This is not a straightforward scenario, so we will provide a concrete example to help with the answer. Here we will focus on the E1, E4 and E5 exclusions commonly associated with a B1.1 licence.
Note in the above example, the E1, E4 and E5 exclusions are all listed directly under the licence category. As such, they are applicable to the category, and by proxy, are therefore applicable to any aircraft “type”. Note that there is no need for E1, E4 and E5 to be listed alongside any “type” rating in this case.
First, let’s look at the category exclusions removal.
There are 3 parts to this removal process, 2 involve theory, 1 involves practical. The exclusions can only be removed by a Part 147 ‘Category’ approved MTO and the process is ‘roughly’ described in the Part 66 MOS. The ‘Units of Competency’ associated with your exclusions are listed in ‘Appendix VIII’ of the Part 66 MOS.
Your chosen MTO will guide you through two processes of theory assessment, and one process of practical evidence gathering, in order for you to receive a ‘Statement of Attainment’ for the ‘competencies’ (UOC’s) listed.
The theory requirement involves the following two processes.
1. Covering the essential theory required by the ‘VET’ system in order for you to fulfil the ‘knowledge evidence’ requirements of the ‘UOC’ (eg. MEA296)
and
2. Satisfying the CASA requirement to cover the Part 66 ‘Module’ theory that correlates to the UOC’s they list for your exclusion removal.
This essentially means the theory requirement involves both satisfying the ‘UOC’ (MEA unit assessment / theory RPL / etc., by the MTO), and undertaking Modular ‘Gap’ exams to satisfy CASA. The part 147 MTO will have a procedure to do both.
• The practical requirement will involve either:
1. Finding the practical requirements of the ‘UOC’ from your work history records, or
or
2. Completing tasks on a ‘Work History Sheet’ that you need in order to 100% cover the ‘UOC’ practical requirements.
In summary, you may be doing anywhere from two to five ‘Gap’ Exams for the theory, and searching for practical tasks you have performed for evidence. Once your exclusion removal application has been processed by CASA, the exclusions will no longer appear after your Category.
Now, let’s turn to the type exclusions removal.
In this example, the licence holder has had their E1, E4 and E5 exclusions removed from their category. Now that these exclusions are no longer applicable to the category, they are listed alongside the types.
One document that explains this process is the:
“AMC/GM Part 66 v7.2 – Continuing Airworthiness – Aircraft Engineer Licences and Ratings” (B.4.4 Policy – removing an exclusion from an aircraft type rating)
Even though particular electrical theory and practical content were covered during the E1, E4, E5 ‘category’ exclusion removal at the Part 147, there is a requirement by CASA to complete ‘OJT’ for your ‘first of type’ exclusion removal. The result would be:
• Even though you may submit an application to CASA to add your 737 type rating to your licence, CASA would withhold any processing until they received your E1, E4, E5 ‘OJT’ for your ‘first of type’ exclusion removal. In theory, you could choose any of your listed type ratings to be the subject of the E1, E4, E5 OJT, but it would make sense to choose to do the 737 OJT, as you have just completed this course.
• Once you submit the completed E1, E4, E5 OJT to CASA, both the 737 type course, and E1, E4, E5 OJT will be processed.
• Your new licence will be issued with the 737 in the ‘Type Ratings’ column, and there would be no E1, E4, E5 listed after this aircraft type. The existing aircraft listed in the ‘Type Ratings’ column would continue to display the E1, E4, E5 after the aircraft type, however, and would require specific E1, E4, E5 exclusion removal training on those particular types. Note that there would be no requirement to complete any ‘OJT’ for these aircraft, as the ‘first of type’ exclusion removal OJT was completed with the 737.
