PTS vs ACS

denverpilot

denverpilot

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Rod Machado has been pretty actively tearing into the new ACS and found some interesting stuff. He's been posting quite a bit of it on FB, but here's his latest letter...

https://cdn.shopify.com/s/files/1/0519/7057/files/Final_NM_Response_to_ACS_Committee.pdf

The really interesting one he's been debating lately is that the ACS no longer requires slow flight to be done with the stall horn on. In fact, it specifically requests it NOT be on.

His main concern can be boiled down to this... That the standards for the check ride just got a lot more lax, and there are always going to be instructors who will only "teach to the test". And where does a pilot who's instructor never gets them to fly slow enough to get the stall horn to come on, learn about flying in the area of reverse command for pitch and power?

As a "soon to be new instructor", myself, I can't say I'm particularly impressed with what's been dug out of the guidelines so far, either. Reminds me of Doc Bruce's icon and catch phrase... "Don't accept minimum standards."

Didn't see an ACS hread here yet, so here we go... Discuss...
 
I'll toss his screenshots here as a basis for the "no stall warning" change, with the highlights. I don't think he will mind.

165b823a6bb18012ff2d160ed0c742ea.jpg


e08b4b9df4eb1fb509ea6db1c4b4bde8.jpg
 
Slow flight can be any speed down to MCA actually. There is a difference. I haven't look at the new ACS as I may give up flight instruction. Is MCA in there at all? If not I agree with you and Machado's concerns.
 
I agree on his comments that risk management at the student level has nothing to do with reducing accidents. A student doesn't have the experience to decide what risk level goes with what operation. They don't know what they don't know. They're just going to automatically worst case every risk value because they have no clue the related risk they're dealing with. Even in the professional level the cookie cutter risk management/ risk assessment process does little in preventing accidents.
 
Velocity173 said:
I agree on his comments that risk management at the student level has nothing to do with reducing accidents. A student doesn't have the experience to decide what risk level goes with what operation. They don't know what they don't know. They're just going to automatically worst case every risk value because they have no clue the related risk they're dealing with. Even in the professional level the cookie cutter risk management/ risk assessment process does little in preventing accidents.
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Only way to get experience is to fly, but we all know that. The goal of the ACS as far as I can tell is to force applicants to read the risk management handbook and related pubs and get a knowledge base. Under the PTS, risk management was an afterthought.

Bob
 
The PTS has been changed several times in regards to slow flight. When I took my private pilot checkride, it stated to establish an airspeed of 1.2 x Vso. After only a couple years they changed it back to what the most recent PTS said.

I have always been critical of the "airspeed at which any further increase in angle of attack, or increase in load factor, or reduction in power, would result in an immediate stall" language. It implies that one must fly infinitesimally close to stall without actually stalling, which in my opinion is not humanly or practically possible. It's stupid.

Now, as far as the new slow flight standard in the ACS, the FAA is really contradicting itself here. Most stall warnings are activated 5-10 knots above stall. How does one fly 5-10 knots above stall without activating the stall warning? It is also stupid.

Thank you for bringing the Rod Machado letter to our attention. I note his criticism of that thunderstorm scenario-based knowledge test question, the same one that I referred to that as "a turd of a question" here a couple days ago. I am glad to read that it has been deleted from the question bank.

The impression I get from the ACS is that it seems to demand an encyclopedic-level of knowledge from private pilot applicants. This seems to be consistent with Machado's view that "the ACS will not have any positive influence on the aviation accident rate...instead, it will merely increase the educational burden on anyone who desires to obtain a private pilot certificate."

The overall theme though, I think, is that there is absolutely no accountability from the FAA in regards to the ACS. The knowledge test questions, which according to Machado are authored by panel consisting of a whopping seven FAA employees, are now strictly top-secret (to the point where the FAA has accused people participating in "exit interviews" to be be cheating) and the ACS has implemented with no attempt to gather feedback from the industry. And it's all because of a tiny handful of overzealous government employees going on a power trip.
 
mscard88 said:
Slow flight can be any speed down to MCA actually. There is a difference. I haven't look at the new ACS as I may give up flight instruction. Is MCA in there at all? If not I agree with you and Machado's concerns.
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MCA hasn't appeared in there in decades.
 
Without teaching a bit about the area of reverse command, how do you effectively teach soft field landings?

I recently flew with a student who requested a status check on her progress with another instructor. When it came to soft field landings she'd just been taught to touch down as softly as possible, but with no use of power. Huh?!

So, I guess we'll teach how to fly, then teach how to take the check ride.
 
1/3 of ACS is (B)S . . .forgive me Ben Rich, wherever you are. . .As so is, IMHO, most implementations of ORM. Guys crash (mostly) based on skills insufficiency; risk management/judgement is the smaller piece of the pie.

Someone(s) at FAA needed a big win to move further up the SES scale. "A tale told by an idiot, full of sound and fury, signifying nothing".

Wish I could think of another quote to mangle. . .
 
LDJones said:
I recently flew with a student who requested a status check on her progress with another instructor. When it came to soft field landings she'd just been taught to touch down as softly as possible, but with no use of power. Huh?!

So, I guess we'll teach how to fly, then teach how to take the check ride.
Click to expand...

That reminds me of another thing I never liked in the PTS was how short-field landings were to be performed. The common procedure of selecting the 1,000' marker to touch down on has no resemblance to a real-world short-field landing. Interestingly, the ACS makes no mention of requiring the applicant to touch down "at or within 200 feet beyond" a selected point. I guess this is one place where I like the ACS better.

And more to your point, I encounter lots of pilots who apparently were never taught about the region of reverse command. I think it is one of the main purposes of practicing slow flight but like you said instructors have been teaching to the test--they teach the how but not the why.
 
dmspilot said:
And more to your point, I encounter lots of pilots who apparently were never taught about the region of reverse command. I think it is one of the main purposes of practicing slow flight but like you said instructors have been teaching to the test--they teach the how but not the why.
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This makes me sad. Or mad. I'm not sure which.

People die or get hurt because of not knowing this stuff.

The recent Hobby crash, for example?? Teds feel for his 414 getting slow with a stuck ASI?? My own experience with a CFI on board with a microburst?? Mountain downdrafts?? A touch and go where the flaps didn't retract and I didn't catch it until it mushed into the air on its own without any pull of the yoke??

Man. I think you have to know how that feels in your butt, and sounds, and looks...
 
denverpilot said:
This makes me sad. Or mad. I'm not sure which.

People die or get hurt because of not knowing this stuff.

The recent Hobby crash, for example?? Teds feel for his 414 getting slow with a stuck ASI?? My own experience with a CFI on board with a microburst?? Mountain downdrafts?? A touch and go where the flaps didn't retract and I didn't catch it until it mushed into the air on its own without any pull of the yoke??

Man. I think you have to know how that feels in your butt, and sounds, and looks...
Click to expand...
^^YEP!
That's what saved my ass 18 years ago, during a solo T&G as a student, when I forgot to raise the flaps!!! Knowing what that feels like and taking corrective action without panicking or raising them all at once, that close to the ground. So glad my instructor gave me a lot of slow flight maneuvers (with the stall horn blaring) prior to that day:D.

I'm with Rod on this one.
 
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I don't especially care for Machado's sense of humor, and often disagree with some of his technical points, but when it comes to the ACS and its application to the PPL level I couldn't agree more with his "walk before run" premise. It is yet another example of government run amok. The sad thing is that PTS was an exception. It was logical, cogent, succinct and to the point. I guess all those attributes were so atypical for government that they became a thorn in some bureaucrat's back side, so they created ACS to snuff it out.
 
LDJones said:
MCA hasn't appeared in there in decades.
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Really. Hard to keep up when one isn't active I guess. I haven't instructed since 89 but I think it was in there back then maybe. I know I taught MCA and slow flight and the difference to students. Thanks.
 
bobmrg said:
Only way to get experience is to fly, but we all know that. The goal of the ACS as far as I can tell is to force applicants to read the risk management handbook and related pubs and get a knowledge base. Under the PTS, risk management was an afterthought.

Bob
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It should be taught under ADM though. I have no problem with risk management being taught in a practical matter and in ground instruction.

Risk management, like CRM, is something that's learned over time. They way the FAA teaches it, is to fill out some risk assessment worksheet that gives an arbitrary number or color that has nothing to do with reducing risk. I fill out an RA everyday. It's only telling me the risks that I'm already aware of. It's the unexpected event that's not on an RA that will kill you.
 
dmspilot said:
And more to your point, I encounter lots of pilots who apparently were never taught about the region of reverse command. I think it is one of the main purposes of practicing slow flight but like you said instructors have been teaching to the test--they teach the how but not the why.
Click to expand...

Personally, I think the problem is a bit larger than just not understanding the area of reversed command. I've seen a lot of advanced students come my way who do not understand the pitch/power relationship, period. The common thread with all these students is that they're in a rush to get all their ratings and have done about zero real world flying. They were also probably taught by instructors that were on the same track and did about zero real world flying prior to becoming an instructor. The most recent guy I worked with is already an instructor and he has a whole 18 hours of solo time. He was another one I had to really work with to figure out the pitch and power relationship.
 
Velocity173 said:
It should be taught under ADM though. I have no problem with risk management being taught in a practical matter and in ground instruction.

Risk management, like CRM, is something that's learned over time. They way the FAA teaches it, is to fill out some risk assessment worksheet that gives an arbitrary number or color that has nothing to do with reducing risk. I fill out an RA everyday. It's only telling me the risks that I'm already aware of. It's the unexpected event that's not on an RA that will kill you.
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Sounds like the risk assessment forms I've seen in CAP. It appears to be an attempt to reduce risk assessment to what amounts to a mathematical formula. My guess is that it's a formula that has never been validated by testing.
 
mondtster said:
I've seen a lot of advanced students come my way who do not understand the pitch/power relationship, period.
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I think you're right, I've seen that as well.
 
Palmpilot said:
Sounds like the risk assessment forms I've seen in CAP. It appears to be an attempt to reduce risk assessment to what amounts to a mathematical formula. My guess is that it's a formula that has never been validated by testing.
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Yep, I've been filling out RA forms for 17 yrs military & civilian flying. Nothing but a check the box item that the FAA & military came up with to make the appearance of safety.

We used to joke about being "low risk" in Afghanistan or Iraq. Yeah right. Or, if we happened to be "moderate" risk we knew we were still going so what's the point? No way you can mitigate the risks with a mission in combat. It became a pencil whipped, red tape task, that did nothing for preventing accidents. Similar to what we have in civilian flying.

The proponents of RAs will have you believe that it makes the pilot aware of risk factors that they otherwise wouldn't be aware of. BS, I'm aware of the risks because of my preflight planning and previous experience. I do my own mental IMSAFE or DEATH IP on top of that. I don't need a form to tell me I'm "low / green" risk or a "5" value when I already know that. I also know that what's going to try and kill me is my own ignorance, or something that I couldn't adjust for that wasn't on some RA form. That's all about proper ADM and you really don't get to that level as a student.
 
Having flown airline, medivac, LEO, charter, corporate and Ag I have found only one situation where the RA actually helped. During a really busy Ag run i have flown lots of hours in a very short period of time. It becomes routine and you settle into a working pace that's sort of like a long distance runner. After a days long stretch of sunup to sunset operations it helps to jump out of the seat and run a quick RA on the rest of the day. Flying that tired and doing something as repetitive as spraying allows stuff to sneak up on you a little. In general I agree they are a waste of time.
 
One of my concerns about them is that the time it takes to fill out the form means less time is available to actually discover and deal with safety issues.
 
mscard88 said:
Really. Hard to keep up when one isn't active I guess. I haven't instructed since 89 but I think it was in there back then maybe. I know I taught MCA and slow flight and the difference to students. Thanks.
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The task has been there. It's the nomenclature that has changed....for reasons still unclear to me.
 
LDJones said:
The task has been there. It's the nomenclature that has changed....for reasons still unclear to me.
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They changed it from "any increase in angle of attack...will result in an immediate stall" to "1.2 x Vso" in 1998 I think, at which time they went from calling it MCA to calling it Slow Flight. A couple years later they went back to the "immediate stall" definition but continued to call it Slow Flight instead of calling it MCA again.
 
The comments on Rod's posts on FB dug up one of the ACS committee members, (relatively well known pilot/author actually, but about two decades less time doing it than Rod), who's basically unable to give much in the way of concrete objective reasons for any of the committee's actions. It's entertaining anyway. Rod is replying to her posts very professionally and rationally, and making excellent points. Go figure. He's been a student of how to teach pilots for most of his life...
 
Palmpilot said:
One of my concerns about them is that the time it takes to fill out the form means less time is available to actually discover and deal with safety issues.
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Gad, yes! Before I finally left CAP, they were stacking that crap deeper and deeper. . .ORM forms of near-zero value, scads of phone calls, and near the end, the flight release guy had one. more. critical. question. he. had. to. ask: has the tow bar been removed? True story. . .
 
Been some further interesting discussion on Rod's FB page.

I attended an FAA online seminar about the ACS on Saturday. Some points they were pushing :

- ACS was not intended to lengthen Private or Instrument checkrides. (See commentary below...)
- DPEs who decided the ACS meant that they were supposed to test all 300+ coded items, were wrong.
- DPEs who thought that because Knowledge, Risk, and Skill items were categorized together on a single page that they had to be done at the same time in the checkride... (As in, while flying...)... Were wrong.

How it really works...

There are 51 major tasks in the ACS for the Private certificate. Under those tasks are close to 400 sub-tasks that are coded. They're broken up into Knowledge, Risk, and Skills tasks.

Knowledge tasks are literally the things being tested in the written test.

Risk tasks are risk analysis/awareness questions and tasks.

Skills are flying skills, very detailed versions of basically what the PTS used to be.

On a checkride...

DPE is required to create scenarios and questions that will assess...

One Knowledge task from all 51 main tasks.
One Risk task from all 51 main tasks.
All Skills tasks from all 51 main tasks.

Additionally any missed questions in the written will be given a code similar to the old "PLT" codes but these directly correlate to items in the ACS (much easier to look up and know what specifically was missed).

DPE is required to cover all codes missed on the written.

DPE at their discretion may add any additional coded items to the checkride that they wish.

Thoughts and commentary...

(A mash-up of my writing here and some of the other online commentary about it all...)

DPE has a lot on their plate to assess 102 Knowledge and risk analysis items in every oral. Plus all the flying skills.

Some of the flying skills are perhaps botched and FAA is reviewing them. Example: Slow flight is now defined as 10 knots above stall WARNING. Folks definitely don't seem to like that one.

FAAs assertion that tests should not be longer may be an indication of something wrong in their measurement of PTS tests. Or not. Various commentary on that. But most folks think figuring out scenarios to cover 102 items is going to be pretty entertaining for them and could really up the time required and/or as some in the instructing biz are concerned about, jump the price of Private and Instrument rides.

(I haven't counted the number of major tasks or sub-tasks for the Instrument. Nor seen anyone else do it yet. Feel free.)

There's a general feel amongst the commentators of two things:

The risk analysis stuff is overdone. Some are even concerned about the physical placement of these tasks in the document. (Stuff is always ordered Knowledge, Risk, and then Skill, but the Skill items are the required items. Seems to give a hint that the risk items are being pushed hard.)

Long time instructors are a bit concerned about having to sign that they've taught over 300 items adequately to folks. (A lot of this stuff was self-study in the past and instructor evaluated whether you knew it or not. Now it's detailed to the Nth degree. And still supposed to be "scenario" based by the time you get to the DPE, not "list" based. But DPE has to cover 51 of them, and instructor must sign off on over 300 total, close to 400.)

Anyway, the other larger concern is nobody knows other than FAA feeling more organized about it all, what the goal really is. Folks are imagining an intense number of items in higher ratings and CFI ratings later on.

FAA feels they were just "writing a standard that didn't exist and needed to".

FAA also pushed pretty hard in the seminar that "industry" was consulted for all of this. List of places was notably major training sellers and major schools who some say may benefit from a much more complex system. (Wear tin foil hat on that one or not, your choice. I'm just typing up what I'm reading for discussion here.)

Rod Machado and others are involved in some very public but civil debates about the purpose of the changes and trying to relate them back to safety changes needed or training faults found that needed correction. Really from my reading, none of the ACS advocates talking to them are saying that it was intended to do that. It seems more like they were very concerned that the PTS would say three lines after "Pre-flight" and it wasn't detailed enough.

Which is kinda odd in my opinion. DPEs usually don't get to be DPEs without knowing all the steps of a proper pre-flight. Doesn't seem like it was necessary to replace those three sub-items with a huge list for them. Just my thoughts.

Anyway, the seminar was interesting. Rotorcraft and Powered Lift versions of the ACS at Private and Instrument levels have not been completed nor implemented. In fact, rotorcraft will be a mix of ACS and PTS for the time being. (Ick. Messy.)

One question was during the transition year where students took the old written and got "PLT" codes for failed test questions, would there be a chart mapping those to ACS codes. Answer: No. (Again messy/disorganized IMHO...)

Also noted heavily was that higher ratings will take YEARS to implement into ACS. Two minimum, probably more.

So Private and Instrument applicants will be using one system, and everyone else, another. Also extremely messy organizationally to me, but maybe it works.

FAA said all questions asked during the seminar would be answered live or via email within "a few weeks". My question was the only unanswered one live, and I suspect I know why...

I asked...

Are the FIA and FII written tests already changing because their test pools are linked to the Private and Instrument test pools?

No answer. And the reason probably is that they can't admit the test pools are inextricably linked in a database, and test questions are the big "super secret" for the last 12 years or so, so the question causes problems to answer it. But I suspect that ACS is creeping into the other writtens via the question pool being linked from my recent mass taking of multiple writtens.

Of course FAA can update the non-ACS tests anytime they feel like it, so it's not really a big deal, but expect more scenario type questions to creep over from Private and Instrument into the other tests is all I'm saying. Hard not to have that happen even though officially no ACS changes have been done outside of Private and Instrument.

Anyway there's some brain dump stuff.

And of course there's also just general confusion going on. Some poor Private applicant posted happily that he passed his "8 hour oral" on Facebook and both sides lost their minds on the whole time aspect, until someone dragged the guy back to a keyboard to explain that it was a 3 hour oral with a bunch of aircraft and weather problems.

Slap forehead...

At least FAA is doing seminars and doing them via GoToSeminar direct out of OKC. Sign up for one if the ACS is going to affect you. It's an easy hour of info and "polls" (quizzes) and gives the basics of how the monster document works.

I figured I'd better take one, being that when I finally get this CFI rating stuff done, I had better know what I need to teach... I'll never have a Private PTS-style applicant ever...

So ACS it is...
 
By the way, medical people will like this one.

I described the new Private and Instrrument ACS to my wife, the nurse, and she said, "So FAA is trying to catch up to the ICD-10..."
 
Sundancer said:
Gad, yes! Before I finally left CAP, they were stacking that crap deeper and deeper. . .ORM forms of near-zero value, scads of phone calls, and near the end, the flight release guy had one. more. critical. question. he. had. to. ask: has the tow bar been removed? True story. . .
Click to expand...
Our glider club works with the CAP. It's absolutely ridiculous the wickets that have to be gone through to "release" a flight. I served 24 years in the Air Force and don't remember half the BS the CAP does in the name of safety. I thought about volunteering in the CAP but after watching how they operate, I decided not to.
 
Yep - it isn't any one particular hoop, and stand-alone, they don't appear that bad. But stacked up, the preponderance just got to be too much.
 
Letter from the seminar with links to more information:

....

Hi,


I’m really glad you had a chance to attend our ACS Webinar. As promised, we have attached the presentation file and answered questions to this email.


Here are some additional resources where you can learn more about the ACS:


AFS-630 Web Site: https://www.faa.gov/training_testing/testing/

ACS Frequently Asked Questions (FAQs): https://www.faa.gov/training_testing/testing/acs/media/acs_faq.pdf

Recorded Webinar:

Training Course at FAASafety.gov: https://www.faasafety.gov/gslac/ALC/course_content.aspx?cID=449&sID=717&preview=true

If you still have questions after reviewing the FAQs, you can email additional questions to the ACS Focus Team: 9-AVS-ACS-Focus-Team@faa.gov


We hope this helps and wish you clear skies!



Christopher Morris

Aviation Safety Inspector (OPS)

Airman Testing Standards Branch AFS-630

Oklahoma City, Oklahoma
 
Velocity173 said:
Risk management, like CRM, is something that's learned over time. They way the FAA teaches it, is to fill out some risk assessment worksheet that gives an arbitrary number or color that has nothing to do with reducing risk. I fill out an RA everyday...
Click to expand...

The only way to gain real aeronautical wisdom is to survive your own occasional stupidity. All those risk assessment, ADM, CRM, PDQ BS mnemonics immediately become obsolete the moment that you walk across the ramp to your aircraft. Expect the FAA to change their safety alphabet soup 6 or 7 times in the next 50 years. In the end, we all know that once a pilot solos, Darwin takes over.
 
denverpilot said:
On a checkride...

DPE is required to create scenarios and questions that will assess...

One Knowledge task from all 51 main tasks.
One Risk task from all 51 main tasks.
All Skills tasks from all 51 main tasks.
Click to expand...

Citation?
 
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