FAA seeks to raise Airline Pilot Standards

[BTDTB4]

Originally Posted by Island-Flyer

No, my opinion is not that our current standards just "train to the test", obviously some airlines are better at training than others, however I do know that some air carriers take advantage of the ability to "train to the test.

Originally Posted by Island-Flyer

I can list a dozen air carriers using the standard system for checking that do an excellent job, and I can think of several that do not. It's not that the current system is bad, but it lacks standardization in the quality of training - leaving a lot of the responsibility on the air carrier. Some airlines do well with it like Expressjet, Horizon, and Skywest....while others train to the test and pump out undertrained pilots to save a buck. The fact is that AQP and N&O eliminates the ability of the airlines that look at training as a cost rather than an investment in safety to minimize training.

If you are saying that an overhaul of the training regulations would be appropriate … I’ll not argue with that premise. There should be NO airline, anywhere, that, as you say, “pumps out undertrained pilots to save a buck.” That may be a problem with the regulations – it may be a problem with regulatory oversight – it may be a problem with ethics of the airline management or training department. In any case, I am of the opinion that adoption of an AQP process – given all of what can be done under the auspices of AQP – provides far too many opportunities to at least compromise, or more likely, lose, the kind of airline training system that should exist in this, or any other, country.

Originally Posted by Island-Flyer

While I agree with you that training of situational evaluation and practical technical skills as a pilot are critical, I disagree in your assessment that AQP neglects the technical flying skills.

I didn’t say that AQP neglects the technical flying skills … I said that AQP allows the neglect of technical flying skills; and, of course, any training program is wholly dependent on the credibility of those actually doing the job. Perhaps it can be better understood by reading their own words: “provided pilots are trained to a standard of proficiency on all objectives within an approved AQP curriculum, it is not necessary to verify proficiency by virtue of a formal proficiency check on every such item. Rather, the proficiency evaluation may consist of a sample of such items, in order to validate that the training to proficiency strategy has in fact achieved its objectives.” The obvious question arises … if a given task is trained and the proficiency of the pilot in accomplishing that task is not checked because that task has been presumed to have been trained to a defined level of proficiency – why is it that we have to endure a proficiency check for any task? Certainly, we all train with the objective of getting proficient. The instructor wouldn’t recommend us for a check unless he/she was convinced that we each would pass that check. Why don’t we simply stop at that point? Why conduct a check at all? Both you and I could probably develop a logical set of reasons why a check is really not worth the effort and the time that it takes. Don’t you agree?

Another quote from the AQP gurus … “the applicant may elect to categorize certain terminal proficiency objectives as currency items. Currency items refer to flight activities on which proficiency is maintained by virtue of frequent exercise during routine operations. Such items do not need to be addressed for training or proficiency evaluation purposes in periodic training sessions.” Seems simple enough … proficiency is maintained by virtue of frequent exercise during routine operations. Hmm. Why couldn’t we just list all the tasks that are frequently exercised during routine operations and eliminate those tasks from ever having to be revisited during training or proficiency checks again? It surely would cut down on the time requirements and therefore the cost … right?

Need more? How about this quote …“Each air carrier applicant, rather than the FAA, develops its own TPO's on the basis of an instructional systems development (ISD) process outlined in Advisory Circular 120-54, Advanced Qualification Program. Once approved by the FAA, these TPO's become regulatory requirements for the individual carrier. An AQP provides an approved means for the carrier to propose TPO additions, deletions, or changes as needed to maintain a high degree of aircrew proficiency tailored to the operator's line requirements.” In case you were wondering, the term “TPO” stands for “terminal proficiency objective” – the objective of the training. Re-read the quote. The carrier sets its own TPOs that become “regulatory requirements” for that operator, and then that operator is provided a means to add, delete, or change those TPOs, as they deem necessary, based on their own evaluation of their own airline’s “operational requirements.” Each airline is setting and modifying their own regulatory requirements? Wow, that sounds like a real stringent set of rules … right?

Originally Posted by Island-Flyer

Pilots will make their judgment and the instructors/check airmen will have the ability to evolve the situation and "force" a pilot to perform functions critical to the safe operation of an aircraft (such as a single engine missed approach). Additionally through careful monitoring of pilot deficiencies AQP allows for the training and checking of known weaknesses in a pilot's skill.

Isn’t that precisely what the “traditional” training and checking provides as well? Pilots will always have an opinion (of course). Instructors and check airmen will always have the ability to “force” a pilot to perform functions critical to the safe operation of an airplane … if they are motivated to do so. What if the company asks them not to? Or what if the check airmen get together to allow their “buds” to skate, and maybe “force” all the “nerds” just a bit more? When and on what do you “force” and when and on what do you relax? Apparently, if there are enough complaints about something, there is the ability to legally change the standards. I was always under the impression that one of the reasons for having a set of training and evaluation standards for the tasks required was to ensure that everyone had to meet the same requirements – sort of a “leveling of the playing field” … and when everyone pretty much does their own thing … how is that possible any longer?

Originally Posted by Island-Flyer

I know for a fact that repetitive mudane line operations can be bypassed during AQP training.

Just as ”mudane line operations” can be bypassed during “traditional” training. An AQP approval isn’t necessary for this.

Originally Posted by Island-Flyer

That is one of twenty-four situations the pilot will encounter during initial new hire training. The check airmen and instructors will be able to draw on over 300 scenarios for training and evaluation. When training is complete all maneuvers that are listed in the PTS will have been accomplished, but put in a real-world context with difficult decisions and pressures. If the pilot lacks either the judgment, CRM, or technical flying skills on this evaluation, those deficiencies will be specifically trained until the pilot consistently demonstrates proficiency.

Two comments, here.
First – the number of scenarios available for training is impressive … but is this not available under the “traditional” training approach? There are some AQP supporters that describe an AQP program as a “proficiency based program,” as if a training program conducted under the “traditional” approach is not proficiency based, but instead, would be completed after spending the requisite number of hours “in training.” You and I both know that is poppycock – of the first order.
Second – if the training received is based on the PTS (the Practical Test Standards) how is that any different from “training to the test?” Are the other training programs out there devoid of some of those tasks? Do you know of any airline that incorporates a line scenario or a line-like approach to training? Let me help with the answers here … No! and Yes! Quite a few. Hmm. If this is true (and it is, I assure you) why is AQP necessary in the first place.

Originally Posted by Island-Flyer

Our qualification standards (as I believe is the case with most AQP operators) do not allow for a crew to show non-proficiency in any area without that area being trained to proficiency. So in other words no matter how amazing their CRM, a pilot won't pass until they can perform a satisfactory missed approach as well.

I would think this would be one of the standards everyone should meet. I would expect the same thing from ALL airlines. There are no "non-AQP" operators who allow someone to demonstrate a lack of proficiency – again regardless of how amazing their CRM – without having to be re-trained and then demonstrate an acceptable level of proficiency. Should any airline - AQP or Traditional - find themselves in a position of having a pilot - regardless of how amazing their CRM - who is not proficient - collectively or specifically, that airline should keep that person off the line until he/she is retrained and can demonstrate a satisfactory level of proficiency - collectively - including each of the specifics.