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Further Comment On Proposed Training Standard Invited

On Behalf of | Nov 14, 2021 | Accidents & Incidents, Articles, Briefs, Regulatory & Other Items


In laying out revised training requirements, the FAA appears to be clarifying some issues while slipping, sliding and reducing many training needs. Using the perverse logic of cost-benefit, if there were no accidents the need for improved training would vanish, even in the face of existing shortfalls in training and the growing lack of experience in the pilot ranks.

Training conditions pilots to the demands of their job, but the FAA seems reluctant to demand tightened standards of training

Significant Regulatory & Related Activity


20 May 2011                     Federal Aviation Administration (FAA)

FR Doc 2011-10554       Docket No. FAA-2008-0677

Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers; Supplemental Notice of Proposed Rulemaking (SNPRM)

This 200-page initiative stems from a 2009 NPRM on the same subject which generated about 3,000 pages of detailed comments/objections. The FAA went back to the drawing board and came up with this SNPRM, which the agency maintains will accomplish the desired goals:

“This SNPRM integrates these new requirements with the original NPRM and lays out a process by which significant safety benefits can be achieved. This SNPRM does this through a focus on the requirements of the [Airline Safety and Federal Aviation Administration Extension A ct of 2010], an effort to address or partially address 28 NTSB [National Transportation Safety Board] recommendations, and adjustments to the original NPRM based upon public comment.”

Attention is called to the use of artful phrases:

New requirements does not necessarily mean that aircrew and dispatcher requirements are higher than in the original NPRM and, in fact, they may be lower.

Partially address NTSB recommendations means only a half-hearted attempt at implementation which may well result in the NTSB eventually classifying the FAA action as “unacceptable”.

Based upon public comment implies the original NPRM stirred up a hornet’s nest within the airline industry and the FAA is now backtracking with the hope of gaining at least reluctant acceptance of its modified proposals.

This is the reality – not a hint of which is reflected in the hype of top officials.

Transportation Secretary Ray LaHood said that “This proposal will make U.S. pilots and other crewmembers even better-equipped to handle any emergency they may encounter.”

The pilot enters a world of automation and routine where training is critical to his response should anything go wrong

Randy Babbitt, head of the FAA, proclaimed that “The FAA is proposing the most significant changes to air carrier training in 20 years. This is a major effort to strengthen the performance of pilots, flight attendants and dispatchers through better training.”

The ‘office’ is full of pilot traps that may catch a poorly trained aviator completely off guard

The changes reflect initial and recurrent training (in flight, in simulators, in the classroom) for pilots and flight attendants. The proposed regulation contains, for the first time, training requirements for dispatchers. The original NPRM spelled out in considerable detail the training for each subject and the frequency of recurrent training.

For example, in the event of ditching, the pilot must demonstrate an “awareness of the time requirements for cabin crew to prepare the cabin.”

For dispatchers, the original NPRM spelled out the number of hours required for both initial and recurrent training in such things as “briefing during the changeover period between an aircraft dispatcher coming on duty, and the aircraft dispatcher going off duty.”

In the NPRM, the FAA estimated the 10-year cost of implementing all training and record-keeping requirements to be $372.7 million. This estimate was probably low, as the training requirements were comprehensive and the cost per year works out to be a paltry $37 million.

For Part 121 and Part 135 operators (scheduled and on-demand carriers), to whom the NPRM was directed, the 10-year benefit – in terms of accidents avoided – was estimated at $737 million.

Based on industry responses to the NPRM, in the SNPRM the FAA has increased the cost of the initiative and reduced the benefits, although being careful to make sure benefits were greater than costs. A summary of the FAA’s cost-benefit estimates appears as follows:

Change from 2009 NPRM to 2011 SNPRM(In millions of $)
Benefits $ 737 $ 445 – $292 (- 39%)
Costs $ 372 $ 392 + $ 29 (+ 5%)
Benefit-cost ratio ~ 2/1 ~ 1.1/1

With another two years to pick away at the FAA’s proposal, the industry may well increase costs further, wiping out any perceived cost-benefit advantage and, thereby, nullifying the entire proposal.

While a detailed review would require a line-by-line analysis, one particular paragraph in the SNPRM suggests that standards have been relaxed to accommodate the airlines:

“In the NPRM, the FAA proposed to require 8 hours of training and evaluation for pilots in recurrent job performance training. However … the FAA believes that all of the recurrent training and evaluation task requirements can be completed in less than the 8 hours set forth in the NPRM [and] the required tasks for a recurrent evaluation could be completed in 3 hours and 29 minutes …

“In the SNPRM, the FAA has revised the minimum programmed hours for recurrent training from 8 hours to 6 hours.”

Given the enormous demands on simulator time, a 30% reduction in recurrent training, especially in light of the future loss of pilot experience, appears to be a convenient fabrication. The suggestion that 8 hours training can be conducted in 3 hours and 29 minutes (the appearance of precision here is bogus, as debriefing alone after such training may take that much time) seems a stretch.

Comments on the SNPRM are due by 19 July 2011. From that date, a further 24 months could elapse before the FAA publishes a final rule on pilot, flight attendant and dispatcher training. Assuming that the original NPRM was a year in preparation, it could take up to five years to get the regulation on the street and as long as three years after that for its provisions to be fully implemented.

Yet, reading through what the FAA proposed originally, one is left with a nagging question: why weren’t these basic training requirements being accomplished all along? Also, if there is a new record-keeping requirement on training, one has the suspicious feeling that the FAA had little in the way of documented compliance with its previous – now deemed inadequate – standards. All of this from an agency which proclaims air safety is Job One; however, the impression is that cost avoidance is the regulator’s primary objective.

The SNPRM suggests the FAA is unsure of how aggressively it should push for tightened and improved training standards. The systematic and built-in delays suggests that the promotion of air travel – rather than the promotion of safety – is the task envisioned for itself by the FAA.