MULTI-CREW

PILOTS LICENCE (MPL) IMPLEMENTATION

John Bent

We can "make or break" the longevity of a student pilots aviation interest by the customer service and professional mentoring we provide in the early phases of flight as an instructor. It is all a part of professionalism and I believe it is all-important to the future of aviation. th [15 March 2011: comment on the International Aviation Flight Training Professional blog (IAFTP.org) from an experienced instructor]

MPL is growing

It was notable at the Asia Pacific Airline Training Symposium (APATS) in March 2011 in Hong Kong that the new ICAO Multi-Crew Pilots Licence for airline entry was now gathering momentum. There were almost no presentations at the Symposium which did not make mention of MPL and related airline pilot selection and training needs If current feedback from MPL graduates now operating becomes further corroborated by larger data-sets (from ICAO, EASA, IATA), MPL will become widely recognized as training for airline entry which is more relevant, than traditional methods. Now, four years after publication by ICAO, the MPL adoption is slowly ramping up, and it is expected that MPL, or refined versions of the concept, will eventually become the only direct cadet entry route to an airliner flight deck

But adoption is slow in relation to safety needs

The airline accident rate has been reduced to remarkably low levels (compared to other parts of the transport industry) via progressive advances in technology, safety management systems, and safety audits (IOSA). IATA noted a leveling off in airline accident rate reduction over past 8 years despite short-term improvements in accident rate. This is the first time there has been little progressive reduction since birth of the airline industry. If no further rate reduction is achieved, airline accidents will escalate in number as expansion continues, and an increase in the numbers of accidents and fatalities will be noticeable to the media and travelling public. Apart from the additional tragic loss of life a disproportionate impact on growth itself could occur due to air travel reluctance. The accident rate has clearly reached a point of resistance using historical methods of safety enhancement. The lowest hanging fruit has already been taken. Numerous technology, SMS (Safety Management System), and ATC infrastructure improvements have been made in recent decades, leaving training relatively untouched. Training has been subject only to slow and ponderous improvement, and is now one of the most potentially productive new targets in the quest for safety. As if to prove the point, accidents statistics still demonstrate continuous human factor triggers reflective of selection and training (Annex A) Yet to simply add training volume is not the answer as its not affordable for the industry. So the new target for safety improvement has to be training quality and relevance (eg. MPL). Only limited action on this must eventually lead to significant additional downstream cost New generations changes in the characteristics of pilot recruits There is evidence to show that attitudes, motivation, interest, and passion of potential young entrants to the industry are all deteriorating in parallel with the decline in career remuneration, and the imposition of self-funding of training on students. There are numerous other generational issues not discussed here. It therefore follows that a doubling of the global fleet will present massive challenges to the provision of the required quality of aviation professionals such as pilots. If there is a progressive reduction in entry standards, it will be essential to counterbalance this with smarter selection and training processes, or additional downstream costs will again be incurred

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MPL compared to traditional process

Still globally dominant, the traditional CPL process subjects airline-destined cadets to: Partly irrelevant instruction at the core stage of learning (risky reversion to first learnt later) Omission of some big messages (stall / upset recovery, ATC, TEM) Poor emphasis on modern commercial multi-crew operations For many decades this process has involved: 1. Ab-initio instruction in light propeller aircraft, normally from instructors without airline experience, motivated to build own hours, 2. Accumulation of experience, particularly in the USA, 3. Airline jet upgrade, 4. Airline type transition, 5. Base and line operational experience (LOE)

Decline to minimum standards

Deepening airline costs cuts have exacerbated this disconnect by driving down training volumes towards regulatory minimums, with increasing reliance on the box-ticking approach (see later paragraph). Future growth will further exacerbate this challenge, adding cost downstream if only limited action is taken.

MPL the differences

The differences in MPL training are quite significant. The objective is to begin with the end in mind. MPL is training targeted directly towards an airline-only licence which does not permit the holder to conduct single pilot commercial operations, as a minimum of 70 hours solo is required for this. While the traditional route to an airline was a prescriptive system based on hours of training, MPL employs an integrated competency-based training process in a multi-crew setting. This is achieved by rebalancing the dominant component of training away from less relevant light aeroplane flight, into modern tailored Flight Simulation Training Devices (FSTDs) moving the student rapidly towards the airliner environment. MPL training qualifies an airline pilot into the right seat with all competencies required for command, subject to a generally accepted command entry requirement of a minimum of 1,500 hours of experience

MPL a framework

MPL provides a broad framework of requirements designed to plug training gaps in the traditional CPL syllabus. Many, but not all, of these gaps were previously addressed with add-on modules (CRM, MCC) but not embedded into the syllabus as an existing requirement: Selection is still conducted along traditional lines. Significant improvement is possible and necessary. MPL requires a more thorough selection process (Not a requirement of CPL) Human factors (in Multi-Crew settings) are still a significant factor in accidents. MPL requires a multi-crew setting with embedded TEM, CRM, MCC (Not a requirement of CPL) Improved Instruction: In times of airline growth FTOs are often used by new instructor pilots to gain experience for airline entry, and cases are documented of more than 50% turnover of FTO instructors in a single year. This is a distraction and de-motivator from the instructional task at the FTO. MPL (in EASA) requires higher entry qualification, dedicated MPL training, a policy by most other authorities (Not a requirement of CPL) Airline Handling Skills weaken as automation takes over. MPL requires continuous competency assessment (Not a requirement of CPL)

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Loss of Control has become a significant accident cause MPL requires Upset Recovery Training (URT) (Not a requirement of CPL) ATC communications are an ongoing safety issue MPL requires ATC communications training (ATC system simulation) (Not a requirement of CPL)

MPL and continuous change

Unlike the traditional CPL published in 1947, MPL is a largely dynamic (rather than hour-prescriptive) airline pilot training framework, built for continuous improvement, requiring CBT (competency based training), all applied to the features above. The MPL concept of continuous improvement raises the issue of the fixed regulation regime in aviation, where regulations are adopted and tend to become established for years or decades while the technology they serve changes. Analogous to this, modern IT companies such as Apple Inc. employ development teams to continuously update products in line with technological improvement. Perhaps the aviation industry also needs a future watchdog team to enable regulations to keep up with change.

MPL less box ticking - more module integration

MPL requires previous add-on training modules to be embedded into the programme as a seamless competency based process. In existing programmes it remains legally acceptable for stand-alone add-on TEM and CRM modules, perhaps of only a few days duration each, to qualify a pilot to apply these vital skills effectively for the next thirty years or more. MPL requires continuous interaction with complex and changing line operational situations, embedded into every lesson plan, and in a multi-crew setting. The hour-prescriptive box-ticking modularized approach has been seen as increasingly deficient in addressing the needs of the modern airline system. It seemed to place more emphasis on the enforcement of historical regulatory compliance than to develop best educational process. The worrying backdrop of loss of control and human factor accidents and incidents (Annex A) were forcing a re-think regarding on quality and relevance of the traditional training process, and the development of MPL was partly a product of this.

MPL since birth

Four years after publication (amendment 167 to Annex 1 in 2006), only 32 of the 190 contracting ICAO States have adopted MPL (20%), and only 13 have approved MPL training programmes (7%). Almost 200 MPL pilots are now flying with airlines, and 2,000 MPL students likely to be training by year-end, but none under USA FAA regulation. These numbers are of course tiny compared to the global pilot population, and although a small sample, encouraging feedback is emerging that MPL graduate performance in base training and on the line is generally higher than those trained via the conventional CPL process. IATA plans to publish a matrix summarizing performance data from MPL training as the adoption envelope expands.

MPL introduction - variety is good

Those States and organizations embracing MPL do so with a wide variety of training methods. Variety is positive in that it enables differing systems to be compared and evaluated (within certain limitations), and accommodates differing cultures across the globe (Annex D)

MPL - the real value of light aircraft time?

One of the only hours stipulations in MPL is a minimum total of 240 instructional hours (as a total product of actual flight and simulation). Yet programmes in operation range widely from 240 to over

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350 instructional hours. Flight time in light training aircraft varies from 80 to 112 hours. A primary philosophy of MPL is to limit trainee exposure to actual flight in non-relevant light aircraft to flight items vital for student pilot learning, so that the bulk of instructional time is conducted in multi-crew airliner flight deck environments in simulation. It is interesting to note that as pilot line performance data accumulates, early analysis of line performance from the traditional ab-initio-to-CPL training shows that pilot graduates performance is no different against different levels of light aircraft experience prior to entry. From zero hours to PPL hours, exposure to light aircraft training time seems to produce no clear added value to airline operational proficiency (Annex B). Anecdotally, this is confirmed by a number of airlines

Is the training equipment appropriate?

The training equipment employed by those FTOs conducting MPL varies significantly, due perhaps to existing inventory inertia, change costs, and local regulatory paradigms. A number of training organisations conducting MPL employ as many as three different types of training aircraft with non- airliner characteristics, such as light singles, light twins, and light jets. This requires students to transition on three non-airline aircraft types, adding complexity to their syllabus, less-relevant learning, and reduced focus. This works against the MPL educational philosophy of a total airline multi-crew focus. Programme feedback derived from current trials employing different mixes of light training aircraft may not be measuring apples with apples.

The ITQI (IATA Training and Qualification Initiative)

In 2007 the MPL was quickly followed by the ICAO-endorsed IATA training and Qualification Initiative (ITQI), which looks at the whole pipeline of pilot training for the airline industry in closer detail, aims to provide benchmark guidance based on evidence This initiative adds meat to the MPL bone rolling together PAT (pilot aptitude testing), EBT (evidence based training defining airline pilot performance markers to be applied at the core of competency-based recurrent, transition, and eventually airline focused ab-initio training - MPL), IEQ (instructor and evaluator training), and the new criteria for FSTDS (flight simulation training devices), updated ICAO doc 9625 published in 2009.

New FSTD criteria

Many professionals and managers in airline training know that FSTDs below the fidelity level of full flight simulators (FFS) may not be certified, quality assured, or maintained with the same regulatory rigour as the FFS. In some cases non-regulated devices form a significant component of transition and recurrent training process where the programme is approved but an unregulated device is used. Poor reliability of any training device will always add unnecessary training programme and flight scheduling disruption (downstream cost) In order to design and match Flight Simulation Devices with training tasks (rather than the historical paradigm of matching training with available devices) ICAO commissioned the Royal Aeronautical Society (RAeS) International Simulation Working Group to update and harmonise the existing criteria for simulation (ICAO doc 9625). This resulted in the revised doc 9625, published in 2009.

Training and Licencing - some history:

After the introduction of jet transports in the fifties, airliners became much more expensive to acquire and operate, and the use of the aircraft for pilot training became prohibitive. Simulation progressively took over as the airline pilot training tool.

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In the early eighties, after huge technological change, the 1947 CPL process was already being seen then as less appropriate for the rapidly developing airline industry of the seventies and eighties. In 1982, an ICAO Flight Crew Licencing working group attempted to upgrade airline pilot training, but this initiative was unsuccessful because the fidelity of simulation was not yet at the level required to support more focused airline cadet training Escalating concern continued amongst training professionals that traditional ab-Initio pilot training, which places emphasis on single pilot light aircraft experience, was inadequate for airline entry. The gap between training process and need was widening Eventually in the year 2000, ICAO commissioned an international working group to build a new airline pilot licence. This international working group took five years to complete their work, and the new SARP (Standard and Recommended Practice) for MPL was published as document 9868 on 23rd November 2006 (ICAO Amendment 167 to Annex 1 Personnel Licensing).

A review of aviation hierarchy the operational regulation of international airlines

ICAO is a unit of the United Nations. ICAO SARPS are the basis for National Aviation Authority (NAA) regulations around the world. Responding to industry safety and efficiency needs, ICAO develops and updates SARPS, contained in the 18 Annexes to the Convention on International Civil Aviation. SARPS cover all operational and technical aspects of aviation and by ICAO mandate form the basis for safe and orderly development of international civil aviation. SARPS implementation at National levels is key to aviation safety and efficiency, and to encourage adoption of SARPS, ICAO regularly audits all 190 Contracting State NAAs MPL resistors - some questions Why is this new and conspicuously improved airline initial training process not yet more widely adopted four years after publication? Why is MPL not developing rapidly towards more appropriate airline pilot graduates and a potentially safer airline industry? What are the resistors to ICAO MPL adoption (by only 32 out of 190 States), and the updated ICAO FSTD criteria adoption (only 1 out of 190 States)?

The lag in global adoption of MPL is probably due to a combination of interacting factors:
Natural change resistance Its new (or is it? - MPL is similar to targeted military training). The need has been long identified, yet CPL has worked for decades, hasnt it? False perceptions Erroneous perceptions that MPL was driven by (cost) commercial motives, as a short cut to manning in times of rapid growth; a completely false perception (source: the ICAO
MPL working group)

Recessionary climate Untimely introduction of MPL; published shortly before the global recession kicked in, diminishing revenues, asset values, and enterprise capital Additional costs In changing to any new programme there are inevitable change costs, and FTOs have not had the resources. The additional costs for MPL may include (for legacy FTOs) the replacement or upgrading of legacy equipment together with more stringent requirements for instructor credentials and training. But necessary industry alignment costs do not go away, but

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simply drift downstream into the airline. Many airlines today find it necessary to add significant amounts of training and simulation to ab-initio graduates to bring them to airline standard. Steady-state MPL cost are projected to be similar to CPL, but MPL will probably eliminate the disruption generated by subsequent additional or remedial training leading to a net saving Lower hours in a light training aircraft The diminishing numbers of training professionals who resist MPL have probably not looked beyond pure training hours. MPL training hours are focused on quality and relevance, apply a solo flight requirement, and are applied via a process of pre-mission in a mated-FSTD; the actual mission followed by a post-mission video debrief. Additionally MPL applies a higher overall volume of instructional hours than CPL, often in excess of 300 hours. Reluctance from candidates Potential candidates for airline piloting careers may be reluctant to qualify to MPL because it reduces flexibility should an airline job be lost. Pitches to decision makers The buck stops at CFO and CEO level, and pitches about the value of MPL have to date been mainly addressed to operational and technical managers. In the background, training quality may be seen at higher levels as a low priority compared to all the other financial challenges in airline operations (because it is regulated, its safe?) (Annex C) Regulatory inertia National regulators tend to strictly serve past and existing regulatory structures rather than those needed for future operations. Laws take time to change

Conclusion

Is MPL really that new?

In 1961, the author received his jet training direct from college into the Royal Air Force, without ever having seen a light propeller aircraft close up in the training context. This comprised relatively few hours, but was relevant, focused, competency based training, with URT; almost a for-runner of MPL! So in 2011, 50 years later, whats all the fuss about?

Vision

A deeper understanding of MPL, which this paper attempts to provide, should encourage more future-think and more rapid adoption of MPL. But in terms of statistical proof, MPL is still held hostage by industry paradigms and the chicken and egg syndrome. While the number of FTOs conducting MPL remains statistically small, the data size needed to thoroughly prove the concept does not yet exist. So in the interim, the industry must depend on (1) the limited feedback available (which appears to be positive), and (2) the educational and system logic provided by those training and safety professionals who fully understand MPL. Their advice should only be sidelined if the level future risk outlined in the preceding arguments is not deemed to be important, and counter arguments made for maintaining the status-quo; a risky safety case from the system perspective!
Key components and extracts from the MPL and IATA ITQI initiatives should eventually permeate from the airline arena into training processes for all categories of pilots in the aviation industry

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ANNEX A
Still today almost 40% of accidents/incidents can be related to human errors (and therefore selection and training)

Probable Human Error/Factors Accidents by Category (Fatal/Non Fatal) from 2006-2009

Extracts from an FAA Study of serious incidents between 2001-2009 (Kathy Abbot) November 2010:
flight crew have never been properly trained for operating highly automated aircraft Inadequate crew knowledge of automated systems was a factor in more than 40% of accidents and 30% of serious incidents between 2001 and 2009 Lack of recognition of autopilot or auto-throttle disconnect; lack of monitoring and failure to maintain energy/speed; incorrect upset recovery; inappropriate control inputs and dual side-stick inputs pilots frequently focused on programming the FMS to the detriment of monitoring the flight path There are many failures with which pilots have little or no help from checklists or training

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ANNEX B
TRAINING RELEVANCE Learning to fly Ab Initio to Airline
Managing Momentum Mass x Velocity (how useful is a light training aeroplane?)

Data from medium sized sample airline in Asia utilizing a conventional cadet programme:

No correlation seen between Cadet Grading to initial operating experience (IOE)

No advantage from additional initial light aircraft hours (PPL 30 hours)!

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ANNEX C
Quality of training is the least important factor in a recent airline survey (CAPA 2009)

SHORT TERM CHALLENGES CONSIDERED BY AIRLINES FOR NEXT 1 YEAR
80% 70% 60% 50% 40% 30% 20% 10% 0%

Regulatory Issues

Environmental Issues

Operating Costs (non- fuel)

Availability of Skilled Resources

Quality of Training

Oil Price Volatility

Funding & Capital Raising

Technology Implementation

Weak Demand

MED-TERM CHALLENGES CONSIDERED BY AIRLINES FOR NEXT 1-3 YEARS

50% 40% 30% 20% 10% Funding & Capital Raising Availability of Skilled Resources Oil Price Volatility Regulatory Issues Operating Costs (non-fuel) Weak Demand Quality of Training Environmental Issues Technology Implementation 0%

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ANNEX D
Four years after publication, few States have encouraged adoption of MPL training within their jurisdictions
USA
The FAA had the greatest difficulty in absorbing the MPL because in the USA it is traditional to build experience in alternative general aviation areas before airline entry, without a regular direct ab- initio to airline route. As if to underline this philosophy, following an accident in early 2009 which exposed training as a factor, the US Congress took the political high ground and enacted legislation (the Senate and the House of Representatives passed the HR 5900 Bill now signed into law in September 2010 effective September 2013) requiring 1,500 flight hours for airline entry; ignoring improved training quality and relevance (ICAO MPL) as a solution. In late 2010, a second Government started to consider similar legislation with subsequent Senate hearings in February 2011 MPL Status 13 States out of the 190 contracting ICAO States (only 7%!) have approved training organisations (ATOs) to conduct training for MPL List of States with MPL-approved training organisations (ATOs): Australia CASA: OAA Australia & China CASA & CAAC: Alteon, (Xiamen & China Eastern) Canada TC: CAE-Air Asia China CAAC: CAFUC & Air China Denmark CAA: CAPA & Sterling Germany LBA: LFT/Lufthansa Group & TFC / Air Berlin Hong Kong CAD: OAA/HK Dragon Airlines Philippines CAA: Alpha Aviation Academy Singapore CAA: STAA / Tiger Sweden CAA: L.U.S.A City Airline & Skyways Switzerland CAA: SAT / Swiss Thailand CAA: Thai Airways UAE GCAA:(Sharjah) Alpha Aviation Academy & Air Arabia UK CAA: FTE & OAA/Flybe MPL in planning: Australia: Flight Training Adelaide USA: Aerosim Flight Academy (formerly Delta Connection Academy) USA: Boeing Training China: proposed Pegasus Flight Academy China

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