OPERATIONS
Beyond pilot qualifications, the regs are vague, but common sense and operational approvals dictate a formalized approach to both initial and recurrent training
In aviation, we train to obtain knowledge and skills for initial qualification and certification as pilots and flight instructors, maintenance techs, flight dispatchers and flight engineers (if there are still any out there “flying sideways” in first-generation jetliners) and then periodically undergo recurrent training to review, reinforce and, in some cases, re-qualify for those disciplines. What is required in the U.S. for training and certification of pilots by the FAA was set forth in FAR Part 61 during the mid-20th century. The rules, which have not changed much in more than 70 years, are specific in terms of initial training, flight time and post-certification recurrent training. But on the operational side under Part 91, where many holders of Commercial Pilot and Airline Transport Pilot Certificates will eventually find employment in business aviation flight departments, the regulation itself is fairly vague in terms of training expectations other than pilot-in-command and second-in-command requirements and recurrent training for compliance under Part 61.58. (Commercial operations governed by Parts 135 and 121, on the other hand, are much more specific in terms of training requirements.) So, in devising a training plan for a noncommercial operation under Part 91, how would an aviation manager hired to put together a new flight department proceed? Obviously, the emphasis is going to be placed on designing a training regimen to reinforce competency and promote safety and risk management. The first two of these qualifiers is the obvious reason why we train; the third is a more recent component introduced to the operational realm by safety-management systems like the International Standard for Business Aircraft Operations (IS-BAO) and Flight Operational Quality Assurance (FOQA), the former introduced by the International Business Aviation Council (IBAC) and the latter by the FAA and oriented primarily toward commercial operators. A ‘Wide Birth’ Under Part 91 Conceding that training “is given a wide berth by Part 91,” Dan Boedigheimer, founding partner at Advanced Aircrew Academy, went on to observe that “little training is specified,” and the FAR only requires a Part 61.58 qualification for pilots. Originally, when the rules were formulated, this had to be conducted in the relevant aircraft for which the pilot was seeking a type rating (or a recurrent check) but now is permitted in a flight simulator covered under Part 142 at an OEM or training organization that has made the very expensive investment in the device.
GULFSTREAM AEROSPACE
“So, Part 61.58 allows training and a check for compliance,” Boedigheimer says. “It is aircraft-specific training. You can qualify the right-seat occupant to be second in command [SIC] in-house, but most insurance companies require simulator training for both pilots, depending on the type of aircraft and the experience level of the pilots. So, you will probably send both the pilot in command [PIC] and SIC to a Part 142 center for initial and recurrent qualification.” So, our new av manager’s first priority will be to ensure their PICs and SICs are properly qualified. Concerning the latter, a chief pilot we know commented that “SICs will have lower requirements: Can you train him or her in the airplane? Sure, but try and justify that with your insurance people. Also, the PIC may not be suited to train an SIC in the airplane, as not all captains are good teachers. Sometimes your insurance company may have stronger requirements than the FAA.” Beyond basic pilot qualifications, the flight department’s mission, or the nature of its operations, will determine what training will be necessary and how often it must be refreshed. If the flight department will be operating only domestically, a small set of FAA approvals will more than likely be necessary. On the other hand, if international operations are intended, then more approvals will be required. These, of course, are in the form of FAA Letters of Authorization, or LOAs, and for Part 91, they frame the operator’s mission, or what kind of flying the flight department can legally perform. “The only other thing that will drive training from the FAA’s perspective is the LOAs that the operator may hold,” Boedigheimer says. “This is where, for example, international procedures training will come in, as you may have to hold up to 11 of these LOAs, and we track about nine of them at AAA.” This collection, typical of international ops in oceanic airspace, includes A56 for controller pilot data link communications (CPDLC); B34, area navigation systems; B36, oceanic and remote nav using multiple nav systems; B37, Central and East Pacific airspace; B38, North Pacific airspace; and B39, North Atlantic high-level airspace. “The LOAs then specify what you must train for,” Boedigheimer adds. “You will have to have a manual explaining how you will train to comply with the authorizations. And this therefore becomes very operator-specific, as the requirement is coming out of the LOAs the operator holds. So, you may add in operator-specific requirements that the FAA has approved in the LOA. In addition to these, the operator may also hold LOAs for the minimum equipment list [MEL] and RVSM [reduced vertical separation minimum].” Next, there may be a requirement for precision runway monitoring (PRM) at some airports, not an LOA but a requirement for operations into some airports. Certain RNP-AR (required navigation performance authorization required) approaches also require this, and a periodic refreshment will need to be included in the operator’s training plan. Note that all these requirements driven either by LOAs or the above procedures may or may not specify training intervals, or how often the operator’s pilots must review and reinforce their knowledge and competency, and in the latter case the training interval may be determined at the discretion of the operator. This is where a safety management system (SMS) or simply the flight department’s operations manual can be used to determine the training schedule, e.g., annually or biennially. The foregoing represents the bare minimum for compliance. “But the Occupational Safety and Health Administration [OSHA] will require training, too, under CFR Part 1910,” Boedigheimer points out. “Also, if operating internationally, there are the ICAO Annexes--the state you are operating to may adopt these as their state regulations.” (And remember, when flying internationally, an operator is obliged to observe the rules of the state in whose airspace it is operating.) As an example, these rules may require training for carrying dangerous goods and the recognition of them. “You may not carry them,” Boedigheimer said, “but you have to be able to identify them.” Or anything going into your airplane. Need For ‘Evidence-Backed’ Training Beyond the minimum requirements enumerated here, Boedigheimer looks at adopting best practices and strategies for managing operational risk. “These would be covered under IS-BAO and the Business Aviation Safety Consortium [BASC],” he says, “and these would drive additional training requirements over and above the minimums. Adopting these standards can go a long way toward managing risk in my [hypothetical] flight department and may give me some insurance discounts and benefits, as well. So, consider adopting these, too.” But training must be relevant if it is to be truly effective, and this admonition factors into an ongoing discussion within the aviation industry--especially business aviation--about whether recurrent training should be structured around existing operational deficiencies, i.e., accident trends like runway excursions or unstabilized approaches. Thus, it should mirror the dynamic nature of operations. According to Nat Iyengar, a senior international Gulfstream 650 captain with Jet Aviation and member of the NBAA International Operations Committee, there is a pressing need for “evidence-backed training” addressing negative trends that have emerged across the fleet. “The biggest problem is that over the years the FAA keeps adding items to training, so now a training event becomes a checking event rather than a training exercise,” he told BCA. “There is a big push from the industry to do evidence-backed training--what issues we are seeing, what failures. You need to have this option to address nescient problems--what ‘hot’ trends we are seeing in the field.” For example, unstabilized approaches continue to be a problem, as is “landing long” while attempting to do “greaser” landings to impress the passengers--with the consequent result of overshooting the runway. “So, we [at Jet Aviation] are not doing the same check ride we have done for 50 years. We are now dealing with a totally different technology than half a century ago, anyway. But Part 61 hasn’t adapted to the new technology.” While Jet Aviation, a major international charter/management company overseeing a huge fleet of business jets, has the resources to design its own training regimen, a small Part 91 flight department, especially one with limited resources, is often forced to follow the existing regulation-driven syllabus for recurrent training. “They will do the same training they’ve done for years,” Iyengar says. “There is nothing original to their training. What resources do you have financially? FlightSafety International does offer an enhancement program, a four-hour, half-day, go/no-go course or a CRM [cockpit resource management] course, involving several hours in the classroom and several more in the simulator. But you have to have the money to support that. The reality is that Part 91 requirements are obsolete--they don’t address the modern SMS world we are living in now. We need more evidence-based training, copying the successful airline programs that allow the training center to provide a more flexible training.”
So, to be relevant, Iyengar believes, “You have to design your own training and be willing to pay for it. How do you want to operate, to the regulatory level--the very minimum required training--or the effective, real-world level? There is no training level under Part 91 to create an ATP. You have to be doing additional work. The only thing I have to do for my aircraft-specific training is to complete my Part 61.58 recurrent every 12 or 13 months, since if operating internationally you get a ‘grace month’ by the FAA.” Customizing the syllabus allows for Iyengar’s inclusion of “hot topics,” or training that addresses dangerous trends in the field. “We have a training module on runway excursions,” Boedigheimer says. “We track them all--25 to 30 a year--and whether we should we modify the training for them--for example, what has happened recently in business aviation where we operate into out-of-the-way airports that may not be monitored. We looked at 12 of these last year where the crews got outdated information on the actual conditions of the runways they were headed for: In other words, the conditions had changed. These [weather-related conditions] are dynamic changes and need to be tracked, especially at uncontrolled airports. They are business-aviation-specific operating conditions.” In devising a training plan that is relevant to problem trends, operators are also encouraged to frequently check out the NBAA’s top safety focus areas, i.e., the biggest risks globally for business aviation. The NBAA Safety Committee has identified these safety focus areas, including upset prevention and recovery training (UPRT), runway excursions, controlled flight into terrain, and ground and maintenance accidents. Training Considerations Another way to keep training from becoming stagnant is to conduct an annual assessment of the training plan to not only assure compliance but weed out items that are no longer relevant to the operator’s mission or the regulations. “Training can be made a lot more efficient this way,” Boedigheimer says, “that is, constantly assessing what is necessary and what can be eliminated as obsolete. Don’t do training out of inertia--that is, ‘What should we be training for and what can be eliminated?’ “One theme we hear constantly,” he continues, “is that ‘We train too much,’ when what we recommend is to train smarter, that is, conduct training that is more aligned with risks that are prevalent today.” So, the annual assessment should be configured to reassess the prevalent risks each year and to then modify the program to accommodate them. “You have to constantly refresh your training plan to keep it relevant,” Boedigheimer emphasizes. “Is it up to date; is it adapted to business aviation; and is it operator-specific--for example, ‘no night ops into dangerous mountain airports?’” An SMS can also be a guide for developing a relevant training plan. “What aircraft do I operate?” Boedigheimer posits. “What is the experience level of my team, and what are the areas we operate to? Under a safety management system, you can compose a safety risk profile that will drive your training needs assessment. I will want to review that annually, too, to prevent the program from becoming stagnant and, instead, be efficient and effective.” But Part 91 does not require an SMS, the anonymous chief pilot quoted at the beginning of this report points out. “An operations manual is not required under 91 either, but you are required to have a checklist: normal and emergency, single-engine performance data for multiengine aircraft, weight and balance data, and performance data. The ops manual is ‘what is,’ and SMS is ‘what will be,’ or the driver of change to improve your operation. The SMS is what forces you to audit your operation for continued safety. This is where lessons learned comes into force, not just SMS but NTSB accident reports, NASA studies and recommendations, and so forth.” He adds, “When you are a Part 91 operator, you can’t change the checklist from what the OEM has determined. What enhances safety in the cockpit more than anything else, though, is SOPs. Both pilots need to be reading from the same page.” And the operator’s training plan needs to reflect and emphasize SOPs, too, as well as best practices. Part 61.58 stipulates a 24-month check in the airplane or sim if it’s a turbojet or requires more than one flight crewmember to operate it. “But you can substitute a check in another airplane that requires two crew every 12 months,” the chief says. “I am typed in and fly a Gulfstream and a Hawker and will require a check every year in one or the other of them, and this can fulfill the 24-month requirement. But even if it’s not a requirement, good sense would dictate annual recurrent training at a factory-approved school. Not being current would fall into the same category: Do a sim check. This is why most training companies offer annual recurrent training contracts.” And how realistic is it for a flight department fielding turbine-powered aircraft to conduct pilot initial and recurrent training entirely in-house? Motion-based simulator training offered by business aviation support companies like CAE and FlightSafety is expensive, and it keeps pilots away from their jobs for several days. While operators on a budget might elect to train at home, it is a controversial subject. “Depending on your resources, you could conduct all your training in house,” Boedigheimer says. “Part 61.58 requires an authorized check pilot for pilot compliance, and you would have to contract that out if doing your own training. Or you could outsource the training syllabus or adopt one from a third-party source. This could be customized to accommodate the specific operation.” (See “How a Startup Flight Department Developed Its Training Regimen” sidebar.) But, according to our chief pilot friend, “There are times when we absolutely need to have to go back to school, if for nothing else than to know what is going on in the world--it gives you a well-rounded education and the advantage of lessons learned in the field combined with training and knowledge of the airplane.” Just as with the issue of hiring a sufficient number of pilots to staff a small flight department to avoid burnout (see “Finding a Balance Between Work and Personal Life in Business Aviation,” BCA, April 2019), if you can afford to purchase the jet, you should be able to afford an annual simulator check at a training center for the pilots who will fly it, thus ensuring the safety of you and your passengers. Then there is the issue of online video training, which became a necessity during the first year of the COVID-19 pandemic. “Depending on the subject,” Boedigheimer says, “what we saw when the pandemic hit was that many flight departments said, ‘Let’s accelerate the training schedule to get as much done as possible in the downtime we have available.’ But at that point, we didn’t know how long this thing would last. International procedures training was pretty much dropped, and now there is a backlog to get it done as the industry comes back on line internationally, and so, much of this is being done via computer.” Pablo Penalva, a Bombardier Global 6000 captain with Prospect Hill Growth Partners, reports that “During the pandemic we did our MedAire [cabin emergency medical] training on line--they shipped us a dummy to practice CPR. It was a full-blown class all day, and we did the classroom block in our respective homes. It wasn’t ideal but it got the job done. Last year, I did the full ground school for my pilot recurrency at home on the computer to reduce the time at CAE in Dallas. Doing it virtually that way, though, you miss out on the live action and exchanges--one of the most valuable experiences you get in attending in-person class. We learn a lot from each other.” In a large, structured corporate flight operation like a Fortune 500 company, training “is more cut and dried,” Penalva observes. “In our shop, it’s one airplane, three pilots, and a scheduler who also doubles as a flight attendant. If we had to plan for a new pilot, we would be looking for someone with experience in the Global Express. We train once a year at CAE in Dallas. We do FACTS [Frequency and Capacity Trends Statistics] training with Aircare International; that includes cabin safety and emergency procedures training, yearly for flight attendants and every two years for pilots. “And we contract with MedAire for the cabin medical emergency training, CPR and defibrillator (AED) every two years for full crew,” he continued. “We do our international ops recurrent every two years; same for security training. Our pilots also have access to our online ops manual and SMS on video, and we review that every quarter. We also review everything if we have a bunch of international trips coming up relatively together.” Both MedAire and Aircare come to Prospect Hill’s hangar with a trailer, and their instruction is conducted there. Don’t Get Upset, and Feel the Gs “At one time we did unusual attitude and upset training at UAT in Kissimmee, Florida, in an Aero Vodochody L-39 Albatros jet trainer and a TF-51 Mustang, one of the best trainings I’ve ever had,” Penalva enthuses (and no wonder: How many of us get to log dual time in the trainer version of a World War II fighter?). “It is extremely valuable trainingyou’re pulling Gs and relating to the whole experience--not like in a simulator. It’s a huge factor to be able to feel the Gs.” Our chief pilot commentator, who has developed his career in both the business and commercial aviation worlds, recommends that operators take advantage of every training opportunity they can. “As a professional,” he says, “you become responsible for your own recurrent training because there is not a department [as there would be at an airline or in the military] feeding you this information. OEM newsletters are a good source. Do your own risk analysis. For new flight departments, a flight risk analysis tool [FRAT] is recommended. You start with a score of 100 and then look down a list of objective indicators. Night ops is a -5; landing at night for the first time in 60 days is a -6; flying in certain parts of Africa is a -60, and so forth. FltPlan.com has a tool for this. You set your own risk thresholds that the company and insurer are comfortable with, and then you have an objective criterion for rating the flight as go or no-go. It might be as simple as ‘We are not going to fly into Aspen at night.’ Use the resources to make safety-based decisions. Use the tools to help you stay safe.” A Startup Flight Department In 2019, Silicon Valley software developer Adobe Systems launched an in-house flight department. As described by Adobe’s lead international captain, Bill Scanlon, this is how they put it together to operate and support a new Gulfstream 650. The operation currently has four pilots and is headed by Aviation Manager Candace Covington. Scanlon, her number two, has broad experience in professional aviation, including previous employment in Boeing Aircraft’s flight department. “We started at [FAR] Part 61, the type rating requirement,” Scanlon related to BCA. “In fleshing out the flight department, we did not consider new hires specifically with Gulfstream 650 experience; instead, we hired for background and attitude, experience with SMS, and an interest in and excitement about the challenges and hard work of starting a new business aviation flight department for a company like Adobe. The idea was ‘All hands on deck for starting a flight department.’ In April 2019, we accepted the airplane on Memorial Day. Candace Covington was hired to set up the department, and I was hired in late July that year.” Covington’s first priority was hiring the right people with industry experience and “great attitudes.” Scanlon was not typed in the G650, so his first challenge was to “get over to FlightSafety International (FSI) for initial. The last Gulfstream I had flown was the GV; the other pilots we’d hired also had Gulfstream experience, but that was not a requirement for being hired.” The next step was PIC qualification under Part 61.58. “If you are qualified in two types,” Scanlon said, “you can spread your recurrent training over two years [i.e., one type each year]. We have the luxury at the moment of only one type to get qualified in, and we have set our recurrent training interval for every nine months.” Composing an Ops Manual That Is Unique to the Operation There are some bare-minimum requirements for Part 91, Scanlon pointed out, but most operators strive to exceed them. “Competency is enhanced by creating a good training program,” he observes. “We used the downtime during the COVID pandemic for administrative work and devising a plan to support our being able to perform well at all times. For a start-up, he says, “one of the most popular options is to contract with certain training providers for an off-the-shelf operations manual--‘just insert your name and logo’--but the disadvantage to that is that it doesn’t always align with the values, approach and people you’ve brought together to create the operation. That option got us started, but then we went back and started from scratch to develop our own ops manual, written internally, and reflecting the uniqueness of our operation. These off-the-shelf manuals work and meet the regulatory requirements and are good for av managers who don’t have the resources to develop their own.” There are other resources that operators can use to round out their training, Scanlon points out. “The training providers like CAE and FSI are a great resource; they provide the training to meet the regulatory requirements and can tailor the training to your needs.” He mentioned a previous job he had where “we did ‘special emphasis training,’ an additional day working with the training provider. This costs more money but is well worth it for specific operations that might carry a higher risk factor--for example, approaches, landings and missed approaches at mountain airports like Eagle and Aspen. This is training focused on actual challenges the operation has to deal with in the real world. But it does cost money and the time of your pilots away from the job [i.e., off the trip roster].” Still Other Resources While larger flight departments with a lot of internal resources can develop their own supplemental training in-house, Scanlon observes, “We can’t do that now at our stage, so we use other providers like Advance Aircrew Academy [AAA] to meet supplemental training--for example, cold weather ops, international procedures, other subjects based on best practices and LOAs. AAA has developed online training modules to meet the needs of those typical LOAs--a great resource for departments that do not have those resources.” Networking can also connect flight departments to colleagues who have been through this before. “You don’t have to reinvent the wheel.”
