Scott Nutter, Principal and Owner at Touch & Go Solutions and a leader in Halldale Group’s Heads of Training program, completed a wide-ranging discussion about Advanced Qualification Program (AQP) with Marty Kauchak, CAT editor. The discussion is provided in entirety below.   

CAT: The overarching ‘umbrella’ for competency-based training constructs has common tenets available for AQP, CBT/A, EBT and even MPL. How do you see the commercial aviation pilot training enterprise evolving with what would appear to be a rich selection of available programs to support the continua of pilot training? 

Scott Nutter (SN): Air carrier training organizations learned a lot in the last 40 years. ‘Traditional’ training curricula built upon generic, one-size-fits-all lists of tasks with arbitrary programmed hours have been replaced with training ‘systems’ that rely on processes such as instructional system design (ISD), data management, and quality management. These systems encourage innovation in training methods and technology.  It is encouraging to see regulators worldwide beginning to embrace the systems approach to training and demonstrating a willingness to entertain airline proposals to advance the state of the art.

A key area where evolution is imperative is agility. Flightcrew training was static for decades, focused on compliance and meeting basic certification minimums. Today’s training organization must move at the speed of business and support ever-changing flight operations. The core components of modern training systems allow training to be nimble, responsive, proactive, and focused on a world filled with threats that seem to change weekly. 

CAT: AQP is about 33 years old. Is participation in the program growing and is the basic construct maturing?

SN: According to the FAA, well over 90% of U.S. §121 air carrier pilots are trained under an AQP, and more are transitioning to the program. While still defined in the regulations as an ‘alternative method’ for training and qualifying pilots, it is, in fact, the norm. There are many reasons behind carriers’ adoption of the program, but once airlines go through the discomfort of the switch, they see the benefits in measurable results. 

In my opinion, FAR §121, subpart Y (AQP) is one of the most enlightened regulations ever written. The FAA forefather of AQP, Dr. Tom Longridge, had the foresight to develop a set of regulations that described a system of training rather than the prescriptive ‘tick box’ programs of the past. This construct provides the airlines with tremendous latitude regarding training program design. I frequently use the analogy of building a house. The AQP regulations are the building codes. These codes are important and ensure that every house is well-constructed and safe to live in. What kinds of houses can you build under the codes? The possibilities are endless. 

Scott Nutter, pictured above, is a 38-year aviation professional with experience in General Aviation, Business/Corporate Aviation, Air Carrier, and Charter operations.

CAT: What’s next for AQP? 

SN: In the 1990s and 2000s, AQP was a ‘scrappy start-up’ program, where airlines and the FAA were figuring out how the theory of a process-based training system would translate to actual airline operations. The industry is past that phase now. We have over three decades of lessons learned and recommended practices that serve as an evidence-based foundation upon which the original theories rest. The industry has reached a point of maturity where we know AQP works, how it works, and why it works. 

Many books explain that great entrepreneurs have a different mindset than businesspeople who excel at running large, established enterprises. There are levels of maturity that describe systems, processes, and programs. On a scale of 1 to 5, I would say AQP is a solid 3.5, trending towards a 4. It is a fully developed methodology that produces great results. That said, Continuous Improvement is a core tenet of AQP, and some operators have seen their programs stagnate. There are perfectly good reasons for this, like a global pandemic. 

Once an airline has a high-functioning AQP, innovation is where resources should be focused. Of course, everyone sees the amazing new technologies available at WATS https://wats-event.com/. However, talk to a Head of Training (HoT) regarding which technology to invest in and you’ll come to understand the difficulty in making the right choices. Adaptive learning platforms, individualized training, moment-of-need performance support, and everybody's favorite, X/R, all hold great promise. The question is, ‘Which one?’ or ‘Which one first?’ 

Regardless of a HoT choice, AQP provides a mechanism that the idea or tech can be proposed, tested, and implemented if found to be effective.    

CAT: How has AQP been integrated with other voluntary safety programs and the Safety Management System (SMS)?

SN: This is a huge success story that does not get the credit it deserves. In the 1990s and 2000s, a single FAA branch managed all Voluntary Safety Programs (VSPs). ASAP, FOQA, IEP, VDP, LOSA, and AQP fell under the VSP umbrella. Each program requires a significant investment of time, effort, and resources. Add the requirement for airlines to implement a SMS, and you have a massive change to how flight operations divisions operate. 

In the US, airlines started a slow, one-at-a-time process of implementing VSPs. As a fan of the crawl first, walk next, and finally run concept, this was the right approach. When industry consolidation picked up speed in 2009 and 2010, airlines saw the benefits of the programs as a way to mitigate the inherent risk of mergers and acquisitions. In hindsight, that proved to be true as mergers were accomplished without hull losses, unlike examples in the past.

Air carriers with mature AQPs manage a continuous data flow into their ISD processes. Curricula and the modules within are no longer static. They are adjusted or replaced based on data. It doesn’t matter if an airline doesn’t have every VSP. They use the data available and tailor training to the needs of the operation.

CAT: What is constraining innovation in AQP?

SN: In a word, resources. Innovation must be managed, and that’s not a skillset Heads of Training acquire during normal professional development paths. Interestingly, their leaders are usually eager to support innovation as long as it has measurable benefits. I’ve been in the room as a Managing Director of Training, and his/her VP of Operations tries to convince the CFO that the training organization needs capital expenditure money to fund a V/R project. In most cases, the MD is unprepared for the barrage of questions that follow the presentation. Training is a sunk cost with difficult-to-quantify ROI. 

Heads of Training need to partner with people who can build prototypes, conduct proof-of-concept projects, and use data to scaffold innovation proposals. Start small, test at each step, learn from mistakes, and once you know something works, share your results with the boss before making the big pitch to executives. HoTs have the unenviable task of sorting through countless “shiny objects” to determine which holds the most value.

I would be remiss in failing to point out the resource limitations our regulators face. Just as airlines have seen unprecedented turnover in pilots and record hiring, the FAA is struggling to meet the demands of the industry. When you run a large AQP you work closely with several groups within the FAA. AQP leaders come to realize that the Feds want to be supportive and attentive to every request, but they are just as understaffed as the operators. AQP expertise within the FAA is in short supply, and it takes years for an inspector to master all facets of the program.      

Scott Nutter observed, "Today’s training organization (one example above) must move at the speed of business and support ever-changing flight operations. The core components of modern training systems allow training to be nimble, responsive, proactive, and focused on a world filled with threats that seem to change weekly." Source: Delta

CAT: Address some of the criticisms of AQP. 

SN: Since many critics have never managed an AQP, I’ll pick two, one specious and one justified. 

The ‘Train-to-Proficiency’ (TTP) concept has long been misunderstood. Early critics of AQP used pejorative phrases like ‘Train-to-infinity’ or ‘No pilot left behind.’ The implication was that AQP airlines used train-to-proficiency as a way to keep poor-performing pilots from failing a program or having a failure added to their training records. Those critics were completely unfamiliar with other components of an AQP that prevent such occurrences, let alone AQP’s integration with standard processes like review boards. Train-to-proficiency simply recognizes that not all pilots are created equal. Some may need more training or repetitions in a task, while others need less. TTP is one of the many tools available under AQP that supports the goal of individualized training.

 A criticism with merit highlights the difficulty of implementing and operating an Advanced Qualification Program. AQP is hard, or at least harder than traditional training. It’s not called the Basic Qualification Program for a reason. 

If an airline opts to transition to AQP, it implicitly commits to adding specific skill sets to the training organization. Disciplines like Data Science, Quality Management (QMS), and Instructional Systems Design (ISD) are critical to the success of an AQP. Outside of flight operations or aviation, people earn graduate degrees in these areas and may make one the focus of their career. 

Here’s where I upset Heads of Training inside the US and elsewhere using other CBTA programs. The last time I checked, the ATP/ATPL knowledge exams did not address data science, QMS, or ISD. Nor do the ground or flight instructor tests. Choosing the senior flight instructor who got the best grades in their college stats class to run your AQP data system is a recipe for disaster. There are people as expert at data science, QMS, and ISD as the HoT is at flying airlplanes.  

Remember, AQP is a voluntary safety program. If you choose to operate an AQP, staff it with skilled staff or contract the expertise needed. 

CAT: Thanks for your time and we look forward to seeing you at WATS2024!

Editor’s note: Scott Nutter is 38-year aviation professional with experience in General Aviation, Business/Corporate Aviation, Air Carrier, and Charter operations. As an FAA-certified ATP with multiple type ratings, CFI-ME-I, and Flight and Ground Instructor certificates, Scott has served as a line pilot, Chief Pilot, Check Airman, written test examiner, and Training Center Evaluator. He also holds professional certifications from ASTD/ATD, ASQ, and PROSCI.