ATO Of The Future – Your Questions Answered

We ran out of time to respond to all of the participant questions during the webinar. But our panel have gone back and answered all those questions we did not get to.

Q1.      Aircraft and training equipment manufacturers provide the tools that are required for a successful and safe flight training. In light of the recent worldwide developments, what can aircraft and training equipment manufacturers contribute to help big and small ATOs to cope with a new reality post-Covid?

John:    I suggest referencing FSTD design to ICAO Doc 9625 (New FSTD Standards tied to training tasks), EASA training objectives, and new digital training technologies to augment the equipment.

Chris:    A review of aircraft data costs is needed to lower the price point of type-specific devices.

Q2.      What will be necessary concerning the regulatory frameworks to allow flight training to make a huge leap forward post-Covid (e.g. self-conducted, remotely supervised scenario-based training, etc.)?

John:    For ICAO or an ICAO Agency, to augment the ICAO Universal Safety Oversight Audit Programme (USOAP) with specific audits of relevant ATO-related SARPS implementation by Contracting States. With approximately 2,000+ ATOs, the task for ICAO to audit all ATOs through States is beyond available resources. Sometime back I was in touch with IATA over the idea of auditing some (about 40) top ATOs and provide IATA accreditation for passes. This would encourage others to secure accreditation and so on….  (similar to the IOSA launch process). But so far this has not been taken up by IATA.

Chris:    1. Embracing CBTA, instead of the current task-based training requirements for type training.2. Expanding the scope of FSTD ICAO DOC 9625 to include new training technologies such as VR/AR.3. Frame regulations around the use and protection of training data (including the use of simulator telemetry data).

Q3.      Are there any lessons already learned in this crisis, from the ATO side, that have direct lasting consequences concerning new requirements for the simulator and FTD training device manufacturers?

John:    Leasing FSTDs and funding business insurance may make sense in terms of managing risk of the unexpected more proactively. Widening the student base, similar to distribution risk, could also be a good strategy. In countries that have closed borders during C19, ATOs with a strong domestic customer base have carried on but some of those leaning on overseas students have closed.

Chris:    1. There have been some approvals in primary flight training organisations where the instruction on Advanced Training Devices (FAA) was provided by an instructor remote from the location of the trainee/training device. This mitigates against travel restrictions, distancing requirements and can be extended to training in FFS.

2. We have seen initial and recurrent simulator evaluations being conducted by authorities remotely - using teleconferencing tools.

Q4.      Is any organization tracking estimates for the number of US / Non-US Airline pilots who will be furloughed on October 1, 2020?

John:     https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/ and pilot career consultant Kit Darby ( https://kitdarby.com/)

Rick:    I have interviewed Kit Darby re US hiring, and will be posting the video over the next few days. I will also be interviewing the European Cockpit Association, which has posted this Redundancy Tracker – https://www.eurocockpit.be/news/redundancy-tracker-european-pilots-losing-their-jobs

Q5.      For John Bent – when talking about training costs @ $250K (Europe) per pilot – does this include all ab initio, or also through type training? Is the estimate direct training costs only? Or, also inclusive of living costs?

John:    My data was researched in 2018 and showed a number of UK and Europe programs with full TR but no accommodation at USD 200k. Since then there have been ad-hoc examples up to 250k. Even if you take away the TR cost the net cost is way above many other regions (60-130k e.g. in US, Canada, and Australia)

Q6.      Issue of delay of regulatory credit for new technologies, such as SATCE, VR and AI, is an issue that impedes innovation in training.

John:   SATCE was included in ICAO PANS TRG Doc 9868 since 2006. It's up to States to adopt.

Q7.      In view of this, where do you see the future of the traditional ATPL(A) versus the MPL?

John:   I believe that MPL was a victim of timing (2008 global recession) and cost of additional equipment required. This does not mean it was not the right solution for modern airline training. It would seem that many States are accepting hybrids now which layer MPL ingredients into the ATPL program.

Chris:   I see both continuing to co-exist.

Q8.      What size of a training management / admin team would you need for a meaningful training data analysis in a medium-size airline?

John:    I suggest a handful of dedicated specialist IT staff managed by an operational training SME; or outsource the analysis to a university (e.g. FAA - University of Texas for LOSA)

Chris:    With modern tools and the right skill set, I have seen this implemented by one data analyst working with training SME's. Increasingly, operators are outsourcing this. The value proposition in this outsourced model is economies of scale and, very importantly, access to benchmark data.

Q9.      Culture trumps tech any day. Have airlines in your experience been successfully using FOQA and SOQA data of individual pilots and drawn useful comparisons between the two?

Chris:    No, I am not aware of the use of SOQA and FOQA data at the level of the individual. However, we do help operators connect training and operations data to reveal correlations of interest, at the fleet, base and pilot experience levels.

Q10.    Regarding the available technologies, the term "remote simulator training" was mentioned. Could you please explain this concept?

John:    The use of advanced remote VR linked to simulation, eventually to permit more than one crew member to participate in a simulated flight from remote locations.

Chris:    There have been some approvals in primary flight training organisations where the instruction on Advanced Training Devices (FAA) was provided by an instructor remote from the location of the trainee/training device. This mitigates against travel restrictions, distancing requirements and can be extended to training in an FFS.

Q11.    Do you see this innovation coming from the likes of an established large ATO who have the money, or a start-up as the fundraising would be the latter challenge? Also, if regulators are not ready to change standards how and why would a radical ATO be successful?

John:    I see this innovation coming from all sectors of the ATO community. While large organisations may have the resources, small may be more agile and able to adjust more easily. New starts have the advantage of not needing to change existing processes and behaviours, applying a completely new template. On the regulatory issue please see my answer to Q21.

Chris:    In our industry we need to constantly progress regulation. As an ATO and device manufacturer, we seek to keep regulators worldwide informed of our R&D efforts in training technology and applied learning science. We recognise that innovation needs constant communication with operators and regulators to realise its potential.

Q12.    What are the reasons for the limited amount of data analysis being done?

John:    My experience in launching the Cathay Electronic Reporting and Analysis System (ERAS) in the late 90s was that the setting up of data collection was in itself a major task which provided the comfort of knowing the data was being collected. The analysis task was shelved and only started many years later, and now the airline has a most impressive digital crew training management system. From broader work in industry I learnt that this was not a unique example.

Chris:    Analysis assumes there are questions to be answered first. I believe that apart from carriers that have incorporated an AQP or ATQP, where data analysis is mandated, there is generally a lack of awareness on what the relevant questions are. For non-AQP/ATQP operators (and even for EBT operators), when we present our analysis of existing training data to an operator, it is the first time they have considered these questions as being of relevance. However, once we are past this – there is much discussion around providing further insights.

Q13.    Can we get new students? We have more than 100 Customers (ATOs and AOCs) with more than 9,000 active pilot students in 38 countries and right now activity level is high – more than 1,500 training flight registrations per day (existing students wanting to finish education) – but the biggest concern right now for most ATOs is how to get new students "on board". How will students be able to get loans for the education – will banks not 'back down'? Any thoughts on how to assist with loans for new students? Or – even better – how to get banks to understand that there is a 'window of opportunity'?

John:    A tough one to tackle and this needs a crystal ball to forecast recovery. My understanding is that there remain many passionate and motivated wannabe pilots out there, and for programs of 18 months to 4 years to start training now could lead to airline opportunities with the inevitable recovery surge. To get students on board, those ATOs that rebuild their programs under an AMC to utilise digital technologies will become more price competitive and move up the student-preferred ranking. On the student funding issue, more careful selection will reduce failures in training, and the application of a ‘failure fund’ (applying say a 3% loading on student fees to pay out students who fail in training) should reassure banks that the loan will be repaid.

Chris    We expect to publish our pilot (and training) demand forecast model in the next few months. One use of this report will be to highlight the opportunity to future pilots, lending institutions and operators.

Q14.    Has there been any data collected to show the benefits of CBTA from an ab initio stage into airline stage?

Chris:    I do not know of any study published that shows the benefits of CBTA. In the main, the benefits of a CBTA approach is to ensure a "mission ready" pilot. While a measure of mission readiness is likely to be a reduction in LIFUS/IOE, true effectiveness should be measured in an improvement in safety and efficiency - an opportunity for a Phd perhaps?

Q15.    When does IATA release the guidelines for CBTA for all training? End of this year or 2021?

John:    Suggest that you contact IATA.

Chris:    I have asked IATA, awaiting a reply.

Q16.    When is it better to use VR training? In an initial point or at any time?

Chris:    When to use VR is a design choice. Its use follows an ISD process and supports the learning objective(s). It can therefore be used anywhere it is appropriate.

Q18.    What can we do to help encourage regulators to allow and even encourage more EBT and CBT rather than classic "check the box" training still favoured by regulation (at least in the USA)?

John:    Ask regulators to adopt ICAO SARPS Docs 9868, 9625, 9995.

Chris:    Active participation in industry groups, education, involvement of pilot unions to allay fears, raising awareness through publications, conferences and webinars such as this one.

Q19.    Interesting presentation. Thanks for that. However, part of it is kind of mixing ATO training with Airline training. Needs and usable tools are different. In addition, I think we forget that so far the training as it has been done has produced a vast majority of very good pilots. An often-forgotten point is the selection process. No matter how good the training, it will not achieve the goal if the trainee does not have the required qualities.

John:    Your point about selection is a big and important one, I believe. Selection must be made more robust as the downstream customer airline costs of getting this wrong are so high. The balance is inclusion for all races and genders who have the basic aptitudes, knowing that the training must be more effective for all.

The other big point today is the instructor; same story – big change in selection and training is generally needed. In flight schools the use of fresh CPLs to instruct so as to gain hours and leave for new pastures does little for the student; limited instructor knowledge of what he or she is training for, and instructor motivation may be more hours-collection than effective training.

To your valid point that ab initio and airline training gear is different, the end game for many pilots is an airline. Excluding single-pilot feeder operations, a multi-crew training approach makes sense for all licensing targets. All of the other advanced requirements for airline training (CBTA, TEM, CRM, UPRT, EBT make good sense for ANY pilot training. The selective use of fixed-base FSTD VR part-task trainers for those NOT going directly to an airline, plus the FFS element for the type rating for those who are, seems to me to be the best way to go.

Q20.    How quickly can we expect regulation to adapt?

John:    Not too quickly, I regret to say.

Chris:    Both EASA and the FAA recognise the need to review regulation to take advantages of changes in technology. CAE participates in Working Groups with both these regulators to address these issues.

Q21.    As we all know with the prescriptive hours of training and experience requirements of traditional licenses, competence is not automatically assumed upon reaching these minimum requirements. Meeting these training and experience hour minimum requirements merely allows a pilot the opportunity to then be evaluated for competence. CBT and MPL removes almost all prescriptive hours and other prescriptive requirements; doesn’t having both prescriptive requirements and assessment of competence, not just one, make for a more robust training program that better ensures overall competence? Doesn’t having prescriptive requirements help avoid short cut compromises by training organizations to reduce their costs that negatively impact competence? Doesn’t having minimum hours of training and experience serve an essential part to ensure overall competence, that no matter how much effort is put into providing the best training and testing can ensure? It seems that the lack of prescriptive elements in CBT and MPL are inappropriate industrial aspects of these concepts.

John:    While Instructor training in CBTA is essential, I believe that the problem with any 'new process' is that it can be seen as the pendulum having swung to another extreme. Many facets of CBTA are not so different from what an effective instructor does now: training to proficiency as much as possible within the prescriptive boundaries. CBTA moves away from this by placing emphasis on training results (competency) instead of 'hours done', but there are still basic outer prescriptive limits, as is the case in MPL. The use of standardised observable behaviours to drive competencies, expressed as precise 'word pictures' removes much of the subjectivity from training assessment and can only be a good step forward, and ultimately testing is still required. So CBTA is not a revolution, rather a sensible training evolution, now widely practiced in other industries.

Chris:    Irrespective of whether the training program is task/hours based or competency based, effective oversight is necessary. The effectiveness of any training program is the product of sound design, quality instruction, courseware, devices and supporting infrastructure. The significant advantage of CBTA and MPL programs is that their design is not constrained by outdated requirements.

Q22.    For Capt. Ranganathan: How do you expect the ATO of the future, as you've described it, will adapt to new and upcoming aviation sectors such as urban air mobility? Will current training methods still apply or will something entirely new be required?

Chris:    We believe the application of CBTA principles in the design and delivery of training is best suited to aircraft that will be used in this area.

Q23     I manage training at an airline that operates older aircraft that do not enjoy state of the art training tools and simulators. What should my area of focus be to ensure the best possible pilot quality whilst ensuring value for money?

Chris:    I suggest a transition to an EBT recurrent training program will allow you:

1. to develop training that addresses the risks relevant to the generation of aircraft you fly,

2. to improve the quality of instruction by allowing your instructors and evaluators to focus on competency development, instead of just task outcomes.

Q24.    Beg to differ, but AQP has been collecting electronic training data for over 25 years.

John:    AQP has indeed been collecting data for very many years, I agree. But not sure what you are differing about; it is only the extent of successful analysis that I have questioned. Data collection has also been going on widely with the majors since the 90s, and in the case of LOSA a most impressive amount (22,000 flights plus). It is the appropriate analysis which has often been sluggish in implementation, and therefore the application of valid corrective action. One of the most impressive data analysis exercises after LOSA has in my opinion been the IATA Data Report for EBT: https://www.iata.org/contentassets/c0f61fc821dc4f62bb6441d7abedb076/data-report-for-evidence-basted-training-ed20one.pdf

Q25.    Why is there so much disparity between qualifying an FNPT II under EASA and an AATD under FAA? The EASA requirements seem onerous and costly compared to the FAA, and yet they do basically the same thing and serve the same purpose. This simply adds complexity and costs to training. It seems 9625/3 was an attempt to bring parity to FTD qualifications and training events, so why is it taking so long to adapt?

John:    I totally agree with your sentiment. After the most impressive RAES WG Doc 9265 development over decades, the failure of States to adopt this is sad. SMEs like Mark Dransfield will no doubt have far more up to date information on this subject.

Q26.    Many SE Asian countries are still following old JAA regulations, and yet those are now defunct. Since EASA is for the EU, what are the old JAA Members states to do when they aren’t part of the EU?

John:    JAA regulations adopted by NAAs are more advanced in the training space than many 30- to 40-year-old regs such as FARs copied from much earlier times. Many SE Asia States regulate ATOs which do now qualify to EASA standards. EASA does this for a number of States outside the EU, including I understand the US (Florida), ME / Indo-China, SE Asia / Oceania / Pacific Islands.

Q27.    Can you provide more detail on sources for ATC comm training on desktops?

John:    Yes, Advanced Simulation Technology Inc (ASTi) ( https://asti-usa.com/index.html) does with their SERA product and believe also that Quadrant ( http://www.quadrantgrp.com/) and others serve this space.

Rick:     Consider also Micro Nav ( https://www.micronav.co.uk/), NLR ( https://www.nlr.org/civil-aviation/ansps/air-traffic-management-simulation/), Adacel ( http://www.adacelsystems.com/MaxSimATC.html), and others.

Q28.    How soon do you expect the ATOs to offer digital training tools in operators’ training programs and how soon do you expect developing the world's regulators to accept such digital training tools as mandatory?

John:    Regulatory ‘mandating' is hard initially. I believe that the evolution of digital training tool capabilities from the gaming industry is now exponential and as there are significant savings to be made (USAF trials) that this will occur quite fast. Many regulators in developing countries are bound by the same challenges of updating aviation law (2-5 years?). But the Acceptable Means of Compliance (AMC) processes are usually available, subject to beta testing, under CAA oversight. Standards Documents subservient to the Act can also be used to regulate such changes.

Chris:    In addition, I believe the emphasis should in the first instance be on the content and quality of training programs, rather than the technology. The existing FFS is an excellent training tool – using the EBT framework to change training content and training instructors to focus on competency development through coaching and facilitation will bring great gains in training effectiveness.