Originally Posted by Island Flyer
I understand where you're coming from with your reservations regarding AQP. I agree it is a new program for many air carriers and as such is under intense scrutiny from the Administrator. Thus far my experience with AQP is that it has given the flight operations department at my company increased ammunition to procure more funding for pilot training from the executives at the company (who are always looking at training as a way to save a buck). As a result the level of precision in training has increased drastically. It does take dedication and a real willingness of the training department to adhere to the qualification standards.
With AQP we are given the opportunity to assess each pilot on an individual scale and rate as to whether there is an ability to "train out" the unsatisfactory habits that have caused them to be unable to adequately perform the maneuver. The qualification standards in AQP, in my opinion, are spelled out in as much detail as the PTS we used under Appendix E and H.
You are certainly correct in your assessment that AQP takes careful oversight by professional pilots and the regulating bodies. It's a double edged sword in that when applied correctly and in the spirit of providing proper training it is superior, but it does leave a lot of ability for an operator to "cheat" and turn out underqualified pilots. If this does not come with more rigorous oversight from the Administrator it could be disastrous for the industry. This also requires skilled and responsible check airmen - of which I am lucky to have available.
I think we may have to agree to disagree on this. In understand AQP isn't infallible and I respect your opinion and the professional manner in which you've presented it. You've definitely given me some food for thought. I do believe AQP has, at least in our case, increased the standards by which pilots are trained and allows us to more accurately identify weak points in a pilot's skillset and train it to proficiency. If I begin to see our program evolve into weaker training standards I assure you I will come here and eat my piece of humble pie for all to see. Though one way or another we are all going to AQP - the N&O requirements forthcoming in 2014 (I Think) are just a watered down version of AQP that will be mandated for all operators.
First, thanks for your very kind comment. Second, the point I’m attempting to make is that all of what you’ve seen accomplished under AQP can be accomplished under the “traditional” training program applications. You say that “…qualification standards in AQP are spelled out in as much detail as the PTS we used under Appendix E and H” when actually, the regulatory language that allows training under AQP contains no specific criteria, per se. In fact, 14CFR part 121, subpart Y (“Advanced Qualification Program”), §121.903(b) states “Each certificate holder that obtains approval of an AQP under this subpart must comply with all the requirements of the AQP and this subpart instead of the corresponding provisions of parts 61, 63, 65, 121, or 135 of this chapter. However, each applicable requirement of parts 61, 63, 65, 121, or 135 of this chapter, including but not limited to practical test requirements, that is not specifically addressed in the AQP continues to apply to the certificate holder and to the individuals being trained and qualified by the certificate holder.” In other words, unless you have been granted a specific authorization under AQP to do something else, you will be required to “do business as usual” by complying with the same regulatory requirements that everyone else has to meet.
Of course, I agree with you that AQP is not infallible; just as any training program used by any part 121 operator is not infallible. But I do not agree that AQP has increased the standards by which pilots are trained. Indeed, the standards expected of pilots training for your airline may have increased, but unless the requirements used by your airline were not fully in compliance with the standards found in the existing rules, that increase you see is not due to a requirement of AQP. How do I know this? I know this because AQP includes no … none … zero … performance standards … for anyone, for any task. In fact, the material found on the FAA public Website that contains information about AQP clearly states the following:
“An AQP entails proficiency based qualification. That is, provided that 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. Terminal proficiency objectives (TPO's), together with associated performance standards, replace the FAA’s traditional event driven compliance requirements. 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 (meaning the AQP officials), 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.”(underline added for emphasis)
This blurb starts out by making a statement that I believe is intended to allay any potential concerns before they materialize … “don’t worry, AQP training is better because it is proficiency based.” Really? Do they think that traditional programs are NOT proficiency based? Ridiculous! So – what’s the big deal? AQP or not – everything is “proficiency based!”
The only things an AQP-approved training program actually authorizes are deviations from existing regulatory requirements. Each of the deviations authorized under AQP may be requested under a traditional training program – but, each would be subjected to the scrutiny of a wider range of persons within the FAA, and each such request may be subjected to public notice and comment – which would allow competing airlines, and the public in general, to know and comment on each such request.
The only things an AQP-approved training program requires that are not required under a “traditional” training program are the following:
1) The training program must be constructed using an Instructional Systems Design concept (specified in an Advisory Circular published by the AQP office);
2) Specific data must be collected (that, once collected and examined, may indicate that a particular task, individual, or group of individuals might benefit from additional or remedial training or a change in a specific aspect of a particular training segment) and;
3) “…approved training on and evaluation of skills and proficiency of each person … to use his or her resource management skills and his or her technical (piloting or other) skills [must be accomplished] in an actual or simulated operations scenario” … quote from §121.917(b).
None of the requirements made by AQP are disallowed in a traditional training program and none would require anything beyond presentation of such additions to the Training Program Approval Authority (the Feds call this the “TPAA”), a review by that person (including whomever that person may choose to involve), and an approval by that person.
Additionally, I agree that, as you say, “…AQP takes careful oversight by professional pilots and the regulating bodies…” In fact, I would say that the same “careful oversight by professional pilots and the regulating bodies” is appropriate for ALL airline training and evaluation practices.
I am also familiar with Training modifications which you reference (i.e., the N&O requirements forthcoming in 2014) – at least as much as one can be by reading the Notices published in the Federal Register. Because there are virtually “no” performance standards under AQP, it is difficult for me to judge these proposed standards against any AQP training program because, first, AQP training programs are held as “proprietary” to that airline (and rightfully so, for the most part), but without something to compare … a comparison attempt would have to be considered “DOT” instead of “DOA” that is … instead of “dead-on-arrival”, it would be “dead-on-thought.” In fact, that everyone using AQP has differing standards (some actually describe it as “widely differing standards”) of performance for their crews is one of the concerns I have for adopting AQP … and, it also allows each airline to have differing standards within the airline, but different from fleet to fleet.
The Federal Register notifications for this pending rule change contained what the Feds called a “Technical Report,” where they described the specific tasks that would be “different” for an “AQP-carrier” from what a “non-AQP carrier” would have if the proposed rules were to be adopted as written. There were 6 AQP-airlines in the comparison (all de-identified). The stunning issue was that for “recurrent” training and testing, for each of those 6 AQP airlines the FAA recognized “differences” in how tasks the AQP-airline would have to perform from how the tasks non-AQP airlines would have to perform that approached 100% of the tasks! Said differently, almost 100% of the tasks referenced in the proposed rules were either “not addressed” or were addressed “differently” by each of the AQP airlines. According to the Report, “different” could mean either the task was different, was authorized to be ignored or substituted completely by another task (i.e., performing "windshear" recoveries instead of approach-to-stall recoveries! What's up with that?!?), or the way the task was to be performed by the AQP airline was different than what the nonAQP airline would be required to do – but, interestingly enough, not one of the tasks referenced was described – at all – the way the AQP airline would be required to perform it. To me, this report was a VERY enlightening revelation, and it is THE issue that got me to looking more closely at what an AQP authorization really meant.
The next thing I’ll likely hear from someone on this forum is that I spend a lot of words and a lot of time making my points. Guilty; and proudly so. I do this because if I’m going to be in this industry for as long as I hope to be, I surely want ALL of us to be guaranteed, as much as possible, that we ALL get the training that we need and that ALL of us meet exactly the same minimum requirements for competency and safety! Gaining deviations, substituting one task for another task, and allowing the adjustment of standards for the performance of piloting tasks on an airline by airline basis doesn't seem to me to be the way to achieve what I think are the necessary requirements to achieve what I would hope we all would like to have!
Last edited by BTDTB4; 29th Mar 2012 at 19:05.