No Pilots Were Harmed in the Making of this Article: RVSM
- Advanced Aircrew Academy
If you are climbing a mountain, it's best to concentrate on just the next few steps. If you keep looking up to see how much ground you must cover, your frustration will be kept at an elevated level while you remain below it. Pilot training is a bit like trying to climb a mountain every year. There is so much information pilots must maintain currency on, it’s a constant anxiety attack for training managers. Before you reach for that bottle of headache medicine again, let's break it down into small steps. Today, let's just look at RVSM training. (This is assuming your aircraft is RVSM Compliant because that's another bottle of headache medicine.)
Reduced Vertical Separation Minimum. Once upon a time, ATC required 2,000 feet of vertical separation from other aircraft between FL290 and FL410 inclusive. The separation in the current airspace is 1,000 feet. If you have two Citation Xs approaching in opposite directions, that’s a 1,400-mph closure rate which means there's no room for error. The training requirement for RVSM comes from either your Ops Specs if you are operating under Part 135, or LOA B046 if you are Part 91.
To get the Ops Spec or LOA issued, you must show in your training manual (Part 135) or operations manual (Part 91) how you intend to comply. AC 91-85A/B details how to comply with B046. It also says Initial and "Recurrent" (I'll tell you why these "Air Quotes" are here in a bit) training is required and specifies the knowledge requirements that need to be met. Subjects like pre/in-flight procedures, MEL, TCAS, Mountain Wave/Turbulence, etc. – topics that would affect your ability to make sure you are properly separated.
A Part 142 center is probably not going to cover all those required training elements unless you specifically ask them to, but, they already have a long list of topics they must cover. They may make mention of RVSM, but it probably won’t meet RVSM training requirements.
Now, the reason for the "Air Quotes". "Recurrent" is not defined by the FAA or most operators in their training manuals. Read it again (we want to see your lips moving). "Recurrent" can mean annually, every 24 months, 36 months, 2 months, 2 days…or any time I remember to do it if you take the meaning literally. Confusion can occur for both the operator and POI on how often RVSM "Recurrent" training is required. Since "Recurrent" aircraft specific training and checking is required annually, the assumption goes that anything listed as "Recurrent" is also an annual requirement, but that's not the case. Ideally the operator details the recurrent interval for items in their manual, but most Part 135 operators don't do this (although most Part 91 operators do).
To add to the level of confusion, if operating domestic only and you have ADS-B installed, you don't need B046; however, the FAA has stated if you are operating in RVSM airspace under this exemption, you still need to meet all the requirements which includes Initial and "Recurrent" training.
Dare us to use some logic when it comes to climbing this mountain of training? Since everything having to do with safety is equally important, but no one has time to pull pilots off the line for three weeks every year, we build and reinforce the pyramid of knowledge each year one block at a time. In the beginning (Initial Basic Indoc), everything is covered. At Advanced Aircrew Academy, we can even customize all your training to your specific operations. New pilot knowledge is an inch deep and a mile wide, but each year reinforces the foundation. Annually, the topics reinforced are subjects like Emergency Procedures, Crew Resource Management, Weather, TSA, and an element of navigation (i.e Instrument Procedures, PBN). Then, each "Recurrent" we dig deeper into rotating topics over the next 24-months. Hazmat, Alcohol and Drug Misuse Prevention, FAR AIM Review, Regulatory, CFIT, Wake, Runway In/Excursion, SMS, EFB, Performance, PBN, Instrument Procedures, Mountain Flying, TCAS, etc. and yeah, RVSM.
As rules and regulations change, topics are introduced, brought to the forefront, and then slid back into the rotation of reinforcement. ADS-B, CPDLC, and EFB (if authorized) are currently in the need for foundation, but as pilots learn and understand, it will be another solid block of foundation for the next new gadget, technology, automation, or rule to sit upon.
If training anxiety is still causing you insomnia, this will help you understand – and fall asleep. Flight Standards 8900.1, Volume 3, Chapter 19, Section 10B2 states: "Title 14 CFR does not require that every subject and topic of training be reviewed during each cycle of training. POIs should encourage operators to construct recurring training outlines with different topics and elements emphasized in each cycle of training, so that when an element is addressed, it may be addressed in adequate depth." Hurrah, there is logic in that statement!
If your training manual Is not clear on how you want to conduct recurrent training, it may be time for a training manual update. Go armed with the guidance in the 8900.1 and an intent to take your training program to a higher flight level. That way, the next POI, Chief Pilot, Director of Operations or auditor will have clear guidance to follow on how you administer recurrent training.
Even the most safety conscientious, enthusiastic pilot must prop their eyelids open during the last of their ground training. Ground training/learning is like an electric current; if there is too much flow there will be a resistance build up and eventually, it will fry the component. We want to put a reasonable yet frequent flow of information into pilots. By making sure the flow of foundational pilot knowledge is strong, we can then build on with everchanging technology, rules, and regulations.
The final building block for you to work on is setting training parameters based on what type of operations your flight department is doing and work it out with your POI by using logic. If you are constantly flying into mountain airports, then add the entire Mountain Flying eLearning module to your 12-month "Recurrent" training even if it's not "required". If you are an International Flight Department, then maybe you want to include a certain territory every 12-months instead of every 24-months. It’s your flight department and you have the power to tell the FAA how you want your training set up. Just be ready to prove it, and to change it when your operations change. Gone are the days of cookie cutter training – or at least that’s what we believe.
At Advanced Aircrew Academy, the final decision is always up to you. We guide and suggest but we can't make the decision for you. Just remember there is nothing we can't do for your general operating subject curriculum! If your training or operations manual isn't specific, let's use logic to set up a defined schedule of rotation on topics. If you need emphasis on a topic, just let us know. If, for example, your new-hire pilots are struggling to understand what Ops Specs are or what a GOM is, we can add your specific flight department information to the Regulatory eLearning module.
Once you have a curriculum plan, each year when we send you the notice that we are putting together your "Recurrent" training, you won't clench and reach for headache medicine. You will breathe a sigh of relief that your pilots are getting the best education and your POI will walk out of your office with all the boxes checked on the audit list and a smile on their face (well, that's a stretch).
Advanced Aircrew Academy has an unlimited number of Training Modules for pilots, mechanics, flight attendants, and schedulers/dispatchers. If you have a question, you can check out our website, www.aircrewacademy.com/ , find us at firstname.lastname@example.org or call 843-557-1266.