Author: David St. George

Sorry, I know an article on the FAA regs can be *quick death* in a popularity contest but please stay with me, I’ll keep this brief and provide good reasons to pay attention. For professionals in aviation this one simple legal requirement is both infamous (but as I hope to show) essential.

CFR 91.103 is the much maligned “all available information” reg we all laugh at initially. No one has “all available information” almost by definition so most people chuckle and immediately move on. But if you read this reg. more carefully, it provides really great guidance. It is the one reg. I insist all my students know from day one for basic safety.

91.103   Preflight action.

Each pilot in command shall, before beginning a flight, become familiar with all available information concerning that flight. This information must include—

(a) For a flight under IFR or a flight not in the vicinity of an airport, weather reports and forecasts, fuel requirements, alternatives available if the planned flight cannot be completed, and any known traffic delays of which the pilot in command has been advised by ATC;

(b) For any flight, runway lengths at airports of intended use, and the following takeoff and landing distance information:

Please look at (b) first: every flight requires basic performance data, your take-off and landing distances and the length of the runway. Why? Because this is probably one of the most popular ways to hurt yourself in an aircraft! Complacency develops pretty quickly because it “always works” and aircraft are well designed to take offs by themselves (if everything goes right) As a result this phase of flight is statistically the most toxic! On flight tests if an applicant does not know the length of the runway or take-off data this is a non-starter! As professional CFIs we must embed respect for both gathering essential performance data and maintaining an attitude of “ready for anything” on each and every take off. This has to start with lesson #1 and continue on every future operation.

The other part (a) above “flight not in the vicinity of an airport” requires that if we are leaving the pattern, we need to gather information on weather, fuel, delays and alternates. Again, anyone familiar with aviation safety can recognize these requirements as the most popular ways to end up in a cornfield instead of a runway. Surprise weather enroute (unplanned IFR) is equally toxic to both VFR and IFR pilots if they do not expect it. Checking weather and fuel are essential (and legally required) if you are leaving the pattern again because they are the common “killers.”

At our flying club the bottom of the dispatch sheet has a “fill in the blank” for all these 91.103 requirements and a PIC sign-off (just like the military). You check and accept the aircraft as inspected and verify current flight conditions as well as personal readiness. A little awareness before committing to the skies goes a long way toward improving safety!

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As an aircraft accident investigator, I have seen pilots come to grief due to fundamental IFR flying mistakes that occurred within a short time of passing an Instrument Proficiency Check (IPC). The IPC is supposed to be a comprehensive review of all of the Practical Test Standard (PTS) tasks. So how could these pilots perform so inadequately so soon after the accident pilot demonstrated PTS proficiency to an instructor?

The answer is, maybe they didn’t, really. In some cases, reviewing logbooks as part of the investigation showed that the IPC omitted required material from the PTS checklist. In other accident investigations, 21st century technology tells the tale. Crosschecking the accident pilot’s logbook with a recovered GPS navigator datacard or with ATC records (via FlightAware) reveals that instrument approaches logged during the IPC (or as part of the pilot’s currency requirements) were not actually performed. Where does that leave the CFI who gave the endorsement that fell short of the PTS standards? And for pilots who falsify logbook entries, how does it them?

As a CFII, I have seen my share of flight review and IPC candidates. When a pilot calls to schedule an appointment, I ask about flying history, including instrument currency and proficiency. Occasionally, pilots will tell me they are proficient but not current. On further questioning, they admit to not having flown any instrument time in well over a year. Yet they still believe they are proficient. There certainly is  a mismatch between their skill level and their belief system. This is dangerous.

When put to the task under the hood it is obvious that their instrument skills are very rusty from disuse and would be dangerous in actual IMC. Some are put off when I decline to endorse them for an IPC. I explain that they must meet all of the PTS requirements set for their level of certificate.

When pilots call me about regaining instrument currency after a lapse in IFR flying, I explain that they will not likely pass an IPC on their first go. I go over the differences between currency and proficiency. Since I have adopted that proactive policy I have not had an unhappy client after the flight, whether or not they earned an IPC endorsement.

Instrument proficiency is a perishable skill that needs constant practice and refresher. If you do not practice instrument flying skills regularly you may end up in a situation where you cannot hand fly the aircraft while in instrument conditions. This could be deadly. According to AOPA survey data, the average pilot is flying 60 hours a year. This amount of flying is likely not enough to maintain your instrument skills, particularly if you are using the autopilot for a majority of that flight time. Currency and proficiency are critical to maintaining a pilot’s skills – especially instrument flying skills. Instructors who grant IPCs for pilots who are not proficient to the level of test standards are placing their client – and their own careers – at risk. For example, I am the President of the Lancair Owners and Builders Association (LOBO). I recently had a conversation with Nationair, an aviation insurance broker and our insurance partner, and we realized that some of our members may not be getting all of the training and documentation required by the carrier. There are only a handful of insurance underwriters that insure the Lancair IVP and Evolution, and 2008 was a bad year for accidents in Lancairs. Some insurance companies were not renewing policies, so the following year we drafted the LOBO training program and convinced the industry to underwrite Lancair owners who participated in this training.

Believe me, this was not an easy task. Unfortunately it has come to our attention that a few individuals have told their insurance company they have completed the training when in fact they have not. If you take LOBO training and complete all of the training you will be issued a LOBO training certificate that you can forward to your insurance company as proof of training. Without that certificate, your insurance coverage may be compromised.

With advances in computerized avionics and the easy availability of historic air traffic control records, pilots and instructors are well advised to maintain scrupulous standards when it comes to currency and IPC performance.

Please “follow” our blog to receive notification of new articles and please write us a comment if you see a problem or want to contribute. We need more articles on aviation excellence or flight safety. There are many highly qualified SAFE members out there! If you are not yet a member, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment worthwhile fun (How about $66 off your annual ForeFlight subscription?)

You probably detect a similarity between this title and the alcohol awareness program “Mother’s Against Drunk Driving”. If you are younger than me, you may not even be aware of this program’s existence since “sober driving” is now the accepted cultural norm. Now we use designated drivers and “friends don’t let friends drive drunk!” Unfortunately this was not the case in my teenage years when drunk driving was almost a locally accepted sport. MADD was founded on September 5, 1980, in California by Candace Lightner after her 13-year-old daughter was killed by a drunk driver. This highly commendable movement ultimately created such a new awareness that drunk driving is culturally unacceptable and morally reprehensible. In my opinion, a similar awakening would be a great improvement in aviation safety if we could similarly curtail our highly prized “freedom to do dumb things” and leverage a new aviation safety norm.

We all have seen other pilots do amazingly stupid things in planes (as we also have certainly done some dumb things ourselves). When someone hurts or kills themselves in a plane, it often is not a “surprise” but an “inevitable result” sometimes after years of drifting into increasingly unsafe practices. Though we in aviation all have a wonderful respect for personal freedom and the privacy,  it often prevents us from intervening and saying something even when safety is clearly compromised and the results are predictable and preventable. I highly prize and defend personal freedom, as you probably do, but I think here it is time to make a change in what is “acceptable.” We all have the potential to make bad decisions and should appreciate a “nudge” toward safety. Even the famous aerobatic performer Sean Tucker publicly shares how Bob Hoover approached him after watching one of his early airshows, put an arm around him and advised a little more safety margin in his routine. Sean says this was a necessary and ultimately welcome intervention that later saved his life after an unexpected mechanical difficulty.

So if you see a clearly unsafe action, I would ask you intervene and compassionately suggest a safer course of action. How about we tell our fellow aviator (in a careful, gentle way) we would like to have them around as a friend and point out  that their current trajectory is not conducive to survival. I believe friends should not allow friends to do unsafe things in aircraft…we can all can benefit from this caring intervention. We can create a safety culture and watch each others’ backs (See “Brother’s Keeper” in Air Facts)

And better yet, if you are proactively safety minded, I would encourage you to arrange a group of like-minded friends to voluntarily join in a “safety net.” This prearranged group of pilots who empower their buddies to oversee their operations to assure safer operations and “no bad days”. In Part 135 charter flying, nothing moves without the sign-off from the “director of operations.” This required oversight and additional set of eyes assures that all the pieces are in place and we have managed all the risks before dispatch. The amazing safety record of charter flying is the enviable result of this oversight. Of course, for GA we certainly do not need this level of regulation and formality. But what if you have an agreed group of flying friends who are available to cross check each other. If an operation is edgy you call for a second opinion (or perhaps a co-pilot to help) and mitigate the risk. Create your own “safety culture.”

If we build voluntary safety nets to proactively address risk and empower our fellow aviators to cross-check and “nudge” fellow aviators toward safer operations, I think we can move the needle on aviation safety. Freedom is precious, but too much “freedom” (as in the freedom to hurt or kill yourself in a plane) is not worthy of protecting (at least in my opinion). Our industry suffers a continuous black eye from the very public loss of pilots and innocent lives in repeatable, predictable accidents. As a flight school operator I hear from too many in the door how unsafe “little planes” are. We can fix this!

Please “follow” our blog to receive notification of new articles and please write us a comment if you see a problem or want to contribute. We need more articles on aviation excellence or flight safety. There are many highly qualified SAFE members out there! If you are not yet a member, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment worthwhile fun (How about $66 off your annual ForeFlight subscription?)

This is an urgent notice to all pilots currently in training to complete your knowledge test soon.  On Jun 13th the new ACS (Airman Certification Standard) knowledge tests go live on the computer testing sites for private, commercial and instructor level certificates. If you have trained with the old knowledge testing bank of questions, you should try to complete your FAA knowledge examination before that date! The new questions will be entirely unique and will also not be available before the test to study (or memorize).

Ultimately, we all know this is the correct method of testing true understanding of a subject at the correlative level. Ideally, you should know the subject matter in it’s entirety and the questions should accurately reflect your understanding with a grade point reference. The pilot training process was broken and that is what the ACS is designed to repair.

Not only was the historic rote memorization game a broken system of evaluation, the material it tested was hopelessly outdated. There will be no more non-movable-card ADF questions and more focus on GPS and relevant information. The FAA has provided a list of now deleted subject areas here. Moving forward you will have to know your material thoroughly to test well, memorization at a rote level will not be available.

There is whole pilot test prep industry built around the current questions and the preparation of pilot test applicants.  This will be in turmoil until the new testing system becomes a known challenge. The FAA provides sample test questions on their ACS website and the private test sample is here. Best of luck!

“Follow” our blog to receive notification of new articles and write us a comment please if you see a problem or want to contribute. Write us also if you have an article to contribute on aviation excellence or flight safety. Most importantly, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment worthwhile fun ($66 off annually on your ForeFlight subscription anyone?)

Please commit to an attitude of aviation safety by taking Tony Kern’s challenge and signing his Aviation Professionalism Pledge. No matter what area or level of aviation you are involved with; piloting an Aeronca 7AC or a Gulfstream G4, maintenance, dispatch or controlling aircraft, please join us and sign this pledge. We need to create an industry awareness that professionalism at every level matters! By handling your aviation duties in a professional, disciplined manner you will enhance your safety and greatly benefit our whole industry! Signing and posting your commitment (an attractive pdf certificate) you will help spread this message and push this vital issue into daily awareness. Safety requires discipline and daily commitment to excellence from all of us.

Dr. Tony Kern is an very compelling author that any committed pilot will appreciate reading. His Flight Discipline and Rogue Pilot and  are already classics.

He runs a private consulting firm Convergent Performance that provides training and products to enhance aviation safety and increase pilot professionalism. A sample of his Pilot Reliability Certification training (very good and FREE) is available here:

“Follow” our blog to receive notification of new articles and write us a comment please if you see a problem or want to contribute. Write us also if you have an article to contribute on aviation excellence or flight safety. Most importantly, please Join SAFE and support our mission of generating aviation excellence in teaching and flying. Our amazing member benefits alone make this commitment painless and fun.

Training time credited by the FAA for flight simulation devices is a moving target caught in a web of regulatory confusion. Even the names and levels have been changed continuously as this process has evolved. Finally, the new rule will be published today April 12th, taking effect on May 12th with a strong move in the right direction. The FAA has restored the 10 hours of credit for BATDs (Basic Aviation Training Devices) and 20 hours for AATDs (Advanced) previously permitted by manufacturer LOAs. Time with a professional educator on even a modestly priced machine can provide a wide variety of challenges unavailable in flight with much greater efficiency, economy and safety. SAFE has advocated continuously for greater “sim” time credit.

Since the 1970s, the FAA has gradually expanded the use of various forms of flight simulation for training. The venerable ATC-610 with realistic “steam gauge instruments” was a mainstay for training all kinds of approaches. Computer based training devices have dramatically expanded the realism and also the utility of these devices with companies like Mindstar even networking devices into a virtual environment (demonstrated at the Pilot Proficiency Center at Oshkosh last year). The realism of the new hardware  is exceptional with motion incorporated in models from Redbird, Frasca and many other progressive manufacturers. SAFE has led the charge for approval of increased simulation credit and we are proud our proposal to the FAA is quoted extensively in the current NPRM. Flight simulation provides a huge opportunity for aviation educators and a superior, less expensive, training environment for clients at all courses and levels. For both initial and recurrent flight training, increased FAA credit for simulation is a huge win.

Incidentally, the requirement for a “view limiting device” was thankfully dropped in the most recent rule (can’t see the ground anyway!) The FAA NPRM again mentioned helpful input from SAFE. Also, per 61.51 (g)4 you do need an “authorized instructor” (we presume that would be a CFII) to observe and sign your logbook to log legal training time or maintain currency. There was lots of confusing interpretations circulating but the recent legal letter of interpretation makes this abundantly clear.

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Since the new FAA rule, as of April 1st, 2016 all new pilots now have to apply for their student pilot certificates through IACRA or on a paper 8710-1 (not encouraged). It helps to repeat after me “IACRA is my friend” because a positive attitude helps immensely when navigating this website for the first time. All DPEs (and many FAA Inspectors) initially struggled with this process but it works amazingly well once you understand the logic. You have probably worked this site recommending pilot applicants, this is a similar process. There is an actual necessity for the complexity when you consider how many diverse certificates and ratings it needs to produce. The site requires everyone to log in as a “recommending instructor” to be a validator. The pdf manual for IACRA is here. The help desk number is now (844)322-6948.

First, remember you (CFI, DPE, ACR) are the validator of this applicant’s identity and ability to read, speak, write and understand English. The FAA guidance is from the 61.65H “In accordance with §61.193(b), before processing an application for a student pilot certificate, the authorized individual must ensure the applicant meets the eligibility requirements of § 61.83 as well as verify the applicant’s identity. The authorized individual should use AC 60-28 and the ICAO Web site to prepare for the assessment. (speaks English)”  And yes, you of course need to meet face-to-face; a virtual arrangement (sharing login/password) is not acceptable!

Every “validator” or agent will login for this process with the role of “recommending instructor” (as DPE I have done many glider and sport pilots with that role but that is gone). Make sure to advise your applicant before the meeting they  will need a valid proof of identity: an unexpired government ID with a photo including a printed expiration date. For young people without a license or passport “legal gov’t ID” can also be a “Sheriff’s ID” so get that process started early. Make sure you have a fairly new web browser (without a pop-up blocker activated) and you have a pdf reader installed on your computer. You have to certify that your applicant can adequately speak, read, write, understand the English language also per AC 20-28.

This IACRA process begins with your applicant. They need to access the IARA website and establish a login and password and obtain their FTN (Federal Tracking Number). The new 61.65H is a little misleading here.

Your student will now log out and then back into IACRA with this unique FTN and apply for their student pilot certificate. This is simple with 6 fields to complete.

They are applying for a “pilot certificate” and the selection should be “student.” Like gliders and sport, no medical is needed here. The medical travels separately and could be acquired later (before solo obviously) according to the help desk. Here are some FAQs from the FAA guidance.

Once all six tabs in the application process are green, click “review”. This button should pop up a pdf of the application (depending on your internet connection this might require some waiting). Make sure you do not have a pop-up blocker set in your browser. This “review” step is required first before “submit” to make that button active. Once the applicant has reviewed the application (opened the pdf) close the document at the top of the pdf and they click “submit.” Once this is complete it should be available on-line for the CFI , DPE or ACR to retrieve and validate.  All validators for a student pilot certificate will enter IACRA in the role of “recommending instructor.”

So now finally it’s the CFI’s turn to login. You will need to meet with your student here since you validate their identity and command of English for this certification. This process cannot be performed remotely (do not share login/password). ON the IACRA site, put in your (CFI) username and password and accept the “terms of service” in the role of “recommending instructor.”

When the page loads you will enter the student’s FTN in the box and it should bring up their application for action. There should be a pull-down with several options here. This will open a page with a list of hyperlinked actions you need to complete in order. First is the verification of identification. You must enter the data from the approved government ID accurately…check it twice!

Next, there will be a link for the applicant to now login again to accept the PBR then “review” first, then “sign” their application (in each case open then “close” the pdf with the button on the top). The “signature” is a blue hyperlink that will center on the pdf and only requires a mouse click. If this does not appear, check for a pop-up blocker or suitable pdf reader installed on the computer. This can be slow depending on your internet connection. Once the application is “signed”, close this at the top of the document and the student’s part is complete.

As the final step, the CFI logs back in (with your CFI login/password) and again enters the student’s FTN as before. Now you should be able to complete the certification process with a “review” and “sign”. Both are pop-up pdfs and you might again need to wait for them to load depending on the speed of your connection.

There is lots of discussion about which browser to use for the IACRA process but most webkit versions work fine. My favorite, that seems to work on Mac or PC, is latest Firefox Browser. Remember in every step you will always have to “review” before you “sign” or the field will be gray and inoperative. Check your browser for a “pop-up blocker” or the pdfs will not load. Take your time and remember to always scroll to the bottom of the page for the action buttons…be patient and good luck!

Personally, I would copy the final result with the date so you can track the progress on the application. There are many guesses on how long the plastic student pilot certificate will take coming from the FAA. You can always look up the date the gov. is currently working on [here]

Let me know if you discover snags in this description and I will update this so we create a clean and usable document for all CFIs and move this process forward. I have now put many students through this process and it works if you are methodical (and patient)…good luck. If you have a problem, please write a comment and we can all learn something. Thanks…I hope this helps.