What does Bombardier Aviation think of the proposed “standardized curriculum (SC) concept for pilot training on Part 135 aircraft? They provided these comments to CAT:
Bombardier Aviation applauds the FAA for forming a working group that addresses this important topic. Ensuring the highest levels of air safety is consistently a top priority across all of civil aviation – from ANSPs, airports and regulators to operators, service providers and OEMs. While it’s fundamentally important to recognize that “one-size-does-not-fit-all” and that Part 135 flight operations are often varied and quite different depending on their respective mandates/missions, Bombardier is generally in favor of a standardized curriculum for pilot training on Part 135 aircraft.
It’s something we have encouraged for some time, as we believe that this approach will have a positive impact on safety. We feel that this approach can contribute toward elevating standards across the board and will favor a consistent output. A standardized approach will also allow for greater flexibility between operators and flight training schools, allowing operators to have access to a wider pool of training professionals who are all teaching the same material, minimizing bias or any complacency that may set in if there is a lack of movement between instructors and operators.
What concerns does Bombardier Aviation have?
Bombardier Aviation cannot speak on behalf of all OEMs, but there are several points to consider.
would be important to find a way to quickly and regularly integrate updates and changes to the standard flight training curriculum. We need to remain agile and responsive to be able to offer the best and most recent instruction to our trainees.
Similarly, we want to signal the importance of evidence-based training – lessons learned in real-world situations. Again, we would want to retain the ability of operators to contribute their evidence-based lessons for a timely inclusion into training situations across the country.
Also, an important part of the training process is to assess decision-making abilities in addition to how well instructions are followed and maneuvers are executed. And this can only be achieved by transitioning from the traditional systems-centric assessment, towards a more situation-centric approach to training and checking. And since this decision-making assessment is often done by individual operators, it’s important that a standardized training takes this nuance into account.
Lastly, as an OEM that demonstrates an ongoing commitment to air safety via the award-winning Safety Standdown seminar, now in its 24th year, as well as strong support and engagement with many industry associations including NBAA, GAMA, EBAA, AsBAA and RuBAA – Bombardier Aviation believes it important to go above and beyond the minimum requirement. We want to ensure that standardization encourages excellence and going above and beyond what is required.
What role should the OEM play in this data gathering?
Real-world situations have always been a key source of learning for the pilot community, either through published accident reports, articles or sharing stories between pilots. Such learning is not formalized, so a standardized approach to data gathering and integration into training curricula would be beneficial to the wider pilot community, but there are some challenges.
One challenge is extracting the right lessons. Recorded flight data, whether from a simulator or an actual aircraft, only describes what happened; it doesn't provide context, it doesn't explain why it happened, and doesn't provide perspective and understanding. These must be gained through analysis. It’s also important to know how to select the most useful and relevant data.
These challenges are where OEMs can contribute. OEMs have unique expertise in interpreting flight data, with specialized knowledge of the aircraft gained through design, certification and flight test activities, and experience through assisting government agencies in the context of accident and incident investigations. OEMs also have visibility on a wide range of operation types, from private flight to air ambulance and more, allowing them to distinguish between lessons for all and lessons unique to certain operational types.
Lastly, it’s important to protect the privacy of the crews from whose flights the data was obtained. While Bombardier favors the distribution of data to help develop training material, it also believes that this must be done with the permission of the crews and with strong privacy protections in place.