Saturday, July 21, 2018

Standards and Discretion

The FAA provides a publication titled "Private Pilot-Airplane Airman Certification Standards FAA-S-ACS-6B." (aka PTS)  It is a 61 page document that clearly documents the term "proficiency" according to the FAA.  The regulations regarding Tail Wheel Endorsement and the WINGS Flight Review refer to these standards.

CFR 61.31(i) is the regulation about Tail Wheel Endorsement:  "endorsement in the person's logbook from an authorized instructor who found the person proficient in the operation of a tailwheel airplane."  

The flight training must include at least the following maneuvers and procedures:
(i) Normal and crosswind takeoffs and landings;
(ii) Wheel landings (unless the manufacturer has recommended against such landings); and
(iii) Go-around procedures.

The CFI has "discretion" to use his personal judgment regarding additional manuevers to be covered, but the "standards" for each of these is pretty clear and well covered in the PTS.  

The FAA requires a Flight Review (CFR 61.56) every two years. The FAA WINGS Program is a well organized one that provides a clear set of activities to be completed. A070405-7, A070405-08 and A100125-08.

A flight review "consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include:
(1) A review of the current general operating and flight rules of part 91 of this chapter; and
(2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.

The FAA WINGS Program is a well organized one. It provides on line resources for the "knowledge" and provides a clear set of activities to be completed. A070405-7, A070405-08 and A100125-08. A different CFI can validate each Flight Activity separately.  One all three are validated, your flight review is complete. 

  • Flight – perform the following:
  • Normal Takeoff and Climb
  • Normal Approach and Landing
  • Soft-Field Takeoff and Climb 
  • Soft-Field Approach and Landing 
  • Short-Field Takeoff and Maximum Performance Climb 
  • Short-field Approach and Landing
  • Forward Slip to a Landing 
  • Go-Around/Rejected Landing
  1. Area of Operation VIII, Task A: Maneuvering During Slow Flight
  2.  Area of Operation VIII, Task B: Power-Off Stalls
  3. Area of Operation VIII, Task C: Power-On Stalls
  4. Area of Operation IX, Task A: Basic Instrument Maneuvers, Straight-and-Level Flight
  5. Area of Operation IX, Task D: Basic Instrument Maneuvers, Turns to Headings
  6. Area of Operation IX, Task E: Recovery from Unusual Flight Attitudes
  1. Area of Operation IV, Task K: Forward Slip to a Landing
  2. Area of Operation V: Steep Turns
  3. Area of Operation VI, Task A: Rectangular Course
  4. Area of Operation VI, Task B: S-Turns
  5. Area of Operation VI, Task C: Turns Around a Point

Each one of these "Flight Activities" are clearly outlined in the PTS, with clear descriptions of the minimum definition of proficiency.  And, for many aspects there are "tolerances" such as "maintain altitude +/- 100 feet and speed +/- 10 knots", "maintain altitude +/- 200 feet and heading +/- 15 degrees", or "touch down within 400 foot beyond specified point" when landing.  Many CFI's will expect a higher precision than these standards--be prepared. 


What is Proficiency?

According to the FAA, proficiency, by definition, "is the state of performing a given skill with expert correctness. Pilot proficiency, therefore, relates to the pilot's ability to perform all tasks associated with the safe conduct of a flight with expert correctness."

The next question is, How is expert correctness defined?

Since the interpretation of regulations ultimately falls to the legal profession, some insight can be gained by examining the way the legal profession defines proficiency and being an "expert".

Each state has a Bar Exam that lawyers must pass with a minimum score in order to "practice" the law.  Minimum required scores are in the range of 130-145 of 200. or about 70%. Lawyers are not expected to score 90% + on their exams in order to practice law. So, I would expect that lawyers would also define pilot proficiency as sufficient for "safe conduct of flight". 

So Pilot Proficiency cannot and does not mean perfection at all times and in all things. I would submit that there is a minimum standard for "safe conduct of flight".  (Sort of like the 70% Bar Exam score.)  Which to me means: good judgment and knowledge; flying within/below your personal minimums; always choosing to fly with a "margin of safety" rather than trying to "show off" how proficient they are by operating near the limits; maintaining directional control---staying on the runway (not necessarily staying perfectly on the centerline); being able to recognize a mistake quickly and to remedy it in a safe manner.   But, of course, even these general descriptions are subject to the arbitrary discretion of the CFI.

So, is it necessary for a pilot to make a perfect landing on every attempt?   Should a CFI withhold an endorsement because the pilot decided to perform a go around because he was not satisfied with his approach or he made a mistake on the round out or flare?  Should a CFI withhold an endorsement because the pilot touched down and rolled out to the left or right of runway centerline, but still remained on the runway?  Should a CFI withhold endorsement because the pilot landed with a "hop" or small bounce on landing from which he recovered safely? Should every landing be performed as if it was a short field landing so the plane can exit the runway at the first turnoff?  Must the pilot demonstrate proficiency landing in crosswinds at the maximum demonstrated limit for the aircraft?


Under the present regulations, the definition of proficiency is clearly in the eye of the beholder--the CFI.  Fair enough, except----my suggestion would be that statistics be maintained as to the actual number of hours required for the CFI to teach and the student to learn and complete the "endorsement" be it the Tail Wheel Endorsement, Flight Review Activities, or any other CFI endorsement.  The distribution for these statistics would certainly be similar to the classic "bell curve" as student's abilities vary. But the "mean" would clearly show the difference between the expectations and/or abilities of the CFI.  The CFI with requiring near perfection in pilot performance would clearly show a much higher "mean" or average time for the endorsement. 














The current system tends to create an environment where there is a huge variance in expectations.  There are advertisements suggesting Tail Wheel Endorsement in 5 hours. There are anecdotal stories of "rusty" pilots requiring 30 hours!  Often, CFI's will claim the "average" is 10-12 hours and then "hedge" by stating that "of course for some, it takes longer"---often the "average" for that CFI is much higher than 10-12 hours---but there is no way for the student to know and once he reaches the 10-12 hours with no endorsement, he becomes discouraged and frustrated. He is faced with a choice--stay with the one CFI in an open ended program with no clear end, or seek out another CFI and start over.  Or, he simply concludes that he "is not good enough" and gives up. (Or in the case of many of the 500,000 "rusty pilots" in the USA, may figure it is just not worth the time, humiliation, frustration and expense.)

When training takes longer than expected, one must wonder if the cause is the student's inability to learn or perform, or the CFI's inability to teach...or higher than necessary definitions of "safe conduct of a flight with expert correctness."

One should keep in mind that a Tailwheel Endorsement is NOT REQUIRED, if a pilot logged ANY pilot in command time in a tailwheel airplane before April 15, 1991. No doubt, there are many pilots that can legally fly tailwheel airplanes that many CFI's would be hesitant to endorse. 

Of course, the "elephant in the room" is that actual skill of each "endorsed" pilot can vary greatly and is difficult to measure, so a CFI that consistently endorses with very few hours of instruction might be allowing pilots with lower skill levels to fly. So again, it is important to "define" proficiency and for it to include the pilot having and using "good judgment" so as to avoid situations that he/she cannot yet safely handle. 

There is no doubt--being a "good" pilot takes lots of practice and never ending learning--not just accumulating hours. Nobody ever becomes a perfect pilot.  Continuous learning and continuous improvement with continuous practice is what ultimately makes a good pilot. 


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