PART II – The 1500-Hour Rule, Data Sharing and NFTA’s Mission

Rick Adams: Where does the 1500-hour rule play in this?

Lee Collins: So the 1500 hour ATPL is actually spelled out in part 61. No part of 141 touches it, although 141 providers have to obviously be aware of it because their instructors will either stay until they get 1000 or they'll stay until they get 1500, depending on where they came from.

We all remember those early days; I worked for the man who actually suggested this. Everybody went, brilliant. But we expected that to be a solution to a problem at the time. No one ever thought this would become ensconced in granite to where we would never envision anything else.

Technology has led us now, over the last 14 years, to be able to do so much more. We can build better pilots, which was the goal in 2010 when we passed that rule. Build better pilots. Now we can, using other means, and I think we have to now entertain that.

I would like, and I've been very public about this, we need to stop talking about hours. That's not the focus. The battle lines have been drawn for so many years now, and it's so vitriolic that when one side or the other says anything about anything, they might tell us the sky is blue this afternoon and the other side will go, no, it's not, because they just are diametrically opposed to anything the other side has to say.

We need some new voices in that discussion to come in and say, wait a minute, let's not talk about hours anymore. Let's not talk about exemptions. Let's not talk about reductions, because those all, to the general public, sound like we're taking a pass on safety. Let's talk about what we can do as enhancements to pilot training, as enhancements and additions to qualifications, how we build better pilots. And I think the 141 rule can, whatever the new rule comes out to be.

I'm not forecasting what it will be, but I'm saying it could really help in that regard because you could say, look at all the things we can do here. And if we're using data analysis and trend analysis and being very nimble on watching and seeing how pilots perform and what methods work here and what methods don't work there, we can adjust to continually improve, which is what the 121 folks do with AQP and have for years. It's a continuous improvement loop. We're looking for even the slightest deviation. Let's fix it because we have a zero tolerance for accidents, right? We need to do the same thing in general aviation.

Rick Adams: In the framework of the 1500 hours, between the 250 to get your private and the ATPL for the airline, what exactly gets trained? Other than I'm a CFI flying around with a student that's two years younger than me.

Lee Collins: Are we developing skills between there and there? Or is it this vast wasteland? It's undefined.

Competency-based training would help us to define that, EBT would help us to define that. I think these are initiatives that have to be fully examined by the Part 141 Modernization effort and have to be given their due level of diligence to make sure that if parts of that should work for us going forward, that we embrace that. Again, the objective is to build better pilots, safer pilots, more competent pilots, pilots that are built for the job that we have today and 20 years from now.

I was in the airline world for 35 years. But for the last four years, I've been over here and I've seen what is capable. We can do better and we can do more. And if I had the opportunity to say to my former colleagues, come over here and objectively look at what we're doing, you'll see, because you’re professional aviators, you get it. They would agree. But what's being articulated now is not necessarily a professional opinion. It's a political opinion. And those are wholly different.

Rick Adams: I've noticed a subtle shift in this industry. It was an untouchable, unmentionable subject. But it’s starting to creep back into the dialogue. And now you get somebody like Bryan Bedford [current CEO Republic Airways] being nominated for FAA Administrator who's been an advocate of moving on.

Lee Collins: The confirmation hearing will be interesting, because you can almost guarantee that certain members of that committee are going to ask that question, of course. Does that mean he gets confirmed on a party-line vote? Well, he gets confirmed nonetheless. If I was advising him, I'd say don't beg the fight on hours. Say, under my administration, we want to look at competency-based training for pilots to ensure they are qualified and competent and safe. And wherever that takes us, we will. We should do it and leave it for the industry to figure out.

Rick Adams: What plans do you have for using data for your arguments? My recollection of the 1500-hour discussion was this industry knew the value of flight simulation, but they had never quantified it to where you could take it to the politicians and say, this is what the data shows, that you can replace some of those hours.

Lee Collins: It's not just that, Rick. They also needed to scale the industry to where simulation was available. You had the big full-motion flight simulators. Well, you're talking tens of millions of dollars. But we now have, through groups like Frasca and Redbird and Alsim and others, really amazingly faithful high-fidelity simulation that's available cost-wise to the general aviation industry. And so now that we have that, now we can start collecting data all along the points, and then we really know what we've got in terms of improvement over time and over qualifications. The stepping stones all the way to the end.

We've had Aviation Safety Information Analysis and Sharing (ASIAS) for many years on the 121 side and the 135 side that meets twice a year and analyzes FOQA data from carriers; the governing body there will recommend changes. And twice a year the whole industry comes together. There is a provision in that document that allows participation by general aviation entities. We believe strongly that we should be appointed to that ASIAS group so that we can share in how they do that.

Right now we have trouble getting people to share the data. But at the 121 level, they have these memorandums that talk about de-identified data and how they use it. Looking at that model and adapting it to the 141 ab initio world to then begin to do the same thing, making sure that we're involved in the info-share safety get-togethers that the FAA has with airlines and others to actively engage in data analysis. If you can do that, then you might find some ways to get that collection done very similarly.

Let's turn the data over to ASIAS and let them be the repository for that, because then the corporate general counsels and all these company lawyers that say, we don't want to share that information because we're afraid of liability to let go of that; we need that.

Rick Adams: I was just in a presentation by Dr. Lauren Burmester of Embry-Riddle. She's in charge of their partner program. She gets data from some partner airliines, but not others. How can you be a partner and not share data?

Lee Collins: The folks from ATP, the largest flight school in the country, said we ask, but we don't get answers. We're saying, help us send you better pilot candidates by giving us the information they need work on when they get to you. What are you seeing that they're missing? We can go back and fix that, but they don't tell them.

We now have, at the general aviation level, commercial providers that allow a flight training provider at every local airport in the country to put a box in their airplane that collects FOQA data, just like the airlines do. They interface with the avionics, the Garmin suite, and provide everything they need on every individual flight. It's available now at this level. So we've got to find a way to get people up on that step.

And then we need to have a place for that data to go. For us to look at, as granular as we can, as thinly sliced as we can get it, then we'll be able to make the kind of improvements we need for general aviation that the folks at the FAA are really interested in, because if there's one thing that gets their attention, it's the general aviation accident rate every year.

I envision ASIAS doing that because they're already doing it. The system is there. We just need to put it into their system, because that would be the easiest thing. That's already set up with our government and the FAA and others, and we've got the whole industry, for the most part, participating - except general aviation. We go there first and see if they'll say come join the club, bring your data. We can make some assumptions about what's happening here and then maybe even affect change here.

Rick Adams: Beyond 141, what's the scope of what NFTA is looking at?

Lee Collins: The core function of this organization is to provide a voice and a vision for the industry. We adopted a branded tagline that I borrowed from a senior FAA official who once said in a meeting that in his estimation, in his career, the training sector rarely showed up. And when they did, they didn't show up well. That's the task: to ensure that training shows up, and when they do, they show up well.

We're committed to providing a deep bench of professional aviation folks who come from across the industry, who are now in the training sector, who will articulate from experience and knowledge the voice of the industry in an effort to provide direction and strategic growth. Our model is that we are the umbrella or the big tent where everyone can come together and have a conversation about what should we be doing, and wherever possible, walk together that path. Because that's the way to get Congress and the FAA's attention and cooperation. When you're all together, it works. When you're split, it never works. So I think we've been very successful so far, particularly over the last two years, as I talked about when we've worked; where we've needed to gather consensus in this 141 piece is a really big piece of that model.

Beyond that, if we can raise the professionalism and the forward-thinking modernization of an industry like ours, everyone involved in that industry will benefit. It's guaranteed. That's what we should be doing. It's been too long that the chair in the room with the label training on it has been left empty.

The other component to what we want to do is to be very engaged with the regulators and our folks up on Capitol Hill. We want to have a strong legislative and government affairs effort to where we're involved in advancing legislation, where necessary, to help things like financing for students, easing the burden on veterans who are engaging in flight training - because the burden is heavy on them right now and it needs to end, absolutely needs to end.

Rick Adams: You might look at Switzerland as far as the apprenticeship and financing. They will actually fund the financing for Swiss citizens and partially fund the financing for non-Swiss citizens.

Lee Collins: There was an effort last fall that could have been very positive, was blunted by a bad effort by some in industry that just turned Congress off to the idea altogether. We want to regenerate that thing. So efforts around financing, workforce development, we've got a bill forward right now on mental health and pilot apprenticeship programs. So we will continually be involved in instigating those kinds of bills and hoping to see them get passed. That's a big component of what NFTA is going to do.

Rick Adams: You have a US-focused organization. Do you see any future internationally?

Lee Collins: It would be interesting hearing what they have to say and if there's any commonality and effort. But we've got our hands full right now, for sure.

I get a lot of interview requests from European reporters. Who are you? What are you guys trying to do? And then give us some insight, some briefing on it. I get as many requests from them as I do in the US.

Rick Adams: Final thoughts?

Lee Collins: We tell people all the time, this is flight training for a whole generation coming up. We can affect change for a lot of people for a lot of years.

I think one of the things I feel best about is after 47 years in the business, I've kind of climbed my ladder. So I'm not looking to make anybody happy. I can just tell it the way it is now.

Part I – The NFTA and Part 141 Modernization