Part 2 of 2 | Part 1 is available at this link: Where will the NTSB Look to Explain the Rise of Mishandled Landings at U.S. Airlines?
Due the recent spate of accidents during landing including Delta Flight 4819 in Toronto, Delta Flight 4814, at New York’s LaGuardia Airport, and Frontier Flight 5306, in San Juan, Puerto Rico, Aviation Law Group’s attorneys are highlighting common factors in each case and other similar accidents like United Flight 702 that NTSB investigators and the FAA will be examining in an effort determine what can be done to prevent these kind of occurances.
Weather
Weather is a factor in every landing, but the question investigators will face is whether it was significant enough to cause or contribute to these accidents. Based upon the preliminary reports, the role of weather in these accidents seems to be minor, if it contributed at all. The investigators will find that in each case, the weather was well within performance limits for each aircraft and was the type of weather that airline pilots face on a daily basis. In the case of Frontier 5306 and United 702, the weather was extremely mild, with winds of less than 10 knots.
First Officer in Control
Outsiders to the airline world may find it surprising that the captain is not operating the controls of the airplane on every flight. Rather, it is standard practice at all U.S. airlines to alternate flying duties between the captain and first officer. In each of these accidents, the first officer was in control of the airplane during the landing. Even when the first officer is at the controls, ultimately, the captain of each flight is still the final authority responsible for ensuring the safety of the flight. They should take over control of the aircraft if the safety of the flight is ever in question.
Investigators will also attempt to determine why the respective captains on Delta 4819 and Frontier 5306 did not take over when a hard landing appeared imminent, and in the case of Delta 4814, why the captain let the situation deteriorate to the point where the aircraft’s wing impacted the runway before finally taking control.
Experience and Training History
What may also be surprising to the general pubic is that the first time a newly hired pilot actually flies an airplane for a U.S. airline is on a revenue flight with passengers. All new pilots will have gone through an FAA-approved training program with multiple sessions in a full-motion flight simulator that is extremely realistic, but they are approved to fly without ever having been in the actual aircraft. The new pilots on their first flights will fly with a training captain known as a “line check airman ” who themselves have gone through extra training and have been approved for this role by the airline and the FAA.
The first officer on United 702 was a new hire with less than 130 hours of flying experience at United. He would have completed his initial operating experience of at least 25 hours of flying with a check airman prior to being “released to the line” to fly with non-training-qualified captains.
While our investigation has not determined the experience level of the first officer in Delta 4814, it is believed that the flight from Jacksonville to LaGuardia in New York was not a training flight. The first officer on Delta 4819 had less than 500 hours of flying experience in the CRJ-900, and the first officer on Frontier 5306 had only been flying at Frontier for approximately one year. While neither Delta 4819, or Frontier 5306 were training flights, our investigation has revealed that the first officer on Frontier 5306 was hired through a cadet training program with Frontier Airlines, in which it granted a conditional employment offer to her before she ever attended a training class with Frontier. Additionally, both first officers on these flights were issued and were operating on a “Restricted Airline Transport Pilot” (ATP) license.
Restricted ATP
In the wake of the crash of Colgan Flight 3407 on February 12, 2009, Federal Aviation Regulations were changed to require all pilots, not just captains, at U.S. airlines to have an Airline Transport Pilot license, which requires at least 1,500 flight hours of pilot experience. This change reduced the number of qualified applicants to regional airlines.
The Restricted ATP pilot license allows individuals to serve as first officers (co-pilots) at airlines before accumulating the full 1,500 hours required for a standard ATP certificate. This reduced flight hour requirement is available to pilots who have completed specific aviation training programs, like those with a bachelor’s degree in aviation or military training.
While the fact that a pilot has less than 1,500 hours when hired at an airline does not necessarily mean that their skills are inferior to those of a pilot hired with 1,501 or more hours, nonetheless the FAA and NTSB investigators will not overlook the fact that these pilots were hired with less experience and will determine to what degree it may have played a role in these accidents.
Airmanship and Airline Training Programs
Perhaps more importantly to the investigation, the NTSB will look to the training records of each pilot to see if there were any deficiencies in their ability to properly handle the airplane noted in their training record. Like in United 702, the first officers’ training records may shed light on their individual aptitude in physically controlling the airplane.
Additionally, the FAA may look to their FAA-approved training programs at the airlines to determine if there is enough training in airmanship, as the training courses are currently designed. The current training courses at mainline U.S. airlines like Frontier and United were not designed to train low-time and inexperienced pilots in fundamental aircraft handling. For decades, these training programs relied on newly hired pilots who had thousands of hours more than the bare ATP minimums. While the minimum required flight hours for first officers at airlines before Colgan 3407 was simply a Commercial Rating requiring only 250 hours, or 190 if the pilot received their ratings from an approved school with structured training program, airlines rarely hired first officers with such little time. For years, most major airlines had their own required minimums, often requiring at least 4,000 hours total time and at least 1,000 hours as captain on a jet aircraft before a pilot could even apply for a first officer position.
Because of a wave in pilot retirements at major airlines during the COVID-19 pandemic, expansion of airline service and a rapid addition of airplanes to their fleets, airlines have been unable to find enough pilots meeting the long-standing airline hiring minimums. As a result, airlines steadily decreased their hiring minimums from 4,000 hours to 1,500 hours (or 1,000 hours with a restricted ATP) and no requirement to have any experience as a captain on jet-powered aircraft.
While airline hiring minimums can change as quickly as updating an airline pilot job advertisement, changing the FAA-approved training program for airline first officers is not as easy. Airline training programs include a very limited amount of time devoted to normal aircraft control training, such as visual approaches and landing practice. Airline programs were designed with the assumption that the pilots have long ago mastered these so-called “stick and rudder” skills. With the technological advancements in newer airplanes airlines are now using such as the Canadair Regional Jet (CRJ), Boeing and Airbus aircraft, airline training programs spend a substantial amount of time teaching new hire pilots simply how to manage the specific aircraft’s highly complex computer technology, along with airline procedures training and emergency training.
Pilots are trained in the full motion simulator to learn the airplane type, how to fly it with the aircraft’s automation, and follow specific and complex procedures for a multitude of scenarios, including emergencies. Pilots are then tested or “checked” for how well they can perform these procedures and maneuvers. Stick and rudder skills are not as challenged or tested during an airline training program as other, more advanced procedures. It is often the line check airman conducting initial operating experience on a revenue flight with passengers who will first get a chance to evaluate the piloting skills and airmanship of the pilot trainee. With a minimum of only 25 hours required to complete initial operating experience, it is possible that first officer trainees are not confronted with enough different situations or weather conditions for a full and accurate assessment of the first officer’s piloting skills. While it is not uncommon for first officer trainees to need more than the minimum hours of initial operating experience to demonstrate competency, first officers are rarely terminated at this late stage in training. It begs the question: are the airline training programs, as currently designed, able to filter out those pilots who do not have the requisite basic flying skills?
In the case of United 702, the first officer had deficiencies in training, resulting in a “short cycle,” and yet apparently completed initial operating experience. On the date of the accident, the first officer was flying with a captain who was not a check airman. After the hard landing and subsequent damage to the Boeing 767, the first officer was ultimately terminated by United.
The flying public should expect that airline training programs are designed not only to train, but also to verify that pilots have the aptitude to handle a transport category aircraft long before they are released to fly the line. Additional simulator sessions may be required to focus on more rudimentary airmanship. Hard landings are not rare, but hard landings resulting in substantial damage to aircraft or serious bodily injury to passengers are not normal and are completely unacceptable.
While there has been no determination on whether a lack of airmanship or stick and rudder skills played a role in the accidents of Delta 4819, Delta 4814, or Frontier 5306, there are indications that it may have been a substantial factor in each case. FAA and the NTSB investigators will examine these recent incidents to determine any common threads and what airline training standards, training programs, and rules may need modification to address the recent increase in these types of accidents.
Christopher Rusing is an attorney with Aviation Law Group PS and has over 20 years’ experience as a commercial airline pilot. He is currently Captain on the A320 series of aircraft, is a Line Check Airman, Simulator Check Airman and Simulator Instructor at his airline.
Aviation Law Group PS, (ALG) is a law firm that limits its practice to aviation accidents and has represented clients involved in major airline disasters to general aviation accidents. ALG currently represents clients involved in Hawaii Airlines Flight 35, Alaska Airlines Flight 1282, and Delta Airlines Flight 4819. ALG has offices in Seattle, Washington, Honolulu, Hawaii, and Jupiter Florida. ALG attorneys are licensed in Washington State, Hawaii, Alaska, California, and Florida, but can represent clients in all 50 states and has represented clients internationally with the association of local counsel.