Read the proposal by CASA online here.
It seems like a good idea as it is simply a streamlining of the process that I went through to get my flight examiner privileges per 61.040.
However, I have a few thoughts starting with this one. The design feature training endorsement permits the instructor to train for any of the design features held. Why isn’t there a single “flight activity training endorsement” likewise? This would be a good time to further simplify the regulations. Get the training endorsement just exercising MPPC in an aeroplane with tricycle landing gear then go off and train tailwheel leaves some gaps which instructors should cover with additional training (usually from a back seat which is novel as well).
The only requirement for competency is through this statement: “the flight instructor conducting the flight test must be approved to conduct flight training for the same kind of authorisation by a Part 141 operator that conducts the training”.
CASA should provide guidance on the scope of experience expected beyond just having a Gr1 training endorsement and approved by a school for that instructor training. At least look at something basic like EASA’s requirements to train a UPRT instructor per FCL.915(e).
CASA should ensure that all applicants for examiner authorities related to flight activity endorsements comply with the Condition on an instructor rating related to flight activity endorsements of CASA 62/20 — Conditions on Flight Crew Authorisations (Edition 3) Instrument 2020.
The same requirement should apply to design feature endorsements.
Let’s consider two scenarios at a flight school where a Gr 1 instructor is very competent in their normal operations:
- Design feature training endorsements done on something like an Airtourer T-6 exercising the MPPC only. The instructor has a tailwheel endorsement gained in, say, a Cessna and is current in that type.
- Spin training endorsement.
TAILWHEEL
In this scenario an applicant wants to do a design feature training endorsement in a Super Decathlon. The examiner studies up on the manuals and the MOS.
- Short take-off
- DFE1 requires take-off power to be fully applied before releasing the brakes – this is contrary to the technique in the 8KCAB manufacturer’s Operating Manual and can cause the aircraft to nose over.
- DFE1 requires rotation at the manufacturer’s recommended speed and climb at speed for obstacle clearance – rotate speed in the Operating Manual is 43 kts – less than the stall speed and the climb speed in the Manual is 50 kts – very close to the stall speed of 47 kts. The Operating Manual warns of risk of injury or fatality in the event of an engine failure in this situation.
- Short landing
- DFE1 requires application of maximum braking after touchdown at minimum speed – this is contrary to the Operating Manual where the instruction is “brake as required” with a warning of injury or fatality due to the risk of nosing over.
- Landing approach speed in the Operating Manual is 52 kts which is very close to the stall speed of 47 kts (with nil instrument error). Enjoy the ride!
- DFE1 requires the trainee to calculate the landing distance and to stop the aeroplane within the calculated distance! Really?
- CASA AC 91-02 has good guidance on this situation but:
- Assumes that this applies “The landing speed at a point 50 ft above the landing threshold. It is not less than 1.3 times the stall speed in the normal landing configuration (Vso).” 1.1 times for the Super Decathlon. I won’t do it myself, let alone with a trainee.
- It recommends a minimum safety factor of 1.15 which is not included in the manual.
- The only way to achieve the landing distance in the manual is to nail the airspeed exactly and hit the brakes hard when on the ground. Adding 15% margin caters for technique a bit less rigorous than the test pilot (back in the days before FAR 23 required consideration of an average pilot’s skills).
- Will the applicant use a landing approach speed of 1.3 Vso and how will the increase in landing distance be calculated? Will the examiner want to fly it “per the book”?
- The tailwheel elements of the MOS are much more onerous than for initial training for an RPL, even if done in a tailwheel aircraft. The tailwheel MOS must be made consistent with the RPL part of the MOS – A2 and A4.
SPIN
In recent years the ATSB has reported on deficiencies in spin training where flight instructors have had inadequate knowledge of types other than what they were trained on. Their latest report on a spin accident included a Safety Advisory Notice with specific recommendations. The spin training issues must be properly addressed before diluting the pool of examiners currently granting spin training endorsements.
- The CASA Manual of Standards for the spin endorsement must be amended to include the recommendations of the Safety Advisory Notice in the underpinning knowledge requirements
- Requirements for the instructor spin training endorsement must include knowledge of the different spin and recovery characteristics of different aircraft.
- Related to that last point – that necessitates knowledge of all of the typical aggravated spin modes. This should be included in the MOS for a spin endorsement.
- CAAP 155-1, Aerobatics is to be replaced by AC 61-18 Aerobatics with updated and revised content. I recommend that a separate AC on spinning be developed, leaving the other AC to focus on recreational, competition and display aerobatic pilots.
- The spinning AC would focus on the flight instructor spin training endorsement. It should include a list of standard references for sources of information with guidance related to elements of the MOS.
- One such reference should be Stall/Spin Awareness by Rich Stowell.
- William K.Kershner’s book, The Flight Instructor’s Manual, should be referenced as a guide on the conduct of training for a spin endorsement.