November 5, 2021, ©. Leeham News: Last week, we looked at our role in creating a competent maintenance activity so our aircraft can be kept airworthy throughout its operational life. The other important part of operational safety is crew training.
We learned that these two parts, keeping the aircraft airworthy with its maintenance and providing adequate training and information to the crews operating the airplane, have a major influence on flight safety. In fact, FAA has found that these parts have a larger influence on flight safety than the aircraft certification regulations.
We, as the OEM, must therefore develop the documentation, curriculum, and training tools so that crews working in the aircraft can fly it safely. This encompasses not only initial training but a continued refresh and check training throughout the crew’s life with the aircraft.
As we work with the operational readiness aspects of our aircraft project, we work with new regulatory branches we haven’t discussed before — Flight Standards. For the FAA this is the Aircraft Evaluation Division (AED) and the Flight Standardization Board (FSB). During this phase of the program we significantly increase engagement with these groups around two key subjects:
Flight Manuals: Under 14 CFR 23.2620 we must produce an Airplane Flight Manual with details about not only operational limitations and performance data, but also information about operational procedures for normal operations as well as abnormal and emergency operations. We also prepare safety-critical information for airplane crews, such as loading requirements. We need to put together our engineering force with our test and line pilots to word the technical data and procedures in a way that pilots can understand. A pilot must understand our airplane’s behavior under all circumstances.
How we write these manuals must be accepted by the regulator’s evaluation team. The reason is, the FAA has about 100 years of experience on what works or not for writing flight manuals. We, as a new OEM, are not guaranteed to have people with such knowledge. We must have the aeronautical knowledge, but the aeronautical “tech” speak about how an aircraft behaves or shall be flown can be very different from how it shall be described in a Flight Manual to a flight crew. The Aircraft Evaluation Division and Flight Standardization Board have people with the required experience to help us with this task.
Training and Simulator Development: Working with the Flight Standardization Board we will need to turn our (at this time draft) manuals into a proposed pilot training program, including how and when it shall use simulators. This includes initial training, any transition training from other types, and recurring training that makes sure the flight and cabin crews stay current during the aircraft’s operational life. The training shall ensure the pilots understand both how to fly the aircraft when everything works as expected, and what to do when things don’t.
A large part of pilot and cabin crew training is devoted to abnormal and emergency procedures. The training includes a combination of ground training (manual study, classroom training, knowledge tests), followed by simulator training where you learn to find the instruments, work the knobbery, and the feel of the controls in different situations. You train the standard procedures such as takeoff, cruise, descent, approach, and landing in different weather conditions in simulators as this costs far less than flight training and gives a better chance to discuss a certain part of a procedure in dept with an instructor (you can push pause and discuss with the instructor in a simulator, not so easy in the air).
When the basic sits, it’s time for training in the aircraft. If the curriculum is well designed the part in the aircraft is more a verification of the training in class and simulator than actual learning the aircraft. For such a training program to be effective, the simulator (governed in the US by 14 CFR Part 60) has to be good, replicating the aircraft experience faithfully. Therefore, we want to partner with experts in this field, as our expertise is not in building simulators. However, we can’t simply hand over the task — the simulator developer will need information from us on the procedures that need to be simulated, and a significant effort is to provide them with the aerodynamic and systems control data necessary for them to accurately simulate the different parts of our aircraft.
There are too many accidents that have inadequate crew information and training as the root cause. Here just two examples, highlighting different aspects of the problem:
How to train flight crews on an aircraft’s systems and how these behave, and how you shall understand what they are doing, was a major part of the controversy around the Boeing 737 MAX accidents.
At first, it was assumed the pilots needed no direct information that a new flight-control augmentation system was added (MCAS). Its normal operation should not be visible to the pilots and the cases where it behaved abnormally should be covered by the basic training of the pilots in recognizing stabilator trim runaway.
The investigation of the accidents showed that these were flawed assumptions. In the operational contexts where the abnormal behavior of MCAS occurred, it was not easy to understand what happened, and crews didn’t recognize it as trim-runaways.
The example shows how difficult the work with manuals and training is. What shall be included, how shall it be described, and how trained. Does the training have to be deep or can it be done with iPad self-taught difference training?
Crew training and the design of the cockpit is also about how to use the fact there are two pilots. The division of work between the pilots during the flight is important and critical in demanding phases like approach and landing in bad weather. The Manx2 Flight 7100 which crashed at Cork airport Ireland in 2011 highlighted several deficiencies in crew cooperation (called CRM, Crew Resource Management) and how the regulator who has issued the Air Operator’s Certificate (AOC) conducted oversight of the AOC holder.
When a new aircraft OEM studies the regulations for what he must provide as manuals and training for his certified aircraft, he thinks OK, should be straightforward. It isn’t. When we work with the regulations around the aircraft we influence something which is deterministic. A system is either correctly designed and programmed or not.
With crew information and training we are working with a very wide, un-deterministic entity. We have 300,000 commercially trained pilots today and we need 500,000 tomorrow. These have different natural abilities, backgrounds, education, value systems, and career paths. How to effectively inform and train such varying recipients of our information is a challenging science.