Aviation Maintenance Technician Schools Source: FAA and CAAC Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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Both CAAC’s and FAA’s Part 91 place primary responsibility on the owner or operator for maintaining an aircraft in an airworthy condition

14 CFR Part 91

 91.403 General  (a) The owner or operator of an aircraft is primarily responsible for maintaining that aircraft in an airworthy condition, including compliance with part 39 of this chapter  (b) No person may perform maintenance, preventive maintenance, or alterations on an aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter  (c)….

CCAR Part 91

 CCAR 第 91.305

条 适航性责任 

(a)

航空器的所有权人或运营人对保持航 空器的适航性状态负责，包括机体、发动 机、螺旋桨及其安装设备的适航性  (b) 作 为落实航空器的适航性责任，航空器 的所有权人或者运营人应当按照第 … 91.303

条的规则保证其使用的航空器完成如下工 

(c)

上述工作可以通过签订协议的方式进 行委托，但航空器所有权人或运营人负有 同样的适航性责任

Similar to FAR Part 91

Source: FAA, CAAC, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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FAA also has more specific requirements on General Aviation sector under 14CFR Part 61 than CAAC

Comparison Between FAR Part 61 and CCAR Part 61

Certification: Pilots, Flight Instructors, and Ground Instructors

FAR Part 61 CCAR Part 61

*Note:            Subpart A--General Subpart B--Aircraft Ratings and Pilot Authorizations Subpart C--Student Pilots

Subpart D--Recreational Pilots

Subpart E--Private Pilots Subpart F--Commercial Pilots Subpart G--Airline Transport Pilots Subpart H--Flight Instructors Other Than Flight Instructors with a Sport Pilot Rating Subpart I--Ground Instructors

Subpart J--Sport Pilots Subpart K--Flight Instructors with a Sport Pilot Rating

           Subpart A--General Subpart B--General Rules Subpart C--Additional Rating and Special Requirement Subpart D--Student Pilots Subpart E--Private Pilots Subpart F--Commercial Pilots Subpart G--Airline Transport Pilots Subpart H--Flight Instructors Subpart I--Ground Instructors Subpart J--Violations Subpart K--Appendix Main difference between FAR Part 61 and CCAR Part 61 is the sports category. Differing from the US, China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots FAA recreational pilot category is not very successful because of nearly same requirements as for PPL and greatly restricted operations. It has been effectively replaced by sport pilot Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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Executive summary Flight standards regulations

Mechanic certification

Pilot certification

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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The US has an established aircraft maintenance personnel certification system

FAA Industry Trade Certificates

Aviation Maintenance Specialist (AMS) Aviation Maintenance Engineer (AME)

FAA Aircraft Maintenance Certification System FAA Certificates Ratings Maintenance Certification Non-Certified FAA Certified

Source: Advisory Circular 65-30, FAR 43, 65, and 147

Mechanic Certificate Repairman Certificate Airframe

 Authorized to work on engines and do limited work on propellers – 400 hours general plus 750 hours airframe

Powerplant

 Authorized to test and repair any part of the aircraft except the instruments, power plants, and propellers – 400 hours general plus 750 hours powerplant   

Airframe & Powerplant (A&P)

Authorized to work on all parts of the plane except instruments. The majority of mechanics working on civilian aircraft today are A&P mechanics 400 hours general plus 750 hours airframe and 750 hours powerplant A&P mechanics is eligible for Inspection Authorization (IA) certification  

Avionics Technician

Authorized to maintain avionics equipment But this privilege is allowed only if that individual is properly trained, qualified, and has the proper tools and equipment to perform the work

Inspection Authorization

  Authorized to perform an annual inspection, or perform or supervise a progressive inspection Approve for return to service any aircraft related part or appliance which has undergone a major repair or alteration Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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The system grants Mechanic Certificate and Repairman Certificate with different level of privileges

FAA FAA Certification Type Mechanic Certificate

Source:     The holder of a mechanic certificate is relatively unrestricted as to working on any particular type of aircraft or to specialized maintenance functions The vast majority of technicians are certificated as FAA mechanics. Under an FAA mechanic’s certificate there are two ratings: Airframe and Powerplant Although most certificated mechanics hold both ratings and are referred to in the industry as an “A & P,” there are many mechanics certificated only with an airframe (A) rating, or only a powerplant (P) rating Mechanic certificate privileges allow mechanics to perform maintenance in a large number of areas Advisory Circular 65-30

Repairman Certificate

   Repairman are maintenance technicians that are certificated by the FAA for only one or two specific tasks Because they are limited by function, they can only exercise the privileges of the repairman certificate by being under the supervision of FAA-approved Repair Stations, commercial operators, or air carriers where these specific tasks are routinely accomplished on a daily basis It is the repair station, commercial operator, or air carrier who recommend an individual to be a repairman Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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The privileges and limitations of certificated mechanics are further restricted by the types of ratings granted

FAA Privileges and Limitations of Different Type Ratings Airframe and Powerplant (A&P)

  

General

Perform or supervise the maintenance, preventive maintenance, or alterations of an aircraft or appliance (or part thereof) for which the mechanic is rated  Perform major repair or major alterations to propellers nor accomplish any repair to or alteration of instruments (only certificated repairmen can perform Supervise the maintenance, preventive maintenance, or alteration of any aircraft or appliance (or part thereof) for which he or she is rated, unless he or she has satisfactorily performed this work at an earlier date   Source: FAA, Booz & Company analysis

Airframe (A)

Approve and return to service an airframe, an appliance, or any related part after he or she has performed, supervised, or inspected minor repairs or alterations Perform the 100-hour inspection on the airframe if required May also perform the maintenance actions required for a major repair or alteration, and should initiate the appropriate form (FAA Form 337, Major Repair and Alteration) associated with that work. However, the return to service action must be accomplished by a certificated A & P technician holding an Inspection Authorization (IA)  

Powerplant (P)

Has the same limitations imposed regarding the powerplant and propeller as the airframe technician has on the airframe rating Approve and return to service a Light Sport powerplant or propeller after performing and inspecting a major repair or major alteration. The work must have been done on products that are not produced under FAA approval (i.e., are not type certificated) and must have been performed in accordance with instructions developed by the manufacturer or person acceptable to the FAA

Inspection Authorization (IA)

 Only certificated A & P technician can get an Inspection Authorization (IA) certification  Inspect and approve for return to service major repairs and major alterations, if the work was done according to technical data approved by FAA  Perform an annual inspection  Perform or supervise a progressive inspection  An IA holder cannot approve for return to service an inspection required under 14 CFR part 91, § 91.409 (e) for large airplanes  An IA holder cannot approve for return to service major repairs, major alterations, or inspection on an aircraft maintained in accordance with a continuous airworthiness program under 14 CFR part 121 Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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Airframe and A&P mechanics has privilege to maintain avionics equipment if they meet additional requirements

FAA Ratings: Avionics Technician Requirements

 (1) An individual who holds an FAA mechanic certificate with an airframe rating is authorized under his rating to maintain avionics equipment. But this privilege is allowed only if that individual is properly trained, qualified, and has the proper tools and equipment to perform the work.

 (2) There are also un-certificated individuals working for air carrier avionics departments or FAA certificated avionics repair stations. These individuals have gained experience in avionics repairs from serving in the military, working for avionics manufacturers, and other related industries

Many schools offer avionics courses that cover electronics and instrumentation

Source: Advisory Circular 65-30, FAR 43, 65, and 147 Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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FAA allows non certified mechanics to work under the supervision of a certificated person with several restrictions

FAA Maintenance Certification Type FAA Certified

   The FAA certifies aviation maintenance personnel in two ways: a mechanic certificate and a repairman certificate Under an FAA mechanic’s certificate there are two ratings: Airframe and Powerplant Repairman are maintenance technicians that are certificated by the FAA for only one or two specific task

Non-Certified Mechanics

     A non-certificated mechanic can work only under the supervision of a certificated person Since these mechanics are not certificated by the FAA, there are no Federal certification requirements to meet As a non-certificated mechanic, he or she cannot sign off a maintenance record “approving the aircraft or component for return to service” Because of this limitation, a non-certificated mechanic is restricted in the scope, function, and duties he or she can perform Therefore, without a certificate, non-certified mechanics are less likely to advance to the top of the career field Source: Advisory Circular 65-30 Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

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CAAC has a two-stage aircraft maintenance personnel licensing system with different disciplines and aircraft type ratings

CAAC Overview of CAAC Aircraft Maintenance Personnel Licensing System Aircraft Type Rating (CCAR 147) Mechanic Certificate

   

Mechanical Basic Type Discipline (ME)

Turbine-engined aeroplane (TA) Piston-engined aeroplane (PA) Turbine-engined helicopter (TH) Piston-engined helicopter (PH)

Avionic Discipline (AV)

   Obtained the Basic part of the Maintenance Personnel License Completed prescribed course and passed examination Fulfilled maintenance experience requirements

Level I Level II

  Certificate required for each of the different aircraft type, e.g. CESSNA172, Cirrus SR22, BELL-212, etc.

Level I and II stipulates different level of privileges that license holders have

Repairman Certificate

     

Basic Type

Aircraft structure (STR) Aircraft powerplant (PWT) Aircraft landing gear (LGR) Aircraft mechanical components (MEC) Aircraft avionics components (AVC) Aircraft electrical components (ELC)    Obtained the Basic part of the Component Maintenance Personnel License Has completed knowledge training and passed the examination Has worked in maintenance for at least one year cumulative in the recent two years on the rating applied for  Note: Source: Same as FAA, CAAC allows non certified mechanics to work under the supervision of certified mechanics CAAC, Booz & Company analysis

Aircraft component ratings

The Rating part of the Civil Aircraft Component Maintenance Personnel License is sub-divided in accordance with Appendix 8 of CCAR-66 R1 Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 26

Only aircraft type rating certificate holders can release aircraft that the rating is granted on completion of maintenance works

CAAC Privileges of Basic and Aircraft Type Rating Certificates Basic Certificate Privilege

   It demonstrates that a mechanic possess basic understanding of: – fundamentals, application and equipage of aircraft – Regulations and procedures related to aircraft maintenance It also demonstrates that the mechanic has possessed minimum work experience as required by the certificate However it is not considered a “complete certification” without the aircraft type rating hence, Basic Mechanic Certificate does not grant aircraft release privilege to the license holder

Aircraft Type Rating Certificate Privileges

   The license holder only has privileges on the type of aircraft that the rating is granted The License holder of Level I aircraft type certification: – may release aircraft on completion of line maintenance inspection, A check or equivalent lower level scheduled maintenance according to worksheet and its alteration works in accordance with CCAR-145 – carry out maintenance work on aircraft and approved the resumption of its use in accordance with CCAR-43 The license holder of Level II aircraft type certification has the Level I aircraft type certification privilege and additionally: – May release aircraft on completion of scheduled maintenance activities higher than A-check equivalent and its alteration works in accordance with CCAR-145 Source: CCAR66, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 27

Compared with US practice, current mechanic training and licensing system in China has several gaps which can be improved accordingly

Issues Identified from CAAC Regulation and Requirements 1 Complex maintenance personnel licensing system

 China has more complex and restrictive maintenance personnel licensing with multiple type and component ratings – Regulations designed for air carrier airplanes – Maintenance functions are restricted to aircraft and components according to ratings certificated – Courses are designed for each rating with training and examination requirements

2 Longer on the job training for full mechanic certification

 It generally takes 2-5 years more to become a CAAC certified mechanic than a FAA certified mechanic

3 Lack conversion system for military-to-civil mechanics

 For military-to-civil mechanics, clearly define relevant procedures and standards to better facilitate the conversion, e.g. no need for personnel to retake training and examination if they already have relevant experience before Source: FAA, CAAC, industry interview, Booz & Company analysis

Impact on GA Mechanics

     Higher entry barrier to become an aircraft mechanic in China as compared to the U.S.

Few mechanics that can work on each type of GA aircraft Longer on-the-job experience to obtain full mechanic certification No exemption on course and training for military veterans despite posing relevant experience Imbalance between remuneration and investment results in high attrition rate of maintenance personnel Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 28

1 Complex maintenance personnel licensing system

Compared to FAA, CAAC maintenance licensing system develops more detailed rating categories

FAA

 Airframe   Powerplant Airframe and Powerplant (A&P)  

Mechanics Type Rating

Avionics technician Inspection Authorization  

CAAC

Basic (mechanical) – Turbine-engined aeroplane (TA) – Piston-engined aeroplane (PA) – Turbine-engined helicopter (TH) – Piston-engined helicopter (PH)  Basic (avionics) Aircraft Type Rating – Type of aircraft (specific model of aircraft that the mechanic is certificated for) – Level of maintenance privileges that the license holders have (Type I and Type II) Source: Booz & Company analysis

Repairman Type Rating

   No rating Recommended by repair station, commercial operator or an air carrier Work under-supervision of approved repair station, commercial operator and carriers   

Comments

The system allows mechanics to perform maintenance in a large number of aircraft types and areas The holder of a mechanic certificate is relatively unrestricted as to working on any particular type of aircraft or to specialized maintenance functions Courses and training is designed to ensure that an applicant is competent to perform in the broad work areas in which he is privileged to function  Basic – Aircraft structure (STR) – Aircraft powerplant (PWT) – Aircraft landing gear ( LGR) – Aircraft mechanical components (MEC)  – Aircraft avionics components (AVC) – Aircraft electrical components (ELC) Component Rating – The Rating part of the Civil Aircraft Component Maintenance Personnel License is sub-divided in accordance with Appendix 6 of CCAR-66 R1     Mechanics face the challenges from more detailed categories and less generality Mechanics have to undertake more courses, training and examination to be certificated for different ratings The system creates greater administrative burden to both CAAC and operators The system results in fewer mechanics who can work on each type of GA aircraft Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 29

2 Longer on the job training for full mechanic certification

FAA requires both classroom and on-the job training over a defined period for granting mechanic certifications

Schooling FAA Aircraft Mechanic Experience Requirements On-the-Job Training Attending FAA Certified Training Schools

  Applicant need to attend one of the 170 FAR part 147 Aviation Maintenance Technician Schools nationwide These schools offer training for one mechanic’s certificate or both. Many schools offer avionics courses that cover electronics and instrumentation

Length of Time Required 12-24 month

Source: FAA, Advisory Circular 65-30 Booz & Company

Hands-on Experience at FAA Certified Repair Station

  Applicant need to work at an FAA Repair Station or FBO under the supervision of a certified mechanic for 18 months for each certificate, or 30 months for both Experience must be documented with pay receipts, a log book signed by supervising mechanic, a notarized statement from the employer, or other proof the applicant worked the required time

18 months for 1 cert 30 month for A&P cert

ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP

Military Mechanics Experience

  The applicant can join one of the armed services and get training and experience in aircraft maintenance, which FAA gives credit An official letter from military employer certifying the length of service, the amount of time worked in each specialties, the make and model of the aircraft or engine on which and where the applicant got practical experience

18 months for 1 cert 30 month for A&P cert

30

2 Longer on the job training for full mechanic certification

Compared to FAA, CAAC requires much longer on-the job training requirements for certifying a mechanic

Example of Time Requirement for a Full Mechanic Certificate



Full Mechanic Certificate Defined…

An applicant that meets all the certification requirement under the aviation authorities regulation

CAAC Mechanic Certificate FAA Mechanic Certificate Basic Type Aircraft Type* Airframe Powerplant A & P

  Require 2 years independent working experience for Diploma holder Require 3 years of independent working experience for apprentice  

5-8 Years

Holder of “Basic Type” certificate  3-5 years of working experience depending on the type of aircraft Chinese mechanic to work 2 to 5.5 years more to get a Full Mechanic Certificate  Require 1-2 years if trained in a FAA certified training school for all certificate Require 1.5 years of working experience if not trained in FAA school for one certificate or 2.5 years for both certificate

2-2.5 Years

*) Source:

Detailed study is required to find out training curriculum differences between the two country that result in much longer on-the-job training requirements for obtaining mechanic certification in China

Aircraft Type certificate is only issued after obtaining the Basic Type certificate FAA, CAAC and interviews Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 31

3 Lack experience conversion system for military-to-civil mechanics

China can consider allowing military mechanic experience conversion to allow easier and faster conversion of veterans to serve GA

FAA Military Occupational Specialty Codes

US Army Example

Comments

   US has Military Occupational Specialty Codes for mechanics serving U.S. Army, Air Force, Navy, Marine Corps, and Coast Guard - each of the specialties are coded and transferable to civil aviation This allows shorter lead time and efforts for veteran mechanics to serve civil aviation including GA CAAC can start to look into some of these issues and work with the military to identify commonalities in aircraft maintenance to allow easier and faster transfer of veterans to serve civil aviation Source: FAA, Advisory Circular 65-30 and industry interviews Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 32

Executive summary Flight standards regulations Mechanics certification

Pilot certification

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 33

China GA Pilot Certification System is still facing several challenges

Key Challenges for GA Pilot Certification System in China 1 Pilot training system does not encourage private GA growth

 Lack of programs in China to encourage the increase of the number of GA pilots

2 Limited funding source restrict GA pilot growth

  Driven by market situations, pilot training is either sponsored by airlines or self funded More financial assistance methods should be explored to subsidize pilot training

Comments

  Driven by market situations, current pilot certification and funding structure is designed to train airline pilots and not suited to stimulate GA demand Going forward, China should explore initiatives to stimulate growth of GA flight instructors and pilots

3 Establish more flight schools targeting at GA training

 Need to establish more flight schools targeting at providing GA training (e.g. private flying activities). Flight schools under CCAR 61 need not be certified, hence easier to set up Source: FAA, CAAC, industry interview, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 34

1 Pilot certification categories

The US has a wider pilot category dedicated for GA enthusiasts and activities

US Pilot Category (ATR not included here)

Ultralight Pilot Sport Pilot None

Medical Eligibility

None

Training Requirements Testing Requirements

None

Add-On Privileges or Ratings

None Current and valid U.S. driver's license unless §61.303(b) applies or Valid medical certificate issued under part 67 Gliders and balloons---Airman medical certificate not required Airplane, Gyro, Weight-Shift Control, and Airships 20 Hours - Total 15 Hours - Flight training 5 Hours - Solo 2 Hours - Dual Cross Country 1 Solo Cross Country 3 Hours - Prep (registered ultralight pilots with FAA- recognized ultralight organizations may be given credit until January 31, 2007 CFI or CFI-SP Recommendation - Knowledge test Practical test Cat/Class Privileges Training - CFI or CFI-SP Recommendation CFI or CFI SP, Proficiency Check- Different CFI or CFI-SP Endorsement / Form 8710.11 Make and model (to operate aircraft within a set of aircraft) Class B, C, D Vh > 87 Knots CAS-- Training - CFI or CFI SP Endorsement - CFI or CFI-SP Recreational Pilot Private Pilot Commercial Pilot Third-class medical certificate issued under part 67, Except for gliders and balloons - Medical eligibility not required Third-class medical issued under part 67 -- Except for gliders and balloons, Medical eligibility not required Second-class Medical certificate Issued under part 67 -- Except for gliders and balloons -- Medical eligibility not required Airplane and Rotorcraft 30 Hours - Total 15 Hours - Flight training, 3 Hours - Solo, 2 Hours - Flight training cross country (limited 50 NM range from departure airport, permitted with additional training (see §61.101(C)) 3 Hours - Prep for airplanes: 40 Hours - Total Additional flight training requirements for each category and class For airplanes: 250 Hours - Total Additional flight training requirements for each category and class CFI Recommendation - Knowledge test Practical Test CFI Recommendation - Knowledge test Practical Test Cat/Class Rating Training - CFI Recommendation - CFI Practical test Cat/class rating Issued (make and model- training recommended) Class B, C, D Training - CFI Endorsement -CFI Cat/Class Rating Training - CFI Recommendation - CFI Practical test Cat/Class Rating Training - CFI Recommendation - CFI Practical test Source: FAA Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 35

1 Pilot certification categories

The US also has more targeted medical eligibility for different pilot categories, making flying more accessible

Ultralight Pilot Sport Pilot Recreational Pilot Private Pilot Commercial Pilot

FAR Part 67 Medical Eligibility

None Current and valid U.S. driver's license unless §61.303(b) applies or Valid medical certificate issued under part 67 Gliders and balloons-- Airman medical certificate not required

CCAR-67FS Medical Eligibility

 Applicants of the following pilot licenses must possess either Class I or Class II medical certicates: – Commercial license for primary category airplane, gliders, and lighter-than-air aircraft – Private pilot license Third-class medical certificate issued under part 67, Except for gliders and balloons - Medical eligibility not required  For applicants who have the intention to pursue air carrier license or commercial pilot license of airplane and rotary airplane, the applicants must have Class I medical certificate. Other applicants can have either Class I or II medical certifications Third-class medical issued under part 67 - Except for gliders and balloons, Medical eligibility not required Second-class Medical certificate Issued under part 67 -- Except for gliders and balloons - Medical eligibility not required    Applicants of the following pilot licenses must possess either Class I or Class I medical certicates: Air carrier pilot license Commercial pilot license of airplane and rotary airplane Source: FAA, CAAC Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 36

1 Pilot certification categories

In the US, the ‘Sport’ and ‘Recreational’ licenses are relatively easy to obtain in terms of hours required and cost

Private Comparison of Training Requirements and Cost Recreational Sport

Airplane          40 hours - total 20 hours - flight training 10 hours - solo 3 hours - flight training cross-country 5 hours - solo cross-country 3 hours - prep 3 hours - night 3 hours - instrument training Average Cost - USD 9,900 Airplane and rotorcraft       30 hours - total 15 hours - flight training 3 hours - solo 2 hours - flight training cross country (limited 50 nm range from departure airport) 3 hours - prep Average Cost - USD 7,700 Airplane, gyro, weight-shift-control, airships       20 hours - total 15 hours - flight training 5 hours - solo 2 hours - dual cross-country 1 solo cross-country 3 hours - prep  Average Cost - USD 4,400 Note: Source:

In order of decreasing privilege

FAA recreational pilot category is not very successful because of nearly same requirements as for PPL and greatly restricted operations. It has been effectively replaced by sport pilot Main difference between FAR Part 61 and CCAR Part 61 is the sports category. Differing from the US, China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots AOPA, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 37

1 Pilot certification categories

Certification requirements, privileges and operational restrictions for private, recreational and sport pilots differ



Type of operations or privileges

Requires FAA medical certificate  Aircraft size limitations    Aircraft with retractable landing gear Carry more than one passenger Minimum flight training time required under FAR Part 61  Flight in Class B, C, or D airspace  Night flight 

FAA Pilot Certificates Comparison Private Pilot

Yes  Yes

Recreational Pilot

     Unlimited (certain aircraft will require specific type ratings) Yes Yes 40 hours (based on reported averages, it typically takes 70 hours) Yes  Yes    Flight outside US airspace Less than 3 miles visibility Sightseeing flights benefiting a charity or community    Yes Yes, in uncontrolled airspace Yes   180 hp max 4 seats max    No No 30 hours (based on reported averages, it typically takes 44 hours)     Only with additional flight instruction Yes, no passengers and under CFI supervision to obtain additional certificates/ratings No No  No        

Sport Pilot

Medical or US driver’s license and self certification 1,320 lb. max certificated gross weight 2 seats max No No 20 hours (using averages for private and recreational pilot; the typical average could be 33 hours) Only with additional flight instruction No   No No  No Note: Source: FAA recreational pilot category is not very successful because of nearly same requirements as for PPL and greatly restricted operations. It has been effectively replaced by sport pilot Main difference between FAR Part 61 and CCAR Part 61 is the sports category. Differing from the US, China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots AOPA, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 38

1 Pilot certification categories

CAAC shares the similar qualification and classification system as FAA , however it hasn’t yet clearly clarified GA pilot categories

CAAC CAAC Pilot Category (CCAR-61 R1/R2)



License/Certificate Student Pilot License (SPL) (Basic VFR under the supervision of a flight instructor)



Qualifications

> 16 year old (14 year old for glide planes 

Aircraft Types

Fixed Wings, Rotorcraft, Glide Planes, Balloons, Airships, etc.

  

Restrictions

Not allowed to carry passengers Operations specifically approved by flight instructors Visibilities must be >5km (day) and >8km (night) 

Private Pilot License (PPL) (VFR)

  > 17 year old (16 year old for glide planes and balloons) 10-40 hours on the correspondent aircraft type, 10 of which are solo flights  Fixed Wings, Rotorcraft, Glide Planes, Balloons, Airships, Primary category airplane  Not allowed as captains on commercial passenger or cargo flights  

Private Pilot License (PPL) (VFR + instrument rating for IFR) Commercial Pilot License (CPL)

–

(VFR and IFR)

    Minimum 50 hours as pilot in command (of which at least 10 hours in the aircraft with the instrument rating applied for) 40 flight hours (which can include up to 20 hours training on simulator)  > 18 year old 50-200 hours on correspondent aircraft types  Fixed Wings, Rotorcraft  Fixed Wings, Rotorcraft, Glide Planes, Balloons, Airships, Primary category airplane  Not allowed as captains on commercial passenger or cargo flights Allowed as captains and first officers on commercial passenger or cargo flights that do not require ATPL qualifications 

Airline Transport Pilot License (ATPL)

– Source:

(IFR)

  CAAC, Booz & Company analysis >21 year old 500-2,000 hours on correspondent aircraft types  Fixed Wings  No restrictions Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 39

1 Pilot certification categories

At present, CAAC pilot certification doesn’t clearly reflect the appropriate certification requirements for Sport Pilot category

FAA Pilot Certification Categories Student Pilot Sport Pilot (SP) Recreational Pilot (RP) Private Pilot Commercial Pilot Airline Transport Pilot

In order of increasing privilege Source: FAA, Booz & Company analysis

CAAC Pilot Certification Categories Sport Pilot and Recreational Pilot

 The Sport pilot certificate is also ineligible for additional ratings, although time in light-sport aircraft can be used towards the experience requirement of other ratings on higher certificate types  The recreational pilot certificate requires less training and offers fewer privileges than the  private certificate. It was originally created for flying small single-engine planes, and has since been largely supplanted by the Sport Pilot certificate because it was unsuccessful Basic requirements and restrictions – > 17 yo – Log >20 hr flight time (SP) – Log >30 hr flight time (RP) – Only fly one single-engined small aircraft or a light sport aircraft (LSA) – Carry no more than one passenger – Daytime flight only

Student Pilot

China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots

Private Pilot Commercial Pilot Airline Transport Pilot

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 40

2 Pilot training cost and financing

The U.S. has the following financing options for pilot training

US Pilot Training Financing Options AOPA EXAMPLE AOPA Flight Training Funds Program Self-Funded

 The candidate can contact local pilot training schools for cost/lesson and make decision on frequency of lesson and payment to the school

Scholarship

  The airline scholarship is the most common one However, there are industry associations and individual funds that offers scholarship - e.g. EAA Young Eagles Scholarship

Line of Credit

  This options can help people to pay part of the training fee The most noticeable one are offered by AOPA - AOPA Flight Training Funds Program Source: AOPA, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP      AOPA Flight Training Funds offers:  Predictable payments No annual fee No collateral needed Renewable source of cash Credit line up to $25,000

In association with

Support AOPA and General Aviation

The program gives perspective pilots flexibility to structure training - the applicant can use the account to pay for a rating or certificate program, get additional training hours, aircraft rental, instructor fees, books and supplies

41

2 Pilot training cost and financing

In China, pilot funding are limited to either Airline / GA company scholarship or self-funding

CHINA EXAMPLE China Pilot Training Financing Options Self-Funded Scholarship

 Pilot training costs in China are comparable to the US. However, as China per capita income is much lower than the US, financial burden on prospective students is hence higher – hence not many students opting for this self funding option   Majority of pilot training are either airline sponsorship or GA company sponsorship Most of these sponsorship are for college students

Explore Other Funding Options

 CAAC, with the help of industry stakeholders, can explore the possibilities of getting more funding options for pilot training - at least for GA pilots - in order to increase the number of pilots  CAAC and industry stakeholders can also learn from AOPA and other industry association example to provide partial support for pilot training with flexible financing structure and low interest rate Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 42

2 Pilot training cost and financing

There are two regulations in the US that oversee the flight school certification - Part 141 and 61

FAA Flight School Certification Part 141

 Part 141 Pilot Schools - prescribes the requirements for issuing pilot school certificates, provisional pilot school certificates, and associated ratings, and the general operating rules applicable to a holder of a certificate or rating issued under this part  Part 141 schools have more FAA oversight, more rigid schedules, and more paperwork. For the added requirements, they are allowed to reduce the minimum required hours of private pilot training to 35 hours, rather than the 40 hour minimum required when training at a Part 61 flight school

Part 61

 Part 61- Certification: pilots, flight instructors, and ground instructors prescribes certificates and rating requirements and authorization requirements  Part 61 schools, including individual flight instructors, are able to be more flexible with training schedules and have the ability to tailor the curriculum to meet individual student ’s training needs. Either Part 61 schools or flight instructors must train you to pass the very same practical test

FAA

Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 43

3 Flight schools

In general Part 61 certification is relatively easy to obtain and the entry barrier are lower than Part 141

FAA FAA Part 141 and Part 61 Flight School Comparisons Purpose of Training Program Difference Flexibility Training Hours Accelerated Training Exam

 

Part 141

 Commercial pilot and above - become a career pilot  Complete formal ground school training Have a structured training program under a standardized syllabus Need to go through ‘stage checks’ as a progress  tracker Provide veteran reimbursed training  Schools must develop a step by step training program which the FAA approves   Private license: 35 hours Commercial license: 190 hours (total log time)  Some school has accelerated training syllabus  Same as Part 61

Part 61

  Self-motivated and fly aircraft for personal or business use No formal ground school is required it’s a shared responsibility between the student and the CFI      Students and Instructors have freedom in how lessons are conducted and when topics are covered Private license: 40 hours Commercial license: 250 hours (total log time) Depend on the instructor qualification Same as Part 141

Cost

  Minimum hourly rate training are the same as Part 61 Other situations at a higher hourly cost than Part 61  Minimum hourly rate training are the same as Part 141 Note: Source: Total log time includes in flight training time, class based instructional time, self flying time etc.

FAA, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 44

3 Flight schools

In China, the CCAR-141 is similar to FAR-141 - however, the reality differs when pilot graduates

Part 141 Pilot Schools

US vs. China

US China



50%

pilot pursue the career of GA and may later return to airline 

50%

pilot pursue the career in the airlines and continued their study after CPL

FAR 141 PPL/ CPL ATPL CCAR 141 CPL ATPL

 Less than

10%

of the pilots go to GA industries  More than

90%

of pilot pursue the career in the airlines and continued their study after CPL

Comments

 CCAR Part 141 follows FAA requirements closely  Due to market situations (e.g. better compensation and career prospects), most pilots enrolled through CCAR 141 certified flight schools and eventually become commercial pilots Source: FAA, CAAC Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 45

3 Flight schools

According to GA Pilot Licensing and Training Management (AC61FS08), the CCAR-61 reflects some requirement for GA pilot training

GA Pilot Licensing and Training Management

通用航空飞行人员执照和训练的管理（ AC61FS08 ）  Applicability – Applicant who trained for pilot license and ratings in CCAR-141 schools to cumulate experience to become airline pilots are not applicable to this AC – Aside from above, GA pilots licensing and training management are applied to this AC  Training Requirement – Follow Part 61.159 and Part 61.161

Comments

 The AC has stated clearly on requirements for: – Fixed wing and rotorcraft pilot training – Instrument rating and aircraft type rating – Training guidelines – Flight instructor requirements – Annual and familiarization inspections – Military transfer requirement Source: CAAC Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 46

3 Flight schools

As for instructors, the US has two types - one of which requires less flying experience compare to the other

FAA Flight Instructor Certification (FAR Part 61) Flight Instructors Other than Flight Instructors With a Sport Pilot Rating (Subpart H)

 According to subpart H, it’s required that the instructors of this category to “hold either a

commercial pilot certificate or airline transport pilot certificate

sought; and with: – An aircraft category and class rating that is appropriate to the flight instructor rating – An instrument rating, or privileges on that person's pilot certificate that are appropriate to the flight instructor rating sought..”

Flight Instructors With a Sport Pilot Rating (Subpart K)

   This subpart K is specifically designed to instruct people who wants to operate light sport aircraft According to subpart K, it’s required that the instructors of this category to “hold at least a current and valid

sport pilot certificate

with category and class ratings or privileges, as applicable, that are appropriate to the flight instructor privileges sought”

Hence, there is no need for this category instructors to hold CPL or ATPL certificate

Note: Source: CPL = Commercial Pilot License; ATPL = Airline Transport Pilot License China flight instructor certification requirements are similar to the US, however there are no time requirements FAA, Booz & Company analysis Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 47

3 Flight schools

The flight instructor certificate with a sport pilot rating have the following privileges and limits

Flight Instructors With a Sport Pilot Rating Privileges and Limits Privileges FAR 61.413

      Student training Sport pilot and flight instructor training Powered parachute and weight shift control – private pilot Flight review or operating privileges Practical and knowledge test preparation Proficiency checks for additional category, class, or make and model privileges

Limits FAR 61.415

          Must hold category and class privileges and make and model privileges at sport pilot level or higher Applicable category and class privileges on flight instructor certificate Private powered parachute and weight shift control requires private certificate and appropriate flight instructor privileges Cannot conduct more than 8 hours of flight training in a 24-consecutive-hour period Must have 5 hours of flight time in make and model within the set of aircraft Must have airspace endorsement in accordance with 61.325 to provide training Must have endorsement to provide training in aircraft with a VH in accordance with 61.327 Must conduct training in an aircraft that meets the requirements of 91.109 Must conduct training in an aircraft with two pilot stations Single place pre-solo training must be conducted in a two pilot station aircraft in the appropriate category and class Booz & Company ACP GAIS - 4_Flight Standards_Revised Oct 2011_EN_vf.ppt

Prepared for ACP 48