September 1, 2004
By Bruce Landsberg
Bruce Landsberg, executive director of the AOPA Air Safety Foundation, has observed a few flights that didn't quite meet the PTS.
Recently I engaged some friends at the FAA in a not-so-philosophical discussion regarding the practical test standards (PTS) as a guide to pilot proficiency. This is the guidance issued to CFIs, pilots, and designated pilot examiners on how well pilots should fly on checkrides. Over the years it has, as government documents are prone to do, become thicker, harder to read, and more precise as generations of lawyers and well-intentioned bureaucrats have sought to remove ambiguity and subjectivity. Which side of "notice of flight check disapproval" that you reside on at the moment could shade your view on whether more waffle room for an examiner is a good thing or not.
Here's an admittedly controversial thought. If all pilots flew to the minimum standards specified in the private pilot or instrument pilot PTS (when IFR), the accident rate would drop like a grand piano in a Laurel and Hardy movie. Pilot standards were set decades ago, but are they still valid today? I believe that with a few tweaks, they are. I've spoken before about the "physical airplane" — all the stick-and-rudder skills to include takeoffs, landings, IFR approaches, heading, altitude, and airspeed control. The "mental airplane" includes programming the avionics, knowing where you are (situational awareness), knowing the pilot's operating handbook limitations, aircraft systems, and the general flight-planning requirements. The final area and the hardest to measure is judgment, decision making — the risk management skills that overlay the other two. A pilot can be a top gun stick, a wiz on the aircraft numbers and avionics, and still stick it in the dirt if lousy judgment leads him into temptation in a marginal-weather situation.
Physical airplane accidents are usually VFR fender benders, but not always. They always occur close to, or on, the ground since nobody ever collides with the sky. Landings, takeoffs, and stalls are prominent examples. Handling an aircraft on instruments is another physical area, but these tend to be serious accidents. Mental airplane accidents are harder to define and overlap the judgment area. This might include a misprogramming of avionics that leads an aircraft off course in instrument conditions or getting lost. Judgment accidents are often serious, such as VFR into instrument meteorological conditions, low-level buzz jobs, and night flight encounters with terrain, and frequently require such high degrees of physical or mental aircraft skill that no rational pilot puts himself into those situations.
There are 13 areas of operations in the Private Pilot PTS and within those areas are specific tasks that pilots must perform to a standard. Since landings account for so many accidents let's look at what the PTS require. This is condensed for space but you'll get the idea: "Considers the wind conditions, landing surface, obstructions, and selects a suitable touchdown point. Establishes the recommended approach and landing configuration and airspeed, and adjusts pitch attitude and power as required. Maintains a stabilized approach and recommended airspeed, or in its absence, not more than 1.3 V SO, plus 10/minus 5 knots, with wind gust factor applied. Makes smooth, timely, and correct control application during the roundout and touchdown. Touches down smoothly at approximate stalling speed. Touches down at or within 400 feet beyond a specified point, with no drift, and with the airplane's longitudinal axis aligned with and over the runway center/landing path. Maintains crosswind correction and directional control throughout the approach and landing sequence. Completes the appropriate checklist."
My take is that if every pilot could perform to this standard, as generous and undemanding as some take it to be, landing accidents would virtually disappear. Any CFI routinely giving checkouts can tell horror stories of pilots who, if they were taking a practical test, would be pink-slipped immediately. In most cases the pilots were rusty on the physical skills and only needed some instruction and practice to meet the minimum. The PTS set a solid guideline. Admittedly, 400 feet of float and 10 knots fast on the ref speed for landing is charitable, but under normal conditions it's safe.
Let's take a condensed look at a mental airplane task under navigation systems and radar services: "Demonstrates the ability to use an airborne electronic navigation system. Locates the airplane's position using the navigation system. Intercepts and tracks a given course, radial or bearing, as appropriate. Recognizes and describes the indication of station passage, if appropriate. Recognizes signal loss and takes appropriate action. Uses proper communication procedures when utilizing radar services. Maintains the appropriate altitude plus or minus 200 feet and headings plus or minus 15 degrees."
This applies to VOR, NDB, GPS, even four-course ranges if you could find one, and it meets all the safety criteria. In simple terms, pilots need to know how to use the gear, know where they are, and how to get somewhere else with it. Maybe I'm missing something, but what else is there to say and how much more complex do we need to make this? Whether the aircraft has glass or steam gauges is completely irrelevant to the application of this standard.
What about the judgment, decision-making business? Good judgment is devilishly hard to quantify precisely, especially in a stranger who will spend only a few hours demonstrating his or her skills in return for a pilot certificate. The PTS describe what constitutes satisfactory performance: "...to safely: perform the tasks specified in the areas of operation for the certificate or rating sought within the approved standards; demonstrate mastery of the aircraft with the successful outcome of each task performed never seriously in doubt...demonstrate sound judgment...." I will concede this is extremely tough to measure and everyone will be on his or her best behavior during the check. There's more to say on this in a future column.
It's my contention that if pilots consistently flew to the PTS it would be difficult to have an accident where the pilot was at fault. I wonder how many certificates are issued if a nonmechanical accident occurs during the practical test. My bet is there are very few and I'd love to hear the circumstances.
So is the bar set at the right level? Standards (and minimums) are arbitrary and can be set where the community thinks it is appropriate. We have many examples. Air traffic control standards for performance are near perfection and to date, the U.S. record is outstanding. For airline pilots, ditto. For the brain surgeons, trial attorneys, or pharmacists who recently finished school, they just passed a minimum standards test and now hold somebody's well being in their hands. For automobile drivers the requirements are fairly low by necessity and application of the rules is spotty. With private pilots the bar is higher and by definition, those standards are also minimums. Did you measure up on your last flight and more important, could you pass a private pilot checkride on your next one? My opinion is we don't need more rules, higher official minimums, or more "clarification." The guidance is fine — it's up to us as pilots and flight instructors to follow it.
We'd like hear your thoughts, especially if you are a CFI or designated examiner who deals regularly with the PTS. Tell us what you like, what you'd change, if anything, and why. Cite some examples to support your case. E-mail it to firstname.lastname@example.org.
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