Stall Requirement on Commercial ACS Gone! Replaced by Hearing Test!

Stall Requirement on Commercial ACS Gone! Replaced by Hearing Test!

Isn't it ironic that the FAA wants all pilots to have better stick-and-rudder skills while, at the same time, it dumbs down the flying skills required to obtain a pilot certificate? In case you've been in the Himalayas practicing chants with the Maharaji for the past year, the private pilot ACS no longer requires a demonstration of flight at minimum controllable airspeed. Same with the commercial ACS, but the FAA goes a bit further in dumbing down pilot skills in this document.

Hold onto to your wheel pants because the FAA no longer requires that a pilot demonstrate an actual stall recovery on the commercial airplane practical exam. You heard me right! A commercial pilot applicant is only required to recover at the first indication of an impending stall, which can be (and is for nearly all commercial applicants) the first "squeak" of the stall horn (or sight of the stall light). Sorry, but that's not a stall. At a minimum, the airplane is still five knots above an actual stall and the wings are not yet at their critical angle of attack. Remember, when the horn activates the wing is still flying! That's the way stall horns were designed to work. Yes, the FAA calls this a "stall" demonstration, but there's no actual stall involved. None! What the FAA calls a stall demonstration on the commercial ACS is actually a "HEARING" test, not a stall recovery test. Therefore, after commercial flight training, you might not be able to handle a real stall but you sure can tell when Sérgio Mendes is in the house. As I said before, I'm not anti-FAA, I'm anti-bad ideas. And this one is a doozy.

Not only is the commercial applicant required to identify the first indication of a stall, that applicant is also required to acknowledge the cues associated with this pre-stall condition. In other words, the applicant is required to say something like, "Hey, there's the stall horn...or maybe Sérgio Mendes is in your flight bag." Therefore, the FAA has added a specialized, in-flight, stall-lingo-only "English Proficiency" demonstration to the commercial pilot practical test.

Ultimately the FAA wants GA pilots to train and behave in the same way that airline pilots do, irrespective of the fact that GA pilots and the airplanes they fly are nothing like airline pilots and the airplanes they fly. The fact is that there is nothing about flying a bigger airplane that pertains to flying a smaller one, while everything about flying a smaller airplane pertains to flying a big one...yes, a generalization but a very good one.

As it stands now, airline pilots are taught to recover from a stall at the first indication of the stall, which is normally the stick shaker (that's a mechanical device and not the copilot who is anxiously trying to get the captain's attention by yanking on the yoke). Yes, airline pilots are now encouraged to practice full stalls and deep stalls in simulators, but not in the actual airplane.

However, starting next year the FAA will require airline pilots to do full stalls in their simulators instead of recovering at the first indication of a stall (as they now do). Do you see the irony here? Commercial pilot applicants no longer have to do full stalls in a small airplane where deficiencies in training can cause real anxiety based on real consequences (a tremendous incentive to remediate these deficiencies). Airline pilots, however, who already fly commercially will soon be required to do stalls in simulators that, to the best of my knowledge, have never physically threatened or hurt anyone having poor stall recovery skills. So once you are actually hired to fly commercially in a Part 121 operation, you're obligated to practice what you should have been practicing when you first obtained the commercial certificate. It's a strange world we live in.

While it's good training for experienced pilots to practice stalls in simulators there are limits to the value simulator stall training offers less experienced general aviation pilots. I'm reminded of the response by the famous martial artist Bruce Lee when he was asked if it was good to practice kicks and punches on a bag. Lee responded by saying, "Bags don't hit back." Lower time general aviation pilots do not receive the same benefit from this type of practice, even if the simulator is highly realistic. Why? Because simulators cannot teach you to respect an airplane. There's nothing like thinking that you have mastered stall recognition and recovery only to find out that, when distracted and uncoordinated at the moment you reach the critical angle of attack, the airplane rolls over on its back and heads toward spin city. That's how you learn to respect the machine you fly. Simulators don't hit back.

Unless commercial applicants can demonstrate that they can handle actual stall entries and recoveries properly, it's unlikely they will feel confident in doing them. Period! Nor will we know whether or not these applicants are actually capable of recovering from an incipient spin resulting from an uncoordinated stall entry. Yes, the private pilot practical exam does require that the applicant demonstrate an actual stall. Since when, however, do we assume that a single full stall demonstration during the private pilot checkride is sufficient to prepare an applicant to fly professionally?

Keep in mind that the average private pilot applicant has probably practiced stalls perhaps 15 times (if that) before he or she takes a private pilot checkride. These stalls were probably practiced under highly controlled conditions with their entries carefully choreographed and monitored by the flight instructor in the right seat. After all, most flight instructors are themselves highly anxious about doing stalls. Many of these CFIs are unlikely to expose a primary student to a full stall in anything other than carefully controlled, slow deceleration, wings-level, coordinated flight. So why do we think that 15 full-stall sorties (or less) is enough practical experience to give a commercial pilot applicant the best chance of preventing, much less avoiding the perils of an accidental stall encounter? Isn't this enough of a reason to require a demonstration of stall entry and recovery on the commercial checkride instead of simply requiring the identification of a stall horn? Common sense suggests it is.

The graphic below shows the evolution of the stall demonstration requirement for commercial pilot applicants starting with the 2002 PTS (Practical Test Standards) to the present 2017 ACS (Airman Certification Standards). Call it what you will, but this sure seems like a dumbing down of aviation skills to me.

1 comment

Greetings Ryan:

No need to feel sorry. That article was written in response to the FAA’s “first” Commercial ACS (not the current Comm ACS). The wording you presented is not what’s shown above. The ACS wording above was in the FAA’s first issue of the Commercial ACS (look carefully at the ACS excerpt. It’s dated 2017). The FAA subsequently changed the Commercial ACS in response to comments from the flight instructor community. This article reflects my thinking on the first issue of the Comm ACS only.

The important questions to ask about the newest Comm ACS requirements are:

1. Why does the DPE get to decide whether or not a pilot ‘should’ demonstrate a full stall? The DPE doesn’t get to decide this on a private pilot checkride, does he?

2. Why would anyone think that recovering at the first indication of a stall has anything to do with recovering from an actual stall (they’re two different things—read the article again).

3. Since when do we allow the DPE to make policy regarding what’s examined on a checkride (and that’s exactly what’s happening here in the commercial ACS)?

I have never received a satisfactory answer from anyone on these questions, especially not from the FAA.

Rod Machado

Rod Machado

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