The FAA’s recent proposed guidance to develop consensus-based standardized simulator training programs for Part 135 marks one of the most significant changes in training approaches for charter operations in years. It is expected to be the first of a series of anticipated updates, said John McGraw, director of regulatory affairs for the National Air Transportation Association (NATA).
The FAA recently put the draft AC, 142-SCC, Standardized Curricula Delivered by Part 142 Training Centers, out for public comment (closed November 13), a move that McGraw said is the culmination of five years of work.
Recognizing that Part 135 rules for on-demand operations and Part 142 rules for training centers were written “at different times, different eras, and those rules didn’t mesh well,” then-FAA Administrator Michael Huerta tasked the Air Carrier Training Aviation Rulemaking Committee (ARC) with exploring areas where efficiency gains could be found, training could become more effective, and rules could change to improve the safety of Part 135, McGraw said.
The ARC formed an air carrier contract training working group, which then produced more than two dozen recommendations, including calling for the option of a standardized training approach. “It’s the first time in many years where there’s been is a dramatic change in the way Part 135 training can be done, and it was well time for an update,” McGraw said.
Under the standardized approach, the agency is facilitating a collaborative process for manufacturers, operators, simulator companies, and the FAA to jointly develop a standardized curriculum for each type of aircraft for which simulator training is available. “The power of that is everyone gets a say in what that training should look like,” McGraw said.
Easing Paperwork Burden
Upon agreement, the training would then be approved nationally by the FAA. “Rather than individual inspectors and offices individually approving training for a specific aircraft at the operator level, this training would be approved at the headquarters level,” McGraw said. These training packages—which will be developed on a model-by-model basis—would then be available for any operator of those aircraft.
“At first blush that probably doesn’t sound like a big change, but there are a lot of efficiency gains built into that,” McGraw said. For example, he noted that currently, an operator must get a letter from the FAA that verifies each simulator instructor is qualified to do so. “They are constantly going back and forth with paperwork, trying to make sure they have a current letter for a current instructor,” he said. “You can imagine how that becomes a real paperwork nightmare to make sure they’ve got it straight.”
This is a process that can take “weeks and weeks,” he added, noting that last-minute changes in instructors from illness or scheduling conflicts could put an operator in non-compliance.
For operators who choose the voluntary standardized program, “all of that goes away, because everybody who is trained on the standardized curriculum can instruct any operator on that curriculum. You don’t have all this variability and non-standardization that is built into all these individual approvals,” he said.
McGraw believes this will result in stronger training programs, because they will benefit from a collaborative approach, data gathered, and lessons learned from all participants.
In addition, the programs are portable; once pilots have received the standardized training, it is good no matter which operator they fly for, as long as those operators use the standardized training curricula. “Pilots don’t have to repeat training, can get a single robust training program done, and take that with them.”
The standardized packages, however, do not replace training conducted beyond aircraft type, such as indoctrination training on company procedures and culture. Further differences training may be required if a particular operator’s aircraft has special equipment or the operator flies more advanced missions, such as transoceanic flights.
But the standardized program is “the basis. Everything else can layer on top of that,” McGraw said.
As for safety benefits, the new approach will come with a feedback loop that enables continued collaboration and discussions to update the programs over time. If a safety issue continues to crop up with a specific aircraft, then the training programs can be altered to mitigate that issue. Not only can operators provide that kind of feedback, but the training standardization board that creates the programs will also be able to tap into data such as from the Aviation Safety Information Analysis and Sharing (ASIAS) program as they continue to evolve the programs.
McGraw is hopeful that the final guidance will be released by the spring, and then the training standardization board can set up action teams to immediately begin work on programs. “The plan is to start at the top and go for aircraft that are most widely used at the [Part] 142 centers and work our way down,” he said.
The participants in the efforts have already conducted two separate dry runs to see what such an effort might entail, he said. “It wasn’t as burdensome as we envisioned,” he said. “In fact, [participants] learned that they came to agreement fairly quickly and found some advantage in learning what others were doing.”
He estimated that such an effort may take a month or so for the initial programs and maybe up to a couple of years for most aircraft. “We’re trying to tackle the biggest chunk of training first.”
He calls the standardized approach a win-win-win: Part 142 centers reduce their paperwork and can focus on quality; operators also see efficiencies in training and can focus on other training aspects; and rather than worrying about paperwork, the FAA can focus on “real safety risks” that might arise. “Everybody gets a benefit out of this,” McGraw noted.
Industry participants have agreed to jointly reach out to the industry through social media, webinars, town halls, and other means to explain the changes and the benefits to the operators over the next year, he said. One of the first efforts was the joint NATA/NBAA press release issued in October after the proposed guidance was released.
This guidance is the first of a number of actions McGraw anticipates to result from the working group. “There are a number of efficiency gains that will come out a little at a time,” he said, such as changes to who can give check rides. This is an area where there’s a lot of angst in the industry because of the length of time required to arrange check rides, McGraw added.
Among other significant changes on the horizon is enhanced scenario-based training for recurrent training. Rather than providing only the same “canned approach” for training involving the same maneuvers every time, pilots will also be handed scenarios specific to their operations. This includes regular departure and destination airports and common weather patterns. The pilots will plan those flights. Then during the training, unexpected events will be folded into the training and pilots will be given the opportunity to test their mitigations. Such an approach can enable trainers to streamline programs, and possibly reduce the amount of time spent on certain procedures that aren’t problematic.
“That will be a much more effective way for pilots to be refreshed,” he said, adding, “We think that will be the next major change to come out.”
All of this will be data driven. “Modern aircraft have a ton of data that’s readily available. Data is going to provide a role. The time couldn’t be more perfect.”
Most encouraging to McGraw is the dedication and the resources that the FAA and the industry have put toward these training changes. “It has been given a high level of focus.”