“We will eventually allow EBT baseline for helicopters, but it will take five years,” says EASA’s Francisco Arenas Alvariño. Mario Pierobon describes the process to get there.
In the aviation community there is near-unanimous consensus that competency-based training and assessment (CBTA) represents the ‘gold standard’ for training in several professional aviation domains. In line with this consensus, the introduction of evidence-based training (EBT) and the implementation of best practices across the European aviation community has been in the making for several years.
While in the fixed-wing part of the air transport business, EBT has been introduced by several international airlines, it is an established form of crew training, and it has a very comprehensive regulatory framework, in the helicopter community there is still progress to be made. Nevertheless, the trend is set for EBT to be consistently embraced by helicopter operators as the reference standard for crew training.
Concept Paper Outlines Helicopter EBT
In May 2022, further steps were taken by the European Union Aviation Safety Agency (EASA) towards the implementation of EBT for helicopter operations. EASA published a ‘Helicopter EBT Concept Paper’ as part of its rulemaking task (RMT 0599) that builds the case for extending the regulatory framework into helicopter operations by setting out the baseline for a helicopter training programme and the different options available.
In the concept paper, EASA points out that existing international standards and regulations for helicopter pilot training were originally derived in response to accidents involving early-generation jet aircraft. “Whilst some elements of helicopter operations are included, they have in essence been ‘built–on’ additions to the core programme, usually in the form of manoeuvre-based practices. Standards have remained virtually unchanged since inception,” says EASA. “During the same period, progressive changes in aircraft design, including the developments in automation, system integration, reliability and significant changes in the operating environment have demonstrably improved operational safety, but also revealed new operational challenges.”
The assertion that the perpetuation of historical airline flight training regimes leads to less-than-optimal output is supported by the helicopter community, as is the implementation of change in both the regulation and development of recurrent airline pilot assessment and training, affirms EASA in the concept paper.
“Whilst helicopters were outside the scope of the original EBT development plan and are not referenced in ICAO Doc 9995 or the IATA EBT Implementation Manual, the offshore helicopter community, operating multi-pilot, multi-engine, instrument flight rules (IFR) aircraft, increasingly equipped with cockpits equivalent to ‘Generation 3’ aeroplanes (as described in ICAO Doc 9995) has expressed a need to have access to EBT,” says EASA.
Baseline for Data Comparison
In the roadmap defined in the concept paper, EASA anticipates the development of an EBT data report for helicopters. “Compilation of the Helicopter EBT Data Report will follow the methodology used by IATA in the development of the IATA EBT Data Report to ensure consistency in approach to the data analysis, which will allow commonalities and differences between aeroplane and helicopter operations to be identified,” says EASA. “This approach will allow future data comparison with the baseline data established today. Results to be published within an EBT Data Report for Helicopters will be drawn from multiple sources, some of which are readily available to the public. Some come from information, access to which is restricted to industry specialists, while other results will be inferred from confidential, de-identified data.”
To date, EASA has achieved a significant amount of work in the EBT Data Report for Helicopters. “We have some preliminary results; however, they will be shared only when we publish the complete work on the EBT Helicopters Data report,” says Francisco Arenas Alvariño, EASA’s EBT project manager. “As a preliminary statement, we can say that data shows that the type of operation plays a greater role in helicopters. Although aircraft generation continues to be important, it is less relevant than the type of operation. It should be noted that in aeroplanes the aircraft generation has a greater role.”
EASA's Francisco Arenas Alvariño speaking at EATS 2021 in Berlin. Image credit: David Malley/Halldale Group.
1st Step: Mixed Implementation
It is important to point out that the process described in the concept paper by which the case made for EBT for airline operators can be described, developed, and evidenced to support EBT for helicopter operators has not concluded yet. Therefore, currently, there is no detailed regulatory guidance available from EASA on EBT implementation for helicopter operators.
Nevertheless, flight crew training regulations in EASA AIR OPS (ORO.FC.231 and ORO.FC.232) in a way already anticipates helicopter EBT implementation. “When we developed the EBT rules for aeroplanes, we decided to make the implementing rules performance-based and ready for helicopters and aeroplanes. Thus, ORO.FC.231&232 are ready for helicopters, and we are only missing the acceptable means of compliance (AMC) and guidance materials (GM). The AMCs and GMs are only ready so far for aeroplanes, not for helicopters,” says Arenas Alvariño.
EASA amended GM1 ORO.FC.230 (a)(b)(f) in ED decision 2020/002/R to allow helicopter EBT mixed implementation. “Mixed implementation is the first step to an EBT baseline. We are following the same approach we did for aeroplanes (mixed implementation in Dec 2015 and EBT baseline in 2020). We will eventually allow EBT baseline for helicopters, but it will take five years,” says Arenas Alvariño.
Draft Manual Now Available
In August 2022, EASA published a draft EBT Manual on the EASA community website. The objective of the draft EBT Manual is to support the design and conduct of EBT programmes by complying with EASA regulations.
There are three sections in the manual:
- Section I contains the need-to-know safety promotion material,
- Section II contains the nice-to-know safety promotion material,
- Section III contains the EBT checklist for baseline EBT.
“The draft EBT Manual is designed as support and guidance for the implementation of EBT mixed (ED decision 2015/027/R) and for EBT baseline (following the adoption of Commission Implementing Regulation (EU) 2020/2036 and the ED decision 2020),” says EASA. “The content of the manual will be expanded in future editions to become a living document that helps in the development and implementation of EBT across the European Aviation Community.”
EASA has also developed a checklist for the implementation of EBT mixed. “It is a generic checklist both for Aeroplanes and Helicopters. However, due to the relevance of aeroplanes, some elements of the checklist are aeroplane centric,” says Arenas Alvariño.
The current AMCs and GMs to ORO.FC.231 and ORO.FC.232 can be used to some extent as references to support helicopter mixed EBT implementation. “We use the word aeroplanes in many AMCs and GMs related to ORO.FC.231 and ORO.FC.232; therefore, it should be clear that, currently, ORO.FC.231 and ORO.FC.232, due to the lack of specific AMCs GMs, should not be used by helicopter operators. However, the AMCs and GMs to ORO.FC.231 and ORO.FC.232 are suitable reference materials to implement EBT, but it is better to use the EBT manual, the EBT checklist and to contact EASA if a helicopter operator decides to implement EBT mixed. We have already reached two operators in the process of implementing EBT mixed,” concludes Arenas Alvariño.