What are we trying to achieve?
I guess I shouldn’t be surprised at what the FAA continues to do. Sure ... setting a minimum time for the issuance of any given pilot certificate will ensure that the pilot has logged those hours. But, if there isn’t any indication of what had to have been going on during those hours – all you’ll be able to be sure of is that this pilot has logged those many hours ... and without some kind of airplane logbook verification ... you won’t even know if these are “real” flying hours, or Parker 51 time! Sure, if the requirement for a pilot certificate to fly in an airline cockpit goes from 250 hours (required for most commercial certificates) to 1500 hours (required for an airline transport pilot certificate) the applicant will have to have logged that additional 1250 hours. As anyone would recognize 1250 hours is 1250 hours ... a nice number ... but 1250 hours doing what? Personally, I believe that the answer to that question is at least as important as having those additional hours. I don’t know about the rest of the world, but I know that in the US, both the Air Force and the Navy have done a rather decent job of taking young men and women – many without any knowledge what-so-ever about airplanes – and after very slightly over a year, are able to produce reasonably competent pilots ... and to avoid all the fighter type/single seat issues – I’m looking strictly at the multi-engine airplanes that have multiple pilot crews – where these “brand-new pilots” wind up in the right seat. Are every one of them the new “ace of the base?” I doubt it. Do some of them have problems? I’m sure they do. But, far and away, the vast majority of these young men and women are well-trained and competent to serve as a “co-pilot” on these multi-pilot crews – and they do so with substantially less than 1500 hours!
My opinion is that this pending rule is certainly not going to provide the kinds of things that our fearless FAAers apparently believe it will provide. Additionally, with this exact same question about pending rules currently being contemplated by the FAA … I’m still trying to find out why it is that the FAA in the US continues to believe that having two different approaches to pilot training under part 121 is good for the industry. We have what is termed “the traditional” program requirements … and we have “AQP” – a regulatory authorization to do just about anything differently than what is prescribed in those “traditional” programs.
I still have the same questions I raised (or attempted to raise) elsewhere in this forum … do we expect the FAA regulations to be “an assistance” to having competence in the pilots that occupy airline cockpits? ... or ... is it essential to follow those rules to have the necessary competence in those pilots? I know the accident rates seem to be on a downward track – at least by some measures – like restricting such looks to part 121 operations, but with the growth in the industry, if we maintain the existing “accident rate,” we’re going to have an increase in the numbers of accidents. It’s simple math … the same percentage of a higher number is a higher number.
If everyone were to train precisely the way the “rules” say we must train … will that prevent incompetence from creeping into the cockpit? Will seeking authorizations to do things differently … i.e., an authorization under AQP (which still requires an FAA approval) … would that complete that connection and prevent incompetence from creeping into the cockpit? Does the FAA publish any “requirements for training” that make any difference at all? If they do … what’s up with having two different sets of “standards?” Why does the FAA publish differing standards in the first place? We are regularly told that a pilot trained under AQP is a more thoroughly trained pilot … and, certainly, they imply such thorough training provides a safer pilot. First, is that true? Second, if that IS true, is it because of the rules (or, more accurately, the authorization to deviate from those rules) or because of the professionals conducting the training – regardless of the rules governing their actions? Third, if it IS true that the rules ARE what makes the difference ... why the heck wouldn’t the regulator require the same training for ALL airline pilots? Am I the only one who gets lost in attempting to understand why we have to do what we are told we have to do when those who tell us what we have to do seem to have little understanding of what it is they want us to do? Otherwise, why have an alternative set of standards?
Each time I ask such questions here ... I get answers like “we’re allowed to focus our training on what those who are having problems really need.” Duh! Isn’t that the purpose of all training? Why do some believe that the “traditional” approach to training prohibits exactly this same kind of recognition and focus? From what I can see, this new “alternative” approach to training is highly dependent on psychologists and what they bring to the mix. I’m not anti-psychologist, per se ... but psychologists that are not aviators and believe they understand how pilots learn and what pilots use when they fly airplanes, and from that conclude that only training conducted in a “line environment” is worth valuable training time ... I tend to take with a grain of salt ... where that “grain” is the size of the “Rock of Gibraltar!” A couple of years ago, I had dinner with a group at one of the WATS conferences in Orlando, Florida. During an after-dinner conversation, I heard an FAA inspector say that he knew of one of the FAA psychologists who had specifically traveled to see, side-by-side, a Level D simulator and a Level 6 FTD, and after careful observation concluded that these devices were “...exactly the same except for the motion system on the Level D device!” One of my colleagues was in attendance as well and asked this guy what his impression was of AQP, CRM, FOQA, ASAP, VDRP, ASIAS, LOFT, LOE, and event-driven training. That inspector danced around the question, saying that he really couldn’t offer his comments, I think implying that his opinion didn’t count, but told all of us that we would have to decide for ourselves what we thought of relying on such processes ... very revealing ... very diplomatic ... and very disappointing.