Eduardo de Vasconcellos, CEO, RPAS Ops Consulting
ANAC´s Personnel Superintendency has issued a 50-page proposal on licence and rating requirements for eVTOLs, for sectoral review and comments.
The proposal takes account of light recent industry and regulatory proposals on the topic, the impending schedules for aircraft certification and entry into service, and underlining FAA´s NPRM/2023 on powered-lift integration and EASA´s Opinion No 03/2023 on VTOL-capable aircraft. It starts by pointing out that FAA´s proposal is based on the existing category of powered-lift aircraft, whilw EASA´s takes a performance-based approach to the development of regulations, including the personnel-related aspects, by defining a new aircraft category, that of VTOL-capable aircraft, VCA. It also notes that ICAO has not yet started discussions on certification requirements for civil aviation personnel, at its Personnel Training and Licensing PANEL. ANAC also cites the regulatory needs associated with Embraer´s EVE-100 certification and entry into service schedules, relative to trained and certified pilots, mechanics and repair stations. To keep up with industry developments on PEL, ANAC just became a member of SAE´s Study Group 35 – Modeling, Simulation, Training for Emerging AV Tech.
Whereas maintenance mechanics and stations for VCA should be accommodated by the existing rules, via development and application of model-specific training programmes, ANAC sees a clear need for modification or adaptation of the existing rules to properly accommodate future VCA pilots and their new competencies, technical and non-technical. Additionally, it is also taken for granted that any regulatory solution in the PEL domain should be based on: performance-based principles, competency-based training, and a review of the role of simulation devices currently used.
In this context, ANAC sets out to detail their proposal, with focus on two major industry consensus transition scenarios:
- technical requirements for licensed commercial pilots, aircraft or helicopter, to be certified on the new aircraft so as to meet the industry´s initial demand;
- technical requirements for citizens who want to become VCA pilots, and that have no previous experience in commercial operations – ab initio training.
Comments to be submitted no later than July 3rd, 2024
ANAC´s full regulatory proposal in English can be found at https://www.gov.br/anac/pt-br/acesso-a-informacao/participacao-social/consultas-setoriais/consultas/2024/cs-03-2024/CS032024regulatoryproposal.pdf