DRAFT

# WHITE PAPER

**[CHANGES IN GENERAL AVIATION\
FLIGHT OPERATIONS\
AND THEIR IMPACT ON\
SYSTEM SAFETY AND FLIGHT TRAINING]{.underline}**

## Robert A. Wright

Manager, General Aviation and Commercial Division (AFS-800)

Flight Standards Service

800 Independence Avenue SW

Washington, DC 20591

April 2002

Version 2.0

### 

### 

#### INTRODUCTION

The purpose of this white paper is to identify recent and impending
changes in general aviation flight operations that may require new
approaches to pilot training and related activities. This paper will
identify such changes within the framework of current regulatory and
system safety metrics as well as new system safety models. It will then
identify the elements needed to apply these concepts to new flight
training tools and Federal Aviation Administration (FAA)/ industry
training standards to maintain or improve system safety and maintain or
increase general aviation's integration in the National Airspace System
(NAS).

This paper is NOT a precursor to major regulatory proposals but rather
will suggest approaches adaptable to partnership with the general
aviation community. The approaches suggested will focus on risk
management and aeronautical decision making techniques, training and
education, and appropriate use of new cockpit and other flight
technologies. They will focus on incentives for compliance rather than
mandates.

This paper was prepared by the Manager of the General Aviation and
Commercial Division with limited consultation with the staff of that
division. As such I take full responsibility for the paper's content.
Accordingly, this document does NOT represent official FAA policy or
proposals for policy change. The purpose is to stimulate responsible
discussion within the aviation community regarding the need for improved
approaches to flight training.

I invite interested parties to comment on this paper. Write to the
address on the cover or send an email (<Robert.Wright@faa.gov)>.

#### CONTENTS

##### Background

I.  The Current Regulatory and System Safety Environment for General
    Aviation

II. Emerging Changes in System Safety Philosophy

III. The Impact of an Evolving NAS on General Aviation Flight Operations

IV. A Modernized Approach to General Aviation Flight Training

V.  Obstacles to Improved Flight Training Policies and Procedures

VI. A New Approach to Training Standards Development and Application

VII. A Strategy for Evolutionary but Responsive Change

###### BACKGROUND

General aviation constitutes the vast majority of the civil aircraft
fleet in the United States and performs a variety of critical functions
ranging from flight training for most pilots to medical evacuation and
law enforcement. Increasingly, general aviation is also providing a
viable air transportation complement to the air carrier "hub and spoke"
system. Corporate aviation and on-demand air taxis have provided such
service for some time and new forms of general aviation are expanding
these alternatives.

General aviation safety has been improving continuously for nearly 25
years and accidents continue to decrease even as activity increases. It
appears, however, that the fatal accident rate may have reached a
plateau. The leading causes of general aviation fatal accidents are
related to weather and loss of control. If general aviation growth
becomes even more pronounced, a major challenge for the community will
be to decrease accident rates to maintain and increase public
acceptability of general aviation as a form of air travel.

Many new developments have taken place that will have a pronounced
effect on general aviation flight operations and, consequently, general
aviation training. The complexity of the airspace will increase as the
NAS is modernized and the FAA's Operational Evolution Plan (OEP) takes
effect. These changes will be magnified as new cockpit and other flight
technologies are introduced and advanced airspace concepts such as Free
Flight emerge. New airspace and other operational changes will also be
inevitable to accommodate aviation security concerns following the
terrorist attacks of September 11, 2001.

General aviation will also be impacted positively by the introduction of
new aircraft and new approaches to shared ownership of these aircraft.
The general flying public, especially those who are not pilots but seek
air travel alternatives to the airlines, are currently benefiting from
fractional ownership schemes. Similar owner-pilot shared ownership
programs are emerging for pilots who wish to use small piston engine
aircraft.

The emergence of new lower cost turbine aircraft could benefit both
groups.

The common denominator in all these changes is the need to have an
adaptable flight training system that will not only maintain but greatly
improve the safety and utility of general aviation flight operations. To
accomplish this challenging goal, it is necessary to examine such
training in the context of both the current general aviation system
safety environment as well as emerging changes in system safety
philosophy. Modernized approaches to flight training systems, policies,
and procedures can then be examined and a mitigation strategy devised.

I.  THE CURRENT REGULATORY AND SYSTEM SAFETY ENVIRONMENT FOR GENERAL
    AVIATION

The FAA's mandate with regard to oversight of general aviation safety
was originally contained in the Federal Aviation Act of 1958 and is
currently contained in Title 49, United States Code. Section 44701 of
Title 49 clearly allows, in fact, mandates that the FAA Administrator
shall differentiate between air transportation (air carriers engaged in
common carriage) and "other air commerce". With respect to air
transportation, Section 44701 mandates that the FAA shall "consider the
duty of an air carrier to provide service with the highest possible
degree of safety in the public interest". Title 49 is silent on the
standard to be applied to "other air commerce" but gives the FAA
Administrator discretion in setting such a standard.

The FAA, through policy directive, has established a standard for other
air commerce in the Policy Statement of the Federal Aviation
Administration (Order 1000.1A). Chapter 2 of that directive states, in
part, that "...in regulating segments of aviation other than for hire,
the FAA will pursue a regulatory policy that...balances the rights of
individuals to accept personal risk against society's interest in the
safety of the individual...limits the individual's right to incur risk
when the exercise of that right creates a risk for others... regulates
in a manner that recognizes the need to protect the public interest".

To carry out its statutory responsibilities with regard to safety, the
FAA has established a safety oversight system. Until recently this
system was based largely on a combination of regulations, certification
(of air carriers and other air operators, airmen, aircraft, and other
entities), inspection, surveillance, and enforcement. These functions
were not correlated in a true system safety approach and other functions
such as safety education, communication of safety information, best
practice promulgation, and flight technology leverage served mainly as
peripheral activities. Since about 1996, the FAA's Flight Standards
Service has been developing a more holistic system safety approach for
air carrier oversight. The FAA began developing a general aviation
system safety model in 2000. These efforts are discussed in Section III.

It is important to note that, other than establishing the basic
regulations for certification of aircraft, airmen, and some other
entities, the level of FAA involvement in certification, inspection,
surveillance, and enforcement of general aviation activities is only a
fraction of that devoted to air carrier oversight. For example, industry
designees, rather than FAA inspectors, perform virtually all airmen
certification work. Accordingly, one may attribute the continually
improving general aviation safety record to a combination of industry
actions and FAA actions other than the oversight methods mentioned in
the previous paragraph. These could, for example, include better
industry training methods, the introduction of new flight technology,
the impact of the FAA's Aviation Safety Program for educational
seminars, and/or some other factors.

The current regulatory infrastructure promulgated by FAA to support
general aviation is contained in several parts of the Federal Aviation
Regulations (FAR), but the ones most relevant to general aviation flight
training and related activities are Part 61 (Certification: Pilots,
Flight Instructors, and Ground Instructors) and Part 141 (Pilot
Schools). These regulations last received a major revision in 1997, as
the second phase of a three-phase program to update them (the last
comprehensive revision having occurred in 1973). The third phase of the
regulatory review was to have addressed the impact of new flight
technologies on general aviation certification and training. This phase
was is proceeding very slowly as a result of other rulemaking
priorities.

Actual general aviation ground and flight training is based around
specified aeronautical knowledge, flight proficiency, and aeronautical
experience requirements specified in Parts 61 and 141. The training is
generally structured to prepare the applicant to pass both the knowledge
test and the practical test specified in the FAR's. Some industry
observers, FAA officials, and others believe this approach fosters a
tendency to "teach to the test" rather than prepare applicants to
operate safely in a complex NAS.

While the above arguments may or may not have merit, further exploration
of these issues is clearly warranted and will be discussed in Sections
III and V of this paper. The FAA believes it has fulfilled its
responsibility under Title 49 to establish minimum standards for "other
air commerce", and a case can be made that this system has served us
well up to this point. Emerging changes in system safety philosophy and
changes in NAS flight procedures and in flight technologies may call for
a new approach to flight training. These issues will be discussed in
Sections III and IV.

III\. [EMERGING CHANGES IN SYSTEM SAFETY PHILOSOPHY]{.underline}

In 1995, the FAA Administrator commissioned a study of regulatory
approaches needed for FAA to fulfill its future safety oversight
responsibility in an era of exploding industry growth, great changes in
flight technology, and static or declining resources. The cornerstone of
this initiative, Challenge 2000, was a study conducted by a major
national consulting firm. The study, concluded in 1997, had many
findings and recommendations but a centerpiece concept was that a new
system safety model was needed to replace the existing one built on
regulations, certification, inspection, surveillance, and enforcement.

A key concept of the study postulated that the current system of minimum
standards was outmoded and recommended, among other concepts, more
reliance on industry "best practices" as a means to achieve higher
levels of safety.

In 1996, following a major air carrier accident, the FAA Deputy
Administrator led a 90- day safety review that corroborated many of the
Challenge 2000 findings and, among other steps, resulted in initiating
the air carrier system safety concept which has become the Air
Transportation Oversight System (ATOS). The ATOS concept continues to be
developed and is being incrementally implemented.

With respect to general aviation, a companion system safety initiative
was begun in 2000 and has become the System Safety Approach for General
Aviation (SAGA). Although SAGA is still in its infancy with regard to
system development, it seeks to achieve higher levels of safety beyond
those that might be achieved with only a regulatory model based solely
on compliance with minimum standards. The centerpiece concepts around
which SAGA is based focus on risk management/ aeronautical
decision-making, education and training, and appropriate use of new
flight technologies to achieve higher safety levels.

Another major safety initiative begun in the last few years that has had
an important impact on system safety philosophy has been the Safer Skies
program. This program is a joint FAA/industry program that, based on
extensive data analysis, targets those safety issues most likely to
impact fatal accident causality. FAA/industry partnerships have been
created for both air carrier and general aviation interests. The general
aviation focus areas include weather, controlled flight into terrain
(CFIT), aeronautical decision-making, runway incursions, approach and
landing, loss of control, and survivability. The initiatives begun to
date include the first four above and these efforts have developed
accident-mitigating approaches that reflect a strong system safety
strategy.

The system safety model for general aviation, SAGA, is developing a
targeted approach to the diverse general aviation community on the
premise that "one size doesn't fit all".

Within the General Aviation and Commercial Division, we are structuring
our programs around five "lines of business" which reflect the varied
purposes of general aviation flight operations. These have been
identified as follows:

1.  Transportation (corporate, business, personal )

2.  Commercial Operations (external load, agricultural, etc.)

3.  Training providers (Pilot Schools and Training Centers)

4.  Airman certification (instructors, examiners)

5.  Sport and recreational aviation (ultralights, parachuting, other
    recreational)

Each of these lines of business will generate unique approaches to
achieving system safety under SAGA. The middle three categories above
will be highly specialized while the sport and recreational segment will
rely heavily on delegation of functions to the community itself, in
keeping with the FAA safety mandate described in Section II.

The transportation segment will receive special attention because of
public interest in air travel options to complement hub-and-spoke air
carrier travel and the FAA's greater responsibility to such activity
under Title 49. In this segment we must further sub-divide the community
into two major categories. One category consists mainly of two pilot
professionally flown operators using turbine aircraft and offering air
taxi, fractional ownership, and corporate transportation. This category
of user has achieved an admirable safety record comparable to that
achieved by scheduled air carriers.

The other transportation sub-segment is an emerging class of single
pilot owner or professionally flown operators using piston or small
turbine-powered aircraft and providing the same services as the
corporate segment, as well as personal and business air travel. This
category of general aviation is quite broad and, although its safety
record is improving, their accident rates are not as good as those
achieved by large corporate operators.

From a system safety strategy perspective, the FAA should place its
highest general aviation safety priorities on those operations that
provide transportation services (as opposed to recreational activity)
and have failed to achieve levels of safety adequate to meet FAA's
statutory responsibilities and public expectations. With respect to
sport and recreational flying, the FAA's main responsibility is to
protect non-participants (persons or property on the ground or in other
aircraft) and secondarily to prescribe minimum standards for the
participants.

In accordance with this analysis, the discussion of strategies relating
to flight training philosophy and improved standards in Sections V
through VIII will focus on single pilot owner or professionally flown,
piston or small turbine-powered aircraft used for travel in air taxi,
business, owner-flown shared ownership, and personal air travel. The
concepts developed will also have broad applicability to other classes
of operators.

[IV. THE IMPACT OF AN EVOLVING NAS ON GENERAL AVIATION FLIGHT
OPERATIONS]{.underline}

The FAA's plan to modernize the NAS, in particular the near term
activities covered by the Operational Evolution Plan (OEP), will have an
important impact on general aviation flight operations and training. New
flight technologies are becoming available to enable general aviation
operators to take advantage of the modernized NAS, as well as to improve
situational awareness, and hence safety, during flight operations.
Finally, several FAA and National Aeronautics and Space Administration
(NASA) programs are developing new technologies, procedures, and
capabilities that are intended to improve general aviation safety and
utility.

The OEP is emphasizing both new air traffic control (ATC) technologies
and aircraft flight technologies as a means of implementing near term
(0-10 years) NAS modernization. A detailed description of the OEP is
beyond the scope of this paper but the relevant capabilities being
targeted include area navigation (with airspace redesign), new terminal
instrument procedures, increased runway capacity, and other
capabilities. The enabling aircraft flight technologies include cockpit
displays, data link (for both ATC and flight information services
(FIS)), enhanced avionics for navigation, greater use of flight
management systems (FMS), automatic dependent surveillance- broadcast
(ADS-B) and other technologies. For general aviation to obtain the full
benefits of the OEP, users will have to equip and receive training in
how to use the technology to meet requirements for communication,
navigation, and surveillance (CNS) and to fully realize the safety
benefits of equipping.

The cockpit flight technology revolution is fully underway in general
aviation, and users are beginning to equip with these new technologies.
Most new general aviation aircraft used for transportation offer as
either standard or optional equipment avionics such as Global
Positioning Systems (GPS), multifunction displays (MFD) with moving map
navigation, and traffic, weather, and terrain avoidance systems. These
systems are also being retrofitted to existing aircraft. Users are also
removing obsolete avionics such as automatic direction finders (ADF),
distance measuring equipment (DME), and older generation communications
and navigation radios. Portable CNS equipment is also proliferating in
the form of "electronic flight bags", hand-held GPS, and other devices.

In the near term, we can expect to see primary flight displays (PFD),
enhanced GPS three dimensional navigation through the Wide Area
Augmentation System (WAAS), real-time weather data link, and other
technologies.

All of the technologies listed above have the potential to greatly
improve situational awareness and flight safety by allowing pilots to
determine where they are in relation to weather hazards, terrain,
traffic, restricted airspace, and their route of flight and destination.
Many in the general aviation community believe, however, that some of
these avionics are training intensive and present complex human factors
issues that must be resolved to obtain the full safety benefits or, in
some cases, to avoid creating new safety issues. In particular, many
believe that the lack of systems integration in some new cockpit systems
and the need to develop avionics with more intuitive operation are
priorities which should be addressed. Clearly, an improved flight
training paradigm will be needed in any case.

The FAA and NASA are sponsoring programs that address many of these
issues. Of particular note are the FAA's Capstone program in Alaska and
NASA's Small Aircraft Transportation System (SATS) program. The Capstone
program has equipped about 150 air taxi aircraft in western Alaska with
advanced avionics including MFD, GPS, ADS-B, and FIS data link to
determine whether these capabilities can improve flight safety in this
remote region where small aircraft are an essential part of the
transportation system. A second phase of Capstone is being planned for
southeast Alaska.

The NASA SATS program is a follow on to the Advanced General Aviation
Flight Experiments (AGATE) program that ran from 1994-2001. The AGATE
program focused on development of new aircraft and avionics technologies
while SATS is focused on deployment of new capabilities that will foster
the actual creation of a small aircraft transportation system. The NASA
SATS research program is focused on four capabilities deemed critical to
creation of such a system. These include high volume operations, lower
landing minimums, enhanced enroute operations, and single-pilot safety
and mission reliability. The program has established four "SATS Lab"
entities to demonstrate these capabilities in real operational settings.
The SATS Labs are consortia of NASA, industry, academia, and FAA
members.

The programs and events described in this section will clearly have an
impact on future general aviation operations that relate to
transportation purposes. The critical common element in whether these
programs fully succeed may be whether or not the general aviation
training system can adapt to establish the framework for a greatly
improved level of safety. The next four sections of this paper will
postulate what a new training paradigm might include, what obstacles
might be faced in creating it, and new approaches and strategies to
accomplish this goal.

V.  [A MODERNIZED APPROACH TO GENERAL AVIATION FLIGHT
    TRAINING]{.underline}

In Section II of this paper, the current system safety environment for
general aviation was described and Section III introduced emerging
changes in system safety philosophy. With respect to general aviation
flight training, there is debate within the general aviation community
as to whether or not the current system safety approach will be adequate
to maintain, let alone improve, general aviation safety in light of the
factors discussed in the previous sections of this paper. If there is an
emerging concept that could best describe what is needed, it may be (to
paraphrase current military training philosophy) "train the way you will
fly (in the real world) and fly the way you trained".

The airlines have, for a number of years, followed such an approach, and
line oriented flight training (LOFT) is now considered doctrine in that
community. Concepts related to this approach are now emerging in the
general aviation training community. The concept of "scenario-based"
flight training, in particular, is attracting considerable support. This
training approach, when coupled with state-of-the-art training devices
and curricula, would be ideally suited to preparing general aviation
pilots for operation in an increasingly complex NAS. In particular, it
could provide an effective bridge between the training environment and
the actual environment pilots will experience. The concept also provides
a way for trainees to integrate various phases of flight operation.
Rather than, for example, conducting practice instrument approaches
repeatedly, scenario-based training may enable a pilot to experience the
complete transition from enroute to terminal to approach operations.

Another concept receiving considerable attention in the general aviation
community is the need for better risk management during general aviation
flight operations. Current FAA training standards require a minimal
amount of training in a corollary technique, aeronautical decision
making (ADM), and there is considerable research and training material
supporting this concept. Some in the general aviation community believe,
however, that many general aviation pilots are doing a poor job of
managing risk and see this reflected, for example, in fatal weather
accidents and other accident causes.

Some research has also been conducted on the benefits of combined
curricula to train pilots for specific mission profiles. Of particular
note is the combined curriculum for the private pilot certificate with
an instrument rating. This track prepares pilots to operate aircraft for
not-for-hire transportation purposes. Present FAA regulations require a
pilot to obtain a private pilot certificate and then accumulate at least
50 hours of pilot-in-command flight time before training for the
instrument rating. During the AGATE program, FAA hypothesized that
development of a combined curriculum for these two ratings could produce
equally capable pilots while improving safety and reducing training
time. Indeed, research sponsored by AGATE and conducted by Embry Riddle
Aeronautical University demonstrated this. The first phase of the
planned research was conducted using current production aircraft with
standard flight technology avionics and demonstrated reduced training
time and pilots who were equally as proficient as pilots trained
conventionally in a control group. The second phase of the research was
to have used aircraft with advanced avionics and other flight
technologies but, unfortunately, was never begun because of funding
limitations.

Related to the concept of combined curricula is the concept of separate
training tracks for recreational, not-for-hire transportation, and
professional purposes. The current certificate system is designed around
a generic student-private-instrument-commercial pilot training track.
The FAA is currently moving towards a split track approach with a recent
Notice of Proposed Rulemaking (NPRM) that would create, among other
proposals, a Sport Pilot certificate tailored for individuals who want
to fly only simple aircraft for sport or recreational purposes during
day visual flight rules (VFR) conditions, carrying no more than one
passenger. For those individuals desiring to use aircraft reliably and
safely for transportation purposes, it is necessary to be able to
operate under instrument flight rules (IFR), hence the need for the
instrument rating.

The discussion in this section was not intended to provide an exhaustive
treatment of modernized flight training approaches but rather to
illustrate some of the concepts, to suggest changes that may be needed
in training and certification, and to point the way for future research.
There are, however, obstacles to improved flight training policies and
procedures that must be overcome.

VI. [OBSTACLES TO IMPROVED FLIGHT TRAINING POLICIES AND
    PROCEDURES]{.underline}

Several obstacles exist which may hamper the creation of a modernized
flight training approach. Each of the following obstacles also presents
an opportunity for changing the business-as-usual approach to creating a
new paradigm.

Foremost among the obstacles is the pace of change when employing
conventional rulemaking approaches to solve aviation safety issues.
Rulemaking processes in the FAA are cumbersome and time consuming as a
result of administrative requirements prescribed under law. In an era
where flight technology product cycle times are measured in months,
rulemaking cycle times measured in years do not provide an effective
tool. For example, the major revision to FAR Part 61 referred to in
Section II was a ten-year undertaking from conception to completion
(1987-1997).

On the other hand, there are other effective tools for creating
guidelines, standards, and certification methods (GSC) within the scope
of the current FAR. For example, conventional tools such as advisory
circulars (AC), practical test standards (PTS), and other methods
already exist. This approach was used to create the combined
private-instrument curriculum for the Embry-Riddle test program
described in the previous section. Since no provisions existed under FAR
Part 141 to approve this curriculum, the provisions of Part 141.57
(special curricula) were used.

Even current non-regulatory tools such as AC's and PTS's have
limitations. The material in the next section will outline an approach
for creating even more flexible and timely methods.

Another obstacle to changing the current flight training approach is the
resource constraints faced by FAA in undertaking major new initiatives.
The agency is faced with increasing requirements and slow or no resource
growth. In this instance the solution is based on a partnership with
industry and other organizations and grater leverage of existing
resources. For example, with respect to research needs the FAA can take
advantage of its own general aviation center of excellence (COE) program
and in-house capabilities within the Civil Aeromedical Institute (CAMI).

The participation of the flight instructor community will be crucial in
implementing change in flight training. The difficulties in reaching
70,000 flight instructors is mitigated, however, by the fact that they
must all renew their certificates every two years and this mechanism,
for example, provides the FAA with the means to reach them with
educational materials or other tools.

Finally, it must be recognized that communicating a new training
approach to the general aviation community at large may be difficult and
may meet with cultural or other resistance. In this case the opportunity
rests with challenging the community to engage in partnership with the
FAA to create a new construct. There are many organizations that the FAA
will work with in taking the first steps and in developing incentives
for the larger general aviation community to benefit from change.

VII. [A NEW APPROACH TO TRAINING STANDARDS DEVELOPMENT AND
     APPLICATION]{.underline}

In Section II, the regulatory infrastructure supporting general aviation
flight training and pilot certification was briefly described. This
infrastructure is supported by a GSC system comprising AC's, handbooks,
test guides, PTS's, aviation safety inspector handbooks, and other
materials. The state of currency of this guidance material varies and,
in some cases, it is out-of-date or non-existent for some functions.
Several obstacles exist to keeping this system up-to-date and were
covered in the previous section.

To describe the state of the current GSC system, it is helpful to
subdivide the current system into categories, based on the regulatory
requirements for initial pilot certification, currency, upgrade
training, and other purposes. These categories are as follows.

1.  Pilot initial certification for a certificate or rating (knowledge
    test, practical test)

2.  Currency requirements (flight reviews, proficiency checks, other
    currency)

3.  Upgrade/transition requirements (type ratings, complex/high
    altitude/type specific)

4.  Flight instructors (initial certification, renewal)

5.  Pilot examiners (initial standardization, recurrent standardization)

6.  Pilot schools/FAR Part 141 (training course outlines, curricula,
    stage checks)

7.  Pilot schools/FAR Part 61 (syllabus)

8.  NAS operations (procedures, operating standards, etc.)

In some of these categories, for example, pilot initial certification,
type ratings, and flight instructor/pilot examiner qualification, GSC
material is current, although oriented towards passing the knowledge and
practical tests rather than outlining a scenario-based training and
testing approach. In the other categories, however, GSC documents are
often out-of-date or non-existent. For example, GSC's for the flight
review requirements are obsolete and do not exist for Part 61 training
entities. There is also an issue regarding whether the existing GSC's
are being used effectively or at all by the training community.

The current system of GSC's has served the general aviation community
well in supporting the training environment described in Section II of
this paper. It is clear, however, that a new approach may be needed to
GSC development for flight training and related functions in light of
the issues discussed in Sections III and IV of this paper relating to
new system safety philosophy, an evolving general aviation industry, and
a modernized NAS. Such a new approach might reflect the concepts
discussed in Section V relating to modernized flight training
approaches. In view of the obstacles to creating such a new approach, as
suggested in Section VI, how might the FAA and general aviation
community move forward?

A new approach to training should be integrated and holistically
centered and must be embraced by both the FAA and the general aviation
community. The system safety approach being developed for SAGA,
emphasizing improved risk management, training and education, and proper
use of technology should form the cornerstone of the strategy. Clearly,
the current system of GSC's may not effectively and efficiently support
such an evolution. Accordingly, a more flexible system of FAA/Industry
Training Standards (FITS) may be needed to accomplish this.

A FITS system could be developed over time in an evolutionary manner and
in full partnership between the FAA and the general aviation community.
It could target those functions most relevant to ensuring continued and
improving general aviation safety in an evolving NAS. To be flexible, it
should take advantage of the latest information technology to allow for
rapid creation and revision of standards. By confining the scope of FITS
to technical standards, rather than regulatory and policy issues, it
should be possible to reduce or eliminate administrative and policy
review, thus reducing product cycle time. To minimize use of static FAA
resources, FITS development should be primarily undertaken by those
elements of the general aviation community who will most benefit by them
(instructors, manufacturers, training material vendors, insurance
underwriters, schools, etc.). The FAA's role would primarily be in the
areas of technical review and as repository for the standards. To ensure
widespread awareness of and use of FITS, the FAA and industry in
partnership must conduct a widespread outreach effort and develop
incentives for training providers to use FITS. Examples of such
incentives could include insurance benefits and reduced training times
for those using the standards (as is done currently for FAR Part 141
schools).

The new approach described above may have considerable merit and appeal.
Accordingly, it would be desirable for FAA and industry, in partnership,
to develop prototypes for such an approach and evaluate them in the
training environment. This should be coupled with research and other
actions to ensure a balanced program.

VIII. [A STRATEGY FOR EVOLUTIONARY BUT RESPONSIVE CHANGE]{.underline}

The pace of development in general aviation is accelerating, especially
as it relates to new aircraft, new avionics and other flight
technologies, and new ways of delivering general aviation transportation
services. Accordingly, the FAA should partner with entities delivering
such products to prototype a new training paradigm. This should be
accomplished in a manner that would foster creation of a dynamic system
of FITS to benefit the end customer/user to increase safety and utility
in a complex NAS, while potentially reducing training time and costs. A
balanced implementation strategy would also sponsor/conduct needed
additional research, increase the role of industry in standards
development, and emphasize outreach to the general aviation community at
large. The FAA and industry would achieve the greatest early benefits by
selecting for improvement those training system elements that would be
most likely to yield improved training and system safety for
state-of-the-art products from original equipment manufacturers and for
the retrofit market.

The following first steps would be needed to undertake this initiative.

1.  Internally, the FAA Flight Standards Service, led by the General
    Aviation and Commercial Division, will develop a more detailed
    program plan to support development of a new training approach, in
    particular a method of implementing FITS.

2.  The FAA will plan a public initiation of the program at an
    appropriate time but in the interim will select a launch customer(s)
    for developing, in partnership, a FITS prototype(s) that meets the
    criteria outlined above. Candidate functions could include the
    following:

```{=html}
<!-- -->
```
a.  Combined private-instrument curriculum (under provisions of FAR
    141.57)

b.  Flight Reviews (FAR 61.56) and instrument proficiency checks (FAR
    61.57d)

c.  Complex/ high performance/ high altitude aircraft (FAR 61.31e/f/g)

d.  Type specific training (FAR 61.31h)

e.  Flight instructor renewal (FAR 61.197, AC 61-83E)

```{=html}
<!-- -->
```
3.  The FAA will approach non-profit organizations, such as the Air
    Safety Foundation and the National Association of Flight
    Instructors, to enlist their support in outreach efforts and
    development of training incentives for use of FITS.

4.  The FAA will work with the launch customers identified in item 1 to
    identify training providers and vendors of training products that
    provide the infrastructure needed to implement a FITS system for
    their products and customers.

5.  The FAA will develop and provide its Flight Standards field
    workforce with appropriate guidance material and training to
    implement functions where FAA operational approvals are required
    (for example, approval of FAR Part 141 training course outlines).

6.  The FAA Flight Standards Service will sponsor appropriate research
    relating to training requirements and effectiveness of FITS training
    standards and other modernized training approaches, especially those
    relating to human factors issues of advanced avionics and flight
    technologies and operations in a modernized NAS. The FAA will work
    closely with its General Aviation Center of Excellence and the Civil
    Aeromedical Institute in this regard.

7.  The FAA will seek partnership and leverage opportunities to
    prototype and develop advanced training approaches. In particular,
    Flight Standards will seek to engage the FAA's Capstone program and
    NASA's SATS program to develop mutually supportive program
    development approaches.

8.  The FAA will use its own Aviation Safety Program to sponsor and
    develop seminars and training and educational materials, focusing on
    advanced flight technologies and the use of FAA/industry training
    standards. These seminars and materials will target general aviation
    pilots and owner-operators, flight instructors, and other audiences.

The timeframe for accomplishment of these activities will be dependent
on the availability of internal FAA resources and the willingness of
partners and other external entities to engage in this effort. The
General Aviation and Commercial Division plans to complete steps 1 and 3
and the first phase of steps 2 and 4 in fiscal year (FY) 2002. Steps 5
through 7 will be ongoing. Broadly speaking, prototype activities and
FITS development would continue in FY2003 and full-scale implementation
would be in FY 2004 and beyond.

The FAA will seek an evolutionary approach to change that will still be
responsive to the pace of development in the general aviation community.
The approach outlined in this paper will be most successful with the
full participation and partnership of the community.