Response 383715227

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Tu

Key changes

Please provide any comments you may have on the key changes proposed.

Comments
The reduction of the experience required is reasonable for obtaining the B1 licence.

Policy option 1 – Proposed modular structure

Policy

Please provide any comments you may have on the proposed policy for the modular licences.
this proposal is relevant and acceptable.

Policy

Please provide any comments you may have on the proposed structure for the subsets.
The 4 subsets are more practical compare to the existing structure.

Policy

Please provide any comments you may have on the proposal for examinations to be specific to each subset.
The examination standards must be maintained.

Policy

Please provide any comments you may have on the proposal for subsets to be initially available via the self-study pathway and mapping for the NVET system.
Self-study must be concurrent with the practical experience.

Policy

Please provide any comments you may have on the proposal to use exclusions framework to allow accelerated implementation.
Shortage of LAE should not be the excuse for the accelerated implementation.

Policy option 2 – Examination requirements tailored to each module

Proposed B1 knowledge requirements

Please provide any comments you may have on the proposed B1 subset knowledge requirements.
M13 should be included in the B1 requirement.

Proposed B2 EIR knowledge modules

Please provide any comments you may have on the proposed B2 EIR knowledge modules.
The B2 EIR knowledge modules are sufficient.

Policy option 3 – Experience requirements tailored to each subset

Proposed B1 experience requirements

Please provide any comments you may have on the proposed B1 experience requirements.
Self-study basic experience logbook must be signed off by the senior LAE.

Policy option 4 – Initially available via self-study pathway provisions

Self-study training and examination pathway

Please provide any comments you may have on the proposed self-study pathway and mapping by MTOs for the NVET system.
No comments.

Policy option 5 – Initial introduction via existing Part 66 exclusions

Exclusions to be used in the short term

Please provide any comments you may have on the use of exclusions.
Exclusions are not pratical in Singapore industry enviorment as limited General Aviation companies available.

General comments

Do you have any additional comments about the proposed policy?

Comments
Generally the proposed policy is acceptable provided no compromise of standard due to LAE shortage.