India needs better preparedness to adopt Multi-Crew Pilot Licence
India has been following the traditional prescriptive training methodology with very few changes over the years
The Multi-Crew Pilot Licence (MPL) was adopted by the International Civil Aviation Organisation (ICAO) in 2006 with an amendment to the ICAO Annex-1. India has still not implemented the change. India has been following the traditional prescriptive training methodology with very few changes over the years. The idiom “don’t fix it until it breaks” fits well in the Indian context.
There is, however, a need to rationalise the training curriculum since it has been overloaded with additional training requirements post a major accident or an ICAO mandate. There are lobbies that have been pushing for the introduction of MPL in India in partnership with a few airlines. The airlines unknowingly are falling for the bait which they have been doing for eternity.
India has always been seen as a milking cow by the West and the sheer numbers in terms of training hours required seems like a lucrative business to anyone. The question here is: is India prepared to launch and support a new training and licensing methodology? The current state of churn within the flight standards directorate of the regulator has seen all new faces. The oversight function is not optimal and the airlines haven’t developed a robust flight operations quality and standards set-up either. The cost of training and interoperability are also areas of concern.
The process of pilot training in the early days started with gathering flight hours and experience mainly with general aviation or as an instructor in a flying school. With enough experience and an airline job, pilots were able to transit from flying smaller and slower aircraft to jet aircraft after some initial base training.
The need to update and review current pilot training was actually first formally recognised as early as 1982 and the first ICAO attempt to adapt to the changes in the airline industry was the installation of the Personnel Licensing and Training Panel (PELTP) from 1982-1986 (IATA, 2011). The panel, unfortunately, failed when its final proposal could not garner the necessary support from the Air Navigation Commission (ANC) and the ICAO Council, thus resulting in no change to pilot training. The discussions did, however, continue.
As these forces converged, the ICAO recognised the need to review training standards, which led to a second attempt to approach this issue in October 2000 in Madrid. The confirmation resulted in the installation of the ICAO Flight Crew Licensing and Training Panel (FCLTP). In fact, this was to be the first major review of existing practices in 25 years and one with an ambition to create an alternative approach to pilot training and licensing.
The FCLTP worked on proposals and/or amendments on identified changes between 2002 and 2005. According to Forbes (in Scheck, 2006, p 21-22), this resulted in the following:
– Amendments to Standards and Recommended Practices (SARPs):
– Annex-1: Flight Crew Licence Requirements
– Annex-6, Part 1 and Part 3: Training Requirements -- Recommendations for certification/approval of training organisations
– Approval of training organisations with regard to this new training methodology
– Development of proposals for a Multi-Crew Pilot Licence (MPL) – Aeroplane
First step: MPL training and design
ICAO states that the course development methodology of the MPL should be structured around the already-mentioned Instructional System Design (ISD) which is based on the Analysis, Design, Development, Implement and Evaluate (ADDIE) model.
The ISD process begins with a rigorous analysis of the profession for which the cadet is to be trained. This analysis should include a study of the organisational system in which personnel must work, the critical aspects of individual functions of the profession and the performance levels required for each function in that profession. This analysis is referred to as the 'task analysis' (Teunissen, 2002).
Then, based on the outcomes of this task analysis, performance standards are set and a training curriculum can be designed. The next step would be to develop and implement a training programme in accordance with the designed curriculum. This creates an apparent benefit and advantage to training as there is a direct link between training standards and the specific requirements of the profession.
Specifically, for MPL training, there is a requirement for feedback and a quality assurance system that is harmonised within the training organisation (such a system is later described and discussed).
An additional benefit of this approach is that the process itself and the resulting documentation remain known to any user involved (Teunissen, 2002). If successful, the process enables and ensures that training programmes and performance standards can keep pace with changes in professional requirements as well as with the cadets’ achievements of the targeted training outcomes. Given the dynamically developing nature of aviation, this logically becomes essential to optimise training conditions.
Implementation and oversight
An MPL training course is generally divided into four phases, often referred to as Core, Basic, Intermediate and Advanced. It only requires a well-functioning student management system to assure that the progress of each student follows predetermined norms in all competencies together with clear definitions of the terminal training objectives.
The ICAO standard for the MPL specifies 240 hours as the minimum number of actual and simulated flight hours, performing the functions of the pilot flying and the pilot non-flying.
However, the standard does not specify the breakdown between actual and simulated flight hours and thus allow a part of the training curriculum that was traditionally conducted on aeroplanes to be done on Flight Simulation Training Devices (FSTDs).
However, there is a requirement that the applicant must meet all the actual flying time requirements for a private pilot licence plus additional actual flying time requirement in instrument, night-flying and upset recovery.
Is the current state of preparedness enough?
The prevailing training and standards set-up may not be conducive for a change from the traditional system of training and licensing. The change management process of the safety management system will require detailed documentation of the need for a change and a threat error analysis.
A justification is that the new system can be supported by the existing infrastructure and the pros/cons of the methodology. A review process in terms of genuine feedback and re-analysis as a part of the ISD loop is needed.
Problem 1: Weak Safety Management System implementation
The implementation of the safety management system (SMS) in India is still in stage two and in the recent past, there have been numerous deficiencies that have been identified during the safety audits of the leading airlines in India.
The series of incidents in 2019-20 and the audit/inspection of the airlines have highlighted the weakness in the safety management system. Most airlines have been tailoring their SMS backwards to meet their operation/training requirements.
Problem 2: Inadequate regulatory oversight and training
The regulator has been struggling to draw talent to meet with the number of Flight Operation Inspectors (FOI) required in the flight standards directorate. These FOIs need to be trained in the new methodology to an expert level since they will be required to evaluate and approve the training methodology.
The lack of experience within the regulator to evaluate, approve and have an effective oversight will become critical in the design and implementation of the MPL. The absence of human factor experts in the regulator's team is a matter of deep concern when safety is a critical element of all activities.
Problem 3: Airlines' quality assurance system weakness
The design and implementation of the MPL not only requires subject matter experts in the field of ISD and training but also software like the training management system. The training of trainers in evaluation and accretion recording of data will determine the quality of the system.
The leading airlines at present are not only lacking in standardisation of trainers but also inter-rater reliability. Competency-based training and assessment require continuous assessment and evaluation of the trainee, and at the command level, requires assessment of the critical thinking skills.
Formative and summative assessments and evaluations have to be meaningful and manageable. Making sense of the data and eliminating noise requires a highly trained and cohesive team working towards achieving the organizational goal and state objectives.
India has traditionally been a milking cow for the West. Training programmes have been sold off the shelf without any customisation to avoid the costs involved. Since India is unique in many ways, the culture is different and work ethics is at a reactive stage, there is a need for a lot of groundwork to be done in terms of strengthening the foundation. In order to open the door for more new and progressive training methodologies, the entire system needs to gear up and work together. The traditional Indian concepts of training like the gurukul, to which the world is coming back, need to be used again. Like the New Education Policy, there is a need to combine the traditional and modern ways of training which suit the Indian palette. Since an accurate recording of data is critical to the evaluation of the system, the use of artificial intelligence is the need of the hour.
If the MPL is introduced in the present state, the only lobby that will be raking profits will be the Full Flight Simulator (FFS) manufacturers and training organisations which would be implementing the training since the FFS requirements are going to skyrocket with this change. The cost of an MPL would be definitely much higher. The licence is given to the airline with which the trainee trains and to convert it into a commercial pilot licence (CPL), additional flying hours will have to be invested in. In a situation like Covid-19, this would not be desirable.
There is no need to rush into importing a new system when the overall preparedness levels are low or undeveloped. Instead, a roadmap needs to be developed so that future long term needs could also be envisioned and a phased implementation planned. Thinkers and institutions involved in research and development must be associated with the whole process. The traditional CPL and an airline-type rating under a stringent quality set-up is a good option too. Let there be debates, discussion and then move ahead with public participation and collaboration.
(This article first appeared in avobanter.com)