"Regulating Flight Crew Training"
J. Randolph Babbitt, London
September 28, 2011
Royal Aeronautical Society Flight Crew Training Conference
Remarks as Prepared for Delivery
Good afternoon, and thank you, Professor (Lee) Balthazor (President-Elect, Royal Aeronautical Society) for that introduction. It is a pleasure to be here, and I thank you for inviting me to join you at the Royal Aeronautical Society’s International Flight Crew Training Conference.
This topic is undoubtedly one of the most important issues facing aviation safety professionals and regulators today. It is also one of the most challenging. Advances in technology and today’s meticulous investigation of accidents have given us the means, and the data, we need to design many of yesterday’s mechanical malfunctions out of the aviation safety equation. It is a much more complex undertaking to design errors out of the human element.
But that doesn’t mean we have stopped trying – far from it. Safety is the FAA’s primary mission and top priority. Addressing the human element in the chain of events that leads to an accident is one of the reasons I have focused so sharply on professionalism since Day One as FAA Administrator. But I’ll say it again: however much I wish it were possible, I cannot mandate professionalism.
But there are certainly things we can do, and that brings me to the theme of this conference—flight crew training standards. A key role for aviation regulators is to design policies, procedures, and regulations that will prevent as many errors as we can, and mitigate the impact of those errors that still occur. And, of course, we have to design and implement effective ways of training flight crews on all those carefully designed procedures and regulations. The best procedures in the world are not worth much unless they are understood and implemented by flight crews. So we have to constantly be alert to how we can improve procedures and training methods.
That’s one of the reasons behind the FAA’s proposal for updating our regulations for flight crew training. We started this process in January 2009, when we issued a Notice of Proposed Rulemaking to revise existing regulations on the Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers. Based on public comments and findings from the 2009 Colgan Air accident, we decided to develop and publish a Supplemental Notice of Proposed Rulemaking. Our proposal:
- Increases the normal, abnormal, and emergency tasks for training and evaluation of each flight crew member;
- Requires the “pilot monitoring” to observe, assess, and inform other crewmembers and appropriate agencies on flight progression, systems, and situational awareness;
- Changes the training and evaluation interval to 9 months;
- Establishes baseline and minimum hours for completion of various curricula;
- Permits credit for training, testing, recent experience, and operating experience based on commonality of aircraft systems design and handling characteristics
- Establishes requirements for requalification training based on FAA guidance and industry practice;
- Incorporates stall, upset recovery, and remedial training requirements mandated by Congress; and
- Requires training and evaluation in a flight simulation training device (FSTD).
On the subject of flight simulation training devices, let me address some questions we have received about our position on ICAO Document 9625 (Manual for Criteria for the Qualification of Flight Simulation Training Devices). We appreciate the ground-breaking work that ICAO and the Royal Aeronautical Society have done in developing this document, and we support the principles and standards it contains. We share the view that those principles and standards will lead to significant improvement in simulator training worldwide, and the FAA is working to adopt them.
The timeframe for adoption is the challenge. The magnitude of the changes recommended in 9625 is significant, and many will require rulemaking. And, as you probably know, the FAA’s rulemaking resources and priorities are currently driven by the requirements Congress mandated last year in the Airline Safety and FAA Extension Act of 2010.
But we are committed not only to looking at adoption of the principles and standards in 9625, but also to all manner of new technologies and new methodologies for improved flight crew training. I am especially encouraged by the proliferation of simulators and flight training devices – including appropriate use of less-costly non-motion devices – for sophisticated scenario-based training and checking. As I remember very well from my days as an airline pilot, there is no limit on the benefits from using simulation technology to experience, and train, for events that we could never safely perform in the aircraft.
I already mentioned the airline safety bill that was enacted last year, which was intended to address issues identified in the 2009 Colgan Air accident. Since a number of those requirements are directly related to flight crew training, let me offer a brief summary of our progress in implementing this legislation:
- Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers: We are just beginning to review comments to our most recent proposal.
- Flight Duty and Rest: We issued a proposed rule last year, and are working diligently to publish the final rule. It is currently in the federal government’s executive review process.
- Training Hours Requirement Review: The Aviation Rulemaking Committee presented its final report and recommendations to the FAA on May 23. Many of its recommendations are addressed in existing projects.
- Stick Pusher and Adverse Weather Event Training: We received the Aviation Rulemaking Committee’s final report and recommendations in July, and we are preparing the report due to Congress this November.
- First Officer Qualification and Upgrade of Airline Transport Pilot (ATP) Requirements: We are working to draft a Notice of Proposed Rulemaking based on recommendations from the Aviation Rulemaking Committee that we convened to address this topic.
In addition to the obvious safety reasons for improved flight crew training, the FAA recognizes the importance of keeping our flight crews up-to-date and ready to work in the context of changes arising from the Next Generation Air Transportation System. Through NextGen, we are undertaking the transformation of our entire aviation system –technology, leadership and our overall philosophy for safely moving aircraft. It’s one of the most important ways to improve safety and efficiency in a system vital to our global economy. We have a clear vision for where we will go in the next 15 years, and we are laying the foundation for that future today.
But for those who think NextGen is about the distant future, I want to stress that this technology is already taking us to the next level of safety and efficiency, and it is also helping us to make aviation more friendly to the environment. We see tangible examples of how the increasing use of Automatic Dependent Surveillance-Broadcast, or ADS-B, is paying off in terms of safety, efficiency, and situational awareness. Airlines are benefiting from the expanding number of performance-based navigation procedures for all phases of flight – departure, en route, and arrival. Communities are benefitting from decreased carbon emissions. In short, we are all reaping more benefits as we introduce new procedures and equipment. I am excited about the progress we are making with NextGen, and about our mutual efforts to ensure that aviation advances in a seamless and interoperable global environment.
Thank you again for inviting me today, and I look forward to seeing the many important ideas and recommendations that this conference will develop.