Single-Pilot Jet Safety

In the last five years, a new crop of small light jets (I promise not to call them VLJs, or very light jets) has entered the marketplace. Aircraft such as the Cessna Model 510 Mustang, Embraer Phenom 100, and yes, the Eclipse 500 are now out there in the hundreds, and they have carved a successful market niche, albeit not the one envisioned by some observers. These airplanes are designed to be flown by single pilots and its fair to ask whether or not our training and safety model for

these airplanes will be up to the task. The record so far looks good but we need to look below the surface for the entire story.

We should be looking at a cohort of airplanes that are destined for an excellent safety record, if we assume they will reflect the record of previous turbojet models certified for single-pilot operations. For example, the Cessna Citation Jet series (model 525) and earlier Citation models approved for single-pilot operations (model 501SP and, with an FAA exemption, certain other Citation models) have enjoyed a generally excellent safety record. As with most categories of general aviation aircraft, pilot issues account for the majority of official factors and causes enumerated in NTSB accident reports. A key question is whether the official NTSB data tells the real story; more on that shortly. Nevertheless, most observers in the manufacturing, training, and regulatory establishment have every reason to be content.

There are at least two factors at play that may be responsible for the excellent safety record of previous light jets certified for single-pilot operation. First and foremost, many of the pilots type-rated in those older aircraft-initially at least-do not obtain single-pilot type ratings, but instead obtain one requiring a qualified second-in-command pilot. In some cases, owners obtain only a second-in-command type rating, leaving the main driving to a professional pilot. For example, somewhere between 70 and 90 percent of type ratings for these earlier single-pilot turbojets are issued requiring a qualified co-pilot. As one result, not that many previous single-pilot-capable jets are being flown by a one cockpit occupant.

A second factor is the type rating applicants previous flight background. In the case of earlier single-pilot models, its likely a large percentage of type-rating applicants had previous turboprop or turbojet experience as they climbed the aircraft complexity ladder, perhaps trading in their Cessna Conquest on a Citation Jet, for example. This may not be the case for a large percentage of pilots transitioning to the new generation of small light jets, however. For example, at Eclipse Aviation (predecessor to the current Eclipse Aerospace), it was not uncommon for most private purchasers to move up from a light twin, Cirrus or Saratoga to the Eclipse 500, perhaps with as little as 10 hours multi-engine time in something like a Piper Seminole.

Given these two factors, its fair to ask what safety record the new crop of small light jets has demonstrated.

In a safety nutshell, the Cessna Mustang, Eclipse 500 and Embraer Phenom 100 are off to a good start. Looking at the NTSB accident databases and industry deliveries, its remarkable to note that with about 800 Cessna Mustangs, Eclipse 500s and Embraer 500s (as the Phenom 100 is formally designated) in the fleet, there have been no fatal accidents since the first of these airplanes entered service in late 2006 (as of March 2011).

The table below summarizes the safety data for these aircraft models, which have been the only aircraft formerly described as very light jets (VLJ) certificated by the FAA and that have entered the fleet. This safety record is remarkable but, as previously noted, we need to consider how the manufacturers are managing their products safety.

All three manufacturers use recognized industry stalwarts to provide pilot training. Cessna uses Flight Safety International, Embraer uses CAE Simuflite and Eclipse Aerospace uses Simcom. According to my sources, however, a very high percentage of Cessna Mustang type ratings are issued as two-pilot or second-in-command-only ratings. My sources also tell me very few pilots purchase the optional mentoring package, and most arrive for training unprepared and expect the instructor to “spoon feed” the training. Consequently, many customers are steered away from the single-pilot type rating.

As one might expect, the original Eclipse entity conceived an entirely different approach to customer pilot training. First of all, some disclosures are in order. I was Director of Flight Training at Eclipse from November 2005 through March 2007, moving to Director of Regulatory Affairs until I left the company in March 2008. I developed the original type-rating curriculum to conform to Eclipses vision, one established prior to my arrival.

My successors include some very capable people who helped the training program mature and overcome some serious obstacles. This included a lack of simulators and flight training devices until late 2007 and turnover in training providers. Finally, I should disclose that I have no formal relationship to the current Eclipse Aerospace entity that took over the Eclipse assets in 2009, although I know many of the principals in the new company.

Having said all that, Ill cut to the chase: We designed the Eclipse 500 training program to be a rigorous multi-phase qualification process, mandating essential training that elements are not required by FAA training and type-rating regulations.

To give this program some teeth, we used a hitherto untried approach, the key element of which was a training limitation in Section 2 of the Eclipse 500 airplane flight manual (AFM). The wording of this limitation is crucial, so its quoted verbatim from the original AFM in the box on the opposite page:

The FAA did not impose this mandate on Eclipse and was, in fact, reluctant to do so. I persisted with the argument that a new type of owner-pilot would be purchasing the aircraft and told the FAA Eclipse wanted to be proactive in ensuring the safety success of the airplane. I and my colleagues worked with the FAA Flight Standardization Board (FSB) to lock down this requirement, and it therefore became part of the type certification basis for the Eclipse 500.

So how can Eclipse or FAA enforce this requirement? Its really quite easy. The FAA, via FAR 61.31(h), may determine additional aircraft type-specific training is required for specific aircraft. The FAA FSB report and proprietary Eclipse documents specify the scope and content of this training.

As far as the pilot is concerned, its a done deal, since under Section 91.9(a), “…no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual….” In reality, the FAA has gone down this route before, with SFAR 73 of Part 61 for the Robinson helicopters and, more recently, SFAR 108 for the Mitsubishi MU-2. Eclipse merely followed a less-cumbersome route costing the FAA a lot less to promulgate.

Importantly, the manufacturers of these two aircraft initiated the rulemaking and actually forced FAAs hand to craft the SFARs addressing the training needs of aircraft for which the standard regulations in Part 61 are insufficient to ensure safety.

So how can someone other than Eclipse or its training provider conduct teach people to fly the Eclipse 500 if they are not privy to Eclipses proprietary training data? A key word in the AFM training limitation allows for this. At Eclipse, we knew that FAA would be unable to create a monopoly training provider, so I added the word “equivalent” to the limitation so that FAA could approve third parties to conduct this training.

Naturally, you might be tempted to ask: How does FAA determine whats equivalent? Well, here the plot thickens a little, but if youre tempted to create your own Eclipse 500 type rating, mentoring or recurrent training program, you need to refer to Advisory Circular (AC) 61-137, Approval of Manufacturers Required Training Programs. The main body of this AC is generic to any aircraft with an AFM training limitation, while Appendix 1 refers to the specific requirements for obtaining approval for Eclipse 500 training.

The FAA has approved several entities to conduct Eclipse 500 training, besides Eclipse and its approved training provider Simcom. How does the FAA ensure the training really is “equivalent” and the provider actually complies with the approved requirements? That will actually make a great future article, but for now we might be better served asking some more fundamental questions about accident causality and about the adequacy of FAA training requirements for turbojet aircraft.

Why did the original Eclipse go to such lengths in designing the aircrafts qualification process? The essence of the rationale rests on realizing the root cause of most fatal accidents-as opposed to stated NTSB causes and factors-is the pilots failure to use higher order pilot skills such as risk management, single-pilot resource management (SRM) and automation management.

Most accident causes and factors listed in NTSB accident reports only describe the proximate accident causality. Thus, terms such as “loss of control” permeate the NTSB lexicon, describing how the accident occurred. In these cases, we dont have a clear idea of what the real root causes are for most accidents and thus are unable to conceive really effective remedies. For example, why did the pilot “lose control” of the aircraft?

To take this example one step further, in a loss-of-control accident with a key instrument failure, we may be tempted to blame the pilots inability to detect an instrument failure and then control the aircraft with standby instruments. In many such accidents, the pilot may actually have known about a progressive instrument failure before takeoff but failed to identify, assess and mitigate the risk by, for example, staying in visual conditions rather than entering the clag.

My own work for clients on accident causality suggests most fatal accident root causes relate to the pilots failure to effectively manage risk. In the latest generation of technically advanced aircraft, this is often compounded by poor SRM and automation skills such that the pilot is often behind the airplane.

At Eclipse, I designed a total qualification program for the Eclipse 500 explicitly covering higher-order pilot skills-especially risk management-which then became part of the mandated training program under the AFM limitation. In fact, I designed the risk management curriculum, created the initial courseware and often taught the classes, since I considered this subject a crucial pilot skill.

The FAAs practical test standards and most industry training curricula are inadequate to assure safe single-pilot operation of turbojet aircraft by pilots with minimal experience. This hasnt been a problem in the past because most single-pilot type ratings have been issued to pilots who either have a professional pilot background, who fly with a qualified second-in-command or who have previous turbojet experience. This demographic may be different for the new generation of small light jets and the follow-on products including small, single-engine turbojets.

Under current regulations, its possible for a pilot to buy a light jet certified for single-pilot operation, find an instructor type-rated in the airplane, get that person to sign off him or her, and then take the practical test, which is really just a glorified instrument rating. There is no required curriculum, no need to demonstrate operation at high altitude or in busy terminal areas, no need to demonstrate most higher-order pilot skills and no requirement for recurrent training. The FAA is moving to close the loophole in FAR 61.58 allowing single-pilot aircraft to escape the annual pilot-in-command proficiency check.

Another deficiency in current regulations is the inadequacy of the supervised operating experience (SOE) requirements specified in FAR 61.63(e). This section requires a type-rating applicant who is trained in a simulator and has no previous type rating to obtain either 15 or 25 hours of SOE before obtaining a type rating allowing pilot in command privileges.

The pilot providing the SOE doesnt need to be either a certified flight instructor or a qualified evaluator and the SOE program doesnt have any specific requirements. All you need to do to comply is find a pilot who is typed in your airplane, is current and has a pulse. You can then go out and bore holes in the air straight and level on a sunny day, under VFR until you get the magic number of hours. In the real world, of course, there are insurance requirements imposing stiffer training requirements. Yet, the insurance market is currently still “soft” and many insurance providers accept training from a wide variety of training providers.

At Eclipse Aviation, we never counted on the insurance providers to police the market, especially with regard to SOE requirements. For example, we created a rigorous “mentor” requirement using Eclipse-designated highly experienced mentor pilots. We required demonstrated proficiency in 16 categories of “events” reflecting real-world operating requirements, like sweating fuel as you were put in the hold in a busy terminal area.

It will be interesting to see if the new Eclipse Aerospace company seeks to maintain the training standard for the Eclipse 500 established by the original Eclipse Aviation. While Eclipse can call the shots with Simcom, if it chooses to do so, it will need for FAA to exercise proper oversight over third-party training providers FAA has approved to conduct Eclipse 500 training. Is this likely to happen in todays budget climate? Stay tuned.

What is the likelihood the training paradigm will shift from the current maneuvers-based, top-down, one-size-fits-all type-rating training currently offered by the major simulator training providers? The problem is not just limited to frustrated owner pilots. At recent annual conventions of the National Business Aviation Association, many corporate operators and air taxi companies grumble about the quality of the training product they receive.

As an owner/pilot of a small light jet, what can you do to force training reform and receive a better training product? In advance of your type and recurrent training, seek out a provider offering a balanced curriculum emphasizing both PTS requirements and higher-order pilot skills. For your recurrent training, ask for alternating cycles emphasizing scenario training in one period, in addition to typical maneuvers and emergency procedures in the alternating periods. Above all, insist on training that improves your ability to identify, assess and mitigate the common risks associated with single-pilot turbine operation.