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Providing online training for business aviation professionals globally.
Author: Scott Macpherson
When TrainingPort.net started in 2006, there was a list of, at most, 20 topics that business aircraft operators needed to keep up-to-date. Most operators needed to keep up-to-date on a dozen or so of these topics, with a few operators needing additional items. Frequencies varied from semi-annual to triennial, depending on the operator’s specific operational risk profiles, but the topic list didn’t grow too much. Airborne Icing, Aircraft Critical Surface Contamination, CFIT, CRM, and several other topics come to mind as the standard requirements. Then there were Ops Spec related requirements, such as Low Visibility Takeoff Operations, to support LOAs or Ops Specs allowing RVR 600 or RVR 1200 takeoff operations, RVSM training for those flying at or below FL410, RNP-10 for authorized operators, and a very few other topics with recurrent training requirements.
Even then, some of the requirements seemed silly: RVSM refers to Reduced Vertical Separation Minima, and for those of us who have been flying that way from the beginning, it is hard to imagine why we don’t change the training requirement to only apply to operations above FL410 and call it “IVSM” for Increased VSM! Repeatedly training for the normal operation engenders contempt; this requirement is nearly 20 years old and out of line with reality.
There are other examples, and the only reason that they persist seems to be the unwillingness of regulators to recognize the norm, possibly because they don’t have the opportunity to gain the experience to know what it is or how it works. Often an experienced (this is becoming less and less true) aviation person enters government service and begins to fall out of touch with the operational realities of their “clients”. Fear of career-limiting activity prevents innovation and change, and hampers our industry. Clearly, regulators preach but do not practise (career) safety culture.
As ICAO Annex 6 has grown, national regulators in various parts of the world have struggled with too few experienced inspectors and technical staff to keep up with changes and the ability to determine what is necessary. Fearing sanction if they make a mistake or embarrass the politicians ultimately overseeing their bureaucracies, the staff of these bodies default to a “more training, more frequently” mode, which is hardly beneficial to operators, and often results in negative training. So, we now see a proliferation of authorizations and accompanying recurrent training requirements coming out of regulatory bodies that are grappling to understand a rapidly changing environment.
In the past few years, regulators have begun requiring operating authority for all kinds of operations, without having the background to determine if the authority is even necessary. Several examples come to mind, but let’s consider ADS-B, essentially a satellite transponder with more data transmission capability. In most corporate aircraft (like the EASy II airplane that I fly), it is turned on when you select an appropriate transponder mode. However, we don’t have, nor should we ever have (please) an Ops Spec for transponder use. This is basic flight training stuff.
Last week, Canada issued an advisory circular describing how to apply for Ops Spec 618 for operations in RNP 1 airspace. Shortly before this, Transport Canada issued an AC describing how to apply for Ops Spec 623, which permits radius to fix (RF) legs to be flown by aircraft that are not conducting RNP AR approaches. Although Ops Spec 618 is probably aimed at aircraft that are not capable of RF operations, it now appears that one possible interpretation of these two ACs is that one must apply for Ops Spec 618 in order to be allowed to apply for Ops Spec 623. Seriously?! If this is the case, we should just have an overriding Ops Spec for applying for Ops Specs. I wonder when we will require Ops Specs for receiving radar vectors in RNP 1 airspace, and what the recurrent training requirements will be for that one…We might also need Ops Specs for visual approaches in RNP 1 airspace. And an Ops Spec for base to final turns while approaching an NTZ between parallel runways…And what about that Ops Spec for operations above FL410, anyway?
This relatively good humoured rant is now over.
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Scott Macpherson is the President and Founder of TrainingPort.net and Vice-Chairman of the International Business Aviation Council (IBAC) Governing Board. He is currently Captain on a Falcon 900LX.