Unusual Attitudes: ACS Makes My Head Ache

I should probably stick to telling flying stories, but ­occasionally I get so worked up that I can’t resist taking off on what I see as some new wacko FAA-mandated requirement or procedure. So it’s no surprise that the agency’s current ­“initiative” (in Bureaucratese) of replacing the Practical Test Standards with the Airman Certification Standards has me seeing red.

Unless you’ve been ­living in a cave, you ­probably know that the ACS has taken the place of the PTS, which 40 years ago replaced the Flight Test Guides … and there was nothing wrong with that test, except, in those simpler times, it wasn’t abbreviated FTG. If you’ve listened to me whine, you know I’m no longer a designated pilot examiner, but I’m a pretty good (well, OK, awesome) pilot and CFI who, for 50-some years, has trained and tested pilot applicants for everything from Sport ­Pilot to ATP and Lodestar to DC-3 type ratings. So I’m experienced, pretty well educated and reasonably intelligent, although something of an iconoclast. But despite a lot of digging and genuine attempts to be objective, I’m flummoxed by the rationale driving this overhaul in how flight instructors teach and how examiners are expected to administer practical tests. I simply don’t have a clear understanding of how this is supposed to work … or why.

My best take is that we’re supposed to believe these lengthy and complex changes — the product of a committee of “selected industry experts,” academics and FAA bureaucrats — are a guarantee that practical tests have finally evolved into something bulletproof and all-encompassing. But it seems strange to me that the actual mechanics of flying, communicating and navigating have been relegated to one small part of the testing procedure. The committee places huge emphasis on other parts aimed at an exhaustive assessment of an applicant’s knowledge, dexterity, risk-management skills and judgment … for all possible situations.

C’mon. That isn’t just a pipe dream of a group of mad professors, entrepreneurial training gurus and self-important bureaucrats, it’s a load of bull!

For an idea of how it impacts just one element — steep turns — in the Private Pilot Airplane PTS, look at the difference between the Private Pilot Airplane ACS and the superseded PTS.

Now the applicant sits for an oral, which assesses his knowledge of nine elements associated with turning an airplane at 45 degrees of bank and not blowing the altitude. If he makes it through what’s ­reportedly as much as a six-hour ­ordeal, he climbs into an airplane to demonstrate the four skills associated with performing a steep turn. But he still hasn’t passed until — before, during and after the flight — he can demonstrate and discuss six “risk management” elements, including concepts like energy management and task management. These ideas come out of the FAA’s newest best friends: “teaching” judgment, situational awareness, risk management, aeronautical decision-making, scenario-based training, and crew and single-pilot resource management. He’d better be able to regurgitate the PAVE checklist, considering Personal, Aircraft, enVironmental and External ­factors before taking off. And remember, this is just one ­element out of an entire test.

But why? What’s the rationale for a change, which, despite the FAA’s claims to the contrary, necessarily involves a substantial increase in the time and cost of practical tests?

The FAA’s official answer to why they’ve adopted the ACS, “to safely manage the risks of flight,” seems nebulous, especially with no proof of its effectiveness.

I have never believed you could teach or test good judgment in itself. But by discussion, demonstration and practice, the student examines the consequences of inadequate knowledge, poor decisions and lack of skill. He’s on the lookout for the unexpected. Call it “situational awareness” if you want, but it’s mostly common sense. But each person’s judgment and his assessment of acceptable risk are highly subjective. And there’s truth in the Will Rogers’ saying, “Good judgment comes from ­experience and experience comes from bad judgment.”

You can’t apply a rigid framework to dynamic sets of circumstances. In an excellent article, author Jeff Burnside says we’re trying to apply an objective test (like the PAVE acronym) to make a subjective decision that a proposed flight is risk-free. Same thing holds true with the ­much-touted risk-assessment matrix, shown here to the right.

A magneto is a “critical” item, and let’s say that on the before-takeoff check, there’s an excessive loss of power, and the engine pops and bangs. If this is an “improbable” occurrence — it doesn’t happen if you lean properly during taxi — and you can burn the carbon off the leads by running it up, the risk is “low.” But if it “occasionally” happens, even though you’ve leaned properly, the chart says it could be a “serious” risk. If you lose power in flight and switching to the left mag causes dreadful noises or total silence, continuing puts you at “high” risk.

If, on the other hand, your vertical speed indicator — a “negligible” item — “occasionally” shows a 100 fpm climb while you’re sitting on the ground, this is “low” risk. Deciding to launch into IFR conditions with a 100 fpm error might put you in a “medium” risk category (no, I don’t agree).

But, c’mon. Does any reasonably intelligent, decently trained pilot need something like the coloring-book illustration above to figure out when to stay on the ground or when to divert if there’s an equipment or weather issue?

OK, I probably have more than my share of bad personality traits for a pilot. I’m anti-authoritarian, too impulsive, and I think I’m invulnerable (well, until last year). So maybe my ­opinions about the ACS are baloney — but I’m not resigned (the fourth hazardous pilot type) to seeing it happen.

ActualIy, I’m still ­waiting for the call from President Trump summoning me to Washington to take over as the new FAA administrator and “make aviation great again.” Flying airplanes is, of course, inherently great, but think how much ­better it would be with fewer complicated, legalistic and too often unnecessary regulations, procedures and interpretations — not to mention fewer deskbound bureaucrats and academics who dream this stuff up. So, I promise, as soon as I’m ensconced at 800 ­Independence Avenue, heads will fall and there will be a saner approach to pilot practical tests.