Formalising the role of simulators

CASA recently released an industry discussion paper to canvass options to mandate the use of simulators for high-risk training such as engine failure exercises, and how the possible introduction of mandatory simulator training would affect industry.

The discussion paper aims to explore training operations where simulators may be considered more advantageous than using actual aircraft, identify the types of aircraft and operations which may benefit from the introduction of mandatory sim use, while assessing the potential benefits and impacts such requirements may have on operators.

The issue of mandating sim use for high risk training stems from a mid-2009 ATSB report on a serious incident in Western Australia involving an Embraer EMB-120ER whose flight crew momentarily lost control of the aircraft while conducting a go-around. The crew’s training hadn’t covered sim use as at the time there wasn’t an EMB-120 sim facility in the country and no Australian regulatory requirement for sim training.

The ATSB report led to a formal safety recommendation being made to CASA recommending that the regulator address the issue. CASA identified a number of other incidents that occurred during emergency scenario flght training conducted in aircraft and proposed that when using sophisticated flight simulators instead of aircraft for emergency and non-normal scenarios training the safety risks are completely removed.

CASA argues that such incidents highlight the dangers and potentially catastrophic situations pilots and instructors are subject to when performing simulated emergencies in an aircraft. The lack of exposure to emergency scenarios in the training simulator environment, which enables pilots to fine tune their responses with minimal risk, can also lead to potential catastrophes in later operations.

CASA Standards Development officer Nick Strange, who is Project Manager of the discussion paper, says these safety concerns were the main motivation for the discusssion paper.

“In this context there are two primary issues that are drivers for the discussion paper,” Strange explains. “The first is the question of whether high-risk training activities should be limited to being demonstrated in simulators.

“Secondly, it is recognised that simulator training has the ability to equip pilots with a more thorough appreciation of how to handle aircraft during emergency situations, if they were to occur in the actual aircraft.

“Any benefits of using an actual aircraft would be negligible. Where risks can be mitigated (by way of a simulator) CASA encourages the use of simulators. Taking everything into account, a simulator is generally a more efficient, safe and useful tool for high-risk exercises.”

While sims have for some time been used during such training activities, a regulatory requirement mandating their use is yet to be put in place. Presently, under Australian regulations sim use is only mandatory when conducting low visibility training.

A quick comparison with overseas regulatory requirements suggests that Australia may well be slow off the starting blocks in examining possible mandatory sim use in high-risk scenario training.

In New Zealand, operators using aircraft with a seating configuration of more than 30 seats or a payload capacity of more than 3,410kg must ensure a flight simulator is used where a non-normal or emergency manoeuvre is conducted during training. In Canada synthetic flight training devices must be used for all initial and recurrent training undertaken by a Canadian air operator for turbo-jet and turbo-prop aircraft with a maximum certificated take-off weight of more than 8,618kg.

Elsewhere, in the US a suitably approved simulator must be used to conduct an operator’s low-altitude windshear flight training program.

Strange told Aviation Business that, as all of the major airlines already make use of simulators in their training and checking programs, it hasn’t been deemed necessary by CASA to mandate their use.

“Simulator use is encouraged in order to expose pilots to a greater variety of emergency scenarios, and many airlines do take advantage of them,” he says.

“Now it is being considered to extend simulator usage to regional-type airlines – which is not typical practice in other countries – by mandating simulators as per the ATSB recommendation.”

“I won’t say we’re behind the eight ball,” Graeme Smith of Ansett Aviation Training adds, “but I think what we ought to do is say, ‘Why do [other countries] have it as a mandatory requirement, and why don’t we?’. That question needs to be asked.”

 

Cost benefit

A byproduct of mandating sim training for emergency scenarios is the potential for reductions in total operating costs for the operator. In its discussion paper CASA highlights that the cost of hiring an Embraer EMB-120 flight simulator is approximately $750/hour, while in contrast utilising the actual aircraft may cost in the vicinity of $4000/hour.

CASA stresses that the main motivator should be the enhancements in safety, but nonetheless such training cost benefits will certainly provide motivation for some operators to support the mandating of sim training.

Smith gives further examples of the potential differences in operating costs: “To do emergency procedures training in an aircraft is potentially high risk to aircraft or aircraft components. To overheat an engine, for instance, is a hugely expensive process. Whereas if you do the wrong procedure in the simulator the simulator will soon tell you that you’ve done something wrong and you can repeat that exercise. So the risk in damage or high cost of training in an aircraft can be avoided. That’s probably the greatest benefit.”

But Smith suggests more education is needed to make operators, particularly those not already using sims extensively, aware of the cost benefits involved.

“A lot of operators of smaller regional-type aircraft have never been near a sim, so they’re not sure what they can get and what can be achieved with simulator training,” he explains. “So I think that’s another issue on which the industry must do a lot better – education. We have to educate those that are currently doing no training in sims that there is a financial advantage. And there is a significant one in some cases.”

 

Sim availability

CASA’s discussion paper admits that historically to a certain degree the lack of availability of sims in Australia has been an issue. This inevitably led to increased financial burdens on operators wishing to incorporate sim use into their training regimes as it added transport and accommodation costs to the bottom line. However, over time simulator technology and accessibility has advanced and that lack of availability has for the most part been addressed.

Should mandatory sim training be introduced, Strange says CASA will consider regulatory transition arrangements to facilitate compliance by operators who remain affected if a particular sim isn’t available locally.

Ansett’s Smith is adamant that, for aircraft over 5700kgs, Australian operators are covered by the sims on offer between Melbourne-based Ansett Aviation Training, Virgin’s simulator centre in Brisbane, and Qantas’ facilities in Sydney and Melbourne.

However, Qantas Airways’ head of training and checking, Captain Glenn Rowland-North, believes smaller regional operators may still struggle in complying with mandatory sim training due to the location of their crews.

“Australia is a big country, so there will be quite a few operators that will be affected by how they would be able to position their crew with the simulator,” Captain Rowland-North argues. “So there obviously would be some impact of cost on the operator if this was to be mandated across the board.

“Obviously it would be difficult for operators, particularly in the northern part of Australia, to be able to comply with any such mandating requirements. We’ve got operations right throughout Australia, particularly in remote areas where it would make this quite a difficult thing to implement.”

 

A broader approach?

While putting his support behind CASA’s decision to consult industry through its discussion paper, Captain Glenn Rowland-North remains adamant that a more holistic approach must also be adopted.

“Sometimes a one size fits all approach isn’t appropriate and sometimes there’s quite a few different approaches that can all achieve similar outcomes,” he explains. “Simulation is definitely one of the answers; it may not necessarily be the whole answer.

“I’d like CASA to be a little bit broader and look at how best we can look at training to mitigate these events in the future – a more holistic approach, not just simulation. Simulation is great, and it’s the perfect answer for most operations, but of course we don’t live in a perfect world as the discussion paper says. It’s very important that industry plays a large part in forming a unified view on how best to manage these events.”

Captain Rowland-North believes the overall aim should be to look at how to best risk manage emergency scenario training, taking into account all the factors of the equation and not necessarily looking solely at simulators as the final solution.

“Simulation is indeed an answer; it may not be the only answer,” he explains. “Risk modelling needs to be taken into account about everything, from how we train our trainers, how we train the people in the aeroplanes that we use to train them, and the way that we train. So it’s a complex piece, and I think this discussion paper is a starting point and I’m sure CASA will involve industry in coming up with a final outcome.”

 

Global collaboration

Qantas is one of a number of airlines currently participating IATA’s Training & Quality Initiative (ITQI). A joint project between IATA and ICAO, ITQI brings together airlines from around the world and examines the ways pilot training is conducted and the very different training requirements from country to country. Using evidence-based gathering from sources including Texas University, OEMs, Airbus, Boeing, and airlines themselves, the ITQI aims to look at all the various training requirements to understand what training pilots actually need.

“The group is working pretty hard to help develop training programs and give training guidance at an ICAO and IATA level to other States so they can see how they may be able to benefit from that group’s work,” Captain Rowland-North explains.

Both CASA and the FAA are reviewing ITQI, and Captain Rowland-North says Qantas are heavily invovled themselves.

“From a higher level perspective, I think that’s where we should be going in training – getting the best of the world and not just responding to regulation that possibly may have been put in place some years ago,” he argues.

 

The next step

Following submissions from various industry sectors on the issues raised in the discussion paper, CASA is currently tabling a Summary of Responses that it hopes to publish within approximately six months. Within the same time frame a proposed policy in the form of a Notice of Proposed Rule Making will also be released and subjected to further consultations and impact assessments.

CASA says it has not pre-empted industry responses to the discussion paper and that all responses and comments will be considered before deciding on an outcome and proposing new regulatory requirements.

The regulator admits it is conscious that the concepts involved in mandating simulator training are likely to have an impact on the industry, including imposing additional costs on some operators.

Strange says an assessment of business compliance costs and/or a formal Regulation Impact Statement consistent with Australian Government requirements will be prepared to assess the impact of any additional costs on operators, taking into account the safety benefits.

Rather than imposing any further amount of training or checking on operators, CASA says that mandatory simulator training would remove components of an already existing training and checking regime from an actual aircraft, and place them in the safer, more versatile environment of a flight simulator.

Smith believes this will introduce many new disciplines into the training environment which currently don’t exist.

“The impact on the industry overall probably will just be a change in disciplines to meet the regulator requirements for recurrency programs,” he suggests. “Some operators will probably have trouble given that they’ve never had to do that.”

Just what other impacts will arise and how far they are likely to reach remains a question of wait and see for now.

 

MPL on the road to validation

10 years on from its inception in 2000, the MPL remains a point of contention for some, while others are championing it as the way of the future. However, the dust is starting to settle as airlines continue to adopt the MPL program and active graduates increasingly prove the merits of the licence.

While the emerging evidence of the MPL’s success may come as a surprise to traditionalists and legacy airlines alike, training industry experts such as aviation training consultant and former Cathay Pacific Airways’ Manager of Flight Training, John Bent, suggest it was only a matter of time. While not directly involved in the creation of the MPL, Bent’s experience in drafting airline policy has kept him intimately in the MPL loop since it was first announced.

Citing industry sources in China, Bent says the six Chinese cadet pilots who graduated from Brisbane’s Boeing Training & Flight Services (formerly Alteon) in November 2008 as part of the world’s first beta test for an MPL course using ICAO’s blueprint have impressed upon their return to China Eastern Airlines and Xiamen Airlines.

“It is reported that China Eastern and Xiamen Airlines are most impressed by their new MPL pilots, and that they want more MPLs,” Bent says.

“I think the [MPL success] comes as a surprise to most airlines. The bigger airlines such as Qantas, Cathay, and British Airways have trouble with making significant changes when they’ve got programs they are happy with. But I think everyone who’s skeptical about MPL will become less skeptical as time goes on.”

While only so much validation can be measured by the success to date of the six Chinese cadets, one only has to look at MPL on a global level to appreciate the inroads it has made into the airline pilot training industry. There are now 62 MPL graduates worldwide and a further 440 currently under training, representing a sizeable industry investment in MPL in the three years since Boeing Training & Flight Services’ six Chinese cadets became the first to commence their training in 2006.

 

MPL misrepresentation

Critics often argue that the MPL is merely a knee jerk reaction to pilot shortages and airlines’ desires to lower training costs. This point of view has been given some credence by the fact that some training organisations are choosing to market their MPL courses purely as a quicker and cheaper option, while failing to highlight the core virtues of the MPL – improving quality and relevance of training – that drove the MPL’s development.

“In the year 2000 when MPL was started it was a slack year in civil aviation and there was no pressure to increase the speed of pilot production,” Bent explains. “So the criteria given to IATA and ICAO at the time was to improve quality and relevance, not to speed up the training process and make it cheaper.

“We did have a lot of spin going on about saving money and efficiency, and although it was never the intent to do this I think it will generate efficiences downstream.”

The primary strength of the MPL is the fact that it is tailored for the task, which Bent believes will lead to safer pilots who possess a skills set that’s completely and specifically focused on piloting airliners.

“From an educational perspective, if you can fine tune people for the task without going around into more generalised training you’re going to have a very focused product,” Bent explains. “The MPL contains the syllabus requirements which are essential to safety in the industry now, whereas the CPL doesn’t. The MPL lifts the bar on training requirements in many areas.”

 

Just around the corner

In a major endorsement, IATA has suggested that the MPL will eventually become the only avenue for cadets to enter airline operations. Bent agrees, saying that this could be the case in as little as five years’ time.

While proponents suggest that widespread industry acceptance now seems a question of ‘when’ rather than ‘if’, the MPL is still undergoing refinement. All airlines that initiate an MPL program are required to supply data to ICAO so progress and outcomes can be monitored to facilitate its ongoing development.

“There’s a lot to do on MPL, it’s only a framework,” Bent stresses. “People are populating that framework now with the intent written in the ICAO document, which is to do this and do that and if you’re not happy with the bare bones of the MPL then add a bit more fat until you are. And that’s what people are doing.”