Rod Machado, a prolific aviation author and educator, is a voice of reason when it comes to how we can improve aviation safety, and his recent comments in response to an FAA notice on new training standards put a fresh spin on an old problem.

The notice highlights ideas to change the knowledge testing and practical test standards that govern private pilot and instrument rating testing in the U.S. The proposal seeks to create new Airmen Certification Standards (ACS), based on recommendations from the Airman Testing Standards and Training Working Group (ATSTWG). What the working group and the FAA are attempting to do is improve testing and training materials to try to lower the number of fatal general aviation accidents “by incorporating task-specific risk management considerations into each area of operation.”

Machado correctly points out, in his comments on the proposal, that the FAA has provided no quantifiable and measurable metrics for the reduction in accidents, but merely seeks to “safely manage the risks of flight.” With regard to risk management, he doesn’t see an urgent need to make risk assessment a subject of special treatment during the practical test. “Where did we come up with the idea that risk assessment isn’t knowledge and therefore needs to be isolated as its own category in the proposed ACS? This is a very strange idea. Risk assessment is knowledge. The risk assessment associated with a physical skill can be evaluated during the performance of that skill. That’s the purpose of a practical test. Risk assessment associated with aviation concepts (other than physical skills) can be assessed during the knowledge exam.”

In Machado’s opinion, this effort is just another example of what he calls “do-something activities,” an attempt by a frustrated FAA and aviation industry to do something to reduce the accident rate. While the idea is well intentioned, he explains, the likelihood of its having a positive effect is low, and there could be negative effects. “The fact is that isolating risk assessment as its own special distinct category that will be applied to each and every required task in the proposed ACS seems to be a do-something activity of sorts. This activity appears to bloat and obfuscate the practical testing process. If it produces any discernible effect on aviation safety, it will likely be to increase the difficulty and expense for someone to obtain a private pilot certificate, thus resulting in producing fewer pilots.”

The fact that the volume of material associated with the proposed changes is already almost double the number of pages of the private pilot practical test standards is already worrisome. There is no way that training will become more efficient or effective just because the requirements are ever more stringent and complex.

Machado isn’t one to complain without offering a solution, and he suggests that we learn from history. “If you really want to reduce accidents, then follow the recommendations in the 2005/2007 Human Factor Analysis and Classification System (HFACS) study. The HFACS study says: ‘The study demonstrated that the greatest gains in reducing aviation accidents could be achieved by reducing skill-based errors.' The study also indicates that ‘skill-based errors were associated with the largest portion of GA accidents (79.2 percent of the 14,436 GA accidents)....'”

“The HFACS study suggests that we are no longer teaching pilots how to physically fly airplanes. Instead, we’re teaching them how to mimic the behavior of airline pilots in hopes of achieving the low accident rate of commercial aviation. The problem is that nothing about flying big airplanes pertains to flying small ones, while everything about flying small airplanes pertains to flying big ones. Were we to emphasize stick-and-rudder skills during the training and the practical testing process, we would most likely see immediate gains in aviation safety. It’s clear to me that the proposed ACS is a step away from testing an applicant’s stick-and-rudder skills, not a move toward it.”

Machado’s comments are exactly right, and I hope the ATSTWG people take them to heart. But there is a reason, beyond the simple sensibility of what he wrote, why his comments are true. And that is because we have real evidence, beyond the HFACS study.

This evidence comes from the FAA’s application of Special FARs in situations where action was needed to lower accident rates in specific aircraft. With the two training SFARs that are appended to Part 61—SFAR 73 for the Robinson R22 and SFAR 108 for the Mitsubishi MU-2 twin turboprop—accidents dropped dramatically after the regulations went into effect. In the case of the MU-2, there has been just one fatal accident since SFAR 108 went into effect in February 2009. These SFARs mandate that pilots be taught specific skills, and they don’t get into the squishy subject of risk assessment.

Maybe all we need to do is stop wasting time on “do-something” ideas such as rewriting the knowledge and practical test standards and simply refocus on the fundamentals of flying. It is such fundamental skills that were lacking in pilots involved in accidents such as the Colgan Air low-altitude stall and the Air France stall into the ocean. No amount of risk assessment training would have prevented what those pilots did, but a little more time on slow flight at minimum controllable airspeed, reduction of angle of attack to exit a stall and other basic skills might have been a great deal more effective.

(Incidentally, plenty of commenters to the ATSTWG agree with Machado and believe that changes to the practical test standards will have no beneficial effect on the GA accident rate and will make training take longer and cost more. You can add your comment until July 8.)