ACS Changes? Don't Celebrate Yet

Flight instructors! Remove those party hats, collect the confetti and deflate those balloons because this is no time to celebrate. Celebrate what? I'm speaking of celebrating the FAA's semi-reinstatement of full-stalls in the June 2018 Commercial Airplane ACS.

It turns out that due to the good workings of organizations such as S.A.F.E., the FAA elected to partially reinstate requirement for commercial pilot applicants to perform full stalls instead of recovery at the first indication of a stall (which is typically the horn or light, neither of which is an actual indication of a stall). As the Commercial Airplane ACS excerpt below shows, the DPE (Designated Pilot Examiner) can decide for him- or herself whether or not to have the applicant perform full stalls. What was once a certification standard (i.e., full stall demonstration) is now a certification suggestion, as in Airman Certification Suggestions.

Last year the FAA issued the first iteration of the Commercial ACS and in it eliminated the requirement for a full-stall demonstration. (Read: Stall Requirement Gone.) The most recent issue of the Commercial ACS (June 2018) allows the DPE to decide whether or not the applicant should demonstrate a full stall or simply recover at some aural (horn) or visual (light) warning that's encountered 5 to 7 knots above the speed at which a full stall occurs.

While this might appear as a significant FAA concession, I'd ask you to rethink that assumption. Ask yourself why the FAA is now allowing the DPE to set the "stall recovery" standard for a flight exam? Yes, that's exactly what's happening here (full stalls were once a "standard" set forth by the FAA). Now the DPE can decide for him- or herself whether or not an applicant's competency at recovering from a full stall should be tested. Hmm, on what basis will the DPE make this decision? What criteria will the DPE's use to place applicants in the "full stalls for this guy" and "no full stalls for that dude (or dudess)" category?

Of course, most DPEs who understand the psychology behind "stall recognition and recovery training" will ask for full stalls on a checkride. (Read: Stall Horn Fallacy.) But what happens when a DPE who services a major flight school or university is told by that entity that the resident instructors--for whatever reason--will no longer teach full stalls when preparing students for the commercial certificate? Will the DPE still require a full stall demonstration? If you understand human nature, it's a good bet that the DPE won't. Remember, it's up to the DPE to make this choice since he or she can now set a standard for stall demonstrations on a checkride. Furthermore, isn't a commercial applicant who is anxious about full stalls likely to ferret out a DPE who doesn't ask for them on checkrides? It certainly seems likely to happen. 

Given that so many pilots, quite a few instructors and some DPEs become anxious over full stall demonstrations (for whatever reason), there's a good chance that at least some DPEs will be less willing to request a full stall demonstration on a commercial checkride. The DPE's rationalization will be, "Well, the applicant has already demonstrated a full stall recovery on the private pilot checkride and that's enough." Is it? Hardly.

The fact is that if full stalls aren't required as part of the ACS it's not likely that they'll be examined and, perhaps even worse, not be taught. Let's remember that flight training seldom evolves to a level higher than the standard (except when good instructors are involved in the training). Instead, flight training tends to devolve to the minimum standard (or lower) where instructors of less competency are involved. I suspect that if this were not true, then loss of control (LOC) wouldn't be responsible for nearly 45% of all aviation accidents.

As I see it, the FAA threw a single bone to all the good folks who petitioned for the reinstatement of full stalls to the Commercial ACS. However, the FAA's offering reminds me of looking at a chihuahua. At first glance it looks like a really big dog that's far least until you walk toward it. Then you discover that it's a tiny little thing right in front of you. In other words, the FAA's offering looks worthy of celebrating, but it's really a very small thing (more for show) that will ultimately do very little good for the basic competency of tomorrow's commercial pilot. Excuse me for saying that I'd like less chihuahua and more meat on the bone.

So don't celebrate just yet. The FAA should reinstate the "standard" of full stall demonstrations on every commercial airplane checkride. Additionally, it needs to reinstate the requirement for a demonstration of flight at "minimum controllable airspeed" as well as reinsert the discussion of MCA in the Airplane Flying Handbook which was removed in 2016 (yep! Hard to believe, isn't it?) While I hate being a critic, someone has to ask why the compass that guides FAA oversight of general aviation is in desperate need of degaussing. That said, I have nothing but appreciation for those organizations and individuals who are attempting to right the FAA's wrong on this and many other issues.

So let me summarize what we're up against. In 2009 the captain of Colgan Air 3407 held the elevator full aft, in a FULL stall, for 37 seconds until impacting the ground. In 2009, Air France flight 447 descended in a full stall from cruise altitude to sea level. In 2016 the pilot of a Cirrus SR20 fully stalled her airplane during a botched go around...and on an on and on. Where should I stop listing all these "full" stall accidents? The one consistent thing about stall accidents is that the wings were stalled prior to the accident. As the FAA sees it, if pilots can learn to recognize the stall before entering one, then stall accidents will be eliminated. Therefore, there's no need for commercial pilots do demonstrate fulls stalls on a commercial checkride. As I see it, recognizing what to do when you're in a stall is just an important (if not more so) as recognizing when you're approaching a stall.

So what's the FAA's answer to the stall/spin loss of control problem? Here are just a few of the perplexing responses the FAA made in response to LOC. I'll list three, but there are many more.

  1. The GA branch of the FAA removed the requirement for demonstrating (thus teaching) slow flight at Minimum Controllable Airspeed for private and commercial applicants. (No, there's no FAA requirement to teach flight at MCA and I can assure you that most CFI won't teach this.)
  2. The GA branch of the FAA removed the requirement for commercial pilot applicants to demonstrate full stalls on their checkride, allowing in its place, applicants to recover at the first indication of a stall horn or light (the horn or light is not an "indication" of a stall. It's an indication that the airplane is 5 to 7 knots above a stall).
  3. The Air Carrier branch of the FAA recently created a new rule requiring airline pilots to undergo full-stall training during recurrency training. (Hmm, apparently full stall training is important if you have thousands of hours and an ATP but not so much if you only have a few hundred hours and no ATP.) 

 Ultimately, the FAA's actions deprive pilot applicants of the valuable experience of operating on the verge of a stall (MCA) as well as handling a fully stalled airplane. The net result is that today's pilots will have less experience and less capability at avoiding real-life stalls to say nothing about becoming more afraid of stalls themselves. As I see it, any reasonable person will consider the FAA's actions both unwise and impractical.

Once again, I am not anti-FAA. I'm anti-bad ideas.

By Rod Machado | | All Rod's Posts, PTS-ACS Arguments | 5 comments
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  • Walt Bogart - June 14, 2018

    This is the same FAA that was recently discovered to have dramatically lowered standards for applicants to ATC training. Obviously stall avoidance is most critical, think base to final or cross control stalls; but recovery is only possible if you’ve been there in practice. I think spin training is very important as well.

  • Joshua - June 13, 2018

    A step back toward sanity is a step in the right direction, but one thing I’ve wondered about for a while is the LOC accidents. When they removed spins from the testing standards and spin accidents decreased, did LOC accidents increase, decrease, or remain constant?

  • Russ Still - June 13, 2018

    Well said, Rod.

  • Charles McDougal - June 13, 2018

    You are right about the latest revision to the commercial ACS. A very real issue is present due to the examiner discretion for a full stall or a recovery at first indication. If an examiner tests one applicant and requires full stalls and the applicant fails the test due to poor control during recovery, then tests his next applicant and asks for recovery at the first indication, he is testing to two different standards. Issues of fairness to the public, treating one applicant differently from the next, and even favoritism are now all part of the ACS. This was, and still is, my feeling about the way risk management was integrated in the ACS. Because there is no objective standard for risk management, the examiner must interject his or her opinion in order to judge an outcome. Like you said, examiners are not dummy’s, and will be reluctant to fail an applicant for a risk management question based on personal opinion. So the whole thing turns into an exercise in teaching by guided discussion and feeling good about it afterwards. Not exactly a testing standard is it? I believe the same thing will happen (as you predict) with the stalls. If a full stall is chosen, what is the likelihood of failing the test during its execution when a recovery from a non-stalled wing would have sufficed? Although I am no longer examining, I cannot envision this resulting in anything but testing to the lowest common denominator.

    Thanks for your insights. It’s always a pleasure to read your work

  • Todd Johnson - June 13, 2018

    Rod is RIGHT ON here. I haven’t actively instructed a primary student for quite some time, but would not DREAM of depriving them of the valuable experiences of MCA and “all the stalls”. I’m somewhat appalled that the FAA would not require these demonstrations, and that they would remove all references in the handbook. Absolutely incredible, especially considering the accident rate. Thank you, Rod!!

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