For those who were not born in this country, the process of acquiring U.S. citizenship includes an English language component as well as a civics knowledge test. The naturalization interview includes up to ten questions from a bank of 100 potential questions. The point is to ensure that anyone seeking the rights and privileges of citizenship meets a baseline standard of knowledge about U.S. history, culture, geography, and values. (I wonder how many of us native-born citizens could pass? Check out the self-test at www.uscis.gov.)
Acquiring Aviation Citizenship
Since none of us are native-born to the aviation community, everyone who seeks to acquire aviation citizenship must pass a set of tests. As with the rationale for the U.S. citizenship civics test, the knowledge test component of the airman certification process is meant to ensure that all aviation citizens meet the standard of aeronautical knowledge for the level of pilot (or instructor) certificate or rating they seek to obtain.
American history and geography don’t change much, so questions for the U.S. citizenship civics test can be fairly static. In aviation, on the other hand, the only thing constant is change itself, and so the knowledge test component of the FAA’s airman certification process needs to keep pace. It’s no secret that many stakeholders – applicants, instructors, training providers, and even evaluators – do not believe the current FAA knowledge test passes muster.
Fixing the Citizenship Test
As previously reported, in late 2011 the FAA chartered an Aviation Rulemaking Committee (ARC) to seek expert stakeholder assistance to address these issues. Although the ARC’s initial focus was on the tests, this industry group quickly realized that it is not possible to fix knowledge tests in an effective and sustainable manner without first addressing several underlying systemic issues.
One such issue is the lack of a clearly defined knowledge test standard. Flight proficiency skills for each certificate and rating are enumerated in 14 CFR part 61. The FAA developed the Practical Test Standards (PTS) to define metrics for acceptable performance of these skills. While 14 CFR part 61 also lists the broad areas of knowledge an airman must master in order to earn certification, the lack of a knowledge test standard corresponding to the PTS gives rise to several problems:
- Overly broad, outdated, and sometimes irrelevant knowledge test questions;
- Inadequate calibration of knowledge test questions to the certificate or rating level;
- Lack of a framework to evaluate, incorporate, and manage changes deemed critical to safety; and
- Insufficient post-test feedback to stakeholders.
In the view of the ARC members, the lack of a knowledge test standard has reduced the potential aviation safety and training value of the FAA knowledge test. The ARC briefly considered proposing a “Knowledge Test Standards” (KTS) document that would serve as the knowledge test companion to the skill-focused PTS.
The ARC ultimately concluded that aviation safety and stakeholder needs, including the core desire for a more relevant FAA knowledge test, would be best served by integrating task-specific aeronautical knowledge into the appropriate area of operation in the existing PTS, and by adding task-appropriate risk management elements for each area of operation.
The ARC thus proposed the creation of an Airman Certification Standards (ACS) document. In August 2012, the FAA assigned this task to the Aviation Rulemaking Advisory Committee (ARAC), a formal standing committee comprised of representatives from aviation associations and industry. The ARAC in turn established an industry-led and industry-composed Airman Testing Standards and Training Working Group (ATST WG), which has spent the last year developing proposed ACS documents for the private pilot and instructor certificates and the instrument rating. During the course of its work, the ATST WG requested public comment on several draft documents, and it used those comments to refine the documents and recommendations. Much work lies ahead for both the FAA and industry, but this effort clearly lays the foundation for fixing the “aviation citizenship test.” (FAA Safety Briefing Sept/Oct 2013)