Pilot groups believe several elements of new Boeing 737 MAX training should be expanded and required more frequently than the FAA proposes so pilots remain familiar with certain non-normal procedures and how a key flight-control function works.

The Air Line Pilots Association (ALPA) wants new special training on the maneuvering characteristics augmentation system (MCAS) flight-control law done on a recurring basis, instead of once. The FAA’s proposed curriculum, outlined a draft Flight Standardization Board (FSB) report released Oct. 6, includes MCAS ground and simulator sessions in a “special training” appendix that pilots preparing to fly the MAX must undergo. But aside from some manual horizontal stabilizer trim scenarios, the appendix proposes a one-time course, with no required refresher training.

“The 737 product line is one of the most prolific airframes operating in commercial aviation to date and some operators have elected to operate a wholly 737 fleet,” ALPA told the FAA in comments filed on the draft FSB. “Because of this, it stands to reason that pilots operating in scheduled large transport category operations throughout the world may spend the entirety of that portion of their career operating only the 737. Yet, this training requirement would equate to them receiving exposure to MCAS in a controlled environment only once throughout that lifetime, leading them to rely on potentially decades-old training if faced with an MCAS activation in service.”

Inadvertent activation of the MCAS, which automatically moves the horizontal stabilizer in certain high angle-of-attack flight profiles to ensure the MAX feels its predecessor to pilots, was central to two fatal accidents that led to the fleet’s grounding. Boeing has revised the MCAS software logic to prevent inadvertent activation and added descriptions of the system to pilot training and flight manuals.

In addition to covering MCAS operations, the new training emphasizes related non-normal scenarios, including stabilizer trim operation, unreliable airspeed, and runaway stabilizer. The FAA proposes pilots practice non-normal “electric and manual stabilizer trim operation” and unreliable airspeed scenarios once every three recurrent training sessions, with a maximum interval of 36 months. ALPA and the Allied Pilots Association (APA) want each done every two sessions, with a 24-month maximum. 

APA, which represents American Airlines pilots, called for a similar change to proposed frequency of runaway stabilizer non-normal checklist (NNC) training. 

The Southwest Airlines Pilots Association (SWAPA) and Airlines For America called for the proposed eight-step runaway stabilizer NNC to be simplified. “Error rates increase exponentially with a checklist containing eight memory steps, including three conditional steps,” the union said. Its pilots have tested the NNC in full-flight simulator session “and found it difficult to recall the steps in order,” SWAPA added. 

The current 737 runaway stabilizer checklist has seven steps. FAA guidance recommends no more than three steps for a procedure that must be memorized. SWAPA and APA have considered a hybrid approach that leverages a short, memorized checklist with the most crucial steps combined with a quick-reference card (QRC) that outlines the conditional scenarios. Southwest and American are among the carriers that have moved to QRCs in lieu of requiring pilots to memorize procedures—a nod to the human-factors challenge that recalling specific tasks, in order, during a high-stress situation such as an in-flight emergency creates. 

ALPA and the APA also urged the FAA to expand the runaway stabilizer and manual-trim scenarios to include high-speed flight regimes. 

“Aerodynamic loads on the horizontal stabilizer will affect a flight crew’s ability to manually trim the stabilizer,” ALPA said. “Such an effect may either enhance or degrade the quality of training being offered.” APA called for manual-trim training to include “a high-speed regime” in addition to the approach, go-around, and level-off scenarios specified in the draft document. “In doing so, the requirements of airspeed range ... and effects of air loads on the stabilizer ... will be accomplished,” APA said.

The FSB public-comment period closed Nov. 2. The FAA plans to evaluate the public comments—more than 30 sets in all—as part of finalizing the FSB, which will set minimum training for MAX pilots. 

Finalizing the FSB is one of the last key steps in the FAA’s process of evaluating Boeing’s proposed changes and finalizing what operators must do to get their MAX back into service. The FAA is not working with a deadline in mind, but Boeing is optimistic that the agency’s approval will come by year-end.