Revising the PTS is the wrong approach to an objective to reduce the accident rate. I have a state teaching license, am an active certified flight instructor, and fifty years of flying experience. There is nothing wrong with the present system of testing pilots to determine if they have the knowledge and ability to safely exercise their duties as PIC of an aircraft. Your efforts would be better spent developing recurring training to reinforce the basic skill set developed for a pilot's initial license. Currency is paramount to exercising the needed ability to do what you have been taught. A person with 100 hours will not perform as well as a person with 1000 hours. Airplanes are marvelous devices and each posses characteristics that must be understood to effectively control them. The need for a tailwheel endorsement is one example that could be cited. You can't stop accidents and the 10,000 hour pilot who landed a DC-6 gear up because he didn't maintain a sterile cockpit throughout the landing phase will confess it can happen to anyone. Insurance actuaries will confirm there are going to be a finite number of accidents in each type, category, and class of aircraft. Related to recency of flight experience the rate should be lower. Further complicating the PTS will not achieve anything save discouraging future pilots, who are all to scarce already. Ask yourselves why we no longer teach students to spin aircraft and only require it be performed during training for an instructor rating. Faulty judgement, in my opinion, is the largest factor in accidents and knowledge with experience will foster the wisdom to exercise good judgement. Life-long learning as the saying goals will do more for safety than changing the way we access knowledge and skills. Annual or semi-annual flight reviews until a person has acquired 500 hours of flight time would be a more pro-active approach to reducing accidents.
Richard Murray, Jr.
This is comment on Notice
Meetings: Aviation Rulemaking Advisory Committee Airman Testing Standards and Training Working Group
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