Jan 3, 2019
NBAA recently submitted comments on the FAA’s draft Airline Transport Pilot (ATP) and Type Rating for Airplane Airman Certification Standards (ACS) in which the association encouraged the shift toward scenario-based training and greater clarification on pilot proficiency requirements under 14 CFR 61.58.
The proposed revisions followed recommendations from the ACS Work Group of the Aviation Rulemaking Advisory Committee tasked with creating an ACS for type rating and ATP training integrating the knowledge, risk management and skill requirements needed to safely operate high performance aircraft in an increasingly complex National Airspace System.
“NBAA members have long wanted to move beyond ‘cookie-cutter’ maneuvers-based training standards,” said working group participant Robert Wright, president of Wright Aviation Solutions and a member of the NBAA Safety Committee. “Operators want more scenario-based training, tailored to their specific operation and addressing the safety issues they’re most concerned about.”
While the FAA’s proposal encourages such real-world instruction, “the ACS and 14 CFR 61.58 still refer back to testing by the rote maneuvers required for initial training,” Wright added. “NBAA’s comments seek further guidance on how the move towards real-world training scenarios will be carried through, especially during recurrent training events.”
The proposed rulemaking also calls for improved risk management proficiency standards, in line with previous ACS publications. However, NBAA noted the agency hasn’t specified how instructors should teach practical risk management, or methods by which FAA inspectors, designated pilot examiners, proficiency pilot examiners and training center evaluators may assess proper risk management during practical testing and proficiency checks.
“Our working group drafted such guidance, including language from NBAA’s Risk Management Guide for Single-Pilot Light Business Aircraft, and forwarded those recommendations to the FAA,” Wright said. “We hope to see those recommendations in the final ACS or a subsequent publication such as the Aviation Instructors Handbook.”
Brian Koester, NBAA senior manager for flight operations and regulations, noted the recommendations continued the mutually beneficial dialogue between regulators and the industry towards the shared goal of improving aviation safety.
“NBAA has been involved with the ACS working group since the beginning,” Koester said. “We hope our comments will help bring about more effective and realistic training standards for all operators, including those in business aviation.”