FAA and EASA Reg Changes in the Wind

WATS Pilot Conference Session 3: Recovery & Resilience: Regulatory

WATS 2022 delegates had the unique opportunity to obtain insights on regulatory topics of interest impacting learning audiences throughout the aviation training enterprise.

Barbara Adams, Program Analyst, Training and FSTD Policy Development Section at the FAA, updated delegates on a key rulemaking project. The Pilot Professional Development Rule amends the requirements primarily applicable to air carriers conducting domestic, flag, and supplemental operations to enhance the professional development of pilots in those operations. This action requires air carriers to provide new-hire pilots with an opportunity to observe flight operations and become familiar with procedures before serving as a flightcrew member in operations; to revise the upgrade curriculum; and to provide leadership and command and mentoring training for all pilots in command. The rule is intended to mitigate incidents of unprofessional pilot behavior and reduce pilot errors that can lead to a catastrophic event. The compliance date for final requirements of this rule is April 27, 2023.

Adams displayed a slide of the new leadership of the “FAA Hierarchy” relevant to the training community. Three of the six leaders are identified as “Acting,” and she noted that “things seem to be changing almost by the minute,” as is the bane of a government agency, so stay tuned.

Dr. Kathy Abbott, Chief Scientific and Technical Advisor, Flight Deck Human Factors at FAA, told delegates that comments closed in March for the update of the Flight Path Management Advisory Circular. The document is the culmination of an effort to address the reality that the loss of control inflight (LOC-I) remains one of the leading causes of accidents. One of the factors that contributes to these accidents is a flightcrew's failure to manage the flight path of the aircraft.

The vulnerabilities of flightcrew automation management have been studied for more than two decades with major improvements in design, training, and operational use of onboard systems for flight path management. Despite these improvements, there are still vulnerabilities that should be addressed. Flight path management topics addressed in this AC include manual flight operations, managing automated systems, pilot monitoring, and energy management.

Dr. Abbott noted there is the potential for future circular revisions to address two current, unaddressed safety topics of FAA special interest: stabilized approach and go arounds. Of additional note, FAA is funding research on additional topics of safety and training interest. In one case, FAA is supporting a research project at the University of Central Florida on the effectiveness of electronic and distance learning, and augmented and virtual reality to better inform organization decision making,

In response to an audience question, she responded there is not a current initiative to address energy management for the new eVTOL (electric vertical takeoff and landing) aircraft types in development.

Capt. Phil Adrian, CEO at MPS, got delegates’ attention when he posted his presentation “FCS: The Task-to-Tool Approach” in terms of why should someone buy a Honda over a Ferrari. The career aviator issued an early disclaimer that this was not a “rant against full-flight simulators.” Rather, Adrian asserted early on that with some of the community still emerging from Covid lockdowns and other converging forces, training enterprises need more flexibility to obtain training credit by using other types of devices beyond expensive (Ferrari-class) FFSs but rather highly capable FTDs (the Honda option).

The executive further categorized this as a regulatory issue, with the use of Compliance-Based Training and Testing (tick-the-box) and the stringent restrictions placed by regulations worldwide stifling new and better training. In the current situation, where training to the old-fashioned paradigm is not possible, he emphasized, there is a need for change to assess pilot competency in other ways.

Help may be on the way, as EASA is drafting a Notice of Proposed Amendment to the FSTD (flight simulation training device) regulations and Parts FCL (Flight Crew Licenses), ORO (Organization Requirements for Air Operations), ORA (Organization Requirements for Aircrew) and ARA (Authority Requirements for Aircrew) – expressing type rating and recurrent training tasks in terms of 12 defined simulation features and 4 fidelity levels, the so-called FSTD Capability Signature (FCS). The implication of this being that rather than Tool-to-Task, industry can now identify the training task and objectives and match the FCS to identify the correct tool, so Task-to-Tool.

“Training costs must decrease. We must implement new technology to overcome existing cost limitations. As important, most of aircrew training can be completed in a Honda,’” the community leader said, and called on ICAO and other global regulatory agencies and all interested groups to work together to review the current training paradigm in professional aviation so the community can train better, cheaper and with a lower carbon footprint to ensure aviation training is a viable option for aspiring aviation professionals.

Capt. Jacques Drappier, EATS Conference Chair, was the session moderator. EATS 2022 will be held 8-9 November in Berlin.