When the Aircrew Regulation came into effect across Europe in 2013 training for all types of pilot licences and ratings had to be provided in Approved Training Organisations. It soon became apparent that this was a burden to the ‘lighter’ end of aviation and EASA started working on a proportionate system for general aviation. The result is the ‘Declared Training Organisation’ (DTO).
Training towards the light aircraft pilot’s licence (LAPL), private pilot’s licence (PPL) and some of the associated ratings can be provided in an DTO. For aeroplanes this includes single -engine piston ratings and additional ratings (night, aerobatics, mountain, sailplane and banner towing). For helicopters it includes type-ratings for single-engine aircraft (including turbines) with five or less seats and night ratings. DTOs can also provide training for sailplane and balloon pilots.
Declared, not approved.
A Declared Training Organisation (DTO) does not need approval from the Competent Authority in the way that an Approved Training Organisation (ATO) does, instead a representative of the organisation submits a declaration. The declaration confirms that the organisation has implemented a safety policy and will comply with all applicable requirements; it lists the training courses the organisation will provide, the aircraft aerodromes and operating sites to be used and the names of management personnel.
Instead of a complex management structure a DTO has to nominate just two management posts. The ‘Representative’ is responsible to develop and implement a safety policy, ensure that the DTO complies with applicable requirements and make sufficient resources available. The ‘Head of Training’ is responsible for the content of courses and the delivery of training. The same person could be nominated as both Representative and Head of Training. The DTO needs to have adequate facilities and aircraft.
There should be training programmes for all of the courses that the DTO will offer. For most courses these will be simple to produce as Part-FCL provides detailed information about the various courses. DTOs can also provide standardisation courses for flight examiners but these courses have to be specifically approved, in advance, by the Authority. DTOs are not required to have an operations manual but might choose to have one.
Records and Reporting
DTOs will need to keep records of all training delivered, the progress of individual students and the qualifications of instructors. Course completion certificates will be issued for the students to use when they apply for their licences or ratings. In place of compliance monitoring a DTO will conduct an annual internal review and produce a report. The review will cover safety performance and adequacy of training. The report will also include details of the training courses delivered during the year.
Although there is no ‘approval’ requirement the Competent Authorities are under an obligation to conduct oversight of DTOs. This will be risk-based oversight, so the Authorities will concentrate their efforts on the larger organisations, those providing more training or those where an Authority has reason to think that there could be safety risks. Authorities will conduct inspections and audits on DTOs, sometimes without prior notice. If they find safety issues then they’ll require corrective action and, in extreme cases, they could prevent a DTO from providing training.