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140624 ACS FAQs vFR

Aviation Rulemaking Advisory Committee

Airman Certification System Working Group

FREQUENTLY ASKED QUESTIONS

What is the ACS project all about?

The goal of this project is to improve airman training and testing by implementing an integrated, 

holistic system that clearly aligns testing with certification standards and guidance.

What is the ATST WG? How does it relate to the ARC?

ARC refers to the Airman Testing Standards and Training Aviation Rulemaking Committee, 

which the FAA chartered in September 2011 to make recommendations for more effective 

training and testing. The ARC submitted its report and nine recommendations to the FAA on 

April 13, 2012.

To benefit from industry expertise in implementing the ARC recommendations, in August 2012 

the FAA turned to the Aviation Rulemaking Advisory Committee (ARAC). ARAC, a formal 

standing committee of aviation associations and industry, assigned this work to a newly-formed 

Airman Testing Standards and Training Working Group (ATST WG) consisting of aviation 

education and training professionals from all major segments of this community. 

Who are these people? What expertise do they have?

When the FAA asked the industry-comprised Aviation Rulemaking Advisory Committee (ARAC) 

to accept this project, the agency stipulated that the Airman Testing Standards and Training 

Working Group should be:

(C)omprised of aviation professionals with experience and expertise in airman training and 

testing, and technical experts having an interest in the assigned task. The FAA would like a wide 

range of members to ensure that all aspects of airman testing and training, including best 

practices, are considered in the development of its recommendations.

In response to the Federal Register notice published on September 12, 2012[77 FR 56251], a 

number of individuals and organizations contacted the FAA to request participation on the ATST 

WG. The FAA selected its membership to include aviation professionals who could collectively 

represent all major sectors of the industry. These include 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 Part 61, 141, 

147, and 121 environments. To help ensure that the FAA has a full understanding of the ATST 

WG’s work and the rationale for its recommendations, the FAA also assigned subject matter 

experts from a number of its policy divisions to attend ATST WG meetings. 
Aviation Rulemaking Advisory Committee 

Airman Certification System Working Group

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What is the problem you’re trying to solve? What’s wrong with the tests we have now? 

To many stakeholders, FAA knowledge testing is the most deeply flawed part of the airman 

certification system. It matters because the knowledge test is an important component of the 

airman certification process. It measures an applicant’s understanding of the rules, regulations, 

and knowledge areas required to receive an FAA airman certificate.

For the flight proficiency (skills) part of the airman certification process, the FAA developed the 

Practical Test Standards (PTS) to define acceptable performance of the required skills. There is 

currently no such guidance for the knowledge test, which creates problems familiar to anyone 

who has ever taken an FAA knowledge test. These include questions that are overly broad, 

trivial, outdated, and sometimes irrelevant. Test questions that require multiple interpolations to 

calculate takeoff, landing, and density altitude to the foot imply a level of precision that, 

ironically, is grossly inaccurate in terms of safety and reality. 

Moreover, the knowledge exam is not a reflection of a typical ground training program. 

Consequently, applicants who have demonstrated knowledge and mastery in an approved flight 

and ground school curriculum must still conduct a comprehensive “test prep” to pass the 

knowledge test. It is difficult for instructors to provide the required remedial training for missed 

knowledge, and difficult for examiners to accurately re-test the missed knowledge. As a result, 

the knowledge exam is disconnected from both training and the practical test. For these reasons, 

many regard the knowledge test as a rote memorization exercise that has no real value for 

aviation safety education and training.

If there are problems with the knowledge test, why can’t you just fix those and leave the 

rest alone?

In September 2011, the FAA convened a group of industry experts to recommend ways to “fix 

testing.” This group – the Airman Testing Standards and Training Aviation Rulemaking 

Committee (ARC) – quickly determined that there is no way to fix the knowledge test in a 

meaningful and sustainable way without having a knowledge test standard akin to the PTS. 

The ARC briefly considered proposing a “Knowledge Test Standards” (KTS) document that 

would be the knowledge test companion to the skill-focused PTS. After much discussion, the ARC 

discarded this approach as unworkable. ARC members feared that creation of separate KTS 

documents could result in divergence between the KTS and the PTS. It would burden 

stakeholders with an additional set of documents, and require a greater expenditure of shrinking 

FAA resources to develop, deploy, and maintain a full range of KTS documents.

The ARC ultimately concluded that aviation safety and stakeholder needs, including the core 

desire for a more relevant FAA knowledge test, would be best served by integrating task-specific 

aeronautical knowledge into the appropriate Area of Operation in the existing PTS, and by 

adding task-appropriate risk management elements for each Area of Operation. The ACS would 

thus define not only the performance metrics for knowledge and skill, but also the required 

content for guidance materials such as the FAA-H-series handbooks and for relevant knowledge 

test questions.
Aviation Rulemaking Advisory Committee 

Airman Certification System Working Group

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140624 ACS FAQs vFR

What’s wrong with the PTS?

The PTS provides metrics to define acceptable performance of the “flight proficiency” skills 

listed in 14 CFR part 61 for a given certificate or rating. Most people believe that the PTS 

generally serves its intended purpose but, like all such documents, it has become bloated over 

the years with an ever-expanding list of “special emphasis” items, repetitive or overlapping 

Areas of Operation/tasks, and poorly-defined additional requirements (e.g., evaluation of the 

applicant’s risk management and aeronautical decision-making skills). 

How does the ACS approach improve the PTS?

The ACS approach does not increase or expand any of the skill evaluation requirements in the 

existing PTS, but it significantly improves the PTS in several ways. The ACS: 

 Provides integrated guidance that defines performance metrics for aeronautical knowledge 

as well as flight proficiency (skill). 

 Strengthens the PTS by explicitly defining the aeronautical knowledge needed to support 

each Area of Operation/task. This linkage enhances the relevance of the testing/training 

process for adult learners by clearly answering the “why do I need to know that?!” question. 

 Enhances safety by using the risk management section in each ACS Area of Operation to 

translate abstract terms like “aeronautical decision-making” into specific safety behaviors 

relevant to each task. 

 Eliminates “bloat” by consolidating duplicative or overlapping tasks in the existing PTS. 

Why does the ACS have a separate section for risk management? Isn’t that just the 

latest buzz word?

The PTS already requires evaluation of the applicant’s risk management abilities, but the 

existing document doesn’t offer the kind of concrete “what do I have to do?” guidance that users 

need and deserve. The rationale for including a risk management section in the ACS is to 

enhance safety by translating abstract terms into specific safety behaviors relevant to each task. 

The ACS is also intended to communicate and demonstrate that risk management is a continuous 

process that includes identification, assessment, and mitigation of task-specific hazards that 

create risk. The risk management element identifies the circumstantial issues that aviators must 

consider in association with a particular task.

So how does the ACS approach improve the test?

Accepted industry practices for any certification process stipulate that training and testing be 

based on a job/task analysis. The ACS documents function as the required job/task analysis, as 

they define the knowledge and skills needed to perform at the level of the target certificate or 

rating. By so doing, the ACS approach better serves the applicant, the instructor, and the 

evaluator. And because the process of developing the ACS requires a thorough review and 

update of knowledge and skills for airman certification, it aligns with certification industry 

standards for periodic review and revision of the job/task analysis. In addition, the ACS 

approach will enable the FAA to create and maintain a clear link between the regulations, 

knowledge/skill performance standards, guidance, and test materials.
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How do you propose to provide the “clear link” connecting knowledge/skill 

performance standards, guidance, and test materials?

One of the overarching goals of this project is to create an integrated, coherent airman 

certification system in which standards, guidance, and testing can be aligned and maintained in 

alignment. Such symmetry is key to fully realizing the benefits the ACS system promises to both 

the FAA and its many stakeholders. It is also key to conformance with accepted industry 

standards for certification programs, which require that items to be trained and tested be 

directly linked to the job/task analysis – in this case, the ACS.

You may have noticed that the revised versions of the private pilot and instrument rating ACS 

documents and the new authorized instructor ACS include a series of letters and numbers after 

each task. These codes provide the means to correlate the tasks in the ACS with guidance and 

testing, and to keep them aligned going forward. The proposed ACS codes would supersede the 

current system of “Learning Statement Codes” (LSC), which is too limited to serve as the 

mechanism for alignment and too complex to effectively serve the needs of the FAA and the 

stakeholder community. 

The proposed coding system has four elements that are anchored in the ACS (not in reference 

documents, like the current LSCs). 

PA.XI.A.K:

PA = (private pilot airplane) – identifies the applicable ACS.

XI = Area of Operation (Night Operation)

A = Task (Night Preparation);

K1 = Task element [knowledge (K), skill (S), risk management (R)]

The proposed ACS-based coding scheme will:

 Clearly align guidance and test questions to the ACS;

 Make the airman test report meaningful to stakeholders (applicant, instructor, evaluator);

 Provide a means for automated generation of tests, whether using the existing test forms or 

future randomized selections; and 

 Eliminate subjectivity and vastly simplify system management requirements for the FAA.

Isn’t the real problem related to deficient skills? If so, what is the point of this change?

Aviators love to debate, and we can argue endlessly about what really causes accidents. Perhaps 

we can agree, though, that most accidents have multiple causes. According to the AOPA Air 

Safety Institute, the three leading general aviation (GA) fatal accident factors are maneuvering 

flight, continued VFR into IMC, and loss of control on takeoff. These factors all imply some 

degree of deficiency in the pilot’s knowledge, skill, and risk management abilities. Even the 

world’s best stick-and-rudder pilot is at risk for loss of control if he or she has an inadvertent 

flight into IMC because of deficiencies in weather knowledge or risk management ability. Safety 

is not served by emphasizing just one of these three abilities. On the contrary, each supports the 

others.

The ACS is therefore an improvement over the current system, because it offers a holistic 

approach to aviation training and testing – it integrates knowledge, skills, and risk management, 

and it provides a way to ensure that the elements of the certification process – standards, 

guidance, and testing – are correlated to these abilities and aligned with each other. 
Aviation Rulemaking Advisory Committee 

Airman Certification System Working Group

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How can you map knowledge to skills?

The ATST WG invested considerable time developing a standardized approach to integrating 

knowledge and risk management with the skills in the existing PTS Areas of Operation/tasks. To 

assist the FAA in this process, the ATST WG’s final report will describe its PTS-to-ACS 

transition methodology in detail. In summary, though, the ATST WG sought to:

 Ensure that all aeronautical knowledge topics listed in 14 CFR part 61 are addressed in the 

appropriate Area(s) of Operation in the ACS

 Define the knowledge topics required to support the skill area for the level of airman 

certificate covered by the target ACS. 

 Calibrate the required knowledge to the level of the airman certificate or rating level.

The ATST WG strongly recommends that the FAA seek expert stakeholder participation in this 

process. And, while calibration is unavoidably somewhat subjective, the use of standardized 

rubrics and a comprehensive task chart (i.e., a document that displays the required level of 

performance for each Area or Operation and/or task) would be helpful. 

The group took a similar approach to risk management. Drawing from the special emphasis 

topics in the existing PTS and sources such as the FAA Risk Management Handbook (FAA-H8083-2), the group listed specific, practical, risk management tasks, skills, or behaviors 

appropriate to each Area of Operation. 

What benefits come from mapping knowledge to skills?

Most accidents have multiple causes, and many involve at least some degree of deficiency in the 

pilot’s knowledge, skill, and risk management abilities. Each of these abilities supports the 

others. The ACS reflects this reality because it offers a holistic approach to aviation training and 

testing – it integrates knowledge, skills, and risk management, and it provides a way to ensure 

that the elements of the certification process – standards, guidance, and testing – are correlated 

to these abilities and aligned with each other. 

Another benefit is that the holistic ACS approach is consistent with principles for effective adult 

education and meaningful testing. According to Malcolm Knowles, effective instruction and 

education of adults occurs when they perceive a need for certain knowledge or skills, understand 

how the area of learning relates to what they want to achieve, and recognize how the area of 

learning applies to the life or work context.

By mapping specific items of aeronautical knowledge and actionable risk management practices 

with the flying skill performance metrics in the existing PTS, the ACS meets these needs and 

significantly enhances the educational value of the FAA knowledge test.

Finally, the holistic ACS approach is consistent with accepted industry practices for any 

certification process. The ACS documents function as the required job/task analysis, because 

they define the knowledge and skills needed to perform at the level of the target certificate or 

rating. By so doing, the ACS approach better serves the applicant, the instructor, and the 

evaluator. 
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Airman Certification System Working Group

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Why is the authorized instructor ACS different?

Because the ACS is intended to be a foundation for the entire airman certification testing and 

training system, the ATST WG invested considerable effort developing an ACS framework that 

can be consistently applied to the majority of airman certificates and ratings. 

The draft authorized instructor ACS follows the overall conceptual framework developed for the 

private pilot ACS and the instrument rating ACS, but its construction reflects fundamental 

differences between the family of pilot certificates/ratings and the instructor certificate. The core 

of the authorized instructor ACS addresses practical application of the instructional concepts 

and techniques presented in the traditional Fundamentals of Instructing (FOI). The authorized 

instructor ACS uses appendices to define the acceptable standards for knowledge, skill, and risk 

management in the aeronautical proficiency tasks unique to a particular instructor certificate or 

rating. 

It is also important to understand that the authorized instructor ACS is not intended to be a 

stand-alone document. Just as a flight instructor certificate must be accompanied by a 

commercial pilot certificate, the authorized instructor ACS is to be used in conjunction with the 

ACS for the pilot certificate level or rating for which the instructor-applicant seeks to provide 

instruction. In addition to mastery of the knowledge and skills defined in the authorized 

instructor ACS, the instructor-applicant must demonstrate instructional competence for Tasks in 

the ACS for the appropriate certificate level or rating, to include analyzing and correcting 

common learner errors. 

What’s the point of changing terms to words like “evaluator” or “plan of action?”

One of the goals of this project is greater consistency. Instead of trying to list every category of 

person authorized to conduct a practical test (e.g., examiner, designee, designated pilot 

examiner, aviation safety inspector), the ACS uses the term “evaluator” to cover the entire 

range. The term “plan of action” is used in the authorized instructor ACS because a plan of 

action for instruction better conveys the intended concept, and also because it corresponds with 

the requirement for an evaluator to have a plan of action for conducting the test.

Why does the ACS mix the terms “learner” and “student pilot?”

The education and training industry has generally adopted the term “learner,” because it 

conveys recognition and respect for adults’ experience and motivation. We followed this 

convention in most instances. However, the ACS retains the term “student pilot” when it refers 

to certification activities involving an individual who is a student pilot within the meaning of 14 

CFR part 61.

Why use the term “airman” instead of “pilot” or “aviator?”

The regulations use the term “airman” to encompass the full range of aviation functions that 

require an FAA certificate or rating. Not all airman certificates and ratings are for pilots or 

aviators; some apply to aircraft maintenance technicians, dispatchers, and other specialties. We 

continued to use this term because it includes all aviation functions that require an FAA 

certificate or rating, and because it is used in the regulations. We did not recommend a change 

because changes that require rulemaking are beyond the scope of this group’s charter.
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Doesn’t this kind of change require a formal rulemaking process?

No. Like the PTS, the ACS simply defines the metrics – the standards -- for meeting the 

regulatory requirements that 14 CFR part 61 enumerates for aeronautical knowledge and flight 

proficiency. The ACS does not change any of the requirements in 14 CFR.

Doesn’t this approach increase the standards?

No. The ACS approach does not increase the standards. Except for those areas where the ACS 

consolidates overlapping or duplicative Areas of Operation/tasks in the existing PTS, none of the 

PTS material has changed. The knowledge and risk management sections simply define the 

standards for meeting the requirements in 14 CFR part 61.

Doesn’t the ACS approach increase the cost of flight training?

No. In fact, a more integrated and efficient presentation of the material to be tested could make 

training far more effective and efficient for all stakeholders – and thus less costly. Instructors 

will be able to effectively and efficiently remediate any deficient knowledge identified on the 

airman knowledge test report in preparation for the practical test.

Won’t the ACS approach dramatically increase the length (and expense) of the 

practical test?

No. In fact, a more integrated and efficient presentation of the material to be tested could even 

shorten the test, especially if the evaluator has more confidence in the quality and meaning of the 

applicant’s knowledge test score. Evaluators will be able to effectively and efficiently re-test any 

deficient knowledge identified on the airman knowledge test report to ensure the applicant has 

trained to proficiency in all areas.

How much will the ACS cost in terms of money and manpower?

Today’s airman certification system is far more costly than it should be for both the FAA and 

stakeholders, because the absence of a knowledge standard and the lack of standardized and 

solid integration of standards, guidance, and testing leads to disconnects and errors that have to 

be corrected on a piecemeal basis. For the FAA, the shortcomings of the present system also 

make it difficult to coherently accommodate and integrate requests for new or enhanced material 

on special emphasis topics. 

For stakeholders, the current system is costly because it creates uncertainty and leads to 

expensive last-minute or off-cycle changes and corrections to training and test preparation 

materials. It is certainly costly for applicants, instructors, and evaluators, if only because of the 

time wasted in teaching or learning topics that have no value for safe operation in today’s 

National Airspace System (NAS). 

While there will be an initial investment needed to implement the ACS approach, the ATST WG’s 

proposal for a phased transition – designed to match the existing schedule for updates – will 

minimize the cost. And, if properly implemented, the ACS approach to airman certification 

testing and training will be much less costly than today’s highly inefficient system.
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What do you mean when you say that the ACS concept is consistent with SMS 

principles?

The safety management system (SMS) framework provides a systematic approach to achieving 

acceptable levels of safety risk. The holistic ACS concept for the overall airman certification 

system is consistent with SMS, because it addresses each of the four SMS “pillars:”

 Safety Policy that demonstrates FAA senior management commitment to continually improve 

safety through enhancements to the airman certification testing and training system; 

specifically, better integration of the aeronautical knowledge, flight proficiency, and risk 

management components of the airman certification system;

 Safety Risk Management processes that create a structured means of safety risk management 

decision making to identify, assess, and determine acceptable level of risk associated with 

regulatory changes, safety recommendations, or other factors requiring modification of 

airman testing and training materials;

 Safety Assurance processes which allow increased confidence on the part of industry and 

FAA stakeholders in risk controls through a continual review of FAA products and the 

systematic, prompt and appropriate incorporation of changes arising from new regulations, 

data analysis, and safety recommendations; and 

 Safety Promotion framework to support a positive safety culture in the form of training and 

ongoing engagement with both external stakeholders (e.g., the aviation training industry) 

and FAA policy divisions.

What did you do with the comments submitted to the docket on the initial private pilot 

and instrument rating ACS documents?

We appreciate the many comments and questions we received in response to the first set of 

documents. As planned, we used this feedback to refine the draft ACS documents. You will see 

some of that feedback reflected in the revised ACS for the private pilot certificate and the 

instrument rating. Other comments and questions were very valuable in showing us the areas we 

need to clarify or better explain, as we have tried to do with these “frequently asked questions.” 

The ATST WG’s final report (due to the FAA in September) will include a more detailed 

discussion of how we addressed the comments received through this process.

How do you expect to evaluate soft skills?

So called “soft skills” are already evaluated through the use of scenarios and circumstances that 

require decision-making and judgment. By providing more specific guidance on the knowledge 

and risk management abilities needed to support a particular skill, the ACS will give applicants, 

instructors, and evaluators much better guidance than they have in today’s system.
Aviation Rulemaking Advisory Committee 

Airman Certification System Working Group

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What’s the difference between this ACS and a training syllabus?

The ACS defines what the applicant must know, do, and consider to earn an airman certificate or 

rating. A training syllabus defines how (where, when and why) these standards are met. 

Accepted industry practices for any certification process stipulate that it be based on a job/task 

analysis. The certification process must analyze, define, and publish the domains and tasks that 

are a part of the certification process. It must further identify the knowledge and skills associated 

with performance of those tasks. The required knowledge and skills become the basis for 

development of assessment activities.

The ACS documents function as the required job/task analysis, as they define the knowledge and 

skills needed to perform at the level of the target certificate or rating. By so doing, the ACS 

approach better serves the applicant, the instructor, and the evaluator. Because the process of 

developing the ACS required a thorough review and update of knowledge and skills for airman 

certification, it also aligns with certification industry standards requiring periodic review and 

revision of the job/task analysis.

How can risk management be tested on a knowledge test?

Risk management can be effectively tested on a knowledge test through the use of scenarios, 

common student errors, misconceptions, or frequent accident causes. Risk management 

questions will remain objective because they will be specific to an area of operation/task.

How will use of the ACS approach change airman training?

With clearly defined standards for knowledge, skill and risk management, airman training can 

be conducted more effectively to ensure applicants who complete flight and ground training are 

safe, competent aviators as well as successful in passing the FAA knowledge test. Training and 

testing will be aligned, which means that “test prep” will be a review of the ground school 

curriculum rather than a separate, unrelated step to learn questions for the sole purpose of 

passing a test.