Boeing MAX Safety Report Widely Misunderstood

Headlines about the recent NTSB Safety Recommendation Report on the 737 MAX design are focusing all attention on the report’s cover page. But is the report really about pilots reacting to emergencies in unexpected ways?

I found the most relevant part of the report on page 5. This is where the NTSB described Boeing’s use of an engineering simulator in testing the severity of MCAS malfunctions.

Failure modes that could lead to uncommanded MCAS activation (such as an erroneous high AOA input to the MCAS) were not simulated.

In other words, Boeing never simulated MCAS sensor failures while evaluating pilot responses to MCAS malfunctions. If you thought this report was about bad assumptions on pilot behavior, you missed the fact that Boeing only used a scenario where the MCAS sensors were working just fine, and the MCAS silently went mad.

So the NTSB isn’t just telling Boeing and the FAA to adjust their metrics for pilot behavior. They are asking for a top-down review of pilot reactions to all realistic problems, such as sensor damage, when approving any new design as airworthy.

Airlines Still Selling Boeing MAX Tickets

Southwest Airlines 737 MAX Tickets

More than three months after the accidents and worldwide emergency grounding of Boeing’s 737 MAX airplane model, airlines in the USA are still selling tickets to fly on these airplanes.  This contradictory market for disreputable flights exists amid frequent press releases about rolling cancellations of the same flights month after month.  Why are these airplanes still scheduled at all?  Are these airlines in such a hurry to have the 737 MAX return to service that they will honor these tickets the moment the government allows it?

Yesterday, the FAA announced that they “recently found a potential risk that Boeing must mitigate.”  This has been widely reported with alarmist spin as a “new” safety concern that will delay the 737 MAX certification review.  However, no official source actually described the risk as “new” or otherwise unique from the original design flaws.  Boeing described the risk as “a specific condition of flight, which the planned software changes do not presently address.”  Some of the more sober news articles later this afternoon described the specific condition as a stabilizer trim runaway in which the manual electric trim switches are unresponsive or slow due to a computer malfunction.  Travelers and industry experts alike must consider this as an ongoing process that may have revealed more information about the original design, rather than creating new or worse problems.

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R-ATP Denied at Eastern Michigan University

Letter of denial from FAA to EMU.A search on federal websites revealed the FAA denied Eastern Michigan University’s exemption petition for R-ATP flight training last month.  “The FAA has fully considered the petitioner’s supporting information and has determined the relief requested is not in the public interest and would adversely affect safety.”  This decision is not surprising in light of the two-year delay and similar decisions preventing other Part 141 flight students from obtaining eligibility certification for a Restricted ATP check ride.

In its letter, the FAA gives this official response:

Based on the FAA’s records, EMU does not hold a part 141 ground school certificate. The FAA reviewed the description that EMU provided of its arrangement with EFC for the ground and flight training of students enrolled in its Aviation Flight Technology program. The arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum. EMU does not have control over the curriculum provided by EFC and the FAA would have no oversight responsibilities with EMU because it does not hold a part 141 pilot school certificate. Therefore, the FAA has determined that EMU’s aviation degree program does not meet the minimum level of integrating its pilot ground training with its broader academic curriculum of an aviation degree program.

Update: R-ATP Exemption Follow-Up

R-ATP Denied at Baylor University

Letter of denial from the FAA to Baylor University.Part 141 flight training graduates have been denied participation in the R-ATP program again, this time at Baylor University.  In its recent denial letter, the FAA explained that even though Baylor’s students are enrolled in an aviation degree program with part 141 ground and flight training, the lack of a ground training certificate in the university’s name prevents the graduates from qualifying under the new regulations.

The FAA reviewed the description that Baylor provided of its arrangement with TSTC for the ground and flight training of students enrolled in its Aviation Science Bachelor degree program. The arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum by virtue of Baylor not holding an air agency certificate issued in accordance with part 141. Baylor does not have control over the curriculum provided by TSTC. As noted in the petition, Baylor students pursuing their instrument rating and commercial pilot training become TSTC students during those phases. Therefore, the FAA has determined that Baylor’s aviation degree program does not meet the minimum level of integrating its pilot ground training with its broader academic curriculum of an aviation degree program.

The FAA also cites the recent denial at MSU Denver as precedent for this new denial at Baylor University.

Update: R-ATP Exemption Follow-Up

Denial of R-ATP Exemption for MSU Denver

Denial of exemption letter to MSU DenverThe Federal Aviation Administration (FAA) this week denied an exemption to the Metropolitan State University of Denver that would allow graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification.  This is a complete reversal from the decision issued last week to Purdue University.  In denying MSU Denver, the FAA writes, “the relief requested is not in the public interest and would adversely affect safety.”

Following that determination is a somewhat bizarre accounting of MSU Denver’s aviation program:

The proposed arrangement does not meet the intent of having the ground training integrated with the broader academic curriculum. MSU Denver does not have any control over the curriculum provided by CNCC and the FAA would have no oversight responsibilities with MSU Denver because it does not hold a part 141 pilot school certificate.

The FAA notes that MSU Denver voluntarily surrendered its air agency certificate on April 19, 2013, and stated in its petition that it will continue to conduct training via part 61 vice part 141. Prior to the voluntary surrender of its part 141 pilot school certificate, MSU Denver held approved ground school training course outlines for the commercial pilot certificate and the instrument rating. Without a part 141 certificate, the FAA will not be able to determine if MSU Denver’s key personnel, facilities, aircraft, equipment, and training syllabus maintain a training standard that is equivalent to part 141. As stated above, the FAA has determined that meeting the part 141 standards are a necessary component to ensuring proper integration of the ground training with the broader academic curriculum and it enables the FAA to oversee the program and ensure continued compliance with the letter of authorization issued on an established 24-month schedule that coincides with the part 141 pilot school renewal. The FAA has concluded this oversight is critical for assuring that the standards set forth by Congress for a reduction in flight time continue to be met.

The FAA also notes that because MSU Denver previously held a part 141 pilot school certificate, graduates who completed their ground and flight training for their instrument rating and commercial pilot certificate under that training program could be eligible for a restricted privileges ATP certificate with reduced aeronautical experience without an exemption. MSU Denver has not yet applied for the authority to certify those graduates.

This decision is a significant setback for MSU Denver graduates, which creates a bad precedent for regulation of flight training in general.  As stated in its petition, “MSU Denver will no longer be able to support industry needs and educational programming to highly diverse populations with the same viability it has sustained for over 45 years.”  If the Part 141 university graduates are unable to qualify for R-ATP certification, then the value of Part 141 training is further reduced at all universities.  Authorization of R-ATP qualification programs began in August 2013 and has reached only 33 States so far, leaving many Part 61 and Part 141 aviation graduates ineligible.

R-ATP Part 61 Exemption for Purdue University

Grant of Exemption letter to Purdue UniversityThe Federal Aviation Administration (FAA) this week granted an exemption to Purdue University allowing graduates of Part 61 flight training to become eligible for restricted ATP (R-ATP) certification with reduced experience requirements.  This exemption is retroactive.  It is effective for all Purdue graduates from 2009 through 2016.  The R-ATP check rides can be conducted through July 2017.  Graduates are now only required to have an eligibility certificate from the university and a copy of the exemption letter from the FAA.

This exemption marks the first time the FAA has accepted R-ATP applicants who did not complete FAA-approved training under Parts 141 or 142.  The requirement for airline pilots to hold an ATP or R-ATP certificate went into effect August 2013 and made no exceptions for university graduates who completed the same training under Part 61.

Purdue’s petition for exemption was dated 24 August 2013.  Petitions from four other universities remain outstanding and were neither granted nor denied.

The FAA gave the following reasons for granting this exemption:

  • Purdue became a Part 141 flight school on 27 September 2013.
  • Purdue received authorization to certify R-ATP eligibility on 31 March 2014.
  • Purdue’s Part 141 ground training “is no different” from its former Part 61 program.
  • “Key personnel, facilities, aircraft, equipment, and training syllabus … also existed when Purdue conducted training under part 61.”
  • Several factors contributed to “an equivalent level of safety … for those who previously completed their ground and flight training.”

Previous article: R-ATP Exemption for Part 61 Training

Pilot Shortage Update

Graph showing pilot and other airmen statistics past and projected.
Airmen Employment Statistics

Graph of active pilot numbers from 1999 through 2013.
Active Pilots in the U.S. the past 15 years.

The release of December 2013 airmen statistics indicated another increase in the number of airline-qualified pilots in the United States.  Labor statistics also showed an increase in pilot employment last year.  As a country, we do not seem to be running out of pilots by any numerical measure.

A deeper analysis is always more interesting, of course.  Despite the new hiring for airline pilots, the long term employment projection changed from positive to negative.  The reasoning offered with the projection is very similar to my own comments posted earlier this year: Airlines will increase the capacity and efficiency of their fleets to improve profitability.  Taken a step further, this could result in fewer flights in the future.  This seems to be a pessimistic view, and I do not agree with the idea that airlines would try to effect a long-term reduction of flights.  Overall flight reduction is also contrary to the FAA projection of more aircraft operating each year through 2034.

Trends in pilot certification remain mostly unchanged, with the exception of accelerated divergence between ATP and commercial-level pilots, likely due to the regulatory changes requiring existing pilots to upgrade.  That regulatory effect will stabilize after 2014, but will remain divergent due to the permanence of upgrades.  The overall lack of trend changes between 2011 and 2013 is significant because the FAA continues to project trend reversals for private pilot and commercial pilot numbers.  This casts further doubt on the new projections for private and commercial pilot certification to increase.  Our general aviation sector has been losing around 8,000 private pilots and 2,000 commercial pilots per year since 2003.  Given that momentum, the GA numbers could easily fall another 10% to 20% or more before reversing.

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First R-ATP Authorizations Announced

Institutions Authorized to Certify its Graduates for an Airline Transport Pilot (ATP) Certificate  with Reduced Aeronautical ExperienceThe Federal Aviation Administration (FAA) this week issued the first Letters of Authorization for universities to make their graduates eligible for an airline pilot certificate under FAR 61.160.

It is a short list of lucky firsts:

  • Eastern Kentucky University
  • Embry-Riddle Aeronautical University
  • University of North Dakota

These three universities can now officially certify graduates as qualifying for a restricted privileges airline transport pilot (R-ATP) check ride.  Without such certification, pilots are required to meet a new minimum experience level of 1,500 flight hours before working at an airline.

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