Get with the 21st Century CASA
Dear CASA,
Recent tragic events prompt me write this open letter to you.
Why do we in GA have to persist with simulating emergencies in flight instead of a simulator or advanced aviation training device (AATD)? AATDs are now relatively cheap and becoming more common place. They can emulate to a very high degree of accuracy the handling and performance of many multi engine aircraft which fall within the Multi Engine Aeroplane Class Rating (MEA). So, if one is available why not use it to advantage?
Modern computing allows accurate visual presentation for day and night scenarios and many weather conditions which we would be reluctant to conduct a real operation in. Indeed some scenarios which can be simulated in an AADT are not permitted to be conducted in flight.
Devices such as the Redbird & PFC DCX Max are here and operating now and many are currently in use in GA in Australia but CASA steadfastly refuses to formally acknowledge their abilities and categorises them as merely a "Category B Synthetic Trainer" with very limited training and assessment credits available for their use. For instance, demonstration of EFATO is not permitted despite many of these devices having the hardware and software to effectively emulate such situations and under conditions much more challenging than we would attempt in flight.
I have put my arguments regarding AADT use and available credits for training and assessment to CASA for over two years now but CASA continue to drag the chain in amending legislation to approve greater use of AATDs by extending available credits and continue to insist that emergencies such as EFATO or engine failure during an instrument approach, be only demonstrated in flight in an actual aircraft even if this means simulating a failure (of whatever type) in real IMC!
For reasons of economy I conduct many IPCs utilising a Piper Seminole for applicants who routinely fly high powered, sophisticated aircraft types but which nonetheless fall within the MEA class. So for these applicants, what are we actually testing when we, for instance, fail an engine on take-off in a Piper Seminole? Are we just testing the fact they don't lose control and maintain airspeed? More, we are testing the pilot's procedures, thought processes and ability to deal with the emergency to ensure a SAFE outcome for all; it is not just the handling aspect. If we were just testing for handling in IMC then, logically, the applicant should demonstrate proficiency in handling in every MEA class aircraft they do or could fly in IMC. But for the purposes of demonstrating a satisfactory IPC they don't have to fly all these types whilst under assessment, do they?
During an IPC, when I simulate an engine failure in, for instance, the Seminole, the applicant is only demonstrating his or her competency on that day in that particular aircraft. What good does this specific demonstration of competency - in what is after all only one of numerous types of aircraft that the pilot is authorised to fly under his or her MEA Class Rating - really prove?
Immediately after the pilot satisfactorily completes the IPC in the Seminole he or she is then legally permitted go and fly another type (subject to general competency of course) which falls within the MEA Class - a type which may have a much more severe reaction to an engine failure or other problem but in which they have not demonstrated for the purposes of an IPC competency in EFATO. There is a big difference between a Seminole and a C-421 for instance. Therefore, what we, as testing officers should be assessing and do assess during an IPC or other check is the applicant's ability to handle the emergency in total and not just the particular aeroplane type, such assessment could and should be conducted in an appropriate AADT in a controlled and SAFE environment. Different scenarios, weather and other factors can be introduced to truly train and asses a pilot in following SOPs, logical thinking and problem solving. Ensuring the general competency requirement stipulated by Part 61 should be left to the pilot and or the employer.
Merely listening to the pilot citing the mantra "dead foot dead engine....." in a particular type proves very little other than rote learning. So we extend the scenario right? How far do we push a pilot in flight in simulated emergencies? Answer: Not far because we want to live! So what is being proved by insisting on using a real aircraft for the emergency procedure part of an IPC or other proficiency check? Who wants to fly on limited panel in real IMC with a person whom you may never have met before? Why not do this in an AADT?
The assessments we conduct are, by necessity, largely generic in nature so they do not require a full flight simulator. Due to the modern computing emulation, an AADT is more than adequate for assessment of competency in an MEA class aircraft.
So why does CASA continue to disallow the use of sophisticated AATDs to assess a pilot's ability, particularly in scenarios such as EFATO and Limited panel operations?
I say to you CASA: your outdated, antiquated approach to pilot assessment is potentially killing people. You should listen more to those of us in industry who know what we are doing, stop being obstructionist to new developments, react to industry demand for a better way of doing things and stop burying us in useless regulation and paperwork and outdated practices and obfuscation.
Wake up to the 21st Century CASA, pull out the proverbial digit and approve these modern, cheap, effective learning and assessment tools and stop contributing to the possible death of pilots by outdated, archaic notions of how to assess and train pilots.
CASA, it is called "Threat and Error Management" and you expect us to adhere to that doctrine so why don't you?
LEXAIR
Last edited by LexAir; 2nd Jun 2017 at 05:51.