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On Airman Certification Standards

You can help the future of aviation by providing your comments regarding FAA testing.

For years pilots have complained about the FAA knowledge test questions.  While there are so many important things to ask pilots about, many test questions have made trivial distinctions.  Worse yet, some test questions, by requiring interpolations on takeoff performance charts, have implied that takeoff distances can be relied on to the foot.  Pilots relying on that level of precision from their airplane might be in for a very scary surprise or worse.

Wouldn’t it be nice if FAA test questions would always test pilots on the knowledge and insight needed to manage the risks of a flight, to get a safer outcome for themselves and their passengers, rather than trying to trick them with trivia?

Not only have pilots been given trivial questions when they take a test,  there have been no standards for the knowledge test that would give pilots practical guidance on what they should study.

Plus, the Practical Test Standards have given pilots no guidance on what will be expected from them regarding how to conduct practical risk management.

Responding to these needs, concerned pilots within the FAA (yes, there a quite a few of them) successfully lobbied to create what is known as an Aviation Rulemaking Committee (ARC).  The FAA solicited highly qualified instructors, examiners, and course designers to participate in the ARC.  (Among the participants were John McWhinney and me from King Schools.)

After many long and thoughtful discussions this very engaged and committed group proposed improving the Practical Test Standards by including standards for the knowledge test and for risk management.

The FAA then sought another equally stellar group of industry leaders to guide the implementation of the program the ARC recommended.  This group is called the Airman Testing Standards and Training Working Group (ATST WG).  (Once again John McWhinney and I from King Schools participated.)  After great effort this group has developed Airman Certification Standards for the Private Pilot and Instrument Rating, with more to come for other certificates.

There have been a few responses to the request for comments regarding the proposed Airman Certification Standards that have slammed the initiative as a ill-advised attempt to do something about the aviation accident rate.  These respondents are truly concerned that this initiative will send the aviation community down the wrong path.  The concern is that a focus on risk management is misguided.

Based on these comments, it is apparent the members of aviation training community who have labored for many months on this vital proposal have not adequately communicated that risk management is much more than just knowledge.  It is a process that we hope that pilots will put into practice.  Plus, it is far more than just “risk assessment” as some have implied.

It may be that some folks don’t fully understand that risk management has three basic elements:  risk identification, assessment, and mitigation.

Identification is an important step in the process because many pilots are unaware that they have exposed themselves to risk.  It is not uncommon that the pilot who comes to grief is, for just a few moments, about the most surprised person in the world–they simply didn’t see it coming.

Other pilots, such as those who continue VFR in worsening weather conditions, know they are taking a risk, but completely underestimate their probability of coming to grief because of it.  They just have not learned to assess the risks they are taking.

Some pilots who fully understand risk identification and assessment fail to come up with a good plan to mitigate the risk.

All of these risk management elements are things that pilots simply aren’t going to get good at unless they have had some instruction and practice.

Finally, commenters refer to a study that says the vast majority of aviation accidents are caused by a failure of skill.  That’s like saying that accidents are caused by the ground, because almost all accidents involve hitting the ground.  Likewise, almost all accidents involve a failure in skill, because pilots who fail to adequately manage risk put themselves in a situation requiring skill they simply do not have, and could probably never acquire even with constant training focused solely on skill.

All of this points out the communication job the aviation community has ahead of us to make this very important initiative successful.

Here’s where you come in. These documents have been posted on the FAA website and we are seeking your input on these efforts in behalf of the future of aviation.

You can review the documents at:!documentDetail;D=FAA-2013-0316-0001

Download and read the 5 files, and then click on the “Comment Now” button on the same web page.

Please help us make these Airmen Certification Standards documents better by giving us your advice and insight.  You’ll want to do it very soon; comments must be in by July 8.

John King


  1. Sherry Richardson

    Unable to comment on FAA test questions. Here in Canada we deal with Transport Canada and I don’t have much of a problem with their questions.
    Sorry, I cn’t be more helpful.

  2. Pat Hill

    As DPE we are required to review subject areas missed on the written test on the practical test. I have always followed this because I have to ,but have always questioned the validity of the written v/s practical test.
    Covering areas missed on the written test because of “bad wording” on the written has always been such a waste of valuable testing time.

  3. Paul Dawson

    John and Martha’s comments concerning changes needed in FAA testing are right on. Unfortunately the proposed changes to the Practical Test Standards don’t address very many of them. I’m afraid that changing the mentality for testing requirements is a very slow process.

  4. Fred Thompson

    Will do; glad to help out. You and the committees are on the right track to incorporate decision making in the tests.

  5. kinoworks

    I have responded after reading material to FAA supporting much of what you have pointed out here.

    However, in the material, I did not see any indication that they are looking at changing the arcane, out of date, and obsession of “tricky” over substantive questions. A change that is badly needed.

  6. Robert W Stansfield

    The FAA tests are not bad up to a point. You comment about trivia is correct. While I understand the need to have test answers clost togeather, they are sometimes too close and it becomes a toss up not a knowledge issue. One area I believe we need to concentrate more on during tests is weather. I don’t mean just yes or no, but meaningful and practical weather problems on the ground an in flight. The flight portion of the test is a great place to test an aspiring pilots decision making. If he choses on decision then the test may move in a different direction than if he chose another. Both paths may come togeather in the end, or result in a different ending. Either way, the pilot gets to make meaningfull decisions.

  7. Barbara O'Grady

    Excellent commentary.

    While competent piloting skills are crucial to flight safety, a study of accidents shows it is the Human Factor that is the root cause of most accidents. Pilots are failing to recognize the limitations of their skills and getting into situations that exceed them.

    Since CRM training was mandated for the airline industry, the number of accidents due to Human Factors has been cut to nearly zero among developed world carriers. Common wisdom holds that such training is not relevant to General Aviation. Not true. As a Human Factors instructor and course developer who has taught classes for Part 121, Part 135 and Part 91 pilot groups, I can attest to the fact that it is possible to teach Risk Management to pilots at all levels, students to professional, flying all types of operations.

    Every pilot has to interact with a Flight Instructor during initial training, in the course of attaining additional ratings and certificates or during a Flight Review. CFI’s are crucial to the education of the GA pilot population as whole. Not only must the Knowledge Test and all material related to Flight training be updated to include Risk Management (RM) and its related skills, but all CFI’s must be trained how to teach and evaluate those skills. The 2008 Aviation Instructors Handbook addresses Risk Management in detail but how many instructors who received their certificate before that date ever refer after that fact?

    In June of last year, the Private Pilot PTS was updated to include RM/ADM/SRMS. The Santa Rosa, CA, FAASTeam worked with the Western Pacific Division to develop a Wings seminar to educate CFI’s on how to teach Risk Management. In addition they developed a detailed checklist to enable CFIs to observe and evaluate those skills. Risk Management can be taught.

    B. O’Grady/CFI

  8. John Epperson

    Thanks for info guys….good to know u are right on top of all current Issues just as always have been. Hope to get to ur area one of these days.? Fifi and Alum. Overcast gave me two low passes over the house in Berthoud this morning…. Was beautiful sight…..hv a great day…….john….. U going to Wisconsin this year????

    Sent from my iPhone

  9. Ben

    I understand your frustration regarding FAA testing, and I think that applies to written tests in general. However, the tests are not there to teach situational awareness and judgement. That’s a job for the CFI. The tests are there so the student develops an appreciation for “attention to detail”. Getting the right answer for a takeoff distance problem is not for teaching judgement. It’s to teach the student how to read a chart (otherwise one could simply select the longest distance and be correct since it’s the most conservative answer). It’s the CFI’s job to interpret that answer and apply in the plane in a safe and conservative manner. In the actual airplane, the “right” answer isn’t necessarily the correct answer.

    However, I agree than many of the FAA tests could focus on more important matters, but the “details” still need to be covered in a way that proves the student knows the material. The FAA test questions, such as takeoff distance, are there so that the student knows how to read a chart. The CFI teaches takeoff distance so the student learns how to apply judgement (takeoff in the cool of the morning instead of the afternoon heat if rwy length is marginal, even if the chart says you can make it with 3 feet to spare).

    The FAA tests do need to focus more on the everyday safety situations a new pilot will encounter. But equally important is that CFI’s need to teach beyond the minimum FAA standards. How can they do that when most CFI’s can’t even spin?

    CFI, CFII, CFI-MEL, Aerobatics instructor
    I also push buttons on a B-777

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