EASA NPA on flight testing
 

I came across reference to this for the first time a couple of days ago...

http://www.easa.eu.int/ws_prod/r/doc...%202008-20.pdf

EASA's NPA on the conduct of flight testing, including the training and qualification of TPs and FTEs. I'd strongly suggest that anybody who works in any form of FT anywhere in Europe should read this PDQ.

I'm not sure that I know what to make of it. If one were to start from scratch with a flight testing system, it seems reasonably sensible - and the grandfather rights clause protects anybody currently practicing within their current role.

But, what's there is a long way from most of current practice across much of EASAland and a lot of new training and qualification structure will need to be created to fill the gap for anybody new entering flight testing.

At least, that's my initial reading of it anyhow.


The other thing which I read is that the consultation ended about 2 weeks ago. I can't say that I've seen anything circulated through RAeS or SETP, there's nothing visible on SFTE's website, I see most of CAA's consultation and don't recall seeing anything. Did anybody outside of probably Airbus and ETPS actually get asked about this?

G

I had a quick read of this a few days ago and got the impression that EASA were in part trying to resolve the problem of how to regulate crew compentency for non-development flight test, e.g. post-maintenance or minor testing following minor modifications, etc. Clearly this type of testing is a world apart from proper experimental or developmental flight test by an approved manufacturer and I can't help thinking EASA have been unwise to try to regulate it all under one roof, so to speak.

Does anyone know if there have been any particular accidents or incidents, or trends, that have led EASA to decide to take this route?

It will be interesting to see where this leads....

There have been accidents, and indeed these are referred to in the document.

I imagine that all aerospace companies who could be affected by this were contacted - we certainly were.

Unfortunately, it seems to me that this was a really poor attempt to standardise which has therefore probably missed an opportunity and will put the whole thing back another 5 years at least.

But it was referring to all types of testing, not just production.

It goes hand in hand with Subpart I of EU-FCL

http://www.easa.eu.int/ws_prod/r/doc...202008-17b.pdf

FCL.820(a)(2)

Nothing ambiguous there at-all!

G

Thanks Genghis for posting this. I've had a good read through it. when Canada eventually comes around to adopting such regulation, I'll be a little more worried. For now, I'm just on guard. Like many attempts to regulate for good reason, the complexity of the regulation extends well beyond the good reason, and starts to immobilize otherwise safe and worthwhile activity, in the name of system safety. We cannot argue against improving safety, but it can be a fine line to overkill, and paralysation

One of the challenges, is that such standards are often initiated and supported by larger organizations. They more likely have the extra funds and staff time to devote to the consultation process. The result can be a regulation which is more appropriate to the larger industries, but misses the mark, or overwhelms the smaller industries.

No pilot can argue down training, but it might be fair to say "let's stop here, the training beyond this point exceeds what would ever be called upon in the intended work environment". This could be particularly true in flight testing simpler aircraft. A flight test pilot who only ever works with slow piston/propeller driven simple Part 23 aircraft, would probably be delighted to take training for advanced jet fighter flight testing (I know I would), but the additional value of that extra training, which did not apply to the "mainstream" tasks of that test pilot, would be a tiny fraction of the cost. Cost/benefit ratio = poor.

To say that test pilots for category 1 & 2 test flying require evidence of large amounts of training could be severe overkill, depending upon what is being tested, and why. The category 2 test flying could be mods to Cessna 172's. Sure, everyone can benefit from more training, but a year at ETPS for a test pilot whose been flying single Cessnas his whole life, may not be a cost effective fit.

I do see some remarks in the NPA relating to "significant experience relative to the task", and I like those words, but it seems to apply more to FTE's than pilots. I entirely accept that pilots seeking to "test fly" be accredited in some accountable way, but I think that there are still appropriate, informal ways of accomplishing this.

Take a 500 hour pilot, train him for 500 hours on the ground, and 120 hours in the air in 15 different aircraft over 10 months, he will now be a very well qualified 620 hour pilot, with experience on 18 to 20 aircraft types, perhaps less than half of which are common to what he will test fly.

When I compare that pilot to a pilot with 5000 hours in 80 aircraft types, in all conditions, all undercarriage types, with all kinds of experience with real failures, over 30 years, that latter pilot will need training as well, but he will have a much broader base of personal experience upon which to draw, when making subjective assessments of aircraft design factors. There are certainly aircraft design features out there, which have been approved, and probably would not have been by a pilot with more total "real world" experience in that type of aircraft.

I am frequently inspired by reading three books: Cessna, Wings for the World, by Thompson, Flight Journal, by Meyer, and The Lonely Sky, by Bridgeman. Each of these books tells the story of a "regular" pilot, who simply said "yes" when asked to test fly something, and it launched the career of a famous test pilot. Particularly Bridgeman, who writes of agonizing over the prospect of test flying the Skystreak, based upon only a modest amount of practice in an F80, and no real dual "test flight" training. I personally know a few more fellows like this, but they have yet to write books!

So, do we get a better aeronautical product if it has been tested and approved by a "test" person trained to be a test pilot, or a pilot person trained to be a test pilot? I would usually vote for the latter. (We probably need the test person to be the FTE, to keep the pilot from having too much fun). I feel reassured knowing that most of the planes I fly were developed and proven by oldtimers who knew the pitfalls, and designed them out.

It applies to aircraft manufacturers and government regulators too. The lower time pilot may not have the broader experience flying, by which he can "find" design compliance where it is a grey zone, and perhaps propose an entirely appropriate "workaround", simply based on previous experience with similar types. I have worked with an FTE who was ready to not allow the approval of a mod to a Citabria, because the wing dropped a little too much in the stall. He just did not have the experience to know that all Citabrias fly that way. We're evaluating the affect of the mod on the aircraft, not re-evaluating the whole aircraft design! On the other hand, I had a very experienced test pilot tell me that I did not know how to fly, because the brand new aircraft I was evaluating could not be stalled without spinning it, no matter how precisely one approached the stall (forgetting that it's not supposed to require unusual pilot skill and attention!) Funny, that he was the test pilot who had recently approved that design. The successor test pilot later required design changes to that aircraft type, because he found it had very poor stall handling! (something I'd known, and reported, 2 years and 2 fatal accident earlier!)

I guess it bears some similarity to receiving flight instruction. I'd far sooner receive it from a 50 year old, 5000 hour, widely experienced private pilot, than a freshly licensed 620 hour newbie instructor.

So EASA will help us all, by trying to quantify flying experience, and measure it relative to the task at hand. This has some merit, but not to the exclusion of pilots who have established skill and value as test pilots. It's a tougher task than you may think EASA! Always remember the grandfathers! You want them, they have the experience, they've seen more!

Those are the thoughts of a wandering mind, about to go to a Transport Canada flight test level of involvement meeting tomorrow!

Pilot DAR

I saw a note that SETP was going comment on the NPA, although initially they were reluctant to do so.

While I reside west of The Pond, I read it with great interest...and think the proposal makes a lot of sense, for many reasons. It's hard to imagine that anything remotely related would come to pass in the USA, though I wish it would...so much for harmonization!

I also believe the NPA would result in some additional benefits, beyond the obvious, through the proposed requirements. The best test pilots are those who can articulate why a problem exists; who can look past the "gee whiz" of new piece of technology to ensure that it's is great as Apple Pie; who can say more than simply "the aircraft complies with the certification requirements" (or the corollary: "show me in the rules where it says we have to do that"); who are willing to take a position with Management as to why a change needs to occur - in spite of the impacts that my result in cost or schedule. This requires test pilots with backgrounds in operations, engineering, human factors, and communications ... a tough proposition for OJT, in my opinion (I have seen it done, but am not a fan).

Trained test pilots should be the backbone of any organization serious about development and certification...

My $0.02.

Oh, and Merry Christmas! :)