To be fair to Charlie, and to clarify my position on this issue, I'm writing this final post on this subject. I will always answer questions, but this is my platform.
Charlie is not incorrect assuming that fatigue is an issue. That there are issues from the first day we start training on the civilian side of flight training on the path to a commercial pilot.
Here's the rub. It does not take much to recognize a problem. Not much experience is needed to look at a set of parameters and do a quick self-check and find out things don't add up. That's what we do everyday.
There is always a catalyst for change. In this case, it seems to be the tragedy in Buffalo.
The actual cause of the accident was a botched stall recovery. Now, what lead to that? Well, that is under investigation. Certain facts have emerged.
The FO commuted in across country, slept in a crew room and was flying sick. This is due to her own commentary.
The CA had multiple failures in the 121 training environment. Also, he had worked for Gulfstream International Airlines.
I'm extraordinarily disheartened, but not surprised that it took such a tragedy for a dialogue to occur about fatigue and other issues in the commuter segment of the industry.
Things that cause me grief:
1) FARs that carve out exemptions for certain types of operations.
Example of a 121 airline allowed to use Part 135 flight and duty times comes to mind. Oddly enough, this relates to the Roselawn accident. Here, a group of people were motivated to move the commuters to Part 121. The ironic part? The airplane, due to it's size, was already operating under Part 121. Actually, that would be a great accident to go back and compare to 3407, as both airplanes were about the same size, and it involved a stall in icing conditions. Perhaps throw in the Comair Brasillia a few years later as a third comparison.
However, this is not limited to the commuter segment. It also relates to other segments such as cargo.
2) The wink and nod approach to certain things. First, Safety, although it's required as part of a Part 119 certificate, does nothing to contribute to the bottom line in the eyes of some managers. So, let me get this straight? You are going to hire an individual to do audits on the integrity of the safety system of your shop, while you pay him? I wonder how many bad, by bad I mean things like missed maintenance inspections, that will be found by the department? Talk about the loyal opposition.
One would assume that they would continually be evaluating schedules allowed by the 8900 (I mean, if it only runs over block 50% of the time is it illegal...)
3) Training. Not only at the airline level, but from primary training. I hear many, many people berate college aviation programs. Comparing them to pilot mills, and FBOs. However, there is no STANDARD for training a professional pilot. The military does a very good job training pilots.
If you desire to be a professional pilot, you need to have certain requirements. A commercial with multi-engine and instrument ratings are the standard today.
There is no standard in the civilian world to know or understand Part 25 aircraft systems, advanced studies of CRM (ADM/TEM - whatever the term du jour is), high-speed aero, turbine powerplant theory, advanced navigation theory, advanced meteorology, and studies of operation in the 121/135 world.
Nope, you just show up. You do one week of indoctrination, after which you are supposed to be an expert in 121, OpSpecs, company procedures (which other than terminology, there is only so many ways to skin the cat per se), CRM, HazMat for your operation, and de-icing.
Then you have 3 weeks to learn the aircraft you are going to be flying's idiosyncrasies. If you don't know how the back systems work, well that's your fault. Oh, memorize a bunch of limitations and immediate action items.
Then spend a couple days to a week in a paper tiger practicing your company specific flows, procedures and callouts. You need to have these tight because....
You have 7 sim sessions to learn THIS particular airplane. The 8th ride (28 hours of flying, actually 14 since you split sessions) is a checkride. That doesn't sound too bad until you realize that you might get 1 normal session with everything working, then maybe 3-4 V1 cuts. You need to be on your "A" game right off the bat.
Is there anything wrong with that pace at the airlines? Not as I see it. They have a business to run, and you are hired in as a professional. As a professional, it is incumbent upon you to show up with adequate knowledge of what you're getting into.
Training at that airline should be specific to that airline only. You should already have a grasp of the theory by the time you arrive. This is where the civilian track can cause problems. The university I went to covered the theoretical stuff very well. Most pilots I taught in ground school, checked out on the line, or flew with on normal line trips, had a very good grasp of the theoretical systems.
Does that mean there are no other sources that train that? No, however, you can't identify what schools do and don't teach the knowledge necessary.
That's my short list that can be branched out into many, many smaller areas that ultimately trace back to the above.
Now, I'd like to address where the issues lay:
1) First and foremost, 1500TT. I call complete BS on this one. I apologize, but if you are working for an airline, requiring an ATP is fine. However, the 1500TT has nothing to do with an ATP.
You can issue a frozen ATP, which proves the applicant can pass the theoretical and practical examinations, thus proving they have the knowledge to operate at the ATP level. The applicant may be lacking one, or more, of the requirements to exercise ATP privileges.
Pretty much each and every 121 FO that passes an initial SIC checkout under 121 Apdx H training has demonstrated this level of proficiency.
So, if this is instituted, the 1500TT argument can go away. If you want a time limit, make it 5000TT, as historically (and this is argument that the ATA, RAA and other industry groups will use, so get used to it) the most dangerous range of time for a pilot is 1500-5000 hours.
Again, without the proper training, two applicants with ATP "requirements" as they stand today can be two VERY different products in terms of knowledge and proficiency requirements. Working for an airline that hired street Captains, all with over 2500 TT from various backgrounds (from other commuter operations to flying the bush in Alaska) and seeing the most basic lack of knowledge (in or out of the cockpit) resulting in unsatisfactory outcomes is not a good thing.
Until a better primary product is required, the issues at the top levels will continue.
Personally, I'm for the frozen ATP, and allowing the airlines and unions to set their own requirements.
However, in the Colgan case, over or under 1500TT is merely conjecture, as there is no PROOF that having more or less time than that would have prevented the accident.
2) Training
I've already discussed ad nauseum where I have felt the issues in primary training lie, so I will not re-hash those discussions.
However, it was noted that the Captain of 3407 had recurring training issues in Part 121 training.
An occasional failure, say one botched maneuver every 5 years or so, on a recurrent is not a red flag. Neither is a failure during an initial equipment checkout.
A checkride is a very mechanical event, and any one of us could have a slight miscalculation on rudder pressure and botch a V1 cut, or the sim was re-configured and the steep turn tricks don't work and you have a U and a retrain. But for an aircraft you are flying with high-frequency in the short haul domestic world should not generate very many failures.
Zero tolerance for checkride failures would be a terrible idea, because it would generate two simultaneous and equally undesirable outcomes.
First, the very proficient pilot that performs continuously very high levels makes a mistake leading to a failure. This individual is now either fired, or under intense scrutiny, adding pressure to the situation. If the pilot is fired, does that not lower the proficiency of the overall group?
Second, the marginally performing pilot is allowed a "mulligan" without it being noted in the records, thus allowing a marginal performing pilot to appear as a very high level performing pilot. Thus lowering the proficiency of the overall group.
The solution? Institute a certain number of failures in a given time frame would require FAA observation of a PC and a line observation. For example, on a 6 month cycle, 2 failures in a 36 month period would result in a trigger to validate the pilot.
Also, mandatory tracking of checkride outcomes by check airman, aircraft program and individual pilot to see if there is a systemic fault in the training department, or certain pilots or checkairmen are not performing to the demanded standards.
4) Fatigue and duty rule issues.
While not directly causal to this accident, they are "yesterday's technology flying into tomorrow".
However, the fact that the FO flew fatigued was not due to rest and duty rules.
The fact that the current rules suck did not cause this. The FO commuted in on her own time. This will be argued by the ATA and the RAA. They will have copious data showing the various means by which Regional FOs can afford the area, and will cite various airlines that have similar pay structures and have bases in the area, and have many graphs proving it is a livable situation.
We all know the tale of the tape, about how airlines that contract open and close bases like they change underwear. However, this point is VERY difficult to tie-in due to the number of pilots that are based in the area on the same salaries.
3) Pay-for-training and Minimum Wage for pilots proposals.
I lump these two together because there is no tie-in to the subject accident.
Again, merely conjecture is the reason for prevention of the accident. There is no evidence stating that the accident would have been prevented by a marginally hire minimum wage (even a 20% increase would have done little in such an expensive area).
Also, Pay-for-training can not be proven to be a factor in this. While the heat has been brought on Gulfstream, and rightfully so as they seem to be the LCD for many of the high profile regional accidents, there have historically been many operators that operated under PFJ/PFT programs that have operated at a high-level of safety.
At the end of the day, what does it all mean?
It's great to have drive and ambition. I merely caution you to reign it in.
Ask the questions, which you have done.
Then have some hypotheses, which you have done.
Test the hypotheses, which seems to have been lacking.
Distill the data to what you can tie-in to the accident.
There is way to much conjecture, in my opinion, to present a good solid case to congress, or anyone for that matter, on areas that CAN be attacked from this accident.
Look at the ATA and RAA. Full of lawyers and money and made to merely lobby. I'm not saying it's impossible, but the case needs to be solid and very difficult to poke holes in. All it takes is for them to find, say 3 of 5 points that are sketchy, then it automatically raised doubts on the other 2 regardless of their merits.
I don't disagree that things need changed. That the lower end of the pilot scale needs brought up. I think there needs to be a systemic change starting with a bottom-up process, rather than the typical top-down process.
There it is. A rambling thesis for your pleasure.