PTS Follow-Up

by Christine Kalakuka

The following article is a follow-up to the author’s Freeflight column which appeared in the May issue of Balloon Life. Editor

In April Balloon Excelsior wrote the FAA questioning provisions of the new Private Pilot Practical Test Standards (PTS), which became effective June 1, 1996. The 3 main concerns were new wording that required: (1) that the Practical Test be conducted in controlled airspace to comply with provisions of the Radio Communications Task; (2) that passengers be carried during the Practical Test to comply with the passenger briefing requirements; and (3) that a total of 18 checklists be used, 16 of which must be carried and "completed" during the flight.

Balloon Excelsior received a letter from Gary Walker, Acting Manager, Operations Support Branch, FAA, Oklahoma City, with the following responses to their questions.

Radio Communications:: "Radio Communications and ATC Light Signals is a task that appears in every practical test standard. For some classes of aircraft, use of radios is a part of every flight. In addition, all pilots should have knowledge of light signals. Our intention for this task relative to balloon and glider pilot certification is primarily from a knowledge standpoint and not a requirement to fly in controlled airspace. As part of the practical test, an applicant should be asked to simulate several radio transmissions and be knowledgeable of radio phraseology and ATC light signals.
Passenger Briefing:: "With the use of the word "passengers" in Area Of Operation II, Preflight Procedures, Task F, Element 3; the words "each passenger" in Area Of Operation IV, Launches and Landings, Task C, Element 4; and the word "passengers" in Task D, Element 5, we expect that the examiner will simply ask the applicant to give a passenger briefing just as they (the applicant) would do if a passenger or passengers were on board."

We now have, in writing, the FAA’s understanding that these Tasks may be simulated. With regard to the excessive checklist requirements, the FAA’s reply, contained in the same letter was not as satisfactory:

Checklists are considered a safety of flight item. Most aircraft manufacturers provide checklists; but in the case of older aircraft, where the checklists may be unavailable, pilot’s (sic) simply write new ones. Checklists can stay with the aircraft, or if they are personal, can stay with the pilot’s flight gear. Checklists can be of any reasonable length. For a balloon pilot, a checklist need not be cumbersome, but can be small enough to fit in a small soft plastic cover that will fit in a jacket, pants, or shirt pocket. Checklists are not meant to be "how-to-fly" lists.

We agree that checklists contribute to safety. Unfortunately, the FAA’s apparent new mandate to emphasize checklists has led them to apply the "completes the appropriate checklist" requirement in a slapdash manner with no consideration of whether or not a checklist is, in fact, appropriate. In some cases where the new PTS requires completion of the appropriate checklist - for example, during a high-wind landing, or launching over an obstacle - use of a checklist could be dangerous, for these are times when the pilot should be flying the balloon, not referring to a piece of paper. Some Tasks, Ascents and Descents, for example, simply do not lend themselves to checklist definition.

We’ve written the FAA again, expressing our concerns with the checklist requirements and asking for clarification. In the meanwhile, we’re trying to create 16 "appropriate" checklists, covering the items that must be completed during the PT, and a separate checklist for emergency procedures. We have a copy of the current Boeing 747 checklist used by a major airline; it has 10 items on it, eight less than the number the FAA considers necessary for a balloon.