As yet we have not seen the FAAs submission. It is reported as:-
“
The FAA's concerns turn on the theory that many pilots lost or never attained adequate manual flying skills because they have come to rely on increasingly complex automated systems designed largely to prevent pilot error in the first place, according to a paper outlining the FAA's recommendations.”
This is an unsubstantiated ‘theory ’. A theory should trigger research, but none has been referenced.
“
But technological reliance has left some pilots unprepared for emergencies …
When automation systems do not work as intended or do not work well in the operational situation, pilots without sufficient manual flight control experience and proper training may be reluctant or may not be adequately skilled to take control of the aircraft,"
The FAA fails to provide evidence of experience and training shortfall - thus ‘supposition’.
EASAs position:- “
Pilot training requirements are not meant to compensate for non-acceptable design on the compliance and safety standpoint.”
Whilst ICAO and member nations might note the FAAs concerns, the international industry must not resort to safety measures based on supposition.
What if the FAA’s theory is incorrect? more rules, unnecessary training, without safety improvement.
Research into loss of manual flying skills suggests that degraded cognitive skills, situation appreciation, is of greater concern,
There is scant evidence of difficulties arising from manual flight in normal operation, but there has been many problems in abnormal situations originated by technology failure. Thus safety focus should be on the origin of abnormal situations; avoid or simplify the systems and situations which pilots are required to understand - fix the machine not the man.
AF447 and 737 Max involved sensor / system malfunction. Airbus changed the sensor, improved the system,
and provided an independent back-up speed display; ‘belt and braces’.
Boeing / FAA, their pants down, promote unproven theory !
EASA’s position
https://www.easa.europa.eu/newsroom-...-clarification