Buffering “FAA Minimums” Aim For Excellence!

The FAA only specifies the absolute minimums (limitations) in their regulations and these are not recommended operating specifications.  This might sound silly to many pilots, but some people have not gotten this memo.  As one example, “one mile visibility and clear of clouds” in Class G airspace is an absolute legal minimum. All of aviation safety involves building (and maintaining) a personal margin above these FAA bare minimums. Minimum weather, fuel requirements, and even hours for pilot certification should have a margin applied to be safe and build better pilots.

I have been giving a lot of private checkrides lately and obviously a private pilot applicant must know Class G airspace and the basic legal weather minimums. But if they tell me they would go flying in this scary weather, they are not adequately managing risk. Similarly, FAA minimum flight instrumentation (day and night) requires only an airpseed indicator, altimeter (not even adjustable) and a compass. Again, every pilot should know this legal minimum, but should also be aware such primitive guidance is not adequate for most flights (especially at night). Building a margin by requiring more complete instrumentation, equipment, preparation and suitable weather is the basis for managing risk and building safety.

This paradigm of “FAA minimums vs safety margin” is an excellent method to understand (and teach) a risk management system (required in the FAA testing standards). Although a pilot applicant at any level must know the FAA minimums, they must also clearly define their personal “safety margin” for their  level of experience in a particular plane, environment and with unique external pressures of the situation. What examiners want to hear is “my thinking and safety margin in this situation is…”

The ACS defines specific areas to be considered when managing risk. This was developed straight out of the military’s “man, machine and mission” formula and is expanded and elucidated in the FAA Risk Management Handbook. P-A-V-E identifies the Pilot, Aircraft, EnVironment, and External Pressures that interact dynamically to cause (or mitigate) risk factors. Unfortunately, this subject is still given prefuctory coverage by many CFIs as they initially educate pilots or prepare them to take flight tests. In my opinion, this paradigm should be the primary vehicle used right from “day one” to expose new pilots to aviation. (Instead of a rarely mentioned “nice to know” addition “don’t forget risk management”)  Much of our aviation education system is still mired in the 1940s military curriculum of lesson planning. We need a cultural change that puts risk management as more central in our aviation education. P-A-V-E is an amazing safety tool for your personal flying and instructional focus.

And speaking of minimums, the current “rush to ratings” clearly is eliminating any “extras” and fun in the flight training experience. The required 5 hours of solo X-C for the private pilots now seems to often only involve one long flight on a very nice day. When I see a pilot applications with absolute minimum hours all I can think is “don’t you like flying?” Can’t we add a little more than the absolute minimum experience and build a margin of safety here too? Exposing students to more than one X-C flight or working with  more crosswind allows them to experience and internalize different weather, expand personal capacities and enhance their skills for a greater safety margin. They are going to need these hours and experience in the future anyway.

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The “minimums trap” seems to be increasingly common in pilot testing too, where applicants just just aim to pass with a minimum grade rather than striving for excellence. A 70% seems to make people happy and “mediocre” is too common in the current rush for ratings. But as proud safe pilots, our whole system of superior safety and professionalism is built on trying harder and striving for the best we can be. There is real safety value and satisfaction in exceeding the minimums and pursuing more comprehensive knowledge and skill when we aim for excellence. Fly safely out there (and often)!


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Author: David St. George

SAFE Director, Master CFI, 141Chief Instructor, FAA DPE, ATP (ME/SE) Currently flying 135 charter (again)

2 thoughts on “Buffering “FAA Minimums” Aim For Excellence!”

  1. I think your call to go above and beyond during training is an excellent idea, however, many of our students are working with funds that may not allow for “extravagances” like another long x-country. The cost for doing so might outweigh the obvious benefits, but for many students, the purpose of training is to get to the certification level where they can then start to expand on those horizons. Until costs for training come down, I feel you’re going to continue to see minimums met during training.
    I think about my flying experience both during training and then after. I think I got more out of it AFTER training, once I “took care” of meeting the needs of the FAA in order to “actually go flying.” The cost-paradox will always be the determining factor for your student’s readiness. I wonder if you’re looking too deeply into what the training is all about. It’s really just to get that green plastic card that then allows us the freedom to fly places that we want to go instead of where we “have to go,” because Big Brother says we do.
    All students would LOVE to take that flight across the country (not just the minimal 50-miles), but it’s impractical, especially when paying not only for the plane, but for that nag to their right as well. Once they can start bringing friends along, they can split the costs and go farther and see more. The counter-argument is “are they ready to do so?” but then, why would you be signing off on them if you didn’t already think so. The only solution for this is to get the FAA to increase those requirements, maybe at the cost of reducing some of the others.
    Just my humble, new-instructor (long time student) opinion.

    1. I do not want to see the FAA increase minimums, but I advocate for pilots (and their CFIs) to voluntarily pursue a higher level of proficiency (as in the new AOPA “Focused Flight Review” exceed the minimums). SAFE specifically focuses on instructor improvement and encourages these professionals to assure their students meet >their< (higher) safety standards and before they recommend students for a test (not sign them and send them and "see what happens") In the current FAA system a mere 70% grade will, by regulations, get you an FAA certificate (and a DPE must legally approve this person). One school I work with reliably produces 72% level pilots and another produces 95% level students. I want a working relationship between CFIs and DPEs that creates better pilots; a huge improvement in safety! Though I personally hope that every pilot continues to learn and grow >after< certification, I also know many will never get better (and probably deteriorate in skill and knowledge). We still lose 400 people a year for very stupid, preventable reasons. As far as the expense of flight training, I would say it usually more a matter of modern priorities and perspective. Flight training today is identical in REAL cost to what I paid 50 years ago to get my ratings; $2K I paid in 1970 (Piper "Blue Skies" Program) actually is equal to $15K today if you run a deflationary index. I do not advocate for excessive effort or expense, but I really want pilots to do this business correctly and safely BEFORE certification...or (unfortunately) they may not live to learn more.

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