Diminished value

But over the past couple of years the FAA inspectors who certify the procedures and curricula of the major training organizations have changed the way recurrent training is conducted. Those changes have diminished the value of training and overall ruined the annual experience. That’s not just my opinion. Every pilot I’ve asked who’s been through recurrent at one of the major training organizations in the past couple years feels the same.

As is often the case in the rules we fly by, FAR 61.58 is ambiguous in the most important area. The rule says “A pilot-in-command proficiency check conducted by a person authorized by the Administrator” satisfies the requirement. But what’s a “proficiency check?”

The way the 61.58 proficiency check was administered by the major training organizations for decades was a combination of training and checking. The typical recurrent training program at a big simulator school takes three days and combines both classroom and simulator work. The common course has a pilot in the sim for 12 hours total splitting time between right and left seats. There is sim brief and debrief before and after each session. About an equal number of hours are spent in the classroom, although some organizations—notably FlightSafety Textron, previously known as TRU—offer online ground school to be completed before coming to the training center.

In the sim the instructors had used a three-level grading system for decades. When we flew a maneuver or approach, or some other task, the instructor would mark our performance as “not proficient,” “making progress,” or “proficient.” Makes sense. On the first day back in the sim maybe our steep turns wander around a little, but not too bad. Making progress. The next day we nail the turns and we’re clearly proficient.

Under the old system we were training because the instructors were constantly offering tips and critiques of our flying. If we were a little rusty, we used that information and time in the sim to make progress, and by the end of three days would be proficient in all required areas. Learning was continuous over the entire recurrent program, but we were still monitored and not signed off for the 61.58 until we showed proficiency. In other words, the famous safety slogan of “train like you fly, fly like you train” applied to recurrent training.

Now, under the FAA changes, the training portion of our “recurrent training” has pretty much gone out the window. Now instead of the sim instructor monitoring and grading our performance, the third day of recurrent is an actual pass/fail checkride, complete with oral exam, and administered by a person specifically designated, not a standard sim instructor.

What that means is that one third—an entire day—of recurrent training is lost, wasted on a checkride instead of more training and continuous checking. And even more damaging, the first two days are restricted to concentration on the specific maneuvers and procedures to prepare for the checkride, even if you would like to practice and knock the rust off areas not covered by the third day check.

Taking sim time to explore unlikely, but possible, system failures as we used to is not available. Flying the sim to difficult airports that you may visit in the next year probably isn’t possible because the checklist of items to be practiced for the checkride takes up all the available time in the first two days. And then the check is just a repeat of what the first two days covered with no new experiences or time for emphasis on areas that may need work.

The previous continuous training/checking recurrent training syllabus was used for all pilots, and after that course was complete those who fly for hire under FAR 135, for example, would fly a checkride specified by the FAA office that holds their operating certificate. Now all of us are flying actual checkrides but without the extra training time.

Although the formalized checkride on the third day appeared to have been enforced piecemeal over the past couple of years by the FSDO inspectors who certify training centers, the FAA recently issued guidance that no training can happen during checking for 61.58. So now we can expect all major training centers to fall into line with a third day formalized checkride and oral. This will be a big change. Even among the major simulator training companies the actual curriculum and procedures for recurrent training have been fragmented varying from one geographical location, or governing FSDO, to another.

An example from my personal experience happened a few years ago. I had been flying right seat in a Beechcraft King Air 350 for a couple years and the owners asked me to add the type rating to upgrade to captain. Both FlightSafety at the Wichita center and CAE at its Dallas center offered four-day upgrade courses for those with second-in-command time in the King Air 300 series.

FSI’s requirements were 100 hours of SIC, and CAE set the minimum at 200 hours of SIC. But at FSI all the SIC hours had to be flown under FAR Part 135 rules that required a co-pilot. At CAE you were eligible for the upgrade course no matter if the 200 hours of SIC were under FAR 135, or because the airplane owner wanted two pilots, or the underwriters insisted on two. It didn’t matter.

The program administrator at FSI in Wichita appealed to his local inspector at the FSDO to give me a waiver. I already had several type ratings and lots of total hours. No dice. It was the full two-week initial course for me in Wichita, or nothing. I went to CAE for the upgrade/recurrent course and passed the checkride in four days instead of two weeks at FSI. Does that make sense? Of course not, but it proves how arbitrary training requirements have been from one FAA jurisdiction to another.

Now the change to demand the formal checkride and cut short the training part of recurrent training seems to be widespread, if not universal among the major sim facilities. The question is, does a qualified sim instructor learn more about the proficiency of a pilot by observing him over three days under all sorts of conditions, or does a designated examiner learn more in an hour or so during a single formal checkride session? The answer is clear to me. And it’s not a single session designed as a pass-fail check.

The formal checkride has made a hash of scheduling for the major training organizations because they must have designees to administer the check for every recurrent training customer, not just those training for a new type rating. It’s been hard to find pilots and instructors for any positions over the past few years, and the new rule interpretation exacerbated the situation. FSI canceled my recurrent training course less than a month before schedule. I’ve been training at FSI centers for 40 years and that is unheard of. Only FSI has the CJ4 sim, so there is no option because the underwriters require recurrent training in “make and model,” not just aircraft type as 61.58 does.

The FSI center in Long Beach did have an opening in my 13th “grace month” for training, but that was a surprise. In the past, that center had been reducing availability because of staffing pressure, particularly having enough designated examiners to administer the third day formal checkride for all recurrent trainees. And I don’t expect the situation to get better.

Please, FAA, put the training back into “recurrent training” and make those three days the most valuable learning experience they can be for us every year. Proficiency is the objective of the 61.58 rule, and the many years of continuous training and checking over three days worked best.

J. Mac McClellan is a corporate pilot with more than 12,000 hours and a retired aviation magazine editor living in Grand Haven, Michigan.