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No CFI ACS; Here’s Why!

You have probably wondered why you have not seen the new CFI ACS (promised for the last 4 years) or any changes to the current standards? A Department of Transportation interpretation (December 20, 2018) classified the current (and proposed) Airman Certification Standards as “Official Guidance Material.” This DOT interpretation coupled with a presidential proclamation from the last administration, requires all ACS/PTS documents to refer directly to Federal Regulations for support. Consequently, any change or update to an ACS was subject to the NPRM process (Notice of Proposed Rulemaking). This is a year-long process requiring publication (with public comment and response) for any change. This draconian interpretation prevents any flexibility in the creation and/or updating of the flight training standards. This cumbersome process, preventing flexibility or rapid update of the standards, jeopardized the safety and the evolutionary improvement of the training process. These standards are were essentially “frozen” until just now; progress is finally being made with a legal workaround called “incorporation by reference.” (Glad I’m a pilot not a lawyer…) But it is about to get really weird for testing as these new standards are (incrementally) published and approved (more soon).

DOT advised the FAA that all future ACS or PTS documents, including updates, will require that the FAA either (1) remove any tasks and maneuvers not explicitly required by regulation; or (2) issue a rule that would make those tasks and maneuvers regulatory.

As is apparent in the Aviation Mechanic release above, we will probably see a confusing progressive release of future testing standards as they achieve approval after being published in the Federal Register (stand by for more). 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.

2 thoughts on “No CFI ACS; Here’s Why!”

  1. Why is #7 missing from the list of potential qualifications for DPEs? It can be found on the next page of the order. The evaluation experience is one option, but so is instructing experience. The list does not seem to be overly restrictive. The selection process at the FSDO level, on the other hand, is an issue.
    (7) Provided at least the following hours of flight instruction to airmen which led to the
    issuance of a pilot certificate or rating as applicable to the categories sought.
    For Authorization In: Hours in Category
    Airplanes 200
    Rotorcraft 200
    Gliders 100
    Lighter-than-Air 50
    Weight Shift Control 100
    Powered Parachute 50

    1. Thanks for that Paul; bad error on my part! I was reading on line and missed that – and was surprised how restrictive the standards were…sorry (see edit).

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