Inside the ACS: Interview With FAA's Susan Parson (Part 2)

10:01 AM

By Dan Pimentel,
Airplanista Blog Editor
In part one of this interview with FAA's Susan Parson, she laid the groundwork for how the replacement of the Practical Test Standards (PTS) for private pilot certificate and the instrument rating with the Airman Certification Standards (ACS) has developed. Parson described her role in the re-write this way: "I always tell everybody that I'm the Chief Border Collie for the ACS. My job was to herd everybody in the right direction, and protect the team from all the wolves and crocodiles that could hurt them or the project."
She told us that the process actually started in September 2011 with the first meeting of the Airman Testing Standards and Training Aviation Rulemaking Committee (ARC), and that body had a "lightbulb" moment when everyone in the room realized that developing a separate knowledge test standard (KTS) to go with the PTS was a bad idea.
Let's continue with the interview now, wading through more acronym salad to find out how the story concludes:

AIRPLANISTA: Once the "light bulb" came on, how did the project proceed?
PARSON: The ARC spent the next few months fleshing out the idea of replacing the PTS with the integrated ACS. They saw it as a systematic approach to the airman certification system that would list the standards for what an applicant needs to know, consider, and do to pass both the knowledge and practical tests for a certificate or rating. It would connect specific, appropriate knowledge and risk management elements to specific skills. It would translate special emphasis items and abstract terms like “aeronautical decision-making” into specific behaviors relevant to each task. It would get rid of the “bloat” in the PTS by consolidating repetitive material. They also saw the ACS framework as a tool to help the FAA connect standards to handbooks and test questions.

The ARC submitted its report and recommendations to the FAA in April 2012. To carry out those recommendations, the FAA went to the Aviation Rulemaking Advisory Committee (ARAC). ARAC is a formal standing committee of aviation associations and industry representatives, and it provides a transparent legal framework for industry to provide advice and recommendations to the FAA. The ARAC does work that the FAA assigns through expert working groups.

ARAC established two working groups for the ACS project. The first was the Airman Testing Standards and Training Working Group (ATST WG). It included aviation education and training professionals from all major segments of this community, and its job was to develop drafts for the private pilot certificate, the instrument rating, and the instructor certificate. The FAA twice established public dockets for this group to receive public comments on its drafts. The ATST WG submitted its final report in September 2013.

To take the next steps, the FAA asked ARAC to form the Airman Certification System Working Group (ACS WG), which is chartered through December 2017. This group was assigned to finish the ACS for the private, commercial, ATP, and instructor certificates and the instrument rating. In December 2015, the ACS WG was also assigned to start work on an ACS for the Aircraft Mechanic certificate.

With support from the FAA, the ACS WG did prototype testing of the private pilot airplane ACS in Orlando, and of the instrument rating ACS in both Orlando and Seattle. The results were overwhelmingly positive, and so the FAA and industry jointly decided it was time to let everyone have the benefit of the ACS – starting with the two we tested.

Membership on the ARC and on each of the two ARAC-established working groups has included flight instructors, designated pilot examiners, the aviation academic community, industry advocacy associations, and training and test preparation providers involved with aviation training and testing in 14 CFR Parts 61, 141, 142, and 121 environments. To create an ACS for mechanics, this spring we added five new members with expertise in part 65 and part 147.

It’s important for people to know that those who serve on ARCs and ARAC working groups are volunteers – they serve entirely at their own expense. During the five years we have been working on the ACS, these wonderful and talented people (and their employers) have contributed their time, their talents, and their resources to bringing the ACS from a good idea to a reality.

AIRPLANISTA: What was the precise expertise you brought to the process that made you a valuable contributor on the ACS development team?
PARSON: Part of the overall challenge was managing all the bureaucratic and political issues that arise…but everything I’ve done in my career so far has helped me develop those skills. One of my "Big Rules for the Little Things in Life" is that people and politics are like lift and induced drag – so you have to learn to maximize the former and minimize the latter. I was really able to hone that skill and master the finer points of what I call bureaucratic black magic during my years at the State Department, which is one of the toughest bureaucracies in Washington. 

AIRPLANISTA: Describe one particularly tough challenge the ACS development team faced, and how that challenge/problem was worked out and overcome.
PARSON: In addition to developing the standards documents, the ACS WG has reviewed and provided recommendations for improving the foundational handbooks in the FAA-H series (e.g., Pilot’s Handbook of Aeronautical Knowledge, Airplane Flying Handbook, Risk Management Handbook) and making sure they support the ACS task elements.

One of the biggest, toughest challenges was getting everyone on the same page (so to speak) with one particular chapter in the Airplane Flying Handbook. Pretty much everybody – both industry and FAA – agreed that the current version of AFH Chapter 4 – the so-called “stall/spin” chapter – was grossly inadequate and out of sync with the huge focus on preventing Loss of Control (LOC) accidents. The challenge was getting to agreement on what it actually ought to say. It took about 18 months of drafting, reviewing, (intense) discussion, redrafting, reviewing, etc. to develop the version that will appear in the October 2016 revision of the AFH.

While it was a long and difficult and sometimes very frustrating process, we overcame it with communication, mutual willingness to consider new perspectives, and a commitment to assuming that everybody is acting with positive intent. There are still some differences of opinion, but the October 2016 version will be a great improvement.

AIRPLANISTA: What were some of the main regulations that caused the most discussion on the team? Please be specific, and tell me how these were worked out.
PARSON: We didn’t have to discuss or argue about regulations, because those weren’t on the table. For this group and for this project, the issue was to look at the list of “aeronautical knowledge” topics that the regulations require for a given certificate or rating, translate that topic into specific knowledge, risk management, or skill task elements that are operationally relevant, and integrate them into the right Area of Operation for training and testing.

Although it isn’t out yet, the developing Instructor ACS is one of the Big Discussion areas. The group is very committed to making the Fundamentals of Instructing section something more than an exercise in memorizing abstract theories of instruction. They have also put a huge amount of work into risk management concepts for instructors. That means not just practicing risk management during flight instruction – something every CFI has to do – but also teaching risk management to fledgling pilots. That, along with figuring out how to construct and present the Instructor Task elements, has required a lot of discussion and hard work.

AIRPLANISTA: What was the ultimate goal of the ACS development team, and do you believe that goal was achieved with the final version?
PARSON: The team’s overall goal was (is) to make airman certification training and testing relevant to real-world flying – and all of us believe the ACS achieves that goal. Here’s why...

Everything starts with defining the “right stuff” to be taught and tested. The ACS clearly defines what an applicant must know (aeronautical knowledge), consider (risk management), and do (skill) to pass the knowledge and practical tests for a certificate or rating. It connects knowledge and risk management to specific skills. That helps applicants, instructors, and evaluators understand what the FAA expects in each phase of the certification process, and how it all works together. A very important improvement is translating abstract words like “aeronautical decision-making” and the list of so-called “special emphasis” items into risk management task elements. So the ACS instills the idea that risk management is a continuous process of identification, assessment, and mitigation of task-specific hazards that create risk.

AIRPLANISTA: Do you believe the ACS will have a positive effect on growing general aviation?
PARSON: We didn’t go into the ACS with the goal of growing general aviation, except in the sense of helping to reduce the fatal accident rate through better training. We do think (hope) that eliminating the nonsense in testing – which drove time-wasting nonsense in training – will eliminate certification testing as a disincentive to pursue GA flight training.

You can read Susan Parson's blog here...great stuff.

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