Regulation (EU) No 1178/2011 AIRCREW : Pilot Licences
DTO.GEN.230 DTO training programme - Regulation (EU) 2020/359
- A DTO shall establish a training programme for each of the trainings specified in point
DTO.GEN.110 which the DTO provides.
- The training programmes shall comply with the requirements of Annex I (Part-FCL), Annex III
(Part-BFCL) to Commission Regulation (EU) 2018/395 and Annex III (Part-SFCL) to Commission
Implementing Regulation (EU) 2018/1976, as applicable.
- A DTO shall be entitled to provide the training referred to in point DTO.GEN.110(b) only
when its training programme for that training, and any changes thereto, have been issued by
the competent authority, upon application by the DTO, with an approval in accordance with
point ARA.DTO.110, confirming that the training programme and any changes thereto comply
with the requirements of Annex I (Part-FCL), Annex III (Part-BFCL) to Commission Regulation
(EU) 2018/395 and Annex III (Part-SFCL) to Commission Implementing Regulation (EU)
2018/1976, as applicable. A DTO shall apply for such approval through the submission of its
declaration in accordance with point DTO.GEN.115.
- Point (c) shall not apply to an organisation also holding an approval issued in accordance
with Subpart ATO of Annex VII (Part-ORA) that includes privileges for that training.
AMC1 DTO.GEN.230 DTO training programme - ED Decision
- The DTO training programme should include at least the following information:
- the aim of the course;
- crediting of previous experience and pre-entry requirements (including
appropriate procedures for students that wish to complete their training after
having started at a different training organisation);
- a list of all air and FSTD exercises to be taught, including a description of
the objective of each exercise;
- a syllabus summary;
- structure and content of the theoretical knowledge instruction;
- structure of the entire course and integration of theoretical knowledge
instruction, FSTD and flight training;
- student progress checks for theoretical knowledge and flight training, as
- When developing the training programme for a type rating course, in addition to
complying with the mandatory training elements included in the operational suitability
data (OSD), as established in accordance with Regulation (EU) No 748/20121,
the DTO should also follow any further recommendations (i.e. acceptable means of
compliance (AMC)) contained therein.
1 Commission Regulation (EU) No 748/2012 of 3 August 2012 laying
down implementing rules for the airworthiness and environmental certification of aircraft
and related products, parts and appliances, as well as for the certification of design and
production organisations (OJ L 224, 21.8.2012, p. 1), as amended.
DTO.GEN.240 Training aircraft and FSTDs - Regulation (EU) 2019/1747
- A DTO shall use an adequate fleet of training aircraft or FSTDs appropriately equipped for
the training course provided. The fleet of aircraft shall be composed of aircraft that
comply with all requirements defined in Regulation (EU) 2018/1139. Aircraft that fall under
points (a), (b), (c) or (d) of Annex I to Regulation (EU) 2018/1139, may be used for
training if all of the following conditions are met:
- during an evaluation process the competent authority has confirmed a level of safety
comparable to the one defined by all essential requirements laid down in Annex II to
Regulation (EU) 2018/1139;
- the competent authority has authorised the use of the aircraft for training in the
- A DTO shall establish and keep up-to-date a list of all aircraft, including their
registration marks, used for the training it provides.
AMC1 DTO.GEN.240 Training aircraft and FSTDs - ED
- The number of training aircraft may be affected by:
- the availability of FSTDs; and
- the number of aerodromes and operating sites of the DTO (cf. AMC1
- Each training aircraft should be:
- equipped as required in the training specifications concerning the exercise for
which it is used;
- except in the case of balloons or single-seat aircraft, fitted with primary
flight controls that are instantly accessible by both the student and the
instructor (for example, dual flight controls or a centre control stick);
swing-over flight controls should not be used.
- The fleet should include, as appropriate to the training courses:
- in the case of aeroplanes and sailplanes, aircraft suitable for demonstrating
stalling and spin avoidance;
- in the case of helicopters, helicopters suitable for autorotation
- FSTDs; each FSTD should be equipped as required in the training specifications
concerning the course for which it is used.
- One single aircraft that has all the required characteristics of a training aircraft
mentioned in (b) and (c) above may be sufficient.
GM1 DTO.GEN.240 Training aircraft and FSTDs - ED Decision
The DTO is required to use an adequate fleet of training aircraft. However, a DTO is not
required to own the aircraft used. In any case, the DTO has the responsibility to use
airworthy and appropriately equipped, certified and insured aircraft and FSTDs, as relevant
to the particular training exercise.
AMC3 DTO.GEN.240 Training aircraft and FSTDs - ED
Two cases for the evaluation process of Annex-I aircraft are distinguished:
- Annex-I aircraft that hold an ICAO-level certificate of airworthiness (CoA)
- To support the evaluation process performed by the competent authority and
provide the competent authority with sufficient data related to the aircraft in
question, an instructor who is qualified in accordance with Annex I (Part-FCL)
to Regulation (EU) No 1187/2011 and nominated by the head of training (HT) of
the DTO should assess that the aircraft is appropriately equipped and suitable
for the training courses provided. The result of this assessment should be
submitted to the competent authority and may be included already in the
application for the authorisation.
- During the evaluation process, the competent authority should consider aircraft
that hold a CoA issued in accordance with Annex 8 to the Chicago Convention to
provide a level of safety comparable to that required by Annex II to the Basic
Regulation, unless the competent authority determines that the airworthiness
requirements used for certification of the aircraft, or the service experience,
or the safety system of the State of design, do not provide for a comparable
level of safety.
- Annex-I aircraft that do not hold an ICAO-level CoA
Before the inclusion of these aircraft in the fleet of an DTO and their use in
training to obtain Part-FCL licences and ratings, the DTO should apply for the
authorisation to the competent authority that should perform the evaluation process in
the following order:
- Initial assessment by the competent authority and criteria taken into
The competent authority should take into account the following criteria
- national airworthiness requirements based on which the aircraft CoA was
- aircraft similarities to a certified variant;
- aircraft with a satisfactory in-service experience as training
- simple and conventional aircraft design;
- aircraft that does not have hazardous design features or details,
judging by experience; and
- operable aircraft systems, equipment, and appliances that do not require
exceptional skills or strength.
- Additional assessment by a qualified instructor
To support the evaluation process performed by the competent authority and
provide the competent authority with sufficient data related to the aircraft in
question, after the positive initial assessment by the competent authority as
per point (1), an instructor who is qualified in accordance with Part-FCL and
nominated by the HT of the DTO should show through an evaluation report that the
aircraft is appropriately equipped and suitable for the training courses
provided. That evaluation report should consider all of the following criteria:
- the aircraft should be safely controllable and manoeuvrable under all
anticipated operating conditions, including after failure of one or more
- the aircraft should allow for a smooth transition from one flight phase
to another without requiring exceptional piloting skills, alertness,
strength, or workload under any probable operating conditions;
- the aircraft should have sufficient stability to ensure that the demands
made on the pilot are not excessive, considering the phase and duration
of flight; and
- the assessment should take into account control forces, flight deck
environment, pilot workload, and other human factors (HF)
considerations, depending on the phase and duration of flight.
Subject to a positive evaluation report as per point (2), the competent authority
should issue the authorisation.
DTO.GEN.250 Aerodromes and operating sites - Regulation (EU)
- When providing flight training on an aircraft, a DTO shall only use aerodromes or operating
sites that have the appropriate facilities and characteristics to allow training of the
relevant manoeuvres, taking into account the training provided and the category and type of
- When a DTO uses more than one aerodrome to provide any of the training specified in point
DTO.GEN.110(a)(1) and (2), it shall:
- for each additional aerodrome, designate a deputy head of training, who shall be
responsible for the tasks referred to in point DTO.GEN.210(a)(2)(i) to (iii) on that
- ensure the availability of sufficient resources to safely operate on all aerodromes,
in compliance with the requirements of this Annex (Part-DTO).
AMC1 DTO.GEN.250 Aerodromes and operating sites - ED
- Except in the case of balloons, the base aerodrome or operating site and any other
aerodromes or operating sites at which flight training is being conducted should have at
least the following facilities:
- at least one runway or final approach and take-off area (FATO) that allows
training aircraft to make a normal take-off or landing within the performance
limits of all the aircraft used for the training flights at that aerodrome or
- a wind direction indicator that is visible at ground level from the ends of each
runway or at the appropriate holding points;
- adequate runway electrical lighting, if used for night training;
- an air traffic service (ATS), except for uncontrolled aerodromes or operating
sites where the training requirements may be satisfied safely by another
acceptable means of communication.
- In addition to (a), for helicopters, training sites should be available for:
- confined area operation training;
- simulated engine-off autorotation; and
- sloping ground operation.
- In the case of balloons, the take-off sites used by the DTO should allow a normal
take-off and clearing of all obstacles in the take-off flight path by at least 50 ft.
- By way of derogation from paragraphs (a) to (c) above, for training that needs to take
place in a specific environment (training for mountain rating, training on seaplanes),
the training sites used should have the characteristics and facilities that are
necessary to ensure a safe conduct of the training.
AMC1 DTO.GEN.250(b) Aerodromes and operating sites - ED
SUFFICIENT RESOURCES OF A DTO THAT PROVIDES TRAINING FOR AEROPLANES OR HELICOPTERS AT
MORE THAN ONE AERODROME OR OPERATING SITE
- Deputy heads of training should meet the same qualification requirements as set out in
AMC1 DTO.GEN.210(a)(2) for the head of training (HT).
- The DTO should have the necessary number of instructors (point DTO.GEN.210(d) and (e))
as well as the necessary number of training aircraft (point DTO.GEN.240) in place to
ensure proper training at all aerodromes and operating sites.
- At each aerodrome or operating site of the DTO, the DTO should have in place the
facilities (point DTO.GEN.215) as appropriate for the type of training carried outat
each aerodrome or operating site.
DTO.GEN.260 Theoretical knowledge instruction - Regulation (EU)
- When providing theoretical knowledge instruction, a DTO may use on-site instruction or
- A DTO shall monitor and record the progress of any student undergoing theoretical knowledge