Is the FAA holding the wrong end of the elephant ?
The FAA safety message is somewhat illogical. The need to address manual handling errors is based on an analysis of normal operations, incidents, and accidents. Yet errors are to be expected; it is the severity of the outcome and underlying cause which demands action. No such reasoning is stated in the SAFO.
Incidents and accidents receive most attention as generally the outcome of ‘error’ in these was more severe (consequential) than in normal operations. Yet a cursory review of ‘handling’ incidents / accidents shows a range of situations; many involved system failures or abnormal operations, and many with adequately trained and experience crews. There were some self-inflicted incidents/accidents, but these and the ‘failures’ all have a common theme relating to understanding the situation (including weather and workload); either in failing to avoid hazardous conditions, failure to appreciate the situation or previous error, or failure to choose or act on a safe course of action.
Requiring pilots to have more manual flight time may help maintain professional standards, but will it address the needs relating to the ‘manual handling errors’. Are we expecting plots to make errors so to practice recovery from the error?
Manual flight is unlikely to be conducted in adverse weather or involving high workload, or with systems failures; and obscure situational factors resulting in accidents are unlikely to be encountered. There is little evidence that crews could not have avoided or recovered from adverse situations (with existing manual flying skills) if the situation had been understood or there was a timely choice of action.
If the dominant issue is in understanding the situation, then perhaps there should be specific training targeting this issue. Manual instrument flight could help, as would wider experience of non-normal operations, e.g. go around. But even non-normal operations require good situational understanding and an apt decision to choose the manoeuvre; the skill to accomplish safe flight is secondary to awareness and choice of action; no evidence of absence of skill is provided.
The FAA has made a case for manual flight without presenting a justified basis. The interpretations in implementing the recommendations may be as wide as the range of views in this thread – but which will address the safety issue; there is a safety issue, but at which end of the elephant is it?