VFR “Pink Slip” Problems!

Many critical pilot deficiencies uncovered during FAA “oral evaluations” are also weak knowledge areas for ALL pilots.  Every pilot needs to thoroughly understand these problem areas for greater safety. So here is a radical idea; the FAA ACS can be a wonderful tool for improvement even for certificated pilots. Maybe you “passed” your pilot test years ago (and missed some sections- or used the older PTS)? Here is a crib sheet for pilot improvement based on the Airman Certification Standard (ACS). It is also perfect for CFIs conducting flight reviews or preparing candidates for a test!

The items below are “pink slip items” – critical knowledge – from DPE evaluations of VFR candidates.  Dig into these areas and test your own understanding for future flight safety. And please add your own personal “aviation pain points” below in the comments.

Risk management is a central structural component of the ACS (and aviation safety). Evaluating pilot judgment was the major change transitioning from the PTS to ACS. The core understanding here is that FAA minimums in every area are *not* “flight recommendations” but regulatory boundaries. The classic bare-bones “one statute mile visibility and clear of clouds” in Class G airspace is a perfect example. This minimum condition might be utilized safely in rare cases by a very experienced pilot but it is certainly inappropriate for a newly certificated pilot. Proper risk management requires “personal minimums” at a much higher (safer) level – creating a “margin of safety!” Risk management is also systematic, objectively separating what might be barely “legal” from a “safe and smart” operation! This same logic carries all through the FAA regulations and operations: e.g. night flight requires only control guidance from a compass, airspeed and altimeter (no AI required). As another example, a pilot can *legally* fly solo day/night for 23 months and 29 days after a flight test or flight review with no subsequent training or experience; just don’t take innocent passengers – get three TO/L first. This is technically “legal” but we can all agree it sucks for safety!

Pilot Qualifications; This is the first Area of Operation and often where your flight test will start; be sharp here for good first impressions! You need to know pilot privileges and limitations – what can you legally fly (or not)? The permissiveness of the FAA here frames the rest of the oral discussion. You did all your training in a C-152, can you (legally) walk out after the flight test, start up a Cherokee 180 and go flying? Is this a good idea? Does risk management come into play with determining reasonable pilot actions?

Know all the limitations in 61.31 (high performance, complex, tailwheel, high altitude) and how you acquire those privileges. Do you add a seaplane privilege the same way? Also remember the 90 day requirement for passengers (and can they pay you?) as well as the flight review (61.56) requirement.

Airspace limitations – required equipment and pilot actions: All pilots seem to be weak on airspace – and this even includes proficient IFR fliers for whom most airspace disappears! The confusion is especially obvious decoding Class E and G airspace boundaries and limitations.  Just yesterday, I had a PPL applicant claim a magenta airport with a dotted magenta dashed line around it was a “Class Delta (towered?)” airport – nope! The magenta dashed line is where controlled (Echo) airspace extends down to the surface, and the higher viz of 3 sm is required with additional separation from clouds. Most pilots do not understand this provides a safety margin for IFR inbound traffic. A “surface Echo” is often an indication that the non-towered field has lots of IFR flights or an ILS approach. (Interestingly, the FAA has not kept up with LPV approaches to the surface by protecting the airspace in a similar fashion). If a Delta airport goes IFR, can we fly VFR in the surrounding Class E surface area (much larger than the Delta)? It is not uncommon for pilot applicants with over 100 hours at their home field to not even know what airspace they are flying in during all their flight training.

System knowledge and required instruments: What instruments are required to be installed and work for legal VFR flight? Many applicants happily quote the “A TOMATO FLAMES” acronym but then cannot remember or apply this rote formula to  real conditions! When asked what the three required flight instruments for VFR flight are (91.205) very few applicants can come up with the altimeter, airspeed and compass. Many will insist an attitude indicator is required for day (or night) VFR or that a leaking and inoperative compass is not a problem for their flight. My advice to my students to build a lasting and useful mental model is to “visualize the most simple plane like a J-3 or Champ” and think of what is in this plane. I call those very few required instruments the “sacred seven.” Just add required instruments and indicators as the plane becomes more complex.

Inoperative equipment: If something is broken in the plane, can we legally fly (91.213)? IF it is legal is it “safe” and does it meet the requirements of a specific “kind of operation.” What actions are necessary to make this plane legal to fly? The FAA guidance is that every airworthy plane has to meet the requirements of the original type certificate data sheet (TCDS) – as new. If *anything* is inoperative, the plane is immediately unairworthy until a pilot analysis is made to determine if the inop. equip. is legally necessary and/or essential for safety.  Can a pilot “properly alter” the plane so it is legal for flight (91.213)? Is a mechanic required? Is a maintenance sign-off necessary? e.g. every pilot (and most CFIs) will tell you if your ELT is inoperative (scenario: the ELT antenna has snapped off) the plane has to be grounded (check 91.207 carefully…)

Failure to calculate the required data: Despite pre-test discussion and recommendations, few pilots effectively analyze the weather or calculate their performance (W&B, take-off landing distances). It is not uncommon for a pilot to not have a taxi diagram or even know the length of their home field runway where they have done hundreds of take-offs and landings.  91.103  – “all available information” is often criticized as too broad, but also names specific calculated data on the five primary causal factors of fatal accidents: “the killers.” How long is the runway and what is the aircraft performance today? Do I have enough fuel and is the weather checked and satisfactory (see personal minimums above)? Have I investigated and planned alternates and looked at delays (NOTAMS)?

Human Factors: I am feeling headachy and nauseous in flight, what is the probable cause and pilot action? WIll O2 provide immediate improvement?  When does a pilot need o2? Does everyone get hypoxic at 12,500 after 30 minutes? A growing number of pilots involved in fatal accidents have illegal drugs in their bloodstream (28%) My passenger is suddenly looking excessively nervous – pasty white and incoherent. What might they be suffering from?

Preventative Maintenance: There is a common joke that one of the most dangerous hazards in aviation is an airplane owner with a toolbox. What can a pilot legally accomplish as “preventative maintenance” and how do we do this? Can a pilot replace a wing nav bulb? Are logbook entries required? Is a maintenance manual (or previous training) required?

Privileges and limitations: Can a newly certificated pilot who has only flown a Cessna 150 legally rent and fly a Grumman Tiger? Again the FAA is pretty permissive, but personal cautions should be in place to keep a pilot safe. In all aviation operations, what is legal and what is safe or smart are often quite different and distinct standards. What logbook inspections must a pilot know and verify to assure an airplane is “airworthy?”

Risk mitigation plan: While planning a cross-country flight, what are the major risk factor areas the FAA recommends a pilot investigate and mitigate (P-A V-E) The ACS requires a risk management plan that specifically addresses these items. “Being cautions” is always good but having an actual defined plan with objective standards is essential. All the other scenario questions from maintenance to equipment and airspace hinge on risk management. How can a private pilot applicant show up at a test and have not heard about P-A-V-E? Some flight instructor badly failed this person.

Systems knowledge is a weak area for most pilots at all levels. Almost any question about “pieces and parts” or technical information seems to often be deadly on check rides. Scenario: “I am flying along on that assigned cross-country and the red ‘low voltage’ light comes on (or other ‘non-charge’ indication). What are the pilot’s immediate actions? How long do I have and what will fail? How will a pilot bring this flight to a safe conclusion?” Answers to questions like these often reveal limited knowledge and a lack of both command authority and the use of resources. If it wasn’t so sad, some of the explanations on how planes work would be very funny. My personal favorite is how the fan belt drives the propeller for thrust.

Preparation for safe piloting requires a lot of imaginative “what if” thinking (and then research of questions discovered). Applying knowledge and creating a plan is essential for safe execution. The ACS-focused knowledge areas where pilots often struggle during flight tests are great review topics for every pilot. Be creative in your imaginative “problem creation” because mother nature sure can be. Make sure you go into the test with all the required documents and endorsements (on the Toolkit App) Fly safe out there (and often)!


Join SAFE and get great benefits (1/3 off ForeFlight!) This supports our mission of increasing aviation safety by promoting excellence in education.  Our FREE SAFE Toolkit App puts required pilot endorsements and experience requirements right on your smartphone and facilitates CFI+DPE teamwork. Our CFI insurance was developed by SAFE specifically for CFIs (and is the best value in the business)

Author: David St. George

SAFE Director, Master CFI (12X), FAA DPE, ATP (ME/SE) Currently jet charter captain.

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