Is simulator time necessary for updated 737 MAX MCAS training?

The FAA’s slow move to ground the 737 MAX last month triggered a schism in the global aviation regulatory community. Other countries chose to act unilaterally rather than follow the FAA’s lead on a US-built aircraft. As plans start to form around bringing the MAX back into the skies following its grounding related to the LionAIr and Ethiopian Airways crashes questions remain about just how willing those countries will be to allow the FAA to dictate terms, and how aggressive the FAA will be in its demands from airlines. Some of that drama is beginning to play out this week with respect to pilot training requirements. Canada and the USA are already on opposing sides, well before any moves are finalized.

In an update issued on April 16th the FAA’s Flight Standardization Board (FSB) responsible for the 737 MAX indicated that it did not believe simulator training would be necessary for the modified Maneuvering Characteristics Augmentation System (MCAS) software, though it does call out the MCAS system for “special emphasis” in the computer-based training. The FSB’s primary responsibilities are to determine the requirements for pilot type ratings, to develop minimum training recommendations, and to ensure initial flight crew competency.

Special Emphasis Areas. Pilots must receive special emphasis on the following areas during ground training, as applicable to an operator’s fleet of aircraft:

• B-737-MAX Maneuvering Characteristics Augmentation System (MCAS). The Speed Trim System (STS) provides speed and pitch augmentation. Speed stability augmentation is provided by the Speed Trim function of STS. Pitch stability augmentation is provided by the MCAS function of STS. MCAS ground training must address system description, functionality, associated failure conditions, and flight crew alerting. These items must be included in initial, upgrade, transition, differences, and recurrent training.

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It is a non-binding recommendation, but it carries significant weight. After a two week comment period the FAA will issue a final recommendation on the issue.

Not requiring simulator time for the system will save airlines millions of dollars. The costs come from from the pilot time as well as the expense of acquiring the simulators themselves. Scant few have 737 MAX simulators, depending instead on their 737 NG hardware and a computer-based transition training. In the US market none of the three airlines operating the type own simulators. Nor does WestJet as it is converting pilots from its NG fleet. Air Canada does have one as the MAX is a new play for the carrier.

Read More: Boeing, FAA coming up short in push to keep the 737 MAX flying

Those last two airlines are particularly significant as Canadian Transport Minister Marc Garneau indicated in a Reuters interview that a computer-based training regimen would be insufficient to satisfy his organization.

It’s not going to be a question of pulling out an iPad and spending an hour on it.. Simulators are the very best way, from a training point of view, to go over exactly what could happen in a real way and to react properly to it.

– Canadian Transport Minister Marc Garneau

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Canada’s willingness to openly demand more could create a problem for the FAA, just as Canada’s decision to ground the plane, based on ADS-B Out data the FAA had for a couple days before Canada received it, did. Cooperation between the national regulators helps lower cost and speeds the process of approving various systems and alterations around the globe. Losing that would be a significant setback to the industry from a pace (and price) of change perspective. It also may be a necessary shift to ensure the well-earned safety reputation aviation has earned over the years.

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Perhaps had more focus been paid to MCAS training in the prior conversion process this would be less of an issue. Yes, the software still needs to be fixed. A critical control system relying on a single input and repeatedly reengaging as pilots attempt to override it is not a reasonable configuration. But it is relatively easy to see a scenario where a computer-based scenario for the update would have been viable had a similar scheme been in place from the start. Without that, unfortunately, other regulators remain skeptical of the FAA’s independence and decision-making process.

A long road remains to getting the MAX back in the sky. This first step is just a small bit of that challenge.