Military Safety Standards should not be transposed to Civil application without deeper analysis

Below are three different reports about the value of simulator training to demonstrate the training needed to assure the competency and proficiency of candidate airline pilots.
- The first is an article addressing the expert views of a Senator who flew helicopters in combat.
- The next discusses the opinions of two former FAA Administrators, both former airline and military pilots, both once members of ALPA and one previously was president of that union.
- The final exposition is a brief announcement by a major aerospace manufacturer and one of the globe’s most respected aviation training company. They have joined together to further rely on simulators to enhance the competence and proficiencies of cockpit professionals.
The Junior Senator from Illinois has called out a colleague for proposing a statutory amendment to the FAA Airline Transport Pilot prerequisites. Senator/ Lt. Colonel Duckworth, a highly decorated, severely wounded helicopter pilot, experiences created some level of credibility for her sanguinary slam of her fellow Senator. Her US Army Reserve first level of rotary training involved 149 hours of flight training in an aircraft and 30 HOURS in a simulator1.
Military aircraft and pilots have different missions and thus different requirements, many more stringent, others vary (low or high) based on the flight parameters. Here are a few examples suggesting that military and civilian aviation standards are not 100% congruent or necessarily cross-relevant:
- A prominent distinction is called thrust excursion cycle; it reflects that combat aircraft are subjected to more severe stresses. A civil airliner observes a less stringent Mean Time Between Overhaul regime because its operations are more consistent in their aeronautical strains- airframe and powerplants.
- Low-altitude flying training requirements, which are necessary for many combat operations that involve high speed maneuvers, air-to-air combat, close-air support and reconnaissance. Low-altitude flying training requires designated airspace and safety precautions to avoid collisions with other aircraft or terrain. Including such demanding training for airline pilot would not make safety of economic sense.
Even more to the point, statements on the efficacies of military simulator policies2 are quite useful to this debate
Military transport pilot training flight simulator can provide many benefits for the military, such as:
– Enhancing the safety and proficiency of the pilots by exposing them to various weather conditions, emergencies, threats and situations that they may encounter in real operations.
– Reducing the cost and risk of using actual aircraft for training purposes, as well as the wear and tear on the aircraft and the fuel consumption.
– Increasing the effectiveness and efficiency of the training by allowing multiple pilots to train simultaneously in different locations, using real equipment such as night vision goggles, and debriefing the performance after each mission.
– Offering high-fidelity and state-of-the-art simulation features such as CrewView All-Glass Mirror Displays, VITAL 1150 visual system, true collimated images, and realistic scene content.
The opinions of Captain/Administrators Babbitt and Elwell reflect a generally held opinion of the value of simulators as a useful instruction tool. Both share the Senator’s military training background, but both had extensive experiences in civil aviation. The Senator’s indirect insinuated “corporate profit” motivation3 is easily refuted by their nonpareil current standing on aviation safety.
The Boeing recent lessons about flight crew competence and the named locations for the first deployment of these state-of-the-art pedagogical machines strongly point to the need for these sophisticated flight training tools.
The source of the opposition to greater reliance on simulators is the Air Line Pilots Assocation (see their President’s quote in article #2 below). Senator, as a Command Pilot in your Black Hawk, you knew whether to question the judgment of your S-I-C in the right seat. You might want to reconsider whether ALPA’s views are 100% reliable; you should be less sanguine in military flight and civilian flight comparisons.
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‘BLOOD ON YOUR HANDS’: Duckworth blasts Sinema for pilot training proposal
Sen. Tammy Duckworth on Thursday blasted a proposal being pushed by Sen. Kyrsten Sinema that could alter how much training a pilot needs to fly a commercial aircraft, saying lawmakers will have “blood on your hands” if they support the changes she is seeking.
“Now is not the time to put corporate profits ahead of the lives of our constituents who may want to board a commercial flight in the future,” said Duckworth (D-Ill.), an Army veteran helicopter pilot who chairs the Senate subcommittee in charge of aviation. “A vote to [change the training rules] for pilots will mean BLOOD ON YOUR HANDS when the inevitable accident occurs as a result of an INADEQUATELY TRAINED FLIGHT CREW.”
Just hours before Duckworth’s speech, the proposal from Sinema (I-Ariz.) had forced the Senate Commerce Committee to postpone a vote on a major aviation policy bill. Because Democrats hold only a slim majority in the Senate, Sinema and the panel’s Republicans could have amended the bill to include her training language. Democrats have largely opposed changing the training rules, and they have joined the Biden administration in targeting what they call corporate malfeasance in the airline industry.
Some smaller, regional airlines have been pushing for changes to the current rule requiring pilots to have 1,500 hours of training before they can fly for a commercial airline, arguing that the rule is contributing to ongoing pilot workforce problems. Sinema’s amendment, drafted with Sen. John Thune (R-S.D.), would allow certain kinds of airline training programs to be weighted more heavily toward that 1,500-hour requirement than they are at present — a proposal similar to those already rejected by the Biden administration.
Sinema, who caucuses with the Democrats, did not immediately have any comment.
The issue broke into public view Thursday during a challenging time for the industry, with air travel climbing sharply toward pre-pandemic levels at the same time the system saw a spate of near-misses earlier this year. Though airlines and the Federal Aviation Administration appear to have, for now, arrested the near miss problem, even one more near-collision with half the year remaining would be a dire warning of freefall for an aviation system that has an otherwise enviable record of safety in recent years.
Duckworth alluded to the near-misses during her speech, calling 2023 “a chilling year” for aviation safety. She said her experience as “a pilot responsible for the lives of my crew and passengers in the most hazardous conditions” and leadership on the aviation safety subcommittee “means that I cannot be complicit in efforts to compromise on safety for the flying public.”
“There has never been a worse time to consider weakening pilot certification requirements to produce less experienced pilots,” she said.
Duckworth said the pilot shortage has been “real and painful” and that she understood “the temptation to cut corners or chase the false promise of a quick fix to a systemic challenge.” But she said she has asked for specifics on how many additional pilots would be available if the minimum hours were reduced and has received “no precise estimates, let alone any credible projections.”
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Two prominent pilots introduce a win/win option to the 1,500 hour ATP debate
#FAA #ALPA #DanElwell #RandyBabbitt
The debate over the Colgan Air Flight 3407-induced 1,500 hour minimum requirement for airline SICs has been a screaming match between airlines and unions—not really about safety but supply of pilots. Now, two retired airline pilots, who also are also former FAA Administrators, have expressed a position BASED ON SAFETY.
First, ALPA’s claim as articulated by ALPA’s current president1 is as follows:
“Our president Capt. Jason Ambrosi testified on Wednesday at a House Aviation Subcommittee Hearing…
Capt. Ambrosi referenced the investigation of the Colgan Air Flight 3407 accident and the subsequent legislation in 2010, which strengthened first officer qualification and pilot training requirements. ‘Since then, passenger fatalities have dropped 99.8 percent.’ He continued, ‘This year’s reauthorization should be based on retaining these provisions.’”
One of thecritical skills needed for flying is the ability to calculate risks based on historical data. The above quote, repeated frequently by the union, fails to distinguish between CORRELATION AND CAUSATION. Yes, commercial aviation over the intervening period has had an excellent safety performance. In that same period, the quality of onboard avionics, the reliability of engines, weather prediction/dispatch has improved and a whole host of other factors have reduced risks. Some of the claimed 99.8% reduction may be attributable to these elements unrelated to the past legislation. ALPA’s logic is dismissed by the following hypothetical illustration:
A well-dressed man, blue suit and hat with a front brim, was standing on the SE corner of 17th and K St. NW. He’s been clapping his hands for HOURS. A woman went up to him and asked him “What ya doing?” The man answered, “clapping my hands keeps the elephants away”. The observant lady noted “There hasn’t been an elephant here in decades.” The man exclaimed “SEE IT WORKS!!!” The lady smiled and said, “Thanks Captain.”
In the context of this contentious argument, two highly credible, exceptionally knowledgeable and unequally qualified individuals have proposed an option that increases safety by amending 14 CFR § 61.159 to allow greater recognition of time accrued in advanced simulators and ground training devices. The Honorables Babbit and Elwell point out that greater reliance on this technically superior training tool could improve the qualification of graduates. This simulator education is superior to hours spent in a single engine, uncomplicated aircraft; for example:
The instruments on airline simulator represent the sophisticated cockpit that these trainees will fly after earning an ATP.
To reach the 1,500 regulatory threshold, most of prospective pilots will fly without the benefit of qualified instructors. Training in these recreations of cockpits usually includes a qualified instructor
Simulator can recreate situations of high risk in which the student can learn how to recover from these threats without injuries.
These sophisticated machines permit the teacher to stop the event to show the student a preferrable technique and/or to replay the tape as another pedagogical approach.
Simulator time can be scheduled to allow the student to continue working to pay for the tuition. Plus, these exercises do not exhaust carbon.
This intervention by these airline pilots, hopefully, will move the resolution of this difference of opinion into a positive resolution mode.
Former FAA administrators call for pilot training regime overhaul
18 April 2023
Two FORMER FAA ADMINISTRATORS are calling on the US government to overhaul training requirements for airline pilots amid a shortage of flight deck professionals that threatens to hinder the industry’s growth for years to come.
In an 18 April letter to leaders of the House of Representatives’ Transportation and Infrastructure committee, Randy Babbitt and Dan Elwell say the CURRENT TRAINING REGIMEN FOR AIRLINE PILOTS in the USA is OUTDATED and needs to be REASSESSED. Their comments come ahead of a congressional hearing about Federal Aviation Administration reauthorization and the aviation industry workforce, set for 19 April.
“The US pilot training paradigm is flipped from where it should be,” they write. “Today’s approach maximizes‘simple flight hours’ but allows minimalcredit for the use of advanced simulator and ground training devices; we strongly believe it should be the other way around.”
Currently, most prospective airline pilots in the USA must log 1,500h of total flight time before they are eligible to apply for a job piloting commercial aircraft – ABOUT SIX TIMES MORE HOURS THAN THEIR COLLEAGUES IN OTHER COUNTRIES. There are few regulations, however, about what kind of flying pilots do to collect those hours.
The pilot experience rule– a response to the deadly 2009 crash of a Colgan Air turboprop – does have some exemptions: military pilots can take airline jobs with 750h, and graduates of university aviation programmes can do so with 1,000h or 1,250h.
Many pilots who do not fall into those categories work as flight instructors in single-engine piston aircraft – a far cry from the complex technology of multi-engine jets they would later fly for airlines. In addition, such candidates rarely experience the difficult weather conditions that they could face in commercial-jet cockpits.
That kind of aviation experience is of little use as a measure of proficiency and safety, Babbitt and Elwell say. They argue the FAA should allow pilot candidates to use modern simulator technology to fill in knowledge and skills gaps.
“Because of regulations written decades before the incredible advances in full-motion high-fidelity simulators, and advanced training devices, pilots are restricted from logging more than about 7% of their [air transport pilot]-qualifying time in simulators,” they say. “As a result, most pilots accumulate over 75% of their airline-qualifying flight hours outside of a curriculum and monitored environment.”
The regulatory environment is long overdue for a “refresh” with “additional structured training programmes”, they write.
“An updated training model would also allow flight schools to continuously adapt to new advancements in aircraft technology and training techniques,” the letter reads. “Experience tells us that an updated model should increase, rather than limit, time spent in modern simulators that expose trainees to emergency scenarios and hostile weather events like icing and thunderstorms – too dangerous to learn or practice in the air.”
In addition to producing better-trained pilots, a shift in the regulatory framework encouraging use of simulators would also support a greater diversity in the pilot population, as it promises to make flight training less of a financial burden, the former FAA chiefs say. Currently, it can cost pilots $100,000 or more to achieve all certificates and ratings needed to reach about 250h of flight time.
A third advantage would be a smaller carbon footprint, due to less single-engine piston flying, Elwell and Babbitt add.
Airlines across the USA are dealing with a massive pilot shortage that has hit smaller regional carriers hardest, prompting airlines to cut flying and leaving some smaller US cities without air service.
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CAE Teams with Boeing To Elevate Pilot Training
– June 20, 2023, 1:49 AM
Boeing enlisted CAE as the first authorized competency-based training and assessment (CBTA) provider on Monday at the 2023 Paris Airshow, expanding a long-standing partnership between the companies.
CBTA, which focuses on pilot proficiency, will initially deploy in Boeing 737 Max simulators at CAE’s centers in Delhi and Bangalore, India, said Boeing Global Services president and CEO Stephanie Pope. She explained that Boeing chose India because of its large delivery backlog there, adding that the 777 stands as another candidate for CAE-provided CBTA in that country.
Boeing said CBTA leverages digital tools and fleet operations data to individualize training and help pilots respond to in-flight challenges. The company is implementing a CBTA curriculum through its training facilities in Seattle, Miami, London-Gatwick, Shanghai, and Singapore, among other locations. CAE president and CEO Marc Parent noted that his company also plans to introduce Boeing-authorized CBTA training in other global markets beyond India.
“This partnership expands our competency-based flight training capacity to better meet the needs of our customers worldwide,” said Pope. “By sharing data, leveraging digital capabilities, and providing greater accessibility and affordability, Boeing and CAE are enhancing global aviation safety.”