After years of living with a multitude of imperfections in the process of certifying airmen, in September 2011 the FAA decided to act. Now nearly five years later, a totally revamped system called Airman Certification Standards (ACS) is planned to take effect on June 15, 2016, starting with Private Pilot and Instrument Airplane certification.
The FAA recognized many flaws in our existing practical test standards and knowledge tests and, in particular, how those flaws evolved. One objective of the ACS is to better facilitate updates so the new system doesn’t get stale like the last. We’ll take a look at that.
The expectations in the ACS are not much different from what we do today, but the ACS spells them out explicitly so there is consistency across the board for applicants, instructors and examiners. The expected result will be better-prepared applicants who are equipped with all the skills to fly safely in our national airspace system.
Problems with the PTS
Part 61 lists the required areas of aeronautical and flight proficiency. Based on Part 61, the PTS was developed to specify practical test performance measures to assess flight proficiency. Tacked into the PTS Introduction is a long list of special emphasis areas that are largely undefined and lack any real context. This makes it difficult to evaluate an applicant’s risk management and aeronautical decision-making skills. The PTS also contains overlapping and redundant tasks, acquired as a result of multiple amendments over time.
It might help to simply think of the ACS as an enhanced version of the PTS. In fact, the PTS Operations and Tasks remain unchanged, but are now a subset of the ACS. Task-specific knowledge and risk management elements are now integrated into each Area of Operation and Task as shown.
The ACS not only defines the flight proficiency items from the PTS, it also defines measures of aeronautical knowledge by each Area of Operation. Instead of just paying lip service to risk management, it takes on real meaning when applied to a specific task as real-world aeronautical decision-making. In sum, the ACS specifies what the applicant must know, consider and do to qualify for a certificate or rating.
The ACS is much better-organized than the sometimes-difficult-to-navigate PTS. The excessively lengthy and often-overlooked PTS introduction has been relocated to specifically focused appendices, making the ACS introduction much shorter. The roles, responsibilities and expectations of both evaluator and applicant are more clearly defined. The lengthy notes in some PTS Tasks have also been moved to an appendix.
The ACS is a compact document that incorporates the appropriate PTS, the Learning Statement Reference Guide (soon to be ACS codes) and the existing Knowledge Testing Authorization Requirements Matrix, which includes details describing each current Knowledge Test.
Knowledge Test Problems
The Knowledge Test is supposed to measure an applicant’s understanding of the rules, regulations and the knowledge areas required to earn a certificate. The test is seriously flawed because many questions are too broad or complex, such as the question that requires calculating a landing distance within three feet. Some questions are trivial, outdated, or even irrelevant. Do you really need to know how to calculate the height of blowing sand?
For many, the way through the test is simple brute-force memorization. Current Knowledge Tests offer little in the way of safety education or training and frequently lack any connection to real-world operations in today’s airspace, especially with respect to GPS.
Part of the problem is that there never was a knowledge test standard against which to build the tests. Instead of building one, the FAA achieved the same thing by building aeronautical knowledge elements into the existing PTS to form the new ACS. In doing so, knowledge elements are now well-defined and closely pertinent to the tasks to be performed, which will hopefully eliminate applicants asking, “Why do I need to know this?” Now the FAA will be able to create and maintain a clear link between the regulations, knowledge and skill performance standards, guidance (as in reference handbooks) and test materials.
Maintaining that “clear link” is made possible through a new ACS coding system. As shown, each ACS item shows a series of letters and numbers after each task. The codes permit easy correlation and alignment between ACS tasks and guidance and testing. In this example from the draft ACS document for the Private Airplane certificate, you can see that the steep turns task is divided into three sections: Knowledge, Skills, and Risk Management. Put another way, the task includes what you must know, what you must do and what you must consider.
The code on the left has four elements. The first is the relevant ACS, in this case the Private or PA. The (Roman numeral) V represents the Area of Operation. The A represents the task as shown at the top, Steep Turns, and the last is the Task Element, which could be a K for Knowledge, S for Skill or R for risk management as shown. Each element contains multiple sub-elements, indicated by the following number. These codes allow the FAA to generate tests automatically, whether using existing test forms or future randomized question selections.
The learning statement codes that currently accompany knowledge test reports quote reference materials and are so broad they’re nearly useless. These codes have befuddled many an instructor and applicant trying to figure out where to concentrate further studies. ACS codes were developed in part because the previous codes were too limited to serve as an alignment tool and too complicated to be of much use to the FAA and the user community.
Since ACS codes observe a strict but intuitive format, they can really help an instructor zero in on whatever error(s) the student made. This finally makes the knowledge tests a useful part of the overall learning process. The codes also help an evaluator identify knowledge questions missed. If the instructor and student have corrected these to 100 percent as they should, the applicant will be well prepared to score extra, easy points during the oral.
Better Test Questions
One of the most important concepts is that now test questions will be directly related to the ACS. Those test questions will be clearly connected to standards, unlike the previous sometimes tenuous relationship. Risk management will be tested through the use of scenarios, common student errors, misconceptions and accident causes. Following a knowledge test, the applicant will receive a set of referable ACS codes, the same ones used on the flight test. On that test, if an applicant receives a Notice of Disapproval, the S codes for skills will be itemized to show areas of deficient skills.
An ACS Exam Review Board consists of subject matter experts from several Flight Standards policy divisions, plus one non-FAA person with extensive experience in test development. This board is already using ACS codes to review and revise knowledge test questions for the private, commercial and instrument tests. Expansion to other question banks will follow. In the end, ACS codes will guide development of new questions that are better aimed at essential knowledge, skill and risk management.
ACS Conversion Status
Drafts exist for private, commercial, instrument and ATP (airplane) ACS. The FAA has announced that it will begin using ACS format for private and instrument (airplane) on June 15, 2016.
The Authorized Instructor ACS is still in development, so the next step will be initial prototyping and publishing in the Federal Register for additional comment. The expectation is that it will substantially improve instructor testing and training. There will be an emphasis on the practical application of fundamentals of instruction, as opposed to the rote method of the past. Instructor applicants must not only understand risk management, but how to teach and practice it during their instructional activities. Applicants will be now asked only about flight maneuver tasks unique to the certificate being sought. It’s possible we might see the instructor ACS later this year.
The draft ATP ACS is still under both internal and external review, with the next step being publication in the Federal Register for comment.
In April 2016, the FAA was expected to post the final private and instrument ACS in the Federal Register. The FAA promised that these documents will be published at least 60 days before they become effective. Right now, both become effective on June 15. On initial implementation, the current learning statement codes will be used. ACS codes will be provided once the FAA’s new test management system is up and running. The FAA says that anyone who uses these ACS documents as a guide to training and test preparation for either test even before June 15, “will be well prepared.”
There are draft versions of the Private Pilot and Instrument Rating ACS already posted at faa.gov. You can also find sample test questions including both the old learning statement codes and new ACS codes. Just Google “FAA airman certification standards” and Google will return an assortment of information on ACS.
Private and Instrument
Again, the ACS changes neither the check ride nor the skill-performance measures in the PTS, and won’t lengthen the practical test. Applicants who complete their training according to the ACS will have the best shot of passing on the first try. Since training and testing are aligned, test prep will be a matter of ground school review, not reviewing the written test. Since you are learning only what you need to know and not irrelevant material, your studies will be more efficient. ACS will not make the test harder, increase the cost of training or change the standards now in effect.
As an applicant, the ACS will help you clearly understand what you must know, must consider in terms of risk management, and do, as in demonstrating a skill.
The draft ACS follows the conceptual framework for the private and instrument tickets, but reflects the fundamental differences between those ratings and an instructor certificate. One key difference will be that the instructor ACS will emphasize practical application of the instructional concepts and techniques presented in the fundamentals of instructing (FOI) examination. The ACS will use appendices to define acceptable standards for knowledge, risk management and aeronautical proficiency skills specific to a given instructor certificate. In specific application, the instructor-applicant will be expected to identify and mitigate the built-in risks of flight instruction. As in the past, the instructor-applicant will also have to demonstrate analyzing and correcting common learner errors.
Since the ACS bundles knowledge, skills and risk management, instructors can more easily assure that a student is prepared with nothing forgotten. Like the other ACS, test prep will be a review of ground school curriculum, not a separate unrelated test.
Those vaguely specified Special Emphasis Areas will be placed in the proper context, simplifying teaching them, especially risk management. For those needing a brush-up, see the Risk Management Handbook, FAA-H-8083-2.
The ACS is not a training syllabus because it simply defines what an applicant must know, consider and do in order to earn a ticket. By contrast, a training syllabus defines how these standards will be met.
Information for Evaluators
The ACS doesn’t change the practical test. As before, the FAA expects the evaluator to focus primarily on just the elements and areas the applicant missed on the knowledge test. Evaluators will have to develop a plan to touch each element of the ACS. To help, the FAA is developing samples for the tests.
Soft skills will be evaluated using scenarios and circumstances that require decision-making and judgment. Evaluators will have more to go on since the ACS specifies risk management elements with each skill.
Yes, there are formal plans to train evaluators, with special attention to plans of action and how to evaluate risk management. Recently the Designee Standardization Branch sent a memo on ACS to all examiners (DPEs), including a link to materials on the airman testing standards web page. The ACS project team is working to develop ACS training as June 15 looms. Internally, ACS references are included in new guidance for DPEs (in the Designee Handbook, 8900.2) and the FAA is in the process of adding ACS references to that handbook.
Once everyone sees the ACS documents, I think they will be impressed by the clarity and organization. Putting everything necessary for accomplishing a task all in one place, and the unambiguous risk management presented in context, are a great improvement. Knowledge tests will finally become worth taking because they are tightly coupled to ACS knowledge topics.
I think ACS will help us turn out safer, better-trained and qualified pilots. We all want new pilots to get off to a strong start, and I think ACS is a step in the right direction.
Fred Simonds is a G1000-certified CFII in Florida. See his web page at www.fredonflying.com.