Ok, I know this post is going to be a long read, but play along with me and I hope you will find it worthwhile. Grab a cup of coffee and read it to the end if you have any interest in how we train and certify commercial pilots today and want to think about adjustments to improve that process going forward.
A few years ago we made the change to ACS from PTS in most main pilot training sequences, the commercial pilot included, but when we did that, we didn’t really take the time to go back to consider what it took to get a commercial certificate. It has been a long time since we critically evaluated what training requirements and maneuvers should be a part of the commercial pilot certification, and I think it might be time to look at a few of these.
There are a few things I would like to see us consider as changes to commercial pilot certification. When I think about these, the changes that I am going to present here are intended to either help training become more efficient (from a regulatory standpoint) or adjust maneuver requirements to be more realistic (and potentially safer) for what commercial pilots (especially in single-engine aircraft) might do with those skills in a job.
Wouldn’t that make more sense? I think so, but I am just one guy who sees training every day. I hope there are others who might have some opinions and chime in with thoughts on what I write here and what I may have missed.
So, with that, I have thoughts on some changes we might consider.
Let’s start with the dreaded Power Off 180 maneuver.
Fix the Power Off 180
The Power Off 180 maneuver has become something of a spot landing and an emergency operation all rolled into one, and as such, it is not practical for either purpose.
The current standards, to a designated touchdown point not to exceed 200 feet beyond it in an engine-out scenario, don’t represent what we would do if we had an emergency in real life. In real life, if we had an engine out, our goal would be to get down on the runway, not short of it, and appropriately at the beginning of the runway so we wouldn’t roll off the end, especially at an excessive speed. We wouldn’t be shooting for a specific spot on the runway, a spot landing.
We have somehow reached the point where our standards now include guidance in the ACS appendix that indicates (with some limited exceptions for safety) that “Initiating a go-around as a result of an applicant’s inability to complete this Task within the tolerances specified in the skill elements is considered unsatisfactory.”
But if this is a performance maneuver, one that is a landing demonstration, why is it listed in the Airplane Flying Handbook (FAA-H-8083-3C) in Chapter 9, Approaches and Landings, instead of Chapter 18, Emergency Procedures? It is likewise in the Commercial ACS (FAA-ACS07B) under Area of Operation IV, Takeoffs, Landings, and Go-Arounds, instead of Area of Operation IX, Emergency Operations. Perhaps it should be in both of those and transitioned truly into an emergency maneuver, which would not be spot landing, but instead an engine out proficiency demonstration of an ability to safely get down to the airport, not a specific point.
If we were doing a spot landing, we would have some control of power and the ability to manage that vertical descent rate using it appropriately. I get that is more like a short-field landing, but it is also why I do not think we should eliminate the skills in this maneuver as a part of training and testing. Just modify the maneuver
We are hurting planes out there doing it the way we are now. We are also not really training something that is the best practice in a real-world emergency, and honestly, going to end up hurting people at some point.
DPEs (and CFIs) are seeing applicants drive airplane noses down when they will be slightly long and cause porpoising, or worse. We are seeing applicants over-flare and try to stretch out a landing and stalling and plopping the plane down instead of managing energy if they think they are going to be a little short. This is all happening because the applicants are being taught to focus on a small point instead of aircraft energy management to a range of area on the runway for their touchdown in an emergency.
Many flight training operators will tell you this maneuver is causing damage to aircraft as people try to force planes down on a specific point due to an arbitrary designation of a landing point. I get it; that is a skill issue, but why don’t we fix this maneuver to make it a skill worth having?
To support this, I don’t think we should dump the maneuver. I think we should keep it, just make it one that is an actual emergency skill demonstration. We keep the short field landing to show people can land on a spot using proper power and aircraft control. But we make the power off 180 a maneuver to landing on the runway in a reasonable portion of the runway to where the pilot can’t be short, has a little bit of room to work with, and can demonstrate they could get down to the runway in the first portion of it and slow down in an emergency to a speed where they could stop on the runway or if it was a very short runway at least minimize energy and roll off the end slowly and cause the least possible damage to the plane, property, and most importantly, any occupants.
To do this,
I Propose:
The power off 180 be conducted with a simulated engine failure abeam the approach end of the runway and that the applicant be able to touchdown in the first third of the runway or no longer than 1000 feet down the runway, whichever is shorter.
This would be a very clear standard for the applicant and examiners to apply and not force anyone to drive the plane to a specific spot.
Don’t do 8’s on Pylons; Do Turns ON a Point.
Eights on Pylons is a fundamental advanced flight maneuver in pilot training, particularly in commercial and flight instructor curricula. It evolved as a practical application of ground reference maneuvers, designed to enhance a pilot’s ability to maintain precise control over an aircraft in varying wind conditions while considering pivotal altitude—a concept unique to this maneuver.
The origins of the maneuver trace back to early aerial navigation and military training. Before the advent of sophisticated flight instruments, pilots relied heavily on visual references to maneuver and maintain orientation. In the early 20th century, barnstormers and military aviators frequently used ground objects as visual cues for turns and orientation. This technique laid the groundwork for later structured training exercises.
As aviation became more formalized in the 1920s and 1930s, flight training began incorporating standardized maneuvers to improve pilot proficiency. The Civilian Pilot Training Program (CPTP) in the late 1930s and early 1940s emphasized ground reference maneuvers, including turns around a point and S-turns across a road. These exercises helped pilots develop wind correction skills, but instructors sought a more advanced maneuver that introduced dynamic lateral control and airspeed management.
Eights on Pylons emerged as an evolution of these exercises, requiring pilots to maintain a consistent visual reference on a fixed point on the ground while adjusting bank angle and altitude based on the aircraft’s speed. The key principle behind the maneuver—pivotal altitude—was formalized in the post-war flight training manuals, particularly in the 1949 edition of the Civil Aeronautics Administration (CAA) Flight Training Handbook. This altitude, at which a visual reference point remains stationary relative to the pilot’s perspective, is calculated using the square of the aircraft’s true airspeed divided by 11.3 (for knots) or 15 (for miles per hour).
By the 1950s, Eights on Pylons became a staple in commercial pilot training, reinforcing energy management, coordinated turns, and wind compensation. The maneuver was refined in FAA flight training materials, and its practical application extended to aerial photography, reconnaissance, and agricultural flying.
Today, Eights on Pylons remains a required maneuver in commercial pilot flight training, but I can’t think of a practical application for which I would actually use it. I can, however, come up with a good application for HALF of an eight on pylon; a turn ON a point.
If I was genuinely trying to mark a point and fly around it, I don’t know why I would leave that point to fly the “8” and then return to it. I would circle it multiple times, using the pivotal altitude to do this while keeping the reference point.
I can see the real-world practical application of the turn around a point for emergency rescue operations where a point is marked and referenced and maintained to keep it in view. Imagine being the person on the ground who the rescue plane found, circled, and then left. I would be a little worried on the ground if the pilot didn’t see me and was leaving. But if they kept going around, I would be a lot more confident they had good vision of where I was, and rescue was going to be coming! I could easily see this maneuver being used in practical commercial flying operations for fire spotting to help firefighting efforts. And I certainly could see it being used with a photographer onboard to keep a good reference line for a photo mission. All of these are much more practically applicable than doing an eight on pylons.
Doing a Turn ON a Point could be done at pivotal altitude, with a minimum of three circuits of the point, asking the pilot to show they can keep a stable bank angle without ending up in a degrading spiral while still referencing the point and going around multiple times. I think it still shows the skills, and is more practically useful.
An examiner could ask the applicant to perform this maneuver on either side, so the applicants would still have to be proficient both ways. Why both sides? Well, to show proficiency, and it certainly seems logical if this was being used for photographic reasons, the photographer could want to shoot the pictures out of either side of the aircraft. So, get good at it both ways.
I Propose:
We drop the eights on pylons and replace it with Turns ON a Point with three circles being flown while keeping the reference point.
Steep Spiraling Descent; not an emergency landing.
The steep spiraling descent has been a pet peeve of mine for a while. It isn’t that the maneuver isn’t a valid one, but that it gets trained and tested in a way that I don’t think is all that practical.
In some cases, I honestly think people are being tested and failed when they should not be, in a way that isn’t correct.
If you reference the Airplane Flying Handbook (FAA-H-8083-3C) it states: “The objective of the steep spiral is to provide a flight maneuver for rapidly dissipating substantial amounts of altitude while remaining over a selected spot.” And I fully agree with that.
But then it adds the following misleading sentence, “This maneuver may be useful during an emergency landing.” This is where the problem comes in. Many pilots and instructors are confused and think that this means the maneuver is what a pilot would be taught to do if they had an engine failure.
I completely disagree with that logic. If I had an engine failure, unless I was on fire, I wouldn’t be in a rush to get to the ground with maximum descent rate. I would want to get to best glide and stay in the air as long as I could to potentially get an emergency checklist done, which might make it so I didn’t end up landing off-field somewhere. I also wouldn’t be introducing lots of banks and making circles. I would never turn my back fully to an intended landing site. I would zig-zag out in a position where I knew a turn of no more than 90 degrees to the field could let me line up with and make the landing as I descended in the event that my descent path got lower than I thought it might have and I could still make the field. The good news is that when we teach such an engine-out procedure from altitudes such as where we start steep spiraling descents, we have lots of altitude to work with.
But we have some DPEs testing applicants to apply the steep spiraling descent to an actual engine out simulation, trying to combine the maneuvers from the ACS. A few even have been asking applicants to actually conduct this maneuver to a landing at a runway. In the worst examples, I have had reports of students being asked to do this to a grass runway (an actual legal airport one at least) and land the maneuver. If the applicant is unable to do this combination of things, they get a disapproval.
There is a problem here.
The last line of the ACS Skill section of the Task for Steep Spiral specifically reads:
“CA.V.B.S6 Maintain the specified airspeed, ±10 knots and roll out toward an object or specified heading, ±10°, and complete the maneuver no lower than 1,500 feet above ground level (AGL).”
A DPE asking the application to complete the maneuver into another one is not showing that they have completed the maneuver and returned to normal flight from that maneuver.
I Propose:
It’s time we stop teaching the steep spiral as a method to descend quickly to an emergency landing. Teach it just as a method to descend over a point in a stable configuration and return to stable normal flight at the end. It’s time to take that second sentence out of the airplane flying handbook.
If you are reading this and find yourself asked to sequence this maneuver to a landing on your practical test, know that the last line says complete the maneuver. If the DPE presses you to do otherwise, ask for a discontinuance and return to the airport and discuss it on the ground.
Add a New Maneuver: Flying a Grid Pattern
Ok, we haven’t added a maneuver in a long time to the commercial standards. I know not everyone wants to do more, but I honestly think this one is one that is a skill that practically applies to jobs people might get as a low-time, freshly certificated commercial pilot.
One of the jobs that people do other than becoming a CFI is to become an aerial survey pilot. Frequently supplying data for online mapping, agriculture, or survey purposes, pilots get to fly grid patterns back and forth, letting telemetry (photo or other) capture data below them. They do that at various altitudes and varying widths of lanes depending on the equipment being used. Many call it “mowing the grass” because the goal is to have lanes overlap to not have missing data blocks between them.
I think we could add this maneuver to the Commercial ACS (and the Airplane Flying Handbook) and start building a skill, and a testing item, that is practical in today’s commercial pilot job realms.
I Propose:
A grid pattern at 3000 feet AGL be added to the commercial pilot airplane single- and multi-engine ACS (yes, they do this in multi-engine aircraft also) where the pilot would fly five lines, returning to the direction of flight they started of approximately 1 mile in length with approximately ½ mile between the lines, showing they can sequence the lines. The maneuver should be flown perpendicular to the wind to show the pilot can adjust for wind drift. The pilot should maintain airspeed plus or minus 10 knots and altitude plus or minus 100 feet.
It might look like this graphic:
Adjust experience requirements language to fix certification confusion [and incorrectly issued certification].
While I am proposing things, I also REALLY want a couple of changes in the commercial pilot experience requirements regulation. There are a couple of hiccups in there that hang up training all too frequently, either for misapplication or lack of awareness of the nuance.
14 CFR 61.129 requires a pilot for an initial commercial pilot certificate (either in a multi-engine or a single-engine) to have “Ten hours of instrument training using a view-limiting device including attitude instrument flying, partial panel skills, recovery from unusual flight attitudes, and intercepting and tracking navigational systems.”
This is too commonly considered to have been accomplished when a pilot completed their instrument rating. While it is possible that they might have, too frequently, the training in an instrument rating is not logged properly, parsing it out as some toward the instrument rating and some toward future commercial pilot requirements. We are left with the student who already has an instrument rating needing to accomplish another 10 hours of instrument training toward the commercial pilot certificate.
We have had lots of legal interpretations on this, but there still is too much confusion. Some of it can be done in simulators, and the honest truth is that people have had to do too much work around to meet the requirements that are needed here.
This regulation is a holdover from when we had people do commercial pilot certificates before they got instrument ratings. When that was the case, the training was certainly warranted, and it still is in the rare cases that someone gets their commercial pilot certificate before an instrument rating. But that is rare now.
Doing an additional 10 hours of basic instrument skills when someone has an instrument rating, and the fact that none of this is tested on the commercial pilot certificate anyway, is a waste. And it can be easily solved.
I Propose:
We change 14 CFR 61.129 (a)(3) and (b)(3) to simply add the words “or be the holder of an instrument rating” in the training sections that require 10 hours of training for instrument skills. This would make this training not required in addition for those who already hold the certificate.
It would also take the confusion away and, honestly, stop us from mis-certifying or delaying the certification of people who didn’t properly accomplish or document 10 hours of instrument training specifically toward the requirements of 14 CFR 61.129. As it is right now, I know of many CFIs and a few DPEs who are misapplying this. If we did a careful audit in our pilot certification realm, I honestly think we have hundreds, if not thousands, of commercial pilot certificates that have been issued where this requirement was not properly met. We can fix this without changing any quality of training concerns here.
Also in the 14 CFR 61.129 concerns, with regard to this instrument training, it specifically states that the training must be “using a view-limiting device”. This implies an instructor and student must do this not in actual IFR conditions. Why wouldn’t we let a CFI-I and a commercial student accomplish this time in actual instrument conditions? Or in actual instrument conditions during their instrument training?
I Propose:
14 CFR 61.129 (a)(3)(i) and (b)(3)(i) be changed to read “Ten hours of instrument training in actual or simulated IFR conditions…” to remedy this limitation.
And just one more regulation change to propose.
While we are at it, let’s fix the solo/DPIC issue that crops up frequently.
14 CFR 61.129 (a)(4) and (b)(4) says that the ten hours of solo time must be “solo” OR “DPIC”. I get that the intent of this section is for it to be solo flight time and that the DPIC is a carve-out we have for some specific purposes. But it is regularly confused and misapplied. The “OR” making it an all or nothing for the entire 10 hours frequently makes it a mix and match that students, under their unknowing CFIs misapplication of the regulation, mess up and it ends up causing students to fail to meet the requirements properly.
When this happens, they either end up flying more flight time to make up the gap for what was improperly flown, or, in the worst of cases, the CFI and sometimes the examiner miss it, and they end up certificated when they technically did not properly meet all the experience requirements.
The best option for commercial pilot candidates is that they have just flown these requirements “solo” without an instructor onboard.
If we still want to protect the option to have DPIC available, we could clean up the language here to make it clearer to applicants and their CFIs.
I Propose:
We change 14 CFR 61.129 (a)(4) and (b)(4) to read: “ten hours of solo flight in a single- [multi-] engine airplane or 10 hours of flight time performing the duties of pilot in command in a single- [multi-] engine airplane with an authorized instructor on board who is not providing instruction during the flight or any combination thereof (either of which may be credited towards the flight time requirement under paragraph (a)(2) of this section, on the areas of operation listed under § 61.127(b)(1) that include…”
This would make the flight a mix-and-match available flight experience activity and more clearly denote that if a CFI is onboard they are not acting in an instructional capacity during this activity. It doesn’t change the actual activity that will take place, it doesn’t ruin the experience process, and it makes it much more likely that applicants won’t have mis-properly tried to meet the particular requirements and end up having to end up flying more flight time due to an administrative challenge or worse, improperly certificated.
These simple changes in regulatory language in the commercial pilot experience requirements would increase the efficiency of commercial pilot training with zero reduction to standards and skills of those applicants. Let’s make these changes happen!
I am sure there are other suggestions out there that might be very well worth considering. Are there other real-world practical things that single-engine commercial pilots do in real jobs that could be considered for maneuvers in training that could make our pilots more prepared to actually be commercial pilots in jobs?
I look forward to your input and discussion!
Oh, and tell me if I am crazy with what I have said here. I can take the critique and welcome points I have not considered if this doesn’t make sense.
Fear is a natural human response, and pilots must understand and manage their fears in aviation to perform safely and effectively. Two common fears often confused are