Posted 4 years 37 days ago ago by Randy Rowles
On October 20th, 2009, the Federal Aviation Administration (FAA) published significant additions and alterations to the Federal Aviation Regulations (FAR). Several changes can be found in 14 CFR 61.129 which identifies the aeronautical experience to meet commercial pilot certification requirements. The changes made to the existing regulation were welcome by many within the ab initio helicopter training industry. However, some of the changes to the regulation may have facilitated instructional coddling that’s proving detrimental to our commercial pilot cadre.
One significant change to the regulations can be found in 14 CFR Part 61.129(C)(4) where it reads that in lieu of 10 hours of solo flight, “10 hours of flight time performing the duties of pilot-in-command in a helicopter with an authorized instructor on board” would be accepted. The intent of this change was to provide a path for the student to “perform the duties of pilot-in-command”. A couple key words used by the FAA when crafting this statement are: “perform” and “duties.”
The definition of these terms as defined by Merriam-Webster are: (1) Perform - to carry out, accomplish, or fulfill (2) Duty - an obligatory task, conduct, service, or function that arises from one's position. In this case, the student shall conduct each training flight as if they were in the position of a commercially rated helicopter pilot. The FAA’s intent is for the student to act as the pilot-in-command of the helicopter performing similar operations and tasks representative of those a helicopter pilot engaged in commercial work may conduct. What would prompt the FAA to use words like “perform” and “duty” when crafting this guidance within the regulation? The answer is accident data.
Many helicopter accidents are the result of the pilot making poor decisions. The FAA’s intent is to provide a path so that instructors may have their students train higher order of thinking skills (HOTS) and learn from their mistakes. Flight training sessions with challenging airspace to navigate, confined areas with varying surface conditions, or night flights into areas of darkness where the student (pilot-in-command) would make the decision to go/no-go or continue/not continue was the desired outcome of the regulation change.
Too many instructors are using these hours to simply fly traffic patterns. Although many pilots in training may benefit from additional pattern work or maneuvers, the intent of altering 14 CFR Part 61.129(C)(4) was to improve the decision-making capability of the commercially-rated helicopter pilot. Instructors conducting HOTS training and evaluation need to stop teaching throughout “performing the duties of pilot-in-command” training sessions. Once you’ve trained HOTS and begin correlative evaluation, it’s time for the instructor to stop talking and start listening and watching.
It’s hard to stop talking as a flight instructor. However, the insight you gain into your student’s decision-making process is priceless. Allowing your student, the ability to use their own thoughts to process information and make decisions within a controlled environment will prove beneficial during the FAA flight exam and give them the ability to say “No” when it matters.
Remember, most life and death decisions in aviation begin as self-induced stressors. We do it to ourselves. Just because we take off doesn’t immediately seal our fate. The option to “Land and Live” (Helicopter Association International) must also be taught and supported by the instructor. Ensuring that a pilot in training will land when the right set of circumstances are presented many times throughout the training curriculum will enhance the pilot’s ability to make that very decision when it matters.
The alternative? Your student eventually becomes an accident data point!
About Randy: Randy Rowles has been a FAA pilot examiner for 20 years for all helicopter certificates and ratings. He holds a FAA Gold Seal Flight Instructor Certificate, NAFI Master Flight Instructor designation, and was the 2013 recipient of the HAI Flight Instructor of the Year Award. Randy is currently Director of Training at Epic Helicopters in Ft. Worth, Texas.