Training and Simulation Regulatory Update

1
Training and Simulation Regulatory Update
One FAAers Hopeful, Optimistic View of the Future
2
First Whats Going On?
1. Part 60, Flight Simulation Training Device
Initial and Continuing Qualification and Use,
has been issued, then revised, and is now
effective.
2. The rewrite of Part 121, training, testing,
and checking (the Subparts N and O Rewrite) has
been issued as a Notice of Proposed Rule Making.
August 10, 2009
Comments from the public are encouraged up to May
12, 2009.
3. The rewrite of Part 135 has been temporarily
paused, but will continue again in the near
future.
4. The FAA is currently updating methodologies
involving Part 142 (Training Centers) and is one
of the top priorities of the Air Carrier Training
Branch in Washington.
5. The FAA has been a principle party to the
efforts of the RAeS to address the ICAO document
on evaluating Flight Simulators, Document 9625.
The first portion (addressing fixed wing issues)
was sent to ICAO last fall, and will likely be
seen any day now.
3
Up-front Acknowledgement
For several decades, the FAA has maintained a
policy that any time someone has what they
believe to be a better idea, we are willing to
listen and, if warranted, pursue data to confirm
or deny the viability of that better suggestion.
And this policy has not changed.
Now, having said this
The current requirements for Flight Simulation
Training Devices are embodied in the new Part
60 Flight Simulation Training Device Initial
and Continuing Qualification and Use
4
I think everyone here knows for whom I work
and this just may be one of those times.
5
FAA Hat
6
(No Transcript)
7
(No Transcript)
8
(No Transcript)
9
And tell you about my
Hopeful, Optimistic View of the Future .
( for whatever its worth )
10
My Hopeful, Optimistic View of the Future
1. A potential for an interlocking mosaic of
FAA regulations.
2. Take the best advantage of simulation,

the RAeS IWG task
analysis,
and an analysis of how
simulation and the analyzed tasks may fit into
that mosaic.
3. This would include
a. Certification of private, commercial, and
airline transport pilots
b. Instrument, class, and type ratings
c. What we should expect for helicopter pilot
training and checking and
d. Training programs (Initial, Upgrade,
Transition, Re-qualification, Recurrent, etc.)
for Part 121, Part 135, and Part 91 K
operators.
4. Perhaps the most important aspect is how I
believe YOU may be able to assist in getting this
project from the drawing board, through the board
rooms, and into the real environment in which we
operate aircraft.
11
What is it I am Talking About?
1. I believe, within the next 7 to 10 years, we
are going to see a significant departure of
qualified pilots from the cockpit due to
retirement.
2. I believe this retirement bubble will contain
20 35 percent of currently active pilots, and
most of the impact will be in the air
transportation industry.
What is the Reality?
3. Am I right ?
I dont know. My
crystal ball doesnt work any better than yours
does!
but, some here probably KNOW this answer.
4. Were going to make decisions some right
and some wrong.
5. The right decisions are no-brainers.
However, when theyre not right, they should be
the least impacting WRONG decision.
6. Do we prepare for a significant pilot shortage
and not need it?
Do we not prepare for a significant pilot
shortage and need it?
12
What is it I am Talking About?
1. Im talking about the logic of making a slight
modification to how we approach flight training,
testing, and checking by adjusting the standards
and the structure to be able to meet any
shortage, still meeting the demands we currently
see, and while harmonizing, to the extent
possible, with our counter parts around the
world.
2. I am talking about developing an organized
structure for the training of replacement pilots,
many of whom will likely have little or no
aviation experience. This alone will necessitate
that the training programs used be structured to
accommodate the shortcomings of the likely
candidates.
3. Currently, there are a number of aviation
training academies in operation in Florida,
Arizona, and California.

They specialize in
taking individuals with little or no flying
experience, and producing competent flight deck
crewmembers.
4. I believe this is precisely the reason behind,
and exactly the desire of, the ICAO developed
concept of Multi-Crew Pilot License or, MPL.
13
What IS Multi-crew Pilot License MPL ??
1. The MPL allows a pilot to exercise the
privileges of a co-pilot in commercial air
transportation on multi-crew airplanes. It
provides the aviation community with an
opportunity to train pilots directly for co-pilot
duties.
2. The license focuses on ab initio airline pilot
training.
3. MPL training and assessment will be
competency-based and involve a multi-crew
environment and threat and error management from
the onset.
4. The ICAO Standard for the MPL specifies
240 hours as the minimum number of actual and
simulated flight hours performing the functions
of the pilot flying and the pilot non-flying.
5. The Standard does not specify the breakdown
between actual and simulated flight hours and
allows part of the training curriculum that was
traditionally conducted on airplanes to be done
on FSTDs.
6. There is a requirement that the applicant meet
all the actual flying time for a private pilot
license plus additional actual flying time in
instrument, night flying and upset recovery.
14
What Should Govern What Pilots Must Be Able To Do?
1. Best Operating Practices?
2. Left to the individual Certificate Holder
(airline)?
3. Recent accident determinations?
4. Recent incident determinations?
Of Course, to some degree, all of these are
important, but
Pilots should be required to perform tasks that
are expected to be performed satisfactorily
during aircraft operations.
Pilots should be given the opportunity to learn
all they can about how their aircraft operates
within the flight envelope of the aircraft. This
includes reasonable exposure to normal, unusual
or abnormal, and pertinent emergency situations.
I believe that we should train pilots to fly the
aircraft We should not teach them to simply
pass the test.
15
If These TASKS Are Going to be Required
Where Should They Be Found?
1. Pilot training, testing, and checking tasks
should be required not merely recommended.
training
testing
checking
2. To do this correctly, required tasks must be
placed in the regulations.
3. The task descriptions should include a minimum
description of what constitutes each task and
what should be expected of the pilot to
satisfactorily complete each task.
4. Each task description should include what
constitutes acceptable performance for both
training and evaluation.
5. Each task should be defined as requiring
either training only or training followed by an
evaluation.
6. Each task that may be introduced or completed
in an FSTD at some defined level should be
clearly indicated.
16
What Do We Have At The Moment ?
Part 61 Certification Pilots, Flight
Instructors, and Ground Instructors.
Part 91 Subpart K Fractional Ownership
Operations.
Part 121 Operating Requirements Domestic,
Flag, and Supplemental Operations.
Part 135 Operating Requirements Commuter and
On Demand Operations and Rules Governing Persons
On-Board Such Aircraft.
Part 141 Pilot Schools.
Part 142 Training Centers.
17
What Do We Have At The Moment ?
1. Part 61, Part 121, and Part 141 have lists of
piloting tasks.
2. Part 61 and Part 141 list piloting tasks as in
the following
a. In-flight maneuvers
b. Instrument procedures or
c. Landings and approaches to landings.
3. Part 121 lists piloting tasks in somewhat more
detail, as in the following
Landings and Approaches to Landings
a. Normal Landing.
b. Approach to Landing or Go Around with
horizontal stabilizer out of trim.
c. Crosswind Landing.
18
What Do We Have At The Moment ?
4. We have a whole system of Practical Test
Standards (PTS)
a. Airline Transport Pilot.
b. Commercial Pilot.
c. Private Pilot.
d. Instrument Rating.
5. We have PTS for Airplanes and Helicopters
... for Lighter-than-air and Gliders
for Gyroplanes and Powered Parachutes.
However
where are these PTS located?
are they required, or merely suggested?

are they just for tests, or do they
discuss training?
or does it really matter?
19
How Do We Get From Here To There ?
Part 1
1. A good plan.
2. A willingness to implement the plan.
3. Hard work by a lot of people.
Part 2
1. A plan exists (Ill let you be the judge as
to how good).
2. A good share of the work has already been done
!
3. The RAeS International Working Group Effort.
a. 80 Delegates / 16 Countries / Numerous
Briefings.
b. Truly a world-wide program - that makes sense.
c. Based on a Piloting Task Analysis (over 200
tasks).
d. Considers FSTD use and identifies appropriate
Levels where appropriate.
20
The RAeS International Working Group Effort
21
The RAeS International Working Group Effort
22
What Should We Have?
1. The existing Practical Test Standards (PTS)
should be moved to Part 61 as QPS Appendices for
training and testing, and modified to include
more detail for each task.
Task Landing Transition Airline Transport
Pilot Large Airplane (a) Condition(s). All. (b)
Awareness criteria. (1) Decide to reject or
continue the landing. (2) Ensure an aircraft or
vehicle does not occupy the runway. (c) Action
criteria. (1) Transition to outside visual
references. (2) Determine that a landing is
assured. (3) Complete a smooth, positively
controlled transition from descent flight path to
touchdown. (i) Achieve and maintain the
longitudinal axis of the aircraft parallel with
the runway centerline and with the centerline
between the main landing gear. (ii) At the
flare initiation point, begin to increase the
pitch attitude to that necessary to achieve level
flight in the present circumstances with the MLG
between 3 and 12 feet above the surface. (iii)
As the aircraft slows, apply additional
backpressure to maintain the level flight
attitude, allowing the aircraft to continue a
shallow rate of descent and a shallow rate of
airspeed reduction. (iv) Reduce power to bring
the throttles to the idle position as the main
landing gear touch the runway between 500 and
3000 feet beyond the approach threshold, and
immediately fly the nose gear to the runway.
(v) As touchdown occurs, ensure that the
throttles are at idle and ensure that the
spoilers have deployed, if applicable. (vi)
Apply wheel brakes, select reverse thrust as
appropriate for the conditions, maintain
directional control with aerodynamic controls
throughout the landing roll, until the ground
speed allows directional control with rudder
pedal steering or nose wheel steering, as
appropriate.
23
What Should We Have?
1. The existing Practical Test Standards (PTS)
should be moved to Part 61 as QPS Appendices for
training and testing, and modified to include
more detail for each task.
2. Incorporate the structure of ICAO/MPL into
these newly constructed Practical Training and
Testing Standards (PTTS) appendices.
3. This would put training and testing standards
into the regulatory structure
and allow all regulation sections
(91K, 121, 135, 141, 142 ) to refer to a single
source for pilot training, testing, and checking
requirements one that already includes a level
of simulation acceptable for support of the
stated task.
4. QPS appendices would allow reasonably easy
revision to standards if (or when) such revision
becomes necessary.
24
What Should We Have?
5. Each task listed in these new Part 61
Appendices would reflect authorizations and
requirements based on the following
a. The type of training or pilot license
involved.
b. Whether or not the task is supported by
simulation
(1) If it is not the task would be accomplished
in the aircraft.
(2) If it is
(a) The Level of FSTD would be indicated.
(b) You would find whether or not the task is
limited to being introduced via training (T),
or if the task may be trained to proficiency
and/or checked (TP).
25
Why Do This, You May Ask
Right now the tasks we ask pilots to do are not
really required.
Right now the system we use does not clearly
describe what is expected of the pilot to
satisfactorily complete the check.
Right now the overall system we use does not
clearly describe what may be, and what may not
be, accomplished in an FSTD.
Right now because of the way our system is set
up, we wind up teaching what is going to be on
the test we dont necessarily focus on teaching
the pilot to fly the aircraft.
Right now where would you go to find out what
pilot training and testing is really required for
a specific certificate or qualification?
Right now because it takes so long to change the
rules, almost everything important is in ACs,
Memos, or other guidance.
26
Wouldnt It Be Better To
have a system that clearly outlined what each
pilot is required to do for both training and
testing?
have a system that clearly outlines what is
expected of the pilot in order to be judged
satisfactory?
have a system that clearly outlines what tasks
may be introduced, or perhaps completed, in an
FSTD?
teach the pilot to fly the aircraft, rather
than teach the pilot to pass the test?
have a system where ALL of the pilot training
and testing requirements were found in one place?
have a system where the pilot training and
testing requirements could be easily changed or
updated?
27
The Advantages That I See
The system Im describing would provide the
following
- Each pilot would be trained on the tasks
(all of the tasks) that have been determined to
be necessary for that particular level of
certificate or qualification.
- Each pilot would be tested on a set of tasks
to determine if the pilots knowledge and
proficiency is sufficient to perform at the level
of license or qualification sought.
- Simply stated this provides consistency and
clarity and if done correctly and completely
will become the basis for standardization where
ever this approach is used.
- And you can ask any regulator or airline
manager present today and hear for yourself
standardization is the very basic support for
safety and efficiency.
28
How I Believe YOU May Be Able to Assist
1. You need to determine if what Ive laid out
here is appropriate and worthwhile.
2. If it is neither Game Over.
3. If it is either Id like to hear what it is
that needs to be fixed.
4. If it is both (or if we fix whats wrong) you
need to know that the FAA is a responsive agency.
Remember my 2nd slide.
5. If warranted, you should call, write, or email
your local FAA Office to tell them your thoughts.
6. The FAA Officials in Washington need to know
the concerns, desires, and preferences of the
public and they, too, would benefit from a
call, a letter, or an email.
7. Please dont underestimate your individual,
professional, or corporate input.
29
How I Believe YOU May Be Able to Assist
1. You need to determine if what Ive laid out
here is appropriate and worthwhile.
2. If it is neither Game Over.
3. If it is either Id like to hear what it is
that needs to be fixed.
4. If it is both (or if we fix whats wrong) you
need to know that the FAA is a responsive agency.
Remember my 2nd slide.
5. If warranted, you should call, write, or email
your local FAA Office to tell them your thoughts.
6. The FAA Officials in Washington need to know
the concerns, desires, and preferences of the
public and they, too, would benefit from a
call, a letter, or an email.
7. Please dont underestimate your individual,
professional, or corporate input.
30
Summary
1. Re-examine the existing Practical Test
Standards (PTS) to ensure they include
appropriate tasks for at least the 15 training
levels and pilot licenses described.
2. Modify the existing Practical Test Standards
(PTS) to include the appropriate detail for each
task.
3. Incorporate the structure of ICAO/MPL into
these standards.
4. Move these standards to Part 61 as QPS
Appendices and change their title to Practical
Training and Testing Standards (PTTS).
5. Ensure the published PTTS provide
authorizations and requirements for simulation
and aircraft use, as appropriate, and whether the
task may be T or TP.
6. Ensure the published PTTS task descriptions
include specific parameters of acceptable
performance.
7. Ensure the published PTTS task descriptions
include specific parameters for repeat training
exposure, where applicable.
31
If I can
Provide any additional information
Supply any additional facts or materials
or
If you would merely care to discuss these ideas
further
Please let me know
Ed Cook
404-832-4701
edward.d.cook_at_faa.gov
I hope YOU share my Hopeful, Optimistic View of
the Future!