The Airman Certification Standards
As most readers of my blog know, I'm not a fan of the new Airman Certification Standards (ACS) for many reasons, not the least of which I originally posted with the FAA in 2013 (click here to read that response). Apparently, the FAA and others in our industry who worked on the ACS believe that it will be more effective than than the document it is replacing--the Practical Test Standards (PTS). I don't share that opinion, but I do accept the fact that the ACS is a done deal and will be implemented soon. So be it (unfortunately). Nevertheless, it might be interesting to take a deeper look at a few issues that I did not address in my original response to the ACS.
As I see it, the PTS had evolved into a practical and useful document that most everyone liked. It was simple, easy to interpret and stood the test of time. That, in itself, should have rendered it untouchable by anyone wise enough to see its ultimate value. But this didn't happen. Instead, the PTS was modified to accommodate the FAA's "Postmodern" and "Fantasy-type" thinking about Risk Management into flight training. As a result, the once relatively objective PTS will now become the highly subjective ACS. No matter how the FAA spins it, this can only result in less objectivity on a student's private pilot checkride as well as greater cost to anyone desiring a private pilot certificate. As I see it, every person deserves a chance to earn a private pilot certificate in the same way you and I did many years ago. Unfortunately, the ACS makes this less likely to occur.
That said, I am against a major overhaul of the PTS when a simple solution—a Knowledge Testing Standard—was clearly the better choice. The ACS Q&As suggested that the aviation community needed a “more relevant knowledge exam.” Really? Relevant in what way? There’s absolutely nothing wrong with our current multiple choice questions that test a person’s knowledge (think SAT, ACT, GRE, etc.). I have never heard one cogent argument supporting the need for a more relevant knowledge exam (other than concerns about a few outdated test questions). Nor did I read any cogent argument to this effect in the ACS Q&As. To be frank about it, almost every response in the ACS Q&As had me shaking my head. So much of it was pure speculation and patronizing. Does anyone seriously believe that the ACS will reduce training times and costs? Believe me, I'd love to be proven wrong here. After all, less cost and time in earning a pilot certificate would only help everyone in aviation, not hurt them. Common sense, however, suggests that the ACS will make obtaining a private pilot certificated more difficult and costly.
Here is a short list of my concerns about the ACS that were not mentioned in my original response.
- The risk management concept in the ACS is highly “subjective” and will decrease the “objectivity” of the practical test. Look up the risk management concept of the “Composite Risk Index.” This is a scientific assessment of risk, which makes it a relatively “objective” assessment. The ACS uses a very soft FAA risk management strategy (it’s actually a “hazard avoidance” strategy, not a “risk management” strategy), which makes this a highly “subjective” activity. Please understand that your primary students are now responsible for addressing specific "highly subjective" risk management questions during their checkride without these questions having "objective" answers located in any FAA document. We are going from relatively objective standards in the PTS to highly subjective standards in the ACS (read my Risk Management blog to learn more about this). Ironically, even the FAA agrees that risk management is a "subjective" act, not an "objective" one as you'll read in two excerpts from the FAA's manuals.
Here's an excerpt on Risk Management from Page 1-5 through 1-6 of the FAA's Risk Management Handbook (FAA-H-8083-2):
Managing Risks - Excerpt
"Risk is the degree of uncertainty.... Risk management is unique to each and every individual, since there are no two people exactly alike in skills, knowledge, training, and abilities. An acceptable level of risk to one pilot may not necessarily be the same to another pilot...."
And here's an excerpt on Risk Management from Page 17-4 of the FAA's Pilot Handbook of Aeronautical Knowledge (FAA-H-8083-25A).
Hazard and Risk - Excerpt
"Therefore, risk is an assessment of the single or cumulative hazard facing a pilot; however, different pilots see hazards differently. For example, the pilot arrives to preflight and discovers a small, blunt type nick in the leading edge at the middle of the aircraft’s prop.... The seasoned pilot may see the nick as a low risk. He realizes this type of nick diffuses stress over a large area, is located in the strongest portion of the propeller, and based on experience, he doesn’t expect it to propagate a crack which can lead to high risk problems. He does not cancel his flight. The inexperienced pilot may see the nick as a high risk factor because he is unsure of the affect the nick will have on the prop’s operation and he has been told that damage to a prop could cause a catastrophic failure. This assessment leads him to cancel his flight."
- Despite what the Q&As suggest, I see no logical way the ACS will shorten the practical test, much less decrease the cost of training. The reason given in the Q&As in support of reduced training times and costs is (with all due respect) deeply naive.
- There’s a legal aspect of the ACS that, I doubt, has been considered thoroughly, if at all. In my opinion, the ACS will make it easier for any lawyer to pursue legal action (where no legal action is warranted morally) against a flight instructor based on the delineation of “highly subjective” risk management standards. As a flight instructor, I am deeply concerned about this.
- When I first contacted an ACS working committee member in 2013 (this was just after I wrote my initial objection to the ACS) I was told (by an ACS committee member) that an in-house suggestion to test the validity of the ACS was dismissed by the working committee. Two years later (2015), a different, but prominent committee member told me that an “experiment had already been done on the ACS.” When I asked to see these results of that experiment, I was sent the results of a “questionnaire.” Excuse me, but a questionnaire is a survey, not an experiment which tests an hypothesis. At the same time I was told that another “experiment” was underway in late 2015 at a South Eastern and North Western FSDO to test the ACS. My question is, “Why is an experiment being done after the ACS is set to be implemented?” Shouldn’t this have been accomplished before the ACS was set to be implemented? Doesn’t this seem like an idea (the ACS) in search of data to support it?
- Why did the FAA not give the “at large” GA community a choice to use the ACS and compare its “claimed” value, utility and ease-of-use to the PTS? If the claims made by the ACS Q&As are true, then the ACS would shorten training times and costs, and make it easier on the CFI and student. What flight instructor could resist that? If these claims were indeed accurate, the GA community would gladly support the ACS. Instead, it seems to me that the FAA is foisting the ACS on the GA community by fiat. After all, changing an FAA advisory book or manual (which is what the PTS is) doesn't require use of the FAA's formal rule making process. People can argue against this change, but if the FAA and industry "stake holders" feel they know better that the collective wisdom in the general aviation community, then these counterarguments carry very little weight.
- The ACS Q&As claim that the current private pilot knowledge exam needed a complete overhaul because of all the outdated and irrelevant questions students were being asked. Any capable flight instructor could have eliminated every single “bad” question in the current private pilot knowledge exam data bank in less than six hours. In my opinion, nearly all the questions on the private knowledge exam are valid and reliable test questions (save a few outdated ones). They have, after all, stood the test of time.
- I think the ACS working committee has a responsibility to “prove” that the claims made by the ACS Q&As are true before the ACS is implemented. The current Q&As are sadly lacking in proof of concept, much less arguments that convince or persuade. If the FAA is indeed conducting an actual test in a Southern FSDO area, then I’d like to see the results of that test. I’d like to see proof that training times and training costs are reduced. I’d like to know if the knowledge test scores of students actually increase and whether or not the designated examiner actually finds his/her job made easier because of the ACS. I’d also like to see how checkride times are reduced, too. I’d especially like to see the experimental data and the structure of the FSDO experiment being conducted. I have training in these areas and am very interested to see what it is that the committee is actually testing. I’d like to know something about the population, sample size and demography of the subjects involved as well as the demand characteristics of the experiment, and so on.
- To name a few more of my concerns (comparison between PTS and ACS below if you're interested).
I fully realize that I'm being a pest to the FAA and the ACS working committee members, many of whom are friends (I hope we still are). But I never offer criticism without also offering an alternate course of action, which is what I've done above. So let me be clear to all my readers that I’m not anti-FAA. Instead, I’m anti “bad ideas.” I’ve supported the FAA on many of their ideas over the years—and they’ve had some good ones, too. The new Airman Certification Standards (ACS), however, isn’t one of them. Yes, it’s an attempt to do good, but as I’ve said more than once, “Having good intentions is a highly overrated virtue.” It’s what you do that counts. In my opinion, the ACS will hinder and not help aviation training at the private pilot level.
Comparison of the PTS to the ACS
Below are two excerpts. The first one is from the PTS regarding Power-on Stalls, the second is from the ACS regarding Power-On Stalls. As you can see, the ACS appears much more complex because it is more complex. It almost looks like a syllabus--a practical "training" standard instead of a practical "testing" standard, which is what is has become by default. Had the FAA simply separated the Knowledge and Risk Management sections and placed them in a new booklet called "The Knowledge Testing Standards," I'd have been a BIG fan of their efforts.
PTS EXCERPT FOR POWER ON STALLS
ACS EXCERPT FOR POWER ON STALLS