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Safety Recommendation Details

Safety Recommendation A-10-110
Details
Synopsis: On December 20, 2008, about 1818 mountain standard time, Continental Airlines flight 1404, a Boeing 737-500, N18611, departed the left side of runway 34R during takeoff from Denver International Airport (DEN), Denver, Colorado. A postcrash fire ensued. The captain and 5 of the 110 passengers were seriously injured; the first officer, 2 cabin crewmembers, and 38 passengers received minor injuries; and 1 cabin crewmember and 67 passengers (3 of whom were lap-held children) were uninjured. The airplane was substantially damaged. The scheduled, domestic passenger flight, operated under the provisions of 14 Code of Federal Regulations (CFR) Part 121, was departing DEN and was destined for George Bush Intercontinental Airport, Houston, Texas. At the time of the accident, visual meteorological conditions prevailed, with strong and gusty winds out of the west. The flight operated on an instrument flight rules flight plan.
Recommendation: TO THE FEDERAL AVIATION ADMINISTRATION: Gather data on surface winds at a sample of major U.S. airports (including Denver International Airport) when high wind conditions and significant gusts are present and use these data to develop realistic, gusty crosswind profiles for use in pilot simulator training programs.
Original recommendation transmittal letter: PDF
Overall Status: Closed - Acceptable Alternate Action
Mode: Aviation
Location: Denver, CO, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA09MA021
Accident Reports: Runway Side Excursion During Attempted Takeoff in Strong and Gusty Crosswind Conditions Continental Airlines Flight 1404, Boeing 737-500, NN18611
Report #: AAR-10-04
Accident Date: 12/20/2008
Issue Date: 7/29/2010
Date Closed: 1/10/2017
Addressee(s) and Addressee Status: FAA (Closed - Acceptable Alternate Action)
Keyword(s): Training and Education

Safety Recommendation History
From: NTSB
To: FAA
Date: 1/10/2017
Response: We note that, as one method of meeting the requirements specified in your March 30, 2016, final rule, “Flight Simulation Training Device [FSTD] Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks,” you developed gust models that are based on wind data from this accident and that are available as guidance material for FSTD sponsors. We also note that FSTD sponsors may propose other gust models, as long as a statement of compliance is provided describing the source data used to construct their gusting crosswind profiles. We continue to believe that training simulators should incorporate multiple gusty crosswind profiles to help ensure that pilots learn how to respond to realistic gusty crosswind conditions, rather than to just one specific model. However, we note that you developed a gusty crosswind profile that incorporates conditions similar to those encountered by the accident pilots. You also developed minimum FSTD evaluation requirements that include implementing realistic gusting crosswind profiles, which have been tuned in intensity and variation to require pilot intervention to avoid runway departure during takeoff or landing roll. Because these actions represent an acceptable alternate solution, Safety Recommendation A-10-110 is classified CLOSED—ACCEPTABLE ALTERNATE ACTION.

From: FAA
To: NTSB
Date: 9/28/2016
Response: -From Michael P. Huerta, Administrator: The Federal Aviation Administration (FAA) published the Flight Simulation Training Device (FSTD) Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks'' Final Rule on March 30, 20 16 (81 FR 18177). In its letter dated July 21, 2016, the Board stated that if only one gusty crosswind profile is available, pilots will learn how to respond to that specific model, rather than to realistic-and varying-gusty crosswind conditions. This final rule codified minimum FSTD evaluation requirements that include the implementation of·· ... realistic gusting crosswind profiles that have been tuned in intensity and variation to require pilot intervention to avoid runway depat1urc during takeoff or landing roll. In response to comments on the notice of proposed rulemaking. the FAA developed examples of gusting crosswind profiles and provided them as guidance material which was published with the final rule as part of a National Simulator Program FSTD Qualification Guidance Bulletin. These gust models were developed using Board-provided wind extractions from the Continental 1404 accident and were simplified to allow for ease of implementation on older. ··grand fathered·· training simulators. The FAA conducted informal testing of these gust models on an FAA Boeing 737-800 simulator using several FAA and non-FAA pilots and found that the implemented gust models were both realistic and significantly increased the difficulty level of takeoff maneuvers as compared to steady state crosswinds of a similar magnitude. Furthermore. since the gust models may be used on other simulators that represent different aircraft, the FAA provided implementation and tuning recommendations in the guidance material that would allow for the use of the models on aircraft types other than the Boeing 73 7-800 which may have different crosswind limitations. Finally, since the FAA-developed gust models were provided as guidance material which may be used by FSTD sponsors as one method to meet the rule requirements. this does not preclude an FSTD sponsor from developing other models that may be more suitable for use in their training program. As required by the final rule. other gust models may be proposed by FSTD sponsors where a statement of compliance is provided that describes the source data used to construct their gusting crosswind profiles. Similar to the existing windshear qualification requirements. The basic wind profiles are used to demonstrate the FSTD's ability to implement realistic gusting crosswinds for FSTD qualification purposes, but other models may be developed to support a particular operator's training needs. The new requirements will be mandatory for all Level C and Level D FSTDs that are initially qualified after the effective date of the final rule (plus any applicable grace period as allowed for in part 60 when the FAA changes FSTD qualification standards). After March 2019, any previously qualified or grandfathered FSTD being used for training credit in takeoff and landing in gusting crosswind must meet the new modeling requirements in the PSTD Directive that was published with the final rule. I believe the FAA has effectively addressed this safety recommendation and consider our actions complete.

From: NTSB
To: FAA
Date: 7/21/2016
Response: We are aware that, on March 30, 2016, you published a final rule, titled “Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks.” This final rule revised the standards in Title 14 Code of Federal Regulations Part 60 regarding performance standards for flight simulation training devices (FSTD). We are pleased that the rule includes, among other things, qualification performance standards that require FSTDs to be able to simulate gusty crosswinds on takeoff. We also note that you have developed, for use in FSTDs, a single gusty crosswind profile that incorporates conditions similar to those encountered by the accident pilots. We are concerned, however, that if only one gusty crosswind profile is available, pilots will learn how to respond to that specific model, rather than to realistic—and varying—gusty crosswind conditions. Therefore, we encourage you to develop multiple gusty crosswind profiles and to give instructors the capability to choose a profile from the options available. Pending the development of additional gusty crosswind training profiles that address our concern, Safety Recommendation A 10-110 remains classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: NTSB
To: FAA
Date: 12/9/2015
Response: This recommendation has two parts (1) the development of gusty crosswind profiles based on a survey of gusty surface wind conditions at airports and (2) the use of this data in flight simulation training devices (FSTD) to develop appropriate pilot training scenarios. In our October 2, 2014, comments on the notice of proposed rulemaking (NPRM) titled “Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks,” we stated that the proposal to include Qualification Performance Standards (QPS) that will require FSTDs to be able to simulate gusty crosswinds on takeoff, responds to the second part of Safety Recommendation A-10-110. However, we expressed concern with your response to the first part of Safety Recommendation A-10-110, the sources of information that would be used to develop the gusty crosswind profiles. We are aware of your efforts to develop and test profiles that incorporate conditions similar to those encountered by the accident pilots, which we believe could constitute an acceptable alternate solution to the first part of the recommendation. Accordingly, pending implementation of a final rule based on the NPRM and our receipt and review of gusty crosswind training profiles that address the concern described above, Safety Recommendation A-10-110 is classified OPEN—ACCEPTABLE ALTERNATE RESPONSE.

From: FAA
To: NTSB
Date: 9/2/2015
Response: -From Michael P. Huerta, Administrator: As we reported in our September 6, 2013, letter, while some simulators are programmed for gusty crosswind profiles, it is not a minimum requirement for Flight Simulator Training Device qualification under part 60. The Federal Aviation Administration (FAA) intends to define such minimum requirements in the upcoming proposed changes to part 60. We approved the part 60 rulemaking action plan, "Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training," on May 1, 2012, and published the notice of proposed rulemaking (NPRM) on July 10, 2014. The comment period closed on January 6, 2015, and the team is reviewing and dispositioning the comments in preparation of drafting the final rule. On November 12, 2013, the FAA published a final rule, titled •'Qualification, Service and Use of Crewmembers and Aircraft Dispatchers." It is also known as the Crewmember and Dispatcher Training 'final rule. In this final rule, the FAA addressed NTSB Safety Recommendation A-10-111 through amendments to Part 121 Appendix E and Appendix F, which include new requirements for crewmember training and evaluation in crosswind takeoff and crosswind landing with gusts. As mentioned in the preamble to the Crewmember and Dispatcher Training final rule, the FAA recognizes that not all full flight simulators are currently capable of replicating wind gusts and the agency is "... reviewing simulator capabilities as part of a separate rulemaking." The part 60 NPRM fully addresses simulator capabilities with regards to wind gusts and proposes simulator fidelity requirements that would directly support the training tasks required by the Crewmember and Dispatcher Training final rule. I believe these rulemaking efforts are responsive to the intent of these recommendations and will provide an update to the part 60 rulemaking by February 2016.

From: NTSB
To: FAA
Date: 10/2/2014
Response: We have reviewed the Federal Aviation Administration’s (FAA) notice of proposed rulemaking (NPRM) titled “Flight Simulation Training Device Qualification Standards for Extended Envelope and Adverse Weather Event Training Tasks,” published at Federal Register 39462-39753 on July 10, 2014. This recommendation has two parts (1) the development of gusty crosswind profiles based on a survey of gusty surface wind conditions at airports; and (2) the use of this data in FSTDs to develop appropriate pilot training scenarios. The NPRM proposes QPS that will require FSTDs to be able to simulate gusty crosswinds on takeoff, responding to the second part of Safety Recommendation A-10-110. However, we are concerned about the first part of Safety Recommendation A-10-110, the sources of information that will be used to develop the gusty crosswind profiles. Although implementation of a final rule based on the NPRM may satisfy this recommendation, that determination will be based on the suitability of the sources of information for the profiles. This recommendation is currently classified “Open—Unacceptable Response.”

From: NTSB
To: FAA
Date: 12/26/2013
Response: We do not believe that the wind gusts used in the Windshear Training Aid (WTA) models are similar to those encountered by the accident pilots during their takeoff roll. Specifically, we are concerned that the gusts in the WTA models are used in the air for windshear and do not replicate the ground-level disturbances and gusting crosswinds that often occur at, or near, the runway surface. We continue to believe that available data on surface winds may be adequate to accomplish the intended training objectives; however, we point out that the profiles must incorporate conditions similar to those encountered by the accident pilots in order to be responsive to this recommendation. Accordingly, pending our receipt and review of gusty crosswind training profiles that address the concern described above, and completion of the recommended action, Safety Recommendation A-10-110 is classified OPEN--UNACCEPTABLE ACTION.

From: FAA
To: NTSB
Date: 9/6/2013
Response: -From Michael P. Huerta, Administrator: As the Federal Aviation Administration (FAA) reported in its November 6, 2012, letter to the Board, while some simulators are programmed for gusty crosswind profiles, it is not a minimum requirement for Flight Simulator Training Device (FSTD) qualification in part 60. The FAA intends to define such minimum requirements in the upcoming proposed changes to part 60; the anticipated publication date of the notice of proposed rulemaking is December 2013 with a final rule anticipated in 2015. In its March 13, 2013, letter, the Board requested additional details about the data contained in the Windshear Training Aid (WTA). The WTA contains several simulator wind models that are derived from estimated wind data associated -wil'l1 windshear related accidents and incidents. These data were compared with Doppler radar measurements of micro bursts as part of the Joint Airport Weather Studies project to confirm the shear rate, shear magnitude, wind duration, and overall shape of the wind model. Section 4.3.5 of the WTA (enclosed) concerning the development of wind models and related substantiation contains additional details. While the basic WTA simulator wind models are generally used to provide longitudinal and vertical wind components to achieve the windshear recovery training objectives, this data can also be used to build baseline gusty crosswind profiles by simply realigning the direction and adjusting the variability of the wind models. Furthermore, the WT A contains additional "complex" wind models with varying crosswind components which can also be adjusted for use during takeoff roll wind encounters. These baseline wind models, combined with subjective tuning of the models for the desired characteristics (taking positive action to avoid runway departure during the takeoff roll), should be sufficient to achieve the required training objectives. This methodology for tuning representative wind models from the WT A has been used very successfully for a number of years to qualify FSTDs for windshear training. The Qualification, Service, and Use of Crewmembers and Aircraft Dispatchers Supplemental Notice of Proposed Rulemaking (SNPRM) proposes to require part 121 operators to train in gusty wind scenarios, including crosswinds with gusts (76 FR 29335). The FAA reviewed the comments submitted to the SNPRM and the final rule is in executive review. We will consider requiring this training for additional rule parts in the future if they become cost justified. I will keep the Board informed of the FAA's progress on these recommendations and provide an update by September 30, 2014.

From: NTSB
To: FAA
Date: 3/13/2013
Response: Although we agree with the FAA that available crosswind profiles may be adequate to accomplish the intended training objectives, we would like to know whether the data contained in the Windshear Training Aid are empirically based and whether they include dynamic, highly variable crosswinds similar to those encountered by the crew of Continental Airlines flight 1404. Pending our receipt and review of this information and completion of the recommended action, Safety Recommendation A-10-110 remains classified OPEN—ACCEPTABLE RESPONSE.

From: FAA
To: NTSB
Date: 11/6/2012
Response: -From Michael P. Huerta, Acting Administrator: Since our October 14, 2010, letter, the Federal Aviation Administration (FAA) has reviewed the existing wind data available. The FAA believes that adequate data is available in the public domain (e.g . in the publicly available Windshear Training Aid, available through the National Technical Information Service) to enable the development of realistic. Gusty crosswind profiles by simulator operators that are tailored to their particular training program requirements. Combined with subjective assessment and tuning with a competent subject matter expert pilot, the FAA believes such crosswind profiles should be adequate to accomplish the intended training objectives. While some simulators are programmed for gusty crosswind profiles, it is not a minimum requirement for Flight Simulator Training Device (FSTD) qualification in part 60. The FAA intends to define such minimum requirements in a proposed change to part 60. A part 60 application for rulemaking was approved by the FAA Rulemaking Council on November 1, 2011, to address this and other FSTD technical qualification requirements. A Rulemaking Action Plan for part 60 was approved by the FAA Rulemaking Council on May 1, 2012. In accordance with this rulemaking action plan, we anticipate publishing a notice of proposed rulemaking for part 60 in 2013. To require operators training under part 121 to train in gusty wind scenarios, the Qualification, Service, and Use of Crew members and Aircraft Dispatchers Supplemental Notice of Proposed Rulemaking (SNPRM), published for public comment on May 20, 2011, includes crosswinds with gusts as a training element. The comment period for the SNPRM originally closed on July 19, 2011, but was extended to September 19, 2011. We are still reviewing comments received to the SNPRM, and anticipate publishing a final rule in late 201 3. The FAA will consider requiring this training for additional rule parts if they become cost justified. We believe these rules will be responsive to the intent of these recommendations. I will keep the Board informed of the FAA's progress on these recommendations and will provide an update by September 30, 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: 12/16/2011
Response: The FAA indicated that flight simulators have the technical capability, correct programming, and data input to handle wind profiles with gusts, and the agency plans to work with the aviation industry to develop methods to collect and use data to create wind profiles that include gusts. Accordingly, pending completion of the recommended actions, Safety Recommendations A-10-110 and -111 are classified OPEN—ACCEPTABLE RESPONSE.

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. The NTSB did not find any provisions in the proposed training subjects that would address training for high gusty crosswinds. The NTSB believes this rulemaking to be appropriate for the subjects and urges the FAA to include them.

From: FAA
To: NTSB
Date: 10/14/2010
Response: CC#201000393: - From J. Randolph Babbitt, Administrator: Current simulators do allow for training profiles that include wind gusts if the wind data are available and the simulator software is programmed for it. The FAA will work with industry to determine how sample wind data could be collected and the feasibility of using that data for the development of wind profiles that include gusts.