Pilot training, including CBT/EBT and automation risk, were on the agenda at ICAO’s A40 gathering. Mario Pierobon describes the highlights for the civil aviation training community.
At the 40th session of the International Civil Aviation Organization’s (ICAO) triennial Assembly in Montréal in fall 2019, agenda items included the multi-pronged approach to enhancing pilot training and competency during a period of anticipated growth and complexity as well as pilot training improvements to address automation risks.
ICAO’s complete “work programme”, which is provided to its Member States to guide their continuing and future work, suggests significant regulatory activity in the areas of CBT and EBT and the reduction of flight crew automation dependency.
EBT Regulatory Framework
EASA has been focussing for several years on the development of an evidence- and competency-based framework for flight crew training in Europe with the aim of improving training delivery with more training and less checking. “The objective of EBT is to seek continuous improvements along the pilot career with an emphasis on non-technical skills. A special effort has to be made to develop a sufficient population of instructors who can correctly apply the principles of CBTA in a harmonised manner,” said EASA. “Rulemaking activities aim to increase the supply of competent flight instructors and to gradually introduce the competency-based concept for the qualification of instructors. Mixed EBT was published in December 2015 with the amendment of Part-ORO (ORO.FC.230). The Opinion for a baseline EBT in December 2019 (www.easa.europa.eu/sites/default/files/dfu/Opinion%20No%2008-2019%20%28A%29.pdf) is a next step to lead to the progressive implementation of enhanced EBT and adopt an operator’s conversion course and EBT type-rating course with a further Opinion planned to be published in the third quarter of 2022.”
Similar initiatives are being implemented internationally. ICAO created the competency-based training and assessment (CBTA) task force in early 2017 with teams in multiple disciplines including flight crew, maintenance and air traffic control training.
“The work of the task force did recommend expanding the use of CBTA to the type-rating and that was approved by the Commission this year. Expanding to other licenses such as the private, commercial, and airline transport pilot (ATP) was considered out of the scope of the task force,” said the US FAA. “However, this recommendation to consider adopting CBTA for licenses was the subject of discussion at an ICAO pilot training and licensing exploratory meeting held in Montreal in July 2019. There was global interest in further exploring the concept. In pilot licensing, one of the challenges is separating the discussion about CBTA, its framework, and why it should be seen as a better way to train pilots and the discussion of minimum flight time or aeronautical experience requirements.”
“The CBTA taskforce is developing guidance material for the recently approved amendment to PANS TRG for States, to support the implementation of this methodology, designed to improve training and enhance safety overall,” said Capt. Miguel Marin, Chief of ICAO’s operational safety section. “EBT was designed using the CBTA methodology to contribute to the professional development of pilots, improve the quality of operations, and consequently enhance safety in operations. The application of a competency-based training and assessment methodology supports the development of an efficient, standardized pilot training programme, fostering capacity-building and a mobile workforce.”
Evidence and competency-based training are embodied in the ICAO Manual of Evidence-based Training. At the moment, evidence-based training only applies to airline training programmes for aircraft that carry 30 or more passengers. “To date, over 50 airlines have implemented an evidence-based training programme. Canada has a similar model in place called Advanced Qualification Programme (AQP).”
Transport Canada Civil Aviation (TCCA) says it is “reviewing evidence-based training to examine possible implementation options that will benefit the training practices for all segments of commercial aviation.”
According to the FAA a majority of US airline pilots are trained using AQP, which was introduced nearly 30 years ago. “AQP is a data-driven program that embraces a CBTA framework. It uses training and evaluation data collected to continuously assess the training program and also uses multiple data sources to influence changes to the training program,” said the FAA. “When it comes to basic certification, there is nothing from a regulatory perspective that would prohibit a US training provider from adopting such a framework and using data to continuously assess the program and the success of its operation and make changes to its training program, including instructor training, as needed. The FAA’s work in transitioning from the Practical Test Standards (PTS) to the Airman Certification Standards (ACS) for the various certificates and ratings defines pilot competencies that will be assessed during the knowledge and practical tests.”
ICAO’s Marin emphasizes that automation and manual handling already form an integrated aspect of pilot training. “Additional issues with automation dependency have recently been brought to ICAO’s attention and we are currently in the process of determining the best course of action to address interdependency between automation and manual handling as well as the impact of a sudden automation loss and the dependency on manual handling skills,” he said.
At the 40th ICAO Assembly, it was the US and Canada, together with Peru and Trinidad & Tobago, that presented a paper seeking further study of the issues surrounding automation in the flight deck that could benefit the safety of flight operations worldwide.
“We advocated that the study should include assessing the degree to which over-reliance on automation may be occurring globally and reviewing the methodologies currently employed by States and industry to ensure pilots maintain necessary skills to manually control the aeroplane, especially when the automated system does not work as intended or it does not work well in an operational situation,” said the FAA. “We gave support for a recommendation that came out of the July 2019 ICAO personnel training and licensing exploratory meeting to create a panel that would undertake this initiative and it received overwhelming support in the Technical Commission. The ICAO Council is now tasked to take the appropriate next steps to support this new initiative.”
TCCA recognises that there has been an increased regulatory and industry awareness of automation dependency. “We have recently introduced a policy that requires a pilot to demonstrate competency in ‘hand-flying’ during annual pilot proficiency checks,” said TCCA.
The FAA has highlighted the importance of maintaining proficiency in manual flight operations by engaging the industry in work groups and by publishing guidance to operators. “The Flight Deck Automation Working Group submitted a report to the FAA in 2013, which addressed flight crew management of automation and provided recommendations regarding manual flight operations,” said the FAA. “Currently, there is a Flightpath Management Work Group within the FAA’s Air Carrier Training Aviation Rulemaking Committee that continues to address many of the issues related to flightpath management and provide recommendations to the FAA in this area.”
The FAA completed rulemaking in 2019 that requires all air carrier pilots to satisfactorily complete initial and recurrent training, which includes an additional six manual flying manoeuvres that must be performed in a specifically qualified full flight simulator. These manoeuvres include manually flown arrivals and departures, manually flown slow flight, recovery from a bounced landing, upset prevention and recovery, and recovery from full stall. Further, the pilots must also satisfactorily perform loss of reliable airspeed, which reinforces the need for pilots to ignore erroneous indications and manually fly the aircraft with sole reference to pitch and power displays.
The FAA has also published two Safety Alerts for Operators (SAFO) concerning manual flight operations. These SAFOs encourage operators to create opportunities for pilots to maintain and improve their knowledge and skills needed for manual flight operations and suggest additional manual flight manoeuvres that could be incorporated into an air carrier training program.
Automation dependency and resilience are addressed in several EASA publications. “We have published two decisions (2015/022/R and 2015/023/R) on crew resource management (CRM) training. New or expanded items are, among others ‘automation and philosophy on the use of automation’ and ‘resilience’,” said EASA. “EBT itself accounts for technological innovations and changing operational environments; it puts more emphasis on non-technical human factors and improves efficiency and effectiveness of training.”
To target automation dependency EASA is currently supporting the implementation of the UPRT requirements introduced by Regulation (EU) 2018/1974 (amending Regulation (EU) No 1178/2011) with the objective to introduce different ‘levels’ of UPRT at various stages of a professional pilot’s career. “This latest evolution [became] applicable in December 2019 and will cater for basic UPRT to be integrated in all CPL and ATPL training courses as well as the MPL training course, an advanced UPRT course to enhance the student’s resilience to the psychological and physiological aspects associated with upset conditions, class- or type-related UPRT during class- or type-rating training to address the specificities of the relevant class or type of aeroplane,” said EASA. “It is expected that UPRT will also equip EU pilots with the needed competencies to face unexpected events including in connection with automation dependencies and will ensure upset prevention and manual recovery when required.”
There are also aircraft design recommendations to reduce the risk of flight crew automation dependency. Indeed, the certification standards are designed to meet the goal of ensuring an aircraft performs its intended function safely.
“Some factors could be considered to improve aircraft systems design as part of the certification guidance, including more robust systems to decrease the probability of failure, a fail-safe criteria and more adequate system redundancy, a design that does not require exceptional piloting skills, and a design that does not create misleading and nuisance indications which impact crew workload,” said TCCA.
Based on lessons learned, the FAA has developed and updated regulations and guidance material, specifically 14 CFR 25.1302 (installed systems and equipment for use by the flight crew) amendment. 137 (AC 25.1302-1), 14 CFR 25.1322 (flight crew alerting) amendment 131 (AC 25.1322-1), and 14 CFR 25.1329 (flight guidance system) amendment. 119 (AC 25.1329-1C) to improve flight crew interaction with the increasing automation of flight decks.
“With a reliable automated system, these regulations require that that the automated system provides clear and unambiguous information to the flight crew and provides appropriate alerts to facilitate flight crew awareness and timely action during failure conditions,” said the FAA. “Dependency on automation at the expense of maintaining flying skills is never intended and depends upon appropriate training and operational procedures and practices. These design regulations and guidance for automated systems require that automated (and other) systems operate in a clear, consistent and understandable manner in flight.”
The Air Carrier Training Aviation Rulemaking Committee has defined ‘flight path management’ as the planning, execution, and assurance of the guidance and control of aircraft trajectory and energy, in flight or on the ground.
“Its flight path management working group focuses on operations and training of flight crews using the design principles and is making specific flight crew training and operational recommendations. We will continue to collect operational and safety data, conduct research into human-machine interfaces, and evaluate recommendations in this area to make further improvements as necessary,” concluded the FAA.