Federal Aviation Administration

1. Federal Aviation Administration Training and Simulation Regulatory Update One FAAer’s Hopeful, Optimistic View of the Future

2. First … What’s 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… But there are times, when it is better to speak as an individual… …and this just may be one of those times. So, if you don’t mind, I’m going to Take Off my FAA hat …

5. FAA Hat

9. And tell you about my Hopeful, Optimistic View of the Future …. ( for whatever it’s 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 don’t know. My crystal ball doesn’t work any better than yours does! …but, some here probably KNOW this answer. 4. We’re going to make decisions – some right … and some wrong. 5. The right decisions are “no-brainers.” However, when they’re 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. I’m 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? testing checking training 1. Pilot training, testing, and checking tasks should be required; not merely “recommended.” 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 … (I’ll 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 don’t 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 AC’s, Memos, or other guidance.

26. Wouldn’t 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 whattasks may be introduced, or perhaps completed, in an FSTD? … teach the pilot to flytheaircraft, 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 easilychangedorupdated?

27. The Advantages That I See … The system I’m 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 pilot’s 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 I’ve laid out here is appropriate and worthwhile. 2. If it is neither … Game Over. 3. If it is either … I’d like to hear what it is that needs to be fixed. 4. If it is both (or if we fix what’s 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 don’t underestimate your individual, professional, or corporate input.

29. How I Believe YOU May Be Able to Assist 1. You need to determine if what I’ve laid out here is appropriate and worthwhile. 2. If it is neither … Game Over. 3. If it is either … I’d like to hear what it is that needs to be fixed. 4. If it is both (or if we fix what’s 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 don’t 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@faa.gov I hope YOU share my Hopeful, Optimistic View of the Future!