After the initial startle effect of the Covid-19 impact on aviation, EASA and industry experts set about the task of sustaining aviation operations. Mario Pierobon reports on their rapid reaction and outlines the ongoing agenda of regulatory updates.
“The scenario that we’ve been facing, that we are still facing, can only be described as apocalyptic”, said Giancarlo Buono, IATA Regional Director, Safety & Flight Operations, in the EASA Update Panel presentation at CAT’s Global Airline Training & Simulation - Virtual conference (Global ATS-V) last month. “We very soon realized that exemptions from the authorities were needed to overcome the almost total halt to the operations… and, as soon as the facilities were accessible, to a certain extent, to restart training.”
“We need legal certainty with regard to the regulations”, he added, “but we also need to be realistic in terms of what can be achieved or what cannot be achieved in a certain situation. We had from the authorities some flexibility in regulation, and this needs to continue to enable us to recover the system.”
Jani Hottola, Special Advisor for CAA Finland transport and communications agency, Traficom, described how the industry and the European Union Aviation Safety Agency took remarkably quick action. “From Friday to Wednesday, from zero to publication”, he summarised the Covid-19 task force creation in March of an initial “exemption template” for regulators and operators to follow. “This is the time that we reap the harvest that we’ve sown with SMS, change management, and so forth.”
“EASA realised that the continuity of commercial operation was in danger, and despite the widespread suspension of flight across Europe, it was paramount to safeguard the main aviation operation and to assure at least the continuation of basic essential services to European citizens”, noted Francesco Gaetani, EASA Air Operations Implementation Section Manager.
In the context of the initial wave of the Covid-19 outbreak, during March and April, EASA was asked by the European Commission and member states to review some of the pending or recent rule adoptions with a view to postpone to alleviate stakeholders from having to implement them during the challenging pandemic period. However, according to Jesper Rasmussen, Director at EASA Flight Standards, “In regard of pilot and cabin crew training there was no need identified to postpone and it was agreed that states could instead use exemptions to defer applicability on a case-by-case basis, and some states opted to postpone applicability of sailplanes and balloon and certain PBN training requirements.”
It quickly become clear, though, that due to travel restrictions and inaccessibility of training facilities, there was an immediate need to support industry with extension of various validity dates. EASA, in close collaboration with the national aviation authorities, developed exemption templates to support industry, subject to mitigations. In addition, EASA and NAAs developed guidelines to enable more use of virtual and remote training, especially for theoretical knowledge instructions.
“Since the beginning, EASA was hosting virtual meetings with NAAs and industry stakeholders to collect feedback on the impacts of Covid-19 and monitor the situation in the field with a view to support where possible”, Rasmussen told CAT.
Subsequently, further guidelines were developed on flight crew recency requirements. Guidance material is under development based on data collected through EASA´s industry advisory bodies to maintain the proficiency of aviation professionals who may lose currency due to not being able to perform their work duties. “EASA in collaboration with NAAs developed guidelines to support operators with managing flight crew recency requirements in a safe and legal way”, says Rasmussen.
EASA issued Covid-19 guidance to all sectors in the aviation industry. These include:
- Guidelines for handling exemptions from crew training and checking requirements in the field of commercial air transport operations under Article 71 of Regulation (EU) 2018/1139 (The Basic Regulation).
- Cabin Crew Recurrent Training.
- Guidance for allowing virtual classroom instruction and distance learning.
From a training perspective, the main change is that training organisations were able to achieve approvals to deliver distance-learning courses that were previously taught at learning centre locations. However, Buono told the Global ATS-V audience, “We’ve seen quite a slow acceptance from certain competent authorities with regards to virtual classroom. It is of extreme importance that virtual classrooms are authorised and enabled as soon as possible and are accepted by the authorities.”
“Many pilots only show up at the learning centre for their simulator training, reducing the time they have to spend on location”, says Steve Gross, Senior Vice President of Sales and Marketing at FlightSafety International. Pilots now have the option of completing all recurrent theoretical training online via the FlightSafety LiveLearning platform. “Regardless of currency, every pilot receives the training required to demonstrate proficiency in all required areas. We offered one-on-one training over the internet for specific pilot programmes as well as our list of over 130 separate eLearning modules that increase the customer’s proficiency in areas such as RVSM, international procedures, hazardous material (do not carry), Pratt & Whitney engine courses, and others.”
According to CAE’s Chris Ranganathan, Chief Learning Officer, there are two main strategies to implement about training in the current global pandemic situation, depending on whether pilots are still employed or are on furlough. To maintain currency while still employed by airlines, key is refresher training targeted at retaining key knowledge: “This can be delivered through a blend of instructor-led and self-directed learning opportunities, with even the instructor-led training in many instances being conducted in a virtual classroom setting.”
Ranganathan continues: “Another important point is simulator training. Airlines can use a mix of knowledge and skill training programmes to keep their pilots current. The content of both knowledge and skill training programmes is determined by the length of time away from active flying, or the last training event; most airlines are adapting this content based on feedback from safety data gathered from the initial line operations restart.”
CAE is providing training to widebody airline pilots who have been furloughed. “Most of them are looking to obtain a type rating on a B737 or A320, as they believe demand in domestic travel will lead the recovery. We have also had pilots look for opportunities as simulator instructors and some look to return to their roots as primary flight instructors”, he says.
When the pandemic first hit Europe and lockdowns were introduced, FTEJerez used its online campus to continue with the delivery of ground school lessons. “Once the restrictions were lifted in Spain and students could return to campus, the changes that were implemented were all geared toward reducing risks to the minimum. For example, the number of students per classroom was reduced to guarantee social distancing and strict safety and hygiene measures are in place, including disinfecting simulators and aircraft between sessions”, said Oscar Sordo, CEO at FTEJerez. “Industry-wide, airlines have interrupted the commencement of any new cadet programmes; however, most of our airline partners have been in touch with their cadets and have maintained their sponsored and mentored students in training.”
From FlightSafety’s perspective, the main regulatory changes that have come into effect the past couple of years have been the CS-FSTD(A) Issue 2 requirements and all the new mandatory Upset Prevention and Recovery Training.
“It is now mandatory to include the required UPRT manoeuvres into all training courses, initial and recurrent. Additionally, new initial type rating course prerequisites came into effect, requiring pilots who apply for their first initial TR course in multi-pilot operation to meet the advanced UPRT requirements of FCL.745.A”, explains Gross.
“We provided on-going implementation support to the aviation authorities for UPRT, including Issue 2 and the KSA100 concept for the ATPL/CPL theoretical knowledge courses”, says EASA’s Rasmussen.
Gross observes that even though there was a ‘push’ from certain smaller operators to reduce training requirements and even allow training in ‘lower certified training devices’ before the current global pandemic, this did not really take off.
“The regulatory requirement did not change for the operators and most are conscious about safety and do not want to reduce training due to the inherent operational safety risk. So really there was no change in this respect”, he says.
“It was interesting, though, that following the Air France 2009 accident, there was a huge push for more training in the area of UPRT, with the follow-on of the very expensive Issue 2 upgrade requirements for all FFSs; on the other hand, one NAA and some smaller operators were pushing for reduced training in lower qualified training devices that were not able to simulate many of the mandatory training requirements. Now this push is on standby”, Gross relates.
Rulemaking Marches On
Crew training is a thoroughly regulated domain of the aviation industry, rightly so considering the high stakes of what crew training concerns. As the industry develops, technology matures, new concepts are introduced and totally unexpected events happen, rulemaking related to crew training must necessarily follow the same path of change.
In recent months newly introduced rules by EASA have included:
- the ‘evidence-based training’ (EBT) concept through EASA Opinion 08/2019 (currently being prepared for a vote and likely applicable from the Q2 2021);
- new requirements for the general aviation domain covering the basic instrument rating (Commission Regulation (EU) 2020/359);
- balloon and sailplane requirements through Commission Regulation (EU) 2020/357 and 358;
- some ‘old rules’ were revised, covering mainly editorials to previous amending regulations, and some training solutions for PBN approaches to enable the operation of legacy aircraft through Commission Regulation (EU) 2020/359;
- introduction of so-called delegated acts for the acceptance of third-country pilots through Commission Regulation (EU) 2020/723”.
Thomas Leoff, Manager of Training Standards at Lufthansa Aviation Training, observes that EASA has started RMT.0194 through which the regulations concerning instructors and examiners will be amended. “The overall goal of this rulemaking task is to introduce competency-based training and assessment as a new paradigm. This is in line with ICAO’s revised strategy concerning training”, he says. “This initiative is crucial as a first step to prepare the instructors and examiners in the function as multipliers in the pilot training system.”
“RMT.0194 ensures an adequate supply of competent instructors. We are revising the instructor requirements with a view to simplify and more proportionate requirements and introduce an alternative competency-based instructor training course”, says Rasmussen.
RMT.0196 – expected as part of a Notice of Proposed Amendment (NPA) before the end of 2020 – is concerned with the use of FSTDs and enables fully the ICAO ‘task-to-tool’ concept, also known as the ‘FSTD capability signature (FCS)’. “The proposed amendments cover the rules for organisation and authority requirements, including a revised FSTD qualification certificate and a new equipment specification list, as well as CS-FSTD(A) Issue 3, incorporating ICAO 9625 elements”, notes Rasmussen.
The main purpose of RMT.0196 is to incorporate in the EU regulatory framework elements from ICAO Doc 9625 regarding the use of FSTDs, including to support the training up to the stall, as well as the new UPRT requirements as introduced through Regulation (EU) 2018/1974; to review the technical requirements for training devices to reflect their actual capability and technology advancement in support of introducing the ‘task to tool’ concept for aeroplanes; and to introduce new certification specifications in CS-FSTD(H) – helicopters – including special conditions for vertical take-off and landing (VTOL) requirements.
It is further aimed at developing more proportionate requirements for operators using FNPTs and other simulation training tools.
In addition, the task is aimed at developing appropriate standards for new technologies including virtual reality, off-board instructor operating station, and secondary motion systems.
New technology is also fostering a range of new training devices based on VR and artificial intelligence which can be tailor-suited to pilot training. “The development of such devices to enhance safety is also supported by the costs and the recent travel bans due to the Covid pandemic that are limiting the access to full-flight simulators”, says Rasmussen.
RMT.0599 provides an update of ORO.FC and addresses general editorials across ORO.FC, with an emphasis on better aligning FCL and OPS training requirements for helicopters and non-commercial complex motor-powered aeroplanes.
RMT.0678 on general aviation introduces new technologies, such as pipistrel and electric propulsion.
EPAS 21-25 Expected Soon
The need to adapt pilots’ competencies to the evolution in automation still remains necessary to maintain a high level of safety. “Competency-based training and assessment (CBTA), such as EBT, focuses on a finite number of core competencies that should allow a pilot to manage situations in flight that are difficult to foresee, due to increasing complexity, and for which the pilot has not been specifically trained”, says Rasmussen.
Indeed, the various rulemaking activities have been re-prioritised to suit the new situation as needed. However, the basic strategies like introduction of CBTA, new developments in the domain of training devices and updates of regulation are still followed, according to Leoff. “The publication of the next version of EASA’s European Plan for Aviation Safety (EPAS) 2021-2025, which is in its final stages of development, will provide insights in the crisis-induced amendments when compared to the actual version”, he says.
According to CAE, despite the short-term decline in the number of active pilots, the civil aviation industry will still require hundreds of thousands of new pilots over the next decade. “Our analysis shows that the fundamental factors influencing pilot demand prior to the Covid-19 outbreak remain unchanged. Age-based retirement and fleet growth were, and will still be, the main drivers of pilot demand. To that point, commercial aviation and business aviation markets are forecast to continue growing over the next decade with over 11,000 additional business and commercial aircraft joining the active world fleet during the next 10 years”, says Ranganathan.
“Ultimately,” concludes EASA’s Rasmussen, “the trend in aviation has historically been upward. We therefore aim to continue to adapt and modernise the pilot training requirements to the needs posed by the changing environment.”