A Report to Congress from the United Chapter of the Air Line Pilots Association (ALPA) Inadequate Pilot Training and Compromised Safety by United Airlines Within the Process of Merging the Continental and United Airlines’ FAA Operating Certificates into a Merged Single Operating Certificate (SOC) Updated November 10, 2011 SUMMARY The United pilots are deeply concerned about inadequate pilot training and the compromise in safety brought about as a result of the merger between legacy United Airlines and legacy Continental Airlines, as the airline seeks a Single Operating Certificate (SOC) from the FAA. The adoption of harmonized aircraft operation procedures must occur when two large and complex airlines such as United and Continental merge. It is important to note that on the fleets of concern, the B757/767 and B777, that legacy United pilots are adopting 80 percent of the changes in procedures. The new management of United Airlines has chosen to train pilots on this large volume of flight related procedures through computer-based training (CBT). This training is broken down into four phases; Phase 1, Phase 2, Phase 3A/3B and Phase 4. Historically, such a large volume of procedural changes, some of which are quite complex, would have required practice in a learning environment such as a simulator or classroom that allow for peer review and discussion. Computer- based training is acceptable for introduction or review, but unacceptable for cognitive absorption and development of the muscle memory required to produce practiced and proficient performance. United’s CBT via the internet has caused confusion and distractions, and pilots are now conducting on-the-job training on revenue flights with passengers aboard rather than in a simulator or classroom environment. This is akin to two surgeons watching a new surgical procedure power point and then practicing it together on an unsuspecting patient. United ALPA, representing the legacy United pilots, has appealed to all levels of United management and the FAA to resolve this issue, but to no avail. We, the pilots of United Airlines, are perplexed by the FAA’s process in accepting and approving what we deem to be inadequate training. The FAA typically requires a complete indoctrination course for pilots learning to operate airliners using procedures under a new FAA operating certificate, as is the case for legacy United B757/767 and B777 pilots. It also seems illogical that the FAA would assign an official who was recommended for suspension to approve the transition plan, integration and issuance of a Single Operating Certificate (SOC) for combining two airlines that will form the world’s largest airline, United Airlines. Less than three years ago, the same FAA Administration recommended Bobby Hedlund, the head of the UAL/CAL Joint Transition Team, for suspension for dereliction of duty in allowing Southwest Airlines to fly hundreds of flights with aircraft in an unsafe condition.1 Congress and its Committee on Transportation and Infrastructure held hearings on the Southwest situation, during which this FAA official’s misconduct was brought to light.2 United Airlines proved incapable of completing even the truncated portion of the already deficient SOC transition plan and were subsequently allowed, by this same official, to modify and further reduce the required portion of the operational integration. This approval will result in an operation in which only half of the flight procedures for the 1 Reukauf, William E., Associate Special Counsel ltr. to President of the United States dtd. 3/18/10 re. OSC File No. DI-08-1750. 2 http://www.youtube.com/watch?v=xmkYzwzKxgI&feature=email [i] common fleets, few of the procedures of the other fleets and almost none of the maintenance procedures will be integrated prior to United Airlines receiving a SOC from the FAA. The training program for the new procedures for the first half of the flight through the cruise portion has yet to be developed for the B757/767 and B777 fleets. Why the rush to SOC? For United management it would seem that executives’ personal compensation, in the form of poorly designed financial incentives, compromises safety. Why would the FAA not protect the interests of the flying public against such a conflict of interest? And why would the FAA appoint an inspector, known to have been previously deficient in his safety oversight of Southwest Airlines, oversee such critically important certificate integration? Why would these same officials, including United’s Principal Operations Inspector (POI), dismiss United ALPA’s safety concerns, which include this rush to SOC, the inadequacy of training and a number of other ongoing and disturbing safety concerns (Exhibits A & A2) United ALPA has tried to bring the deficiency of the SOC training to the attention of the new United management; every level of the FAA (Exhibits B-E), including the Administrator himself; the federal courts; and now Congress. Everyone is hiding behind the FAA. A number of stakeholders, including the public and their representatives in Congress, have been working under the assumption that the FAA is the top cop on the airline beat and ensures the highest levels of safety. We have found during UAL’s rush to receive an SOC that the FAA often isn’t effective or even methodical in its monitoring of airlines’ self- regulation due to limitations in the data it receives or chooses to analyze. The FAA is at best a weak safety monitor and at worst compliant and compromised when working with airline managers whose goals are cost-cutting at the expense of safety and for their own personal benefit. [ii] TABLE OF CONTENTS 1. History of a strong collaborative management/ALPA culture with regard to flight training and safety at legacy United Airlines, p.1 2. Former Continental managers who control the merged United Flight Operations do not value or collaborate with ALPA and their safety and training subject matter experts (SMEs), p.1 3. New United management has failed to properly plan, manage and train B757/767 and B777 pilots during the first two phases of the SOC process, p. 3 4. FAA oversight of United’s SOC process has been wholly inadequate, p.9 5. Pilot reports show great reason for concern, p.13 6. ALPA’s attempted TRO against United Airlines, p.15 7. Actions necessary to correct training and SOC deficiencies, p.16 Addendum: Exhibit A: Letter from UNITED ALPA to FAA Administrator Babbitt, 9/1/11, p. 18 Exhibit A2: Letter from UNITED ALPA to FAA Administrator Babbitt re. Aircraft Magnetic Reference Data, 9/6/11, p. 39 Exhibit B: Letter from UNITED ALPA to FAA POI John Martin, 9/2/11, p. 45 Exhibit C: Letter from FAA Asst. Director Gilligan to UNITED ALPA, 9/8/11, p. 47 Exhibit D: Letter from FAA POI Martin to UNITED ALPA, 9/27/11, p. 49 Exhibit E: Letter from UNITED ALPA to FAA Administrator Babbitt, 10/14/11, p. 52 Exhibit F: Exhibit F: Letter from FAA POI Martin to UAL VP Corporate Safety Quiello, 9/12/2011, p.65 Exhibit G: Letter from Associate Special Counsel William E. Reukauf to the President of the United States, 3/18/2010, p.67 Exhibit H: Resignation Letter from Line Check Airman (LCA), 8.26.2011, p. 70 Exhibit I: Resignation Letter from Line Check Airman (LCA), p. 75 Exhibit J: Partial Chronology of United ALPA/FAA Communications, p.76 References: Evolution of Crew Resource Management Training in Commercial Aviation, p. 77 United Airlines Flight 173 Accident Narrative, p. 88 Safety Management System (SMS) Explained, p. 91 2010 UAL Proxy statement, 4/22/11 (excerpted), p. 92 House Transportation and Infrastructure Committee hearing on 6/16/10 (excerpted), p. 94 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK- ALPA v. UNITED AIRLINES, p. 95 [iii] Glossary ALPA Air Line Pilots Association is the largest airline pilot union in the world and represents more than 53,000 pilots at 37 U.S. and Canadian airlines. ATP Airline Transport Pilot is the highest level of aircraft pilot rating/certificate. CAR Corrective Action Request is a formal request to an airline and the FAA to fix serious threats to safety identified in FSAP or other reports. CBA Collective Bargaining Agreement is a labor contract. CBT Computer-based Training is internet-based audio-visual slide show best suited for introductory or cursory pilot training or review. CMO Certificate Management Office is responsible for the certification, surveillance, and inspection of major air carriers and their Training Centers. FAA Federal Aviation Administration is the national aviation authority of the United States. FAR Federal Air Regulations are rules prescribed by the FAA governing all aviation activities in the United States. FBS Fixed-based Simulator is a device that duplicates relevant aspects of the aircraft and the cockpit environment, but is immobile. FMS Full-motion Simulator is a high-fidelity training device that duplicates relevant aspects of the aircraft and its cockpit environment, including motion simulation. FOQA Flight Operations Quality Assurance is a method of capturing, analyzing and/or visualizing the data generated by an aircraft. Applying the information learned from this analysis helps to find new ways to improve flight safety and increase overall operational efficiency. FSAP Flight Safety Awareness Program is a reporting system designed to identify and resolve flight safety concerns. JTT Joint Transition Team is the FAA group responsible for approving a SOC transition plan and integration. LOSA Line-oriented Safety Audit utilizes observers riding in cockpit jump seats to evaluate several aspects of crew performance. LCA Line Check Airman is a pilot who is qualified, and permitted, to conduct flight checks or instruction in the airplane. MEC Master Executive Council is the governing body for an ALPA represented pilot group.