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Safety Recommendation Details

Safety Recommendation A-10-013
Details
Synopsis: On February 12, 2009, about 2217 eastern standard time,1 a Colgan Air, Inc., Bombardier DHC-8-400 (Q400),2 N200WQ, operating as Continental Connection flight 3407, was on an instrument approach to Buffalo-Niagara International Airport, Buffalo, New York, when it crashed into a residence in Clarence Center, New York, about 5 nautical miles northeast of the airport. The 2 pilots, 2 flight attendants, and 45 passengers aboard the airplane were killed, one person on the ground was killed, and the airplane was destroyed by impact forces and a postcrash fire. The flight, which originated from Liberty International Airport (EWR), Newark, New Jersey, was operating under the provisions of 14 Code of Federal Regulations (CFR) Part 121. Night visual meteorological conditions prevailed at the time of the accident.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Issue an advisory circular with guidance on leadership training for upgrading captains at 14 Code of Federal Regulations Part 121, 135, and 91K operators, including methods and techniques for effective leadership; professional standards of conduct; strategies for briefing and debriefing; reinforcement and correction skills; and other knowledge, skills, and abilities that are critical for air carrier operations.
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Aviation
Location: Clarence Center, NY, United States
Is Reiterated: Yes
Is Hazmat: No
Is NPRM: No
Accident #: DCA09MA027
Accident Reports: Loss of Control on Approach, Colgan Air, Inc., Operating as Continental Connection Flight 3407, Bombardier DHC 8 400, N200WQ
Report #: AAR-10-01
Accident Date: 2/12/2009
Issue Date: 2/23/2010
Date Closed:
Addressee(s) and Addressee Status: FAA (Open - Unacceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: FAA
Date: 3/28/2019
Response: From the Aircraft Accident Report: “Departure from Controlled Flight Trans-Pacific Air Charter, LLC, Learjet 35A, N452DA, Teterboro, New Jersey, May 15, 2017.” Report Number AAR-19-02, Notation 58039, adopted March 12, 2019 and published March 28, 2019, PB2019-100271: Section 2.6.2 Leadership The PIC was responsible for setting the appropriate tone in the cockpit and managing communications and workload in a manner that promoted professionalism and adherence to SOPs. The absence of adequate preflight planning and the omission of required checklists, callouts, and briefings demonstrated the PIC’s inadequate leadership. Paragraph (a)(1) of 14 CFR 135.330 requires operators to provide training that addresses the PIC’s authority. However, this requirement is vague because the regulation does not specify the leadership skills that should be trained, which could include professional standards of conduct and strategies for (1) briefing and debriefing, (2) reinforcing and correcting skills, and (3) encouraging adherence to SOPs. Thus, the topic of PIC leadership responsibilities may not receive adequate attention in Part 135 operators’ CRM training programs. Trans-Pacific’s CRM training, for example, contained very little information explicitly addressing the responsibilities of the PIC as the team leader. Leadership was only covered in three bullet points on one slide that stated that “a leader’s actions and ideas influence the thoughts and behavior of others,” “leadership is acquired,” and “a leader can be either crew member and must know how to effectively communicate ideas and observations.” This material did not adequately describe core leadership functions necessary for ensuring effective crew performance. The NTSB has noted deficiencies in PIC leadership in previous accidents, most notably in our investigation of the February 12, 2009, accident in Clarence Center, New York, involving Colgan Air flight 3407, a Bombardier DHC-8-400, while on an instrument approach to Buffalo-Niagara International Airport, Buffalo, New York (NTSB 2010). In that accident report, the NTSB emphasized the importance of effective leadership for ensuring successful crew performance and recommended that the FAA take the following actions: Issue an advisory circular with guidance on leadership training for upgrading captains at 14 Code of Federal Regulations Part 121, 135, and 91K operators, including methods and techniques for effective leadership; professional standards of conduct; strategies for briefing and debriefing; reinforcement and correction skills; and other knowledge, skills, and abilities that are critical for air carrier operations. (Safety Recommendation A-10-13) Require all 14 Code of Federal Regulations Part 121, 135, and 91K operators to provide a specific course on leadership training to their upgrading captains that is consistent with the advisory circular requested in Safety Recommendation A-10-13. (Safety Recommendation A-10-14) In a September 24, 2012, response, the FAA reported its intent to issue a notice of proposed rulemaking (NPRM) addressing leadership training for Part 121 operations. On January 11, 2013, the NTSB noted that the FAA did not plan to include Part 135 or Part 91K operations in the proposed rule and indicated that “leadership skills are essential for all upgrading captains, regardless of the operation.” Thus, the NTSB classified these recommendations “Open—Unacceptable Response.” On October 7, 2016, the FAA issued an NPRM titled, “Pilot Professional Development” (81 Federal Register 69908), which proposed modifying requirements for leadership training that were primarily applicable to Part 121 air carriers conducting domestic, flag, and supplemental operations to enhance the professional development of pilots in those operations (FAA 2016c). On January 4, 2017, the NTSB commented on the rulemaking, stating that “catastrophic outcomes associated with unprofessional behavior are not limited to Part 121 operations.” This accident provides another example of inadequate leadership on the part of a PIC, contributing to poor CRM and ineffective flight crew performance. The PIC was responsible for setting the appropriate tone in the cockpit, but the PIC’s numerous expletives throughout the flight and negative comments about a controller handling the flight (“she’s a # idiot”) were unprofessional. The PIC was also responsible for following company SOPs (including those for preflight planning and briefings) as a means of managing crew workload and avoiding errors, but his actions during the flight demonstrated disregard for the SOPs. As with the captain of Colgan Air flight 3407, the PIC’s failure to establish a professional cockpit tone and show appropriate command authority is disconcerting. The NTSB notes that the PIC in this accident had never been employed as a Part 135 PIC before being hired by Trans-Pacific and had never received formal specific leadership training to prepare him for the leadership duties associated with the upgrade to PIC. The NTSB is concerned that, even if the FAA provides the CRM training guidance recommended in Safety Recommendation A-19-8 for Part 135 operators, leadership training for future captains might not be provided at the time of upgrade, when the training would have the greatest impact. The NTSB continues to believe that specific leadership training for PICs provided during the upgrade process would help standardize and reinforce the critical command authority skills that PICs need. Lack of leadership in the cockpit can occur in any dual-pilot operation; without appropriate training, some Part 135 and Part 91K PICs may lack the necessary leadership skills to operate as PIC, which poses a safety risk to the traveling public. Thus, the NTSB concludes that specific leadership training provided to Part 135 and 91K pilots at the time of upgrade to PIC would help standardize and reinforce critical command authority skills and improve flight safety. Therefore, the NTSB reiterates Safety Recommendations A-10-13 and -14.

From: NTSB
To: FAA
Date: 1/4/2017
Response: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled, “Pilot Professional Development,” which was published at 81 Federal Register 69908 on October 7, 2016. The NPRM proposes to modify requirements primarily applicable to 14 Code of Federal Regulations (CFR) Part 121 air carriers conducting domestic, flag, and supplemental operations to enhance the professional development of pilots in those operations. The proposal includes requirements for air carriers to provide leadership and command and mentoring training for all pilots in command (PICs), provide new-hire pilots with an opportunity to observe flight operations (operations familiarization) to become familiar with procedures before serving as a flight crewmember in operations, and establish pilot professional development committees (PPDC). Leadership and Command and Mentoring Training The NTSB has previously addressed the importance of improved leadership training for pilots upgrading to PIC and discussed this issue at length in our investigative reports on the October 14, 2004, accident involving Pinnacle Airlines flight 3701 in Jefferson City, Missouri; and the February 12, 2009, accident involving Colgan Air (operating as Continental Connection) flight 3407 in Clarence Center, New York. Safety Recommendations A-10-13 and -14 were issued as a result of findings in the Colgan Air investigation and asked the FAA to do the following (A-10-013 and A-10-014). The proposals for requiring leadership training in the NPRM, if adopted, would likely satisfy the intent of these two safety recommendations as they relate to Part 121 operations (the applicability to Part 135 operations is discussed below). Specifically, the NPRM proposes that all pilots upgrading to PIC be provided leadership and command training as part of their upgrade curriculum both in ground school and in flight training (these training requirements would also apply to new-hire PICs). In addition, the NPRM proposes that all pilots qualified as PIC before the effective date of the rule must complete the PIC upgrade ground training on leadership and command. Finally, the NPRM proposes that leadership and command training be integrated into the PIC recurrent curriculum. The NTSB strongly supports these aspects of the proposed rule and commends the FAA in expanding the scope to include upgrading pilots, as well as the existing cadre of PICs, and in making the training part of the recurrent curriculum. We also strongly support the proposed rule’s emphasis on ensuring that this training include scenario-based instruction both in ground and flight training. However, the NTSB notes that the NPRM currently does not place any restrictions on whether this new training requirement must be satisfied via in-person training or whether distance instruction or other methods would suffice; the FAA specifically sought comment on this aspect of the proposal. The NTSB believes that, because of the importance of this training and its inherently interpersonal topic, it should only be done in-person through facilitated discussion and interaction. Therefore, restrictions on distance instruction are necessary to ensure the effectiveness of this training. By providing in-person training, the operator would be better able to provide facilitated discussions with qualified instructors and improve opportunities to acquire this information in the setting in which it is practiced: in the presence of others. The NTSB also notes that the NPRM does not address the qualifications of the instructors providing the required leadership and command training and believes that the effectiveness of this training can be impeded if this issue is not addressed in the final rule. The final rule should outline the minimum qualifications and experience of instructors who would provide this training. It should also address the importance of involving pilots who have significant line experience with the operator—either as instructors or facilitators—to help ensure that a connection exists between the course content and techniques for implementation in line operations. The NPRM also proposes to require training on mentoring skills for all PICs serving in Part 121 operations. The NTSB concurs with this aspect of the NPRM and recognizes the potential benefits of establishing a mentoring environment to help develop SICs. We also recognize that establishing this environment can and should be a duty of all PICs in their leadership role. The current proposal is adequate to provide baseline knowledge and skills to help align pilots to the importance of this process in the professional development of SICs. However, recognizing that—even with training—not everyone can be an effective mentor, the NTSB suggests that the mentoring proposal associated with this NPRM be expanded to accommodate identification and selection of a designated group of senior pilots who are trained under a separate program to serve as mentors to newly hired pilots. In addition, the NTSB strongly supports the NPRM’s proposal for Part 121 operators to establish and maintain a PPDC composed of pilot and management representatives to develop, administer, and oversee a formal pilot mentoring program. The PPDC would help establish a structured program of mentoring with defined parameters, management involvement and visibility, and top-down administration. Therefore, the NTSB believes that a PPDC would be an integral component to a mentor program and to any effort to enhance air carrier pilot professionalism. However, the NTSB disagrees with the NPRM’s proposal that the PPDC meet annually, as we believe that more frequent meetings would improve the visibility of this committee and its effectiveness in administering and overseeing a pilot mentoring program. We also note that the NPRM outlines qualifications for the management representative on the PPDC but does contain qualifications for the pilot representative and believe that this should be addressed in the final rule. The NPRM provides for credit for command and leadership and mentoring training taken before the effective date of the final rule, if the previous training meets the requirements and content of the training in the final rule. The NTSB strongly disagrees with this aspect of the NPRM because of the challenge that both operators and the FAA would face determining that training conducted before publication of a final rule and its associated guidance material is indeed equivalent to the final rule. Even though all prior training in this area would be beneficial and operators should not be discouraged in providing it to their pilots, the effectiveness of these new rules in mitigating instances of unprofessional behavior can be undermined if all pilots are not provided common training to ensure that they are baselined to the same standard instructional objectives. The NTSB appreciates the draft nature of the AC and believes that, in its final version, it will likely meet the intent of Safety Recommendation A-10-13. However, the draft AC remains a high-level framework for an instruction module. Its utility for providing usable guidance to operators developing leadership and command training programs (and its ability to meet the intent of Safety Recommendation A-10-13) will depend on expanded discussion and situational examples in the areas of professional standards of conduct, strategies for briefing and debriefing, and reinforcement and correction skills. In addition, the background section in the draft AC only contains discussion of the Pinnacle and Colgan accidents. The NTSB believes that this section would be improved with the addition of a more comprehensive list of recent pilot-involved events in both Part 121 and Part 135 operations associated with deviations from SOPs and other areas relevant to professionalism and leadership.

From: NTSB
To: FAA
Date: 1/11/2013
Response: We note that the FAA plans to address Safety Recommendation A-10-14 as it pertains to Part 121 operators in its upcoming notice of proposed rulemaking (NPRM) titled “Flight Crewmember Mentoring, Leadership and Professional Development.” We also note that the FAA plans to publish with the NPRM an advisory circular (AC) that will contain guidance on mentoring, leadership, and professional development. We believe that these actions may be responsive to Safety Recommendations A-10-13 and -14; however, we point out that leadership skills are essential for all upgrading captains, regardless of the operation. Therefore, we believe that the FAA should develop an AC that contains useful guidance for all operators. In addition, we urge the FAA to expand its rulemaking efforts to include Part 135 and 91K operators, as well. Pending our receipt and review of an AC and NPRM that addresses all Part 121, 135, and 91K operators, Safety Recommendations A-10-13 and -14, are classified OPEN—UNACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 9/24/2012
Response: -From Michael P. Huerta, Acting Administrator: Public Law (P.L.) 111-216, section 206, titled Flight Crewmember Mentoring, Professional Development and Leadership, required that the Federal Aviation Administration (FAA) initiate rulemaking with a notice of proposed rulemaking (NPRM) issued by August 1, 2011. In response to the P.L., the FAA chartered the Flight Crewmember Mentoring, Leadership and Professional Development Aviation Rulemaking Committee (ARC). The ARC consisted of several members of academia, industry, pilots, and the FAA. The ARC's recommendations were used to draft the Flight Crewmember Mentoring, Leadership and Professional Development NPRM. The NPRM entered executive level review on May 17, 2011, and the FAA anticipates publication of the NPRM in late 2012. The FAA believes the NPRM will address Safety Recommendations A-I 0-13 through -15 for part 121 operators. Along with the NPRM, an Advisory Circular (AC) on mentoring, leadership, and professional development will be written and published in the docket for public comment. The FAA's current rulemaking effort is focused on pilot mentoring and professionalism for part 121 operations. While part 135 and 91 K operators could elect to comply with the rule or AC. the FAA has no immediate plans to include part 135 and 91 K operators in this rulemaking effort. After the NPRM is published, the FAA will consider developing multimedia guidance materials beyond what the draft AC will provide in response to Recommendation A-10-15. I will keep the Board informed of the FAA's progress on this safety recommendation and provide an update by July 2013.

From: NTSB
To: FAA
Date: 4/30/2012
Response: Notation 8406: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled “Pilot Certification and Qualification Requirements for Air Carrier Operations,” which was published at 77 Federal Register (FR) 12374 on February 29, 2012. The notice proposes to create new certification requirements for pilots in air carrier operations, including requiring that first officers in 14 Code of Federal Regulations (CFR) Part 121 operations hold an airline transport pilot (ATP) certificate and type rating for the aircraft to be flown; allowing pilots with an aviation degree or military pilot experience but fewer than 1,500 hours total time as a pilot to obtain an ATP certificate with restricted privileges; and requiring at least 1,000 flight hours in air carrier operations to serve as pilot in–command (PIC) in Part 121 air carrier operations. The notice also proposes to modify the requirements for obtaining an ATP certificate with an airplane category multiengine class rating or type rating to require 50 hours of multiengine flight experience and completion of a new FAA-approved ATP certificate training program that would include academic training and training in a flight simulation training device. According to the NPRM, these changes would help to ensure that pilots entering an air carrier environment have the training and aeronautical experience necessary to adapt to a complex, multicrew environment in a variety of operating conditions. The NPRM cites the 2009 Colgan Air accident near Buffalo, New York, as an event that focused public, congressional, and industry attention on flight crew experience requirements and training for conducting Part 121 air carrier operations. In February 2010, the FAA published an advance notice of proposed rulemaking (ANPRM), titled “New Pilot Certification Requirements for Air Carrier Operations” (75 FR 6164, February 8, 2010) that sought input on current Part 121 eligibility, training, and qualification requirements for seconds-in-command (SICs). The current NPRM is based on comments in response to the ANPRM, input received from an aviation rulemaking committee established in July 2010, and statutory requirements for modifying ATP certification outlined in the Airline Safety and Federal Aviation Administration Extension Act of 2010 (Public Law 111-216). Adding to that foundation, the NPRM states that the FAA conducted a study of 61 NTSB investigation reports from fiscal year (FY) 2001 through FY 2010 (31 Part 121 accidents and 30 Part 135 air carrier accidents, with 107 fatalities, 28 serious injuries, and 44 minor injuries). The study showed that the accidents examined involved pilot deficiencies in aircraft handling, including stall and upset recognition and recovery, high altitude training, active pilot monitoring skills, effective crew resource management (CRM), stabilized approaches, operations in icing conditions, and hypoxia training. The NPRM asserts that the changes to air carrier pilot qualification would address, in part, 21 NTSB safety recommendations in the following areas: Safety Issue Recommendations Training flight crews to respond to sudden, unusual, or unexpected aircraft upsets: A-96-120, A-04-62, A-07-3, and A-09-113 Developing and conducting stall recovery training and providing stickpusher familiarization training for pilots of stickpusher-equipped aircraft: A-10-22 and -23 Training in high altitude operations: A-07-1 and -2 Training and guidance for rudder use in transport-category aircraft: A-02-2 Airport situational awareness: A-07-44 Stabilized approach concept: A 01 69 and A-08-18 Landing performance calculations: A-07-59 and A-08-41 CRM training: A-03-52 Pilot monitoring duties: A-10-10 Requirements for flight crewmember academic training regarding leadership and professionalism: A-10-15 Training in icing conditions: A-07-14 Hypoxia awareness training: A 00 110 Training in landing and taking off in crosswinds with gusts: A 10-110 and -111 The NTSB is generally supportive of the proposed rule as it relates to many of the issues previously identified in our safety recommendations. Specific comments on several areas of the NPRM follow. Academic Credit To Reduce Flight Experience Requirements Although the NTSB has not made recommendations for flight hour minimums for air carrier pilots (instead focusing its recommendations on specific procedures and training, needed regulations, and needed guidance to crews and operators), we stated in our comments on the ANPRM that: Ensuring a high level of knowledge, skills, and professionalism for flight crewmembers is essential, but total flight hours or an airline transport pilot certificate does not necessarily equate to the level of knowledge, skills, and professionalism required for consistently safe flight operations. The comments went on to state that, “the NTSB recognizes the value of academic training for air carrier pilots, but the NTSB also believes that academic training is not a substitute for practical experience.” An important tenet in the recent NPRM is the concept that, “in certain circumstances, the combination of focused academic training and structured flight training can substitute for actual flight experience” (p. 12379). The NTSB concurs with the FAA’s acknowledgement that there may be multiple pathways to becoming a qualified air carrier pilot. However, there remain unresolved issues for how academic credit should be applied, including student performance within an accredited academic program and the type of degree conferred. These issues are not addressed in the NPRM and require more evaluation before this proposal is implemented. It is essential that the content and rigor involved in academic training be clearly defined and, most importantly, appropriate resources allocated to conduct evaluation and oversight of these alternative methods of qualification. ATP Certification Training Program The NPRM discusses the establishment of an FAA-approved ATP certificate training program for a multiengine class ATP or type rating. The proposed training program outlined under section 61.154 would include 24 hours of classroom training and 16 hours of simulator training (8 in a full flight simulator of at least Level C standards) and is intended to provide pilots with the core knowledge and understanding in areas critical to operating high performance aircraft in a complex and high altitude environment. The training would be provided by an authorized training provider and would be required to be completed before a pilot would be eligible to take the ATP knowledge test. Issued as part of the NPRM, draft Advisory Circular (AC) 61-ATP, “Airline Transport Pilot Certification Training Program for Airplane Category Multiengine Class Rating or Type Rating,” contains an outline of the curriculum topics and objectives for both the classroom and simulator training making up this training program. The AC is intended for use by training providers when developing the program and by the FAA when reviewing and approving the programs. Many of the topics contained in the draft AC address issues from NTSB safety recommendations; in fact, the FAA notes that most of the 21 recommendations cited in the NPRM are addressed, in part, by the proposed amendments and advisory material. Although the NTSB concurs with the FAA’s assessment that, in most cases, the topics addressed will serve to partially satisfy the action requested in existing recommendations, the amount of specificity provided in the proposed rule and AC does not allow a comprehensive review of the degree to which the FAA’s proposed actions would satisfy the intent of the NTSB’s recommendations. In some instances, neither document provides evidence that a recommendation topic is addressed. The NTSB notes that recent safety recommendations in this area have focused on attempts to improve crew response to in-flight emergencies, including task prioritization and training. While AC 61-ATP does include a classroom training objective named “differences between emergency and non-normal checklist procedures and checklists,” the guidance on emergency procedures should be made more explicit to incorporate the issues identified in these NTSB recommendations. CRM is another topic relevant to previous NTSB recommendations and outlined in AC 61-ATP. However, the list of proposed topics in the AC does not explicitly refer to the importance of first officer assertiveness, which is an issue addressed in Safety Recommendation A-11-39. This recommendation is not cited in the NPRM, but the NTSB believes that it is within the scope of the draft advisory material and suggests amending the AC to include information consistent with Safety Recommendation A-11-39 to help support this important aspect of CRM. The NTSB is encouraged that the NPRM proposes to centralize the process for approving ATP certification training programs. Specifically, the NPRM states that only authorized training providers can administer the training required under section 61.154. These providers can be certificate holders providing training and operating under Parts 141, 142, 121, or 135, and each provider must receive approval of their ATP certification training program by the FAA Air Transportation Division (AFS-200). The NTSB notes that, theoretically, centralization should help to ensure standardization of these programs, but suggests that additional guidance documentation with more specific and robust detail about the content of the proposed training is necessary to provide a solid foundation on which the FAA can evaluate the program content (and to assist training providers to develop courses likely to receive FAA approval). For example, additional detail, such as cross-referencing material from draft AC 120-STALL, would be appropriate in the discussion of stall training in AC 61-ATP. In addition, the FAA will need to provide the appropriate oversight resources to these programs—not only in their initial approval but also to conduct ongoing oversight to demonstrate that the content delivered is consistent with the approved program. The rigor with which these programs are implemented and overseen will determine their ultimate influence on improving safety in air carrier operations. Pilot-in-Command Requirements for Air Carrier Operations The NPRM proposes primarily experience-based requirements for new PICs in air carrier operations. However, the NTSB has previously issued safety recommendations addressing the need for a specific leadership training course for upgrading captains. Although the NPRM cites Safety Recommendation A-10-15 and describes it as applicable to leadership and professionalism training, it addresses only the latter topic. The NPRM does not mention Safety Recommendations A-10-13 and -14, which were issued with -15, but the NTSB believes that a leadership training course for upgrading captains is within the scope of the proposed rulemaking and that section 121.436 should be amended to include a specific requirement for such a course. In addition to the requirements already outlined in section 121.434, the NTSB has recommended that Part 135 pilots who need a type rating for the aircraft they fly be required to have a minimum level of initial operating experience. Given the applicability of the NPRM to Part 135 pilots who are engaged in air carrier operations, the NTSB believes it would be appropriate to incorporate similar experience requirements for these pilots as exist for Part 121 pilots. The NTSB supports the use of simulators in training environments and notes that the training program outlined in the NPRM specifies that training on topics such as low energy states/stalls and upset recovery techniques will be conducted in a Level C or higher full-flight simulator. Simulators, regardless of their fidelity, are dependent on their physical limits of motion, as well as the efficacy of the available computer programs (which are often limited in issues of upset training because of the lack of flight test data at the extreme areas of the flight envelope). Simulators are not always adequate in portraying upsets and stalls and may inadvertently introduce negative training. Consistent with Safety Recommendation A-04-62, the FAA should allow flexibility in determining what level of simulation or automation is appropriate for specific training. Summary Observations This NPRM addresses many training issues applicable to becoming an air carrier pilot, including some critical issues demonstrated in recent accident history to be responsible for accidents. The NTSB is encouraged that its recommendations were considered in the development of this proposed rule, especially as the issue areas relate to the core content to be provided to new entrant pilots through the ATP certification training program. However, the intent of our recommendations in this area is for all pilots to receive training in these topics. Therefore, it is important that air carriers provide equally robust training in these topic areas for their current air carrier pilots on a recurrent basis. The NTSB appreciates the opportunity to comment on this NPRM.

From: NTSB
To: FAA
Date: 7/15/2011
Response: Notation 8106A: The National Transportation Safety Board (NTSB) has reviewed the Federal Aviation Administration's (FAA) supplemental notice of proposed rulemaking (SNPRM) titled "Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers," published at 76 Federal Register 29336-29526 on May 20, 2011. The notice proposes to amend the regulations for flight and cabin crewmember and aircraft dispatcher training programs in domestic, flag, and supplemental operations. The proposed regulations are intended to contribute significantly to reducing aviation accidents by requiring the use of flight simulation training devices (FSTD) for flight crewmembers and including additional training and evaluation requirements for all crewmembers and aircraft dispatchers in areas that are critical to safety. The proposal also reorganizes and revises the qualification, training, and evaluation requirements. The SNPRM is based on the FAA's review of comments submitted in response to the January 12, 2009, notice of proposed rulemaking (NPRM) on these issues and its determination that the NPRM did not adequately address or clarify some topics; it is also based on provisions of the Airline Safety and Federal Aviation Administration Extension Act of 2010. This recommendation asks for the development of guidance on leadership training for upgrading captains. The SNPRM includes extensive discussion of leadership and training for upgrading captains, but the development of this needed guidance is likely to occur outside of the rulemaking process. Therefore, while this recommendation is related to the subjects covered by the SNPRM, implementation of the associated final rule will not close this recommendation.

From: NTSB
To: FAA
Date: 1/25/2011
Response: The NTSB asks the FAA to provide additional information to clarify how it plans to address Safety Recommendation A-10-13. The FAA's letter only indicates that the FAA will review the options available to require or foster compliance with the guidance developed in response to Safety Recommendation A-10-13, but it does not address the FAA's planned response to the recommendation. Because it appears that the FAA plans to take the recommended actions, Safety Recommendations A-10-13 and -14 are classified OPEN – ACCEPTABLE RESPONSE pending the receipt of additional information and completion of the recommended actions.

From: FAA
To: NTSB
Date: 6/22/2010
Response: MC# 2100243 - From J. Randolph Babbitt, Administrator: We understand that the Board wants the FAA to develop a specific course that complies with the guidance developed in response to Safety Recommendation A-l0-13. This course would include, but not necessarily be limited to, such items as methods and techniques for leadership, professional standards of conduct, and other items necessary for a pilot in command to affect the safe conduct of a flight. The FAA will review the options available to require or foster compliance with guidance developed in response to Safety Recommendation A-10-13 and will provide an update on our actions and progress by December 2010.