No More Inflight Selfies?

Well silly me for not keeping closer tabs on the Federal Registrar. I didn't know about this until a friend brought it to my attention, but in April the FAA published a final rule amending FAR §121.542 - more popularly known as the "sterile cockpit rule" - to include a prohibition on the personal use of laptops and personal electronic devices during all phases of flight. This isn't a huge surprise, because Congress told them to change the rule two years ago in a delayed reaction to the NW188 overflight incident in 2010. It's somewhat of a moot point now as the language is restricted to Part 121 operators and most airlines have already changed their policies to prohibit inflight pilot usage of PEDs. But the final language is a bit interesting, not least because it leaves somewhat ambiguous the question of whether it is legal to take a photo in cruise with a digital camera.

§121.542(d): During all flight time as defined in 14 CFR 1.1, no flight crewmember may use, nor may any pilot in command permit the use of, a personal wireless communications device (as defined in 49 U.S.C. 44732(d)) or laptop computer while at a flight crewmember duty station unless the purpose is directly related to operation of the aircraft, or for emergency, safety-related, or employment-related communications, in accordance with air carrier procedures approved by the Administrator.

First off, the reference to "flight time as defined in 14 CFR 1.1" means that this rule is applicable from the time the aircraft first moves under its own power to the time it comes to rest after landing - i.e., from taxi until parked at the gate. Though it doesn't say it in the reg, the FAA clarified in the final rule that the "personal" in "personal wireless communications device" refers to usage, not ownership. So this regulation also applies to company-provided EFBs or tablets if they are used for any purpose not directly related to operation of the aircraft, or emergency, safety-related, or employment-related communications. The real question is what exactly constitutes a "wireless communications device." The definition used comes from the Communications Act of 1934, which as amended states that "personal wireless services means commercial mobile services, unlicensed wireless services, and common carrier wireless exchange access service." In the final rule, the FAA further defined wireless telecommunications as the transfer of information between two or more points that are not physically connected. This would seem to exclude, say, an old-school iPod or cheap memory stick music player, yet the FAA included these as examples of devices which would be prohibited, as well as e-readers though the early ones had no wireless capability. Their sample list of prohibited devices doesn't really jibe with the language of the ruling.

What about cameras, then? There's no specific mention of them in the rule or accompanying discussion. It's pretty clear that a smartphone or tablet camera is prohibited. I suspect my little Nikon Coolpix is as well, since it has wifi & bluetooth transmit features. But what of my Nikon D5100 digital SLR? It has no wireless capabilities. Ditto for my first-generation GoPro camera. It's a gray area. Here's another potential loophole: the FAA says jumpseaters are excepted from the rule. So maybe, you can have a jumpseater fish your smartphone out of your bag and take a photo! But don't ham it up too much for the camera, the feds might call that "use!"

It's a moot point for me, in any case. My new airline has FOM language that is more restrictive than the FAR, as it includes both pilots and jumpseaters using any electronic device not certified for use in the aircraft, and actually begins with the reading of the Pre-Flight Checklist (typically 10 minutes prior to pushback). I originally had the idea that my old Nikon N60 35mm SLR would be allowed, but then realized that as old school as it is, it does use electronics for autofocus, metering, and film rewinding. So it looks like the one legal camera to use for inflight cockpit shots at my new airline is one of those 12-shot disposable film cameras...as long as I can find one without a flash! Sorry to say, I don't think you can expect any more inflight shots from me, at least in the Mad Dog.

Now the Cub? That's still fair game! The feds seem hellbound on legislating airline pilots straight to sleep, but thankfully we can still have some fun in GA!

The Way We Train Today

The last fifteen years or so have seen a significant change in the way that airlines train their pilots, even though in many cases the airplanes themselves have not changed (the Mad Dog being a perfect example - it's a mid-80s update to a 1960s design). The methods of instruction, means of evaluation, areas of emphasis, training footprint, and regulatory framework are all completely different than they were through most of aviation history, up until the late 1990s. There were many factors behind the seismic shift: advances in technology, greater data collection and analysis, human factors and CRM research, cultural shifts, and aggressive airline cost-cutting. Whether the new system is better is still occasionally debated by line pilots, but it's almost certainly here to stay.

I arrived at the airlines midway through the changeover, and so I got to see a glimpse of the old ways during new-hire training at Horizon, when they were just beginning to change their program. Other than that experience, most of what I know of how it used to be has been related to me by older pilots, instructors, and check airmen.

Under the old regime, there were three distinct, separate phases of training: ground training, flight training, and checking. "Ground School" typically lasted several weeks and covered all aircraft systems, limitations, and emergency procedures in great detail. Everyone - Captains,  Copilots, and Flight Engineers - was expected to learn aircraft systems at an aeronautical engineer level of understanding. Because the QRH (Quick Reference Handbook) concept was still in it's infancy and cockpit warning systems were still fairly rudimentary, it was expected that flight crews be able to diagnose malfunctions instinctively through advanced knowledge of the systems involved. This knowledge was tested through lengthy oral exams in which the questions occasionally reached a ridiculous level of detail ("How many rivets are there on the left wing?") that had little to do with the actual operation of the aircraft.

Flight training was originally conducted in the actual airplane - mostly at night when it wasn't needed for revenue operations - but moved into full-motion flight simulators as they become more advanced in the late 1970s and early 80s (later for smaller regional aircraft). The emphasis was mostly on specific maneuvers required to be tested by the FAA, and especially V1 cuts, single-engine approaches, and various other emergencies. There was little emphasis on line flying during initial training; this was reserved for line check airmen conducting Initial Operating Experience (IOE) during revenue operations. In the late 80s and 90s, as CRM became a greater emphasis item, the FAA required that airlines tack on a few LOFT (Line Oriented Flight Training) events to train & evaluate crews in their use of CRM during line operations. This was practically an afterthought at many airlines, and usually a non-jeopardy event.

The culmination of training was the "checkride," the Proficiency Check required by FAR 121.141. There was really no checking before the PC; though the instructors ultimately had to sign you off, you weren't under the microscope during training events. Woe to the pilot who failed a PC, though! At many airlines, failing a PC could be a career-ending event, especially if you were a new hire. And you could - and would - be failed for very minor deviations from ATP Practical Test Standards. Everything was geared towards passing the PC. Even at Horizon in 2004, for new hires it was a high-pressure event in which you were expected to perform flawlessly if you wished to stay employed.

Nearly all of that is gone now. First off, ground school is almost an anachronism. The vast majority of systems training is done via Computer-Based Training (CBT) - usually at home, on your own time, though most airline contracts still pay you for it. You may or may not get paper reference materials - at NewCo if you wanted them you had to print them off the PDFs at your own expense. Far better to learn to love Acrobat, and Ctrl/Cmd-F is your friend. The level of systems knowledge taught is far, far less detailed than in years past. If you're the sort of person who actually likes to know the path that an air molecule takes on its journey through an Air Cycle Machine, good luck finding that information in anything the airline provides you. They don't expect you to know it, and you will not be tested on it. The reality is that they'd just as soon have you not know it. Over the years they've come to the conclusion that crews attempting to diagnose systems malfunctions make things worse as often as they make things better. Now crews are expected to religiously use QRHs any time a system abnormality is encountered, which combined with greatly advanced indication & warning systems has greatly simplified the task of dealing with malfunctions. Meanwhile the number of aircraft limitations and emergency recall items expected to be memorized has been greatly reduced, essentially to only those time-critical safety items that aren't easily referenced in real time.

Nearly all airlines have moved to the Advanced Qualification Program (AQP) regulatory framework which replaced the old system of separate flight training and checking events. Training and checking are practically the same thing now. AQP programs typically consist of several blocks of training each consisting of a number of training modules followed by a validation. Each module has completion standards associated with it, essentially turning every event into a checking event that can be failed & required to be repeated. Meanwhile the validations are not 100% checking events; many allow for some degree of retraining and repetition of unsatisfactory maneuvers. Rather than being purely "pass-fail," most events are graded on a scale both by maneuver and by competency. For example, you may have flown a "5" V1 cut (good!) but only get a "2" in use of CRM (bad!). A mid-level passing score may involve some deviation from ATP standards, but with early recognition and correction.

Typically the earlier blocks of training now take place in "paper tigers," "systems/procedures trainers" (SPTs),  & "flight procedures trainers" (FPTs). These are all non-moving simulators of varying sophistication in which the pilot cements systems knowledge, learns flow patterns, and practices "buttonology" and basic flight procedures before moving on to the more elaborate & expensive full flight simulators. In the flight simulator, the initial emphasis is on maneuvers such as steep turns, stalls, V1 cuts, approaches, go-arounds, and landings. These lessons are followed by a Maneuvers Validation (MV) which is very similar in format to the old Proficiency Check.

LOFTs now typically make up the entire last block of training and are followed by the penultimate checkride, the Line Oriented Validation (LOE). These events help ease the transition to Initial Operating Experience, and allow the trainee to see a variety of emergencies under realistic line conditions. Where the emphasis used to be on individual performance, now crews are now expected to use all available resources in dealing with abnormal situations, exactly like they would on the line. It's entirely possible to fail a LOE by responding to a malfunction with the correct technical actions but in a "lone ranger" fashion. It's equally possible to fail the LOE for failing to speak up when your partner is doing something boneheaded.

The end result is a training footprint that is considerably shorter than in years past, and less use of the full flight simulator, which the airlines love for cost and scheduling reasons. Much of the burden of training has been shifted onto the pilot; rather than just showing up and expecting to be spoonfed, you have to do a lot of homework before training begins or you'll never keep up. That said, you're expected to remember a lot less total information than in years past. The pressure of training events has gone up, but the pressure of checking events has gone down. It's harder to flunk out, but it's also harder to sail though.

This is what the training footprint looked like on the Mad Dog (it's actually changed somewhat since, I was the last person to go through this curriculum):

• 4 modules Systems Training. 2 SPTs, 2 FPTs. Electronic Systems Validation (eSV), an extensive computerized written test that replaces the oral exam. 
• 4 modules Procedures Training. 4 FPTs. Procedures Validation.
• 4 modules Maneuvers Training, all in full-flight simulator. Maneuvers Validation.
• 4 modules Line Oriented Training, all in FFS. Line Oriented Validation. 

This is very similar to most airlines' training footprints today, including NewCo, United, USAirways, and Spirit (have had friends go through all those programs lately).

I'm happy to say that I passed each event on first try and did particularly well on the 4 validations. I studied my tail off and was assisted by a very sharp sim partner, one who had actually been a Mad Dog captain before he was displaced back to the right seat. He also happened to be an avid motorcycle rider and I had a bike in town, so we snuck in some fun rides to decompress from the grind of training. The one big hiccup was when I came down with shingles - on my face! - the day before my MV. The APD (check airman) rightly insisted that I call in sick for the MV for various reasons, not the least of which was he'd never had chicken pox and could therefore get them from me. I got on meds right away and only lost a few days, and the training department was great about rescheduling me. Unfortunately they sent my sim partner ahead without me, so I was by myself or with seat support for the remainder of training. It still went quite well. I had a very good LOE on Tuesday, sat on Mad Dog jumpseats for an observation rotation on Friday and Saturday, and start IOE tomorrow. I'm really looking forward to it. The Mad Dog is a very interesting, busy airplane, a unique combination of old and new. I'll write about that in my next post.