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What The FAA Commercial Test Needs.

The current commercial pilot test standard, as administered, is often a joke. Jumping into a C-152 or DA-20 and doing the same private pilot maneuvers to the same PPL tolerances does not really “test” anything. There is no added challenge or demonstration of superior skill required at the “commercial pilot level” unless CFIs and DPEs step up and apply the ACS standard more rigorously. Remember, the next step for most of these pilots is as a flight instructor (to your children?) or flying in the right seat of a transport plane (with your loved ones in the back?). Maybe *real* skills are acquired during “on-the-job training” – or not?! Look at the flight track above to see how well this is working; that AIrbus was nearly a CFIT.

In many cases, the FAA commercial flight test is the aviation industry’s version of a “participation trophy.” It only assures that a pilot showed up and flew 250.1 hours – usually with only 5 hours total actual solo – and is rebranded as “commercial” under diminishing test standards. First, commercial lost the +/-50 ft tolerances, then the requirement for retractable gear (complex) airplanes, then minimum controllable airspeed (SAFO 16010), then “supervised PIC” under 61.129(a)4 became the norm for all “solo.” Now, most new CFIs have only been alone in a plane for 5 total hours (private pilot solo) and they are the primary purveyors of all future aviation wisdom.

a pilot must choose to log all ten hours as solo flight time in a single engine airplane or, in the alternative, log all ten hours performing the duties of a pilot in command in a single engine airplane with an authorized instructor on board. A combination of hours is not permissible under the rule.

Pilot examiners can only test what the FAA standard provides and there are pretty limited tools for the DPE in the current ACS to assess a higher level of proficiency. It is incumbent upon every CFI to teach beyond the FAA minimums and for every DPEs to dig deep and test comprehensively; our lives depend on this.

The rudder challenge of the chandelle or lazy eight is appreciated, but 200 feet of altitude gain with the limited power of trainers does not require huge skill. The 180-degree power off landing certainly does sort out a few pilots but luck and rote recitation often prevails here (and its pass/fail)/. AThis pathetic process demonstrates how badly flawed our flight training system has become. For the initial CFI, the passing rate is now the same as the private pilot test. We need teeth in these evaluations (teaching and testing) to provide challenge and inspire a higher standards of performance.

AIrbus 321 leaving Bozeman, MT last week; LUCK avoided CFIT?

I would encourage every CFI teaching at the commercial level and every DPE testing potential commercial pilots to spend a moment here and examine the FAA Commercial ACS in more depth. Some areas to focus on are the take-off briefing (II, F) to assure safety during this most dangerous phase of flight. “No comprehensive take-off briefing, no approval” has to be a red line. Rejected take-off and engine failure during take-off are in the ACS, but unfortunately, not explicit and seldom tested except perhaps orally. The cross country *could* be flown entirely with pilotage if an early failure takes out the “GPS magic” (ACS VI, A). Do any DPEs adequately test VI. D (lost procedures)? Headed back to home base, have the applicant find the airport without any “geo-location.” Situational awareness (SA) is a complex skill and hard to calibrate or “prove” on an unsatisfactory evaluation. But SA is mentioned 45 times in the commercial ACS. This can be a headache for DPEs because some aggressive flight academies protest every unsat.  requiring unpaid time for DPEs who have to support their judgment calls.

Here are some basic knowledge questions every pilot at the commercial level should be able to answer at the correlation level. This is essential knowledge but not often tested – because it’s not specifically stated in the ACS. These questions also provide good knowledge for all pilots who want to be better and safer in aviation.

1) What is the most efficient altitude to fly this flight at? Few commercial applicants are aware of the bigger picture outside of the performance tables (which are usually perfunctory in small trainers). Dig into ACS section I, F or VI, d. PIlots at the commercial level should know that IAS remains essentially the same as we climb at a fixed percentage of power but TAS increases at approximately 2% per thousand. (Fewer molecules of air=less friction and drag).  This provides the performance benefit of flying higher than the usual student cross country. Available power decreases with altitude at a rate of approximately 3% per thousand in a normally aspirated piston plane. Consequently, the optimal altitude will be where the desired percentage of power is full throttle (and best volumetric efficiency). Headwinds will obviously have to be considered (but let’s not get involved with “weather ignorance here). Graphing the 3% power loss against the 2% TAS gain usually provides ~ 8K density altitude cruise in calm winds at ~65% power.

2) Extrapolating from the above understanding, what are the effects of this disparity in TAS and IAS (and loss of performance) for high density altitude (DA) pattern operations? Approaching to land at Centennial Airport in Denver on a hot summer day (10K DA) might show an indicated 65K on final when actual TAS is 75K. Most pilots are going to drop their plane onto the runway due to their unfamiliarity with this high-speed visual illusion. (CFIs can easily simulate this in training with a tailwind landing on a long runway). High DA take-offs are even more dangerous when a plane can get airborne in ground effect below (IAS) stall speed. Rotating when it “looks about right,” puts the plane airborne in ground effect – still not able to fly. A pilot must be able to lower the nose to climb in this situation, just like a soft field take-off (and most don’t). High DA accidents often sail off the end of the runway in ground effect. And your C-172 is a C-152 in Denver on a hot day.

3) What is “stall speed” if we can stall at *any* speed? Why does Va change with weight? “Stall speed” is a 1G determination at max gross weight. “Stall speed” changes with a/c weight (and G force) and CG location. And if we multiply 1G Vs times the square root of the load factor, we can derive that variable Va. Unfortunately, most commercial applicants don’t even know normal/utility G limits. Another way of saying this is a plane will stall before it breaks at speeds below Va (a safety valve? – above Va we are test pilots). What is the effect of weight on Vx and Vy (hint – they meet at the service ceiling of the airplane). Most commercial applicants have never seen a Vg diagram.

4) Expanding on this discussion, how doesa pilot experience/induce G force in normal flight? Most commercial applicants never thought of G force as just another form of weight. When this ligh bulb goes on it all starts to make sense – why don’t most CFIs teach this stuff? The increase in stall speed from G force (bank) is non-linear (square root function) and this can surprise pilots. In repeated surveys, the majority of pilots overestimate the G force and stall increase at 45 degrees of bank (only 19%) and fail to appreciate how quickly this exponential force increases past that angle. The recent jet accidents while circling to land clearly illustrate this ignorance. We do accelerated stalls at the commercial level, but few applicants can calculate the effect of bank angle on stall speed. Slip/skid/spin is an under-appreciated knowledge area (but required: VII, E “spin awareness). This will be a future blog…

5) Most commercial applicants do not understand the effect of forward and aft CG on stall speed, stability and controllability (I, F). The CG is forward of the center of lift and provides a variable lever-arm of controllability. The tail providing the downward balancing force surprises most pilots. Controllability and stall speed become easier to understand once this force is understood.

6) There is no mention of type certificates, supplemental type certificates or 337 forms in the current commercial ACS. Most new commercial pilots will be flying old beasts with 15 STCs modifying the original type certificate. This has an obvious effect on the airworthiness of the airplane (see FrankenPlane).

These are just a few basic items that come to mind that are seldom tested at the commercial level. This knowledge is critical for every pilot’s survival as they fly more unforgiving airframes (those Lear 35 examples). Let’s prepare our pilots better and we will have fewer unnecessary deaths as a result of ignorance. Fly safely out there (and often)!


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Author: David St. George

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

14 thoughts on “What The FAA Commercial Test Needs.”

  1. I’ll keep this short, because I could write and talk on this for hours, but the problem is the flight school! Yes, the flight school! Many are in it for the money and offer set cost for various rating. As such, they cut corners in order to get the client through under budget. When you think about it the Part 61 flight instructor out there probably is doing a better job than the 141 instructor who just got their Private, instrument, commercial and CFI within the past year and is building time to go to the airlines. There not the CFI who does it because they love teaching. I’ve been an active instructor for 55 years, I love doing it because I love see pilots learn, not for the money not for the hours, but for the smiles. These are the instructors who teach what Va is, what Da is how weight, CG, temp, etc affect the airplane. These are the instructors who are going to teach their students how to fuel an airplane. Yes how to fuel an airplane! So many flight schools do not teach fueling. Or how abut this on, again, many flight schools do not teach proper stalls and different stall configuration. I could go on about that issue. Many instructors do not or cannot teach proper flight attitude flying. I heard one school use greas pen marks on the window to reference the various aircraft attitudes. Well I don’t think an airline would appreciate there crew using these crutches. And, they are crutches to speed up the learning, not to teach basic flying skills.
    Well enough, I could go on but I said I would keep it short. Don’t worry about the hours, don’t worry about how fast one can become a pilot, teach good basic skill, spend time on the ground and one will succeed.

    1. I completely agree. A lot if the flight schools teach how to pass the checkride instead of how to fly. Hence the 5 day quick multiengine courses, the quick instrument courses. They are just teaching what the “selected examiner” will ask.

  2. Actually I think some of the items you mentioned are good things to know, but are not necessarily required to fly an airplane safely and accurately. Overall nothing in the article is surprising. Every week, I see I don’t know how many pilots and instructors that don’t know what the ‘Region of Reversed Command’ means. This includes people that put on FAASafety classes – one was from SAFE. Another was a fairly recent CFI of the year. If our leading educators can’t get the fundamentals straight, why should we expect CFI’s to instruct correctly?

    1. Well at the commercial level we require more than flying “safely and accurately;” that is PPL. Commercial additionally requires “smoothly and efficiently” and all should be at a high level (used to be +/-50′ The elegant management of the energy is a big factor and understanding the physics involved is critical to smoothness and success. I always loved the term “region of reversed command” since it sounds sinister….but physics is really not repealed. Try reading AC 61-50A and see if that squares with the new Chapter 4 in the Airplane Flying Handbook on energy management?

      1. I guess I should have used more adjectives. Certainly smoothly and efficiently are goals for both Private and Commercial and I think go hand in hand with safely and accurately. The AC and the new chapter seem to have similar discussions – have read the new chapter only once. It’s information CFI’s should be able to use to explain progressively for efficient student understanding. But I think it all can easily be misunderstood and is in fact broadly misunderstood. The discussion on the region of reversed command in the PHAK chapter 11 is far better. And the discussions in the Airplane Flying Handbook chapter 9 on how to correct for low and/or slow approaches are simple for anyone to understand and far more effective.

  3. Ah, good morning David and the rest. I see names commenting that are regular readers and commenters.

    The consensus here seems to be that the FAA is “dumbing down” the ratings based on the idea that doing so will fill the ranks of airline pilots more rapidly, and yet they will still have the necessary skills to meet unusual demands in the cockpit. Yes, the airlines do an excellent job of taking qualified applicants and actually turning them into airline pilots … most of the time. Unfortunately that leaves pilots who are not bound for the airlines somewhat in the lurch. Where are they going to get the requisite skills to actually become good pilots? It sure isn’t the typical 141 school but unless the CFI goes out of her way to gain more knowledge, skill, and experience, it isn’t going to be the part 61 CFI either.

    I am not sure that things have changed much over the past 54 years I have been flying either. Yes, the tests were more rigorous when I got my commercial ticket in 1972 but also, most CFIs were ex-military and had received far more comprehensive instruction in the first place and could (sometimes) impart more knowledge. The FAA back then was filled with people who had come from aviation, often military aviation. When you went to the FSDO for a field approval for a change to your airplane you ended up talking to someone with an engineering degree and extensive experience with aircraft. Today that is no longer the case.

    If the FAA cannot do the job then it is up to those of us who have the skills to do so. Sometimes an industry has to regulate itself. SAFE and NAFI have the right idea but I am not sure they go quite far enough. The idea of the Master Flight Instructor who meets and exceeds a higher bar is a good one. We should develop those standards and then encourage CFIs to meet them. We need to enlist the aid of organizations like AOPA and EAA, then we need to get the insurance companies to recognize AND REWARD pilots and CFIs who aspire to higher standards.

    I would create an extended test criteria that goes beyond the PTS/ACS and ask DPEs to offer testing to that higher standard if the applicant requests it. Of course, if the application only meets the ACS standards they will receive their certificate/rating but they won’t be able to show that they have the greater level of proficiency and the insurance companies will then act accordingly. (It would be interesting to see what happens if you can’t get insurance because you didn’t reach the greater standards.)

    So, what are the next steps? As I see it the steps required are:

    1. Codify new standards;
    2. Teach new CFIs to the new standards;
    3. Get AOPA, EAA, and GAMA behind the standards;
    4. Get the insurance underwriters to grant reductions in insurance cost to pilots who meet the new standards.
    5. Get the airlines to grant preferential treatment to pilot applicants who meet the new standards.

    That’ll fix it. Of course, that will be a challenge but, hey, challenges make life fun!

    1. ‘Codify standards’… real bad idea. Do you think even 10% of congress knows the first thing about aviation?
      ‘New Standards’… really?… there is only one standard, do not crash. Everything else is regulatory. Student can’t do spiral decent in an emergency? Or a 180 landing on downwind to land if their engine goes out? I can not think of a single skill required by a commercial pilot that a private pilot shouldn’t be able to perform.

      Here is something to wrap your brain around. I got a FAA commercial pilot certificate with ZERO hours… to fly drones. You see,’commercial’ is just regulatory to the public, congress, and more important… the courts.
      Anyone that is taught to fly is expected by the public to fly over their property without the fear of that plane crashing down on them. That is why there are pilot certificates. This means, they expect everyone to be flying to the SAME STANDARDS at all times… if they knew an unlicensed pilot was flying over their home on a solo… they would go nuts and push to ban solo training flight.

      The public expects skills between a private and commercial pilot to be the exactly same… don’t crash. These are the skills needed not to crash… every pilot should be flying with these exact same skills. Name a single skill that a commercial pilot needs to be able to demonstrate that a private pilot shouldn’t.

      Everything else… should be a regulatory written test.

      As for ATP hr requirements… they are silly stupid and dangerous. Every pilot should be required to receive training on any new aircraft flown… be it a 150 to a 172. The level of training need depends on the complexity of the new aircraft to be flown. Each aircraft should be signed off.

  4. You clearly misunderstand what I am saying. When I say, “codify standards,” I do not mean asking Congress, the FAA, or any other official government body to do this. As you suggest, they don’t have the knowledge or experience.

    No, what I am suggesting is that WE come up with new and better standards, write them formally, and present them as a proposed improved standard to the aviation community. Clearly SAFE and NAFI seem to be moving along that track. I am just suggesting that we be more proactive in getting it done. I have been hearing about how the quality of pilots and instruction have been decreasing over the years. It seems like it is time to actively change things.

    I have been a pilot for 54 years. I have been a CFI for 24 years. I know I keep seeking ways to become a better pilot and instructor. Now I want to help others become better too. So, what is “better”? That is what I think we need to “codify”.

    So, what do you think the skill set for the “average” pilot and CFI should be? I think we all agree that the PTS/ACS is NOT it. What do we need to add? I certainly have my own ideas but what do others think? Let’s get it all down, distill it, and present it to the community. I find bits and pieces of it everywhere but not so much having it in one place, similar to the PTS or ACS.

  5. Airline preferential treatment?… why are ‘airlines’ special?
    Many 121 airlines are really glorified 135 operations now. Their so called ‘schedules’ are rarely met.
    121’s are even moving to bussing as a portion of their ‘air’ transportation.
    So, why treat a 121 bus service differently than a 135 taxi or Uber service? Commercial Regulations…all based on public perception.
    Ever seen an Uber driver with a commercial drivers license? Nope.
    They are still expected to drive to private car standards… don’t crash.
    Who really regulates all commercial operations? Insurance companies.

    Over the last ten years the entire training thought pattern for aviation has gone from safe effective training, to time riding around in a small plane… The law makers say it worked, look, no airline crashes. They haven’t asked airlines how much more training is required to rid bad habits and how many wash out. The good thing about flight training loans… you can bankrupt them still, unlike college loans.

  6. You misunderstand. I am suggesting that the airlines could give preferential treatment to pilots who demonstrate a higher level of knowledge and proficiency over the, “meets the minimums only,” part 141 pilot.

    Let’s turn this around. Ask yourself, “Why should anyone go out of their way to be better if there is no advantage to being better?” I am suggesting that we create a standard for “better” and then shop it to the insurance companies and to the airlines. If the insurance underwriters believe that someone who has trained to a higher standard is a better risk, they might lower their rates, a clear advantage to the pilot. If the airlines believe that someone who has trained to a higher standard is more likely to be a better pilot in the long run, they might choose to preferentially hire that candidate over someone who does not have the additional training/credential.

    1. The only real way to train to what the airlines want, is to let them set the training standards to what they want for a new hire. It shouldn’t have anything to do with commercial operation certificates or regulations if they want 10,000 hr pilots… let them find 10,000 hr pilots. The FAA shouldn’t be making these decisions. The FAA should be setting a base skill standard that keeps the people safe on the ground and in the air, paying or not paying.
      Does 1500 hrs make a pilot safer? If so, every pilot should be required to fly 1500 hrs. Statistics show, more hrs doesn’t make a better pilot. A demonstration of skills does make for a safer pilot.
      The FAA base pilot skill standard is what ALL pilots should be flying at. It seems like when ‘sport pilot’ came along there was a mission to dumb down being a pilot. Can’t navigate, no problem, be a sport pilot.
      I flew with an instructor that never actually stalled a plane before. I showed him a stall and he was visibly frightened. Apparently knowing how to actually fly an airplane is no longer a skill set required to be a instructor anymore, much less a private pilot. By the way, I was flying with this instructor as a ‘private pilot’ for the type of aircraft.

      I say do away with ‘sport’, ‘private’, ‘commercial’, and ‘airline transport’ pilot completely and make everyone learn all skills to be a PILOT. And leave ‘commercial’ to business licensing and the IRS collection of taxes.

      We need more base training of pilots in general, not more regulations.
      There should be one type of pilot, and an instructor sign off for each aircraft you intend to fly. Killing off the Commercial and ATP certificates would be a great start to making aviation safer. If a business wants pilots to fly boxes at night, they will require more night flight than a Hawaiian helicopter tour operation. This is a business operational training decision. It shouldn’t have anything to do with a certificate. If a business wants a pilot to fly a B747, they train to that business operational level for that aircraft. If they fly Cessna 206 sea planes… then that is the training and sign off of the business. The government shouldn’t be making business decisions, that is too close to communism.

    2. Not likely to work in aviation. No organization that I know at any level would take someone else’s word on someone’s skill level. This ranges from rental checkouts to airline jobs.

  7. My last commercial student the examiner had her use an airplane POH for a larger aircraft than she had ever flown previously for all of her cross country flight planning and had her plan a scenario under part 135 with W&B and performance questions related to what regulation the flight would be under. He had many students/CFI’s get upset at him for changing this up on them from a standard checkride approach but his reasoning was very solid. A commercial student can go and fly SIC in something way bigger and he wanted to test their adaptability to those new challenges vs something the student was familiar with.

    I’ve also had a recent student who was working on his flight instructor certificates that had somehow got through his commercial and multi last year that clearly was not at that level. After flying with him for a few hours, I definitely questioned how someone like that gets through the system. His basic skills just weren’t there at all, from airspeed and pitch control, to landings and go arounds. I have a different CFI student that I flew with last week and it was a completely different story. By the time I was done flying with him in one flight (were it not for the the requirements still needing to be met) I probably would have signed him off. How the same system can produce two totally different products that are both “tested” at the same level is beyond me.

    1. I would love to present challenges like that, but (according to my FAA guidance) DPEs are legally limited to the airplane that the applicant brings to the test! And a Cessna 152 (or similar) does not have extensive performance, W&B or systems information to challenge an applicant at the commercial level. Back when we had “complex” aircraft (e.g. Mooney) there were extensive performance tables to explore during an evaluation.

      This brings me back to the key point in many of my blogs; it is the *recommending CFI* who really determines the quality of the future pilot! They can inspire excellence and a higher level of skill, knowledge and judgment. DPEs have a couple hours and are tied to a pretty limited standard (that is also pass/fail!). Thanks for your comment🙏

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