The FAA has set minimum requirements that pilots must meet in order to legally fly, but meeting those minimums probably arent enough to keep you safe.
A couple of years ago Daniel Webster College established an orientation program for incoming freshmen in which they would be indoctrinated into the ways of college life. One speaker, a professor of Humanities, discussed the virtues of the educated man in days gone by versus the learned man or woman of today. One of his points was that although there was a time when an individual could, in fact, read every book in existence and learn all that educated people should know, those days were long gone. His point was that it is no longer possible to be completely educated, rather, learning must be a continual journey whose end ideally would never come.
I recalled that incident was when I was reflecting on just when I last felt completely proficient flying an airplane. The sad answer was a while ago, which led me to wonder what it would take to once again make me feel as though I was the master of my fate the next time I got into an airplane. The answer to that question became much more difficult to deliver.
That, in turn, caused me to consider that if I, who am fortunate enough to have an occupation that immerses me in aviation every day, find it difficult to keep completely current, how can occasional general aviation pilots be expected to do better? After all, most pilots have real jobs that merely serve to generate money to spend on airplanes. Maybe just as importantly, if the government regulations that set minimum standards arent enough to ensure proficiency, where can pilots look for helpful guidance?
There is, of course, no single answer. As long as the question is raised, one possible answer is that, if legal minimums arent enough, perhaps they should be raised. However few experts would argue that increasing the number of federal legal hoops is the answer to questions of pilot proficiency.
Bill Stevens, Safety Program Manager for Operations at the Boston Area Flight Standards District Office, seemed to hit the nail on the head when he said, We already have programs in existence where we are able to teach pilots a lot of things that will increase their proficiency, but what we cant do is regulate good judgement.
Correlating legal compliance with proficient flying doesnt work, either. John Carson, a statistician for APOAs Air Safety Foundation, says there may be a way to generate a statistic that measures the relationship between proficiency, such as when a pilot gets a Biennial Flight Review, and his or her likelihood of having an accident. But, he warns, Among pilots who do have accidents, I can give you a figure but it doesnt really mean that much because we dont have a comparison among those pilots who have a BFR but dont get involved in an accident.
An alternative to the BFR that also bears consideration is the FAAs Pilot Proficiency Award [Wings] Program. The Wings program includes designated flight segments with a CFI and attendance of several safety seminars. Completion of the program is a legal substitute for a BFR in the FAAs eyes, and may be even more valuable to insurance companies.
The Wings program includes minimum flight segments, as does a BFR. But Wings requires three hours of flight training, while the FARs specify a minimum of one hour for a BFR. In addition, Wings includes three safety seminars, while a BFR requires one hour of ground instruction. Stevens said he believes Wings to be very helpful in terms of increased proficiency.
Most aviation insurance companies give discounts to pilots who have participated in the Wings Program, so there clearly must be value there, he says.
Even so, two years is a long time to rely on proficiency honed over three hours of flying. At the peak of safety is a segment of aviation where accident prevention and avoidance had become a proven reality: the airlines.
Are there lessons there for the general aviation pilot or is it a simple matter that more money makes it work better? Though it may well be a little of both, the consistently strong safety record among the worlds major air carriers shouldnt be ignored in our own search for answers.
Airline training is, by general aviation standards, as grueling as it is continuous. Couple that with the fact that those who fly heavies get far more hours behind a yoke than most general aviation pilots and its clear that, from a training standpoint, few comparisons can be made. But there are some lessons to be found.
One valuable lesson I learned occurred by way of a friend and neighbor who was a Boeing 737 captain and a check airman for USAir while I was a controller at Pittsburgh International Airport. He was a proud new Mooney owner and called me to ask how to get into the Pittsburgh TCA (now called Class B airspace). His questions: What frequency should he use? Where and who was he supposed to call? What code should he squawk?
Initially, I was incredulous. What kind of an airline pilot doesnt know the answers to those simple questions? I asked myself. After a little more thought I realized how knee-jerk that first reaction was. I concluded that one could be a very good airline pilot indeed and not know the answers to those questions.
With probably more regulations to deal with in a month than I worry about in a year of flying and with more complexity in an airplane to learn about than I have ever experienced, my neighbor had only enough time to master that which he used. Jim had done no VFR flying for a number of years and when it came time to getting up to speed in his own airplane he was smart enough to realize what he didnt know and wise enough to ask for help from someone who did.
The lesson is that you probably cant know everything about flying. That means you must establish priorities based upon what is most important to know for the type of flying you will be doing in the foreseeable future. Only then can you figure out what questions need to be asked and who the right people are to supply the answers.
Another conclusion that becomes crystal clear when comparing a general aviation pilot to one of those heavy metal pilots is that, for most GA pilots, making a comparison to airline pilots in an effort to improve safety is a waste of time.
The average airliner has at least 10,000 hours of combined experience sitting in the cockpit seats. Those pilots are flying a multi-million dollar aircraft that has been maintained by a team of equally experienced experts, only after the plane has been dispatched by other experts. Every step of the way, those professionals have had to certify airworthiness and safety has been given all possible regard. Not so incidentally, the money used to pay for this level of safety has come from somewhere other than directly out of the pockets of any of the aforementioned players. In some ways it seems as though the average piston pilot just doesnt stand a chance.
In fact, general aviation pilots dont stand a chance of replicating the low risk that airlines have developed despite the fact that they fly in all weather under tight schedules. Only by reducing the risk factors can general aviation pilots increase the level of safety a reasonable cost. This will only happen if – and this is a big if – pilots can honestly assess the risks involved in a specific flight and make an equally honest evaluation of the skills they possess to mitigate those risks.
Rules and Obligations
The FAA rightfully acknowledges that it cannot regulate good judgement, but that doesnt mean pilots cant learn it. One of the mainstays of Daniel Websters collegiate aviation program is that, through a variety of deliberately planned flight and ground experiences, flight students can learn good judgement at a pace that is greatly accelerated. That is, they can learn in four years and 200 to 300 hours of flying much of what, if left to their own devices, would take significantly longer to learn.
For those who are not still in college, fear not. The FAAs regulatory requirements for maintaining proficiency can be a route to learning many of those same lessons, but only if approached from a students perspective. One example is the BFR. Depending on the pilot getting the review and the CFI offering it, the BFR can be an opportunity to improve skills and enhance judgement or it can be a waste of time. The FAA has granted the latitude for it to become either. The pilot being reviewed gets to decide if he or she will follow the letter or the intent of the regulation.
FAR 61.56 simply states that, …a flight review consists of a minimum of 1 hour of flight training and 1 hour of ground training. The review must include: (1) A review of the current general operating and flight rules of part 91 of this chapter; and (2) A review of those maneuvers and procedures that, at the discretion of the person giving the review, are necessary for the pilot to demonstrate the safe exercise of the privileges of the pilot certificate.
Economics, expedience or attitude may lead a pilot needing a BFR to find the most lenient instructor available and the most economical airplane suitable. Do that and the Feds will be satisfied. Good judgement, on the other hand, suggests that a learning opportunity presented will only be meaningful if something new is available to be learned.
For example, if you regularly fly a multi-engine airplane, you can use the BFR to practice those rusty skills you may be hesitant to practice on your own. You can also take the BFR in a Cessna 150 and probably have little difficulty keeping up with the tasks required.
Either way, both you and the instructor giving the review will be legal, but when its all over the instructor wont have to worry about whether he or she is capable of handling the loss of one engine just after takeoff in IFR conditions. In addition, if you still have questions about your proficiency even after completing a BFR from a qualified instructor in the airplane you regularly fly, good judgment says you have more work to do, regardless of the economic or legal implications.
One of the problems is that most people will tend to seek out circumstances that ensure their success in any test situation. Therein lies the need to approach a BFR with the right attitude. The question you have to ask is what constitutes success? If meeting the FAAs minimum requirements is all you want, then success means to find the most lenient instructor around (or a friend with a CFI rating) to pencil whip your log book and send you on your way for another two years. On the other hand, if becoming a safer pilot is the goal, then success means nothing less than taking full advantage of a learning opportunity.
Remember that a planned exercise in a controlled flight environment can become a valuable learning experience. The same event occurring unexpectedly in an unsupervised situation could well become an accident. The BFR is an excellent opportunity for every pilot to enjoy a valuable learning experience.
Clouding the Issue
Probably nowhere is the distinction between being current and being proficient more critical than with respect to IFR operations. Again a look at airline operations can shed valuable light on why the safety record for air carrier flights is better than that for general aviation operations. Even though airline pilots are, for the most part, more experienced both in their number of total hours and in their recency of experience in IFR operations than are general aviation pilots, they actually have less discretion when it comes to attempting an instrument approach when the weather is at or below minimums.
Whereas the general aviation pilot may legally fly any approach to minimums, regardless of the reported weather at the airport, a flight crew operating under FAR Part 121 may not even attempt the approach if reported conditions are below legal minimums. In addition, most airlines restrict newly appointed captains or those transitioning to new aircraft to higher minimums for a specified period of time. That lets the pilot become more seasoned and more comfortable with the new airplane or new responsibilities.
For the instrument-rated general aviation pilot, there is a significant degree of latitude in determining whether IFR operations are legal. In fulfilling the recent flight experience requirement, for example, its up to the pilot to log approaches, but whos to say when an instrument approach is in weather low enough to make it useful should conditions on the next flight be at minimums?
Likewise, the instrument proficiency check offers the pilot and instructor a significant degree of latitude. The FAA, for example, stipulates only that the IPC consist of a representative number of tasks required by the instrument rating practical test. Again the FAA rightly leaves room for judgment. For guidance, an individual pilot would do well to abide by the stricter definition of proficient as found in the dictionary: highly competent; skilled; an expert.
Additionally, think about how often you alter your own minimums based upon your recent experience in IFR operations, total experience in the air or recent experience in type. The accident record would indicate that most pilots dont make such self-assessments often enough.
In the final analysis, it seems evident that the FAA has done its part to allow pilots to use good judgment instead of specific regulations when exercising many of the privileges of their ratings. The question pilots have to ask themselves is, Are we living up to our part of the bargain when we exercise those privileges and if not, what can we do to improve?
Every pilot is presented with the opportunity to improve his or her skills and judgment. The BFR and the IPC represent the FAAs attempt at laying the foundation upon which pilots can build. The Wings program is a chance to add valuable blocks to that foundation. Its up to you whether you take the time to build a brick house or rely on a straw hut and the hope of no wind.
When it comes to assessing your safety as a pilot, the most important factor is to honestly and critically evaluate your abilities and skills in light of the type of flying you are currently pursuing. There simply is no quick, easy fix that can adequately replace continued learning.
What is safe on any given day isnt measured by an immovable bottom line but rather a series of highly fluid conditions that vary significantly day by day and occasionally moment by moment. Thoughtful analysis of the many variables is the place to start making that assessment, but paying attention to that feeling in your gut may well be the place to evaluate the assessment. How safe is legal is the irrelevant question. How safe am I is the one that counts.
-by Milovan S. Brenlove
Milovan S. Brenlove is an Assistant Professor of Aviation at Daniel Webster College, a flight instructor and a former air traffic controller.