Comments on Supplemental Notice of Proposed Rule Making on Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers

Transcription

1 AIR CARRIER EMPLOYEES REPRESENTED BY IAMAW DISTRICT 141 AND TWU LOCALS 541, 544 AND 557 Comments on Supplemental Notice of Proposed Rule Making on Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers Docket No. FAA ; Notice No A International Association of Machinists and Aerospace Workers District 141 (Fleet Technical and Related) and Transport Workers Union of America Air Transport Division Locals 541, 544 & 557 9/19/2011

2 Stakeholders included in this comment to the SNPRM IAMAW District 141 Fleet Technical and Related Ground School (Fleet Technical) Instructors and Emergency Procedures Instructors at United Air Lines and legacy Continental Airlines TWU Local 541 Ground School Instructors and Pilot Instructors at American Airlines TWU Local 541 Ground School Instructors at American Eagle TWU Local 541 Flight Simulator Technicians at American Airlines and legacy Continental Airlines TWU Local 544 Flight Simulator Technicians (Engineers) at US Airways TWU Local 544 Ground School (Flight Crew Training) Instructors at US Airways TWU Local 557 Ground School and Simulator Instructors at Southwest Airlines Basis for Stakeholder Comments The stakeholders represent individuals employed by air carriers who perform training and evaluation of pilot, flight engineer and flight attendant crewmembers. The stakeholders also represent individuals employed by air carriers who maintain flight simulator training devices and other training equipment used in pilot, flight engineer and flight attendant training programs. This SNPRM will directly affect the represented individuals and their ability to provide crewmembers with safety critical training. Focus Areas (concerns and discussion) from Stakeholders The SNPRM is clear regarding proposed pilot academic and job performance training supporting the document s purpose; however, the SNPRM is silent on which level of instructor provides that academic and job performance training. As a result of evolving technologies and complexities of crewmember training, the stakeholders believe it is necessary to reconsider the traditional role for the pilot (and flight engineer) ground instructors who provide Part 121 and other FAA-required pilot academic and job performance training and evaluation. The new paradigm requires reassessment of this role and the need to establish minimum certification and qualification requirements for these instructors as they perform not only academic instruction but also every increasing and more complex job performance (line operational) instruction in FSTDs. The existing FAA definition of Distance Learning is constraining and focuses on what Distance Learning is NOT rather than what it is, and the stakeholders believe this needs further clarification to include the industryaccepted term of e-learning. The SNPRM is silent on the qualification of simulator technicians who are responsible for maintenance and repair of FSTDs and cabin simulators. The stakeholders express a concern that the SNPRM does not appear to address how those carriers utilizing data driven training systems (Appendix Y Advance Qualification Programs) are guided as to what data points to sample and collect. We express a concern that the feedback is only as good as the sampling process. Consideration should be given to utilizing a third party, independent of both the carriers and FAA in order to determine, analyze and crosscheck this data points to prevent potential manipulation (dummying down) of data Page 2 of 7

3 in order to mask the need for additional training (with associated costs). The development of a data set should include predictive modeling rather than simply being reactionary (based on past trends). We recommend establishment of forward looking analysis of minimum academic and job performance skill-sets in order to preclude eroding into a purely reactionary programs. Principles behind Stakeholder Response Based upon the pilot age demographics no doubt the industry faces tremendous training volumes over the next twenty years and beyond. The Stakeholders suggest the FAA should not allow the quality of crewmember training to fall victim to the pressures and costs related to this anticipated training volume. In fact, cost should never be the primary driver when it comes to effective academic and job performance training. Proposed Modifications relating to Certification of Ground instructor (pilot or flight engineer) Sections , , , 65.7, 65.70(a), (a)(1)(i), (a)(2), , , (c), (d)(2)(iv), (d)(2)(vi), (d)(3), (e)(1), (e)(2), (a)(1), (b)(1), , (a)(2)(i), (a)(3), (b)(1)(i), (b)(3), (a), (d), , (a)(1), (a)(1)(ii), (a)(2), (a)(2)(ii), (a)(3), (a)(3)(ii), (b)(1), (b)(2), (b)(2)(i)(A), (b)(2)(i)(B), (b)(2)(ii)(A), (b)(3), (b)(3)(i), (b)(3)(ii), (b)(4), (b)(4)(i), (b)(4)(ii), (c), (d)(1), (d)(2), (d)(2)(i), (d)(2)(ii), , (a), (a)(2), (e)(2), (f)(2), (e), (g)(2), (g)(4), (c), (c)(1), (c)(2), (d)(1), (d)(2)(i), (d)(2)(ii), (d), (d)(1), (a)(1), (b)(1), , (a), (a)(2), (a)(8), (a)(8)(iii), (b), (c), , (a), (b), (a)(2)(i), , , (a), (c), (e), (e)2, (d)(2), (g)(2), (g)(4), , (a), (a)(1), (a)(9), (b), Attachment 3 of Appendix Q and related Sections The SNPRM details initial and continuing qualification and recency of experience for dispatch and flight attendant instructors but is somewhat confusing when dealing with the initial and continuing qualification and recency of experience for pilot (and flight engineer) ground instructors who provide academic and job performance instruction and evaluation. There are multiple locations in the SNPRM referring to instructors and there appears to be lack of clarity as to the exact meaning of the individual intended to be performing the instruction or evaluation in some of these references. The SNPRM includes the following prefix or suffix when describing an instructor: academic, accepted flight engineer, accepted flight engineer ground, accepted pilot ground, aircraft dispatcher, authorized, certifying, dispatcher, flight, flight attendant, flight engineer, flight engineer flight, flight engineer ground, ground, job performance, pilot, pilot flight, pilot ground, qualified, qualified flight attendant, simulator, simulator-only, training center and unspecified. The role of a pilot (and flight engineer) ground instructor has evolved from one that was traditionally focused on crewmember instruction and evaluation on aircraft systems and emergency equipment in classroom academic instruction and hands-on training. In today s training environment this instruction includes (in addition to classroom academics) the job performance training of crewmembers in a FSTD under a line oriented, operational environment (application of system knowledge, flight deck flow patterns, normal checklists and procedures, non-normal checklists and procedures, emergency procedures, programming of navigation and auto-flight systems, instrument approaches, missed approaches, de/anti-icing, TCAS, Windshear, etc.). Page 3 of 7

4 Currently, the stakeholder air carrier training programs employ professional pilot (and flight engineer) ground instructors who instruct academics in a classroom and who also conduct job performance instruction in a FSTD and in cabin door trainers and other training devices. Often these same instructors conduct oral and written examinations, evaluations and data collection. The SNPRM fails to clearly address the minimum requirements of those who deliver this academic and job performance training, evaluation and data collection. We believe this omission is best addressed and corrected by an FAA certificate reflecting the actual work performed by these instructors. This new certification criteria would ensures a consistent level of training and qualification of these instructor personnel throughout the industry. Accordingly the IAMAW/TWU represented stakeholders propose the FAA should establish a certification or rating known as ATI Airline Transport Instructor to cover those individuals performing the work of air carrier pilot (and flight engineer) academic and job performance instruction, evaluation and data collection. This would include those individuals who presently provide academic and job performance instruction (classroom, FSTD and FFS) and who perform evaluations, validation checks (oral and written examination) and data collection. We also believe the proposed ATI certificate holder would be trained and qualified as a subject matter expert (SME) for aircraft systems, procedures and technical subjects (including international flight procedures). The stakeholders recommend grandfathering of those instructors presently performing this work with an air carrier. Proposed Addition of Minimum number of Pilot (and Flight Engineer) Ground Instructors Sections (a)(6), (f) and related The SNPRM is silent on the minimum number of pilot (and flight engineer) ground instructors required. This oversight should be corrected by establishing a minimum similar to other personnel required by this section. Proposed Modifications relating to Academic Training (Distance Learning) Section (a)(1), Attachment 2 of Appendix Q to Part 121 and related Sections The represented stakeholders find that the SNPRM fails to achieve the goals and objectives listed in the SNPRM. The primary purpose of this proposed rule is to establish new requirements for traditional air carrier training programs to ensure that safety-critical training and evaluation is provided for crewmembers... The proposed changes seek to make a significant contribution to the FAA s accident reduction goal The proposed requirements also implement numerous safety recommendations from the National Transportation Safety Board. The objective of the rule is to enhance crewmember training programs by including additional training requirements in areas that are critical to safety. The proposed changes are intended to contribute significantly to reducing aviation accidents and improving crewmember performance. Specifically we believe elimination of traditional academic classroom training is the wrong course of action when looking at the anticipated training demand over the next twenty-five years. Replacing classroom academic training with asynchronous e-learning or Distance Learning does not improve quality and competency of trainees, rather trainees (especially novice trainees) need more in-classroom time with interactive discussion amongst trainees facilitated by a qualified instructor. Shared experience is a valuable component of learning, wherein a question posed by one trainee (based upon his life s knowledge, or by comment from the instructor) has a high degree of probability to stimulate discussion not apparent to another trainee. We believe that self-directed training is not appropriate when it comes to laying the foundation for a crew-oriented work environment. The attempt to substitute Distance Learning for academic classroom instruction flys in the face of common sense. In an industry with less long term, experienced pilots we believe Page 4 of 7

5 it is wholly inappropriate to lessen the facilitated training exposure and thereby reduce the safety of our air transportation network. Actual experience indicates that some crewmembers may not be personally completing the required Distance Learning modules, but instead are using another individual (as a proxy) to complete this training. There is no provision within the SNPRM that addresses how carriers are to positively confirm that a crewmember is personally taking the required webbased (asynchronous) modules. This lack of confirmation extends to security sensitive training programs. We believe that the SNPRM should stipulate that each web-based training program be synchronous and provide for confirmation of the enrolled trainee (via live imagery) and that the enrolled trainee must have direct and immediate access to a qualified instructor when participating in that training. The stakeholders provide the following replacement to the FAA definition of the term Distance Learning: Distance Learning is academic training or evaluation that may take place in other than a formal classroom and shall be delivered by electronic media. Distance Learning delivered by web-based media shall be referred to as e-learning and shall be synchronous, using a qualified pilot (and flight engineer) ground instructor to facilitate the content delivered to a trainee. In each case the pilot (and flight engineer) instructor shall be required to provide appropriate monitoring and oversight of the trainee s progress, and shall intervene when necessary. Finally, the stakeholders provide the following text to be incorporated in the SNPRM to describe the use of e-learning for crewmember training: A crewmember, dispatcher or instructor may receive, engage in, or otherwise participate in an e-learning program approved by the FAA Administrator for an air carrier s Initial, Transition, Conversion, Cross Crew Qualification, Recurrent, Special, Security, and Hazardous Materials training, and Dispatch training, Maintenance training, Flight Attendant training, and all other training required by the FAA Administrator for those personnel to qualify, or to remain qualified, to operate an aircraft, serve as a Crewmember, perform Dispatcher duties, or perform instructor or evaluator duties. For security purposes air carriers must ensure trainees who are participating in each e-learning training module are positively identified. This positive identification may be accomplished by direct contact between the instructor and the trainee, or by electronic or visual confirmation (webcam image) of the trainee by the instructor each time the trainee logs on to an e-learning module. Carriers shall also ensure that the instructor must be able to randomly sample each trainee to confirm by electronic or visual means (webcam image), that the trainee is in fact the person authorized to take the particular e-learning course of instruction. Distance Learning may be accomplished only through an e-learning program and may be used only to supplement and not replace existing in-classroom courses of instruction. Whenever a trainee receives, engages in, or otherwise participates in an e-learning program for the air carrier s Initial, Transition, Conversion, Cross Crew Qualification, Recurrent, Special, Security, Hazardous Materials training, and other training required by the FAA Administrator, that e-learning program must permit real-time, interactive synchronous communication through telephonic or electronic technology (i.e.; instant messaging, voice over internet protocol VOIP or other technologies as may be developed) between the instructor and trainee, and between multiple trainees registered in that same e-learning module at that same time. An Airline Transport Instructor (formerly known as pilot (and flight engineer) ground instructor) for this purpose must be an individual who is trained, currently qualified and competent to act as an Airline Transport Instructor on behalf of the carrier. An Airline Transport Instructor shall be the person responsible to monitor and facilitate each e-learning Module received by the trainee(s). That instructor must be currently qualified and competent to teach and facilitate the course and subject matter that the trainee is viewing via e-learning. Each air carrier shall provide for a method of data collection of each e-learning module to include: length of time to complete each module by each individual trainee; the number of correct and incorrect responses to each quiz or test question which may be incorporated within each module; the number of times each individual frame or segment of instruction within a module was repeated by each trainee; the date and time each module was commenced and completed; and other parameters as determined from time to time by the FAA Administrator. Each e-learning module shall be constructed so as to include summative evaluations so the trainee can provide feedback anytime during the training. Each air carrier conducting an e-learning program shall ensure that each trainee has access to each required e-learning module and shall provide required software and hardware necessary for each trainee to complete that e-learning. Each air carrier shall also establish contingencies (approved by the FAA Administrator) so a trainee may complete the requisite course or module in the event that the e-learning module cannot be completed due to technical or other difficulties. Page 5 of 7

6 Modifications Proposed regarding Flight Simulation Training Devices Sections (e)(4), (c)(2) and (c)(6), (a)(3), Attachment 3 of Appendix Q to Part 121(C) and Table 3B and related Sections The standards for a FSTD should be established with the concept of providing job performance training of crewmembers in a device that presents a realistic representation of the flight deck environment including the tactile feel of all system interface panels (switches, push buttons, etc.), oxygen masks, communication (including interphone and radio), flight controls, thrust levers and other devices which are manipulated by the pilot in the performance of his flows and checklists. Use of a FSTD below Level 6 compromises the ability to provide the level of fidelity and automation integration with today s highly automation dependent transport category aircraft. Cascading automation failures could present a significant risk (as in the Air France A330 accident) and we contend that the best way to train pilots for is to provide a high fidelity training device which is fully capable of accurate simulation of flight instruments, integrated systems and avionics, and flight controls in order to conform with the law of primacy. There should be no deviation permitted to this standard to utilize at least a Level 6 FSTD. Proposed Addition of Duty Time Limitations for Instructors (Pilot and Flight Engineer) Sections , and related The SNPRM is silent on the duty time limitation for pilot (and flight engineer) ground instructors. We believe that a limitation should be added to the SNPRM in order to prevent training by a fatigued individual. Therefore we propose including a new section that states: No certificate holder may assign a pilot (or flight engineer) ground instructor and no pilot (or flight engineer) ground instructor may accept an assignment for duty time that exceeds 12 consecutive hours of duty. And, no certificate holder may assign a pilot (or flight engineer) ground instructor and no pilot (or flight engineer) ground instructor may accept an assignment for duty time that exceeds 100 hours of instructional duty within a 30 day period. Proposed Addition of Training Records for pilot (and flight engineer) ground instructors Section and related The SNPRM fails to include language which covers training records for pilot (or flight engineer) ground instructors. Proposed addition of Flight Simulation Technician Certification No existing Section The SNPRM fails to include language which discusses initial and continuing qualification of simulator technicians. These individuals are typically responsible for acceptance checks and ongoing maintenance and upgrade of FSTDs and cabin door and window training devices as well as other pilot and flight attendant training equipment. We believe the FAA should establish Certification criteria for this job function. Page 6 of 7

7 Desired Outcome The SNPRM should focus on improving quality of training by ensuring appropriately qualified individuals perform training and the maintenance of training devices. The SNPRM should also ensure proper FSTDs are utilized and that proper modalities be employed to deliver academic training. In summary and to that end we suggest the following points: Establish Certification for an Airline Transport Instructor (ATI) to cover ground school instruction. This would include: academic instruction in a classroom and e-learning environment, job performance instruction in a FSTD and other training devices, subject matter expert (SME) for aircraft systems and procedures, performing validation checks (oral and written examination) and data collection. o Grandfather existing instructor personnel performing this work at air carriers, and o Establish initial qualification criteria for Airline Transport Instructors (including line observation from flight deck observer s seat with Universal CASS access amongst US Carriers), and o Establish continuing qualification criteria for Airline Transport Instructors (including line observation from flight deck observer s seat with Universal CASS access amongst US Carriers), and o Establish recent experience criteria for Airline Transport Instructors. Re-define Distance Learning in order to properly train crewmembers and dispatchers to prevent carriers from eliminating the important classroom academic phase of instruction (as presently incorporated in the SNRPM). Distance Learning should be limited to synchronous web-based training (e-learning) monitored and facilitated by a qualified instructor. e-learning modules must provide for direct interaction between the Instructor and trainees and amongst trainees. The stakeholders also recommend that no deviations be granted to permit carriers to convert classroom academic instruction to a Distance Learning platform. The SNPRM must establish a positive match validation protocol for trainees participating in e-learning training, testing and examinations (to preclude persons other than the intended trainee from taking the training, testing or examination). Provider for certification of those technicians who perform acceptance, maintenance and repair of FSTDs and other training devices. Respectfully submitted, ss/kevin Martin for International Association of Machinists and Aerospace Workers, District 141 Fleet Technical and Related ss/jim Fudge for Transport Workers Union of America, Air Transport Division Local 541 ss/william E. Gray for Transport Workers Union of America, Air Transport Division Local 544 ss/ron Sparks for Transport Workers Union of America, Air Transport Division Local 557 Page 7 of 7