The FAA's AC on Flight Path Management is a 'mess'.
It attempts to address issues which are poorly explained, and for which there may be no unique solution; particularly not training. Training has served us well, a high level of safety, but not a universal solution.
The origin of the 'safety' data is questionable (pre 1996); dated and subjective HF interpretations from accident investigation, categorised by error, blame and train; old views of safety with reducing relevance to the modern world.
Flight path specific data, if any, is not presented or discussed in context, nor related to the new generations of aircraft and operational situations, in a very safe industry.
The 1996 report focussed on technical interfaces, where revised design requirements still refer to human error, and the assumed ability of crews to alleviate design issues (25.1302) in older aircraft.
The updated review 2013 does not refer to modern aircraft and operations. There is little or no substantive data, lacking explanatory understanding or justification beyond blame the human, i.e. human error, more training.
There are no comparisons with recent safety trends - flatlining since 2020 - (which suggest that the excellent safety record may be as good as it gets), new technology, focussed learning, and compatible operations.
Reading the AC from a European, UK English, viewpoint, and considering that meaning stems from communication, the wording poses many problems.
The AC "… provides guidance and recommended practices to operators … in developing operational policies, procedures, and training to support effective flightpath management (FPM)."
Words are increasingly subjective, meaning is formed according to local context - it means whatever the reader wants it to mean.
'Effective' may only be judged after the fact, by lack of incidents, or with incidents, ineffectiveness is used as an alternative for error, blame; without reasoned explanation or justification.
No human related intervention can be 'Assured', only judged relative to viewpoint; who's view, who judges - the regulator against the non existent 'how to' achieve the ill-defined objectives in this AC.
The FAA devolves responsibility to the operator, to the pilots; 'To be fully aware, capable, proficient'; … if not … blame, train, constrain.
Regulators must 'stand up', take responsibility, at least for explanation and practical guidance relative to the problem issues (beyond explanation by outcome).
… and the crux with this approach to safety is in para 2.2.1
"Operational policy and procedures for FPM should be based on guiding principles that state the general philosophy or overarching concepts and expectations for FPM."
An expectation of the safety of flight path management - the pilots day job - based on principles, philosophy and concepts, and expectations, assumes too much.
The AC creates conflict, '… procedures for the execution of most maneuvers, contain highly scripted actions and callouts. Training for these maneuvers should ensure that pilots are not taught to focus on the procedural details at the expense of the “big picture,” which is that FPM is the highest priority aspect of every maneuver. Standardized procedures are important, but procedures should be taught in such a way that the overall context of FPM is clearly conveyed to the trainee.'
So follow the SOP, except where the context has to be interpreted otherwise. Double Bind, catch 22.
… and cross checked with monitoring, the least effective human ability.
The preceding Flight Operational views (Air Carrier Training Aviation Rulemaking Committee) make similar assumptions;
"17-8(a): Operators should provide flight crews with recommended strategies on the use of automated systems in normal, rare normal and non-normal operations. Training these strategies should be scenario-based and operationally relevant." But what is relevant, who's view.
There are others, and a glimmer of hope from ACT ARC Recommendation 19-4 Energy Management which considers the wider problem issue; unfortunately encapsulating the complexity of the issue by reverting to definitions - illustrating the difficulties in understand the issue, thence understanding is inferred by definition.
Where next?
The regulator could start with the ICAO guidance for HF in regulation; a revised view of safety, Safety-II, Resilience.
Relinquish expectations that humans will conform to Work as Imagined in regulation, advice, or guidance.
Seek real-world line-orientated knowledge of the problem, an understanding of Work as Done; beware of the limits in industry sponsored operator or national reports which often suffer bias as above.
Accept the uncertainty in modern operations; outmanoeuvre it opposed to control it.
It is difficult to change the human condition, easier to change working conditions, particularly if aligning recommend practice, regulations, etc, with the realities of operation, aircraft systems, operational scenarios, and human performance - the day job - work as done.
Present the evidence, discuss, relate; is there a problem, or just a perception lacking explanation; or is this a reactive initiative by controlling bureaucratic regulator, which risks adverse outcome due to lack of understanding?