Pilots planning for a career that requires certification to airline transport pilot (ATP) standards will need to set aside thousands of dollars to pay for additional training mandated by new FAR 61.156. The training is required before the candidate can take the ATP written and practical tests (beginning August 1 next year), and the portion that will cost the most is 10 hours of simulator training, including at least six hours in a full-flight simulator (FFS) meeting Level C standards and replicating a multiengine turbine-powered airplane weighing at least 40,000 pounds. This requirement applies no matter what type of airplane the ATP candidate will be flying, whether it’s a Seneca piston twin or a four-engine A380 weighing more than a million pounds.
The new 61.156 is the result of a U.S. congressional mandate following the February 2009 Colgan Air Flight 3407 crash and others, which brought issues of pilot competency and training to the attention of the general public and politicians. The mandate took the form of the Airline Safety and FAA Extension Act of 2010. According to FAA Advisory Circular 61-138, which is designed to help the aviation industry develop the necessary training programs, the training will help pilots fill a “knowledge gap” in their training. According to the advisory circular, “Though [the public law] focused primarily on modifications to the certification requirements for an ATP certificate, the knowledge gap identified by the [rulemaking committee] remained relevant as both initiatives focused on enhancing the qualifications and training for pilots who desire to work in an air carrier environment. The FAA has determined this knowledge gap extends to pilots beyond Part 121 air carrier operations to include pilots that are required by regulation to hold an ATP certificate (§§ 91.1053 and 135.243). This knowledge gap can be best and most effectively bridged through successful completion of a modern flight training program that methodically integrates academic training and aeronautical experience in a FSTD [flight simulation training device].”
One aspect of the mandate got a lot of attention, a requirement for a minimum of 1,500 hours of flight time, ATP certification and a type rating for Part 121 airline first officers. But the pre-ATP training requirement may be the more significant result of the accident, both in terms of the cost of earning the ATP and on the qualifications and training of new professional pilots in the U.S. The new rule means that U.S. airline pilots will enter their field of employment with higher qualifications than before the rule was enacted. Previously a Part 121 first officer needed only a commercial pilot certificate (190 to 250 hours of flight time, depending on the type of school attended), instrument and multiengine ratings and a second-class medical certificate.
While pilots in some countries with shortages of pilots are entering airline cockpits with what seem like much lower qualifications, under the multi-crew pilot license (MPL) scheme, the 61.156 requirements seem to mirror some of the MPL concepts. MPL–an ab initio program for new pilots with no previous experience–was developed by the International Air Transport Association. The goal was to “Replace by competency-based training the traditional application of box-ticking, hours based, prescriptive syllabi” and employ much more simulator and multi-crew training, upset prevention and recovery training (UPRT) and other modern practices such as training in the multi-crew environment. An MPL candidate can earn this license in as few as 246 hours of flight time (85 in an aircraft and 161 in a flight simulator, total course length 14 months), according to the IATA’s Global MPL Course Tracker.
In 61.156, ATP candidates must have a graduation certification from an FAA-approved training course that covers:
• 30 hours of classroom instruction covering eight hours on aerodynamics, including high-altitude operations, two hours on meteorology and 14 hours on air carrier operations (covering physiology, communications, checklist philosophy, operational control, minimum equipment list/configuration deviation list, ground operations, turbine engines, performance and automation, navigation and flight path warning systems.) Another six hours must include “instruction on leadership, professional development, crew resource management and safety culture.”
• 10 hours in an FSTD that meets Part 60 qualifications and represents a multiengine airplane. The training must include six hours in a Level C or higher full flight simulator (FFS) that replicates a multiengine turbine airplane with an mtow of at least 40,000 pounds. The six hours must include training in low-energy states/stalls, upset recovery techniques and adverse weather conditions (icing, thunderstorms, gusty crosswinds). The other four hours of FSTD training can be done in a Level 4 device and must cover navigation (including flight management systems) and automation (including autoflight).
It is the 10 hours of FSTD training that will add significantly to ATP candidates’ training costs, although the regulation does offer some potential relief. “The Administrator may issue deviation authority from the weight requirement…upon a determination that the objectives of the training can be met in an alternative device.” This could allow the six hours of training in a Level C simulator to be done in a larger variety of simulators such as those that replicate light and midsize business jets.
Stakeholders Weigh In on Regulations
The FAA published an advanced notice of proposed rulemaking in February 2010 to begin the process of writing the new regulations mandated by Congress. In July 2010 the agency created the First Officer Qualifications (FOQ) Aviation Rulemaking Committee (ARC). Participants included the Regional Airline Association (RAA), Aviation Accreditation Board International (AABI), NBAA, National Air Disaster Alliance/Foundation (NADA/F), Aircraft Owners and Pilots Association (AOPA), Air Line Pilots Association International (ALPA), The Coalition of Airline Pilots Associations (CAPA), Pilot Career Initiative (PCI) and the Air Transport Association of America (ATA). A relatively high number of comments–1,904–were submitted to the proposed rule.
AOPA expressed concern about the lack of available full-motion simulators and the high cost of simulator training. According to AOPA, the University of North Dakota “was quoted $8 million to purchase a Level C FFS. This means UND would have to charge $1,000 per hour to operate the simulator–passed directly to the student. This cost does not include the cost to build a structure in which to house the FFS or the cost to hire staff to operate the equipment.”
AOPA pointed out, “The FAA seemingly did not consider the availability of FSTDs when drafting this proposal. Lack of availability of FSTD time could make this a regulation for which compliance is impossible.” While many Part 121 airlines have access to leased or owned simulators, pilots who plan to fly for Part 135 operators or simply want to earn the ATP will have to work with a Part 142 training center. However, simulators at these centers are booked way in advance and fly 24/7 to meet training demand.
Training Providers Prepare for Mandate
Training provider SimCom Training Centers is well aware of these issues and is already working with some regional air carriers that are concerned about where their upcoming pilots will obtain the training needed to meet the new regulation. “We have a team that’s in the process of putting final touches on what our course would look like in terms of the ground and simulator component,” said SimCom president Eric Hinson.
While SimCom does have a Saab 2000 FFS that meets the 40,000-pound threshold, a FFS for a swept-wing jet such as the Hawker 800 may be better suited to meet the intent of the new regulations, he explained. “If you read through the language,” he said, the FAA’s “primary concern is a device that can adequately simulate the environment you would see on a swept-wing jet. We’ve looked at some of our programs and believe several of our business aircraft would meet that need. Anything in the 20,000- to 30,000-pound category with a 0.7 to 0.8 Mach cruise is going to be pretty similar to the flight characteristics they’re looking for. We’re confident that we’ll be able to satisfy the requirements that the FAA has and in no way diminish the capability from a training perspective, but we do need to have discussions with the FAA.”
If the FAA is willing to work with training providers such as SimCom that can show the logic of meeting the rules with a deviation for the weight threshold, he said, “then I think we will have adequate capacity.”
As for the issue of how much such a course will cost, SimCom “is in the middle of costing that now,” Hinson said. “We have to come up with the most cost-effective way to meet the requirement, to impart the knowledge the FAA has identified it wants [pilots] to have, not just pass a test. We know we need to do that in the most cost-effective manner we can. We’re exploring a variety of ways to do that.”
CAE is planning to offer a course that will allow clients to comply with the new requirements. The company will be submitting its proposed curriculum to the FAA in the following months after which it will finalize course details and pricing. “Our goal is to provide a comprehensive and cost-effective solution to our customers in the first half of next year,” said the company.
Certainly other companies besides the big-three simulator training providers could develop their own training programs. One such company is Aviation Performance Solutions (APS) of Phoenix, Ariz. APS already offers UPRT training in a combination of an Extra 300 aerobatic airplane and a CAE regional airliner FFS. “Our plan is to provide this course at both our Phoenix and Dallas locations,” said APS president BJ Ransbury. “Our preferred devices will be appropriately qualified CAE simulators at both locations. We haven’t zeroed in on a price.”
There is much more to this new regulation and how it will affect the aviation industry, and Advisory Circular 61-138 is a useful guide to standards that the FAA will likely apply. It should be noted that another element that will add to the cost of providing these courses is the instructor. According to the FAA, instructors must not only hold an ATP with an airplane category multiengine class rating but must also have two years of airline experience.