Stalls Redefined as Emergency Flight Operations
I managed to watch the recent NAFI-sponsored ACS webinar on replay (http://www.mentorlive.site/program/3.html). I’d like to offer a different opinion from those provided by the FAA and ACS committee members in this video.
First, let me say that in all my comments on the ACS (Airman Certification Standards) beginning in 2013, I’ve never publicly mentioned any ACS committee member’s name or publicly commented on any committee member. I have no desire to hurt or embarrass anyone. I don’t do those types of things. Instead, I’ve kept names and personal references out of these discussions except where a specific ACS committee member elected to identify him- or herself in a public forum. This is the first video (other than my debate with a main ACS committee member John King) where a primary ACS committee member and FAA leader have elected to comment about the ACS in this type of public forum. Therefore, my comments here reference the opinions offered in this video. Once again, I will use no names because my intent is not to criticize any specific person. I prefer to criticize ideas, instead. The ACS committee members are all fine people and some are considered friends (how many still are is open to question:). I’m interested only in ideas, not personalities. And, as I’ve said numerous times: I’m not anti-FAA, I’m anti “bad ideas.”
That said, I believe the FAA and ACS committee are inflicting a terrible wound on general aviation (I've chosen my words carefully here). These folks may have good intentions but that's irrelevant. It's what you do that counts. And what they are doing will not serve general aviation well. Five years ago, anyone who suggested that the FAA would stop testing private and commercial pilot applicants on slow flight at MCA, much less test commercial pilot applicants on full stalls, would have been pilloried and placed in public stocks—or at least laughed off the airport. Well, that's exactly what has happened under the leadership of the ACS committee. So strap in, hold on tight and be prepared to better understand how this committee is disassembling the fundamentals of basic flight training one behavior at a time.
The ACS Webinar
A few things in this video caused me to raise an eyebrow enough so that I can now scratch my back with my forehead. One of these was the discussion of stalls (time 20:25 on video). If you listen to the discussion here, you’ll hear the presenter say that the ACS committee wrestled with the slow flight issue trying to “make it match” the new standards. Make it match? Really?
As you know, the FAA no longer tests a private or commercial pilot applicant’s slow flight skill at Minimum Controllable Airspeed (MCA). The FAA and ACS committee feel that continuous operation of the stall horn during slow flight desensitizes a pilot to the necessity of taking immediate action to recover from a stall. The FAA and ACS committee were so committed to this change that the FAA removed the term Minimum Controllable Airspeed (MCA) from the slow flight section of the 2016 Airplane Flying Handbook (AFH). It’s completely gone. Now the standards in the ACS match. Good grief! (Note. So significant was training pilots to fly at MCA that, in the earlier versions of the AFH, the FAA had nearly two pages of text explaining and elaborating on the idea.)
Many highly experienced members of the flight instructor community believed this change to be a step backward in the development of essential airmanship training. So, the FAA and ACS committee had to rationalize this change. What explanation did they come up with? The ACS committee members in this video offered this explanation: “We are testing slow flight because you have to go through slow flight to get to the stall.” Let that sink in a bit. Read it again. This is the official FAA "slow flight" language that appears in FAA/ACS literature.
Really? This is an example of fantasy-based flight training. I wonder how many experienced instructors actually agree with the idea that the transition time between stall horn (or light) activation and the actual stall (for the purpose of demonstrating a stall) is a sufficient substitute for training at “minimum controllable airspeed?” Furthermore, the FAA no longer tests full stalls on a commercial checkride. Therefore, if a commercial pilot applicant is allowed to recover from a stall at the first peep of a stall horn, then how can that applicant "pass through" slow flight to get to the stall? He can't. Therefore, by FAA/ACS committee definition, that applicant couldn't have been tested on slow flight at MCA. These are the contradictions that creep into doctrine as you try to "make things match" without thinking them through clearly.
While watching this video I also observed, for the first time, the FAA and ACS committee’s new definitions for three different flight conditions (see accompanying graphic). The ACS committee redefined flight from the point of stall warning up to the critical angle of attack as an “abnormal flight operation.” Flight faster than the stall warning speed is defined as a “normal flight operation.” By creating the artificial designations of normal and abnormal flight operations the ACS committee was able to comfortably state, “We’re testing slow flight such as you would use in a normal flight operation such as in the traffic pattern.” By this new definition, normal flight operations are those that don’t activate the stall warning device. Let’s remember that the FAA/ACS committee allows pilots to be tested on their slow flight skills at speeds up to 1.34 Vs. That’s faster than the speed at which most manufacturers recommend flying a fully loaded airplane on final approach.
But wait! There’s more. In this webinar, stalls were redefined as an “emergency flight operation.” Keep in mind that when the ACS committee redefines something, it is most likely doing so to make the “thing” in question “match” the new standards. The ACS committee redefined a stall as an emergency flight operation for a very good reason. The FAA/ACS committee is no longer concerned that you can demonstrate your ability to recover from a stall on the commercial checkride (i.e., full stalls are no longer required by the commercial ACS). It is, however, very concerned that you can recognize and avoid a stall (I’m concerned about both). The thinking here is that if pilots are trained only to recognize pre-stall clues, they won’t stall. This is a naïve assumption.
Isn’t it reasonable to assume that most of the stall type accidents occurring over the past several decades had activated stall warnings (horns/lights) prior to ground impact? Are we to assume each pilot involved in one of these accidents recognized but “consciously dismissed” the stall warning? Most likely there was a stall horn (light) to be heard prior to ground impact. Isn’t this evidence supporting the idea that hearing a stall horn isn’t an inoculation against stalling? Isn’t this what common sense suggests? It certainly is why a NASA study once indicated that in over 2/3rds of all stall spin accidents where the pilot survived the crash, he or she didn’t remember hearing the stall horn. That also means that 1/3 of surviving pilots did hear it but did nothing about it.
Ask yourself why the pilot of Colgon Air stalled his airplane and continued pulling aft on the yoke for 37 seconds (until hitting the ground) with the stick shaker activated? He did so for numerous reasons but not because he consciously dismissed the obvious stall warning. He simply didn’t have enough experience with all the pre-stall clues that should trigger the proper stall recovery behavior, nor was he trained in the proper procedures to recover from a stall (you don’t pull aft on the yoke if you hope to recover from a stall). This is why all general aviation pilots need extensive training in slow flight at MCA as well extensive training in stall recognition and recovery procedures. It’s also why the FAA wrote the following in the pre-2016 version of its AFH: “…a ‘feel’ for the airplane at very low airspeeds must be developed to avoid inadvertent stalls and to operate the airplane with precision.” This statement or some variation of it was in all AFHs and FAA Flight Training Handbooks for the past 45 years. It is, however, no longer in the current AFH. I can only assume that the FAA no longer believes that this statement is true.
Additionally, referring to stalls as an “emergency flight operation” makes pilots more afraid of them and less likely to practice them. Yet, this definition helps the FAA/ACS committee defend the idea that full stall demonstrations should not be a required maneuver on the commercial checkride. After all, we are supposed to “avoid” emergency flight operations, aren’t we?
A part of me thinks that the FAA will eventually eliminate full-stall demonstrations from the private pilot checkride. They have to if they want to be logically consistent with ACS philosophy. After all, when pilots stall an airplane during private pilot training, they’ll hear the stall horn but keep pulling aft on the yoke until the airplane fully stalls. This is the opposite of the conditioned-response to the stall-warning stimulus that the FAA desires. It seems quite clear that the FAA believes that training pilots to remain solely within the envelope of “normal flight operations” makes them less likely to stray into the abnormal or emergency operations environment. And this is why I’m going to offer the following idea. It seems a bit heretical but it also seems to logically flow from the FAA’s evolving ACS philosophy.
It’s entirely possible that the FAA/ACS committee’s master plan is to make pilots and their instructors anxious (i.e., afraid) of stalls. Before you run off thinking that I’ve lost touch with reality, let’s remember that lead man on the ACS committee actively promotes the idea that pilots should be told that, “Flying is not safe.” His words, not mine. (Isn't it more accurate and reasonable to say that flying can be as safe as we want it to be?) Let’s also remember that fear is a very powerful motivator and this idea is not lost on some ACS committee members. Fear is the easiest of all cognitive behaviors to condition (e.g., get a painful bite by a spider and most folks will develop a significant fear of spiders. This is known as a one-trial learning).
If we define stalls as an “emergency flight operation” we’ve now given pilots a reason to be anxious (fear of the future) even before they perform their first stall. But if we assume that pilots will recover at the first indication of a stall, then they’re not in an actual emergency operation. Defining stalls as an “emergency flight operation” does nothing to increase a pilot’s understanding of stalls but it goes a long way in teaching others to fear them. I’ve never known pilots to be better off by making them frightened of stalls in lieu of helping them understand stalls.
Now you know why so many pilots and their instructors fly approaches at 1.4 to 1.6 Vs instead of 1.3 Vs as most manufacturers recommend. They’re afraid of flying too slow. Do you think the elimination of flight at MCA will help eliminate a pilot’s fear of flying at slower speeds? I certainly don’t. This also helps explain why too many pilots are afraid to exceed 30 degrees of bank in the traffic pattern. Pilots are told that exceeding this bank angle increases their exposure to a potential stall-spin scenario (this FAA recommendation is new and only appears in the 2016 AFH, not earlier versions, as best I can tell. If you want to establish 30 degrees as a personal limit in the traffic pattern, that’s fine. Just don‘t do so on the basis of fear).
Finally, let me say that I’m not a conspiracy buff. But I can’t help but see a disturbing pattern here. Here’s how it looks to me.
- First, we tell new pilots that slow flight at MCA is “abnormal” and that we don’t do abnormal things in an airplane.
- Then we remove all statements referencing MCA (an abnormal flight operation) from the Airplane Flying Handbook.
- This is followed up by saying that we’ll only test for commercial piloting skill in the airplane’s “normal operating range.”
- And just to be on the safe side, we’ll allow pilots to demonstrate slow flight at a speed that’s actually higher than the typical approach speed manufacturers recommend for their airplanes (all the while hoping that these same pilots won’t notice the logical inconsistency here).
- Then we will tell pilots that stalls are an emergency flight operation and eliminate these from the commercial pilot ACS.
- To top it off, we’ll ask someone to be the lead man on the ACS committee who is on record saying that, “Flying is not safe.”
- Finally, if we don’t hear too much grumbling from the flight instructor community, we’ll eventually eliminate the full stall demonstration requirement from the private pilot ACS.
Color me a skeptic, but doesn’t it seem as if the FAA and ACS committee are replacing fear for understanding in hopes of reducing loss of control accidents? Hmm?