I have read, with interest, IGh’s “Examplar for PEI” in which he has pointed out several areas where the FAA (specifically the, Flight Standards offices – the HQ in Washington, and one he referred to as the SW Region) and how those offices have either incompletely addressed the issue of “stabilized approaches,” or have, if I understand his meaning, differing opinions on what that means, or at least, how it is to be achieved. He also has indicated his belief that the US NTSB erred in their investigation of the AA2065 tail strike at Denver in 2006, citing the Chairman’s comment about the board agreeing that the AA’s definition of a stabilized approach not being in “compliance” with FAA Order 8400.10. I’m not sure how that should warrant a criticism of the NTSB, but that’s a discussion for a later time. IGh has also, and very correctly, pointed out that there was a problem in the management of some activities in the SW Region. Since that time, the FAA has apparently taken significant steps to correct the lack of oversight that had apparently existed, according to DFW area newspapers and according to non-attributable confirmations in Washington, by removing and replacing the top two position holders with personnel from other areas within the FAA.
Additionally, some of you may or may not be aware that the FAA Flight Standards HQ office has been engaged for quite a while in updating and modernizing the regulations under which most passengers in the US are carried. You would note that the material that IGh referenced are “orders” and “advisory circulars,” and, as any astute observer or participant in aviation within the US would immediately recognize, the only thing the FAA can enforce are regulations. All the rest of it – including “orders” and “advisory material,” of all types – are recommendations that, while the FAA may believe important, are not requirements that anyone must follow.
You should also know, that, because the US is a nation of laws, it is imperative that the laws that will ultimately govern what happens be subjected to the scrutiny of anyone who may have an interest. It is this process that has lengthened the time that the Flight Standards office has taken to complete this project. Obviously, when anyone attempts to write a “regulation” or a “rule” that is to be followed by everyone, the task of the rule writer becomes more than a bit challenging … as this industry has long ago departed from the idea that a “one-size-fits-all” approach to something like this is not an easy thing to achieve. Also, the speed with which new technology is entering all facets our lives, it is a huge force making its way into the inner most workings of aviation. We are learning more each day about the way people learn to do things … we learn more about how simulation may be used to assist in that learning … we are able to determine, with much greater accuracy today, the root cause of incidents and accidents. And, because all of this is terribly important to the safe operation of aircraft, it is imperative that this material be taken into consideration when the rules and regulations governing the operation of aircraft are levied on those who make their livings in this industry. The rather archaic method in which the US regulatory functions have been mired was beginning to be seen as an “un-indicted co-conspirator,” so to speak, in obstructing efforts to have rules and regulations stay abreast of the situations currently existing in this fast-paced industry.
The FAA, to their credit, I believe, has opted to try a new approach to incorporating into their rules and regulations, a process that sets out requirements in a regulation (a regulation being enforceable) but in a manner that will allow that regulation to be modified rather quickly, when necessary (e.g., learning something new about how pilots learn, or learning something new about why certain accidents occur, or to keep pace with developing technology in simulation, etc.) – while still providing all of the “safe-guards” of having the general public have an opportunity to read and comment on the proposed rules prior to their going into effect. This new approach has been successfully employed in a recent rule on the evaluation of simulators, and, I understand, will be employed in the new rules governing cockpit crewmember training. As a part of that new approach, there is considerable undercurrent in the industry about what it says and what it doesn’t say … but one of the things that it will allegedly contain is a bit more specificity for a “stabilized approach.”
I have learned from someone who claims to know a lot (and has always been relatively accurate in his comments) that the material on stabilized approaches will look like the following:
A pilot flying a stabilized approach must …
1. Have the aircraft in the desired configuration for landing with the engines spooled and stable.
2. Maintain a constant pitch attitude.
3. Maintain a constant heading (within ±10°) or maintain electronic navigation indication with no more than one-quarter scale deviation vertically and laterally
4. Maintain a constant airspeed within +5 and -0 knots.
5. Maintain a constant rate of descent (not to exceed 2,000 fpm below 2,000 ft AGL or 1,000 fpm below 1,000 ft AGL).
6. Keep the aircraft trimmed.
7. Maintain altitude at MDA, when reached within +50 to -0 ft.
8. For constant angle non-XLS approaches (where “XLS” means either ILS or MLS), execute a missed approach when reaching the MDA, DA, or DH (as appropriate – and that is purportedly to mean, if the runway is not in sight or cannot be reached safely).
9. Except where the required visual references for the runway are distinctly visible and identifiable, going below the MDA, DA, or DH prior to the initiation of the missed approach procedure, is unsatisfactory performance.
To maintain my own reputation (such as it is anyway) I can’t guarantee that the above is an accurate listing of what the FAA is proposing, but it does offer an interesting series of steps which we all could, and probably should, contemplate.