Sea Change

When I wrote the series of posts on Colgan 3407 back in May, I noted that the new FAA administrator appeared to be receptive to changing crewmember rest and duty rules, and that the Senate's Aviation Operations, Safety, and Security Subcommittee was preparing to hold hearings on the Colgan crash in June. I noted that it would be "interesting to see whether any substantial legislation emerges from the process." I didn't say what I thought the chances of that actually happening were. Pilots are pessimists and cynics by nature. I knew that the FAA had proposed rewriting rest & duty regulations in the past only to be cowed into submission by intense airline industry lobbying. I presumed that the Senators were simply doing what Senators do best: providing themselves with a platform to bloviate and look Senatorial (or better yet, Presidential) while the attention of the country was still focused on air safety.

I may have been wrong.

We now appear to be headed for some of the most sweeping regulatory changes the industry has seen since deregulation, or the Federal Aviation Act of 1958 before it.

The FAA has convened an Aviation Rulemaking Committee (ARC) to rewrite the regulations concerning crewmembers' flight time, duty time, and required rest periods. The committee, which is comprised of FAA, industry, and labor representatives, started meeting in early July and has been given a September 1st deadline to make a recommendation to the FAA. Administrator Babbitt has stated that he wishes to have new regulations in place by the end of the year. The Air Transportation Association and other industry groups are rather wisely supporting the aggressive rewrite, in public at least. These are the same airlines that sued the FAA earlier this year to halt a very modest rewrite of rest rules for flights over 16 hours.

The few rumors to emerge from the ARC thus far indicate that maximum duty time will decrease by several hours, weekly and monthly duty time may be restricted, rest periods will be lengthened or will reflect time actually at the layover (right now transportation to and from the hotel is considered "rest"), and maximum duty time may be limited for late afternoon and evening show times. Work is reportedly proceeding very quickly and the airline industry participants have not stonewalled and created deadlock as happened in several past ARCs.

Meanwhile, the members of the House of Representatives' Aviation Subcommittee have introduced bipartisan legislation H.R.3371, "Airline Safety and Pilot Training Improvement Act of 2009." It goes to the full House Transportation and Infrastructure Committee tomorrow, and if approved there, on to the full House sometime after the August recess. A corresponding bill has not yet been introduced at the Senate's aviation subcommittee, but based on statements from both the majority and minority leaders during the June hearings I don't doubt that one will be forthcoming.

The full bill isn't yet available to the public, but the summary linked to above contains the following high points:

• Require all airline pilots, not just Captains, to hold an Airline Transport Pilot certificate (1500 hours total time, among other requirements).
• Establish tougher screening criteria for airline pilot interviews.
• Create a Pilot Records Database to include licenses, ratings, check rides, and "pink slips," both from the FAA and employers, to be used for hiring purposes only.
• Require mentoring programs for new-hire pilots and command/leadership for Captain upgrades.
• Require stall recovery training at the airlines, and forms a FAA task force to study requiring training in stick pusher usage.
• Study whether the airlines' new hire and recurrent programs provide enough time to cover the necessary subjects in great enough detail.
• Require the FAA to implement new flight time and duty rules within one year.
• Requires air carriers to create FAA-approved fatigue management systems.
• Require websites that sell tickets to disclose who actually operates a flight on the first page that flight is displayed on.

If this legislation ends up being passed by both chambers of Congress and is signed into law in its current form, it will be a big, big step forward in addressing a lot of the industry problems that I've written about on this blog over the years. I'm eager to read the actual legislation, but here are a few first reactions to the rough outline we have now.

First, there is no doubt in my mind that every pilot sitting up front on a Part 121 airliner should have an ATP. For most of the industry's history this hasn't even been an issue. Even back in the late 1990s when the major airlines had multiple years of record hiring and the turnover at the regional airlines was huge, your resumé wouldn't even get looked at if you didn't have ATP minimums. A few years of hard work flight instructing and freight dogging was the norm, and the regionals enjoyed a steady stream of experienced newhires. The conditions of 2005-2007, where it was possible to get hired at many regionals with little more than a fresh commercial certificate, were the direct result of the destruction wreaked upon the piloting profession in the post-9/11 era. There were still plenty of pilots out there with more than ATP minimums, there were just very few willing to prostitute themselves for poverty-level wages and the eventual chance of being hired by one of the major airlines (which themselves had become much less lucrative). Rather than offer higher wages and threaten their business model, regional airline management conveniently took the view that experience doesn't matter, and their major airline partners looked the other way. Well, experience does matter, and if the airlines aren't willing to do what it takes to attract experienced pilots, Congress is entirely right to force it on them.

I've already heard objections to this by some pilots, mostly those without ATP minimums or who were originally hired with low time. I say putting in another year or two of entry level work isn't going to bankrupt anyone - it generally pays as well or better than first year regional wages - and the experience will serve them well throughout their career. It will also weed out less committed pilots, tightening the job market and giving pilots the leverage to make a livable wage at the regional airlines. Heck, the increased labor costs at the regionals could even destroy this accursed two-tier system that was destroying their careers before they even began.

An electronic pilot records database is a welcome and overdue replacement for the inefficient mish-mash verification system in place now. Right now the airlines use a FAA database to verify certificates, type ratings, and medicals, and check whether enforcement action has ever been taken against the candidate. They then contact the candidates' previous employers for the last five years to verify that the candidate's employment, training records, and check for flying-related disciplinary actions; if the previous employer is out of business or doesn't bother to forward the records, the hiring carrier assumes everything is OK. They check the National Drivers Records database for prior DUIs or DWIs. Otherwise, they simply rely on the candidate's word regarding FAA or Part 141 checkride busts, accidents/incidents, and training or disciplinary events at employers more than five years ago. Obviously in this digital age there is a better way to do this. Many pilots will complain that airlines might not hire them based on a long-ago Private Pilot checkride bust but that's simply not true: most airlines today ask about checkride failures and are mostly concerned about a pattern of failures. Presumably they're truthfully answering the questions on the application, so why object to a database that verifies the information they willingly give the airline?

The hiring & training items - pre-employment screening, mentoring & command/leadership programs, stall recovery/stick pusher training, and study of whether airlines alot enough time for training - are all things that the major airlines and the "better" regionals do already. This is really aimed at some of the smaller or more cost-obsessed regionals who have been trying to eke by with the legal minimum. It's a recognition that safety programs and training are not the place to compete on costs.

The requirement that the FAA publish new flight and duty regulations within one year strikes me as odd given that it's well known that such regulations are in the works right now. I suspect this was inserted to put the industry groups on notice that foot-dragging and stonewalling will not be tolerated this time around. The requirement for airlines to create FAA-approved fatigue management systems is intriguing to me, I'd like to hear the details. Depending on how it's structured, it could become either a meaningless formality or a forced change to the airlines' "our crews are legal, therefore they're safe" approach to fatigue.

The final item, requiring ticket sellers to disclose who really operates a flight before the customer selects that departure, seems reasonable from a public-right-to-know standpoint, but I doubt it will actually affect many passengers' purchasing habits. At best it makes the airlines slightly more sensitive to negative publicity concerning safety programs and practices, making the adoption of voluntary programs like ASAP and FOQA more likely. In reality all the major websites (Expedia, Travelocity, Orbitz, Priceline, Hotwire) already make this information readily available before booking, although sometimes not on the first page.

My reaction to the new rest regulations will have to wait for when the FAA actually publishes a Notice of Proposed Rule Making, but based on what we're hearing it sounds like the rules will address the most egregious scheduling practices at the airlines today. Unfortunately it will significantly decrease pay and even time off at some airlines, particularly at those regionals without rigs or daily minimums in their contracts. That's a pill I'm willing to swallow in exchange for a safety improvement we've been demanding for so long, plus the fact that these rules will likely force airlines to increase staffing, putting many currently-furloughed pilots back to work.

Obviously none of this is set in stone; I don't doubt that as the airline industry remains supportive in public, they are furiously lobbying against these changes both at the FAA and Congress. We'll see just how much of this actually makes its way into law. That said, there's more momentum for substantial change than anytime in recent history, and I'm guardedly optimistic.

The Old Guy

Larry is, in many ways, a very typical specimen of an airline pilot of a certain age. He has been flying for quite a few years, and has the head of grey hair (thinning just a little on top) to prove it. He worked his way up from the "commuter" airlines back in the day, flying the ubiquitous Beech 1900. He was then hired by a major airline, where he progressed through the 727, 737, and 757 before upgrading to Captain on the 737. He flew scheduled service and charter, domestic and international; he crossed the North Atlantic a number of times but mostly bid for mainland-Hawaii runs, which were the most convenient trips to commute into from his home near Denver. Now in his 50s, Larry has reached the point in his career where all those years of hard work start to pay off, and for his last ten years or so, he enjoys a top salary and his choice of work schedule.

Or rather, that's what he was looking forward to until his airline, ATA, hit financial troubles and shut down, abruptly putting Larry out of a job. Now he is a junior First Officer for NewCo, flying the JungleBus for $23 per hour - far less than he made flying the 19-seat Beech all those years ago, when adjusted for inflation. On his last trip, Larry flew with a 28-year old Captain who has a mere five years of airline experience and who has never been a Part 121 Captain before - namely, me. Now, one could expect Larry to be fairly bitter over this turn of events, but he's taken it in stride, and is in fact a rather pleasant guy to fly with. The same has been generally true of the many other ex-ATA, Midwest, Aloha, Champion, and United pilots I've flown with, all of whom have paid their dues and worked their way up the ladder only to be thrown back to Square One.

Larry's situation is not uncommon in the airlines today. There have recently been a lot of "old guys" who, having nearly reached the pinnacle of their careers, have seen the rug yanked out from under them. This isn't exactly a new phenomenon: twenty years ago, there were plenty of senior Braniff, Eastern, and PanAm pilots who went from hero to zero almost overnight. That said, those three failures were the result of circumstances particular to those airlines, and there were other airlines that prospered around the same time or shortly afterward. In short, while these pilots certainly lost a lot, they at least had viable options for making a living for the remainder of their careers.

What is different today is that the remaining major airlines who might otherwise form a safety net for these newly unemployed "old guys" have farmed out a huge portion of their flying to the lowest bidder. The only airlines really prospering and hiring in the last few years are those regional carriers who specialize in snapping up small-gauge flying from the major airlines whose pilots have been coaxed or forced into relaxing the amount of outsourcing permitted. The common thread connecting these regionals is that they offer starting pilots wages that break historical lows going back to the very dawn of the airlines. Experience matters for naught; if you're a new-hire, with 250 flight hours or 25,000, you start at poverty-level wages.

In jobs like computer programming or mechanical engineering, for example, experience pays. These jobs are not unionized, and productivity is closely linked to proficiency. At the airlines the relationship is not so clear. A very experienced pilot might hold up a flight in a situation where a newer, more company-oriented pilot might gladly launch into the wild blue yonder. Over the short term, the less experienced pilot's approach will probably save the company money, but in the long term the more experienced pilot's caution may well result in more safety - and more profits. In America today, sadly, the primary corporate focus seems to be on next quarters' profits, and a completely free market would likely reward less cautious pilots. This is the way that it was in the early days of the airlines; this is what gave rise to the pilot's unions of today. Unfortunately, in striving to establish a system whereby rewards come through longevity rather than malleability to management's wishes, the unions have created a system wherein overall experience is utterly ignored.

There has been no shortage of theoretical proposals to rectify this situation. One long-standing idea has been the establishment of a national seniority list, whereby a national union - presumably ALPA - would essentially become a crew-leasing company. A pilot could easily move between companies, keeping their longevity intact, choosing the employer whose contract paid the most for their overall experience. Ten years ago this idea was being pushed by those at the regionals, who (with equal parts foresight and self-interest) reckoned that this would neuter the whipsaw mechanism then being laid in place by major airline management teams. It was most opposed by the highest-paid major airline pilots, such as those at United, who figured this was a scheme by lesser-fortunate pilots to weasel their way into hard-earned contracts like their own. Ironically, the national seniority list idea was most recently floated at ALPA-National last year by a group of United Airlines pilots who have realized that their management has no intention of running a long-term profitable airline.

A major problem with a national seniority list is how you would implement it from the beginning. The USAir-America West merger is a hopeless mess because of the wildly disparate demographic makeup of the two pilot groups involved; an all-encompasing national integration would be the same situation writ large. How do you reward experienced pilots at failing airlines without upsetting much younger pilots at newer, aggressive, and profitable airlines? How do you account for a regional lifer Captain's greater experience without setting back a former regional Captain who took the calculated risk of jumping to a major airline? Very much like the move to Age-65 retirement, this is the sort of proposal that everyone can get behind so long as it doesn't set them back personally! Ultimately, any remotely fair integration would result in most pilots feeling like they got screwed, and would likely result in the mass decertification of whichever union had the audacity to propose such a scheme in the first place. This is a debilitating roadblock even before you consider how you'd get the various airline management teams to agree to such an arrangement in the first place. The right to hire whomever they please is a management right that has gone unchallenged thus far and one that they reserve rather jealously; without a costly and fundamental change in who controls hiring, management would simply hire the most junior and thus cheapest pilots, and the result would be even worse than the current situation.

Another proposal that I have heard is to decouple F/O and Captain seniority lists and stop automatic upgrades. Under this proposal, both regional and major airlines would hire both First Officers and Captains off the street; perhaps even narrowbody and widebody seniority lists at the majors would be separated. The advantage is that those most experienced in each category would naturally advance to the next-highest paying category, regardless of which airline they'd been employed at last. Guys like Larry who have a lot of experience but have suffered a major career interruption could pick up almost where they left off as soon as other airlines began hiring Captains. It would stop the phenomenon of pilots flocking to airlines with inferior contracts in hopes of a quick upgrade. This is actually not a new idea: it's virtually identical to the way that many foreign airlines hire expatriates. These airlines generally offer excellent contracts despite being mostly non-unionized; without the lure of fast advancement to larger aircraft or a quick upgrade, they must compete for qualified pilots on pay and benefits alone.

This system has important benefits to airline management that might make them more likely to sign off on such a radical change. Stagnant seniority lists are the bane of many companies: they artificially inflate labor costs through increased average longevity. A system in which pilots on a stagnant list could make the jump to another company without suffering a major pay setback would tend to even things out. Under this system, management not only keeps control over hiring but gains control over upgrades. This is actually one reason such a system might give many pilots pause: it undoes some of the protections of our present seniority system and gives management the means to reward cronies with quicker advancement by hiring them for Captain or Widebody positions ahead of those with known pro-labor attitudes.

I've had my own thoughts about what an ideal system would look like. The following proposal has been developed over the last few years and I've talked about it at length with other pilots (both in person and on various web boards). I think longevity ought to be done away with altogether, and that there should be a set formula for pay across the industry according to position and aircraft size. My suggestion is an annual base salary of $40,000 for Captains and $30,000 for FOs, with a capacity override of $1/hr/seat for Captains and $.75/hr/seat for FOs. This payrate would increase annually at the same rate as inflation as calculated by the government's Consumer Price Index. A pilot's earning power would increase throughout his career as he progressed to larger aircraft, but if one ever found himself in Larry's situation, at least he'd still have a livable wage. Just so you don't have to do the math, here's a table of annual earnings for various aircraft types based on 80 hours per month:

Aircraft CA FO
Saab 340 (30 seats) $68800 $51600
CRJ-200 (50 seats) $88000 $66000
JungleBus (76 seats) $112960 $84720
A320 (148 seats) $182080 $136560
B757-300 (224 seats) $255040 $161280
B747-400 (404 seats) $427840 $320880

While these rates are a big jump from todays depressed salaries, they are not out of line with historical airline payrates adjusted for inflation, and would not actually add that much to the price of a ticket. As an example, this payscale would add $2.60 in cost per passenger on a RedCo 757 from SFO to MSP (assuming 80% load factor, 8 year FO, 12+ year CA). This is additional cost that can easily be passed onto the passenger without hurting demand. The important thing in making the extra cost palatable is that it would apply industry-wide; every airline would be on an equal footing where crew costs are concerned. Management would also gain the advantage of fixed labor costs that are 100% known for years to come, and never having to negotiate new labor contracts.

The only way this system would work is if it were 100% universal across the industry (at least in the U.S.) and that's where the biggest roadblocks are. First, it would need to be adopted industry-wide basically simultaneously, which is simply not possible within the confines of the Railway Labor Act (RLA); it would need to be repealed for this plan to have a chance. Secondly, there would always be new startups that attempt to undercut existing airlines by offering pilots less than the standard rate, and there will always be pilots who jump at the "opportunity." The only way to discourage such behavior would be for the unions to gain power over the hiring process and ban the hiring of those pilots who have worked for less than standard wages. Thirdly, this would require a huge amount of cooperation - and indeed, devolvement of political power - not just from the various MECs within ALPA, but also between ALPA itself and the various independent unions, including a few with historically antagonistic relations with ALPA (APA, USAPA). In short, changing the industry over to a Guild system would require a lot of leadership and political will that simply is not there. I've come to the conclusion that my proposal, like the national seniority list, is a utopian idea that has zero chance of success in the real world.

That's not to say that more modest changes will not be made. In 2006, ALPA formed a Fee-For-Departure Task Force composed of representatives from various regional airlines, particularly those affiliated with WidgetCo. They've been exploring ways of more closely cooperating and preventing management from whipsawing them against each other, including a minimum standard contract and better portability of seniority and longevity in transferring between airlines. The reality is that ALPA should have been thinking about this a decade ago, but late progress is better than none at all. It'll be interesting to see if anything concrete comes out of the task force, and whether some of the ideas spread beyond the regionals. I hope so. I enjoyed flying with Larry a lot, but couldn't help but see in him myself in 30 years.

Northern Light

Has it really been a full month since I posted anything to this blog? Whoops. Dawn and I just got back from a two week trip to Norway (with short stops in Germany & the Netherlands) and the two weeks prior to that were chock full of flying, to say nothing of preparations for the trip. I'll be writing something aviation-related in the coming week, but in the meantime I'll share some of my favorite photos from the fjords and mountains of Norway.

Thirty Years of Outsourcing Safety

"Captain Renslow and First Officer Shaw did know what to do, had repeatedly demonstrated they knew what to do, but did not do it."

So stated a press release that Colgan Airlines released on the first day of the NTSB hearings into Colgan 3407. In an effort to limit the damage to their reputation, Colgan was quite willing to throw their deceased crewmembers under the bus. In the hearings, Colgan management was evasive and defensive, attempting to ward off every suggestion that culpability for this accident might not begin and end with the two individuals not there to defend themselves. In doing so, Colgan management came off looking like rank amateurs.

Nobody can deny the kernel of truth within Colgan's statement. This crew did undoubtedly make a number of serious mistakes, some commonplace and others nearly inexplicable, which compounded on each other and resulted in tragedy. Yet these mistakes did not take place in a vacuum; there were a number of circumstances that may have contributed. In my previous posts I have explored how latent training errors and self-induced distraction may have been factors. Any serious look at this accident must also examine the regional airline industry itself for widespread patterns and trends that helped create the right environment for an accident like this.

At the time of the accident, the Captain had approximately 3300 hours of flight time and the FO had 2300 hours. By most airlines' standards this was an inexperienced crew, but they actually weren't horribly inexperienced compared to some of the crewmembers at the regional airlines. At airlines like Colgan, Pinnacle, and Mesa, in the not-so-distant past one could find 2000-2500 hour new Captains paired with 250 hour newhire First Officers. Worse yet, the Captain might be new to not only the left seat, but the airline and their routes as well; all three of the above companies hired direct-entry Captains. This was because they did not have enough First Officers qualified to upgrade due to a combination of growth, attrition, and their newhires' low flight time. Captain Renslow had 625 hours total time when he was hired at Colgan. First Officer Shaw, with sixteen hundred hours of fair weather flying in mostly single-engine piston aircraft, was actually a "high-timer" for the period in which she was hired.

Colgan testified at the NTSB hearing that a particularly favorite source of pilots is an institution known as Gulfstream Academy; they hired Captain Renslow from there. This "academy" is actually a functioning Part 121 airline in Florida that flies as Continental Connection. Brand-new commercial pilots pay $30,000 to buy a "job" as a First Officer on a Beech 1900 turboprop. Few of Gulfstream's paying passengers have any idea of their crew's extreme inexperience. After 250 hours on the line, these pilots are hired via bridge programs at airlines like Pinnacle and Colgan. They are a management dream: too inexperienced to be hired anywhere else, possessing some airline time to make training go smoother, and willing to work for any wage that's an improvement on paying bucketloads of money for their job.

What these pilots do not have is the experience of taking over the controls from a student who has put the airplane in danger, or having scared themselves straight on a low approach in a decrepit old freighter - or for that matter, having practiced hundreds of successful stall recoveries. Gulfstream portrays this as boring, useless timebuilding to potential enrollees looking for a shortcut, and a certain class of airline management enthusiastically agrees. After all, the modern regional airliner is relatively idiot-proof. If management could hire monkeys to fly them, they would - provided the price of bananas did not go too high.

The noteworthy thing here is that not all airlines stooped to hiring low-time pilots from the likes of Gulfstream. There were plenty of experienced pilots to be had but for a modest price. Despite paycuts and gutted contracts and seniority list stagnation, the major airlines were flooded with resumes from supremely qualified candidates when they began hiring again. It was the regional airlines, with their inferior pay, benefits, schedules, and work rules, who had to settle for pilots with little aviation experience, and a particular class of regional that struggled to fill their classes despite no hiring standards at all.

Here's a real-life example of how Colgan's low pay deprives them of experienced pilots. In the summer of 2007, I briefly considered applying to Colgan. With 4500 total hours and 2200 hours in the Q400, I would have been much more qualified than the average newhire. I chose not to apply because of Colgan's insultingly low pay rates and lack of work rules or union protection, and because the airline's cheapness in compensation bespoke a cheapness in other areas to me.

Training is a perfect example. Like many regional airlines, Colgan has sought to decrease training costs through outsourcing (to FlightSafety), shrinking their training footprint, and allotting a minimum number of hours for Initial Operating Experience (IOE). Colgan's pilots, and those of many regional airlines, are taught by sim instructors who often have never touched the actual airplane, and usually teach for several airlines with differing procedures. Ground instructors may have never flown any airliners! Is it any surprise that Coglan pilots were a little hazy on the significance and proper usage of the Ref Speeds switch? After sim training, Colgan pilots were given 30 hours to complete IOE; any more required approval and invited unwanted scrutiny. That's not very much for inexperienced pilots learning a rather quirky airplane. At Horizon you could go to 50 hours without them batting an eye, and ANA actually requires 70+ hours for their pilots. Sure, you can hammer out the basics in 30 hours, but that doesn't leave much time for a check airman to impart the nuances of the airplane - like, for example, "Be particularly mindful of your airspeed when you put the gear down and the props to 1020, there's a ton of drag and you can get too slow very quickly if you don't pay attention."

Hiring woefully inexperienced pilots and rushing them through training is bad enough; subsequently operating under policies that encourage them to fly sick and/or tired is simply asking for trouble. Unfortunately, many regional airlines including Colgan do just that. It's another side effect of a mentality that stresses cost savings above all else and pretends there are no negative consequences for safety in doing so.

Most regional airlines operate with fewer pilots per airplane than the majors. This is partially a result of differing stage lengths, regulations, and contract work rules, but many regional airlines also intentionally short-staff themselves as far as they can and still maintain schedule integrity. Low-paid regional pilots who are trying to build hours can generally be depended upon to pick up plenty of overtime, after all. The problem is that running so close to the edge means that a few months of high attrition or recruiting difficulties can make the airline severely short-staffed in perpetuity. Pilots suffer the most under these conditions: their schedules get built to the maximum limit, they have fewer days off to recuperate between trips, and even those days are subject to "junior-manning" as desperate crew schedulers force pilots to work on their days off. A few bad months can leave one feeling chronically fatigued. A long or difficult commute only makes things worse.

Many people have correctly noted that it is a pilot's own choice to commute. This is a decision most pilots will make a few times throughout their career, and it's never easy. I chose to leave a city and area I love dearly in order to avoid a notoriously bad commute, but my choice may have been different if Dawn and I had family in Portland, or had kids in school, or if the cost of living in my base was higher. The Seattle-Newark commute has to be one of the worst out there; the FedEx Captain who gave FO Shaw her last ride to work told her as much. Her choice to move to Seattle was apparently sparked as much by financial considerations as personal ones. Ms. Shaw was barely able to make ends meet in Norfolk by holding down a second job as a barista, so New York was clearly out of the question. She and her husband had moved to Seattle to live with her parents, at least initially.

From the multiple yawns noted on the CVR transcripts, it's likely the crew of 3407 was tired. One can understand why: it was after 10pm, they'd both been up very early, and the FO likely had very little quality sleep the night before. Moreover, they'd spent the entire day in the crew room due to a cancelled roundtrip. In my own experience, this is more tiring than actually flying, especially if there's no dark and quiet place to sleep. Most airlines provide such a place near their crewrooms, but not Colgan: they actually left the lights on full-time to discourage pilots from sleeping!

The FAA is quite clear that crewmembers must be fit to fly, and must remove themselves from duty if any condition, including fatigue, would impact their performance. Virtually every airline has a fatigue policy in their contract or FOM. How they actually administer that policy, however, varies widely by airline. At most majors, calling in fatigued is a non-jeopardy event; some even let you use your sick time. At Colgan and many regionals, calling in fatigued results in loss of pay and potential disciplinary action. Fatigue calls are usually tracked and monitored for any "patterns" of fatigue, which is left up to management's discretion and may be a mere two events. Besides the threat of discipline including termination, unscrupulous managers have been known to force fatigued pilots to undergo sleep studies during unpaid time off, or even report them as chronically fatigued to the FAA's aeromedical division. Such scare tactics are meant to cut down on "absenteeism" which threatens schedule integrity at chronically understaffed airlines. The practical effect is that pilots will often just fly tired in all but the worst cases. Most of the time they make it to their destination without incident and the airline can justify their policies as being "safe."

A similar story plays out in the realm of sick call policy. Again, the airlines' policies, ostensibly in place to prevent schedule disruption due to sick time abuse, having a chilling effect on the proper use of sick time as well. To begin with, sick time accrual at many regionals is agonizingly slow. In Colgan's case, it takes a newhire nine months to accrue enough sick time to cover a four-day trip. A newhire already at poverty-level wages can ill afford an unpaid week. Secondly, sick calls are often handled in the same paranoid manner as fatigue calls. Calling in sick at many regionals prompts personal questions from crew schedulers and follow-up calls from chief pilots. If you're unfortunate enough to fall ill on a holiday, around your vacation, or even on a weekend, they'll often demand a doctor's note - procured at your own expense under often-inferior health plans. Mind you, there are many things that a pilot should call in sick for that don't require a visit to the doctor and can usually be handled with rest and OTC medications; FO Shaw's head cold comes to mind. If their policies result in such a marginal pilot deciding to fly, management doesn't seem to mind. At least the schedule gets covered, and it's pretty rare that a sick FO fails to notice her Captain doing something disastrously boneheaded.

It's easy to vilify regional airline management for this behavior, but the reality is that it is generally borne of financial necessity rather than a perverse hatred of pilots or the pursuit of personal enrichment. Regional airlines live and die by their cost structures because the major airlines they contract with have made it this way. Virtually all regional airline management is cheap; the main difference between them is the degree of their aggressiveness in cutting costs and how vile they're willing to be to their employees. The most foul - i.e., the most cheap - have reaped the most growth in recent years as they lap up contracts with major airlines. In the case of Colgan, this came in the form of 15 Q400's to be flown as Continental Connection.

Now, the major airlines do have certain performance metrics that must be met along with the baseline requirement of low cost - witness Mesa's fall from grace - but otherwise the majors generally leave their regional airline partners to their own devices. They don't concern themselves with hiring practices or minimum experience levels, training programs, or sick and fatigue call policy. They generally are not involved in whatever safety programs the regional airline participates in. In short, by their silence they endorse regional managements' view that penny-pinching in every aspect of the operation doesn't impact safety so long as everything is legal. Of course, when a regional partner suffers a crash, the majors are very quick to point out the actual identity of the carrier involved. It's a convenient about-face after selling the victims a ticket with their name on it and festooning the outsourced airplane with their livery. Those passengers likely expected a mainline standard of safety, but only after an accident does mainline fall all over themselves to explain just how little they had to do with the operation of that flight.

The circle of blame for this unholy situation only expands outward from there. You can include the Congress of 1978 for deregulation, subsequent Congresses for lack of oversight, the FAA for turning a blind eye to the regionals' most abusive practices, pilots for being willing to take such low-paying jobs in hopes of an eventual payoff, and so on. Ultimately, though, what we're seeing is the free market at work. The situation exists because it benefits all of us as a collective group of consumers. Passengers are paying less, in real dollars, than they've ever paid to fly, and they still think they're getting stiffed. Improving safety would require increasing fares, and passengers are utterly unwilling to pay more (if you doubt me, read some of the comments here). While the flying public always make concerned noises about aviation safety, most people know enough basic math to reason that even if the regionals are more dangerous than the majors, the accident rate is still so low that there's a miniscule chance of ever being personally affected. Why spend more money for something that won't affect you? The logic isn't flawed, but it does need to be followed to its ultimate conclusion for real moral clarity on the situation: I am willing to let others die so I can save a few bucks.

As collaborators get the innermost circle of hell to themselves, I've waited to the end of this post to write about one particular group's culpability in creating the environment that fostered this accident: our very own Air Line Pilot's Association. This may come as a surprise to some of you, as I've defended airline unions on this blog before and have noted that I am active within the union. I still maintain that unions are necessary in this industry to guard against management's worst tendancies, but I fully recognize that ALPA has been utterly clueless on the matter of outsourcing and in fact fully cooperated with management in creating the two-tier system we see today when it benefitted them. Having bought into management's stance that regional jet feed was necessary for mainline growth but could not be operated cost-effectively with the payrates that mainline pilots expected, ALPA's mainline MECs declined to fly the first wave of RJs but gladly shared in the revenue they produced. They didn't concern themselves with the question of who would fly those RJs or under what conditions. When regional pilots unionized - often under ALPA - and attempted to better their lot, they got little help from their mainline counterparts. ALPA granted management scope relief after scope relief, but there was never any insistance on requiring that ALPA pilots fly the RJs, or setting a minimum standard contract, or at least insisting on some oversight of the outsourced operation's safety programs. All these things were determined to be the regional pilots' problems, despite the fact that any attempt to solve them, like the Comair strike in 2001, only made mainline shift flying to other, cheaper carriers.

Even after everything that's happened since then, this mindset is still quite prevalent at ALPA. A few months ago I was involved with a group of WidgetCo pilots in a grassroots effort to force their union to at least study the feasability of recapturing 76-seat flying. Just before a meeting of the union's Atlanta council, we were called into a meeting with the MEC chairman. He rejected the idea of recapturing outsourced flying outright, saying it would be too expensive and there would be no benefit for the majority of the membership. He said not to worry about scope, that ALPA was done giving up scope (this was a few days after he had granted scope relief to increase the allowed number of 76 seat airframes!); he then stated that outsourced flying was good for mainline pilots because the low cost flying brought in revenue they shared in. This is coming from the popular union head of the world's largest airline, and a likely future candidate for ALPA's presidency. I left that meeting utterly shaken that ALPA would or could be part of the solution to the mess we're in, at least in its current form.

If anything is going to change, it will likely come through the legislative response that has already begun in response to the Colgan hearings. Randy Babbitt, the FAA's new administrator, is much more favorable to changing duty and rest regulations than previous administrators have been; meanwhile the Senate's Aviation Subcommittee is going to be holding hearings into working conditions and safety at the regional airlines in early June. It'll be interesting to see whether any substantial legislation actually emerges from the process. In the meantime, those of us at the regionals can do our own little bit to keep our airlines safe, whether that means enforcing cockpit discipline, making an active effort to refresh our knowledge of systems and procedures, or standing up to management intimidation when we shouldn't be flying.

Thirty Minutes of Distraction

At 22:16:27.4 EST on February 12th, 2009, the crew of Colgan 3407 experienced a stick shaker activation. They were hardly the first crew to do so; although one wouldn't describe a stick shaker as a common event, it's not unheard of either. A stick shaker is a warning, a clear and unmistakable message to watch thy airspeed lest the ground come up and smite thee. Most crews in this situation heed the warning and take appropriate action, and the only subsequent danger is to their careers. For reasons that will remain unknown to us but possibly include some of those delineated in my previous post, this crew did not take the correct action, and paid the ultimate price.

The fact that the fate of this crew and their passengers was determined by their response to the stick shaker, and the fact that stick shaker activations usually have happier endings, does not mean we should not examine the circumstances that led to the stick shaker activating in the first place. There are more lessons for the average pilot here than there are in the ultimate cause of the accident. Most of us find it very hard indeed to imagine pulling back on the yoke in response to a stall warning, but a great many of us have found ourselves distracted at a critical moment of flight.

If the CVR transcript did not have timestamps, an experienced pilot's first impression upon reading it would be how utterly normal the conversation contained within it was. They talk about the aircraft logbook, reminisce about past flights and old airplanes, discuss upgrades and future career plans, talk about favorite air traffic controllers, and discuss their respective experiences in icing conditions. Even the First Officer's now-famous statement about her lack of previous experience in IMC and icing, taken in its entirety and without interruptions, isn't nearly so scandalous as it's been made out to be:

"Yeah, that's another thing. All the guys— @ came in when we interviewed and he said 'Oh yeah, you'll all be upgraded in six months into the Saab' and blah ba blah ba blah, and I'm thinking, 'You know what? Flying in the northeast, I have sixteen hundred hours. All of that in Phoenix.' How much [actual] time do you think I had, or any in ice? I had more actual time on my first day of IOE than I did in the sixteen hundred hours I had when I came here...I'm not even kidding. The first day! All these guys are complaining, they're saying 'you know how we were supposed to upgrade by now' and they're complaining; I'm thinking, 'You know what? I really wouldn't mind going through a a winter in the northeast before I have to upgrade to captain. I've never seen icing conditions. I've never deiced. I've never seen any— I've never experienced any of that. I don't want to have to experience that and make those kinds of calls.' You know, I'd have freaked out. I'd have like seen this much ice and thought 'Oh my gosh we were going to crash.'...but I'm glad to have seen, oh— you know, now I'm so much more comfortable with it all."

This is the stuff that cruise conversations are made of. This portion of the conversation, however, did not take place at cruise. They were at 4000 feet, and later descending to 2300 feet, on vectors for the approach. Indeed, the last lines of the conversation - from the Captain - were spoken only two and a half minutes prior to stick shaker activation. As even many private pilots know, this is a major violation of FAR 121.542, which states:

(a) No certificate holder shall require, nor may any flight crewmember perform, any duties during a critical phase of flight except those duties required for the safe operation of the aircraft. Duties such as company required calls made for such nonsafety related purposes as ordering galley supplies and confirming passenger connections, announcements made to passengers promoting the air carrier or pointing out sights of interest, and filling out company payroll and related records are not required for the safe operation of the aircraft.

(b) No flight crewmember may engage in, nor may any pilot in command permit, any activity during a critical phase of flight which could distract any flight crewmember from the performance of his or her duties or which could interfere in any way with the proper conduct of those duties. Activities such as eating meals, engaging in nonessential conversations within the cockpit and nonessential communications between the cabin and cockpit crews, and reading publications not related to the proper conduct of the flight are not required for the safe operation of the aircraft.

(c) For the purposes of this section, critical phases of flight includes all ground operations involving taxi, takeoff and landing, and all other flight operations conducted below 10,000 feet, except cruise flight.

One of my commenters in the previous posts noted that nearly all of the conversation below 10,000 feet was at least nominally about icing - which the aircraft was accumulating - and interpreted the FO's statement as being a very passive, beat-around-the-bush way of suggesting to the Captain that she wasn't comfortable with the icing and that he should do something about it or at least reassure her. Perhaps. I personally think that the conversation as a whole was decidedly "nonessential," to use the regulation's wording, but this will no doubt be argued back and forth to exhaustion by the various parties' lawyers.

In his testimony at last week's NTSB hearings, Captain Rory Kay of ALPA's Executive Air Safety Committee pointed out that there is the letter of the regulation, and then there's the intent of the regulation. The intent was clearly to minimize distractions at times when the crew needed to focus on their duties, and there are duties to be completed above 10,000 feet. Some airlines actually call for sterile cockpit below 18,000 feet; Captain Kay noted that he personally also enforces it during any climb or descent. To my mind, the most troubling thing about the Colgan crew's chatter was not that some of it took place below 10,000 feet, but that it was fairly incessant throughout the short flight and it does seem to have impinged upon other things that needed to get done. The descent and approach checklists were both skipped until quite late in the flight, three minutes before the upset as the crew descended to 2300 feet on a base leg for the approach. Both were hammered out in the space of twenty seconds, and one critically important item got glossed over: speed bugs. Even as the crew interrupted a discussion on the perils of icing to do their approach checklist, there was no discussion of what effect that icing would have on their approach speeds. They bugged a speed that was twenty knots too slow.

Distraction likely wasn't the only culprit here. I don't doubt that fatigue - and a possible head cold on the FO's part - made the crew less sharp than they might've been. Reading through the NTSB's post-accident interviews, it is also clear that there was a lack of guidance and training at Colgan concerning the use of deice equipment and appropriate icing speeds. Most of the crewmembers interviewed were vaguely aware that the Ref Speeds switch changed the parameters at which the stall protection system activated, but could not give specifics, and there was no consensus on when exactly it could or should be turned off for landing. Likewise, when asked about when one would use a Vref-ice speed, the answers were varied, few matched Colgan's guidance, and none tied it to the use of the Ref Speeds switch, which in fact decreases stick shaker activation from 12 degrees angle of attack to 8 degrees. All of this was hammered home repeatedly in initial and recurrent training at Horizon; I suspect they had a few stick shaker activations of their own in the Q400's first year or two. It was a deficiency that was clearly not picked up on or acted upon by Colgan management. In fact, less than a month after Colgan 3407, another Colgan crew experienced a stick shaker on approach to Burlington, Vermont. Again, the ref speeds switch was selected to INCR, and they were using non-icing speeds (in this case, they really were well out of icing). This crew wasn't sick or fatigued, and there was no sterile cockpit violation; they actually had a check airman in the jumpseat conducting a line check.

Using non-icing speeds with the ref speeds switch at INCR will not, by itself, set off the stick shaker; it just considerably decreases the margin between Vref and the low speed cue. Unlike the Burlington incident, this was not a case of simply getting a few knots below Vref. In this case, the airplane was level at flight idle and a high-drag configuration from 170 knots down to 126 knots with no interference from the Captain. There are really two possibilities here: that the Captain really was intending to go straight to the Vref of 118 knots and simply called for Flaps 15 too late, or his attention was diverted elsewhere at the time and he didn't see the airspeed get low. I think the latter is more likely than the former: you seldom plan to fly the entire approach at Vref, and looking at the PFD would have made it painfully clear that Vref would put him under the low speed cue without a configuration change. If he wasn't looking at the PFD, though, nobody knows for sure why. You can't blame it directly on the chatter; all conversation had stopped by then. It's clear that he was distracted at a critical moment, though, and there had been a pattern of distraction through the last thirty minutes of the flight. While the violation of sterile cockpit didn't directly cause this accident, I personally think that it was merely one of many holes that lined up at the wrong time (think swiss cheese model).

The only reason I devote an entire post to it is because I do think it's a hole we allow to line up way too often. Most of us, in our most honest moments, will admit that sterile cockpit is not always followed as strictly as it should be. It's generally not willful disobedience, it's usually a matter of letting a few words slip out before remembering that you're below 10,000 feet. The other crewmember will usually reply with a grunt, a few words, or silence, but very rarely with an outright challenge. I've been as guilty of this as anybody. Nobody wants to be known as the "mean Captain" who jumps all over his First Officers for minor slipups. The problem is that not strongly enforcing the rule creates a culture of acceptance. Although the violation might not have been egregious, ignoring it means that when we get two "Chatty Cathy's" flying together, there isn't an cultural taboo that makes them clam up when they should.

From my time jumpseating and from talking about this to fellow pilots, I do think this problem is more acute at the regionals than it is at the majors. The accident record certainly paints that picture. Of the last three regional airline accidents, violation of sterile cockpit was a factor in two, and was also present in the third as one of many manifestations of wildly unprofessional behavior throughout the flight. You have to go back a ways to find a major airline accident in which it was a factor. Why the difference? Some can probably be attributed to differences in age and maturity level, some to the majors' longer stage lengths that provide more time for conversation in cruise. Ultimately, though, I think it's a difference of culture.

The last thirty years have seen a real transformation of the major airlines to where a culture of professionalism prevails. Deviation from standards and regulations is simply not tolerated. The hiring process has changed to emphasize CRM skills and professional attitudes over stick and rudder skills. Management, primarily those in flight operations and training, has helped set the tone by seeking out negative trends and addressing them early on. You do not see this sort of proactive safety culture at all of the regionals, or even at most of them. There is a reason that many major airline pilots will not let their families fly on regional airlines. I myself have prohibited my parents from non-revving on certain carriers.

Don't get me wrong, there are a great many excellent pilots who exhibit the utmost professionalism at the regional airlines. The airlines, however, do not go out of their way to attract and retain these pilots, or give them superior training, or provide them with the support they need to do their jobs well. Nor have they done a stellar job of weeding out weak pilots, or those with poor judgement, or those who simply need more experience. Most of all, they give safety a lot of lip service and always proclaim in to be their first priority, but in reality they seek the highest level of safety that is possible without raising costs.

But I'm getting ahead of myself. There were a lot of holes that lined up in this accident, and some of them were lined up by airline management and their enablers over the past years; they deserve their very own post, which will be my last concerning Colgan 3407. This cannot obscure the fact that there were several holes that were lined up by the crew's own action, and they are holes that all of us who consider ourselves professional pilots must be on our guards against.

Thirty Seconds of Confusion

Beep!

"Three thousand for two thousand."

It was a dark night; the landing lights lit up the thick layer of clouds slipping rapidly around us. The plane bobbed rhythmically in light turbulence as we descended at flight idle power. Paul, my First Officer, slid his seat forward and cleared his throat.

"I was talking with what's-his-face the other day, our ALPA communications guy."

I looked over at Paul. "Yeah? What about?"

"Advertising. It occurred to me that we could do a much better job of getting out our message to the general public."

"Definitely."

"So why don't we put out some ads that capture people's attention?" Paul continued. "I was reading a magazine the other day, and there was this really brilliant ad. It featured a lovely voluptuous young lady, and she didn't have any clothes on - this was taken from the back, mind you - but this ad was for -."

PPPPPRRRRRBBBBBBBBTTTTTTT! DING DING!

The cockpit erupted into a cacophony of alarm horns and lights as the autopilot disconnected and the yoke began vibrating furiously. I snapped back to the instruments to find the airspeed dangerously low and the torque still at idle. I grabbed the yoke and shoved the power levers forward. "Set power!" I commanded.

It was obvious what had happened, we had leveled off at 2000 feet during the conversation without me noticing and bringing the power back up. Now, with the engines at full power, the airspeed stopped decaying and started creeping back. The stick shaker stopped momentarily.

"Altitude!" Paul called out.

Crap, we had drifted below 1900 feet. I applied some back pressure to the yoke. PPPRRRBBBBTTTT - the stick shaker started up again and the wings began a light burbling back and forth. Ish, don't want that. I eased the back pressure and gingerly nursed the altitude back to 2000 feet. The airspeed finally crept up to a safe number and I started breathing easier.

Fortunately for my career, this incident took place in a SF340 simulator rather than the JungleBus, and my "First Officer" was actually the director of training for a well-known regional airline. This company does stall training completely differently from most airlines, and in the aftermath of Colgan 3407 and Turkish 1951, Paul invited me to fly their jet and turboprop simulators and experience it for myself. We did departure stalls just after departure, approach to landing stalls while approaching for landing, and high altitude stalls at high altitude. A great many stick shaker events in the real world involve distraction at a critical time while on autopilot, so we did the scenario described above. While all of this might seem quite logical to an outsider, it is actually a revolution in the airline world. Moreover, it is done in apparent contravention of the FAA's Practical Test Standards.

In the last few days, a great many pilots - including some of the commenters on my last post - have been asking what in the world could possess a presumably competent airline pilot to pull up in response to a stick shaker - or for that matter, to use 80 to 120 pounds of force to override the stick pusher that might've saved his life. It's the most puzzling aspect of this crash. Even if the crew was relatively inexperienced, it is drummed into pilots from day one that you don't pull up in response to a stall. What could cause an airline pilot to abandon this most elementary of precepts?

Even if the pilot did survive to answer for his actions, I'm not entirely sure that even he could've given a satisfactory answer to the question. Since he is not around, all we - or the NTSB - can do is speculate about some of the possible culprits and do our best to eliminate them as potential causes of future accidents. There are three primary possibilities that have been discussed: 1) the Captain was a poor pilot to begin with; 2) he simply got confused in the heat of the moment; 3) there was some latent defect in his training. These are not mutually exclusive theories, all three could have come into play simultaneously.

By now it has been widely reported that the Captain failed five checkrides in his career. The first was his instrument checkride, back in 1991, on the partial-panel VOR approach and the NDB approach. He disclosed this failure on his application at Colgan. The next two failures, on his Commercial-Single Engine and Commercial-Multi Engine rides, took place in 2002 and 2004 respectively, and were disapproved for a fairly wide range of tasks. He only disclosed the instrument ride failure on his application. At Colgan, he failed a recurrent Proficiency Check as a First Officer and his upgrade/ATP ride. He also had to repeat a small portion of his initial PC as a new FO in the SF340.

There are a great many capable pilots who have a checkride bust or two in their past, but a long string of them raises warning flags. The interesting thing is that when you read through the NTSB Human Performance Group's interviews, everyone describes Captain Renslow as a good, consciencious pilot. Many FOs he flew with described him as above-average. Perhaps it's simply a case of not wishing to speak ill of the dead, but if he really struggled on the line you'd think the NTSB could've found someone who would have told them about it. It's hard to reconcile the popular Captain with all the checkride busts. It's possible that he simply wasn't a good test taker. That's not insignificant for our purposes: falling apart on tests can be a symptom of not coping well with pressure, period.

There was plenty of pressure to be had in the last thirty seconds of Colgan 3407. That the stick shaker was a complete surprise is self-evident. We don't know where the Captain's attention was in the moments before stick shaker activation; perhaps looking at the wingtips to see how the deice boots were coping, perhaps around the cockpit to see if anything had been missed during the rushed descent and approach checks. Maybe the long day had got to him and he was simply zoning out. It doesn't really matter; it's very unlikely he had any clue that the stick shaker was coming before it went off. It is difficult to explain to those who have never flown airplanes with stick shakers just how jarring their activation is - even in the sim, much less the real world. The whole idea behind them was to have one signal in the cockpit that is so overpowering and unmistakable that the crew cannot possibly ignore or misinterpret it. Both yokes shake so heavily that you can feel it even if your hands are nowhere near the yoke. Loud clattering noise fills the previously quiet cockpit. The autopilot disconnects with the accompanying lights and aural warnings. In the Q400's case, this is a loud horn that repeats over and over until you acknowledge it by pressing the autopilot disconnect button on the yoke. The Colgan crew never did so - they had their hands full enough already - and that sound must have surely contributed to the chaos and confusion that filled that cockpit in the last 30 seconds.

The sudden cacophony had a clear meaning: do something, now. The Captain indeed reacted very quickly, within half a second. More than a few pilots have suggested that he had tail stalls on the mind. It's possible. He'd just transitioned from an airplane that was known to be susceptible to tail stalls (early models, anyway) and had recently viewed the NASA video on tailplane stalls in recurrent training. The crew had been talking about the icing only a few minutes before. With a tailplane stall, of course, one would not expect to see the stick shaker activate, as that indicates a high aircraft angle of attack and, by extension, a low tailplane AoA. I'm not sure that the distinction would be evident to anyone within the space of a half-second, but by the same token I'm a little skeptical that anyone would think of a tailplane stall within a half second in the first place (much less remember that the corrective action for a tailplane stall is to pull up). It's possible that five or six seconds later the Captain mistook the stick pusher for a tailplane stall (they would feel similar in an aircraft with unpowered flight controls, although not in a Q400) and that's why he fought it. It's very easy to play these parlor games after the fact, having reviewed the NASA video and FAA circulars and discussed among ourselves. At the time, caught by surprise and with little idea of what's going on and events moving far faster than he could really think about them, I rather doubt that the Captain consciously thought about what he was doing, in the same way that the First Officer obviously wasn't thinking about what she was doing when she retracted the flaps in the middle of a stall. Amid the confusion, pure instinct took over.

Why that instinct might involve pulling when new pilots are taught over and over again to push may have its roots in the way that most airlines teach stalls. To begin with, they are not even stall recovery procedures; they are stick shaker recovery procedures. The ATP PTS directs you to recover at the first indication of a stall, which includes the stick shaker. Many pilots will never experience a stick pusher or a real stall in the simulator unless they request it; it was never part of the syllabus at Horizon or NewCo. The maneuver is typically taught and checked well above the ground. The setup is far from realistic: the applicant usually hand-flies and stops trimming well before the stall. The reason to do so is that it makes the recovery easier: the plane won't pitch up when you apply power. The purpose of stall training is really to prepare the student to pass the maneuver on the checkride rather than to prepare them for the possibility of being surprised by a stick shaker on the line.

And this brings us to the most outrageous thing about stall training at many airlines. Applicants are taught to hold their altitude throughout the maneuver. Again, this is due to the Practical Test Standards, which state that an applicant must:

Recover to a reference airspeed, altitude and heading with minimal loss of altitude, airspeed, and heading deviation.

The FAA never defines "minimal loss" of altitude. A great many instructors and check airmen have substituted their own standard, often 100 feet as several Colgan instructors testified. People can be and have been failed for trading altitude for airspeed during a stick shaker recovery. Instead, you are taught to immediately go to full power, and use whatever yoke force is needed to keep the airplane level while it accelerates. This often involves "riding the shaker" for some time. Let me say that again: we are being taught to stay in the shaker for longer than is necessary. Because we stop trimming at such a high airspeed, this can involve significant back force on the yoke until the airspeed increases again. Therefore, you are developing the exact motor memory that, if applied to a real-world situation like Colgan 3407's, will induce exactly the wrong control movements.

It's entirely possible that the Captain was reacting to the stick shaker exactly as he did in the simulator and simply overreacted a bit with the adrenaline rush. It didn't take that much back pressure to start the abrupt pitch-up after the shaker, only about 25-30 pounds according to the Flight Data Recorder. The fact that the autopilot was engaged right up to the stick shaker meant that the plane was trimmed for the speed at which the autopilot disengaged, which certainly didn't help matters when the Captain shoved the power levers forward during the pitch-up. I don't doubt that he was as surprised as anyone that his reaction to the stick shaker induced a 30 degree pitch up and subsequent stall. It was still a recoverable situation at that point; it was fighting the stick pusher the whole way down and retracting the flaps mid-stall that ultimately doomed the crew. These actions may reasonably be attributed to panic at a situation that had quickly spiraled out of control.

So why did stalls come to be taught this way? I think I see the FAA's original reasoning. A lot of training and checking used to be accomplished in real transport category aircraft, many of which reacted very poorly to full stalls. In the interest of safety, the FAA decreed that recovery be initiated at the very first sign of a stall. Simply increasing one's airspeed from a low number to a high number doesn't seem like a very difficult task, and nobody wants crews to be diving transport category jets at the ground in a low-altitude situation, so the FAA added the language about minimum loss of altitude. Transfer this to the simulator, where the element of danger is removed, and many check airmen began treating it not as a survival maneuver but a proficiency maneuver not much different than steep turns.

Many major airlines at least include simulator training to the stick pusher for their pilots, but as far as I know only Paul's regional airline has completely revamped the way they do stall training. They teach their pilots that reducing angle of attack promptly is the most important thing in recovering from a stick shaker, and that this involves both increasing power and lowering pitch to trade some altitude for airspeed. I tried both their method and the traditional method in the sim, and using the new method resulted in far less time spent in the shaker in exchange for altitude loss generally no greater than 200-300 feet (the scenario I described at the beginning of this post was using the traditional recovery method). Just as importantly, this airline trains and checks stick shaker recoveries using the most common scenarios in which real crews have encountered stick shakers: accidental reversion to pitch mode after takeoff, mountain wave at high altitude, leveling off on a non-precision approach, and turning base leg to final approach. Most scenarios involve the autopilot being on and trimming all the way to the low airspeed. They often give students low speed scenarios when they're not expecting them, and make ready use of distraction. In my own case, I knew exactly what Paul was doing when he struck up the conversation about the ad with a naked woman in it, yet I still found myself surprised when the shaker went off. The end result is that if one of their pilots ever finds themselves surprised by a stick shaker at low altitude, it won't be the first time they've had that experience, and they'll have accurate motor memory to call upon for the recovery.

So why haven't more airlines changed the way they train stall recovery? Surprisingly, the FAA isn't standing in the way: they wholeheartedly approved of the changes that Paul introduced to his airline's training program. A lot of it is simply institutional inertia. Until now, few have thought there was a problem that needed addressing. This a symptom of a reactive rather than proactive safety culture at many regional airlines. Another element is cost: many regionals' training programs are all about turning out pilots as quickly and cheaply as possible while maintaining a basic level of competence and safety. When you compare regional airline training syllabi to those at major airlines, you typically see fewer simulator sessions despite having similarly sophisticated aircraft and less experienced pilots. That means that certain things get glossed over, and no "superfluous" training is included. This accident will of course change the way we teach stalls - I fully expect to be using Paul's method next year (and I hope they call it "Paul's method" in recognition of his foresight) - but I do worry that it will take future accidents to expose other weaknesses unless there is a fundamental change in the safety culture at the regional airlines. I'll write more about that in my next post.