Same Old, Same Old?

The slow and reactive regulatory paradigm has probably outlived its usefulness in terms of industry safety. Captain John Bent, FRAeS, argues that we need to establish new primary pilot training standards.

We have seen astonishing technological improvements in the air transport industry in just one century. Regulatory processes were always well intentioned. But the systems borrowed from past processes in other industries in the early days were slow, and not designed to keep pace with rapidly changing training needs of the air transport industry. A culture prevailed which focused on past requirements, and ‘due process’ which viewed change as risk before being proven otherwise.

Despite the active conversations among operational training managers about necessary changes and improvements, there was usually no effective process for the practitioners themselves to get this information to regulators. While they knew what must be done to improve primary pilot training, convincing their CFOs to release resources without pressure from the regulators was always difficult. The result was often a state of complacency where no real progress was made and continued reliance on outdated practices was the norm.

ICAO is limited in its ability to impose regulations down to State level – leading to infrequent and sluggish modifications to training regulation. Eventually it can take major accidents involving CFITs and Upsets – that result in devastating fatalities – before changes are made on the legislative front.

One reason for regulatory ‘lag’ has been the increasing influence of legal process over time, leading to multiple layers of scrutiny which take inordinate periods of time. While the culture that ‘change is the mother of all risks’ is a prudent, conservative approach to regulatory change in safety-critical industries, the aviation industry has changed at a pace which caused regulatory process to fail to fully respond in a timely manner to the needs of modern air transport industry, especially in the training arena. An example is best illustrated by the table describing the ICAO change process:

Unwittingly, in earlier years, aircraft manufacturers gave limited consideration in design to man-machine interfaces, and then offered inadequate initial training solutions to customer airlines. This issue has vastly improved for Gen 4 airliners.

Now, the Covid pandemic has impacted the airline industry like no other aviation crisis since WW2, and there has never been a greater need to improve the quality and supply of primary professional pilot training. The Covid pandemic has driven a sea-change in thinking and now provides only a short window for improvement.

With new technologies, more nimble and safe methods exist to achieve more appropriate rates of change.

10 Factors Influencing the Need for Change (since WW2)

Technology. Four generations of airliners have driven the need for new skills and competencies, CRM, monitoring, and manual skill replacement in the increasingly automated environment.

Network. Network growth and complexity have demanded improved competencies for interaction with supporting systems outside the flight deck, not the least of which is air traffic control, now a huge part of situational awareness. The MPL licence stipulates Simulated ATC Environment (SATCE) in the syllabus.

Generational changes in learning styles demanded compatible new training approaches to training transfer, including VR, AI, and SATCE, especially in the acquisition and retention of theory. Many of these are now mature.

Flight Instructors. For primary training ATOs, flight instructors are traditionally sourced from freshly graduated commercial pilots looking to build flight hours to then move to the airline industry. This model has always restricted the relevance and quality of training given in primary ATOs, as the flight instructors are often neither airline literate nor motivated to deliver quality instruction. Many responses to this challenge have been tried, but in times of rapid growth, instructors are hard to find. The MPL prescribes improved instructor selection and training.

Student Selection. For commercial aviation, more robust selection standards reduce failures downstream in training and career and minimise the insertion of latent pathogens into the airline system. The first step is at the point of selection. The MPL prescribes improved student selection.

Unconscious Discrimination. A look at the demographics of the professional pilot population around the world still shows domination by white males. Restrictive approaches to pilot selection need to be completely replaced by zero discrimination on eligibility standards, allowing all to see piloting as a possible career. As many have identified before, this will unlock a vast pool of young people and go a long way to solving pilot shortages.

Airline demands are usually for improved primary training relevance and efficiency compatible with contemporary operations, but this is not so easy to deliver.

Student saturation as more ‘modules’ are added to legacy programs by regulators. The prescriptive training ‘module’ does not embed knowledge skills and attitudes well but is a convenient tool for regulation.

Self-Funding. Many airlines offloaded training costs to those seeking a piloting career. These costs are significant (USD 150,000 +) to be repaid to private lenders or to airline financing through salary deduction. This has the effect of limiting career interest and the size of the potential pool of career pilots. Today, advanced training technologies have the potential to significantly reduce training costs, and airlines may have to reconsider outsourcing and requirements for student self-funding, to keep their airliners in the air as they find themselves on the wrong side of the demand/supply equation.

Continuous improvement. Lack of programs designed for continuous improvement and adaptation, supported by increasingly sophisticated learning management systems.

The Ingredients for a New-Generation Primary Training Model

When making a cake, first make sure you have all the ingredients. For a new primary training model, most of the ingredients exist and are defined in Annex 1, PANS-TRG ICAO Doc 9868. IATA has also developed guidance documents on how to cook the training cake, including Guidance Material and Best Practices for MPL Implementation (July 2015).

Many existing syllabi already include most regulated ingredients, but some items such as Simulated ATC Environment training (SATCE) are missing from primary training programmes. This despite new graduates entering a sky populated by other aircraft and controlled by ATC. Their practical understanding and exposure to ATC situational awareness should start on day one of training, not day one of commercial flying. SATCE systems are now mature and can be installed on classroom PCs, also supporting the development of Aviation English.

More Robust Student Selection. The first of the two prime ingredients, leveraging published ICAO competencies and observable behaviours required for an airline career and aimed at reduced failures and cost downstream.

Improved Instructor Selection and Training; The second of two prime ingredients. Select instructors for passion to instruct and thoroughly train contemporary instructional techniques, CBTA, the requirements of MPL, instrument flying, and airline operations.

Improved Instructor Retention, without which continuity is lost, and student learning suffers. Improvements include:

• More attractive remuneration,

• Progression opportunities to support interest in long-term instructional careers,

• An airline seniority number,

• An airline career plan which includes short-period instructor secondments back to the ATO to help complete the cycle of relevance.

MPL as the foundation syllabus framework, enhanced, updated, and continuously embedded with:

• A high proportion of syllabus in a student multi-crew setting (FSTD)

• Competency-based training and assessment (CBTA)

• Threat and error management (TEM)

• Evidence-based training (EBT) using actual accident scenario examples, a powerful learning tool.

Training tools tailored to training task:

• Training aircraft, ideally all twin, with airline-style cockpits (seating four); modern instrumentation, and ceiling-fitted video to record key exercises and enable rapid debriefs. Also, access to an SE UPRT training aircraft.

• Flight Simulator Training Devices (FSTD), including Mixed/Virtual Reality. The FSTD suite is the dominant training medium for the best multi-crew learning environment throughout the program. The training aircraft representative FSTD fitted with video to record key exercises and enable rapid debrief.

• Simulated ATC Environment (SATCE) to ensure ATC situational awareness and deeply learnt ATC communications before flight in busy airspace. SATCE systems are also powerful aviation language tools.

• New and proven remote learning and ground school training platforms including VR, AI enhancements, to raise the impact of training and reduce time and cost.

• Advanced Learning Management System (LMS) to continuously monitor and adjust competency development and program relevance and quality. Enabled by issuing all students and instructors with a mobile tablet device which can be strapped to the upper leg as a single point of access to syllabus, schedule and changes, training modules, media, competencies gained, revision needed, for use anywhere, anytime.

Instructional Design Process for a New-Generation Primary Training Model

Rebuild or new build? Have you ever tried to re-make an already-baked cake? This is somewhat analogous to trying to upgrade an existing training program. A cake that was made a long time ago and was added too many times would not be so edible. Many of the ingredients of a cake baked long ago will be hard to change. To make a better cake:

1. Start afresh with the objective of assembling the above ingredients into a holistic programme aimed at optimal learning in terms of sequence and reinforcement, catering for differing learning rates (CBTA) where the student is king. Except for intros, dispense with prescriptive (add-on) modular training, replacing this with continuously embedded CBTA throughout the training day (sometimes referred to as the spiral process) as required for every professional pilot every day at work.

2. Understand the best process required for the fundamentals of effective training:

I hear and I forget.

I see and I remember.

I do and I understand.

3. Maintain student centric-focus open to student ‘discovery’ rather than on instructor delivery convenience.

Conclusion

This article has taken a brief, generalised, but critical look at existing primary pilot training, which inevitably carries the risk of being seen as tarring all ATOs with the same brush. But this is neither intended nor true, as out of the over 2,000 ATOs delivering professional pilots to the commercial air transport industry pre-pandemic, some were clearly delivering high standards of training… now augmented by a small number of new-entrant ATOs also dedicated to this objective. But the baby steps being taken at this time to meet primary training challenges are inadequate.

For many years before the pandemic, there were demands for improved primary pilot training in terms of variability and quality around the world. The limited corrective action taken to date has been massively damaged by the effects of the Covid pandemic and unless vigorously re-addressed presents a threat to future safety. The pandemic-induced challenge of reduced experience on flight decks around the world has few mitigants except improved training.

Pandemic impacts are being seen vividly in the US where airlines are short of thousands of pilots exacerbated by an already-scheduled surge of retirements. The pool of previously grounded pilots is drying up; recruitment from other airlines is in full swing, and some US airlines are paying USD 300k for B737 Captains. Although the cost impact of such salaries may be unsustainable, the global effects are already in play. Twelve US airlines are currently sourcing pilots from airlines in Australia, now suffering high turnover rates and shortages, back down through the supply chain. At the start of the pipeline, a decimated primary training industry is struggling to deliver to demand and quality. The pilots required by only the top four US airlines (from recent direct contact with each) are shown in this table:

At the time of writing, China has removed Covid pandemic restrictions which will add an additional huge demand for pilots already in short supply in that country.

New tools now exist to reduce training time and raise quality. But without proactive regulatory action the solution must come from the industry itself, via the establishment of a whole new primary training programme which embeds the variables described. Due to change resistance and re-tooling requirements within existing ATOs, legacy upgrades will generate unnecessary cost and are less likely to solve the current primary training dilemma than a clean greenfield solution.

As State regulators will only approve programmes under published ICAO Standards and Recommended Procedures (SARPS), an enhanced MPL programme is the foundational solution, containing most of the elements needed. Enhancements will take this programme beyond the standards delivered by the basic MPL, to produce graduates more suitably selected and trained for the air transport industry. By example, this would have the effect of creating a whole new standard of primary pilot training for the airlines, which would become scalable around the world.

But there can be only limited execution of the global solutions if there is little foresight and meaningful action at industry decision-making levels. Maintenance of the remarkable levels of air transport safety so far achieved cannot be guaranteed if regulators will not drive the urgent changes required.

From biplanes to supersonic jets, the air transport industry has seen remarkable technological advancement in just over a century. However, regulatory processes are often slow to catch up and tend towards stifling innovation with a 'risk before reward' attitude that prevents exploration of faster and more responsive strategies – like those enabled by modern technology. It's time for authorities across the world’s skies to recognize that agility can be part of safety when it comes to progress in aviation safety.

Note: This paper has described the rationale for ‘Project X’, which intends to demonstrate how the regulated ingredients of primary pilot training can be assembled into a more effective new-generation programme – to deliver better-qualified professional pilots to airlines at reduced time and cost. Project X intends to bring this new programme to industry as soon as possible. (Project ‘X’ | Halldale Group)

Looking Back at Training Development

A brief review of key milestones in aviation training history post-WW2:

1947  Commercial Pilot Licence (CPL) framework laid down by ICAO (Generation 1 airliners).

1982 Airline-focussed primary training. First proposal to ICAO (by Lufthansa Flight Training) for a new licence relevant to airlines was not adopted by the ICAO Air Navigation Council.

1980-now Skill loss. Increasing automation, to the extent manual handling experience for Ultra Long Haul Pilots reduced to as little as 3-5 hours per year in the aircraft.

1990-now Modules were added to the basic 1947 CPL framework for CRM, MCC, TEM, CFIT, UPRT, progressively crowding the syllabus with no commensurate additional time to learn. Educationally of questionable in value, ‘modules’ as prescriptive processes relied on the assumption that ‘module done = pilot competent’. Good for regulation but not for student retention.

1980s-90s Pilot training as non-core airline business. Most airlines outsource primary training as non-core business, like catering, forcing Approved Training Organisations (ATOs) to maximise student ‘churn’ for profitability, at the lowest regulatory requirement levels. Most primary training ATOs had:

o Instructors who only met basic instructor rating requirements with a primary motivation of building their hours for airline entry, not to instruct effectively. Improved instructor competence is stressed in the ICAO Multi Crew Pilot Licence (MPL) training requirements.

o As much as 90% instructor turnover per annum during airline demand cycles.

o Little or no resident airline experience, limiting the training objectives for airline operations to be understood and taught effectively.

The anomaly of safety. Airline mission statements espousing safety as their top priority seemed not to acknowledge the clear connection between training and safety when outsourcing primary training, with reduced control and oversight of their remote ATO suppliers.

Financially, ATOs had to survive the peaks and troughs of training demand, while airlines negotiated every year to hold down training costs, limiting ATO resources for self-improvement of their product, and requiring high student churn rates to maintain their businesses.

Selection. Airlines usually select their students, and the selection processes have been variable and non-regulated over the years. For non-airline customers, student selection could be scant, with prospective students looking for the lowest possible training fees, and ATOs accepting all the students and training fees they could secure, regardless of suitability. ATOs would drive students through their training programs however long this took, and this caused ATO costs to escalate.

The graduate. The combination of these factors inevitably led to many commercial pilot graduates meeting only the most rudimentary regulatory requirements to hold licences, who in some cases failed the airline entry process.

Military selection. The model of selection used in the air forces of the world is generally far more stringent, enabling a more efficient training process, and more competent pilots in subsequent military careers. This saves military training organisations the massive costs of failure downstream in training and career. The Multi-Crew Pilot Licence (MPL) stipulates improved selection.

2003-18  New Licence. An International ICAO working group developed the MPL; the first new professional pilot licence since 1947 dedicated to airline operations, published in Annex 1 SARP Doc 9868. Rollout has been very slow due to factors such as recession, the costs of re-tooling, and resistance to change. Pre-pandemic, only about 40 ATOs were conducting MPL training globally (out of 2,000+), none fully aligned with the intent of the published ICAO Doc 9868 (training); and ATOs were held back by demands from their State regulators to include legacy training elements in the syllabus.

2011  IPTC. Seeing the need for improved training, ICAO, FAA, RAeS, and IFALPA joined forces to form the International Pilot Training Consortium (later Association). Absorbed by RAeS in 2014, IPTA achieved increased global awareness of training issues, but few concrete changes to regulation.

2020-22 The Covid pandemic impact (the most severe shock in aviation history since WW2) has caused contraction of the global corps of ATOs delivering professional pilots to industry. Training development mostly stalled.

Pilot supply. The experienced pilot pool is drying up as airlines re-build operations, with the temptation for airlines to tolerate lower entry standards and apply delivery pressure on their suppliers to get airliners back in the air. Corner-cutting training regulation under post-pandemic pressures can combine into a bad mix for safety, as evidenced by increasing incidents.

As air travel demand continues to recover in 2022, the most recent forecast of Oliver Wyman now projects that demand for pilots will outstrip supply in most regions globally through 2024 and continue to worsen over the next decade.