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Booz & Company

Beijing , 25 September 2009. Booz & Company. General Aviation Implementation Support (GAIS) Flight Standards Module (Revised) 1 st Revision: October, 2010 Final Revision: October, 2011.

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  1. Beijing, 25 September2009 Booz & Company General Aviation Implementation Support (GAIS) Flight Standards Module (Revised) 1st 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.

  2. 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 (PFiduccia@aol.com) • Mr. Frank Yu (Dongfang.yu@ge.com) • Mr. Kevin Wu (kevinwu@textron.com) • Dr. Edward Tse (edward.tse@booz.com) • Mr. Yang Guang (guang.yang@booz.com) • Mr. Timothy Wong (timothy.wong@booz.com)

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

  4. In China, GA refers to all civil aircrafts activities other than public aircraft transportation activities NON EXHAUSTIVE Three Main Categories of General Aviation Flight Activities* Definition of General Aviation 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. Public Service Economic Construction Consumer Aviation Agriculture Aerial Photography Training and Sports Forestry Mine Exploration Tourism FAA: General aviation (GA) refers to all flights other than military and scheduled airline flights, both private and commercial. Meteorology Petroleum Services Business Travel Disaster Relief Others2 Private Use ICAO: General aviation comprises all aircraft that are not operated by commercial aviation or by the military. Others1 Non scheduled commercial operations3 (*) CAAC categorization (1) Others include aircraft seeding, pest control, farming and emergency rescue (2) 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

  5. 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

  6. Flight Standards involves regulatory requirements and oversight of civil aviation airmen Various Types of Airmen for Civil Aviation Airmen Pilots Mechanics Flight crewmembers Flight instructors Repairmen Scope of ACP GAIS Project Flight Standards Module Air-traffic control tower operators Ground instructors Aircraft dispatchers Parachute riggers

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

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

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

  10. Executive summaryFlight standards regulationsMechanicsPilot

  11. 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

  12. We have identified differences in below areas which have impacted the effectiveness of current regulatory system Key Areas Key Differences Impact 1 • It’s common for GA companies to lose mechanics to air carriers Restrictive Maintenance Training and Certification System • 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 2 • 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 Pilot Training Systems Source: Booz & Company analysis

  13. We recommend two initiatives that will improve the effectiveness and efficiency of the current GA regulatory system Key Areas Key Recommendations Expected Benefits • 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 1 • Increase GA dedicated mechanics numbers and job opportunities 1.1 Restrictive Maintenance Training and Certification System 2 • Develop plans that will stimulate the increase in GA flight instructors and GA pilots • Increase the number of GA flight instructors and pilots 2.1 Lack of plans that help stimulate growth of GA flight instructors and GA pilots Source: Booz & Company analysis

  14. 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 Task 2: Reference the FAA Material Alternative: Seek New Opportunities • Review current mechanic certification system • Work with industry experts to identify areas where the certification methodology can be streamlined • Get the draft document ready • 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 • 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 Expected Benefits Next Steps/Follow-up • Mechanics from GA and airlines • FAA • GA manufacturers and AVIC • GA companies • Industry associations and experts • Increase GA dedicated mechanics numbers and job opportunities • Set up steering committees/work groups for each task • Draft detailed scope and work plan

  15. 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 Key Objectives • Develop plans that will stimulate the growth of GA flight instructors and GA pilots • 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 Task 2: Review Flight Instructors and Pilots Licensing Task 3: Review Medical Eligibility • 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) • 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 Stakeholders and Experts to be Consulted Expected Benefits Next Steps/Follow-up • Pilots from GA and airlines • Industry associations and experts • FAA, AOPA and EAA • China General Aviation Association • 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 • Set up steering committees/work groups for each task • Draft detailed scope and work plan

  16. Executive summaryFlight standards regulationsMechanicsPilot

  17. FAA Flight Standards Service sets the standards for certification and oversight of airmen and maintenance requirements FAA Flight Standards Service Organization Flight Standards Service Air Carrier Maintenance Branch Regional Divisions Certification and Surveillance Division FOCUS Regulatory and procedural compliance of mechanic training and maintenance organizations FOCUS Set policy and regulations for GA, including flight training and GA operations General Aviation & Avionics Branch General Aviation & Commercial Division Aircraft Maintenance Division Air Transportation Division Flight Tech & Procedures Division Program Management & Information Branch Civil Aviation Registry Regulatory Support Division Repair Station Branch International Programs & Policy Flight Standards Training Division Special Programs Branch Organizational Resources & Program Mgnt Flight Program Office GARA II Study Scope Source: FAA

  18. CAAC and FAA share very similar flight standards related regulatory system General Aviation Related Flight Standard Regulations (FAA) Source: FAA and CAAC

  19. Both CAAC’s and FAA’s Part 91 place primary responsibility on the owner or operator formaintaining an aircraft in an airworthy condition 14 CFR Part 91 CCAR 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 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) 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作… • (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

  20. 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 • 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 *Note: FAA recreational pilot category is not very successful because of nearly same requirements as for PPLand greatly restricted operations. It has been effectively replaced by sport pilot

  21. Executive summaryFlight standards regulationsMechanic certificationPilot certification

  22. The US has an established aircraft maintenancepersonnel certification system FAA FAA Aircraft Maintenance Certification System Industry Trade Certificates FAA Certificates Ratings Aviation Maintenance Specialist (AMS) Aviation Maintenance Engineer (AME) Avionics Technician Airframe Non-Certified • Authorized to work on engines and do limited work on propellers • 400 hours general plus 750 hours airframe • 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 Maintenance Certification Mechanic Certificate 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 FAA Certified Powerplant Repairman Certificate • Authorized to test and repair any part of the aircraft except the instruments, power plants, and propellers • 400 hours general plus 750 hours powerplant 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 Source: Advisory Circular 65-30, FAR 43, 65, and 147

  23. The system grants Mechanic Certificateand Repairman Certificate with different level of privileges FAA FAA Certification Type Mechanic Certificate Repairman Certificate • The holder of a mechanic certificate is relatively unrestricted as to working on any particular type ofaircraft 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 • 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 Source: Advisory Circular 65-30

  24. 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 Airframe (A) Powerplant (P) Inspection Authorization (IA) • Perform or supervise the maintenance,preventive maintenance, or alterations of an aircraftor 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 • 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) • 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 • 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 Source: FAA, Booz & Company analysis

  25. 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

  26. FAA allows non certified mechanics to work under the supervision of a certificated person with several restrictions FAA Maintenance Certification Type FAA Certified Non-Certified Mechanics • 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 • 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

  27. 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 Basic Type Aircraft Type Rating (CCAR 147) • Obtained the Basic part of the Maintenance Personnel License • Completed prescribed course and passed examination • Fulfilled maintenance experience requirements Mechanical Discipline (ME) Avionic Discipline (AV) Level I Level II • Turbine-engined aeroplane (TA) • Piston-engined aeroplane (PA) • Turbine-engined helicopter (TH) • Piston-engined helicopter (PH) • 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 Mechanic Certificate Basic Type Aircraft component ratings • 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 • Aircraft structure (STR) • Aircraft powerplant (PWT) • Aircraft landing gear (LGR) • Aircraft mechanical components (MEC) • Aircraft avionics components (AVC) • Aircraft electrical components (ELC) • The Rating part of the Civil Aircraft Component Maintenance Personnel License is sub-divided in accordance with Appendix 8 of CCAR-66 R1 Repairman Certificate Note: Same as FAA, CAAC allows non certified mechanics to work under the supervision of certified mechanics Source: CAAC, Booz & Company analysis

  28. 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 Aircraft Type Rating Certificate Privileges • 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 • 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

  29. 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 • China has more complex and restrictive maintenance personnel licensing with multiple type and component ratings • Regulations designed forair 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 Impact on GA Mechanics 1 Complex maintenance personnel licensing system • 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 2 Longer on the job training for full mechanic certification • It generally takes 2-5 years more to become a CAAC certified mechanicthan 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

  30. Complex maintenance personnel licensing system 1 Compared to FAA, CAAC maintenance licensing system develops more detailed rating categories Mechanics Type Rating Repairman Type Rating 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 FAA • Airframe • Powerplant • Airframe and Powerplant (A&P) • Avionics technician • Inspection Authorization • No rating • Recommended by repair station, commercial operator or an air carrier • Work under-supervision of approved repair station, commercial operator and carriers 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) • 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 Source: Booz & Company analysis

  31. Longer on the job training for full mechanic certification 2 FAA requires both classroom and on-the job training over a defined period for granting mechanic certifications FAA Aircraft Mechanic Experience Requirements Schooling On-the-Job Training Attending FAA Certified Training Schools Hands-on Experience at FAA Certified Repair Station Military Mechanics Experience • 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 • 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 • 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 Length of Time Required 18 months for 1 cert 30 month for A&P cert 18 months for 1 cert 30 month for A&P cert 12-24 month Source: FAA, Advisory Circular 65-30

  32. Longer on the job training for full mechanic certification 2 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 • An applicant that meets all the certification requirement under the aviation authorities regulation Full Mechanic Certificate Defined… 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 • Holder of “Basic Type” certificate • 3-5 years of working experience depending on the type of aircraft • 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 Chinese mechanic to work 2 to 5.5 years more to get a Full Mechanic Certificate Total Length of Time Required 5-8 Years 2-2.5 Years 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 Source: FAA, CAAC and interviews

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

  34. Executive summaryFlight standards regulationsMechanics certificationPilot certification

  35. 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 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 2 Limitedfunding 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 3 • 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 Establish more flight schools targeting at GA training Source: FAA, CAAC, industry interview, Booz & Company analysis

  36. Pilot certification categories 1 The US has a wider pilot category dedicated for GA enthusiasts and activities US Pilot Category (ATR not included here) Source: FAA

  37. Pilot certification categories 1 The US also has more targeted medical eligibility for different pilot categories, making flying more accessible Source: FAA, CAAC

  38. Pilot certification categories 1 In the US, the ‘Sport’ and ‘Recreational’ licenses are relativelyeasy to obtain in terms of hours required and cost Comparison of Training Requirements and Cost In order of decreasing privilege Note: FAA recreational pilot category is not very successful because of nearly same requirements as for PPLand 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 Source: AOPA, Booz & Company analysis

  39. Pilot certification categories 1 Certification requirements, privileges and operational restrictions for private, recreational and sport pilots differ FAA Pilot Certificates Comparison Note: FAA recreational pilot category is not very successful because of nearly same requirements as for PPLand 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 Source: AOPA, Booz & Company analysis

  40. Pilot certification categories 1 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) Source: CAAC, Booz & Company analysis

  41. Pilot certification categories 1 At present, CAAC pilot certification doesn’t clearly reflect the appropriate certification requirements for Sport Pilot category FAA Pilot Certification Categories 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 Student Pilot Sport Pilot (SP) China adopts a “grade” approach in managing sports pilot licensing. CCAR61 classifies sports pilots as “Primary/ Entry level” pilots To Conduct Most of Private GA Activities Recreational Pilot (RP) Private Pilot Private Pilot Commercial Pilot Commercial Pilot Airline Transport Pilot Airline Transport Pilot In order of increasing privilege Source: FAA, Booz & Company analysis

  42. Pilot training cost and financing 2 The U.S. has the following financing options for pilot training AOPA EXAMPLE US Pilot Training Financing Options AOPA Flight Training Funds Program • The candidate can contact local pilot training schools for cost/lesson and make decision on frequency of lesson and payment to the school Self-Funded AOPA Flight Training Funds offers: • Predictable payments • No annual fee • No collateral needed • Renewable source of cash • Credit line up to $25,000 • Support AOPA and General Aviation In association with • 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 Scholarship 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 • 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 Line of Credit Source: AOPA, Booz & Company analysis

  43. Pilot training cost and financing 2 In China, pilot funding are limited to either Airline / GA company scholarship or self-funding CHINA EXAMPLE China Pilot Training Financing Options Explore Other Funding Options • 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 Self-Funded • 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 increasethe 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 • Majority of pilot training are either airline sponsorship or GA company sponsorship • Most of these sponsorship are for college students Scholarship

  44. Pilot training cost and financing 2 There are two regulations in the US that oversee the flight school certification - Part 141 and 61 FAA FAA Flight School Certification Part 141 Part 61 • 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- 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

  45. Flight schools 3 In general Part 61 certification is relatively easy to obtain and the entry barrier are lowerthan Part 141 FAA FAA Part 141 and Part 61 Flight School Comparisons Note: Total log time includes in flight training time, class based instructional time, self flying time etc. Source: FAA, Booz & Company analysis

  46. Flight schools 3 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 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 FAR 141 CCAR 141 • 50% pilot pursue the career of GA and may later return to airline PPL/ CPL CPL • Less than 10% of the pilots go to GA industries • 50% pilot pursue the career in the airlines and continued their study after CPL ATPL ATPL • More than 90% of pilot pursue the career in the airlines and continued their study after CPL Source: FAA, CAAC

  47. Flight schools 3 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） Comments • 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 • 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

  48. Flight schools 3 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) Flight Instructors With a Sport Pilot Rating (Subpart K) • 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 with: • An aircraft category and class rating that is appropriate to the flight instructor rating sought; and • An instrument rating, or privileges on that person's pilot certificate that are appropriate to the flight instructor rating sought..” • 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: 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 Source: FAA, Booz & Company analysis

  49. Flight schools 3 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 Limits FAR 61.415 • 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 • 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

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