In September 2013, the industry-led Airman Testing Standards and Training Working Group submitted its report and recommendations for improving the FAA’s airman certification system to the FAA through the Aviation Rulemaking Advisory Committee (also industry-led). FAQs:
What is the Airman Certification Standards (ACS) project all about?
The goal of this project is to improve airman training and testing by implementing an integrated, holistic system that clearly aligns testing with certification standards and guidance.
Who are these people? What expertise do they have?
The Airman Testing Standards and Training Working Group (ATST WG) includes aviation professionals who collectively represent all major sectors of the industry. These include flight instructors, designated pilot examiners, the aviation academic community, industry advocacy associations, and training and test preparation providers involved with aviation training and testing in 14 CFR part 61, 141, 147, and 121 environments. To help ensure that the FAA has a full understanding of the ATST WG’s work and the rationale for its recommendations, the FAA also assigned subject matter experts from a number of its policy divisions to attend meetings.
What is the problem you’re trying to solve? What’s wrong with the tests we have now?
FAA knowledge testing matters because it is intended to measure an applicant’s understanding of the rules, regulations, and knowledge areas required to receive an FAA airman certificate. For the flight proficiency (skills) part of the airman certification process, the FAA developed the Practical Test Standards (PTS) to define acceptable performance of the required skills. There is currently no such guidance for the knowledge test, which creates problems familiar to anyone who has ever taken an FAA knowledge test. These include questions that are overly broad, trivial, outdated, and sometimes irrelevant. Test questions that require multiple interpolations to calculate takeoff, landing, and density altitude to the foot imply a level of precision that, ironically, is grossly inaccurate in terms of safety and reality. Moreover, the knowledge exam is not a reflection of a typical ground training program. Consequently, applicants who have demonstrated knowledge and mastery in an approved flight and ground school curriculum must still conduct a comprehensive “test prep” to pass the knowledge test. As a result, the knowledge exam is disconnected from both training and the practical test. For these reasons, many regard the knowledge test as a rote memorization exercise that has no real value for aviation safety education and training.
If there are problems with the knowledge test, why can’t you just fix those and leave the rest alone?
In September 2011, the FAA convened a group of industry experts to recommend ways to “fix testing.” This group – the Airman Testing Standards and Training Aviation Rulemaking Committee (ARC) – quickly determined that there is no way to fix the knowledge test in a meaningful and sustainable way without having a knowledge test standard akin to the PTS. The ARC 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 ACS would thus define not only the performance metrics for knowledge and skill, but also the required content for guidance materials such as the FAA-H-series handbooks and for relevant knowledge test questions.
How does the ACS approach improve the PTS?
The ACS approach does not increase or expand any of the skill evaluation requirements in the existing PTS, but it significantly improves the PTS in several ways. The ACS:
- Provides integrated guidance that defines performance metrics for aeronautical knowledge as well as flight proficiency (skill).
- Strengthens the PTS by explicitly defining the aeronautical knowledge needed to support each Area of Operation/task. This linkage enhances the relevance of the testing/training process for adult learners by clearly answering the “why do I need to know that?!” question.
- Enhances safety by using the risk management section in each ACS Area of Operation to translate abstract terms like “aeronautical decision-making” into specific safety behaviors relevant to each task.
- Eliminates “bloat” by consolidating duplicative or overlapping tasks in the existing PTS.
Why does the ACS have a separate section for risk management? Isn’t that just the latest buzz word?
The PTS already requires evaluation of the applicant’s risk management abilities, but the existing document doesn’t offer the kind of concrete “what do I have to do?” guidance that users need and deserve. The rationale for including a risk management section in the ACS is to enhance safety by translating abstract terms into specific safety behaviors relevant to each task. The ACS is also intended to communicate and demonstrate that risk management is a continuous process that includes identification, assessment, and mitigation of task-specific hazards that create risk. The risk management element identifies the circumstantial issues that aviators must consider in association with a particular task.
How do you propose to provide the “clear link” connecting knowledge/skill performance standards, guidance, and test materials?
One of the overarching goals of this project is to create an integrated, coherent airman certification system in which standards, guidance, and testing can be aligned and maintained in alignment. The proposed private pilot, authorized instructor, and instrument rating ACS documents include a series of letters and numbers after each task. These codes provide the means to correlate the tasks in the ACS with guidance and testing, and to keep them aligned going forward. The proposed coding system has five elements that are anchored in the ACS (not in reference documents, like the current LSCs). The proposed ACS codes would supersede the current system of “Learning Statement Codes” (LSC), which is too limited to serve as the mechanism for alignment and too complex to effectively serve the needs of the FAA and the stakeholder community.
Isn’t the real problem related to deficient skills? If so, what is the point of this change?
According to the AOPA Air Safety Institute, the three leading general aviation (GA) fatal accident factors are maneuvering flight, continued VFR into instrument meteorological conditions (IMC), and loss of control on takeoff. These factors all imply some degree of deficiency in the pilot’s knowledge, skill, and risk management abilities. Even the world’s best stick-and-rudder pilot is at risk for loss of control if he or she has an inadvertent flight into IMC because of deficiencies in weather knowledge or risk management ability. Safety is not served by emphasizing just one of these three abilities. On the contrary, each supports the others. The ACS is therefore an improvement over the current system, because it offers a holistic approach to aviation training and testing – it integrates knowledge, skills, and risk management, and it provides a way to ensure that the elements of the certification process – standards, guidance, and testing – are correlated to these abilities and aligned with each other.
Doesn’t this kind of change require a formal rulemaking process?
No. Like the PTS, the ACS simply defines the metrics – the standards – for meeting the regulatory requirements that 14 CFR part 61 enumerates for aeronautical knowledge and flight proficiency. The ACS does not change any of the requirements in 14 CFR.
Doesn’t this approach increase the standards?
No. The ACS approach does not increase the standards. Except for those areas where the ACS consolidates overlapping or duplicative Areas of Operation/ tasks in the existing PTS, none of the PTS material has changed. The knowledge and risk management sections simply define the standards for meeting the requirements in 14 CFR part 61.
Won’t the ACS approach dramatically increase the length (and expense) of the practical test?
No. In fact, a more integrated and efficient presentation of the material to be tested could even shorten the test, especially if the evaluator has more confidence in the quality and meaning of the applicant’s knowledge test score. Evaluators will be able to effectively and efficiently re-test any deficient knowledge identified on the airman knowledge test report to ensure the applicant has been trained to proficiency in all areas.
How will use of the ACS approach change airman training?
With clearly defined standards for knowledge, skill, and risk management, airman training can be conducted more effectively to ensure applicants who complete flight and ground training are safe, competent aviators as well as successful in passing the FAA knowledge test. Training and testing will be aligned, which means that “test prep” will be a review of the ground school curriculum rather than a separate, unrelated step to learn questions for the sole purpose of passing a test. (FAA Safety Briefing – NovDec 2013)