A proposed rule that calls for a sweeping overhaul of flight crew and dispatcher training has certainly piqued the interest of RAA vice president of technical affairs Dave Lotterer, but for all the wrong reasons. The NPRM, published in the Federal Register on January 12, includes the equivalent of some 900 pages of recommendations, cost estimates, analysis and background, but it doesn’t contain what Lotterer would like to see most–a modicum of clarity, according to the RAA technical specialist.
“This has been tying me up quite a bit,” said Lotterer. “Right now I’m on 17 pages of a response and I haven’t even gotten to the flight attendants and dispatchers sections yet.” Speaking with AIN early last month, Lotterer said the RAA joined the Air Transport Association and the National Air Carrier Association in filing a request to extend the proposed rule’s comment period 180 days beyond the original May 12 deadline.
Titled “Qualification, Service and Use of Crewmembers and Aircraft Dispatchers,” the proposed regulations add a long list of new training requirements in areas the FAA deems critical to safety, including mandatory use of flight simulation training devices and simulators for LOFT during recurrent training, without exception.
To start, Lotterer characterized as “irrational” language in the proposal that implies that all its various provisions offer a level of training equal to the already widely used Advanced Qualification Program (AQP).
Adopted by most major airlines and now used by at least three regionals by Lotterer’s count, AQP can serve as a substitute to subparts N and O of Part 121. In essence, AQP provides for alternative means of complying with certain rules that might inhibit the use of modern technology for training and generally allows for more flexibility. But in what has become known colloquially as the N & O rewrite, the DOT states that current AQP programs already meet the safety improvements the new proposed rule contains.
“The particular provisions that are being proposed are much more restrictive than AQP, so how would they cost justify the additional requirements if AQP would satisfy the equivalence in safety?” asked Lotterer. Therefore, no rational operation would choose to follow the new rules, he submits, but rather opt for AQP.
Lotterer said that the proposed rule contains nearly 100 separate provisions that would require specific FAA approval. Under today’s rules, the FAA approves every operator’s training program as a whole. “They’ve always had the authority to approve or disapprove the training program in total,” said Lotterer. “In this rule proposal they have nearly 100 separate FAA approvals. They say that you must do this as approved by the FAA. Well, OK, but what are the criteria under which the FAA will accept this? All of that information is missing... Ultimately you will have different POIs [principle operating inspectors] who will approve certain programs and POIs at other airlines who will not approve them.”
To Lotterer, one of the most troubling requirements involves mandatory use of flight simulators for recurrent training. “Everybody uses simulators for training, but when you say mandatory and no exceptions, I mean there are certain check rides and so forth that you do in the airplane, and this would prohibit those. You might not be able to get a simulator for several months. So what are you supposed to do with that particular check airman or pilot or whatever? Is he going to sit and wait for several months? There’s just no justification for those kinds of restrictions.”
Another provision with which Lotterer takes issue centers on the proposal to raise initial systems training in the classroom for turboprop pilots from 80 hours to 124 hours, bringing them in line with jet systems training. “So, in effect, a Beech 1900 classroom program would require as many hours as…a 747 or a 777,” said Lotterer.
That, of course, would seem ridiculous to anyone familiar with the difference
in sophistication between a 777 and a Beech 1900. The RAA, however, must keep in mind how its position might sound to a lay public still shaken by February’s Colgan Air Q400 crash.
“Our comments have got to be carefully crafted,” said Lotterer. “We don’t want to give the impression to the public that we’re more interested in saving a buck than in training our people. So it’s a sensitive issue.” –