July 30, 2009
Docket Operations, M-30
U.S. Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590-0001
RE: Docket No. FAA-2009-0023, Notice of Proposed Rulemaking: Crew Resource Management Training for Crewmembers in Part 135 Operations
The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA’s 2,000 member companies own, operate, and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft air carriers and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air transportation, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation, and the military.
NATAappreciates the opportunity to provide feedback with regard to the Federal Aviation Administration’s (FAA’s) Notice of Proposed Rulemaking (NPRM) for crew resource management (CRM) training in Part 135. NATA supports measures to incorporate CRM into Part 135 and overall is supportive of the FAA’s rulemaking in this regard.
Part 135 ARC Recommendation
CRM has a proven record for reducing accidents and incidents which is why a large number of Part 135 operators already incorporate it into their pilot training programs. As the FAA notes in the NPRM, mandatory CRM training for both single- and dual-pilot operations was a recommendation from the Part 125/135 Aviation Rulemaking Committee (ARC), of which NATA was a member. CRM has long been applied only to aircraft operations with multiple pilots. However, the ARC members strongly believed that the communications, equipment management and organizational principles of CRM would also hold significant benefits for the single pilot who is solely responsible for managing all aspects of flight. NATA is pleased that the FAA proposal is in accordance with the ARC recommendation.
Concerns For Small Operators
NATA is concerned about the level of support the smaller operators, particularly the single-pilot operations, will receive from the FAA. These operators are overwhelmingly small businesses and are more likely than larger operators to conduct all pilot training in-house. Therefore, it is critical to ensure that they are provided with meaningful guidance to assist them in starting their CRM training program.
NATA strongly recommends that the FAA provide a standard, customizable, training program targeted for the single-pilot operational community. While there is a plethora of CRM-related information available from the FAA and commercial sources, at this time little or none of it is designed to consider the application of the training in the single-pilot environment. This puts these operators at a distinct disadvantage as they attempt to incorporate CRM into their training programs.
Provision of a standard program is not unprecedented, and the association contends this is an area where such a program is highly warranted and desired. Most recently, the FAA made available a standard training program to meet hazardous materials training requirements for “will not carry” operators. While no operator would be required to use a standard program, its availability will both reduce the impact of the rule on operators and help ensure consistent training throughout the industry.
Initial and Recurrent Training Times
NATA agrees that setting an hour-based standard for initial and recurrent training would not necessarily be effective with such diversity in the industry and the different learning methods that may apply. However, NATA cautions the FAA to provide clear guidance to the field on this matter. Too often, NATA members report to us that a new inspector demands changes to a previously approved program without a documented regulatory deficiency or policy/guidance change from FAA headquarters. Inspector guidance must clearly state inspector limitations on application of personal preference and defer to the regulatory requirement when approving or seeking changes to the CRM training program.
A standard program could help to reduce this issue significantly as a potential problem as use of the FAA-issued standard program would give operators confidence that their program need not change simply because a new inspector requests it.
Compliance Timeline
NATA believes that the two-year implementation schedule should be sufficient. The association is wary of the impact the submission of these new programs, which require FAA approval, will have on inspector workload. With every Part 135 operator needing to develop and submit a program, which then must be approved in a timely enough fashion so as to begin training in accordance with it, the potential for unacceptable delays is more than likely.
NATA recommends that in the final rule the FAA identify what it believes is a reasonable timeframe for a program, once submitted, to be approved. This may vary by type or complexity of operation, but providing a general guideline will assist operators in knowing when they should have a program submitted and approved so that they can meet the compliance deadline.
Again, NATA notes that a standard program could help alleviate this problem. Operators that most likely do not already have a formal CRM program that would meet FAA’s proposed requirements are likely the smallest of the businesses impacted (as mentioned by the FAA in the NPRM). An operator, using a FAA standard CRM program, could in theory be permitted to adopt that program and implement it knowing that the FAA will approve it as their program.
Credit For Previous Training
NATA supports the provision to allow a new employer to accept a pilot’s prior CRM initial training. FAA mentions that the credit for previous training would be allowed if the crewmember is able to provide appropriate training records. NATA requests that the FAA specify in the preamble for a final rule precisely what records would be acceptable so as to avoid problems with variation across the FAA regions and FSDOs as to what type of documentation is required.
Overall, NATA is highly supportive of the FAA’s effort to formalize CRM training throughout Part 135 and appreciates the consideration of our suggestions to improve the implementation process.
Sincerely,
Jacqueline E. Rosser
Director, Regulatory Affairs
View in PDF format.