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The Standards Approach

By By Joseph Ambrogne | August 1, 2015



Colorado Heli-Ops already has begun incorporating risk management and other elements of the new standards in its training course outlines. Here, CFI Tyson Bolduc performs a discovery flight for a new student.  Photo by Dennis Pierce, courtesy of Colorado Heli-Ops

Any good CFI will tell you that the secret to performing a stellar takeoff to a hover is ascending to a stable two-to-five-foot height above ground and holding your heading to +/-10 degrees of your flight path. Well, maybe there’s a little more to it. But on paper, that’s how you prove to the designated pilot examiner that you have the hovering skill required to earn your pilot certificate. It may not cover the myriad variables that affect if and how you even attempt a hover, but that 10-degree, two-to-five-foot margin demonstrates your capacity to perform the maneuver, according to the Practical Test Standards (PTS)—the FAA’s primary document for how we certificate helicopter pilots in the U.S.

The PTS have been the linchpin in the certification process for decades. Pilot examiners use them to conduct practical flight tests. Certificated flight instructors (CFIs) refer to them as a guide for developing lesson plans. Student pilots are told from the very first day of training that they will be tested against their contents. The PTS have also, by the way, been deemed inadequate. They’re on their way out.

You may not have heard this yet, because nearly all developments have occurred in the fixed-wing industry. But the FAA has been developing a replacement to the PTS.

The proposed, called Airman Certification Standards, take the focus off a maneuvers-based approach to training—as in maintaining that two-to-five-foot height at all cost. Instead, they emphasize a risk management process designed to encourage pilots to exercise better judgment. Experts believe that when these new standards are in place they will go far toward reducing accidents in and out of training attributed to pilot error. Though their adoption may require flight schools to revise their training materials heavily, at least two such schools already are incorporating the proposed standards in their curriculums.

The Problem with Numbers

Colorado Heli-Ops uses flight simulators as part of its training programs. Depicted here is one such device built by Merlin Simulation.  Photo by Dennis Pierce, courtesy of Colorado Heli-Ops

A June FAA presentation noted that the PTS have acquired a series of “barnacles” in the form of Special Emphasis Areas. Presented separately from the flight maneuvers comprising the bulk of each PTS booklet, the section lists topics that nevertheless are “considered critical for flight safety,” and which therefore should be evaluated during—not apart from—the performance of each maneuver.

For example, the Special Emphasis Areas on page 5 of the 2005 Private Pilot Rotorcraft PTS include subjects like aeronautical decision-making, risk management, wire-strike avoidance, positive aircraft control and “other areas deemed appropriate to any phase of the practical test.”

Vague descriptions like that not only make it hard for pilot examiners to determine exactly how to rate a pilot’s aptitude in risk management during an off-airport landing maneuver, for example, but they make potentially lifesaving concepts seem like little more than afterthoughts.

They may also impart a greater emphasis on a numbers-based approach to flight. But some of those numbers (like maintaining a heading within +/-10 degrees) are arbitrary; others border on illogical.

Nick Mayhew is a member of the U.S. Helicopter Safety Team (USHST), a group of industry and government leaders working to improve U.S. civil helicopter safety. That team volunteered to evaluate the Airman Certification Standards concept for helicopter flight training and point out problems specific to that industry.

Michael Arditi, Bristow Academy’s EASA training captain, is helping draft new training course outlines that prioritize higher-order thinking skills over by-the-book maneuvers. Photo courtesy of Bristow Academy

“For the CFI practical test in the PTS, you have to do a full touchdown from a 180 autorotation,” said Mayhew, whose full-time job is commercial programs manager and head of European Aviation Safety Agency training at Bristow Academy in Titusville, Fla. The PTS refer readers to the Helicopter Flying Handbook for the technical details. That book says all 180 autorotations should be begun between 500 and 700 feet AGL.

“So the instructor gets hold of that and says ‘I must go out and train my student to do an autorotation from between 500 and 700 feet,’” Mayhew said. “So they go out there and come in at 600 feet or 500 or 700, and that’s what they do day in and day out.”

For non-pilots: a 180-degree autorotation is a power-off landing that involves turning around mid-descent to land in the opposite direction. It’s also an overwhelmingly fun, or harrowing, experience—depending on your perspective.

Mayhew said a better way to teach the maneuver to a new student might be to enter the autorotation from 2,000 foot AGL and terminate it well before reaching the ground. After all, you can’t crash into the sky. This would give the instructor far more time to regain control in case of a mistake, while alleviating the tension a student might otherwise feel at, frankly, seeing the ground rushing forward at high speed.

That said, the Helicopter Flying Handbook explicitly states that the 500-700-foot entry is just one of many acceptable training methodologies. Readers would be well within their rights to question why anyone would take the PTS or its references literally. One could fairly point out that the PTS was never meant to take the place of common-sense training.

One might even suggest that it’s the CFI’s responsibility to go above and beyond the baseline standards. One would be right.

But as USHST’s Mike Franz pointed out, the flight training industry has more challenges to overcome than simply improving safety. The competition between schools means that a bottom-line-oriented mindset is rewarded.

Colorado Heli-Ops Chief Pilot and CFI David Dziura is an advocate for the new standards, which promote a learning philosophy he said “drives a safer industry.”
Photo by Dennis Pierce, courtesy
of Colorado Heli-Ops

“Flight training is expensive in airplanes, let alone helicopters,” said Franz, owner of Naples, Fla.-based school HelicopterSBT. A school that charges $12,000 to train a pilot well beyond the baseline may not be able to compete with one across the field that charges $9,000 to teach minimum standards. “The PTS, which is a minimum standard, has become the training standard—and it was never intended for that.”

It is unclear exactly how the Airman Certification Standards might affect future versions of the Helicopter Flying Handbook or other materials, though it’s possible that authors eventually will work backward from the new standards to develop better quality supplements. The new fixed-wing standards, however, have been tested in training by the FAA’s Orlando, Fla., Flight Standards District Office. That experience presents a clear picture of how the Airman Certification Standards may work.

For a given flight task or area of operation, the new standards would replace the numbered list found in the PTS with three subcategories of standards: knowledge, skills and risk management. Items within each subcategory are given a unique code instead of vague Special Emphasis Areas. Each code should map logically to both test questions and specific sections of the reference texts. Codes are comprised of a standard, the related area of operation, the specific task and the specific element of that task. With a basic legend, the codes shouldn’t be that hard to decipher.

For example (from the fixed-wing set), PA.III.B.K4 translates to Private Pilot Airplane (PA), Airport & Seaplane Base (III), Traffic Patterns (B) and Right of Way Rules (K4).

This system is intended to have three benefits. First, students and CFIs should know exactly where to find reference material behind a given standard, perhaps down to the exact page. Second, students should see the same codes at the bottom of their knowledge exam reports, indicating exactly what questions they missed. That should make remedial training a lot easier. (Currently, the computer test reports use a system of learning statement codes (LSCs), which often are too broad to locate the specific item that the student misunderstood.)

Third, the new standards’ inclusion of risk management elements within each task is intended to encourage CFIs to discuss risk management with students throughout flight training. It also should give pilot examiners exact criteria for passing or failing a student during a practical test.

Of course, this all means that rotorcraft training curriculums—particularly at the highly regulated Part 141 flight schools—eventually will change. It remains to be seen exactly when and how the necessary information will spread throughout the industry. The FAA’s goal is to have at least one set of Airman Certification Standards ready for implementation by 2016, though that most likely will be for a fixed-wing private pilot rating. Implementation may not reach the rotorcraft industry for another few years. Franz suggested that the FAA might issue an advisory circular to give flight schools advance notice.

Education about the new standards is going to be required, said Franz. “I see a time where flight instructors, flight schools, curriculum developers, designated pilot examiners and FAA aviation safety inspectors are all in transition mode and trying to adapt to this.”

That will be an immense task, Franz said. USHST team members realized they were in a perfect position to spread the word about the new standards.

Franz founded HelicopterSBT to teach the FAA Industry Training Standards, an approach developed at the turn of the century to reduce the accident rate for “technically advanced aircraft,” a new classification at the time that included Cirrus and Diamond models. That approach combines scenario-based training with the PTS.

That work put Franz in frequent contact with the Denver-based flight school Colorado Heli-Ops. As he collaborated with it, Franz also gave the school drafts of the Airman Certification Standards. That led the school to begin revising its training materials well ahead of formal implementation.

“We’ve tried to do our part in understanding from the drafts what’s going to be out there, and to make the training course outlines conform to that,” Franz said, “so the principal operations inspectors don’t have to come back to flight schools and say, ‘Hey, now you’ve got to redo all of these.’ We’ve added all the elements in.”

Colorado Heli-Ops chief pilot David Dziura said adapting the fixed-wing Airman Certification Standards for helicopters has been a relatively simple process. “For example, the lesson on departure procedures has all the ACS standards for risk management integrated from the airplane ACS as it stands, but edited as necessary to make sure that we aren’t talking about stalls on departure and other things that don’t apply,” said Dziura. “We’ve found it really useful, because when you look at the syllabus, [risk management elements are] integrated right into it.”

Those elements include “things like risks associated with using outdated publications or short wait times, the way the winds are on takeoff, non-radar environments, and accepting an ATC clearance that you don’t understand,” he said. “It’s nice that they are highlighted directly and associated with that lesson, because it’s going to increase the standardization.”

Dziura said Colorado Heli-Ops believes in the Airman Certification Standards’ value and isn’t simply trying to get ahead of any looming requirement. “What drives a safer industry, and makes a smarter industry, are all of those things that are not the flying aspects,” Dziura said, adding that he looks forward to “more discussion of human factors in risk management, which I really think are being recognized as a major causal factor of issues in the industry.”

At Bristow Academy in Titusville, EASA Training Captain Michael Arditi is part of an effort to revise the school’s flight training programs. That is due partly to Mayhew’s long-term involvement with the school and comes in response to the Airman Certification Standards.

Leading By Example

Bristow is “pushing forward in trying to make sure that we could actually do this,” Arditi explained, adding that “what we’ve started to do is formulate a whole new approach to the way that helicopter training has been done.”

Bristow Academy is the world’s largest private helicopter flight school, with locations in three U.S. states and one in Europe. Its large number of flight lessons generate a huge training data base, and the financial backing of its parent company, Bristow Group, gives it the resources to analyze the data extensively. The academy uses its safety management system and air safety reporting structure to collect data from flights that fail to go as planned. This allows CFIs to find and fix negative patterns in training, and it puts the academy at a distinct advantage over smaller flight schools in being able to properly implement the new standards.

Smaller schools “don’t have that many students that have come in and reproduced that role,” said Arditi. “It’s going to be hard for them to reproduce those numbers” without a big fleet.

In analyzing the data, Arditi and his colleagues have noticed the occasional trend in superficial learning that stems from a numbers-oriented PTS approach. This manifests itself during emergency procedures, with some students reacting reflexively without first pausing to consider the best course of action.

In response, the academy is rewriting its training procedures to ingrain better, more analytical habits in students from the moment they set foot inside the cockpit. Instead of reacting out of fear, Arditi said, he would like to see students use aeronautical decision-making, a systematic thought process based on considering one’s options and taking calm action. He cited the 2009 accident in which a USAir flight lost power on takeoff and its captain made an emergency landing in New York City’s Hudson River, saving all 155 passengers and crew. That made the captain, Chesley “Sully Sullenberger, famous.

“He acted so slowly, but made very definitive actions,” Arditi said. Sullenberger opted against returning to LaGuardia Airport, telling ATC “Nope, we’re going to be in the river.”

He “made his choice, but then he acted very slowly to make sure that choice came to the best possible conclusion,” Arditi said. “It wasn’t a rapid exercise in fury.”

Arditi and others are quick to point out that they aren’t trying to downplay the quality of smaller flight schools. Nor will they pin the misuse of the PTS or other materials on those schools. Arditi cited a number of possible reasons why helicopter flight training has suffered, ranging from strict adherence to FAA policy to a lack of visibility to the behavior of past students. He said CFIs may even fear leaving published performance boundaries and risking a loss of life or equipment. “It’s a challenging world out there for all of them, so I don’t want to diminish their role, or the fact that they still produce quality pilots, because they do.”

Neither is Bristow Academy’s goal to dominate flight training, he said. Instead, it hopes to spread its lessons learned to other schools, so higher-quality training can prevent accidents that, in recent years, have given helicopters a bad name. Arditi called what he and his colleagues are doing “slightly revolutionary” because “what we are really finding is that there are things that were literally right in front of our eyes that have just appeared, because we started to look at them a little longer.”

The Airman Certification Standards for helicopters are years away from becoming official. But any flight school interested in learning more is encouraged to contact the USHST. Additional information can be found on the FAA’s website.

The quality of training hinges to a large extent on a student’s attitude. There always may be a debate about whether the industry can teach better decision-making skills to pilots. But if the proposed changes reduce training fatalities even slightly, then they will be worth every revision.

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