Monday, June 27, 2022
Home Flight Safety What The FAA Commercial Test Needs.

What The FAA Commercial Test Needs.


The current commercial pilot test standard, as administered, is often a joke. Jumping into a C-152 or DA-20 and doing the same private pilot maneuvers to the same PPL tolerances does not really “test” anything. There is no added challenge or demonstration of superior skill required at the “commercial pilot level” unless CFIs and DPEs step up and apply the ACS standard more rigorously. Remember, the next step for most of these pilots is as a flight instructor (to your children?) or flying in the right seat of a transport plane (with your loved ones in the back?). Maybe *real* skills are acquired during “on-the-job training” – or not?! Look at the flight track above to see how well this is working; that Airbus was nearly a CFIT.

In many cases, the FAA commercial flight test is the aviation industry’s version of a “participation trophy.” It only assures that a pilot showed up and flew 250.1 hours – usually with only 5 hours total actual solo – and is rebranded as “commercial” under diminishing test standards. First, commercial lost the +/-50 ft tolerances, then the requirement for retractable gear (complex) airplanes, then minimum controllable airspeed (SAFO 16010), then “supervised PIC” under 61.129(a)4 became the norm for all “solo.” Now, most new CFIs have only been alone in a plane for 5 total hours (private pilot solo) and they are the primary purveyors of all future aviation wisdom.

a pilot must choose to log all ten hours as solo flight time in a single engine airplane or, in the alternative, log all ten hours performing the duties of a pilot in command in a single engine airplane with an authorized instructor on board. A combination of hours is not permissible under the rule.

Pilot examiners can only test what the FAA standard provides and there are pretty limited tools for the DPE in the current ACS to assess a higher level of proficiency. It is incumbent upon every CFI to teach beyond the FAA minimums and for every DPEs to dig deep and test comprehensively; our lives depend on this.

The rudder challenge of the chandelle or lazy eight is appreciated, but 200 feet of altitude gain with the limited power of trainers does not require huge skill. The 180-degree power off landing certainly does sort out a few pilots but luck and rote recitation often prevails here (and its pass/fail)/. AThis pathetic process demonstrates how badly flawed our flight training system has become. For the initial CFI, the passing rate is now the same as the private pilot test. We need teeth in these evaluations (teaching and testing) to provide challenge and inspire a higher standards of performance.

AIrbus 321 leaving Bozeman, MT last week; LUCK avoided CFIT?

I would encourage every CFI teaching at the commercial level and every DPE testing potential commercial pilots to spend a moment here and examine the FAA Commercial ACS in more depth. Some areas to focus on are the take-off briefing (II, F) to assure safety during this most dangerous phase of flight. “No comprehensive take-off briefing, no approval” has to be a red line. Rejected take-off and engine failure during take-off are in the ACS, but unfortunately, not explicit and seldom tested except perhaps orally. The cross country *could* be flown entirely with pilotage if an early failure takes out the “GPS magic” (ACS VI, A). Do any DPEs adequately test VI. D (lost procedures)? Headed back to home base, have the applicant find the airport without any “geo-location.” Situational awareness (SA) is a complex skill and hard to calibrate or “prove” on an unsatisfactory evaluation. But SA is mentioned 45 times in the commercial ACS. This can be a headache for DPEs because some aggressive flight academies protest every unsat.  requiring unpaid time for DPEs who have to support their judgment calls.

Here are some basic knowledge questions every pilot at the commercial level should be able to answer at the correlation level. This is essential knowledge but not often tested – because it’s not specifically stated in the ACS. These questions also provide good knowledge for all pilots who want to be better and safer in aviation.

1) What is the most efficient altitude to fly this flight at? Few commercial applicants are aware of the bigger picture outside of the performance tables (which are usually perfunctory in small trainers). Dig into ACS section I, F or VI, d. PIlots at the commercial level should know that IAS remains essentially the same as we climb at a fixed percentage of power but TAS increases at approximately 2% per thousand. (Fewer molecules of air=less friction and drag).  This provides the performance benefit of flying higher than the usual student cross country. Available power decreases with altitude at a rate of approximately 3% per thousand in a normally aspirated piston plane. Consequently, the optimal altitude will be where the desired percentage of power is full throttle (and best volumetric efficiency). Headwinds will obviously have to be considered (but let’s not get involved with “weather ignorance here). Graphing the 3% power loss against the 2% TAS gain usually provides ~ 8K density altitude cruise in calm winds at ~65% power.

2) Extrapolating from the above understanding, what are the effects of this disparity in TAS and IAS (and loss of performance) for high density altitude (DA) pattern operations? Approaching to land at Centennial Airport in Denver on a hot summer day (10K DA) might show an indicated 65K on final when actual TAS is 75K. Most pilots are going to drop their plane onto the runway due to their unfamiliarity with this high-speed visual illusion. (CFIs can easily simulate this in training with a tailwind landing on a long runway). High DA take-offs are even more dangerous when a plane can get airborne in ground effect below (IAS) stall speed. Rotating when it “looks about right,” puts the plane airborne in ground effect – still not able to fly. A pilot must be able to lower the nose to climb in this situation, just like a soft field take-off (and most don’t). High DA accidents often sail off the end of the runway in ground effect. And your C-172 is a C-152 in Denver on a hot day (💡).

3) What is “stall speed” if we can stall at *any* speed? Why does Va change with weight? “Stall speed” is a 1G determination at max gross weight. “Stall speed” changes with a/c weight (and G force) and CG location. And if we multiply 1G Vs times the square root of the load factor, we can derive that variable Va. Unfortunately, most commercial applicants don’t even know normal/utility G limits. Another way of saying this is a plane will stall before it breaks at speeds below Va (a safety valve? – above Va we are test pilots). What is the effect of weight on Vx and Vy (hint – they meet at the service ceiling of the airplane). Most commercial applicants have never seen a Vg diagram.

4) Expanding on this discussion, how does a pilot experience/induce G force in normal flight? Most commercial applicants never thought of G force as just another form of weight. When this light bulb goes on (💡) it all starts to make sense – why don’t most CFIs teach this stuff? The increase in stall speed from G force (bank) is non-linear (square root function) and this can surprise pilots. In repeated surveys, the majority of pilots overestimate the G force and stall increase at 45 degrees of bank (only 19%) and fail to appreciate how quickly this exponential force increases past that angle. The recent jet accidents while circling to land clearly illustrate this ignorance. We do accelerated stalls at the commercial level, but few applicants can calculate the effect of bank angle on stall speed. Slip/skid/spin is an under-appreciated knowledge area (but required: VII, E “spin awareness). This will be a future blog…

5) Most commercial applicants do not understand the effect of forward and aft CG on stall speed, stability and controllability (I, F). The CG is forward of the center of lift and provides a variable lever-arm of controllability. The tail providing the downward balancing force surprises most pilots. Controllability and stall speed becomes easier to understand once this force is understood(💡).

6) There is no mention of type certificates, supplemental type certificates or 337 forms in the current commercial ACS. Most new commercial pilots will be flying old beasts with 15 STCs modifying the original type certificate. This has an obvious effect on the airworthiness of the airplane (see FrankenPlane).

These are just a few basic items that come to mind that are seldom tested at the commercial level. This knowledge is critical for every pilot’s survival as they fly more unforgiving airframes (those Lear 35 examples). Let’s prepare our pilots better and we will have fewer unnecessary deaths as a result of ignorance. Fly safely out there (and often)!


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