We have worked for years with the Federal Aviation Administration (for free, with no charges for our time, and paying all our own expenses to attend meetings), to improve regulations for balloonists, to rid the written (knowledge) tests of inappropriate questions, to help re-write the Practical Test Standards, and have rarely criticized them publicly. However, the new Private Pilot Practical Test Standards (PTS) which was just issued and becomes law in June 1996, has some serious flaws.
The Practical Test is the final oral and flying test a student must pass to obtain a pilot certificate. The applicant must comply and the Designated Pilot Examiner (DPE) must certify the pilot successfully completes all tasks during the test.
The new PTS will make the test harder to administer, harder to pass, and, definitely, more costly.
We understand from talking with FAA people who worked on this PTS that they were under orders to complete it by a certain time, and that certain features of the new PTS were demanded by the National Transportation Safety Board (NTSB), the federal agency that investigates transportation accidents. We have never been convinced that the NTSB is familiar enough with ballooning to determine the true cause of balloon accidents, or that they are savvy enough to make a genuine correlation between flight training and reduction of accidents.
The most glaring, impractical feature of the new PTS is reference to 18 checklists; at least 16 must be carried and completed during the test, and 2 must be followed.
Although the FAA is stressing the use of checklists, nowhere do they provide a definition of checklist, or how a checklist should be used. There is no definition of checklist in FAR Part 1 (Definitions and Abbreviations), nor in the PTS itself.
Checklists are valuable tools, and we believe in their effectiveness. We use two detailed checklists in our school, but checklists must not interfere with flying the balloon. Checklists can be a terrible distraction when a certificate applicant must "complete" 16 checklists, and "follow" 2 checklists. We’re not quite sure what the difference is between "complete" and "follow", nor were FAA Inspectors we consulted. However, there seems to be an unwritten understanding that a physical copy of the checklists must be carried in the balloon and referred to during the flight.
What is proper use of a checklist? Should it be a "to-do" list, to be referred to while operations are actually being conducted? Should it be a list that is checked-off after an operation is complete? Flying a balloon is a single-pilot operation where the pilot is standing up, outdoors, in an aircraft that will not fly straight and level when unattended. Unlike airplanes, where the pilot is sitting surrounded by places to put things, and has a lap to place a checklist, a balloon pilot must find a place to keep these many checklists and some way to refer to them.
The statement "Completes the appropriate checklist" is required for 16 separate Tasks in the PTS (I’ve starred those we think are appropriate):
"Utilizes all appropriate checklists" is required for Basket/Gondola Management. "Appropriate checklists" are not defined. Does this mean the pilot applicant must "check" all 16 lists? If so, for what? Perhaps to make sure they are on board. Where are the pilot applicants to keep/find all these checklists?
Balloons are single-pilot aircraft. It is dangerous to bury the pilot in 18 pieces of paper. One of the first safety rules a pilot learns is the three most important rules, which are FLY THE AIRCRAFT, FLY THE AIRCRAFT, FLY THE AIRCRAFT. It seems as if the FAA is saying REFER TO A CHECKLIST, REFER TO A CHECKLIST, REFER TO A CHECKLIST. Flying the balloon is much safer than referring to a checklist.
The FAA continues to label water landings an emergency even though they have been advised many times that sometimes and in some areas a water landing is the most appropriate landing and is not an emergency. Balloons are amphibious.
One Task, Normal Landing, requires the applicant to stabilize the balloon "prior to passengers exiting." We presume this is a case of sloppy writing, not a requirement that passengers (plural) be carried on board during the Practical Test, but the intention should be clarified. As written, a minimum of two passengers must be carried in the balloon with the approval of the applicant, the examiner, and the owner/operator of the balloon. What if the applicant supplies a balloon that won’t carry 4 people?
A new task, entitled "Radio Communications and ATC Light Signals," requiring use of VHF radio and interpretation of ATC light signals, has been added to the Private PTS. There is no provision for simulation of this task, therefore, unless we can obtain some relief from this requirement, all Private Practical Tests will have to be conducted in controlled airspace (i.e., at an airport with a tower) beginning June 1, 1996. We doubt if this is what the writers of the PTS intended, as the FAA knows most balloonists do not fly in controlled airspace, however, the way this task is written, requiring transmittal of information, with acknowledgement and compliance with instructions received, it can only be accomplished in controlled airspace. This provision will certainly increase the cost of a Private Practical Test and place balloons in congested airspace. How many small, controlled airports have operating towers that are open at DAWN? Most rural airports are uncontrolled, with no tower; some have towers that don’t open until seven or eight o’clock in the morning.
For now, it looks as if it might be more practical, easier, and cheaper just to go directly for a Commercial certificate, which doesn’t require 18 checklists or a PT in controlled airspace. Current regulation permits bypassing the Private PT as long as other requirements are met.
There are several other questionable provisions of the new PTS, but these are the most disturbing.
In the Foreword to the new PTS, William J. White, Deputy Director, Flight Standards Service, Federal Aviation Administration, says: "FAA Inspectors and designated pilot examiners shall (meaning mandatory, my underlining) conduct practical tests in compliance with these standards." Elsewhere in the Introduction is the statement: "Flight instructors are expected to use this book when preparing applicants for practical tests. Private pilot applicants shall be evaluated in ALL TASKS included in the AREAS OF OPERATION..." Examiners have little discretion when conducting a Practical Test, therefore Instructors must prepare their students for these new requirements.
Remember, all you Examiners, Instructors, and Students, the Practical Test Standards, which are written without the assistance or input of the general flying public, are Federal Law. If you like this new PT, do nothing. If you don’t like it, exercise your prerogative as a citizen and write the Federal Aviation Administration at Flight Standards Service, AFS-630, P. O. Box 25082, Oklahoma City, OK 73125. We’re writing our letters now.