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Article appeared in Flying Magazine June 2019
by John King

The instrument rating requirement for commercial pilots created a hullabaloo in Juneau, Alaska that was just an early episode in the on-going dialog about the qualifications a commercial pilot should have.

For the commercial seaplane pilots in the area, it was not happy times.  The FAA had just mandated that all commercial pilots must have an instrument rating, or accept a limitation on their certificates prohibiting flying passengers for hire on flights of more than 50 nautical miles or at night.

This requirement was especially galling for these seaplane pilots, since the communities they served had no instrument approaches.  And flying seaplanes on instruments in the prevailing icing conditions was a really bad idea anyway.

Today, the commercial pilot certificate is changing again.  What you can do with the certificate, the airplane you need to train in and bring to the checkride, and what you have to demonstrate to the evaluator to prove that you are qualified are all changing.

All this is in the context of great demand for commercial pilots because of the airline pilot shortage.  Even though a commercial pilot certificate no longer qualifies a pilot to be a co-pilot in the airlines (they need an ATP now), it is a necessary step on the way to getting there.  Plus, of course, pilots still need a commercial certificate to be a flight instructor and for many other aviation jobs.

For several reasons flight schools are up against a wall.  There are not enough flight instructors.  And there is a severe shortage of complex airplanes—those with retractable landing gear, flaps, and a controllable pitch propeller.  For decades, commercial applicants have had to be trained in complex airplanes and demonstrate their proficiency in them on their practical test.  Like most pilots, Martha and I had to rent a complex airplane specifically for our commercial pilot training.  In our case we used a Cessna Cardinal RG.  Complex airplanes are increasingly expensive and, in some cases, just not available any more.  For instance, Cessna doesn’t even make a qualifying airplane.

The good news is that commercial applicants no longer have to use a complex airplane, and flight schools don’t even have to own one.  The 10 hours of training required for a commercial applicant in a “sophisticated airplane” can be conducted in any combination of a turbine-powered airplane, a complex airplane, and a technically advanced airplane.  And the checkride can be done in any aircraft that’s capable of doing the maneuvers—even a round-dial C172.

A technically advanced aircraft is what most of us would call a “glass cockpit.”  It must include a primary flight display (PFD), a multi-function display (MFD) with a map showing your GPS position, and a two-axis autopilot connected to the navigation and heading guidance.

Through the years, what is expected of a commercial pilot has evolved.  The first step in that evolution was the mandate for most commercial pilots to have an instrument rating.  Instrument qualifications remain an important part of being a commercial pilot.  Even though commercial pilots can still elect to not get an instrument rating and just accept the limitation, the FAA wants all commercial pilots to at least have emergency instrument skills.  So in preparation for the commercial certificate, all applicants must have ten hours of instrument training.

Many instructors consider the ability to fly the airplane without instruments equally as important, if not more important, as instrument skills are.  Their apprehension is that many of today’s new pilots are too dependent on modern technology.  This concern is exacerbated by crashes like that of Asiana Flight 214, which hit a seawall at San Francisco when attempting to manually fly a visual approach.  So, the age-old visual maneuvers remain a significant part of the requirements to be a commercial pilot.

The latest and most significant changes come as a result of the adoption of the Airman Certification Standards.  The ACS replaces the Practical Test Standards, which as the name implies gave guidance for the checkride.  By contrast, the ACS provides all the standards for being a pilot.  It is the result of a fabulous 8-year collaboration between the FAA and the aviation community.  I participated in this collaboration and believe it to be one of the most important and inspiring examples of teamwork I have ever seen.

Previously, the biggest requirement for pilots going for the commercial certificate was to be able to demonstrate their physical skill at flying the airplane.  Now the pilot’s ability to demonstrate their knowledge has become more explicitly required and for the first time there are standards for knowledge.

Perhaps the most drastic change as a result of the Airman Certification Standards is the requirement for applicants to demonstrate their ability to systematically identify risks and develop strategies for mitigating them.  There is some controversy about this requirement.  Many flight trainers contend that risk management cannot be taught and tested.  The argument is that the risks are so varied and situational that there can be no correct answer.

The inflection point corresponds with when risk management started being taught and evaluated.

When they say this, some people are thinking about “judgement” and “aeronautical decision-making.”  In that case, they are certainly right.  It is very hard to measure judgement and aeronautical decision-making.  Moreover, if someone tells you that you are a failure in these, it gives you no guidance for going forward.

On the other hand, if someone helps you develop good risk-management habits, they can be measured.  And the practice also will help you develop better attitudes, judgment and aeronautical decision-making.

So, what an evaluator is looking for is not correct answers, but correct habits.  A pilot with good risk management habits will continually maintain situational awareness and be thinking about ways to mitigate the risks they perceive.  As in the rest of flying, memory devices to make sure we don’t overlook things can be helpful.

Some pilots like to use the PAVE checklist in planning a flight to help them scan for categories of risk—in this case, risks associated with the Pilot, the Aircraft, the enVironment, and the External and internal pressures on the pilot.  In the air, the C-CARE checklist can help in mitigating the risks.  The first C prompts you to be aware of the Changes taking place.  Then CARE prompts you to think of the Consequences, the changing Alternatives, the Reality of what is occurring, and again the External and internal pressures.

The evaluator on your checkride may not require you to use those exact mental checklists, but you will need to demonstrate your ability to manage risks one way or another.

Now more than ever, the last thing any evaluator wants to see is an applicant who is fat, dumb and happy, and doesn’t see dangerous situations coming.  The goal is to create a new commercial pilot who is not just knowledgeable and skilled but is truly ready to be pilot-in-command.

There is a clear inflection point on the graph of the general aviation fatal accident rate when risk management began being taught through scenario-based training, and later, evaluated on the ACS.

I am very optimistic that we will see this trend continue.



  1. Dale Rust

    Yes, I must agree with Mr. McCormick and Triller. I am an ATP, CFII, MEL, Adv. Grnd & Inst Grnd Instr., with many hrs instructing, both basic and Inst. Instructing. Flew 133 Weekend AOPA Flight Training Clinics back when they were going strong, approx. between 1960 and ’88, mostly inst. refresher. Flew single pilot corporate for 21 years, the last 6 yrs in a Cheyenne II. Yet even though I can drive to the airport using my two god-given eyes, I cannot act as a safety pilot .. hence not give certain instrument instruction .. a bit of a farce, in my opinion. (i.e., no medical and my primary doc is not in the business of bestowing basic meds even though I am as healthy as .. most horses at age 85)

  2. Jerry

    I don ‘t agree with angry Dave. He needs to look into this much deeper and pull his head out of the sand. I am not speaking from uninformed inexperience. I have over 30,000 hours accumulated over 58 years which includes 6,000 hours as a GA CFII, the balance of my flying for 33 years was with a major airline, 6 years in ANG, nearly two years training to fly the space shuttle (before the program was cancelled due to the loss of two shuttles). I can guarantee you that risk management training was an integral part of my training in all these areas and invaluable when applied to GA flying. This risk management training can be approached with practical application without sacrificing any the piloting skills we had taught before ACS.

  3. Cal

    Don’t agree with angry Dave. It is sure expensive to fly and train however. Just did my IPC in my vans rv 9. Single pilot IFR sure is tough to stay current and proficient.

  4. Dave

    Just plane stupid!
    I am seeing first hand some of these today’s trained pilots. Skills are way down. The only reason why you are such a proponent of the new rules and standards is because you are making a buck off the process.

  5. Robert McCormick

    The shortage of flight instructor’s could be lessened if the medical requirements for CFI’s were adjusted to allow primary, and instrument, instruction to be given by CFI’s and CFII’s without medicals. As a 50+ year flight instructor I am prohibited from giving primary or instrument instruction because I cannot act, legally, as pilot in command.

    • Triller

      Amen!!! Same here. I’m looking to start a sim-based training business because of the medical issue but would rather be imparting my knowledge while airborne.

      If I can ride my 18-speed bicycle over 15-18 mi of hilly terrain every other day and 25-30 on the weekend, probably will be able to function sitting in an airplane. Also take care of a half-acre yard via a push mower, an edger (about 400 ft of drive & sidewalk edging) and then blow it all clean with a gas blower. Believe I can survive a student pilot.

      And yes, as most of us, I have a medical history and take “blacklisted” meds, for both joint pain, and one that is so-categorized because it was developed for a brain-related condition that I don’t have, its just been found to be effective for other applications. The med provides relief fm non-functionally-impacting light-neuropathy (not a deteriorating condition) and I can fully-function without it, just not as comfortably, If forced to do so, assuming I would otherwise qualify for a 3rd class OR a NEW more-relaxed “INSTRUCTOR-CLASS MEDICAL”, I would stop taking both.

      In the event of an in-flight impairment issue (if prior-denied CFI s were to be permitted to have a special “instructor” medical) a slightly-impaired CFI is probably STILL safer than a poorly-trained healthy solo student!

      One example, I know many individuals who sleep with a C-PAP device. None has ever fallen asleep on the job, in their vehicle or after we’ve played a round of 18-holes. So? SO WHAT! The FAA has to stop making up death scenarios in its collective head and apply, just as in the new ACS, a more practical and realistic scenario approach to CFI-medicals.

      Please excuse some of the “snarkiness”, I feel better now!

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