FAA NPRM on Pilot Professionalism
The History & Potential Improvement
The Federal Aviation Administration issued an NPRM intended “to enhance the professional development of U.S. air carrier pilots to make certain that they adhere to standard procedures and prevent behavior which could lead to pilot errors.” The rule, if finally adopted, would require leadership and command training, and mentoring training for pilots-in-command. It would also require each air carrier to establish a committee to develop, administer, and oversee formal pilot mentoring programs.
The history behind this proposed rule is relevant to its issuance and the potential improvement is immense.
I. Regulatory History
In response to the October 14, 2004 Pinnacle Airlines and the February 12, 2009 Colgan Air, Inc. crashes, the NTSB and the Congress identified problems with the professionalism of the pilots. The NTSB issued recommendations based on their investigations of the Pinnacle and Colgan accidents, which are well summarized in this quote from the later Board decision:
“Develop, and distribute to all pilots, multimedia guidance materials on professionalism in aircraft operations that contain standards of performance for professionalism; best practices for sterile cockpit adherence; techniques for assessing and correcting pilot deviations; examples and scenarios; and a detailed review of accidents involving breakdowns in sterile cockpit and other procedures, including this accident. Obtain the input of operators and air carrier and general aviation pilot groups in the development and distribution of these guidance materials.”
Congress enacted the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public Law 111-216). That statute directed the FAA to convene advisory groups and conduct rulemakings related to the results of the NTSB investigation of these accidents.
The FAA established three ARCs in 2010:
- the Air Carrier Safety and Pilot Training (ACSPT) ARC,
- the Flight Crewmember Mentoring, Leadership, and Professional Development (MLP) ARC and
- the Flightcrew Member Training Hours Requirement Review (THRR) ARC.
All three ARCs were comprised of labor, industry, and FAA experts who provided recommendations to the FAA (see above links).
II. The Proposed Requirements
The FAA Administrator Huerta explained the purpose of the proposal: “Pilots have an enormous responsibility for the safety of their passengers and crew…We have some of the best pilots in the world and should take full advantage of our pilot’s wealth of experience to raise professional standards and cockpit discipline.”
Here is a summary of the specifics from the Federal Register notice:
|Proposed provision||Summary of proposed provision|
|Operations familiarization for new-hire pilots (§ 121.432(d))||• Operations familiarization must include a minimum of 2 operating cycles. A new-hire pilot completing operations familiarization must occupy the flight deck observer seat.|
|Upgrade training curriculum requirements (§§ 121.420 and 121.426)||• Upgrade ground and flight training requirements have been updated based on the qualification and experience that all upgrading pilots now have as a result of the Pilot Certification and Qualification Requirements for Air Carrier Operations rule requirements.|
|• Leadership and command and mentoring training must be included in the upgrade curriculum. Leadership and command and mentoring training are required subjects for upgrade ground training. Leadership and command training must also be incorporated into flight training through scenario-based training. (Note: For those air carriers that use an initial curriculum to qualify pilots to serve as PICs, leadership and command and mentoring training must be provided as part of that initial curriculum (§§ 121.419 and 121.424)).|
|Leadership and command and mentoring ground training for pilots currently serving as PIC (§ 121.429)||• All pilots currently serving as PIC must complete ground training on leadership and command and mentoring. • The Administrator may credit previous training completed by the pilot at that air carrier.|
|Recurrent PIC leadership and command and mentoring training (§§ 121.409(b) and 121.427)||• PICs must complete recurrent leadership and command and mentoring ground training every 36 months. • Recurrent Line-Oriented Flight Training (LOFT) must provide an opportunity for PICs to demonstrate leadership and command.|
|Pilot professional development committee (PPDC) (§ 121.17)||• Air carriers must establish and maintain a PPDC to develop, administer, and oversee formal pilot mentoring programs. The PPDC must consist of at least one management representative and one pilot representative. The PPDC must meet on a regular basis. The frequency of such meetings would be determined by the air carrier, but must occur at least annually.|
|Pilot recurrent ground training content and programmed hours (§ 121.427)||• Pilot recurrent ground training has been aligned with the pilot initial ground training requirements for pilots who have completed the Airline Transport Pilot Certification Training Program (ATP-CTP). As a result, the existing content and corresponding programmed hours for recurrent ground training have been reduced.|
|Part 135 Operators and Part 91 Subpart K Program Managers Complying with Part 121, Subparts N and O||• Part 135 operators and part 91 subpart K (91K) program managers complying with part 121 subparts N and O would continue to use the existing upgrade curriculum requirements and the proposed leadership and command and mentoring training would only apply to PICs serving in operations that use two or more pilots.|
|Flight Simulation Training Device (FSTD) Conforming Changes (Part 121, subparts N and O and appendices E, F, and H)||• Part 121, subparts N and O and appendices E, F, and H are updated as follows: (1) Reflect the terminology currently used to identify FSTDs approved for use in part 121 training programs; (2) Remove references to simulation technology that no longer exists; and (3) Remove requirement for FAA certification of training and remove pilot experience prerequisites for using a Level C full flight simulator (FFS) to reflect advances in current FSTD technology.|
|SIC Training and Checking Conforming Changes (Part 121 appendices E and F)||• Part 121 appendices E and F are updated to align with the current 14 CFR 61.71 requirements for SICs to obtain a type rating in a part 121 training program. Initial, conversion, and transition SIC training and checking must include the few training and checking maneuvers and procedures formerly designated in appendices E and F as PIC-only.|
|Other Conforming and Miscellaneous Changes||• Pilot transition ground training has been aligned with the pilot initial ground training for pilots who have completed the ATP-CTP. • The term used to identify the training provided to flight engineers qualifying as SICs on the same airplane type has been changed from “upgrade” to “conversion.”|
|• Conversion ground training for flight engineers who have completed the ATP-CTP has been aligned with the pilot initial ground training for pilots who have completed the ATP-CTP.|
|• Part 121 appendices E and F and § 121.434 are amended to allow for pictorial means for the training and checking of preflight visual inspections of the exterior and interior of the airplane.|
The heavy reliance on the robust work product of the three ARCs has resulted in very practical proposals to improve pilot professionalism.
What is a little odd is that the reports of the Flight Crewmember Mentoring, Leadership, and Professional Development Aviation Rulemaking Committee, the Flightcrew Member Training Hours Requirement Review ARC, and the Air Carrier Safety and Pilot Training ARC were completed as much as six years ago.
It is understood that the ARC output required careful review and revision, but a five year period to get from a fairly mature set of procedures to an NPRM seems more than what is warranted by this task.