European Regulators Prepare for Reduced-Crew Operations
EASA’s Plan for Regulatory Changes Is Set
By Gavin Francis, Senior Aviation Writer
The front line in the battle to stop reduced-crew operations is in Europe. And if we can’t stop it there, it won’t be long before we’ll be dealing with it here in North America. That’s the message ALPA hoped its members hear as the Association rolls out communications about regulatory changes that the European Union Aviation Safety Agency (EASA) is considering. These changes would make it possible for airlines to operate with only a single pilot on the flight deck during significant portions of certain types of flights.
Recognizing the implications that such a regulatory change would have for global aviation, ALPA has mobilized staff and resources to increase awareness about this possible rule change in Europe. Capt. Jason Ambrosi, the Association’s president, has called attempts to implement reduced-crew operations one of greatest threats to aviation safety. ALPA joined forces in early 2023 with the European Cockpit Association (ECA) and the International Federation of Air Line Pilots’ Associations (IFALPA) to oppose a change in the rules.
Like the FAA and Transport Canada in North America, EASA is the aviation authority responsible for ensuring aviation safety across the EU. While each EU country has its own national aviation authority, decisions made at the EU level by EASA are binding on all EU member states. EASA began studying the feasibility of reducing the number of pilots on the flight deck, particularly during cruise on long-haul flights, after aircraft manufacturers Airbus and Dassault Aviation approached the agency in support of the rule change.
A concept known as extended minimum crew operations (eMCO) would require one pilot to leave the flight deck to rest during cruise on long-haul flights, while the other pilot remains on the flight deck alone. An additional concept envisioned along the same line, single-pilot operations, would allow for the possibility of operations by a single pilot in all phases of flight. The Association recently released a white paper that discusses the Airbus single-pilot agenda in greater detail.
The push to implement reduced-crew operations is driven primarily by technological advances in flight deck automation and the promise of artificial intelligence. Airlines and aircraft manufacturers believe these advances will reduce labor costs. Proponents have argued for an aggressive timeline for implementation, suggesting that eMCO could be introduced before the end of the decade, and possibly within the next few years.
But safety advocates say that the presence of at least two pilots on airline flight decks during all phases of operations presents an irreplaceable safeguard, providing redundancy in managing emergencies and complex situations, and that regulators must first demonstrate that new and developing technologies can match or exceed current safety standards. Various safety studies by NASA and other groups have highlighted the significant risks associated with single-pilot operations, including the possibility of pilot incapacitation, increased pilot fatigue, and the challenges of handling complex decision-making processes by a single pilot.
The consensus among many safety experts, backed up by a NASA Ames Research Center study on the feasibility of single-pilot operations as well as FAA human factors research, is that current technology doesn’t yet provide, and certainly hasn’t been proven to offer, an adequate substitute for having at least two experienced, highly trained, and well-rested pilots in command of the aircraft. However, it appears that EASA isn’t listening to these experts.
At a minimum, EASA’s rulemaking could lead to a complex regulatory environment in which different regions have different rules, potentially complicating international operations. But more likely, it would set a precedent that pressures regulatory bodies in other regions, including in North America, to consider similar regulations. Indeed, EASA’s action on eMCO could influence decision-making within the International Civil Aviation Organization (ICAO), which sets global standards for aviation. And although individual member states would have a role in any proposal to change ICAO standards, if a rule change occurs in Europe, then there’s a risk that EU member states would likely act as a de facto voting block to support a similar change within ICAO.
“It’s obvious that manufacturers are pushing for swift approval of eMCO,” says Capt. Otjan de Bruijn, president of the ECA. “However, our position has been consistent from the beginning: eMCO is a gamble with safety. It’s an inherently dangerous concept, driven solely by the commercial interests of manufacturers and airlines.”
EASA’s rulemaking process, which can be long and complex, includes a best-intervention strategy in which EASA determines the most effective way to integrate new regulations or changes into the existing aviation regulatory framework. Terms of reference are also developed to define the scope, objectives, and timeline for a specific rulemaking task. A rulemaking group, consisting of experts from EASA, industry, and other stakeholder groups, is formed to develop the regulations or amendments based on the terms of reference.
Once the rulemaking group has drafted the regulations, they’re published for public consultation. A comment period allows stakeholders, including the public, to review and provide feedback on the proposed regulations. And after considering feedback from the comment period, EASA submits a regulatory proposal—a so-called “EASA Opinion”—to the European Commission, which will determine if the proposal becomes regulation. This process is supposed to ensure that rulemaking is thorough, transparent, and results in effective regulation.
ALPA, IFALPA, and the ECA have coordinated their opposition to eMCO and are actively engaged in advocating against the proposal, meeting with regulators to express concerns, providing subject-matter expertise, and submitting public comments. Additionally, these pilot advocacy groups have launched public-awareness campaigns like ALPA’s “Safety Starts with Two” and the ECA’s “One Means None,” which strive to educate policy makers and the public about the dangers and unacceptable risks associated with removing pilots from the flight deck.
Airbus is already developing a version of the A350 long-haul airliner that, if all goes according to its plan, will be certified for eMCO. But if it manages to push eMCO through, it’s doubtful the company will stop there as proposals for remotely piloted or even autonomous flight aircraft are already being discussed in some circles. Safety advocates must challenge any concept that would remove pilots from the flight deck to ensure that safety remains the highest priority. It’s crucial that stakeholders remain vigilant and engaged to protect the high safety standards that ALPA and its partner organizations have fought so hard to achieve.
“To prevent this risk to safety from reaching across our borders, we must work together with aviation regulators and stakeholders to discourage it across the globe,” says Ambrosi. “We can’t allow foreign regulators to grease the skids for their manufacturers, trying to force our hand to undermine safety here at home. And we can’t create unsafe conditions for American and Canadian passengers traveling into and out of North America on foreign carriers.”
