Are We Sleepwalking?

A pandemic-driven sea-change has occurred, and there is no more room for old process. Commercial aviation is threatened by high rates of grounded pilot attrition and a huge loss of average experience on flight decks; pilot shortages due to this, plus reduced interest in piloting careers; and new generational learning and career expectations. The primary pilot training industry has been depleted by two years of poor or non-existent student enrolment levels. Captain John Bent urges rapid adaptation to these new threats as vital, but not evident at this time.

As the airline industry exits the Covid pandemic, is commercial aviation unwittingly sleepwalking into an escalating series of safety threats related to pilot supply and training?

The political consequences of the Covid pandemic have inflicted the most serious damage on the airline industry in its history. Many airlines are in short-term survival mode. Process improvements are hardly affordable at this time.

I and many others have been convinced for some time that primary pilot training has needed a root-and branch overhaul, a need now brought into sharp focus by the effects of the pandemic. Demands for training improvements are hardly new, proposed by training subject matter experts for many years.

The Future for Professional Pilots

Prior to the inevitable arrival of fully automated airliners and possible space-based transport systems, there will remain a substantial period of time during which professional pilots will still be needed on airliner flight decks – together with more relevant training standards. Without the standards, safety margins will be at risk. Of course, no one wants more accidents in this historically ultra-safe industry, and the big question is how will improvements be funded and executed?

The basic professional pilot training framework has remained largely unchanged since 1947, while technology has advanced exponentially, and at least four generations of pilots have each required new training methods to adapt to new learning styles.

Continuously adding band-aid, box-tick prescriptive training modules (tick = module done) to the old framework may satisfy a legal need for records but will not address the fundamentals of long-term competency acquisition. Powerful new training technologies now exist to holistically enhance the legacy framework which is no longer fit for purpose.

Despite the overall statistical safety of air transport, some examples of accidents where training had been executed to the requirements of existing State Regulations: AF447 (June 2009); JT904 (April 2013); AAR214 (Dec 2013); QZ8501 (Dec 2014); TN235 (Feb 2015). 414 people died in these accidents, which are by no means a comprehensive list of all that occurred in recent years.

Misguided training delivery in any training phase can become a contributing cause in an accident. One such example was the AA587 accident (A300B4) in 2001 where the recovered flight data recorder showed the loss of control after the fin departed the airframe causing the loss of 265 lives. [The NTSB report explained that the overuse of the rudder mechanism caused the plane's vertical stabilizer (tail fin) and both engines to detach from the plan, and that another possible contributing factor was a simulator routine intended to train pilots for recovery from upsets could instill the sense (from the simulator performance] that the real airplane would be unresponsive, and that swift and vigorous rudder action would be needed to arrest any incipient upset. During years before this accident I attended training symposiums in which this process was proposed by the airline concerned.

From my own experience, newly qualified cadets in Lockheed Tristar L1011 airline base training have shown an over-enthusiastic use of rudder in normal flight as an embedded but inappropriate skill for an airliner, most likely derived from primary training.

What is Needed

Instead of tinkering around the edges with add-on modules, a rebuild is required of both selection and primary (ab initio) training processes. Selection because many current selection systems, especially when under the high demands of growth, allow candidates to slip into the system without optimal qualities required for this career, possibly inserting latent pathogens into the system as unintended consequences. Many approved civil candidates would not get through the more stringent military selection processes. Primary training because the framework needs a total refresh, and not by additional modules ad hoc. We know that ‘first learnt lessons are longest lasting’, and if primary pilot training does not set and embed the right skills, reversion to first learnt can occur later in piloting careers.

Even in the early 1980s, Lufthansa Flight Training SMEs presented a training upgrade proposal to the International Civil Aviation Organisation (ICAO) to move away from 1947 prescriptive box-ticking methodology in training to competency-based processes.

But this concept was not accepted by ICAO until 25 years later in 2006 when the ICAO Air Navigation Council (ANC) published the updated Training Document 9868; mandating an entirely new airline-dedicated licence; the Multi-Crew Pilot Licence (MPL). This licence requires competency-based training, embedded Threat and Error Management (TEM); reduced emphasis on less-relevant light aircraft skill acquisition; increased emphasis on teamwork simulation in crew settings; and realistic simulation of the Air Traffic Control (ATC) environment (SATCE) - now available and mature. (See SATCE Closes the Fidelity Gap)

But by February 2020, 16 years after publication, only around 60 of the total of 193 ICAO Contracting States had formally adopted MPL into their regulation; only 53 MPL programmes were running amongst a total of over 2,000 professional pilot training schools around the world; and only 3,661 graduate MPL pilots were flying in a global population of around 250,000 commercial fixed-wing pilots in service. This is a poor indictment on the capabilities of the global regulatory system to genuinely meet the needs of industry in any useful timescale.

Consequence of Doing Nothing

The industry’s exceptional safety record can itself create complacency amongst decision makers.

‘More of the same’ legacy processes using band-aid fixes added to the training framework cannot deliver the deep, enduring competencies needed. A pilot on the line may encounter at any time the need to promptly apply learnt competencies for specific events such as potential upsets and Loss of Control (LOC). ‘One-time’ training modules do not encourage long-term retention of Knowledge Skills and Attitudes (KSAs). During the pandemic, the significant loss of piloting experience cannot be safely countered with legacy selection and training standards without heightened risk.

Assuming the accuracy of projections of a return to 2019 airline activity by 2023 or 24, there is still time to act to improve primary training during the downtime. Training programmes should demand competencies to be learnt and re-learnt as continuous reinforcement throughout training programmes, both initial and recurrent.

While many expert pilot training panels around the aviation world have for many years delivered proposals into the regulatory system, many have not been adopted. Those that are have sometimes arrived too late to stop further fatalities (CFIT and LOC), and execution at the primary training level has been sporadic around the world. In the cases of CFIT and LOC, the former was eventually mitigated with Enhanced Ground Proximity Warning System (EGPWS) technology, but revised procedures and emphasis in training could have been mandated immediately.

The process for establishing new Standards at the top ICAO level (see diagram below) takes an average of two years from the Preliminary Review by the ANC to the applicable date. This review is already a period after the proposal. In explanation, “although this process may seem lengthy at first glance, it provides for repeated consultation and extensive participation of States and international organisations in producing a consensus based on logic and experience”. But in cases such as CFIT and LOC, lives may have been lost while new regulations were being debated in the 2+-year process.

ICAO Process Timeline

Supported by the mantra “change is the mother of all risks”, a prudent conservative approach to regulatory change in this safety critical industry is required and well understood. But this mantra gets in the way of process speed, encouraging regulators to cling to existing practice.

The traditional legacy-driven process does not cut it in this rapidly changing industry, especially in the area of training key personnel. Mechanisms for rapid response have to be enhanced. Today, numerous new technologies and analytics exist to enable process time to be reduced to months rather than years.

Underlying any acceleration of process, the inexorable obstinacy ‘virus’ clings ruthlessly to the culture of comfortable past practice and should perhaps be eliminated and replaced by the ‘why not’ approach. To shield from unintended consequences, prudent checks and balances are still required, but must be more promptly and effectively applied.

If it is not the law, cash-strapped airlines will not generally fund training updates. Because airlines generally adhere to regulation as the justification for funding training budgets, the regulatory system has to execute change more appropriately. I believe that only ICAO, at the top of the airline regulatory system, can provide the impetus for the investment needed. ‘Short-termism’ thinking and lack of recognition of the threat must be overcome without delay.

After 9/11, a major aviation crisis with far less impact on the airline industry than the Covid pandemic, no one questioned the cost of implementing security initiatives. The cost of protecting future safety through improved training will be small by comparison. 'Where there's a will, there's the means'.

Suggested Ingredients for Improvement:

1. Process: A total revision of primary pilot primary training for airlines, using the MPL as the foundation with competency-based training in crew settings at the core.
2. Measurement: Continuous measurement of key elements of the process to enable genuine feedback into continuous programme improvement.
3. Delivery: Via improved selection and training of instructors.
4. Training Modules: Replaced by continuously embedded exposure of the subject matter to trainees, except for the initial introductory module.
5. Training Technologies - Simulation: FSTDs tailored to training task, as with the MPL, but utilising the increased technical capabilities of FSTDs.
6. Training Technologies – Virtual Reality: Artificial intelligence, including A/M/V/XR, careful embedded into the new framework to excite learning, and reduce time and cost.

But most pandemic-surviving airlines are severely financially impaired and, again, airline CFOs use regulatory requirements to establish budgetary bottom lines, leaving no excess resources to upgrade processes. Other funding sources may be necessary.

New Training Efficiencies are Ready

In 2022, business plans for new-generation primary training programmes are offering higher impact competency-based training processes. New training technologies are suggesting significant reductions in programme time (and cost) in the order of 20-30%. Later, green electric training aircraft will augment the process, offering large reductions in direct operating costs.

The urban mobility industry now in birth will require dedicated training for the estimated 60,000 UAM pilots who will be flying in coming years.

All of these factors will change the paradigm for investors who should see more investment opportunity in the pilot training industry if the necessary changes are made. (A solution is at hand – see  ‘Project X’).

To prove new programs, beta programs are essential under Acceptable Means of Compliance (AMC), closely monitored by a combined team of industry experts and regulators. Throughout the programme, student performance from the training management system will be compared with the control data from a legacy program.

The opportunity has arrived to work in parallel with regulators, to rethink the paradigms of training regulatory change, crafting a comprehensive new framework for professional pilot primary training, relevant to the modern aviation age – to provide for the safest possible operations during what could be the last phase of fully manned air-transport systems.

As most airlines have no available resources right now, aggressive ICAO action with States to sustain safety margins… significantly improved profitability of primary training programmes using new training technologies (20%+ Return on Investment)… plus the inevitable training demand surge ahead… should combine to interest astute investment from other parts of the aviation industry.

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