On Airman Certification Standards
You can help the future of aviation by providing your comments regarding FAA testing.
For years pilots have complained about the FAA knowledge test questions. While there are so many important things to ask pilots about, many test questions have made trivial distinctions. Worse yet, some test questions, by requiring interpolations on takeoff performance charts, have implied that takeoff distances can be relied on to the foot. Pilots relying on that level of precision from their airplane might be in for a very scary surprise or worse.
Wouldn’t it be nice if FAA test questions would always test pilots on the knowledge and insight needed to manage the risks of a flight, to get a safer outcome for themselves and their passengers, rather than trying to trick them with trivia?
Not only have pilots been given trivial questions when they take a test, there have been no standards for the knowledge test that would give pilots practical guidance on what they should study.
Plus, the Practical Test Standards have given pilots no guidance on what will be expected from them regarding how to conduct practical risk management.
Responding to these needs, concerned pilots within the FAA (yes, there a quite a few of them) successfully lobbied to create what is known as an Aviation Rulemaking Committee (ARC). The FAA solicited highly qualified instructors, examiners, and course designers to participate in the ARC. (Among the participants were John McWhinney and me from King Schools.)
After many long and thoughtful discussions this very engaged and committed group proposed improving the Practical Test Standards by including standards for the knowledge test and for risk management.
The FAA then sought another equally stellar group of industry leaders to guide the implementation of the program the ARC recommended. This group is called the Airman Testing Standards and Training Working Group (ATST WG). (Once again John McWhinney and I from King Schools participated.) After great effort this group has developed Airman Certification Standards for the Private Pilot and Instrument Rating, with more to come for other certificates.
There have been a few responses to the request for comments regarding the proposed Airman Certification Standards that have slammed the initiative as a ill-advised attempt to do something about the aviation accident rate. These respondents are truly concerned that this initiative will send the aviation community down the wrong path. The concern is that a focus on risk management is misguided.
Based on these comments, it is apparent the members of aviation training community who have labored for many months on this vital proposal have not adequately communicated that risk management is much more than just knowledge. It is a process that we hope that pilots will put into practice. Plus, it is far more than just “risk assessment” as some have implied.
It may be that some folks don’t fully understand that risk management has three basic elements: risk identification, assessment, and mitigation.
Identification is an important step in the process because many pilots are unaware that they have exposed themselves to risk. It is not uncommon that the pilot who comes to grief is, for just a few moments, about the most surprised person in the world–they simply didn’t see it coming.
Other pilots, such as those who continue VFR in worsening weather conditions, know they are taking a risk, but completely underestimate their probability of coming to grief because of it. They just have not learned to assess the risks they are taking.
Some pilots who fully understand risk identification and assessment fail to come up with a good plan to mitigate the risk.
All of these risk management elements are things that pilots simply aren’t going to get good at unless they have had some instruction and practice.
Finally, commenters refer to a study that says the vast majority of aviation accidents are caused by a failure of skill. That’s like saying that accidents are caused by the ground, because almost all accidents involve hitting the ground. Likewise, almost all accidents involve a failure in skill, because pilots who fail to adequately manage risk put themselves in a situation requiring skill they simply do not have, and could probably never acquire even with constant training focused solely on skill.
All of this points out the communication job the aviation community has ahead of us to make this very important initiative successful.
Here’s where you come in. These documents have been posted on the FAA website and we are seeking your input on these efforts in behalf of the future of aviation.
You can review the documents at:
Download and read the 5 files, and then click on the “Comment Now” button on the same web page.
Please help us make these Airmen Certification Standards documents better by giving us your advice and insight. You’ll want to do it very soon; comments must be in by July 8.