Project Overview
Presentation about
the Offset proposal
to support
the Aviation Industry in Taiwan
during the transition period
to the new CAA part 66 and 147regulation
LTTT US/G Gü
15 July, 2010, Seite 1
Project Overview
•
Project:
Support the Taiwan Aviation Industry to upgrade their
maintenance personnel and their training department
abilities to comply with the new CAA part 66 and part 147
regulations.
•
Sponsor:
Thales
•
Local Partner:
Taiwan Aviation Industry, represented by EGAT and
supervised and controlled by the Civil Aeronautical
Administration of Taiwan R.O.C.
•
Foreign Partner: Lufthansa Technical Training Germany
Time line
•
Estimated project approval: October 2010
•
Estimated project start:
November 2010
•
Project duration:
max 2 years
LTTT US/G Gü
15 July, 2010, Seite 2
Reasons for the Offset Proposal
•
The Taiwan CAA in discussion with airlines and MRO’s has nearly completed the
draft for the new CAA part 66 and 147 regulations. The draft is expected to be
released in the second half of 2010.
•
The final version is expected to be empowered until end of 2011.
•
The previous license knowledge and skill requirements were based on FAR part
65 standards.
•
The new license knowledge and skill requirements are based on EASA part 66
standards including the curriculum for basic and type training.
•
There is a huge gap between those both requirements and the arrangement of the
training modules is completely different between the old and new regulation.
•
Conversion training and/or conversion examinations will be needed to upgrade
the present license holder (estimated 1800 license holders) to the new license
without limitations.
LTTT US/G Gü
15 July, 2010, Seite 3
Reasons for the Offset Proposal (cont.)
•
Taiwan is the first National Aviation Authority transferring from an FAA based
system to an EASA based systems. There is no documentation and
experience available from another aviation authority which can ease and
speed up the comparison.
•
The comparison determines what conversion requirements have to be
covered by each license holder to convert to the new license.
•
To convert, license holders have to take examinations. For the preparation
training or self preparation there are no customized books available.
•
The license holder would have to pick out of many books what they need to
learn what causes them much more time to prepare as it is necessary.
•
Since the differences between the old and new licenses are not defined yet,
there is no curriculum for the conversion training.
LTTT US/G Gü
15 July, 2010, Seite 4
Reasons for the Offset Proposal (cont.)
•
The data base for examination questions covering the additional knowledge
for the conversion requirements is not available yet. Examination questions
need to be prepared in accordance to the conversion requirements.
•
For airlines and MRO’s everyday a qualified mechanic is absent for training
costs money and influences production. They want that the conversion is as
efficient as possible within the shortest time and highest passing rate.
•
That means an optimized program for the conversion is needed, including
curriculum, training books, examinations, avoiding any waste of time,
Who can provide enough qualified manpower and has the know-how to do this
job and how long will the preparation take? And who will pay for all those man
hours needed?
Conclusion: An Offset Program is needed.
LTTT US/G Gü
15 July, 2010, Seite 5
Relationship of involved parties
Offset Provider
TBD
Offset Service
Provider - LTT
Offset Authority
IDB / ICPO
Offset Recipient
EGAT
Offset
Beneficial
China Mandarin
Airlines Airlines
UNI
Air
Trans
Asia
Airlines
LTTT US/G Gü
15 July, 2010, Seite 6
FAT?
AIDC
Air
Asia
Offset Controller
CAA
ACTS
Daily
Air
Sunrise
Airline
147
Schools
Tasks and services included in the Offset program
Conversion and transition:
•
The offset program shall provide the Taiwan Aviation Industry with:
•
Analysis of the differences between the current license and the new license
requirements. The analysis report needs to be approved by CAA and to be
converted into limitations for the new license, the work already done by China
Airlines can be used as a base.
•
Out of this analysis a curriculum shall be developed which knowledge
requirements are necessary to remove those limitations.
•
Experience and education background of present license holders shall be
assessed to reduce the required duration of conversion training to the
minimum.
LTTT US/G Gü
15 July, 2010, Seite 7
Tasks and services included in the Offset program
Conversion and transition (cont.):
•
Training books shall be tailored for teaching and self study to meet those
knowledge requirements.
•
An Examination Data Base will be developed which will be controlled by CAA
to perform the conversion examinations. The data base software can be
purchased in accordance with Taiwanese Aviation Industry requirements.
•
Providing a summary conversion report of the Taiwanese Aviation Industry
and individual reports of each Airline and MRO
LTTT US/G Gü
15 July, 2010, Seite 8
Tasks and services included in the Offset program
Conversion and transition (cont.):
•
Training of 300 license holder for the conversion examination.
•
Consulting services for the maintenance departments to help setting up the
new procedures for license conversion issues and release to service.
•
Assist the authorities in all kinds of needed support to speed up the
conversion process.
•
Experts from Europe will be brought to Taiwan for the specific jobs.
•
The CAA will oversee and control the entire project and will allocate resources
and services to airlines and MRO’s as needed.
•
Other demands which can be defined by airlines and MRO’s.
LTTT US/G Gü
15 July, 2010, Seite 9
Tasks and services included in the Offset program
Basic Training Setup:
•
The offset program shall provide the Taiwan Aviation Industry with:
•
Training books and training media for CAT-A, B1 and B2 basic training.
•
Provide the curriculum and instructor guides for CAT-A, B1 and B2 basic
training.
•
Provide the examination questions for CAT-A, B1 and B2 basic license
examination .
•
Support 147 basic training schools to set up their training, qualify their
instructors and examiners and setup the required practical training.
•
Provide new staff training based on EASA basic training standards.
for a period two years.
LTTT US/G Gü
15 July, 2010, Seite 10
Tasks and services included in the Offset program
Type Training Standardization:
•
The offset program shall provide the Taiwan Aviation Industry with:
•
Provide the course lay-out for approved type training courses and
examination questions.
•
Provide the standards for new type training concepts integrating maintenance
simulators and electronic documents.
•
Provide a type training course (e.g. A320) as a best practice example of the
new training concept for seed instructors within the airlines and MROs .
•
Setup standard and develop procedures for the practical on the job training.
•
Train practical OJT instructors and assessors.
LTTT US/G Gü
15 July, 2010, Seite 11
Tasks and services included in the Offset program
Type Training Standardization (cont.):
•
Provide task training curriculums, training and approval procedures and
training materials for CAT-A.
•
Transfer the know-how for the generation of Training Needs Analysis (TNA)
•
Updating training for instructors, examiners and assessors.
•
Provide methodology training (same as for EASA staff) for setting up
examination questions, including validity, reliability, training level and
difficulty level.
•
Practical Assessor, Examiner and Seed Instructors training.
•
Support for maintenance staff who have previously joined EASA like CAT-A
training to receive the CAA CAT-A qualification
LTTT US/G Gü
15 July, 2010, Seite 12
Tasks and services included in the Offset program
Consulting services:
•
Coaching of surveyors, inspectors, and auditors for the aviation industry and
CAA.
•
Solving problems related to the regulation change (e.g. quality system
procedures and organizational structure and reflect the changes of the Part
66/147 and their impact on CAR 145…)
•
Support the final drawing up of the CAA part 66 and 147 regulations. Experts
from the Taiwanese aviation industry will be included for this task.
•
Pre-survey of part 147 applications for type training and basic training.
•
Influence and adoption evaluation of new NPA’s (e.g. NPA 2007-02 / 2007-04 /
2009-05)
LTTT US/G Gü
15 July, 2010, Seite 13
Tasks and services included in the Offset program
Consulting services (cont.):
•
Information service about evolution of the EASA regulations.
•
Draw up procedures for license extensions
•
Support the setup and usage of individual log books for practical experience
•
Support to setup procedures for logbook assessor qualification and terms of
reference
•
Consulting services for training schools of Airlines and MRO’s to gain 147
type training or/and basic training approval. This Includes examination
procedures, practical training set up, and MTOE procedures.
LTTT US/G Gü
15 July, 2010, Seite 14
Timeframe for the Offset Project
•
The executive committee of the ICP office is deciding every 3 months on
offset applications.
•
1 month after the decision for this offset project the analysis will start and
will take about 3 months. Finished sections of the analysis can already be
submitted during this period for review by CAA.
•
The curriculum can be finished within 3 weeks after the approval of the
analysis.
•
The preparation of the training programs will take about 4 months. During
the same period the examination data base can be prepared and
instructors, examiners and assessors can be trained.
•
Conversion examinations and courses can be performed directly
afterwards.
LTTT US/G Gü
15 July, 2010, Seite 15
Offset Rules
Offset rules:
•
An offset provider has offset credit obligations depending on the value or
his sales to a country. These credits can be used for offset projects.
•
An offset project can be applied by an organization which needs such a
project or the offset provider can apply by himself.
•
The project is performed by a foreign company which provides the
special know-how, needed to perform the project.
•
The ICP office reviews the application and if there is a positive result it
will submit it to the executive committee for final decision.
LTTT US/G Gü
15 July, 2010, Seite 16
Offset Rules (cont.)
Offset rules:
•
The real costs of different services are converted into offset credits.
•
Depending on the technical value of each service a multiplier applies.
Multipliers can be between 1 and 10 depending on the technical value.
•
Standard products which can be purchased everywhere have a low technical
value.
Products and services which can not be purchased on normal base have a high
technical value, e.g. training books customized for a conversion program.
•
The sum off the calculated credits from all offset services is deducted from the
offset obligations from the offset provider.
•
For the received services the offset recipient should pay 0.35% of the value of
the credits received back to the IDB office.
LTTT US/G Gü
15 July, 2010, Seite 17
Offset Rules (cont.)
Calculation example:
Assumption for conversion training.
In order to remove all limitations from the new license it is assumed that e.g.
700 hours of conversion training is needed. Each hour would account for
350 NT. Since the technical value in offset projects is appreciated by a
multiplier the technical value of training is normally considered as the
multiplier 5.
350 TWD * 5 = 1750 TWD.
In accordance to Taiwan offset regulation the recipient must return 0.35% of
the received value to the IDB office.
0.35% of 1750 TWD = 6.125 TWD per training hour.
LTTT US/G Gü
15 July, 2010, Seite 18
How can this offset project help to perform the change?
• The same principle applies to consulting services. For services which
benefit the entire aviation industry system for sharing must be
defined.
• Since this sharing ratio is difficult to be evaluated the 0.35% should
be refunded to the airlines and MRO’s by the offset service provider.
LTTT US/G Gü
15 July, 2010, Seite 19
Qualification of the Service Provider
Why is LTT qualified to perform the conversion project services?
LTT was approved as the first 147 school under JAA and later under
EASA.
LTT has performed the same services for Lufthansa Technik.
LTT was supporting the conversion in UK, Singapore and Malaysia.
LTT has been selected by the EU to build up the European EASA
examination data base.
LTT has long term experience in Asia and especially in east Asia.
LTT has the necessary resources needed for such a project.
LTTT US/G Gü
15 July, 2010, Seite 20