Chapter 2
Pilot experience requirements; Pilot recruitment and training; and Pilot retention
2.1
This chapter discusses a number of terms of reference concerning airline
safety in connection with the issues of pilot experience requirements,
recruiting and training and pilot retention (terms of reference (a), (b), (c),
(d) and (e)). The specific terms of reference are:
-
pilot experience requirements and the consequence of any reduction
in flight hour requirements on safety;
-
the United States of America's Federal Aviation Administration
Extension Act of 2010, which requires a minimum of 1500 flight hours before a
pilot is able to operate on regular public transport services and whether a
similar mandatory requirement should be applied in Australia;
-
current industry practices to recruit pilots, including
pay-for-training schemes and the impact such schemes may have on safety;
-
retention of experienced pilots; and
-
type rating and recurrent training for pilots.
2.2
The issue of pilot experience requirements was one of the main issues
addressed in the submissions and evidence received by the committee,
particularly in relation to the current experience levels of commercial airlines—that
is, regular public transport (RPT)—pilots and co-pilots, and the proficiency
levels achieved through modern pilot training methods.
Pilot experience requirements and the consequence of any reduction in flight
hour requirements on safety
Regulatory requirements relating to
pilots' minimum flight experience
2.3
The committee heard that, in Australia, the Civil Aviation Safety
Authority (CASA) is responsible for 'setting the minimum requirements for
flying experience and knowledge standards necessary for gaining Australian
pilot licences and endorsements and ratings that may attach thereto'.[1]
2.4
There are three legislatively based elements governing pilot experience
requirements for obtaining a pilot's licence and any related endorsements or
ratings. These are:
-
the minimum experience (flight hours) and knowledge standards specified
in the [Civil Aviation Regulations 1988 (CARs)] for the purposes of gaining
various pilot licences and any additional ratings that may subsequently attach
to a licence;
-
the minimum periodic currency standards specified in the CARs to ensure
the holder of a licence or rating maintains the proficiency necessary to safely
continue to exercise the privileges of [that] licence or rating; and
-
the regulatory requirement for airlines to have in place a
training and checking system.[2]
2.5
Airlines may establish experience requirements in addition to the
legislative elements outlined above. These are 'often expressed in terms of a total
number of flying hours, which...[are set] as a minimum entry level to a particular
airline'.[3]
Current experience requirements for
regular public transport airline pilots
2.6
The committee heard that, with the exception of pilots (captains) of low
capacity RPT,[4]
CASA does not prescribe minimum experience requirements for co-pilots or pilots
of RPT flights in Australia. However, the requirements for obtaining pilot
licences operate as a de facto minimum experience requirement.
2.7
There are two licence types which are the basis of qualification to act
as a co-pilot or pilot for a commercial RPT flight. These are, respectively,
the Commercial Pilot Licence (CPL) and the Air Transport Pilot Licence
(aeroplane) (ATPL).[5]
2.8
A third type of licence, the Multi-crew Pilot Licence (MPL), may also
qualify a person to act as co-pilot for a commercial RPT flight. While there
are currently no co-pilots operating in Australia on an MPL issued under the
CARs, a number of submissions discussed these licences, given their potential
to be issued in future.
Commercial Pilot Licence
requirements
2.9
In simple terms, a CPL qualifies the holder to:
-
fly a single pilot aeroplane as pilot in command (captain) while
the aeroplane is engaged in any operation;
-
fly a multi-pilot aeroplane as pilot in command while the
aeroplane is engaged in any operation other than a charter operation or RPT
operation; and
-
fly an aeroplane as co-pilot while the aeroplane is engaged in
any operation (including RPT operations).[6]
2.10
To qualify for a CPL via a commercial training course, a person must
have, inter alia, a minimum of 150 hours of flight time flown as a pilot during
the training course. The regulations specify the amount of particular types of
experience that may count towards the total 150 hours.[7]
2.11
To qualify for a CPL via general aviation, a person must have a minimum
of 200 hours of flight time. The regulations specify the amount of particular
types of experience that may count towards the total 200 hours.[8]
Air Transport Pilot Licence
requirements
2.12
In simple terms, an ATPL qualifies the holder to:
-
fly an aeroplane as pilot in command (captain), or co-pilot,
while the aeroplane is engaged in any operation (including RPT operations).[9]
2.13
To qualify for an ATPL, a person must have, inter alia, a minimum of
1500 hours of flight time that includes 750 hours as pilot of a
registered, or recognised, aeroplane. The regulations specify the amounts of
particular types of experience that may count towards the total 1500 hours.[10]
2.14
CASA submitted that the regulatory standards governing experience
requirements for CPL and ATPL licences represented 'safe and internationally
recognised minima for the operation of Australian registered aircraft by
airlines'.[11]
The CASA submission stated:
The minimum number of hours required to obtain a
qualification (such as a private pilot licence) is generally set by [the International
Civil Aviation Organization] ICAO and, in practical terms, provides a degree of
confidence that a person with the prescribed number of hours of training and
experience has acquired the skills needed for the award of a licence.[12]
2.15
As noted above, however, airlines 'frequently' set minimum experience
levels as a precondition of employment that are higher than the regulatory
minima set out above.[13]
2.16
In both cases, CPL and ATPL holders must also hold additional
endorsements (such as a class endorsement) and ratings (such as a flight crew
rating) to be entitled to co-pilot or pilot a particular class or type of
aeroplane. Such endorsements or ratings may also increase a licence holder's
flight or training experience above the minimum licence requirements.
2.17
The committee heard that minimum experience requirements for licensing
purposes are complemented by requirements which ensure that proficiency is
maintained. As noted above, pilots must adhere to periodic currency standards,
which require a mandated number of hours to be flown over a specified period in
order for a licence or rating to remain valid.[14]
Airline operators are also required to maintain 'internal training and
checking' systems to induct and train new and ongoing pilot employees, and
pilots are required to undergo at least two proficiency checks in each calendar
year. Training and checking systems are audited by CASA.[15]
Multicrew Pilot Licence
requirements
2.18
In simple terms, an MPL qualifies the holder to:
-
fly an aeroplane as co-pilot while it is engaged in any operation
conducted under an Air Operators Certificate (AOC) that authorises charter or
RPT operations.
2.19
To qualify for an MPL, a person must have, inter alia, a minimum of
240 hours of training as a pilot during an approved course of training,
including:
-
40 hours of flight time as pilot of a registered aeroplane;
-
at least 10 hours of solo flight time in a registered aeroplane;
-
at least five hours of cross-country flight time as pilot in
command (captain) in a registered aeroplane; and
-
at least 12 take-offs and landings in a specified type of
aircraft.[16]
2.20
The regulations also specify requirements for an MPL holder to hold a
relevant endorsement and crew rating to act as co-pilot on a particular class
or type of aeroplane.[17]
Pilot licence experience requirements
2.21
On the question of the types of experience that are counted towards the
minimum experience requirements for the grant of a pilot licence, the
Australian and International Pilots Association (AIPA) expressed concern that
glider experience is able to be counted towards the 1500 hours required to hold
an ATPL.
2.22
AIPA contended that glider experience does not correlate well or closely
enough with the flying of engine-driven aircraft in a multi-crew environment.[18]
2.23
AIPA's view was supported by Captain Tim Berry, Director of Operations
for Tiger Airways, who felt that 'no consideration should be given...in the
context of an ATPL to glider pilot hours, ultralight pilot hours or anything of
that kind'.[19]
2.24
Accordingly, AIPA called for the experience requirements for the grant
of an Australian ATPL to be reviewed to ensure that sufficient weight is placed
on multi-engine aeroplane experience as opposed to the recognition of glider and
ultralight experience.[20]
Consequences of any reduction in
flight hour requirements on safety
2.25
The terms of reference for the inquiry directed the committee to
consider the consequences of any reduction in flight hour requirements on
safety. Very little, if any, evidence was received on this question, most
likely because there is no apparent proposal or likelihood that the current
minimum experience requirements for the granting of pilot licences will be
reduced.
2.26
However, many submissions commented that, historically, co-pilots and pilots
of RPT flights generally commenced with flight experience hours well in excess
of the minima prescribed for licence qualification. Suggested reasons for this
included airlines setting higher entry requirements, a greater proportion of
candidates coming through the general aviation pathway (where high numbers of
flight experience hours are common), and traditional career pathways whereby
candidates often gained significant flight hours as second officers. Captain
Geoff Klouth submitted:
Traditionally experience has been valued in aviation and it
was only through the accrual of experience that a pilot was able to progress to
the next level of operation. This would result in experience levels in the
cockpits of jet aircraft being high with the First Officer and the Captain. The
stable nature of the Australian airline industry also meant that First Officers
generally had many years in the right hand seat before progressing to Captain. With
the collapse of Ansett and the rapid expansion of Virgin Blue that stable progression
was replaced by pilots obtaining jet Command positions within 6 to 12 months of
commencing with the airline.[21]
2.27
The committee heard that co-pilots are today frequently commencing as
first officers with a number of flight experience hours much closer to the
prescribed licence minima. The consequences of this apparent development were
addressed in much of the evidence provided to the inquiry.
2.28
Accordingly, the committee considered the consequences of the current
trend towards flight crews having lower average experience levels than in the
past.
Consequences of trend towards lower average experience levels
2.29
As noted above, a number of submissions identified a trend in the
aviation industry towards pilots operating on RPT flights with lower average
flight experience levels. Tiger Airways noted that a worldwide shift in
recruitment practices, away from general aviation and military pathways, was a
factor in declining experience levels:
...there has been a trend internationally over the past twenty
years, or so, away from 'traditional' routes [that is, general aviation and the
military] for pilots into commercial aviation. Traditional routes into aviation
did generally mean that pilots did have a higher number of flight hours than is
the case today.[22]
2.30
VIPA submitted that the general 'lowering in the average flying
experience levels of crews', was due to the increased competition and number of
aircraft being operated in Australia.[23]
2.31
Some airlines indicated that, for various reasons, their recruitment
strategies favoured candidates coming through training courses specifically
designed to produce commercial RPT pilots. This is discussed further below
under the discussion of cadet schemes (term of reference (c)).
2.32
However, some airlines provided evidence indicating that they continued
to recruit pilots with experience levels well in excess of the prescribed
licence minima. Captain Rick Howell, General Manager of Flight Operations and
Chief Pilot for the Virgin Blue Group (Virgin), for example, advised:
...for Virgin Blue and...V Australia as well, the first officer
standard...is 1000 hours and 500 hours in multiengine aeroplanes so...it is well
above the minimum standard...I do not believe that we have actually recruited
anyone into a first officer position with less than 1500 hours.[24]
2.33
Mr Tony Davis, Tiger Airways' Chief Executive Officer and President, advised
that Tiger Airways had in place a requirement of 2000 hours for its co-pilots.[25]
Risks associated with lower average
experience levels
2.34
CASA submitted that current licensing standards, along with supporting
measures such as training and checking systems, meet international standards
and produce pilots with adequate levels of proficiency to operate safely in the
aviation sector:
Australia's basic pilot licensing system meets or exceeds
ICAO requirements and produces pilots equipped to move safely and competently
into the airline environment. Similarly, the mandated training and checking
system required of airlines, when properly designed to meet the airline's
operational and human capital environment, provides an ongoing training and
proficiency checking outcome that helps to ensure high safety standards.[26]
2.35
However, a number of submitters and witnesses expressed concerns about
pilots operating close to minimum experience requirements.
View of the Australian and
International Pilots Association
2.36
High level concerns over the lower average experience levels for
operating pilots were encapsulated by the views of AIPA. AIPA expressed concern
that 'the widespread shift in emphasis on airline pilot recruiting...has and will
continue to increase the risk of an aviation accident'.[27]
While AIPA acknowledged that modern training systems place an emphasis on
competency based approaches,[28]
it believed that:
...the current minimum hours required...[to hold] a licence to
act as a crewmember on regular public transport (RPT) [is] insufficient to
provide the appropriate balance between technical skills, knowledge and
experience that would enable a pilot to adequately perform that role in all reasonably
foreseeable circumstances.[29]
2.37
AIPA described the solution to current shortcomings in pilot skills as
'multifolded':
You have got to give the basic flying skills to the pilot to
start with. The second thing is that you have got to teach them about the
systems of the aeroplane so they can fault analyse and the third thing is that
you have got to teach them how to use the automation of the aircraft properly
and how to deal with it when it operates incorrectly. So you have got to teach
people the basics of analysing what the automation is doing with aircraft right
now. Modern aircraft are very complex and have many modes that you can use. ...[There]
have been a number of accidents worldwide where the pilots simply got confused.[30]
2.38
AIPA called for a 'comprehensive review of the minimum experience requirements
for Australian airline pilots to act as a crewmember on [RPT] operations [to] be
undertaken by [CASA].[31]
In terms of the scope of the review:
The ultimate purpose of the review should be to design a
compulsory "pilot experience and safety management plan" (PESMP) that
would be binding on commercial airlines operating into and out of, or operating
in Australia. In turn, the essence of the PESMP would be to establish a
compulsory risk management framework that would see lower experienced pilots
having their piloting skills assessed, corrected and confirmed more frequently
than experienced flight crew. The PESMP would also have to address a robust
support and supervision requirement that would mitigate increased pressure on
Captains operating with a low experience crewmember.[32]
2.39
Similar concerns were voiced by a number of groups and individuals that
provided evidence to the inquiry, with particular emphasis on the following
specific matters.
Capacity to respond to emergency
situations
2.40
A number of submitters expressed concern that an inexperienced co-pilot
would not be able to effectively support his/her pilot (captain) in high stress
or emergency situations. VIPA, for example, described this as a latent risk in
current airline operations
...we are seeing an emergent risk...[where] a relatively inexperienced
airline captain will be faced with a situation where a low-experienced First
Officer is unable to provide the Captain with the level of operational support required...[This
will] increase the likelihood of an undesired outcome should an abnormal
situation arise. VIPA believes that the obvious latent...nature of this issue and
the increased demand for close supervision of the First Officer by the Captain
has a negative impact on operational safety. [33]
2.41
VIPA did not believe that there were appropriately directed strategies
in place to address the latent risk identified:
In isolation, the inherent risk of this situation could be
dealt with by utilising the traditional mitigators of increased training and
greater mentoring by the airlines, aligned with specific quality oversight of
risk management and training by the regulator. VIPA is of the opinion that
these risk control strategies are ineffective or completely nonexistent.[34]
2.42
Captain Klouth noted that the presence of a relatively inexperienced
co-pilot 'puts the other pilot under more pressure to make up for the lack of
experience', and that there was an increased risk that 'they may find
themselves in a situation that neither pilot knows how to deal with effectively'.[35]
Cockpit authority gradients
2.43
A number of submissions commented on the issue of cockpit authority
gradients, which refers to the relative experience levels of a pilot (captain)
and his/her co-pilot. A 'steep' cockpit authority gradient occurs where a pilot
has substantially more experience than the co-pilot. In this situation, there
is an increased risk that a co-pilot with relatively few flight experience
hours will be less likely to question or challenge the judgement of the flight
captain, even where the safety of a flight and its passengers may be stake.
Captain Klouth explained:
...when you have a high cockpit gradient where you have a
significantly experienced captain with a first officer who does not have much
experience, then that can create a situation whereby maybe the first officer
does not feel he can speak up.[36]
2.44
Further, a 'steep' gradient will increase the level of supervision and
work required to be done by a captain in all circumstances, and this may
increase the potential for accidents in both normal and emergency operating
conditions.
2.45
A number of airline operators, while acknowledging that issues could
arise from 'steep' cockpit authority gradients, pointed to significant aspects
of organisational culture or operating procedure which can ensure that safety
is not undermined.
2.46
Regional Express, for example, submitted that 'the industry has put a
considerable amount of work in...[over] the last 15–20 years around...cockpit
resource management [CRM] and...threat and error management'.[37]
Mr Chris Hine, Flight Operations General Manager, commented that training in
Regional Express was strongly geared to overcoming authority gradients, and
such training was reinforced by the airline culture more broadly:
...we have got a culture in the airline in which the first
officers feel very supported in coming forward and indeed the captains feel...open
to that feedback. That has been one of the fundamental changes in the last
20-30 years in aviation, that the [First Officer] should not just sit there and
say nothing and make the captain look good.[38]
2.47
Virgin advised that, while the regulation of training in non technical
skills or human factors (which deals with, inter alia, cockpit authority
gradient issues) was somewhat deficient, the airline had pursued a best
practice approach to training in these areas. Captain Howell advised:
[With regard to]...what is normally called in aviation circles
non-technical skills or human factors training...the regulation has actually
lagged in many ways...[and] industry best practice has gone well in advance of
the regulation. Not only have we been consulting to CASA on the development of
the new standard but we have set out to ensure that the standard that we
achieve across our three airlines—Virgin Blue, V Australia and Pacific Blue—is
at a standard that we would accept as being best practice.[39]
2.48
Mr Anthony Petteford, Oxford Aviation Academy, expressed the view that
cockpit authority gradients were "very much a thing of the past" in
modern airline operations.[40]
Mr Petteford's views do not necessarily appear to be supported by a number of
experienced Australian airline pilots.
2.49
The committee notes evidence from CASA advising that proposed new
regulation CASR Part 121 will place restrictions on the crewing together of
inexperienced pilots.[41]
Multicrew pilot licenses
2.50
AIPA outlined significant concerns in relation to MPLs, notwithstanding
the very limited issue of such licences by CASA. AIPA observed that MPLs had
been issued overseas on the basis of very low flight experience requirements,
and could be issued in Australia on the basis of similarly low requirements:
...if [an MPL holder]...did the bare minimum they would have
about double the hours it takes to get a drivers' licence in New South Wales.
It is 120 hours to get a drivers' licence in New South Wales. It is 240 hours
to get an MPL licence as a pilot, 40 of which can be flying and 10 of which are
as pilot in command—total. So we can see one of those graduates come into an
airline and ultimately be given command of an airliner with no more than 10
hours ever in command of any aeroplanes.[42]
2.51
However, Swinburne University of Technology (SUT) noted:
In Britain the academically supported competency based model
has been the basis for recruitment of new pilot intakes. The first multi-crew
pilot licence (MPL) trainees have recently graduated and are currently
undertaking the final stage of training to take up co-pilot positions with a
British registered airline. The MPL is a low hour competency based pilot
training model.[43]
2.52
AIPA submitted that experiences overseas with MPL pilots suggested that
such pilots were not making the transition from simulator training to real
flight effectively. AIPA was particularly concerned that such pilots could not
take over from the chief pilot in the event that he or she was incapacitated
(discussed above).[44]
Proposals to ameliorate risks of
lower average experience levels
Imposing mandatory minimum
experience levels
2.53
A number of submitters and witnesses supported the proposal to introduce
a minimum experience requirement of 1500 hours for certain pilots. This
proposal is discussed in detail below.
2.54
This issue of experience levels is related to the question of what
proficiency standards are being achieved through the various training pathways
that are intended to qualify graduates immediately for co-piloting roles (and
thus with flight hours experience approaching the theoretical minimum
established by the requirements for licence qualification). This is considered
below in the discussion of cadet schemes and similarly tailored training
courses.
2.55
In its supplementary submission, AIPA noted:
that the extensive risk mitigation strategies that now drive the
supervision and mentoring of cadet pilots in Jetstar, while an excellent model
for other operators is an overt recognition that experience acts as a risk
mitigator and that compensating arrangements are necessary for low experience
pilots.[45]
2.56
Indeed, Qantas Group in its answers to additional questions taken on notice
on 25 February 2011, gives details of the level of supervision (which far
exceeds the level of supervision for non-cadets) and includes acknowledgement
of the need to treat cadets differently from direct entry pilots.
Question 4 (Senator Xenophon):
Qantas' submission observes that, for cadets, the operational
restrictions are tailored and materially different to that of a direct entry
pilot, however the remainder of the paragraph which describes training and
supervision in such a way it is not clear. Specifically:
(a) What is included
in the 1000 hours of training and how much actual flight time is provided?
(b) When does the 18
months of further supervision begin and is there some form of competency
assessment to end it?
Answer (a)
The 1000 hours includes 100 hours of simulator time and 185 hours
flying time provided during ab initio training, including for the A320 Type
Rating. An additional 20 hours of simulator time and 200 hours of flying time
are included in the transition course and line training provided by Jetstar.
Following Clearance to Line, cadets are rostered with experienced captains for
a minimum of 500 hours. In total, this amounts to 1000 hours of training and
close supervisory flying.[46]
Answer (b)
The 18 month period of close supervision commences on the
completion of (a minimum of) 500 hours operating with an experienced captain
following Clearance to Line. During this period, at least three competency
checks will be conducted.[47]
Question 5 (Senator Xenophon):
Qantas' submission observes that, for cadets, the operational
restrictions are tailored and materially different to (sic) that of a direct
entry pilot. Does this not indicate that Jetstar recognises the need for risk
mitigation of the cadets' lack of operational experience in contrast to its
direct entry pilots?
Answer (Qantas):
This is not a recognition of 'risk'. All our cadet pilots are
trained to be fully competent on the aircraft type they operate, in line with
Jetstar's internal standards and CASA regulatory requirements. However, a cadet
scheme must clearly be managed differently from the training process for a
direct entry pilot. The cadet program approach is conservative and allows for
close monitoring in the early stages of its introduction. It provides a broad range
of simulator and actual flying time to ensure that cadets meet internal Jetstar
and regulatory standards.[48]
Ensuring adequate experience levels
of flight crews – operator policies
2.57
Virgin advised the committee that, while it did not employ cadet pilots,[49]
it had in place a policy relating to the relative experience levels of captains
and co-pilots on its services—a so-called 'green-on-green' policy, which was
intended to ensure that inexperienced pilots were not placed together to
operate as flight crew.[50]
2.58
In answer to a question on notice Virgin advised that the policy was
comprised of the following elements:
1. A flight crew member is deemed to be 'inexperienced'
following completion of a type rating or command course (and the associated
line flying under supervision), until achieving the following additional
experience on the type in their respective flight crew station"
-
100 flying hours and flown 10 sectors, within a consolidation
period of 120 consecutive days; or
-
150 flying hours and flown 20 sectors (with no time limit).
2. At the roster construction stage, the Aircrew Rostering
Officer shall not roster flight crew together unless one or both crew members
have achieved the minimum experience requirements listed above.
3. Once the flight crew rosters have been issued, and control
of day-to-day rostering is passed to the Crew Controller, the following policy
applies:
-
Where a published roster has to be varied for any reason the Crew
Controller shall ensure that, as far as possible, one or both flight crew
members meet the minimum experience requirement listed above; and
-
If the first officer does not meet the minimum experience
requirement then the captain must have a minimum of 300 hours and 100 sectors
total experience on that aircraft type.[51]
2.59
Virgin's approach was cited with approval by the Australian Federation
of Air Pilots (AFAP), which submitted:
Our experience with the generically titled 'Low Cost Carrier'
models in Australia supports the need to mix and match the levels of experience
as an operation grows. Virgin Blue’s entry into the industry is an example of
successfully mixing experienced Captains with less experienced First Officers.
In this case, the experienced Captains provided a solid mentoring and training
base for the airline to grow and develop and for those less experienced first
officers to attain command early in their Virgin career.[52]
2.60
Qantas and Jetstar advised that, following clearance to line, cadets
'are rostered with experienced captains for a minimum of 500 hours' and then
subjected to an 18-month period of 'close supervision'.[53]
2.61
A number of submitters and witnesses also indicated that they had in
place policies relating to supervision and the imposition of operational
restrictions on low-experience pilots. These are discussed below under term of
reference (c), which relates to current industry practices to recruit and train
pilots.
2.62
AIPA submitted that CASA should be required to develop and publish:
...a specific policy on the risk mitigation strategies for the
employment of low experience pilots to both address the increased risk and to
provide a standardised approach for all operators...[54]
Increasing multi-crew operations
training
2.63
Mr Petteford urged the committee to consider a recommendation that all
prospective RPT pilots be required to 'complete a two-to three-week course in
multi-crew operations and crew resource management using both the turbine
simulator and a classroom environment, before they embark on their initial type
endorsement training'[55].
Mr Petteford explained that such a course would:
...provide pilots with highly relevant skills for our RPT
operations...[and enable] the pilots to gain far more relevance and value from
the type endorsement course itself. These skills will then form the core
foundation in which new airline pilots will both build and grow their
teamworking skills, which are absolutely essential in stressful emergency
situations during which human beings have a tendency to revert to the law of
primacy, which is a critical factor in RPT operations.[56]
2.64
Mr Petteford stressed that improving the ability of crews to communicate
and adhere to standard operating procedures (SOPs) in highly automated
environments would address the main causes of airline accidents, and would
therefore improve flight safety within RPT operations 'overnight'.[57]
2.65
In relation to crew resource management, SUT explained:
Crew Resource Management is specifically focussed on the
ability to lead or follow, and aims to develop abilities to communicate with
associates, apply critical thinking skills and generally perform as a
professional aviator.[58]
2.66
In answer to a question on notice, CASA advised that under proposed new
regulation CASR Part 61:
...the new regulations for flight crew licenses, flying
training organisations and training and checking organisations will introduce a
multi-crew cooperation course which is modelled on the European MCC course. An
MCC qualification will be required for all pilots flying multi-pilot aircraft.[59]
2.67
Mr Peter Boyd, an Executive Manager with CASA, noted that human factors
training, which could address, for example, issues around cockpit authority
gradients, was currently being implemented more broadly across the aviation
industry. He explained:
[Human factors training]...is being mandated more widely at the
moment within CASA, and not just for [CASR Part 61]. We have amended our
current system and our current civil aviation orders to require human factors
training across regular public transport operators. So that will include the
next generation, if you like, of that type of training. In terms of time frame,
the operators must submit their training plans to us by next week and they must
have implemented those types of human factors training by June [2011].[60]
The United States of America's Federal Aviation Administration Extension
Act of 2010 which requires a minimum of 1500 flight hours before a pilot is
able to operate on regular public transport services and whether a similar
mandatory requirement should be applied in Australia
2.68
Term of reference (b) required the committee to consider the United
States of America's Federal Aviation Administration Extension Act 2010 [sic]
(the US Act),[61]
and in particular the requirement for 'a minimum of 1500 flight hours before a
pilot is able to operate on [RPT]...services and whether a similar mandatory
requirement should be applied in Australia'. A number of submissions addressed
this proposal in general terms, however, the US Act itself was not the subject
of detailed submissions.
2.69
Given the existing requirement that pilots (captains) of RPT must hold
an ATPL, and that a condition of qualification for such a licence is a minimum
of 1500 hours flight time, the committee understood the proposal to be to impose
a minimum requirement of 1500 hours as applying only to co-pilots (first
officers).
2.70
As outlined above, the minimum requirement to act as a co-pilot on a RPT
flight is the holding of a CPL, based on a minimum 150 hours (for those
undertaking a commercial flight course) or 200 hours (for those coming through
the general aviation pathway).[62]
A MPL holder could act as co-pilot on the basis of 240 hours' experience, of
which only 40 hours must be actual, as opposed to simulator, flight time.
Should Australia adopt a mandatory requirement of 1500 hours?
Opposition to proposal for a
mandatory minimum 1500 hours' experience
2.71
Many submitters and witnesses did not support the proposal that
Australia adopt a mandatory requirement of 1500 hours' flight experience for
co-pilots operating RPT flights.
2.72
AFAP, for example, supported the maintenance of current arrangements,
subject to appropriate oversight and management of less experienced pilots:
...[AFAP] does not support the reduction (or increase) of
mandatory flight time requirements. Our experience, such as at Virgin Blue, is
that less experienced pilots can and should be incorporated into airlines,
providing there is a solid existing experience base and sound internal check
and training systems in place.[63]
2.73
AFAP also noted that 'many individual operators overlay these minima
with higher internal minimum experience levels. These are often adjusted in
response to market demands and other factors'.[64]
Experience not an effective
indicator of proficiency
2.74
A common objection to the proposal for a 1500 hour minimum was that a
bare requirement for minimum flight hours' experience would not necessarily
equate to an adequate or certain level of pilot competency. CASA, for example,
submitted that 'completing an arbitrary number of flight hours alone may not
necessarily ensure competency to perform a task safely'.[65]
The CASA submission stated:
Experience-based flying training is based on the accumulation
of a prescribed number of hours for training activities, at the completion of
which a flight test is undertaken. Assessment of performance in this context
may be less objective with results being less consistent than the
criterion-referenced assessment required by competency based training.[66]
2.75
Similarly, SUT commented that 'quantity of training is no substitute for
quality'.[67]
2.76
The Regional Aviation Association of Australia (RAAA) submitted that
flight hours are not a useful determinant of a pilot's skill or likely levels
of safety,[68]
and noted that in many cases:
...junior pilots who join...[regional airlines as first officers
(co-pilots)] with less than 1500 hours often excel when compared to pilots with
higher initial total time but...less airline exposure.[69]
2.77
Virgin also noted that pilot experience was not universal in terms of
its relevance to RPT services:
It is also relevant to consider the circumstances in which
pilot experience is gained, ie aircraft type (light, commercial, military) and
single pilot versus multi-crew as these cannot be considered equivalent for the
purposes of assessing capability to operate RPT services safely.[70]
2.78
AIPA concurred with this analysis, noting that, while experience
requirements had historically acted as a 'filter' for young pilots developing
skills and experience in general aviation, a substantial number of flying hours
based on a narrow set of flying conditions and experiences would not necessarily
deliver a well-rounded learning experience. Captain Richard Woodward, a Vice
President of AIPA, observed:
There is a common statement that one hour [of experience]
repeated 2000 times is not much of a learning experience.[71]
2.79
Mr Petteford noted:
...not all general aviation experience is relevant to RPT
operations and in some instances it can generate unsafe attitudes and practices
which are not conducive to the operation of RPT aeroplanes.[72]
2.80
These comments were supported by anecdotal evidence suggesting that pilot
standards emerging from the general aviation route are variable, and that a
high number of flight hours' experience does not therefore necessarily equate
to proficiency for RPT purposes. Regional Express, for example, advised that it
had previously encountered varying standards of pilot competency when
recruiting on the basis of a relatively high minimum experience requirement. Mr
Chris Hine, Flight Operations General Manager, explained:
We used...[2000 hours minimum flight experience] as our paper
benchmark [for recruitment]. [However, we] got to the point where we were so
concerned from a duty-of-care point of view about some of the things that we
were finding in the interviews that we...met with our local CASA office and said,
'We wish to at least advise you that these are the standards we've seen.' It
raised for us the fact that these were pilots who had what would be considered
considerable experience levels, yet they did not have the standards that we
felt were required.[73]
Unintended consequences for regional
airlines
2.81
A number of airlines contended that a mandatory requirement of 1500
hours' flight experience for pilots would have unintended adverse consequences,
particularly in relation to the ability of regional airlines to recruit and
retain pilots.
2.82
Captain Tim Berry, Director of Flight Operations, Tiger Airways, noted
that, if a requirement for 1500 hours' experience were adopted in Australia,
'budding' pilots would have no choice but to seek training overseas as there
are not sufficient opportunities for a pilot to gain 1500 hours' experience in
the non-commercial aviation sector in Australia.[74]
2.83
Mr Petteford supported the view that the general aviation industry in
Australia would not provide sufficient opportunities for pilots to attain the
1500-hour minimum.[75]
2.84
The RAAA noted that, unless any such requirement was 'grandfathered' for
all existing RPT pilots, a number of pilots would be forced out into the
general market for aviation pilots to achieve the mandatory minimum.[76]
2.85
The RAAA also pointed to problems retaining experienced pilots for
regional airlines if the mandatory minimum were introduced. The RAAA submission
explained:
One of...[the] biggest challenges for regional airlines is
holding onto their pilots. As they become more experienced they become more
attractive to the major, jet airlines – which can pay higher salaries and offer
larger aircraft for pilots to fly...If regional airlines cannot hire pilots for
RPT until they have 1500 hours, then it will be very difficult to secure them
for any reasonable time before they move to the larger airlines, making it even
more difficult than now to recover the very high costs of induction, check and
training, etc that is a necessary part of getting a pilot into an RPT
operation.[77]
2.86
Similarly, Regional Express warned of 'catastrophic implications' for
regional airlines, as a 1500 hour mandatory minimum would lead to the cessation
of pilot cadet schemes, which would become uneconomic if cadets were required
to attain 1500 hours within such a scheme. This, in turn, would lead to
'increased recruitment of experienced regional pilots by the larger airlines',
and 'serious safety implications for the smaller operators as they lose large
numbers of experienced pilots'.[78]
Regional Express noted as a relevant example its experience during a pilot
shortage in 2007-08, in which the company lost 50 per cent of its pilots to
recruiting by the larger airlines.[79]
2.87
This view was supported by the evidence of Virgin, which predicted an almost
immediate effect on regional airlines:
Regional airline pilots tend to have accumulated relatively
less experience at commencement, because the type of aircraft generally
operated by those carriers enables a natural progression from general aviation.
More experienced regional pilots in turn supply a significant proportion of the
technical crew for the major Australian airlines.[80]
2.88
Virgin observed that the adverse effects of a mandatory minimum
experience requirement would ultimately also impact on the ability of major
Australian airlines to recruit experienced pilots:
It could...be expected that over time – and particularly in
times of strong growth such as those experienced by the highly cyclical aviation
industry in 2007 and 2008 – such a requirement could have a measurable impact
on airlines such as Virgin Blue, with regional airlines anticipated to be
subjected to severe labour shortages.[81]
2.89
In response to the concerns outlined above, AIPA acknowledged that a
mandatory minimum as proposed could adversely impact on the 'smaller elements
of commercial aviation'. However, AIPA contended that such 'market distortions'
could be taken into account in the legislative scheme that imposed the
requirement.[82]
2.90
Specifically, AIPA proposed that any such requirement could be limited
to 'pilots of jet public transport aircraft'.[83]
Context of the US Act does not
translate to the Australian aviation industry
2.91
Lastly, the committee heard that Australian conditions are significantly
different to those which drove the introduction of the 1500 hour requirement in
the US. CASA identified a number of differences between Australia and the US in
relation to pilot qualification:
For domestic flights conducted within the United States,
co-pilots are not required to hold a type endorsement for the aircraft being
operated and receive only the training the operator deems necessary to perform
the co-pilot duties. For international operations, the co-pilot must be fully
qualified, and must hold an aircraft endorsement, as this is an ICAO
requirement.[84]
2.92
Further, CASA noted that 'there is a significant difference between the
approach taken to basic flying in Australia'. It explained that, in the US, 'basic
training can be conducted by flight instructors working independently of a flying
school with very limited regulatory oversight'.[85]
Where such training is conducted by an approved training organisation, a
reduction in the minimum number of flying hours is granted.[86]
In contrast, in Australia, 'all flying training for CASA issued licences must
be conducted by the holder of an Air Operator's Certificate which authorises
flying training'.[87]
2.93
Other points of distinction raised by CASA were:
-
that 'a large portion' of training in the US is not based around
competency based principles; and
-
that aspects of the US training and checking requirements are
'less rigorous' than the systems in place in Australia.[88]
2.94
Qantas and Jetstar observed that the US Act allows for the recognition
of 'non-flying training', and expressed a preference for 'academic training
courses [that] will enhance safety more than requiring the pilot to fully
comply with the flight hours requirement' (that is, competency based flying
training).[89]
While there was no evidence of how this process would work in practice, the
committee notes that a similar provision in the Australian context, where competency
based training is the norm, could impact on the operation of a mandatory
minimum.
2.95
Given the factors identified above, CASA concluded that 'it is unclear...what,
if any, safety issues would be addressed in Australia by increasing minimum
hour requirements for co-pilots to an arbitrary 1500 hours'.[90]
CASA did not support 'the requirement for co-pilots to hold an ATPL (with a minimum
experience requirement of 1500 hours).[91]
Support for proposal for a
mandatory minimum 1500 hours' experience
2.96
In contrast to views opposing the introduction of a 1500 hour minimum, a
number of submitters and witnesses supported the proposal.
2.97
AIPA contended that actual flight experience is qualitatively superior
to theoretical or simulated approaches to pilot training:
...practical and appropriate piloting experience is a
significant risk mitigator that cannot be replaced by theory or simulator
training, only supplemented.[92]
2.98
AIPA also acknowledged that minimum experience requirements are but one
factor in the production of competent pilots:
...hours alone is not a determinant...[of pilot competency].
There is obviously a minimum number of hours where you have enough experience
to be self-reliant...but the other thing you need is competent training and
certainly a mentoring program for the pilots.[93]
2.99
However, AIPA felt that the minimum flight hours' requirement must
reflect 'a balance between skills, knowledge and behaviours versus the
operational risk',[94]
arguing that 'pathways to gaining operational experience should be focused on
situations that reduce the exposure of the travelling public to the risk of an
error caused by inexperience'.[95]
Accordingly, AIPA's view was that:
...subject to appropriate supervision and mentoring, low
experience pilots should enter the system through operations that employ
non-jet aircraft with 50 or fewer seats. Proposals to employ low experience
pilots on jet aircraft and larger non-jet aircraft should be possible, but only
after rigorous controls are established and monitored.[96]
2.100
AIPA therefore supported the 1500 hour minimum for all pilots of jet
public transport aircraft through the requirement to hold an ATPL and, 'until
such time as the existing legislation is modified, that a minimum hours
experience requirement be established for high capacity RPT aircraft captains
and co-pilots'.[97]
2.101
While AIPA acknowledged an emerging international consensus that
750 hours 'may be an appropriate minimum', the ICAO requirement of 1500
hours' experience for an ATPL, which is binding on Australia, meant that this
was the only mandatory limit that was practically achievable currently.[98]
2.102
Captain Klouth supported the proposal for a 1500 hour minimum, arguing
that:
A person with 1500 flight hours will be more capable than a
person with 200 flight hours. They will have been exposed to a full change of
season and know how to cope with weather changes and generally have more
knowledge about the environment they work in. To obtain an ATPL a person
requires 1500 flight hours so that should be the minimum standard before they
are permitted to operate on RPT services.[99]
2.103
Captain Klouth also pointed to certain factors, discussed above, as
justifying a requirement of 1500 hours for both pilots, namely the need for a
co-pilot to be able to support or possibly take over from the captain in an
emergency, and the dynamics of a steep cockpit authority gradient.[100]
Current industry practices to recruit pilots, including pay-for-training
schemes and the impact such schemes may have on safety
2.104
A number of submissions commented on current industry practices relating
to pilot recruitment, and the impact such practices might have on safety.
2.105
The committee received a considerable amount of evidence commenting on
this issue, particularly pilot cadet schemes. In keeping with the focus of the
terms of reference, the committee was interested to explore whether aspects of
such arrangements have any adverse impacts on the quality of pilots and airline
safety more generally.
2.106
In general terms, the main pilot recruitment/training options are:
-
direct entry: where a pilot has pre-existing qualifications and
can be employed directly—although they will typically require training in the
SOPs of the employing airline; and may require training in the piloting of a
particular aircraft (type endorsement); and
-
cadet programs: courses for aspiring pilots that are tailored to
producing pilots for RPT operations. Generally these are pilots who would not
otherwise meet the airline's minimum experience requirements. These may be run
in-house or through third-party providers. Various fee arrangements may apply:
cadets may be required to pay their own fees (pay-for training schemes), or an
airline may pay fees on a loan or bond basis.
Cadet schemes
2.107
The CASA submission explained that:
...a cadet pilot scheme...sees recruits trained ab initio
to CPL standards, with ATPL theory examination passes, following which these
pilots are employed in co-pilot or second officer positions...[101]
2.108
CASA noted that cadet programs have been 'in existence for many years
[in Australia], as well as overseas'.[102]
2.109
Tiger Airways also noted that cadet pilot programs have been 'well and
truly established' overseas since the 1980s, and are now 'generally the
preferred method of recruitment into an aviation career [in Europe]'.[103]
Captain Berry stated:
In Europe, for years and years they have had pilot cadet
schemes. I personally was involved with the KLM pilot cadet scheme...Lufthansa,
Air France, British Airways and further afield, Emirates, Cathay and Singapore
Airlines all have pilot cadet schemes, take pilots off the street and train
them up to the standard they want and put them in their aircraft. And they have
all been highly successful.[104]
2.110
Captain Berry noted that Tiger Airways did not currently employ any
cadet pilots. However, he believed that Tiger Airways 'should be looking to
cadet pilot schemes [in future]',[105]and
that the airline supported cadet schemes as being one of a range of routes that
should be available to potential pilots to become qualified.[106]
Increasing use of cadet training
schemes
2.111
A number of submitters and witnesses observed that Australian airlines
are increasingly using cadet training schemes to recruit pilots. The Qantas and
Jetstar submission observed that Australian carriers:
...have introduced a range of programs to train new pilots for
the industry. Although the nature of these programs varies in the way the
training is delivered, all are subject to approval by CASA.[107]
2.112
Mr Jim Davis, Managing Director of Operations, Regional Express, advised
that a number of airlines were 'progressing towards training their own pilots',
and that there was a trend for either airlines or 'large professional training
organisations' to perform most pilot training.
[108]
Mr Davis advised that Regional Express ran its own in-house cadet training
scheme.[109]
2.113
Virgin advised that it would be implementing a cadet scheme, and was in
the initial stages of planning for the scheme.[110]
2.114
A range of factors were identified as driving the move toward cadet
schemes. Qantas and Jetstar submitted that traditional routes through general
aviation and the military were not sufficient to meet current and projected
demand:
The demand for pilots in Australia and overseas is strong.
The traditional pilot recruitment processes, such as sourcing pilots from
General Aviation and the military, have proven to be insufficient to meet the
needs of the Australian aviation industry in recent years...Forecasts from ICAO indicate
that this region will suffer the greatest number of pilot shortages in the next
twenty years.[111]
2.115
This view was supported by Tiger Airways, which submitted that it 'was
recognised in the 1960s and [19]70s that these two routes into aviation would
not provide pilots in the numbers that were required'.[112]
2.116
Captain Klouth, however, questioned the claim that general aviation
could not provide sufficient numbers of pilots, and noted that cadet schemes
were originally intended to supplement traditional sources of pilots:
Australia, as opposed to places like Europe and Asia, has had
a quite significant general aviation industry and...there are still plenty of
general aviation pilots who would love the opportunity to apply for and receive
an interview with a major domestic airline. As for saying there are not enough
pilots out there...[as] other people have mentioned, the cadet pilot system as it
was usually done here was never intended to be the primary source of pilots. It
was intended to supplement the usual stream. To say that there are no pilots
out there is not entirely correct.[113]
2.117
AIPA also disagreed with claims of a shortage of pilots:
AIPA believes that Australia is not currently facing a
shortage of qualified pilots and we further believe that there is an adequate
distribution of operational experience among the pool of prospective pilot
employees available to airlines.
AIPA believes that the approach taken by Jetstar, as a prime
example, has nothing to do with a shortage of suitably qualified and
experienced pilots.[114]
2.118
AIPA expressed the view that, in fact, cadet schemes could be acting as
a disincentive to prospective pilots due to the associated costs.[115]
Mr Bruce Buchanan, the Chief Executive Officer of Jetstar, however, asserted
that cadet schemes offered another route for entry into the pilot profession.
Mr Buchanan stated:
No good training system exists such as that which
universities provide for doctors and lawyers. For a young person trying to
become a pilot, there is a huge cost barrier to get into this field. We are
trying to create mechanisms where people can get into this field, where they
can afford to get into it no matter what their socioeconomic background is and
where they can get to really good salaries very quickly.[116]
2.119
Tiger Airways also identified 'significant advantages' attached to cadet
schemes, provided that they were properly regulated, employed pilot aptitude
testing as a requirement for entry, and were tailored to the needs of
individuals in the program.[117]
The Tiger Airways submission observed that, while military trained pilots were
historically 'sought after' by airlines, there was 'a growing realisation that
the personality traits that suit a pilot to fly a high performance fighter in
battle are not necessarily suited to the role of the airline pilot'. Pilots
undertaking the general aviation route could be of 'mixed quality', due to a
large portion of their experience being gained 'flying alone, uninstructed and
un-mentored'.[118]
2.120
Qantas and Jetstar also pointed to the consistency of training offered
by cadet schemes, as compared to the experience gained through the general
aviation pathway.[119]
2.121
Mr John McCormick, Director of Aviation Safety, CASA, noted that cadet
schemes could offer advantages in terms of providing cadets with a stronger
exposure to an airline's operating procedures and safety culture. He explained:
[Cadet schemes are]...in a lot of ways, very good for someone
who is going to have a career in the airline, because right from the start there
is a certain amount of inculcation of the principles of safety, and there is
perhaps even by osmosis a...carryover of the character of the organisation and
the way it operates. That [is beneficial]...for the ethos...of flight deck
management...of how the crew cooperate, of how the captain and the first officer
cooperate.[120]
2.122
These views were supported by Regional Express. The committee heard that
the Regional Express in-house cadet scheme currently supplies 100 per cent of
its new pilot intake. Mr Davis explained that one of the drivers behind the
scheme was the issue of pilot quality:
...a few years ago we did recruit from general aviation using minimum
experience requirements. We typically required 2,000 or 3,000 hours to get a
pilot into Rex. We were not happy with what we were getting—we saw some
standards there that did not meet our requirements—and we started looking at a
cadet scheme.
2.123
In terms of pilot quality and safety, Mr Davis commented:
I see this as a very positive trend, I see this as an
increase in safety, because we are getting the standard of pilot that we want
out of our own training schemes when we start from day one, ab initio.[121]
2.124
Virgin, however, reported that the quality of pilots sourced through the
general aviation pathway was adequate for its recruitment purposes. Captain
Howell noted that Virgin:
...have not had any trouble recruiting applicants [through
general aviation] that meet our standards. We are quite comfortable that our
selection process is robust and shows a good correlation between recruitment
process and success as an operating pilot.[122]
2.125
An additional driver for Regional Express to establish an in-house cadet
scheme was that this allowed the business to establish a relatively secure pilot
workforce against the historical trend for pilots to move from regional
operations to the larger commercial airlines such as Qantas. The committee
heard that Regional Express had suffered a dramatic loss of pilots during a
recent pilot shortage, and the scheme offered a greater potential for the
airline to retain pilots for a reasonable period.[123]
This was because the Regional Express scheme included financing arrangements
intended to create a financial incentive or bond for pilots to remain with the
company. Mr Davis explained:
...cadets enter into a financing arrangement with the company, [whereby
Regional Express]...actually supply three-quarters of the cost of training [which
is approximately $88,000]. They supply one-quarter up front. After six years,
we will forgive a quarter of the cost of training, so the cadet then only has
to pay three-quarters of the total cost of training, but half of that total
cost is a HECS type scheme. They pay it back to us at low interest. So the
incentive to stay with Rex is because, as soon as they leave us, at whatever
stage of the repayment schedule they are at, they have to pay us what they owe.[124]
2.126
AIPA identified the introduction of the low-cost carrier (LCC) model to
Australia as a significant reason for the increased use of cadet schemes:
...cost pressures brought about by the Low Cost Carrier (LCC) model
have resulted in airlines offering terms and conditions that are unattractive
to experienced pilots. The likelihood of increased pilot turnover from pilots
seeking more equitable terms, combined with the need to generate financial
ratios acceptable to their owners, has resulted in airlines seeking ways to
circumvent the traditional approach to hiring pilots with experience in
commercial operations.[125]
2.127
According to AIPA, a key feature of the LCC training model is to offer
'increasingly poor terms and conditions'. AIPA submitted that such approaches
were:
...cost-driven models consistent with an oversupply of pilots.
AIPA asserts that those models are entirely out of step with the now ubiquitous
forecasts of a worldwide shortage of pilots that airlines and their
representative organisations are currently scrambling to address in other ways.[126]
2.128
AFAP, although it supported a 'variety of pathways to an airline
career', was concerned about:
...growing over-reliance on the 'pay-for-training' or cadetship
model. These programs have an intrinsic commercial incentive for the parties to
get through the training by the quickest allowable means. This risk needs to be
managed and closely monitored. It also has the potential to undermine internal
training systems and traditional career paths to an airline career.[127]
2.129
Captain Klouth noted that certain business models employing cadet
schemes exhibited significant financial incentives for airlines:
There are some in the aviation industry who consider that
this form of experience is not relevant to a modern airline and the best and
safest way forward is to get young men and women, train them to the minimum
hours allowed, load them up with significant debt and then pay them at a third
of the cost of experienced first officers. I am yet to see any evidence that
the cadet system, as it is currently being run, is anything other than a
cost-benefit to the airline.[128]
2.130
Similarly, AIPA submitted that:
...cadet schemes such as those engineered by Jetstar appear to
be motivated by converting a cost centre into a revenue centre as well as
transmitting business to offshore entities.[129]
AIPA is firmly of the view that the recent exposure of the
so-called 'Jetstar Cadet Scheme' has shown it to be nothing other than a scheme
to avoid Australian employment and tax rules and to shift work offshore as a
means to reduce labour costs. The evidence on cadet schemes shows some schemes
are usurious and a long way from the philanthropy that some...claim.[130]
Adequacy of cadet scheme based
pilot training
2.131
CASA submitted:
...[Provided] there is an appropriate ongoing training and
development system in place, there is no evidence to suggest that [the cadet
training type] approach has resulted in any diminution of safety standards.[131]
2.132
CASA pointed to the balance of elements in Australia's approach to
initial pilot training, noting that this 'combines a rigorous competency based
flying training program with the specification of a required minimum number of
flying hours'. Such an approach:
...recognises the need to ensure competency while at the same
time acknowledging that the exposure gained by flying experience is also an important
factor in developing piloting skills.[132]
2.133
Similarly, SUT commented:
The integration of targeted high level educational and
practical training programs with advanced technology aircraft and associated
training aids delivers a graduate equipped with both the technical and non technical
skills required for a flight crew member.[133]
2.134
Mr Buchanan commented:
...the combination of training elements has proved the most
effective way to get pilots trained to deal with the issues that they are going
to deal with. So a combination of a lot of practical time, getting them ready
for multicrew jet operations, and then simulator time where they are practising
different scenarios and events, and flying time, has been proven the best by
studies around the world to prepare pilots to fly a modern jet aircraft.[134]
2.135
Mr Anthony Petteford, OAA, commented:
...it has been quite clearly proven over the years that quality
cadet programs, whilst requiring significantly fewer hours of flying experience
than the GA pilot route, do enhance RPT operational safety as opposed to
reducing it...[135]
2.136
The Regional Express submission provided an empirical analysis of the
performance of cadet pilots and 'traditional' pilots. Appearing before the
committee, Mr Hine explained the findings of this analysis as follows:
[Regional Express has a system which] digitises all of our
check reports. Every pilot that does a check is scored on a range of variables
from 1 to 5, 1 being unsatisfactory and 5 being the highest standard. For the
last five years all of the data from every single check report that is
completed has gone into an electronic database. We are able to query that
database and ask it to give us the average scores of cadets versus what we will
call 'traditional' first officers. We found that the scores were almost
identical. In the first year there was a less than three per cent variation
across the board, and certainly into the second year we found that the data
showed that the cadet pilots started to outperform the traditional, more
experienced pilots.[136]
2.137
In discussing the very low failure rate for cadets (at around five per
cent), Regional Express representatives noted that the selection processes for
entry into its cadet scheme ensured that candidates possessed a high aptitude
for pilot training. Mr Davis explained:
When we started the cadet scheme we did change our
recruitment methods. We became far more selective. We introduced a different
simulator test, we introduced the pilot aptitude test, we introduced an
academic test and we also introduced several ranges of interviews. They do two
or three interviews.[137]
2.138
Qantas and Jetstar also reported that its cadet graduates attained
equivalent levels of skill and competency to direct entry pilots:
Irrespective of the originating recruitment program all
QantasLink pilots must undergo the same airline training path and demonstrate
the same high level of flying skills in a range of competency assessment
milestones prior to unrestricted line operations. This is evident in the
performance of pilots completing each program, as over 94 percent of total checks
of pilots in the Trainee/Cadet program record satisfactory results, which is
almost equal to the results of pilots in the Direct Entry program.[138]
2.139
Further, Qantas and Jetstar noted that the cadet pilot scheme employed
selection processes designed to identify candidates with the appropriate skills
and aptitude for piloting modern aircraft:
It is important to note that Cadet Pilot Training processes
provide three distinct opportunities to vet candidates; initial entry screening
processes, meeting the requirements of the competency based training program
and then via additional screening prior to a pilot being checked to line.[139]
2.140
Qantas and Jetstar also noted that:
Following the completion of the training and oversight
process for a new cadet pilot the operational restrictions are tailored and
materially different to that of a direct entry pilot.[140]
2.141
For example, in relation to Jetstar pilots:
Operational restrictions have been developed to quarantine a
cadet pilot to only operate with approved Captains for the first six months of
line operations. In addition, extra check points (simulator checks/line checks)
and training details have been developed by Jetstar to increase the training
and oversight of the cadet during his/her initial period of operations.
Restrictions on the cadets during their initial phases also include a lower cross
wind limit for landings and operating restrictions on narrow and short runways.[141]
2.142
AIPA submitted that the use of flight simulators, which was prevalent in
cadet style training schemes, did not adequately prepare pilots for real life
flying:
...the use of flight simulators and other synthetic flight
training devices cannot adequately replicate the physical environment of real
aircraft responses to the vagaries of actual weather phenomena and busy air
traffic services that are critical to ab initio pilots developing sound
situational awareness, aircraft handling skills and coping behaviours under stress.[142]
2.143
AIPA submitted that there was an increasing risk of airline safety
incidents or accidents in Australia, which could be seen as part of an
'increasing trend for accidents worldwide', largely due to 'poor training,
automation reliance by pilots and poor manual flying skills'.[143]
Captain Woodward explained:
We see similar elements developing in Australia. We are not
necessarily predicting an accident tomorrow, but we see there is a potential in
the industry to go down the same route that they have seen in Europe and in the
United States—decreasing experience levels and dumbing down of training.[144]
2.144
AIPA was particularly concerned about the use of cadet schemes in the
context of LCCs. It noted that:
Few, if any, LCCs invest in any training infrastructure and
generally favour third party training providers. The cost of training is moved
off the balance sheet, the profit and loss account is improved and the pilots
now carry a financial burden that acts as a disincentive to start again with
another operator.[145]
2.145
AIPA was particularly concerned that LCCs:
...typically deny any linkage between experience and
operational risk and make little or no effort to establish supervisory and
mentoring schemes to manage that risk.[146]
2.146
In contrast to AIPA's concerns over LCC cadet scheme models, the
association identified the Regional Express cadet scheme as a successful model.
In relation to this scheme, Captain Woodward commented:
I heartily endorse the Rex cadet scheme system, providing
there is proper mentoring and training. They are bonding those pilots for six
years. We talked to the Rex people and went and looked at their facilities.
They said that if they could get six or seven years out of a pilot they accept
that they will move on. So they have come to grips with the constant loss to
the bigger side of the industry.[147]
2.147
The AIPA submission stated:
AIPA supports the Rex approach in which the company created
its own training school, guaranteed employment for the graduates and provided
significant financial incentives for the trainees to achieve high standards.[148]
2.148
AIPA called for the Commonwealth Government to set standards relating to
the operation of cadet schemes.[149]
Consistency with competency based
approaches to training
2.149
Many submitters and witnesses highlighted the fact that cadet schemes in
Australia are designed around a competency based approach to training, which
was said to be recognised as the best practice approach.
2.150
Qantas and Jetstar, for example, contrasted the competency based
approach with one that focuses solely on pilot hours:
There is considerable international evidence and practice to
suggest that competency based training as an approach delivers better safety
outcomes than focusing on quantitative training measures.[150]
2.151
The Qantas and Jetstar submission noted that the trend towards
competency based training, as opposed to 'purely experiential training', was
'consistent with broader educational training trends and supported by a number
of studies comparing training approaches'.[151]
2.152
In particular, Qantas and Jetstar pointed to a review of pilot training
practices conducted by the ICAO in 2003, which was undertaken in recognition of
changes in the nature of aircraft and piloting demands post Second World War.[152]
The review had led to a greater emphasis on competency based training and the
development of the MPL.[153]
Such developments demonstrated that:
...international regulatory bodies such as ICAO and
representative industry bodies such as IATA agree that the safety of commercial
airline operations are best ensured through a well designed and managed
competency based approach to pilot training.[154]
2.153
Mr Alan Joyce, Qantas Chief Executive Officer, noted, however, that the
company continued to value experience. He stated:
I want to emphasise that moving towards competency based
training does not mean devaluing the merits of experience, or at least the
right kind of experience. On the contrary, we are very proud of our senior
experienced pilots. We value the wisdom that comes with that experience. We
think young pilots, however well trained, can always benefit from the
observation of more experienced pilots and the mentoring that they provide,[155]
2.154
Similarly, SUT commented:
The International Air Transport Association (IATA) is
currently working with the International Civil Aviation Organisation (ICAO) to
'modernise and revolutionise training and qualification schemes, focussing on
competency based training'.
Worldwide there is increasing support by authorities and
airlines for high quality competency based training models and the increasing
enhancement of these programs with educational delivery.[156]
2.155
On this issue, CASA noted that the competency based approach for
training pilots had been in place in Australia for 'almost two decades', and
that such an approach 'is the basis for all Vocational Education and Training
conducted in Australia, under the auspices of the Australian Quality Training
Framework'.[157]
2.156
CASA identified a number of proposed improvements to training regulation
through proposed CASR Parts 141 and 142, and CASR Part 61, which would apply to
flight training operators and flight crew licensing respectively. In relation
to CASR Part 61:
The proposed regulations recognise that both aircraft
captains and co-pilots should receive equivalent training and demonstrate the
same essential levels of proficiency to achieve safety of flight operations.
Consequently, the introduction of CASR Part 61 will [inter alia] introduce the
requirement for co-pilots to also hold command instrument ratings and command
aircraft endorsements (type ratings) and to be assessed against the same
standards applicable to aircraft captains.[158]
2.157
In addition to proposed new regulations, CASA advised that it had
implemented a number of safety initiatives relating to the flying training
sector since 2004, culminating in the establishment of a flight training and
testing office in 2008. This measure had been 'highly successful in driving
improvements in the standard of graduating instructors'.[159]
2.158
CASA also drew the committee's attention to its establishment of a
Flying Standards Branch (FSB) within the flight training and testing office,
which is:
...responsible for practically assessing pilot proficiency
standards, oversighting pilots that have been appointed as Approved Testing
Officers...and assisting the flying training sector.[160]
2.159
The FSB had initiated or was developing a number of programs, including
regular testing of approved testing organisations (ATOs), publication of an ATO
manual, conduct of industry flight tests and conduct of a formal training and
assessment course for ATO applicants.[161]
2.160
Finally, CASA noted that there were two 'key mechanisms to allow CASA
and industry to work together to review pilot training standards'. Mr McCormick
explained:
There is the flying training panel, which CASA formed to
provide strategic advice on flying training matters. This panel is chaired by
industry and meets quarterly. There is also the flight crew licensing
subcommittee of the standards consultative committee, CASA's industry chaired
committee, which brings together CASA staff and representatives from a diverse
range of aviation industry groups to work jointly during the development phase
of regulatory material.[162]
Third party providers of cadet
training
2.161
As noted above, cadet schemes may be run in-house by an airline, such as
the Regional Express approach, or by a third party provider, such as the Oxford
Aviation Academy (OAA). Tiger Airways observed that there had been a trend away
from airlines running their own cadet schemes, with such training being
outsourced to third-party training providers. The Tiger Airways submission
commented:
Typically the programme will be built around 250 flying
hours. The academic requirements and flight tests will all be conducted to
Captain standard although the licence issued is 'frozen' at the First Officer
level until the pilot has achieved minimum on the job experience requirements
(typically 1500 hours).[163]
2.162
The committee received submissions and evidence from, and in relation
to, a number of institutions that act as third-party providers of cadet
training schemes and/or flying and non-flying aviation programs.
2.163
In relation to OAA, Qantas and Jetstar noted:
Oxford Aviation Academy has trained approximately 24,000
airline pilots for 80 airlines including a wide range of full service, low cost
and charter carriers such as British Airways, BMI, Air France, Ryanair, EasyJet
and Gulf Air. Oxford Air Training School (the pre-cursor to Oxford Aviation
Academy) was established in 1964 when they provided their first courses to...[the
airlines that went on to become] British Airways.[164]
2.164
A submission from OAA advised that the company had been a 'fully-fledged
airline flying school since 1960', and focused on a 'core business' of
'teaching pilots how to fly (ab initio and type specific), as well as
cabin crew and maintenance staff'.[165]
2.165
The committee also received a submission from SUT, which described
itself as:
...one of the predominant providers of Aviation tertiary
programs and pilot training in Australia with over 470 Aviation students
currently enrolled in programs from VET, undergraduate degree, and postgraduate
coursework programs.[166]
2.166
Professor John Beynon, Dean of the Faculty of Engineering Services and
Industrial Sciences, SUT, advised that, in addition, the university's program
aimed to support a broad range of graduate outcomes:
Although in cooperation with Oxford Aviation Academy we are
delivering the Jetstar cadet pilot program and in the recent past the Qantas
cadet pilot program as part of an associate degree, most of our pilot training
programs are not focused on a particular airline. This enables our graduates to
choose rather than to go into either general aviation or commercial airlines
or, indeed, into management careers in airline or airport operations. The
academic content, while tailored for a career in aviation, also serves our graduates
well for a wider range of careers in the tradition of undergraduate education.[167]
2.167
SUT cited an empirical study which supported a conclusion that:
...the best performing pilots had graduated from collegiate
accredited flight programs with aviation degrees and had received advanced
(post-Private) pilot training in college.[168]
2.168
However, SUT suggested that standardisation of third-party aviation
training providers could be considered:
In Australia there are a number of university aviation
providers whose programs have been developed through their self accrediting
status. Benefit in standardisation could be gained through accreditation of
these programs through an appropriate professional body such as occurs through
the Aviation Accreditation Board International in the United States.[169]
2.169
Professor Beynon also noted that the institution would welcome a
recommendation from the committee that the 'progression of trained pilots in
the industry be tracked', and noted that the university was 'preparing a
research proposal to monitor the performance of recently trained pilots from a
selection of pathways to enable a quantifiable comparison to be made'.[170]
2.170
The committee heard that some submitters and witnesses were concerned
about the quality of training provided by third-party training providers, and
particularly the potential for such arrangements to lead to confusion or
inadequate knowledge regarding SOPs. Captain Klouth, for example, submitted:
Having experienced in-house training and pay for training,
the in-house training prepares one better for line training and gives a better
foundation of knowledge of the aircraft. I did my A320 rating with Alteon which
is a Boeing owned company. I was not provided with cockpit diagrams on which to
practise procedures (colloquially referred to as paper tigers), provided with
any systems manuals (other than those that were purchased from Jetstar),with
which to revise the computer based training and had simulator instructors who
had never actually flown the aircraft. The instructors were not familiar with
the airline operating procedures and would actually speak disparagingly about
the airline that I was to be employed by.[171]
2.171
While Captain Klouth could point to an exception regarding the generally
poor quality of third-party training, he concluded that such training:
...provides little more than an endorsement approved by CASA.
It does not provide value for money and does not prepare a new pilot adequately
for line training.[172]
2.172
Similarly, AIPA was concerned that:
...training schools may not be producing a consistent product
and that low end operators may not be value adding to their employees'
experience. It may be instructive if the [Productivity Commission] PC examined
whether there is really a shortage of suitable candidates for the bigger
airlines and, if there is, the underlying reasons. Similarly, the PC or the
Bureau of Infrastructure, Transport and Regional Economics (BITRE) should
investigate the likely trajectory of Australian domestic airline pilot
employment to inform the debate and future planning for the training industry.[173]
2.173
Mr Stephen Phillips, who appeared in a private capacity, noted that the
commercial nature of third-party training meant it was unlikely that training
organisations would train students to a standard above the regulatory minima
required to achieve a pilot licence, as this would involve increased cost to
those students. While the regulatory minima were 'quite reasonable' to achieve
a 'level of competency', this was 'not necessarily the level of competency that
[was appropriate for a commercial RPT pilot]'.[174]
2.174
Captain Woodward considered that the minimum regulatory standards were
'adequate', but noted that the aim of pilot training should be to exceed these
levels. However, he observed that 'training is always pitched at the minimum
standard, because training costs a lot of money'.[175]
2.175
Captain Dick MacKerras, Technical, Safety and Regulatory Affairs Adviser
for AIPA, commented that the current regulations were not developed with LCC
business models in mind, and it was these types of carriers that tended to
pursue minimum compliance strategies:
...the lower the cost of the carrier the more that minimum
compliance becomes a flaw, because that is their target. The problem is that
the existing legislation never envisaged that. It was written around reasonable
people behaving reasonably.[176]
2.176
Mr Petteford stressed that third-party training must be delivered in
partnership with airlines. He noted that 'if you simply give your type
endorsement training to a third party without having created any bonds then
that is a recipe for disaster'.[177]
2.177
Virgin indicated that it customised third-party endorsement training to
ensure that such training accurately reflected the company's SOPs and flight
operations. Captain Howell explained:
In terms of the endorsement training, it is possible to take
a pilot who has taken a 'plain vanilla' endorsement and provide added training
to get them competent to operate in our area, but it is actually advantageous
for us to modify the simulator training package such that, when they have come
out of the simulator training, they are familiar with how we operate the
aeroplane, where we operate the aeroplane and the slight variations from the
way we might operate the aeroplane to the way that Boeing might for other
customers.[178]
2.178
AFAP commented that, although it had a preference for in-house training,
third-party training providers were a part of the aviation industry landscape
and should be subject to direct regulation by CASA:
Our strong preference is that the endorsement training of
those pilots by the airlines be conducted in-house, and for that in-house
training to be supported by a solid internal experience base and a sound check
and training system. We do, however, recognise the advent, particularly over
the last 10 years, of third-party training providers, but would fully support
those providers being regulated to the same standards as those that apply to
the air operator certificate holders.[179]
2.179
The committee notes that the proposed new regulation CASR Parts 141 and
142, relating to flight training operators and flight crew licensing, propose
that third-party training organisations that provide training either independently
to individuals or in concert with aircraft operators, must be responsible for
the training they provide or take shared responsibility with the aircraft
operator. Such relationships are not currently subject to direct regulation.[180]
CASA advised that CASR Part 142 'is under review as a matter of priority and
has now been progressed to the Office of Legislative Drafting and Publishing'.[181]
2.180
Mr Petteford noted that CASR Part 142 was based on ensuring conformity
of training quality systems between airlines and third party training
providers. Citing current European arrangements as an example, he explained:
...under the European regulations, it is a requirement that
where you are working with an AOC holder of multipilot operations, the quality
systems must harmonise together, and so there has to be an oversight by one of
the quality systems, whether it is from the AOC or the training provider
overseeing the airline quality system. The quality system dovetails it together
and that is the way it works. That is the foundation on which the [CASR Part] 142
concept comes about. It is the mutually working together, which should be
through the safety management and the quality management systems.[182]
Pay-for-training approaches
2.181
The committee received a significant amount of evidence regarding
pay-for-training arrangements and, more broadly, the various means or
mechanisms by which trainee pilots are able to fund the costs of their
training.
Pay for training
2.182
Apart from cadet training schemes—in which, as noted above, it is common
for cadets to pay the costs of, or to raise a debt against the costs of, their
training—the committee understood this term to apply also to the practice of
airlines requiring employee pilots to bear the cost of aircraft type
endorsements.
Criticisms of pay-for-training
approaches
2.183
A number of submitters and witnesses outlined concerns regarding
pay-for-training schemes.
2.184
The AIPA submission argued that current training practices have departed
from historical approaches, whereby the costs of ab initio training
(that is, training to receive the relevant pilot's licence and instrument
rating) was generally borne by the individual, and subsequent training (such as
training to receive type endorsement in a particular aircraft) was borne by the
employer. AIPA submitted:
Two inherently industry damaging and risk exacerbating
schemes were introduced to Australia by LCCs. The more common 'pay-for-training'
schemes refer to postgraduate training where the employer transfers the cost of
training to prospective employees.[183]
2.185
AFAP expressed concern that pay-for-training approaches could create an
'intrinsic commercial incentive' for trainees to be qualified as quickly as
possible, and commented that this risk would need to be 'managed and closely
monitored'.[184]
2.186
Mr Phillips commented that, although he did not believe that flying
schools were graduating pilots who patently lacked competency, there may be
students being passed who were at the margins of proficiency. He stated:
I believe that, at the end of the day, no school will
graduate someone that they really believe is unsafe. [However, they]...will
graduate people who they are not overly comfortable with.[185]
2.187
Mr Phillips noted that, with the exception of some flying schools, such
as OAA, most third party providers did not employ selection processes to ensure
a high quality of student pilots. Mr Phillips indicated that he would support
the introduction of such a requirement in the case of people seeking to obtain
a CPL (as opposed to a person seeking a recreational or Private Pilot Licence
(PPL)).[186]
2.188
The VIPA considered that employer funded training had in the past
'proved to be an effective entry-risk mitigator', and that the shifting of
pilot training costs on to pilots carried two 'significant' risks:
-
experience and suitability has been superseded by ability to 'buy'
or 'finance' a job; and,
-
entry risk mitigation is severely reduced due to no syllabus or
standards control of the training provider by the airline.[187]
2.189
Further, VIPA noted:
...the related effects on flight safety, either directly
through reductions in control over flight standards or indirectly as a response
to changes in corporate culture and the social welfare of pilots, have not been
adequately researched or debated.[188]
2.190
AIPA was concerned that pay-for-training schemes resulted in cadet
pilots beginning their careers with significant levels of debt,[189]
and referred to overseas examples of cadets declaring bankruptcy 'because they
cannot afford to live on their wages'.[190]
AIPA noted that, in the context of a projected increase in demand for pilots in
Australia and overseas, pay-for-training schemes could act as a disincentive to
would-be pilots. This was compounded by the reduction in entry-level salaries
for cadet pilots:
If we do not have a serious look at the Australian industry
where the growth comes from both general aviation and those cadet schemes, we
will see young people not entering the industry because why would they pay upwards
of around $200,000 for a cadet and training scheme when they are going to earn NZ$42,000
per annum for three years as a cadet pilot? That is less than the Australian [average]
wage.[191]
2.191
Captain Klouth shared these concerns, and noted also that significant
debts carried by new pilots could affect their willingness to voice concerns
related to safety:
The pay for training schemes that are currently used by the
Low Cost Carriers result in new pilots commencing their career in airlines with
a substantial amount of debt. Combined with debt that they may have incurred
during their commercial training debts of over $100,000 are not uncommon. This
puts an additional layer of stress on the new First Officer that may result in
them not wanting to 'rock the boat' when it comes to criticism of their
training.[192]
2.192
AIPA's view was that:
...the cost of running cadet schemes should be cost neutral
with direct entry schemes because the training should elicit the same graduate competencies.
If Government believes that direct intervention is inappropriate, then AIPA
strongly suggests that consideration should be given to extending HECS support to
Air Transport Pilot Licence (ATPL), Instructor and type rating training.[193]
2.193
AIPA recommended that:
...the Bureau of Infrastructure, Transport and Regional Economics
(BITRE) be tasked with investigating the price sensitivity of flying as a
career choice, pricing structures within the aviation training industry and the
relative position of aviation training within Government financial and fee [194]assistance/incentive
programs.
Alternate views on pay-for-training
approaches
2.194
The evidence of a number of submitters and witnesses did not support the
concerns outlined above in relation to pay-for-training schemes.
2.195
CASA noted that pay-for-training schemes had been in use internationally
for 'many years', particularly by European low-cost carriers, and had become
'the norm in certain sectors of the Australian market'.[195]
The practice of airlines paying for pilots' aircraft ratings was 'occurring
less often today than it once did', and there was no evidence of any
detrimental effects on airline safety from such practices.[196]
2.196
In response to concerns that pay-for-training provided an incentive to
pass sub-standard recruits, Captain Berry stated that he did not believe that
pay-for-training schemes had any particular tendency to create pressure for paying
students to be passed.[197]
He noted that low failure rates were, in part, attributable to the use of
aptitude tests as a barrier to entry into flying training courses.[198]
2.197
The Qantas and Jetstar submission also rejected such concerns:
There is no evidence of a connection between the manner in
which a training program is funded and the skill level or safety of a pilot. It
is common practice across a range of industries for the provision of training
to have moved away from a more traditional apprenticeship model.[199]
2.198
In the case of OAA, Mr Petteford noted that, in relation to both airline
sponsored cadets and private student training, OAA employed selection processes
and continuous assessment, which ensured a high quality of graduates. He
explained:
If an airline is supporting the program and willing to
support them into employment at the end, then it is highly competitive and 95
per cent of them are rejected. If they were white tails, they don’t know who
they are going to work for at the end, we are doing all of the selection
initially and we reject 52 per cent of our applicants. During the program—and
this is the bit that really makes the program the filter as well—we carry out a
process of continuous assessment, of which four per cent of them fail.[200]
2.199
In the case of students who failed to meet required standards, Mr
Petteford noted that:
[OAA's] solution to the moral dilemma is if we terminate
their training we give them all of their money back [for the balance of the
course]. That is it. They get a full money back guarantee.[201]
2.200
In contrast to concerns about low wages for cadets, some evidence
pointed to low starting wages as a feature of other professions, noting that
people may accept low starting wages in light of the potential for better wages
and conditions as their career advances. Captain Woodward commented:
It is an apprenticeship, really. Most young pilots realise
that they are doing those things in the Northern Territory or earning such poor
wages because ultimately they will be sitting where I am sitting as a 380
captain in an airline. It is a bit like doing training as a surgeon. Doctors
end up doing 15 years of training to become a surgeon. They work long
hours and get pitiful wages initially, but in the long term they do very well
out of it, so they are rewarded. [202]
Other training funding arrangements
2.201
Qantas and Jetstar submitted that there is a number of payment
arrangements in place for pilot training schemes, which provides a suitably
broad range of options for aspiring pilots:
The cost of...[training] programs is not uniform or standard.
Some programs have an aspect of government and/or company funded arrangements,
while others have the option of either direct payment by the training pilot or
via salary sacrifice arrangements. These different payment options create
flexibility to ensure that appropriately skilled individuals have a range of
options in attaining their [CPL]. The range of options for pilot training available
currently assists in attracting the most suitable candidates, rather than merely
relying on ex service pilots and General Aviation pilots (who historically paid
for their training in any event).[203]
HECS-HELP and VET FEE-HELP
2.202
The evidence received by the inquiry indicated some support for
expanding the operation of HECS-HELP and VET FEE-HELP schemes.
2.203
The Department of Education, Employment and Workplace Relations website
explains that HECS-HELP 'is a loan available to eligible students enrolled in
Commonwealth supported places, and will cover all or part of the student
contribution amount'.[204]
2.204
VET FEE-HELP is:
...a student loan scheme for the Vocational Education and
Training (VET) sector that is part of the Higher Education Loan Program (HELP).
VET FEE-HELP assists eligible students undertaking certain VET courses of study
(diploma, advanced diploma, graduate certificate and graduate diploma courses)
with an approved VET provider, to pay for all or part of their tuition costs. A
VET provider is a registered training organisation who has been approved by the
Australian Government to offer VET FEE-HELP assistance to their students.[205]
2.205
The RAAA commented that the current HECS-HELP arrangements favoured
universities over independent training institutions, with anomalous results:
Those students undertaking their training through a
university can qualify for HECS (and a significant debt). However, those
training through the independent CASA approved flight training schools cannot
access HECS while the parallel VET FEE-HELP scheme has become a bureaucratic
quagmire and proving useless to the aviation industry. The latter schools can
train competent commercial pilots in 18 months-2 years while the university
schools take 3-4 yrs because of their degree structures. The anomaly is that
students are attracted to the university schools because HECS is available. In
other words government policy and administration around the HECS/VET FEE-HELP
schemes is seriously skewing the market towards the university based flight
schools. Both types of schools are producing competent commercial pilots but
students are choosing the longer path for financial reasons and non-university
based schools are closing. This is madness when the industry needs well-trained
pilots now. Australia has the potential to be a world leader in aviation
training but cannot achieve this goal with the current policy settings.[206]
2.206
Mr Phillips supported a broadening of HECS-HELP. He commented that
HECS-HELP:
...should not be just tied to universities...[as there] does need
to be a broader pool...[Piloting is] one of the few professions where the
individual carries the whole can for their training and professional
qualifications and then rolls out at the end of it to probably some of the
lowest paid positions around the place.[207]
2.207
In relation to VET FEE-HELP, Mr Stephen Fankhauser, Aviation Discipline
Leader, SUT, advised that VET FEE-HELP was not available for a Certificate IV
course of study, which was the accredited level of study assigned to the CPL
under the current framework.[208]
In addition, Mr Fankhauser noted that the current VET FEE-HELP limit of $86 000
was 'not adequate for [the eligible practicum part of] aviation training',
particularly when compared to the limits in place for other disciplines, such
as veterinary science.[209]
2.208
Mr Peter Sobey, Compliance and Training Manager, RAAA, noted also that
it was difficult for smaller training organisations to meet the criteria for
attracting VET FEE-HELP, relating to financial requirements and the primary
purpose of the training organisation, which must be for education.[210]
Mr Sobey commented that, as a result, there were very few smaller training
organisations were eligible for VET FEE-HELP:
Unfortunately in pilot training in Australia, one of the
biggest problems that we have is it is only the pilots or cadets whose parents
can support them that can make the journey through in the world of aviation.
VET FEE-HELP was introduced to help the VET sector in the training area that I
am in. As far as I know, there may be one actual training organisation that is
qualified for VET FEE-HELP. So the scope around qualifying for VET FEE-HELP is
ridiculous. It may be available to the bigger universities and TAFE colleges
that have the government's backing, but there would not be a private enterprise
training organisation that would not have some debt at the bank, and we do not
make the financial requirements of VET FEE-HELP.[211]
2.209
AIPA supported the expansion of VET-FEE HELP support to registered
institutions.[212]
2.210
Virgin also supported this proposal:
The cost of pilot training is high, and prohibitively so for
many aspirants. The Government's Vocational Education and Training (VET)
reforms have enabled approved providers to offer VET FEE-HELP to eligible
students in the aviation sector. While the number of providers offering flight
training courses is limited, this may increase over time. The opportunity for a
larger pool of labour to train as pilots and compete for selection should be
positive in terms of maintaining high performance standards creating a more
stable workforce.[213]
Retention of experienced pilots
2.211
Term of reference (d) required the committee to consider issues relevant
to the retention of experienced pilots.
2.212
The AIPA submission advised:
Prior to industry deregulation in the US and the emergence of
the LCC worldwide, pilot retention was essentially not an issue. Pilot
conditions of service were stable and rewarded years of service in a company.
Remuneration was at the high end for salaried employees.[214]
2.213
However, the AIPA submission observed that industry deregulation and the
emergence of LCCs had seen pilots' salaries and conditions significantly
reduced. Captain Woodward observed:
We are seeing the situation where pilots are paid salaries
that are below the basic wage in Australia and certainly below the wages of
baggage handlers that are handling the bags in the aircraft.[215]
2.214
VIPA noted that the transition to low-cost methodologies in Australia,
and the increase in competition, had seen the historical use of pilot wages to
attract and retain experienced personnel come under 'significant pressure'.[216]
This had also resulted in a shift away from the 'traditional airline practice
of identifying and developing, experienced airline technical managers from
within the pilot ranks.[217]
VIPA was concerned that such approaches to pilot wages and conditions could
amount to a 'race to the bottom', and ultimately lead to 'blowback' in the form
of a deterioration in safety'.[218]
2.215
VIPA felt that airlines were increasingly focused on and concerned with
business cost or 'bottom line' considerations in setting and negotiating over
pilot wages and conditions. VIPA characterised a company involved in recent
industrial negotiations as:
...so deeply tied into business cost and negotiating the most
business efficient outcome that the safety aspects and the real need for experience
is forgotten in the rush to undersell pilots terms and conditions for less experienced
pilots who will work for less money.[219]
2.216
Similarly, AIPA submitted that LCCs in Australia operate on a
recruitment model that does not seek to retain experienced pilots, but rather seeks
to service a high turnover of less experienced and therefore more affordable
pilots through particular recruiting practices, such as cadet training schemes.[220]
Demand for pilots
2.217
Many submitters and witnesses placed their remarks on the issue of pilot
retention in the broader context of the likely demand for pilots in Australia
in future years.
General industry trends
2.218
CASA advised that there is a 'limited supply of skilled aviation
personnel in Australia', and that some predicted worldwide 'major shortfalls of
trained pilots if the [current] rate of industry expansion continues'.[221]
The CASA submission stated:
The dimensions of the skilled staff shortage throughout the
world can be seen in figures produced at ICAO's Next Generation of Aviation
Professionals conference...[in 2011], which indicate that, over the next
sixteen years, there will be a need for an additional 800 000 new pilots and
engineers to keep the international aviation industry functioning smoothly.
Boeing predicts that there will be a requirement for an extra 180,600 pilots
and 219,900 new technicians in the Asia/Oceania region alone by 2029.[222]
2.219
Captain Woodward observed that the expected increase in demand for
pilots would impact on the ability of Australian airlines to retain pilots, and
influence the employment dynamics of the airline industry. He explained:
Traditionally, you might have joined your national carrier
and stayed there for 40 years. You will probably see pilots migrating back and
forth now between countries and airlines trying to achieve best outcomes...We
will see pools of pilots coming from all over the world because there will be a
period soon where, if you are warm and upright and you have a professional
licence, you will get a job.[223]
2.220
CASA observed that the general aviation sector experienced problems
retaining experienced pilots as a result of pilots moving from 'commuter,
charter or instructional backgrounds' to commercial airlines.[224]
2.221
Tiger Airways noted that such movement of pilots from general aviation
and smaller operators to larger operators was a longstanding feature of airline
operations. Captain Berry commented that:
...aviation has always been a career ladder. Pilots have
generally progressed from flying smaller aircraft to flying larger aircraft.
Pilots hold various ambitions, but to be a captain of an A380 one day is
probably on a lot of people's lists. There is an element of one airline feeding
upon the other, if you like, when seeking pilots for employment...We do not
knowingly go out and 'poach', to use the term, but where a pilot presents
himself to us, if he has discharged himself of his obligations to his previous
employer, we are very happy to take him on.[225]
2.222
Similarly, Captain Woodward observed that the ability of larger carriers
to offer superior pay and conditions and, to some extent, the prospect of
piloting larger and more powerful aircraft, was a constant source of attraction
to pilots seeking 'better remuneration and conditions'.[226]
The retention of pilots was a 'perpetual problem' for the 'low-capacity end of the
aviation sector', such as regional carriers.[227]
2.223
Virgin also acknowledged that 'the career aspirations of the regional
pilots are to fly for Virgin Blue or other mainline carriers'.[228]
In recognition of the pressures that this could place on regional carriers, Virgin
advised:
What we have done recently is be more transparent with the
regional carriers. We are starting to share the number of pilots we plan on
hiring for the year...so that they have the opportunity to see from a planning
perspective how many of their pilots are going to put their hands up and say, 'I
would like to fly for Virgin Blue.' That will continue. What we are trying to
do is help them manage their process as well.[229]
2.224
The RAAA submitted that the movement of pilots from regional to major
airlines meant that the regional airline industry carries relatively higher
costs of training and developing pilots:
There is little doubt that the large airlines treat the
regional airlines as their training pool. Some of the large airlines do not have
their own pilot training program and make no contribution to developing young
pilots. They rely on attracting pilots from smaller airlines and overseas, and
benefit from the training previously given by other aviation companies. As a
result, the regional airline industry which has much lower economies of scale
and decreased ability to bear high costs, incurs the largest proportion of the
cost of developing a commercial pilot into a professional, experienced and
polished RPT captain or [first officer].[230]
2.225
As a particular example of this trend, Regional Express noted that,
during a shortage of pilots in 2007-08, the company had lost 50 per cent of its
pilots to larger airlines, and that this had been a significant factor in the
company instituting its own cadet pilot training scheme.[231]
The Regional Express cadet scheme contained financial incentives to encourage
pilots to stay for at least the period over which the training costs are repaid
to the company (approximately seven years).[232]
2.226
Mr Sobey commented:
...the best way we can see to keep pilots is for companies like
Jetstar, Qantas and Virgin to have their own cadetship programs. That way, they're
not out poaching our pilots.[233]
2.227
CASA observed that the movement of pilots from general aviation to
commercial airlines had potential safety implications, and advised that it had:
...adjusted its oversight of individual operators and sectors
of the industry accordingly by increasing surveillance where appropriate and
providing increased and targeted educational support...[234]
2.228
In contrast to general aviation operators and regional airlines, Qantas
and Jetstar advised that the group of companies had a 'high level of pilot
retention over recent years', as evidenced by the 'low attrition rate for
pilots employed by each of the [Qantas Group's] Australian flying entities,
especially when compared with the Australian average'.[235]
The pilot attrition rates for the three entities comprising the Qantas Group
were all below the Australian industry average of 12.5 per cent:
-
Qantas (1.1 per cent);
-
Jetstar (1.4 per cent); and
-
Qantaslink (7.2 per cent).
2.229
With regard to Qantaslink, the Qantas Group advised:
Whilst having a low attrition rate, QantasLink's attrition
rate is higher than the other Group airlines as it reflects the general trend
of pilot progression from regional turbo prop operations to jet aircraft
operations.[236]
2.230
Virgin advised:
The annual turnover of pilots in the Virgin Blue Group is
less than 1%, which is much lower than other major groups of its workforce.
Turnover in the industry generally rises during growth periods as demand for
labour and accordingly choice of employment opportunities increases, and is
lower during times of reduced economic activity such as the global financial
crisis. It should also be noted that the ability to retain pilots, is not
solely influenced by the airline employer. Broader factors such as more
competitive personal tax frameworks and lifestyle also drive decisions.[237]
Type rating (endorsements) and recurrent training for pilots
2.231
For the purposes of the inquiry, the committee understood the term 'type
rating' to refer to aircraft 'endorsements', which is a specific qualification
to fly a type or class of aircraft. An endorsement is issued on the basis that
the pilot in question can safely operate a type or class of aircraft as pilot
in command or co-pilot, as specified.[238]
2.232
The committee understood the term 'recurrent training' to refer to
airlines' training and proficiency checking systems. CASA offered the following
description of an airline training and checking systems:
Within an airline training and checking system, a pilot will
be proficiency checked; that is a specific proficiency will be assessed by the
operator, such as the pilot's proficiency to operate a company aircraft on line
operations (the line check). [An]...operator may also provide its pilots with the
opportunity to periodically practice emergency flight manoeuvres that would not
be encountered during normal operations. Personnel employed by the airline may
have previously received training conducted by a number of different providers
or been issued qualifications on the basis of foreign licence qualifications.
An airline training and checking system must determine a person's competency to
perform their duties to the standards expected of the airline and in compliance
with CASA regulations.[239]
2.233
Training and checking may apply to the following aspects of a pilot's
skills and career development:
-
induction into an airline;
-
training in the airline's operations before being released to
unsupervised line operations;
-
training on any new procedures or equipment;
-
endorsement on company aircraft (if the company conducts its own endorsement
training);
-
checking for continuing proficiency at least twice per year; and
-
testing for the re-issue of command or co-pilot instrument
ratings on an annual basis.[240]
2.234
The committee heard that, in Australia, type endorsements can be
conducted by airlines, specialist approved training organisations, ATOs or qualified
flying instructors.[241]
As the safety regulator, it is CASA's role to set the standards for aircraft
type endorsements.[242]
2.235
The committee heard that the large commercial airlines in Australia are
required to have in place a CASA-approved training and checking system.[243]
For smaller operators, the Chief Pilot is responsible for maintaining flying
standards.[244]
As the safety regulator, it is CASA's role to set the standards for training
and checking of flight crew.[245]
This includes:
-
approving various approaches to training and checking;
-
periodically assessing and approving training and checking
pilots; and
-
assessing and approving chief pilots.[246]
Concerns relating type endorsement
and recurrent training
2.236
AIPA submitted that type endorsements and recurrent training were
directly relevant to the three of the four root causes in an increase in fatal
accidents in large aircraft since 2005. These were:
-
training being inappropriate for today's aircraft;
-
automation reliance; and
-
degraded manual handling skills.[247]
2.237
AIPA noted that modern aircraft were heavily reliant on automated flight
systems, and that there was an attendant risk that pilots' manual flight skills
would 'eventually deteriorate if not regularly practised'.[248]
2.238
AIPA also noted that automation carried inherent risks for safety:
A series of accidents and incidents related to incorrect or
inappropriate auto-flight use have led most airlines to publish auto-flight
usage policies in order to give the pilots guidance on when they should use the
auto-flight system, at what level and, more importantly, what to do if there is
an auto-flight system malfunction or auto-flight system confusion on the part
of the pilots.[249]
Adequacy of flight simulator
training
2.239
AIPA submitted that these issues relating to automation were effectively
'all issues associated with training', largely conducted through the use of
flight simulators.[250]
AIPA was concerned that flight simulators were being used to enable pilots to
achieve a minimum standard rather than to equip them with the skills and
knowledge to address the problems arising from aircraft automation. The AIPA
submission explained that cost was a factor in determining how simulators were
being used for training:
Almost all pilot training in large aircraft is conducted in
simulators rather than in the aircraft itself, both as a cost and a risk reduction
measure. However, modern simulators can cost $20 million dollars each with
running costs of hundreds, or even thousands, of dollars an hour. These high costs
result in training courses that are pitched at the lowest number of simulator sessions
that will allow the pilot to achieve the minimal acceptable standard. This is often
a selling point by the manufacturers: company A's aircraft requires two less simulator
sessions for a pilot conversion from a similar type than company B's aircraft.[251]
2.240
The use of flight simulators for a minimum compliance outcome was also
encouraged by baseline training ratios set by aircraft manufacturers:
The aircraft manufacturer generally establishes the baseline
type rating training. Invariably, this baseline training is focused on the minimal
training required to operate the aircraft as originally intended, rather than
with the design flaws and unexpected outcomes that typically arise over the
life of the aircraft. Despite the rhetoric, manufacturers and operators
infrequently revisit these baselines in the pursuit of quality and most LCCs
are particularly wary of increases in training costs. The previous situation
where operators easily exceeded the minimum regulatory requirements is rapidly
disappearing and the minimum statutory requirements are now becoming the
benchmark.[252]
2.241
Virgin, however, advised that, in respect of type endorsement training,
for example, the company exceeded the minimum number of hours training
prescribed by the regulations.[253]
2.242
AIPA submitted that simulator training was also lacking in human factors
training:
AIPA is of the view that most currently available aircraft
type ratings tend to treat predominantly skills in the simulator with minimal
reinforcement of knowledge and virtually no [human factors/non technical
skills] HF/NTS training. We believe that instructors have to be capable of HF/NTS
training and assessment in order to integrate the training. Unfortunately, airline
training of instructor staff is unregulated and very patchy, as is typical of
course development. There is a paucity of guidance material and regulatory
standardisation.[254]
2.243
Given these factors in relation to simulator training, AIPA submitted
that:
...the current regulatory requirements are inadequate as benchmarks
for quality type rating training and consequently for recurrent training. The
role of the Civil Aviation Safety Authority (CASA) is to specify a minimum standard
of required knowledge, skills and behaviours that reflects modern systems and
maintains the quality of training. Quality type rating and recurrent training
provide the essential system resilience to address emerging issues as well as
to maintain acceptable levels of safety.[255]
2.244
Mr Joyce described simulators as valuable and critical elements of
modern training:
They have improved dramatically over the years, and keep
raising the levels of reality. [Simulators replicate]...challenging flying
conditions...and...scenarios...The simulators are important aids to pilot training
and to the maintenance of pilots' skills. Even the most experienced Qantas pilots
spend an average of 16 hours per year in the simulators. In addition to the
cost of training-related infrastructure such as flight simulators, we spend
approximately $30 million each year on pilot training, including recurrent
training.[256]
2.245
Captain Bryan Murray, AFAP President, was also confident that simulators
were a valuable aspect of modern aviation training approaches:
I consider that the simulator is an outstanding training aid
and we obviously can do things in the simulator that we would not even think
about doing in the aeroplane. I personally consider that the simulator is more
difficult to fly than the aeroplane, as good as the simulators are. It is
different, but I am sure that, having had simulator training on the 737
simulator and recurrent training, if the same thing happened in the aeroplane I
would more than capably handle it because of the training that I regularly get
from Virgin Blue.[257]
2.246
In relation to type endorsement and recurrent training more broadly,
AIPA recommended that:
...airline operators no longer be permitted to charge employees
for post graduate training programs to fly specific aircraft types. In AIPA's
considered view, these forms of training should remain an airline's cost of
doing business.[258]
2.247
Finally, AIPA recommended that:
CASA review the knowledge, specified behavioural objectives
and skills required for type rating and recurrent training programmes. This
review should focus on the skill set necessary for a pilot of a modern complex
aircraft to deal with sophisticated automation, degraded auto-flight modes and
manual flight skills throughout the aircraft’s flight envelope. It should also
define minimal levels of systems and aircraft knowledge such that systems
confusion and automation dependency do not become a flight safety issue.[259]
2.248
CASA advised the committee that it was currently conducting a review of
airline training and checking activities. Mr McCormick explained:
This review—the most comprehensive CASA has ever
undertaken—is ongoing. Preliminary indications suggest that there is
opportunity for CASA to provide more guidance to operators regarding airline
training and checking. To this end we have expanded the approved testing
officer manual and we will be developing an entry control theory course for new
check pilots. We will also be expanding the use of our flight test notification
system to enable a more comprehensive analysis of data relating to pilot
standards. During this process, we will involve the airline industry through
the formation of specialist industry advisory panels.[260]
2.249
CASA drew the committee's attention to a number of proposed new
regulations relating to type endorsements and operator training and checking.
These were CASR Parts 119, 121, 133, 135 and 142. The committee notes that CASR
Part 121 in particular is intended to introduce 'more comprehensive
training and checking requirements for cabin crew...flight crew and ground
support personnel'.[261]
However, the committee did not receive evidence on the substantive detail of
this proposed new regulation.
Committee view
Introduction
2.250
The committee notes that the inquiry provided a valuable opportunity for
an extensive airing of, and investigation into, a raft of issues to do with
airline safety. As noted in Chapter 1, given the nature of the airline
industry, in which accidents and safety incidents can have such profound
consequences, safety is an issue that in theory and practice cuts across every
aspect of airline operations.
2.251
Given the breadth of issues raised by submitters and witnesses, and in
light of practical considerations, the committee has limited the focus of this
report to the issues of pilot training and accident and incident reporting, and
their potential impacts on airline safety more generally.
2.252
The committee's approach means that a number of issues that were raised
in evidence are not addressed in detail in this report. An example of one such
issue is aviation maintenance, which, while not given detailed consideration in
this report, may be worthy of particular examination by this committee or
another appropriate body in the future. Similarly, the committee notes that,
while the focus of the report is on the larger commercial passenger airlines in
Australia, an inquiry into the general aviation sector may well be warranted in
future.
2.253
Throughout the course of the inquiry, the committee also received a
number of public and in camera submissions inviting it to consider particular
incidents relating to safety. While the committee examined any such incidents
for evidence of broader or systemic pilot training or reporting deficiencies,
the committee did not make findings regarding individual fault or blame in any
such case. The committee raised a number of these reports and incidents with
the regulator, and was satisfied in all cases that appropriate investigations
and action had been, or would be, undertaken.
2.254
The committee notes that the evidence of all submitters and witnesses
was underpinned by a desire to maintain Australia's enviable aviation safety
record. The committee rejects any suggestion that parties to the inquiry were
motivated by matters other than their interest in ensuring that Australian
aviation continues to achieve world's best outcomes in terms of safety.
Pilot experience requirements and
the consequence of any reduction in flight hour requirements on safety;
The United States of America's
Federal Aviation Administration Extension Act of 2010, which requires a minimum
of 1500 flight hours before a pilot is able to operate on regular public
transport services and whether a similar mandatory requirement should be
applied in Australia;
Current industry practices to
recruit pilots, including pay-for-training schemes and the impact such schemes
may have on safety;
Retention of experienced pilots;
and
Type rating and recurrent training
for pilots.
2.255
Terms of reference (a), (b), (c), (d), and (e) required the committee to
consider a broad range of issues relating to pilot experience requirements,
recruiting and training and pilot retention, as well as a specific proposal to
require that all pilots operating regular public transport (RPT) should be
required to have a minimum 1500 hours flight experience.
2.256
The committee heard that pilot experience requirements in Australia are
effectively established by the minimum experience requirements which apply to
the licences needed to operate as a pilot on RPT services. While there is no
proposal or apparent likelihood that these minima will be reduced, there was
significant comment in evidence regarding whether these minima remain sufficient
to ensure positive safety outcomes.
2.257
The committee heard that this question has become all the more relevant
given recent trends in the aviation industry, whereby pilots are moving into
the co-pilot's seat more quickly than was historically the case. While pilots
(captains) are required to have a minimum 1500 hours experience, the minimum
experience requirement for co-pilots is an apparently modest 150 or 200 hours,
depending on the course of qualification undertaken.
2.258
Generally speaking, there was a significant consensus among stakeholders
that acceptable levels of pilot proficiency are achieved through a mix of
flight experience (including flight simulator training) and competency based
training.
2.259
However, there was substantial disagreement regarding the exact number
of flight hours that should, combined with the achievement of the relevant
competencies, qualify a co-pilot to operate RPT services. A number of
submitters and witnesses, including the CASA, regarded the existing minima as
satisfactory. In support of this view, it was noted that the current
requirements are in accordance with international norms, and are sufficient in
light of competency based and tailored training approaches. Further, it was
noted that specific policies and airline training checking systems are directed
to ensuring that low-experience pilots are properly mentored and monitored once
allowed into the co-pilot's seat.
2.260
A number of submitters and witnesses, however, argued that the minimum
flight hours requirement for co-pilots operating RPT flights should be
increased to 1500 hours (term of reference (b)). This proposal was said to
achieve a more appropriate balance between experience and competency based
training approaches, particularly in light of the potential consequences of
accidents involving high-capacity RPT services. The use of co-pilots with
flight experience hours approaching the licence minima was said to involve a
number of latent safety risks, notably the inability of a co-pilot to replace
and/or support the captain in cases of emergency, and the reluctance of a very
inexperienced co-pilot to question the actions of an experienced captain (a
circumstance described as involving a steep cockpit authority gradient).
2.261
A critical issue in these arguments was the adequacy and quality of
current training methods for prospective pilots, as well as for the granting of
type endorsements and recurrent training of already licensed pilots. The focus
of much of the evidence in relation to these matters was on cadet schemes and third
party training providers (term of reference (c)), which the committee heard are
increasingly being used by Australian airlines.
2.262
Supporters of the current licence minima generally argued that cadet
schemes and third party training arrangements promote adequate if not superior
training outcomes, as they are specifically tailored to producing commercial
pilots to operate multicrew aircraft in accordance with the specific standard
operating procedures of a particular airline. Cadet schemes were also
identified as enabling regional operators to better retain pilots through
bonding arrangements, in order to resist the historical loss of pilots to
larger airline operators.
2.263
In addition to evidence regarding the specific benefits of cadet schemes
and third party ab initio training, the committee heard that the
proficiency of low-experience pilots was supported by ongoing training and
checking requirements, as well as particular airlines' policies governing the
use of such pilots. The committee heard that, generally speaking,
low-experience co-pilots are placed under operational restrictions. One such
example was the Virgin Blue Group (Virgin) policy which restricts the pairing
of inexperienced pilots.
2.264
Proponents of an increase in the minimum experience requirement for
co-pilots operating RPT argued that the methodologies employed by cadet
training and third party ab initio training do not substitute for the
breadth of experience and situational awareness that comes from real life
flying. In particular, it was argued that simulator training is pursued as a
minimum compliance or 'tick-a-box' activity, and is not fully utilised to
achieve proficiency outcomes. Third party provision of cadet or pilot training
was also said to potentially suffer from a similar compliance focus, as well as
create potentially dangerous learning discrepancies in relation to the standard
operating procedures (SOPs) of the contracting airline (this issue arose in
connection with term of reference (h), discussed below). Significantly, it was
noted by many that third party providers currently fall outside of the
regulatory purview of CASA.
2.265
Evidence provided to the inquiry by pilots (in particular by AIPA and
Captain Geoff Klouth) refers to the additional pressure on a captain flying
with a low-experience pilot, particularly in a stressful flight situation, let
alone in an emergency. For these reasons alone, the committee agrees that those
who hold only a CPL or an MPL should not be permitted to co-pilot the largest
high capacity regular public transport jet aircraft in Australia, as identified
in Recommendation 1.
2.266
The concerns outlined in the preceding paragraph regarding the quality
of simulator training and the use of third-party training providers were also
relevant to (term of reference (e)), relating to type rating (endorsement) and
recurrent training for licensed pilots.
2.267
In relation to (term of reference (d)), relating to pilot retention, a
number of submitters and witnesses argued that airlines, particularly low cost
carriers (LCCs), are increasingly utilising cadet schemes to avoid paying
higher wages for experienced pilots, or even as a strategy to generate revenue
through the training costs applied to cadets or to pilots obtaining type
endorsements. The committee heard concerns that new pilots were beginning their
careers with substantial debts, which could impact on both morale and the
preparedness of such pilots to raise safety concerns.
2.268
However, these practices were defended as being relatively longstanding
practices that provided a legitimate entry pathway to a career as a pilot, for
those who did not have the capacity to pay the significant costs of training
up-front, and which supported a variety of business models in the aviation
sector.
2.269
In relation to the issue of co-pilots operating on RPT flights with
flight experience hours closer to the established licence minima, the committee
observes that this must, of itself, represent a reduction in safety compared to
past practices in which pilots would not usually progress to the co-pilot's
role without flight experience significantly in excess of the prescribed
licence minima. However, given the evidence that the current minima accord with
international standards and are not considered by CASA to represent a threat to
safety standards, the committee could not conclude with any confidence that
this represents a reduction in safety that equates to a significantly or
unacceptably higher risk to Australian aviation.
2.270
In addition, the committee was concerned that the imposition of such a
requirement could adversely impact on the supply of suitably qualified pilots
to particular sections of the Australian aviation industry, notably the general
aviation sector and smaller regional operations.
2.271
Further, MPL programs worldwide are still in their infancy and the jury
is still out on their quality and effectiveness.
2.272
However, the committee did not support the proposal that all RPT
co-pilots in Australia be subject to a minimum experience requirement of 1500
hours.
2.273
Despite this conclusion, the committee observes that the increasing use
of co-pilots with flight experience hours approaching the licence minima does
give rise to legitimate concerns regarding the capacity of flight crew to
respond to emergency situations, such as the recent uncontained engine failure
of Qantas flight QF32 over Batam Island near Indonesia. Equally, the use of
low-experience co-pilots may increase the potential for adverse consequences arising
from steep cockpit authority gradients.
2.274
Accordingly, the committee agreed that commercial passenger airlines
should be required to develop and implement policies relating to the use of
low-experience pilots, to maximise, wherever possible, the collective
experience levels of flight crew.
2.275
The committee would also highlight evidence regarding the importance of
multicrew training, or crew resource management (non-technical skills) and
human factors training, as an antidote to many of the inherent risks identified
as arising from low flight experience, such as poor situational awareness and
steep cockpit authority gradients, and the increasing reliance on automated
aircraft systems. The committee heard that there is not currently sufficient
requirement for such training in respect of the qualifying requirements for the
grant of a Commercial Pilot Licence (CPL) or Air Transport Pilot Licence
(ATPL). However, the committee understands that such training will be
incorporated into the qualifying requirements for these licence types with the
implementation of proposed new regulation CASR Part 61, which is expected to be
complete by June 2011.
2.276
Subject to the committee's general comments in the next chapter regarding
CASA's regulatory reform process, the committee agreed that the implementation
of CASR Part 61 should be pursued as a priority, and should ensure that all
prospective regular public transport (RPT) pilots are required to complete
substantial course-based crew resource management and human factors training prior
to, or in reasonable proximity to, initial endorsement training.
2.277
In addition, the committee agreed that, given the importance which all
stakeholders placed on the quality of simulator training, there are legitimate
questions surrounding whether such training is being used to achieve optimum
safety related outcomes, as opposed to minimum compliance outcomes. For
example, the committee considered that a number of stick shaker incidents
discussed in evidence to the inquiry may suggest inadequate simulator training
with respect to avoiding an imminent stall, one of the most dangerous
situations that a pilot may encounter. Given this, the committee felt that CASA
should be required to undertake a risk assessment of current simulator training,
to assess whether the extent, aims and scope of such training is being utilised
to achieve optimum safety outcomes rather than minimum compliance objectives.
Recommendation 1
2.278
The committee is of the view that an ATPL should also be required for
first officers in high capacity regular public transport (RPT) jet aircraft
such as Boeing 737, A320 and other aircraft of similar or greater capacity, and
that consideration be given to implementing this as a standard.
Recommendation 2
2.279
The committee recommends that for non-jet operations which employ low-experience
first officers, operators be required to provide enhanced supervision and
mentoring schemes to offset such lack of experience.
Recommendation 3
2.280
The committee recommends that Air Operators Certificate (AOC) holders be
required to develop and implement 'green on green' policy positions relating to
the use of low experience pilots in RPT operations, to maximise, wherever
possible, the collective experience level of flight crew.
Recommendation 4
2.281
The committee recommends that Civil Aviation Safety Regulation (CASR)
Part 61 ensure that all prospective regular public transport (RPT) pilots be
required to complete substantial course-based training in multi-crew operations
and resource management (non-technical skills) and human factors training prior
to, or in reasonable proximity to, initial endorsement training; the committee
recommends that the Civil Aviation Safety Authority (CASA) expedite, and assign
the highest priority to, the implementation of CASR Part 61.
Recommendation 5
2.282
The committee recommends that the Civil Aviation Safety Authority (CASA)
ensure that Part 61 of the Civil Aviation Safety Regulations currently being
reviewed place sufficient weight on multi-engine aeroplane experience as
opposed to the current recognition of glider and ultra-light experience.
Recommendation 6
2.283
The committee recommends that the Civil Aviation Safety Authority (CASA)
be required to undertake a risk assessment of current simulator training to
assess whether the extent, aims and scope of such training is being utilised to
achieve optimum safety outcomes rather than minimum compliance objectives.
2.284
In relation to third party provision of cadet and pilot type endorsement
and recurrent training, the evidence showed that currently there is a
regulatory 'blind spot' in relation to such entities. The committee heard that,
while CASA maintains oversight of training standards and outcomes through its
regulation of AOC holders, the lack of regulatory oversight of third party
training does not provide for optimal safety outcomes. In particular, there is
a strong view among many industry stakeholders that third party providers may
be giving priority to commercial imperatives by pursuing minimum compliance or
'tick-a-box' strategies. Further, there is a very real risk that such
arrangements may be giving rise to learning discrepancies between third party
provider training courses and the SOPs of airlines contracting such training
services. The potential for such outcomes was reinforced by the committee's
consideration of the Jetstar 'go-around' event in connection with term of reference
(h).
2.285
In relation to these issues, the committee notes evidence that proposed
new regulations CASR Parts 141 and 142, relating to flight training operators
and flight crew licensing, propose that third party training organisations that
provide training either independently to individuals or in concert with
aircraft operators, must be responsible for the training they provide or take
shared responsibility with the aircraft operator. The committee understands
that CASA is pursuing the implementation of the proposed new regulations as a
priority.
2.286
In light of the evidence regarding third party training providers, and
subject to the committee's general comments in the next chapter regarding
CASA's regulatory reform process, the committee shared the view that the
implementation of CASR Parts 141 and 142 should be afforded the highest
priority.
2.287
The following Recommendation 4 and the supporting analysis are also
relevant to term of reference (e), relating to type rating (endorsement) and
recurrent training for licensed pilots.
Recommendation 7
2.288
The committee recommends that the Civil Aviation Authority (CASA)
expedite, and assign the highest priority to, the implementation of Civil
Aviation Safety Regulations (CASR) Part 141 'Flight Training Operators' and
Part 142 'Training and Checking Operators'.
2.289
In relation to cadet schemes, the committee notes that, notwithstanding
the issues surrounding third party provision of training and the use of
simulators, cadet schemes improve the ability of airlines, particularly
regional carriers and smaller commercial operators, to train pilots for the
purpose of business continuity. The use of cadet schemes by larger airlines may
also reduce the need for such airlines to 'poach' pilots from regional
operators. Subject to ensuring quality training outcomes, including adequate
supervision and mentoring, the committee found that cadet schemes are a
legitimate pathway for pilot recruitment, training and development.
2.290
However, the committee was concerned by evidence provided over the
disparate terms and conditions of cadet schemes. Some members of the committee
were particularly concerned over the terms and conditions for the Jetstar cadet
scheme.
2.291
In relation to the issue of pilot retention, the committee notes that
there was significant disagreement on the extent to which airlines may be improperly
pursuing cost reduction strategies at the expense of employing and retaining
experienced pilots. The committee notes that the increased competition in the
Australian market, flowing from the introduction of international carriers and
the advent of LCCs, has resulted in a wider variety of business models offering
pilots a range of salaries and employment conditions. While the committee
acknowledges that levels of remuneration may impact on the ability of airlines
to attract the 'best and brightest', the inquiry did not receive evidence that
the current range of pilot salaries from general aviation through to LCCs and
premium employers such as Qantas acts as a disincentive to talented prospective
pilots. Indeed, the committee notes that pilot career progression has
historically taken a course from less sophisticated operations, operating relatively
basic aircraft and offering relatively modest remuneration, through to high-end
carriers operating state-of-the art aircraft and offering more generous
salaries and conditions.
2.292
The committee notes that a fundamental driver of pilot retention and levels
of remuneration is the domestic supply of pilots, and this was an area that was
also subject to significant disagreements in the evidence received. While some
claimed that that general aviation is unable to provide adequate numbers of suitably
skilled candidates for general airline intake, another view was that general
aviation continues to provide sufficient candidates with a skills base that is
readily convertible to RPT operations.
2.293
In the committee's opinion, general aviation remains a fundamental and
necessary source of pilots for the Australian commercial airline market. While,
as noted above, the inquiry's focus was not on general aviation, it remains the
case that the route from general aviation through to regional carriers and high-end
commercial operations remains one of the critical pilot recruitment pathways. Further,
in a country as vast as Australia, the committee agrees that the ongoing health
and viability of the general aviation sector is vitally important.
2.294
Beyond general aviation, ensuring sufficient future domestic pilot
supply also relies on removing barriers to entry to the profession relating to
both cost and opportunity. In this respect, the committee notes wide support
among industry stakeholders for the broadening of current HECS HELP and VET FEE-HELP
arrangements to provide support for a wider range of training options and
pathways.
2.295
In response to the issues raised in relation to pilot retention and
supply side issues, the committee considers that the Government should require
the Productivity Commission or another suitable body to undertake a review of
the current and future supply of pilots in Australia, with particular reference
to the general aviation and cadet training pathways, and HECS HELP and VET
FEE-HELP arrangements.
Recommendation 8
2.296
The committee recommends that the Government require the Productivity
Commission or another suitable body to undertake a review of the current and
future supply of pilots in Australia, with particular reference to the general
aviation and cadet training pathways, and HECS HELP and VET FEE-HELP
arrangements.
2.297
Since the committee last heard evidence, an updated briefing has been
provided by France's Bureau of Investigation and Analysis (BEA), France's
equivalent to the ATSB, on the loss of Air France 447 on a flight from Rio de
Janeiro to Paris on 1 June 2009.
2.298
It appears likely from the preliminary briefings by the BEA, that issues
of pilot training and experience will be further considered in extensive detail
in relation to the loss of Air France 447, and the final findings of the BEA's
investigation should be extensively considered by CASA, the ATSB, and the
aviation industry generally.
Recommendation 9
2.299
The committee recommends that the Civil Aviation Safety Authority (CASA),
the Australian Transport Safety Bureau (ATSB) and Australian aviation operators
review the final findings of France's Bureau of Investigation and Analysis into
Air France 447, including consideration of how it may apply in the Australian
context. Subject to those findings, the committee may seek the approval of the
Senate to conduct a further hearing in relation to the matter.
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