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Get with the 21st Century CASA

Old 2nd Jun 2017, 05:14
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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?


Last edited by LexAir; 2nd Jun 2017 at 05:51.
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Old 2nd Jun 2017, 06:23
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Well said.

I think a related safety issue is that the chosen methods for simulating failures in real aircraft often have operational consequences that are substantially different from the operational consequences of the usual causes of real failures.
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Old 2nd Jun 2017, 07:26
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Can we get this out to a few Media Outlets in a controlled manner please? Explained to Journalists in a way that gets the point across without them resorting to the usual alarmist BS?
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Old 2nd Jun 2017, 10:07
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Well argued points of view. Accidents of the type under discussion are often caused by an over-enthusiastic and probably over-confident instructor - whether training or checking. Over-confident in that he is certain he has the ability to recover the aircraft from any handling problem the pilot under test may exhibit.

The pilot under test may be experienced in terms of flying hours, and maybe even a popular chap among his colleagues, but that does not necessarily mean he is always on top at his job. A low altitude cut to simulate an engine failure after lift off is fraught with the danger of mis-handling particularly if done in simulated IMC using a hood. Initial full wrong rudder applied has been known to happen under the stress of a test. At low altitude that can be dangerous unless immediately stopped by the ATO or flying instructor. Instructors and testing officers must be disciplined enough not to risk cutting an engine at dangerously low altitudes in the desire to be realistic. That point needs to be strongly emphasised during instructor courses.

Far better to use an appropriate simulator. If the simulator is not an exact replica of the aircraft, it probably matters not that much. In fact a King Air or Metro full flight simulator adequately represents the physical handling qualities in terms of foot and aileron loads of similar turbo-props under asymmetric conditions. I understand a draw-back of most flight training devices, rather than true full flight simulators, is the absence of realistic foot-loads in asymmetric flight.

For limited panel flying with the only ADI inoperative, thus leaving only one altimeter, one ASI and a Turn and Balance Indicator or Turn coordinator, an appropriate synthetic trainer is an excellent aid - rather than risking mishandling in IMC in the real aircraft during an IPC. After all, limited panel flying is concerned primarily with accurate cross-reference while flying on instruments and an appropriate synthetic trainer should be good enough for that task.
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Old 2nd Jun 2017, 10:59
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Lexair - what a brilliantly worded and put together piece, of which I could not agree more of. From what I believe this very FOI was a strong driver of use of simulators where available after the Air-North EMB120 accident in DN.

In my time in aviation I haven't recalled a FOI ever being killed in an accident where they were on duty in an observational role. Perhaps as part of this process now they will have to look at it from a WH&S perspective from an employer point of view.

This industry can be excellent to introduce all manner of things to minimise the chances of crashing aircraft, GPWS, TCAS, etc etc, but all of those are in the higher profile areas of RPT and jets.

GA flies around in 40 year old aircraft with a 40 year old mentality. There is a better way of doing things, exactly as you said, sadly it may have taken the death of one of their own for finally some change to result out of this terrible accident.
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Old 2nd Jun 2017, 11:23
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Excellent, I agree 100%. Let's start to get rid of some the old ways, examine the real risk and use technology to improve training outcomes.
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Old 2nd Jun 2017, 12:38
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Some say that cheap sims are pointless....

Microsoft, X plane etc, are bloody great tools, and they can be adapted to just about any type you like, you can even get instrument panels designed that specifically match your fleet.

As lexair says, its a shame they have zero recognition. I personally used MS flightsim throughout my training, if only to get my checks and routines working the way they should, all valuable.

The sims out there, and their ease of reconfiguration needs to be recognised, to make the most dangerous of testing safer. In this day and age, there is little, if any need to undertake high risk training in the air. At worst, I would agree to doing it once in the air to show the mind that what you learnt in the sim is actually how it really happens...and that would only be AFTER you achieve standard in the sim.

Puff mentions the Air North one, and it raised a tear for me. My friend was on that flight. He had just returned from melbourne, setting up the Sim training for type. He was to be the last to do the routine in a real aeroplane, and that ultimately proved true.

The other thing puff mentions, is the fact that CASA might finally recognise how dangerous this stuff can be. The real danger is that they put an immediate halt to such flights with no alternative way forward in the short term.....
How many operators would that ground?

Safer skies are empty skies
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Old 2nd Jun 2017, 18:38
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Spot on.
At my last organization my Chief Pilot, with my approval bought, with a mate, a limited motion sim for a relatively modest $30,000 which could be configured for GA type piston turboprop and jet with a substantial airfield database, With sufficient fidelity that he hired it out to other training orgs.
As a corporate jet operation operating nationally and internationally with ad hoc destinations likely to be anywhere, the fidelity was such that it was possible to train to practise approaches and landings to anywhere the client wished. Google Earth also provided some really accurate terrain data and the "fly through" mode gave the crews a really good appreciation of the terrain surrounding unfamiliar destinations and for preflight planning.
Its not hard.
gaunty is offline  
Old 2nd Jun 2017, 23:06
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LexAir is correct, but CASA will not do anything that:

(a) Reduces its power or cede power to someone else.

(b) Increases its accountability or perceived responsibility.

(c) Reduces its opportunity to obtain revenue through fees.

(d) Reduces career opportunities for staff.

Thus, the use of simulators for this type of GA testing will be complexifide to add yet another layer of fees, administrative costs and approvals by CASA. Simplification, streamlining and the cutting of red tape are anathema to CASA.

CASA will probably do this by dreaming up a set of simulator requirements that are uniquely Australian and prohibitively expensive to satisfy.

Didn't the RAAF (RAF?) call this type of dangerous training "practicing bleeding?".
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Old 3rd Jun 2017, 02:01
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The watershed event for the RAAF was the loss of a Boeing 707 with its crew over Bass Strait during the 80s. The captain was practicing a Vmc (air) demonstration for his instructor qualification check ride, and lost control of the aircraft.
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Old 3rd Jun 2017, 02:21
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First a King Air now a Conquest, both seemingly some sort of engine related event (on face value). Just this year.

Wouldn't surprise me if things change. If they do, hopefully industry will be heavily involved and help make a good plan (rather than sitting back and then whinging about the changes).

I love sim training. But it won't be easy to implement. If it's left to CASA alone it would probably cripple industry. There's plenty of operators out there, there's a few people building fixed base and motion synthetic devices that are a lot cheaper than the full-on simulators. Everyone should get together to look at a way for getting better cost-effective, beneficial trainers approved and in use for initial and recurrent training. Whilst they may not need to be full flight sims, there is still a lot of benefit to be had from a fixed base, type specific (to your operation) trainer.
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Old 3rd Jun 2017, 02:34
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Great post LexAir, the tech has well and truly advanced the regulations!
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Old 3rd Jun 2017, 03:02
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The captain was practicing a Vmc (air) demonstration

.. with hydraulics off .. which just didn't work very well.
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Old 3rd Jun 2017, 07:42
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LexAir, an excellent post and convincing argument.

Where there is no type-specific simulator available locally it would be great if CASA mandated the use of a generic-type device for complex types e.g. any turboprop up to 5700 kg.

However, while these things are great for experiencing engine-out situations and practising instrument flight, the ones I have played with fall down in that they can not possibly replicate switch and control positions for multiple types and neither can they fully replicate the effect of various systems failures across multiple types. This is where you will have difficulty with old mates at CASA. Which is unfortunate, as no one who uses the real aircraft for training ever pulls total electrical or hydraulic or pressurization failures in flight and never engine failures at max gross weight in limiting ambient conditions. And neither should they!

The solution of course is - in addition to a few hours every year in the generic device - to require annual or biennial recurrent ground school on each complex type flown, augmented by a few hours in the cockpit (safely on the ground) going through various failure scenarios with a type specialist check pilot.

Operators will snivel at the downtime and cost. Pilots will snivel at the encroachment on their beer drinking time (because the typical GA operator won't pay them for such frivolous activity as TRAINING). GA is its own worst enemy.
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Old 3rd Jun 2017, 15:04
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We are valiantly maintaining our record of killing pilots on training, can anybody remember the last fatality from a real engine failure on takeoff in a FAR 23 twin ( as well as the recent Kingair -- which may not have been an actual engine failure)

So much for the CASA (and too many industry types) hairy chested (sorry, ladies, but at least one I know can consider herself to have an honorary hairy chest) approach to rational risk management ---- demanding performance for which aircraft are not certified.

And having certified (FAR 23 commuter amendment or FAR 25) is no guarantee (Tamworth, Darwin) with the slightest misjudgement.

Tootle pip!!
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Old 4th Jun 2017, 05:30
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So LeadSled, your Chief Pilot of a small GA company that has a couple Cessna 402's, a Conuest and a Bandeirante.
Like most chief pilots in this sector, you have newbies coming into the C402, some come with a new IFR rating and all in that 1,000 to 1,500 hour bracket with the usual instructing or 206 bashing around in the bush exposure. The Conquest is flown by the old hands that have done a few years in the 402 and survived on the night freight and charter work. You have a one older guy that has been flying the Conquest for a good ten years plus. The Bandeirante is flown multi- crew on a contract that has reasonable experience requirement set down by the mining company.
As a chief pilot the C402 drivers get an IFR renewal every year and a profiency check, likewise applies to the Conquest drivers and the Bandeirante crew get some additional training.
As a chief pilot your big worry, getting the newbies up to speed- some of those IFR schools have very funny ideas about flying and doesn't match the real world of IFR flying.
You have a good checkie, that takes pride in his product and likewise as chief pilot you also cover check and training and do most of the C402 endorsements. Again you find amongst your pilots, some guys handle the asymmetrics very well, others need extra training or in some cases back to basics. Again you wonder wtf, does Captain Duchess really know at Advanced Flying Skills Organiation, who did Bloggs initial twin rating. Yes young Bloggs can recognise a twin engine aeroplane, and he can give you a nice big briefing on VMCA, etc. However the asymmetric overshoot he did left a lot to be desired, and he got a bit upset when you asked him to retact the flap for the fourth time as the aeroplane limped along!

As a chief pilot what do you do, a sim would be lovely but is there one for the C402?
You could convince the boss that the sim is the way to go, it would save money in the long run, likewise for the Conquest the nearest sim is the USA, nothing avalable for the Banderiente though!
You might be able to stretch the relationship with the owner to send one or two to the Conquest sim in the states, it will be a big dollar exercise, plus loss of crew for a few weeks and then Murphy's law , one of the bloke will come back resign as he has got a jet job!

So what does a chief pilot do, he has to keep CASA happy, insurance company happy, the mining company happy, the owners of the business happy and I suppose he has to have faith Bloggs taking the C402 out at night on the freight run!

So LeadSled what would you do?
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Old 4th Jun 2017, 05:47
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Originally Posted by LeadSled View Post
We are valiantly maintaining our record of killing pilots on training, can anybody remember the last fatality from a real engine failure on takeoff in a FAR 23 twin ( as well as the recent Kingair -- which may not have been an actual engine failure)
Beech C90 LQH in Toowoomba. Left engine failed on takeoff, and hit powerlines in a 90* left bank.
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Old 4th Jun 2017, 12:11
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+ the C404 at YPJT not so long ago... Leadsled, you either have a very selective memory or are losing it...
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Old 4th Jun 2017, 23:16
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With all due respect....bollocks.

Firstly.....nothing at all stopping instructors using lower level devices as a pre-aircraft training element.

And......CASA has introduced simple mandatory requirements for simulator training. And yep....lots of squeals from people who should know better saying "but it hasn't got the ACME glass cockpit" and "why can't we do it in the aeroplane like we always did?".

There would not be a single inspector in CASA with the vested interests you list....and by the way just out of respect please remember they just lost a highly valued and respected colleague.

You folks want CASA to stay out of the cockpit and let the professionals do it properly.....til something happens then you want CASA right back in there.

There have been some good points made in this thread. And they are in line with directions the industry (including sim manufacturers, CASA and training organisations) are moving toward. But if for example the use of some generic AATD was mandated as well as actual aircraft sure that you're not posting the next day about CASA over-regulating. Same if CASA said you had to use the simulator for a similar type. "Oh the cost!!!"

Just remember.....probably 95% of the passengers traveling today will be flown by pilots for whom simulator training is mandatory and aircraft training forbidden. Ranting about CASA "not caring" is hardly likely to get that number closer to 100%.

Now please get out of the way and let actual professionals further improve the system.
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Old 5th Jun 2017, 00:21
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You folks want CASA to stay out of the cockpit and let the professionals do it properly.....til something happens then you want CASA right back in there.
That's not what I want. The experienced older FOIs are retiring and the replacement pipeline is empty. I want CASA to pay enough to be able to attract the best, which they don't do now. Some excellent CASA FOIs are even going back to industry which is delaying approvals for that very same industry.
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