Comments on Draft AC 120-FPM

*** Do not use this for flying refer to your AFM and company policy OM ****

The Draft AC can be viewed here

Dear Sir or Madam,

This is a great and long awaited-for AC.

Here are my comments on this very important AC.

  1. General:
    1. The acronym FPM is somewhat confusing with the FSF term EFPM for Effective Flight Path Monitoring.
    2. I believe a “background” or “Forward” section is in order. And that it should include references to SAFO 13002, 17007 and EASA SIB 2013-33
    3. The AC starts with “policy” and leaves out philosophy and I believe it to be important.
    4. I recommend adding appendix with an example of Flight Path Management policy.
    5. Such a policy and philosophy are not easy to implement. Starting with convincing the “old guard” and dealing with natural conservativism and the fear of violations and their consequences.
    6. I think it could not be stressed enough that this is the responsibility of the operator. As many smaller airlines tend to adopt the OEMs suggested SOP and these not always match the policy of this AC but rather regulatory compliance.
    7. It is our experience that the issue of Flight Path Management should be presented as a risk mitigation measure. We are mitigating the risks of automation dependency the risk of underperformance in a non-normal environment and to an extant the risks associated with startle.
  2. Chapter 2 “Flight Path Management-General”
    1. Part 2.1.1 I recommend adding the words “at the right time” at the end.
    2. Part 2.1.3 I highly recommend removing the (s) that follows the word pilot. The way it is phrased now suggests that relief pilots have other duties to that of augmenting crews for Fatigue management. This is not supported by any research I am aware of, nor by any regulation I know of. The additional flight crew member in the cockpit has some serious negative effects on the crew at the controls. As a minimum their presence must be addressed in terms of risk mitigation let alone implying it is a good practice. Even during IOE or LC. The phycological studies I have found relevant point to the dangers of distractions, social-loafing, complacency and overpressure mainly during out of normal operation.
    3. Part 2.2.1 recommend adding a third bullet “this includes normal and non-normal parts of the flight”
    4. Part 2.2.4.2 As stated in the general section. This is of utmost importance – It is the responsibility of the operator to develop procedures for FPM. It is not the OEMs. This point might be obvious to major airlines it is most certainly not to smaller outfits with less resources as they will be more dependent on the OEMs suggested SOPs. This could be referenced to AC 120-71B section 2.2
  3. Chapter 3 MANUAL FLIGHT OPERATIONS
    1. 1 At the end of the paragraph recommend adding “High level of MFO skills gives pilots the required confidence to take control in due time rather than wait for the airplane to recover by itself”.
    2. Recommend adding section 3.5 “Operators should adopt and publicize a tolerant policy towards minor unintentional deviation from the theoretical most accurate flight path” This is one of the hardest objections we got from the “old guard” – “you are going to discipline me if I bust the cleared altitude.”
  4. Chapter 5 PILOT MONITORING
    1. Out of the eight or nine pilot competencies as defined by ICAO Workload Management WLM is the trickiest of them all. It is also one the most important ones.
    2. Sterile cockpit is a regulatory idea Areas Of Vulnerability AOV is a practical notion.
    3. Prioritizing tasks goes all the way from philosophy to practices. Good or bad.
    4. This is again on occasion stand in contradiction to the OEMs suggested procedure. The PM’s duties must be approved by the operator. The company may approve the OEM’s recommended procedures but must adjust when necessary to make sure the PM is actually monitoring the flight path. Some of us are inclined to monitor the other pilot’s actions or get totally occupied with the read-and-do non-normal checklist malfunction and neglect monitoring the flight path. This is apparent in the Swiss 111investigation report and the reason for adding a “diversion may be required” comment every few lines in the “SMOKE” checklist of all models. This inclination is apparent during all elongated non-normal checklists such as unreliable Airspeed and smoke.

Thank you for taking the time to read my comments.

With great respect.

Captain Hovav Ben David.

Practical-Aviation

 

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