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Audit Initiated of FAA's Pilot Training Requirements (dot.gov)
65 points by infodocket on Feb 10, 2020 | hide | past | favorite | 40 comments

This seems fairly reasonable. One of the criticisms of the Max situation is that the FAA went along with Boeing's plan that only additional minimal training was required. Reviewing those standards seems like a good idea.

> This seems fairly reasonable.

We'll see.

How the FAA works is they come up with a NPRM (Notice of Proposed Rule Making) document, circulate it, and receive feedback.

Likely the airline industry will reply with a push back on the 1,500 rule since they're doomed financially if it continues (US airlines NEVER pay for ab initio pilot training, unlike Europe and Asia.)

As long as Congress is not involved in more regulatory fiascos like the 1,500 hour rule, I'm good.

This big question has to both be whether this has the efficacy to make legitimate change in the industry and also doesn't squeeze out he competition who offer a better replacement for the existing industry.

Few people are accepting the fact that Boeing's sweetheart relationship with FAA is a result of the fact they are largely one of the fee only players in the game.

There's no competitive pressure for Boeing to change behaviour iwth the politicians and regulators in their pocket they have little to fear by going forward with business ss usual.

The fact they are managing to push Boeing to adopt more stringent training is good. I just hope it doesn't just add to the long list of things excluding any entrepreneur from honestly competing with him (just look at Virgin Airlines which was one of the most enjoyable flight experiences getting squeezed out).

Every major regulation in history has had unintended side-effects which frequently offset the benefits of the original plan (because of course they were designed for the entrenched mega-coprp interests of today with little thought of the wider long term effects on the industry).

Thomas Sowell wrote two good books which highlight a hundred examples how these well-intentioned regulations have contributed to the wealth inequality and consumer monopolies both [1] and Basic Economics [2].

Its not a simple as anti-regulation or pro-regulation, but getting the right kind of regulation based on data and with foresight into the unintended implications.

[1] https://www.amazon.com/Wealth-Poverty-Politics-Thomas-Sowell...

[2] https://www.amazon.com/Basic-Economics-Fifth-Common-Economy/...

The FAA training review may be triggered by the Boeing 737 Max crashes, but I wasn't specifically talking about Boeing.

The public misunderstands the role between FAA and Boeing.

Boeing is the ODM, so safety is largely delegated to Boeing. That is necessary because the FAA does not have aircraft designers on staff, and won't, because aerospace keeps advancing.

What is needed is criminal penalties for what Boeing did regarding the inaccurate MCAS FAA filings.

Congressional representatives have at times pursued fraud charges against pilots for various reasons. The problem is that if they do that against campaign donors, then those briefcases of cash will disappear.


To offer something constructive:

1) In American corporate mgmt., discussion and accountability is diffused across multiple teams. Even attempting to use the word accountability is perceived as "a problem."

2) That's compounded when you have complex systems that use both hardware and software. In the case of the 737 MAX, you have external sensors subject to weather and damage, internal wiring and software. In this case it appears the software was outsourced. It would take their best Sr. Engineers to trace through that and say anything definitive. See #1 for why it's not worth it as an employee.

3) Submitting FAA aerospace compliance documents and outsourcing software development may simply be incompatible due to change management iterations and accountability.

So my summary would be that Boeing needs to be re-organized around accountability instead of penny-pinching. That would require turning a huge company inside-out. None of the founders are left. The current CEO has that mandate, but seeing is believing.

> That is necessary because the FAA does not have aircraft designers on staff, and won't, because aerospace keeps advancing.

I don't understand this part. Could aerospace engineers working at the FAA not learn about advances?

In UK financial regulation, the traditional problem is: Competent subject-matter experts at regulators get job offers for ££££ at the companies they're regulating; and anyone who moves the other way or cycles between the two is at risk of 'revolving door' corruption, where they use their position as a regulator to advance the interests of their former employer.

If you're an American aerospace engineer, working for the FAA and specialising in airliners - where is your next job likely to be?

why are us airlines doomed if they pay? it's not part of their current costs, but airlines in other countries manage to survive.

The regional airlines only exist to hire cheap low-time non-union pilots for $18k/year.

There is no reason for them to exist if they have to pay competitive salaries.

It's actually even worse than that - "regional airlines" are merely contracts with straw men. The funding comes from the majors who control them like puppets. Get it now?

You got any sources for this one? I'm super curious about how this works.

I think it cuts both ways, not only have there been issues with the minimum training specified by the manufacturer, but with the minimum training evaluated by the FAA. This shows in what kind of mistakes are being made these days and really shows in general aviation where seemingly more fundamental mistakes are showing up.

> minimum training specified by the manufacturer,

It's rare for mfgs. to set training requirements, as that's the FAA's perogative.

The only mfg. that I know has a training S-FAR is Robinson Helicopter for R-22 and R-44 models because of mast-bumping:


Icon has pre-purchase contractual language requiring all kinds of things, including approved training:


The Robinson S-FAR was because of previous accidents, while for Icon it was due to the litigious nature of US society and the target audience being recreational owners.

Jets usually require a type rating or an FAA Letter of Authorization (LOA.) Same for gross weight over 12,500 pounds.

Fun fact 1: FAA examiners and designated pilot examiners usually watch flights from the ground for warbird LOAs and float plane ratings because those are so dangerous. If the applicant can survive a takeoff and landing in a taildragger with a 1,000 - 2,000 HP engine, that's pretty much all that matters. :)

Fun fact 2: Most pilot certification exams are done by Designated Pilot Examiners (DPEs) who are not FAA employees - they are independent contractors. FAA Examiners seldom do pilot rating exams except for CFI ratings, which I believe are free of charge.

DPEs can make good money as a weekend job - around $1,000/day for 2 exams. (When I did my commercial single, the DPE asked, "How about another rating today, like an add-on?") Ka-ching! :)

There was a weird FAA regulatory wrinkle around 2000 that DPEs were required to hold a current medical, even if the applicant was a rated pilot. (It affected one of the DPEs in Hawaii.) I heard that was changed, but I haven't seen anything in writing, and the FAA generally moves slowly.

Can you elaborate on your reference to GA? Our safety record is far worse than commercial, and always has been, but in general has seen an improving trend until the last year or two which has seen a bit of a bump in the other direction. There have been no fundamental training differences that I'm aware of which would account for that bump, so I'm curious what you may be referring to.

The AOPA has a ton of detailed GA accident graphs for those who may be interested.

It's not unexpected, flaws aside the MAX issues have shown flaws in the way we train pilots, mostly in re increasing airframe complexity.

I'm not sure I see these training issues as a problem with the methods and processes we use to train pilots. Rather, this seems like information which was kept from pilots in order to avoid costly training altogether. The methods we use to train pilots have resulted in consistent safety gains even as the cost to fly for passengers has gone down.

My personal take is that the industry and regulatory incentives which led to the lack of information to pilots is the problem, not the methods by which we do train pilots to handle automation.

I live in Fiji and know a few pilots. Fijian pilots have traditionally sat ATPL exams out of Australia (CASA). To get this ATP License, one needs to pass 7 gruelling theory exams within a 2yr period.

For some pilots this is too difficult, so recently more pilots have been choosing instead to fly to Hawaii and get an American ATPL. Getting an American Air Transport Pilot license takes a single o̶p̶e̶n̶ ̶b̶o̶o̶k̶ theory exam.

The EASA (European) ATPL involves 14 theory exams.

It's a closed book exam, an in-person oral exam, and a high-precision practical flight evaluation. Plus minimum 1,500 hours of experience.

Along the way they've probably taken at least 3-4 other other written/oral/practical exams, including private pilot, instrument, commercial, and multi-engine. And possibly the flight instructor exam as well, since that's a common way to pay for flight training.

Not to mention aircraft-specific type ratings, and biannual flight reviews with a check airman.

I think you're selling the requirements a bit short. It's certainly not easy.

> in-person oral exam, and a high-precision practical flight evaluation. Plus minimum 1,500 hours of experience.

Yeah that's the same everywhere. OK so the exam is closed-book, thanks. I must have heard wrong. The point still stands though.

FAA exams are not open book, see: https://www.faa.gov/training_testing/testing/

Eh... It's more complicated than that. The US ATPs have a few other hoops to jump through beyond the exam. There are ground training requirements and a checkride to high precision standards. The US is also unusual in requiring 1500 flight hours of experience.

> The US ATPs have a few other hoops to jump through beyond the exam. There are ground training requirements and a checkride to high precision standards. The US is also unusual in requiring 1500 flight hours of experience.

It's the same in Australia, hence I didn't mention those requirements. The only difference was the single theory test vs the 7 that CASA requires.

> The US is also unusual in requiring 1500 flight hours of experience.

Not unusual at all. 1500 hours is the standard in most places AFAIK.

> Not unusual at all. 1500 hours is the standard in most places AFAIK.

You're fixating on a number rather than the meaning behind the number.

The US ATP certificate is 1,500 hours, and has been for a long time, but now an ATP is required for US airliner operations. (There is also an R-ATP, starting at 1,000 hours.)

Before 2010 (ie. before Colgan), a commercial multi (about 250 hours) was sufficient for Second-in-command" (SIC) globally. Only the US requires ATP for all stations, and it's because of Congressional "we have to do something."

As a result, all US "regional airlines" (aka union-busting pricks) have either stopped operating, or are in the process of shutting down, since there's no qualified cheap airline pilots.

Having said that, there is a cutout if you attend a Part 141 school: "If you complete a degree in an aviation field from a qualified university, you can get a Restricted ATP certificate, or R-ATP, once you've accumulated as little as 1,000 hours of flight time and are at least 21 years old."

Sadly, the "aviation degree" is a poor choice for most students, as they need a degree in another field like accounting in case they fail their FAA medical, thus instantly ending their pilot career.


"Although it did nothing to address the specific causes of the crash – improper stall recovery technique and pilot fatigue" https://en.wikipedia.org/wiki/Colgan_Air_Flight_3407

The above pilot training scenario is bad, but the airline mechanics situation is far worse. Thanks to our lawyer-driven political system, we've hollowed out the leader in aviation into something resembling a failed African state.

Source: commercially-rated pilot with some ATP training

> As a result, all US "regional airlines" (aka union-busting pricks) have either stopped operating, or are in the process of shutting down, since there's no qualified cheap airline pilots.

Uh, what? Regional airline pilots are not at all ‘Union-busting pricks’. Most are also members of ALPA who represents a large percentage of the major airline pilots as well.

Regional airlines exist because airline management groups were able to get their pilots to relax scope clauses on the smaller side of operations. In many cases these scope clauses became loosened up in bankruptcy. No pilots at regional airlines lobbied for this to take jobs from mainline carriers.

99% of regional airline pilots want to make it to a major carrier. Major carriers practically require a pilot to gain experience at a regional airline before they will consider hiring them.

Regional airlines are a product of airline management and bankruptcy law and you’re practically calling the pilots scabs. You’re blaming the wrong group.

Also, regional airlines have been consolidating which is good for employees long-term (some are facing short-term setbacks in the midst of the consolidation) and for customers who hate riding on tiny regional jets.

Short of a flying-phobia, I can't fathom hating smaller jets or turboprop planes. They're quicker to load, quicker to unload, and often the airports you have access to don't have TSA molesters trying to grope you. The last regional flight I was on was with a Dash 8 and the experience was as hassle-free as riding an intercity bus. It was truly delightful compared to the typical major airline experience.

The newer Dash 8 Q400 isn’t bad. The seats sit lower and the windows are higher so it makes it more comfortable. Contrast that with a CRJ200 or ERJ145 though and you’d see why people dislike regional jets. They’re horribly cramped and uncomfortable.

In addition to the comfort of the plane, regional airlines generally are just less likely to have it together. All of the employees are paid less and expected to do everything for bottom dollar pay. When the wheels start falling off schedule wise they tend to really fall off hard. Think maintenance delays or system wide delays that leave crews behind and in the wrong places.

This is all speaking from a US perspective. Not sure where you were flying to avoid the TSA as any scheduled airline service is going to have TSA or a contracted equivalent in the US.

The flight in question was in the US, with Ravn Air from Kenai Municipal Airport to Anchorage. There was no TSA nor any apparent contracted security; maybe there was a guard lounging around somewhere, but they certainly weren't rifling through people's belongings like the TSA likes to. It was very civilized compared to a major airport.

I have to say, what I saw from Ravn impressed me. A wildfire had stopped traffic on the sole road out of town, the only way out was by air or sea, so that tiny airport was packed with people trying to get out. The airline employees were obviously stressed but remained very professional and courteous. I believe the airline managed to get one or two extra flights scheduled and flown out of town that night, with only a few hours of notice.

Ah, Alaska. It’s a bit of a different world up there. I’m not sure it would compare to flying a regional airline in the lower 48. The vast majority of the airports down here still have some form of terminal and TSA even if you’re boarding a Dash 8. The only way to escape TSA in the lower 48 is to fly on a charter.

Edit: Did some research and found there’s a special exemption on TSA for aircraft over 12,500 lbs but under 61 passengers that most of the companies in Alaska use to avoid TSA. I’m not aware of it being used in the lower 48. Business opportunity?


To be fair, prior to the 1500 hour rule, the insurance companies dictated how many hours were the minimum. I'm not sure I knew anyone who could get into an "ATP" class (what is that, 10+ passenger?) aircraft with less than 800 hours. Depending on how the market was doing, 1000+ hours did not seem abnormal.

Getting that 1500 hours now is usually by instructing students who are trying to kill you on a regular basis or dropping meat missiles on the weekend to build up the time. Not easy flying for sure. I've got a lot of respect for someone who did 500+ hours of instructing. The military guys program is very rigorous for the hours they spend in the air.

I can't wait for things to thaw out enough to do some pleasure flying this Spring.

Thanks, that's good to know. In Oceania (Australia/NZ/Pacific Islands) you can get what's called a frozen ATPL upon completion of all the necessary theory exams. You qualify to attempt the practical flight test to get a full unrestricted ATPL upon completing 1500 hours of (AFAIK) multi-engine jet time.

You need an unrestricted ATPL to captain an airliner, and as a first officer on flights longer than X hours (where the captain is expected to leave his post to rest at some point).

Source: not a pilot, but friends with a couple of them.


The 1500 hour rule was initially instated by the FAA. CASA followed suit but EASA did not for co pilots.

Hopefully this will include the simulators that Boeing outsourced as a profit centre. Trained by the lowest bidder was never going to end well for them.

"Fighting Firmware at 25k Feet" or how I learned to root cause distributed control systems in free fall.

Nothing is mechanical anymore, it is intermediated by an algorithm and servo. Automation, as done in these flight control "smoothing" systems, reduces situational awareness.

Here comes the hammer...

This sounds a lot like a political deflection rather than a hammer. The wording suggests an angle towards foreign "international" standards rather than just domestic. This also subtly passes blame towards pilots and their training rather than the extremely lax airframe certification standards.

There’s a non-zero amount of blame that properly lands on the pilots and their training, IMO.

Failing to acknowledge that would be passing up an additional improvement to safety in the system.

It does, but it's not at all related to what they're talking about here, at least as far as the text describes.

The issue is that large aircraft require an aircraft model specific training program called a type rating which is rather involved and expensive. Both Boeing and Airbus have common type ratings across multiple aircraft models and sub-models to save on training costs for airlines. To do this, they need to maintain a high degree of controls and systems commonality between the types and in this case, they fudged these limitations by adding a system which was a significant departure from the older 737 type and type rating training programs without requiring additional training on the MAX sub-model.

Indeed. Even if we accept that Boeing's malfeasance was the primary issue, we might as well audit the process around how the training material is actually determined, as that is where the biggest, most glaring failure seems to exist.

The FAA claimed they didn't know/weren't told that MCAS was as major as it was. This should help figure what led to the outcome through which their attention was directed away from asking the question that should have been asked.

Season 24 of the bachelor has some serious political effect.

This strikes me as Boeing lobbyists trying to pay people to create doubt. "Maybe it's not the plane, maybe the pilots are inferior to AMERICAN pilots, yeehaw!"

Seems pretty contrary to Boeing fighting tooth and nail to make sure the FAA didn't require a lengthy amount of training.

"One of the company’s big selling points with customers had been that pilots certified for an earlier generation of 737 jets only needed a short computer course to brush up their skills for the Max. Those assurances helped make the Max Boeing’s best-selling jetliner." >https://time.com/5762666/boeing-max-faa-messages-clowns/ >https://www.nytimes.com/2020/01/09/business/boeing-737-messa... >https://www.businessinsider.com/boeing-737-max-employee-call...

I think Boeing is getting smacked in the face by a change in pilot skill levels and areas that has been happening around the world since the 90's.

Boeing is in a really bad position to specify minimum training requirements, since any time they ask for more training requirements of their customers, the customers ask for more money back. So its good that the FAA wants to enhance training requirements.

Based on some of the things that have happened around these two accidents and others recently, I think the increased training should encompass more core skills as well.

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