The aircraft type rating is exactly difference training. You don't start from scratch just because a type certificate differs between two airplanes. The whole point is to require that difference training, and for it to be specifically laid out.
Whereas without that, what did Boeing do? They gave pilots an iPad for difference training, and kept them in the dark about the differences between 737 NG and 737 MAX. That was their choice. The lie of omission by manufacturers is the whole reason why we have type certifications in the first place.
> The aircraft type rating is exactly difference training. You don't start from scratch just because a type certificate differs between two airplanes. The whole point is to require that difference training, and for it to be specifically laid out.
You're talking about training for completely different planes. Type training is commonly multiple weeks long. What I'm suggesting is something intermediate for two variants of a plane that are much more alike than that ("subtype training"), so that it's hours or days rather than weeks because there aren't as many differences to cover between two 737 variants than between a 737 and a 787.
> Whereas without that, what did Boeing do? They gave pilots an iPad for difference training, and kept them in the dark about the differences between 737 NG and 737 MAX.
Right, exactly. So they have the tiers too far apart. There is too big a jump between "here's an iPad" and tens of hours of training over multiple weeks, so there's a need for something in between for smaller variations.
I'm not talking about completely different planes. If you have a Boeing 737 type rating, obtaining a 757/767 type rating is more expedient than it is for someone who has no prior Boeing 737 type rating.
Further the regulations say whether a type certificate is required, and what goes into it, is up to the administrator. It's not strictly defined. You can in in effect have subtype ratings.
FAA regulations are very much dependent on delegating authority rather than detailing every nitpicky thing. They really aren't that complicated.
> I'm not talking about completely different planes. If you have a Boeing 737 type rating, obtaining a 757/767 type rating is more expedient than it is for someone who has no prior Boeing 737 type rating.
Aren't the 737 and the 757/767 completely different planes? Isn't the difference between a 737 NG and a 737 MAX a lot smaller than the difference between a 737 NG and a 767?
> Further the regulations say whether a type certificate is required, and what goes into it, is up to the administrator. It's not strictly defined. You can in in effect have subtype ratings.
It's not surprising that the regulators have that level of discretion, but that only helps if it's expected they'll use it like that, which seems contrary to what Boeing did expect given their apparent aversion to it.
>Aren't the 737 and the 757/767 completely different planes?
No. But then, given your questions thus far, we clearly don't have a common frame of reference, so I don't really know what you mean by completely different. They are not 100% different, that's for sure.
Consider this: the difference between a 737 NG and MAX is smaller than the difference between a 757 and 767. And yet the 757/767 share a single type rating. They were designed at the same time and have nearly identical cockpit layouts. And guess what, the Airbus 320 and 340 share the same type certificate as well, they're more different from each other than the 757 and 767 are to each other. But the two Airbus's also have the same cockpit layout, control systems, and software abstraction such that in normal flight they pretty much behave the same (obviously ground operations are different, they are rather substantially differently sized).
A "subtype" is just not applicable in this discussion. Any completely redesigned airplane from Boeing, in lieu of the 737 MAX, no matter its size, is going to so radically depart from any other airplane's flight characteristics and cockpit layout, that it would absolutely end up with its own type certificate. You can't design a new airplane model, and shove in the cockpit from a 737 NG. You can't and you wouldn't want to.
They dropped the ball. And the instant the Airbus 320neo was announced, Boeing was shown to have gotten caught with their pants down, and that has nothing at all to do with the regulatory paradigm.
Whereas without that, what did Boeing do? They gave pilots an iPad for difference training, and kept them in the dark about the differences between 737 NG and 737 MAX. That was their choice. The lie of omission by manufacturers is the whole reason why we have type certifications in the first place.