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“Minimal Pilots” and CFI Mandate!

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To understand the FAA regulatory philosophy, we first need to examine the FAA minimums for flying under CFR 91. For daytime flying in Class G (“go for it”) airspace, the FAA only requires 1 sm. viz. and “clear of clouds!” This is legal, but “a suicide mission” unless you are over a familiar landscape in a slow plane. Under all of part 91, the FAA only specifies minimums. By contrast, the FAA strictly regulates flight under CFR 135 and 121.

In flight training also, the FAA supplies minimums. Only requires 35 total of hours  and one 100nm X-C (CFR 141) or 40 total to become a private pilot under CFR 61. The “minimums only policy” has unfortunately become the de facto “normal”  in our “accelerated training” environment! As a result, we are often only creating “minimal pilots” – mediocre. Though all knowledge tests are required to be trained and tested to 100%, (endorse by CFI, tested by DPE in the practical test), nothing brings mediocre flying skills up to 100%.

The standards defined in the FAA ACS for testing are the absolute *MINIMUMS* required to pass a flight test (pass/fail). Achieving only these minimums would be a grade of 70% or D-. Unfortunately, these minimums have become the *target* for successful training/testing. They are also often the standard CFIs use for an endorsement for a flight test (ouch!). New pilots under FAA regulations can sometimes resemble the old joke, “What do you call a med. student graduates last in their class? – “doctor!” This is exactly what our flight training world is resembling – except “pilots!” To distinguish excellence, Flight Safety issues a “Pro Card” to superior pilots. This distinguishes superior achievement from a mere “pass!” All the weak areas below are “opportunities to improve!”

The ramifications of “achieving only minimums” is even more horrifying when you move up the ladder to new CFIs graduating under CFR 141 with only 5 hours of real solo time (or 10 hours under part 61). What kind of “experience” will these new CFIs have to share with their new clients? SAFE has created the CFI-PRO™ course to add “The Missing Manual” of what is missed during accelerated initial CFI training. Instrument instructors and even new ATPs in the right seat of your airliner have never flown in a cloud. This is what you get with “minimal.” So what is sensible and safe? What would “best practices” policy suggest? Every aviation educator should start by considering the CFI Model Code of Conduct. We need to be working diligently to create  fully capable aviators demonstrating far more than minimums.

Instructors should:

a. make safety a high priority,

b. seek excellence in airmanship,

c. develop, exercise, and teach good judgment, and aeronautical decision-making,

d.recognize and manage risks effectively, and teach sound principles of risk management,

e.demonstrate and teach situational awareness, prudent operating practices and personal operating parameters,

f. aspire to professionalism,

g. act with responsibility and courtesy, and

h. adhere to applicable laws and regulations.

Best Practices Before Solo (61.87)

Click for larger image

This FAA guidance makes it clear that “training beyond the minimums” is the FAA intention: the faasafety.gov website is all about “safe and smart” beyond the minimums.  For initial solo, mere “survival” involving a couple of times around the pattern is not appropriate or sufficient. Adequate solo training *requires* that a learner not only can perform when everything goes right, but also in case things actually go wrong. Every pilot can study those 15 required solo items in CFR 61.87 and work to do better in every one of these essential skills (opportunity).

When a CFI endorses a logbook for solo, they are saying “this pilot is competent to fly on their own.” Even with a full page of limitations added to that endorsement (no wind & 10K ceiling) the expectation is that every pilot is a fully competent PIC. This means being able to not only fly safely in perfect conditions, but also make risk management decisions for dispatch and handle a level of inflight confusion and distraction. They should have achieved a level of PIC (command authority) beyond their total dependence on their CFI.

Crosswind Training (61.93)

CFR 61.93(e)(10) requires  instruction in “crosswind takeoffs, approaches, and landings,” but no proficiency standard is stated here. In the private pilot test this is skill is seldom tested (“discussed” instead). Crosswind landings are only *required* in the ATP evaluation. SAFE recommends all private-level flight applicants should have trained and logged at least 10 landings with 10 knots of crosswind. DPEs regularly see even CFI candidates canceling checkrides for only 5 knots of crosswind! If crosswinds are not trained at the private level, they usually never get better. CFR 61.93(e)(10) is the only required crosswind training a pilot will receive in their whole march toward professional pilot! The statistics for pattern landing accidents with wind (>80%) make the need for this training imperative.

When the winds blow, the risks increase for light aircraft operations. The single leading cause of accidents involves loss of directional control during takeoff or landing…over an 11-year period the National Transportation Safety Board identified wind as a primary cause of more than 2,800 accidents.

Click to enlarge: The only *required* crosswind demonstration.

“Slip to Land” Capability and Comfort

Slips to a landing are a required maneuver in the PPL ACS. Unfortunately, many DPEs give this area short shrift, and all see a serious reluctance on the part of applicants to demonstrate this maneuver confidently.  This fear comes largely from a misunderstanding of the maneuver on the part of these pilots (and their CFIs). Greater knowledge and practice is essential for any comprehensive understanding of basic aircraft aerodynamics required in the PPL evaluation. I guarantee if any DPE tested this area in a comprehensive manner consistent with the ACS, most PPL candidates would fail. DPEs need to test these maneuvers fully so pilots will be trained properly.

Engine Failure/Emergency Landing

This maneuver is required in presolo training (61.87) but is certainly a critical and essential “life skill” for every pilot. For reliable success, emergency landings should incorporate the technique (formerly proscribed in the AFM) of high key/low key (learn from your glider friends). This is often one of the weakest maneuvers on a PPL test. And most applicants do not understand the necessity of memorizing (and following) the POH “immediate action” items. Instead applicants intone the “internet wisdom” of the A-B-C-D checklist. This is not going to work Ready for anything!for their airline sim training. When performing this maneuver for real, it is essential for to first try a restart, then “get to the field, and only descend, in a spiral, when you are over the field. The big pattern with a two-mile final seldom works. Gravity *always* works, and every pilot needs to keep this skill sharp.

Actual Cloud Experience (IMC)

This is helpful at the private pilot level with 61.93 training, but essential when a pilot is pursuing an instrument rating. Unless the environment completely prevents some “wet wing” time, this is so useful that its importance cannot be overemphasized. To fly commercially,  a pilot will always be IFR and frequently in the clouds. Not introducing real IMC flying and preparing a pilot for the real world is unconscionable.

Real Spin Training For CFIs

The current flat-rate “circus ride” for CFI candidates to get their required spin endorsement is worse than useless. With no exposure to the theory of aerodynamics and procedures in AC 61-67 (the very basics) most CFIs are still scared of stalls and unprepared to really recover an in-flight Loss of Control. The fact that they accomplished some perfunctory training can convey an unfounded sense of safety and competence. Real proficiency only comes from thorough ground training and a complete different spin entries.

Yes, you can teach MCA (just not test it)!

How many senior CFIs have I heard say “I wish we could teach Minimum Controllable Airspeed (MCA) like we used to.” Well, you really can, and it is a valuable skill to demonstrate energy management and induced drag (while also building good rudder control habits). Once a learner has mastery of this level of control, it is easy to just be clear: “On the FAA Flight Test,” fly it faster with no stall warning horn, please!” The FAA actually reintroduced MCA in the CFI ACS *requiring* this skill for CFIs to demonstrate (on the test and also to learners).

Useless 10 Hours “Complex” in Commercial Training

I have written elsewhere about the currently useless “complex” training. The FAA eliminated the “complex” – retractable/constant speed – for safety, but had no fast substitute under 61.129. (put *your* suggestion in the comments). Currently, this 10 hours is a wasted opportunity, which usually involves teaching more G-1000 time (“complex?”).  Instead, we could be teaching some basic UPRT or the SAFE EET curriculum to address our #1 pilot killer: Loss of Control. (maybe a tailwheel endorsement?)  Any of these curricula would expand the pilot’s confidence and capability to handle an upset situation. Just my thoughts; fly safely out there (and often).


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8 responses to ““Minimal Pilots” and CFI Mandate!”

  1. Byron Hamby Avatar
    Byron Hamby

    Great article.. The current 141 modernisation program has some proposals that are interesting to say the least. There is a goal to increase the number of programs with self testing authority. In my experiences as a DPE many of the pilots from 141 programs were “marginal”. A perfect example.. cross country flight requirements for 141 schools, are often flown Ito the minimum.. 100 nm solo.. Pilots often fly looking at the moving map more than looking outside. Often pilots never develop the skills of actually focusing on an object in the distance. I don’t see any changes to the training that will help reduce the number of fatalities in loss of control accidents. All fundamental basic flaws in training.

    1. warrenwebbjr Avatar
      warrenwebbjr

      I don’t know what your current guidance is from the FAA for checkrides, but one DPE we used to use would always cover the airspeed indicator once or twice at the most critical time (ex: takeoff or landing). We all know about the over-reliance on the modern GPS equipment even though it can fail like the pre-GPS equipment. Is it ever covered? If it were covered, and after word got around, I think you’d have your problem resolved.

      1. David St. George Avatar
        David St. George

        This is a bit of a gray area in the FAA guidance. DPEs are supposed to determine understanding and skills for coping with at least 3 systems failures in A/O IX; this includes pitot/static failure (PA.IX.C.K2C). Whether this is tested in flight without creating an undue hazard is very contextual. I always make sure my *learners* have seen this and can successfully land without ASI.

  2. David St. George Avatar
    David St. George

    I have the same misgivings about an expansion of 141 facilities and privileges as a new “magic bullet” to assure quality and safety (unless accompanied by a significant increase in 141 standards and oversight). Admittedly, some 141 schools are great, but I have experienced applicants from 141 schools that are quite frankly scary to fly with. Closer supervision is necessary for quality assurance.

    I also wonder how the FAA plans to manage their anticipated increase in 141 programs, all requiring increased FAA oversight, with their current struggle to manage a sufficient number of DPEs. It seems a significant increase in the number of inspectors will be necessary.

  3. Terry Pitts Avatar

    I have used Seminole time with people for “complex.” We do multi-Commercial training for ten hours, pause to finish initial Commercial SE, then restart to finish up multi add on.

    When on the way to “250” ME time only costs the incremental amount over flying something else.

    Mastery not minimums is what Gary Reeves advocates.

    Break.

    I did a 182 checkout for a wet CFI once. 300 hours of G1000 time and he’d never seen a prop control. Or a six pack.

    I don’t believe “everything used to be better,” but TAA is not “complex” if that’s all you’ve ever seen!

    And why do we have PDPIC for single engine commercial? An instructor along for a flight a Sport Pilot is allowed to do?! Sheesh!!

  4. Charles McDougal Avatar

    David,
    Thanks for this excellent article. When I was active with SAFE, we had many discussions on these topics. My suggestions to the PHD contingent at the FAA, as well as the “work group” writing the CFI ACS, was to require that the CFI applicant demonstrate competency in teaching every maneuver using an attitude based control concept and when applicable, utilizing specific visual references in this endeavor. I believe doing so would have gone a long way to solving many of the problems you described here.
    Of course that suggestion went predictably nowhere but the bin, and merely raising this issue begged the question; “who among the FAA inspectors and (sorry) DPE’s had the authentic knowledge to understand such a requirement, and to test it effectively? In response to every issue or conflict with ICAO, the FAA has continued to follow its baffling practice of lowering the minimum requirements for testing and the standards of the test.
    Thank you for your persistent work to bring awareness to the need to train and test pilots to a standard of authentic competency.

    1. David St. George Avatar
      David St. George

      Thanks Charlie! We keep trying to maintain and even *raise* the standards. Very please MCA was added to the new CFI ACS with the help of SAFE’s ACS representative, Dr. Donna Wilt 🙏 Now we have an opportunity at the “141 Modernization” to speak up (and of course Doug Stewart attended recently and *vociferously* advocated for keeping PO180 and other commercial maneuvers under attack by the big university programs. Eyes out “attitude-based” maneuvering is a lost (old school) art and yields amazing control and precision; keep fighting Charlie!

  5. […] learner accept the mandate to continuously improve and perfect the landings. Crosswind training is required in 61.93 before cross-country. Short-field accuracy landing is the pinnacle of perfection, and usually not […]

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