FAA knowledge tests -- 24 calendar month time limit

FixedWing

FixedWing

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Stephen Williams
Over the weekend I drafted and filed with the FAA a petition for
rule making asking that they extend the validity of FAA written tests
from the current two years to something more reasonable.

https://downloads.regulations.gov/FAA-2024-0001-0001/attachment_1.pdf

As explained in the petition, two years is incredibly arbitrary. It's
been in place since 1961 without modification, despite that the newer
ATP written is good for five years.

Why this matters to our members is that the two year limit often means
that they need to refrain from studying until they are closer to their
practical check-ride. Otherwise, they risk having the written expire
before they can take the check-ride forcing them to repeat it. This is
especially true for our younger members who can solo at 14 but cannot
take the check-ride until 16. At that stage, it can be difficult to
force yourself to hit the books again. We've lost a lot of members this
way. Having to refrain from studying hardly fosters learning and
aviations safety.

If this sounds like something you care about, and I hope you do, you can
help by posting a comment. Personalized comments that explain how this
effects you are the best. To comment:

https://www.regulations.gov/commenton/FAA-2024-0001-0001

HNY!

Stephen
 
I’ve never come close to 12 months between written and practical; I get there’s edge cases resulting in a written exam expiring, but I’d he surprised at the knowledge retention beyond 24 months, even if someone is slowly working towards the practical exam.
 
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I've only ever come close to the 24 months due to procrastination. The 24 month deadline was the motivator I needed to break through the procrastination. I know scheduling checkrides is difficult, but 2 years is plenty.
 
I don’t see the benefit. You'd think that with good progress being made in the cockpit & the check-ride quickly approaching, a pilot would be even more motivated to study. Besides, the information for the oral portion of the check-ride would be fresher in the applicant’s mind. 3 yrs—even 2 yrs—is pretty stale knowledge to be demonstrating to a DPE.
 
I think you explained why the FAA expires the test.


"Why this matters to our members is that the two year limit often means
that they need to refrain from studying until they are closer to their
practical check-ride. Otherwise, they risk having the written expire
before they can take the check-ride forcing them to repeat it. This is
especially true for our younger members who can solo at 14 but cannot
take the check-ride until 16. At that stage, it can be difficult to
force yourself to hit the books again."

Since they have forgotten what they need to know to be safe, legal pilots, they should restudy.

If they have NOT forgotten, the written is easier the second time.

Personally, I continued to study and take partial tests on a regular basis until I quit flying PIC. Any one serious about being a good pilot needs to take this approach, as your book knowledge fades slowly, unless refreshed.
Our flying club had written quizzes at the monthly meetings, the CFI led the discussions, and we all became better pilots.

The student pilots were included, and it was part of their preparation for the test.
 
Good luck. I've done two petitions for rulemaking over the years. One I figured was incredibly straight forward. There was a change made in rearranging some paragraphs that indicated that safety pilots needed instrument ratings. This was not mentioned at all in the rule making for the reorg or in any of the comments. I just intended to fix the exception to put it back the way it was (the intended changes in the rule were unrelated to this). The refusal I got from the FAA (from the greatest idiot they had working there John Lynch) was so off the wall that it made Captain Ron's head explode.

I was about to bring up the battle again when the FAA counsel made some equally off the wall statement that 61.55 didn't apply to safety pilots at all which seems bizarre to me but what the hell. It moots my concerns.

The other was when I fixed the the definition of night. The part 1 definition of night referenced a publication that hadn't existed in over a decade, though Part 121 got the correct citation. That one went direct to final because they considered it a mere typographical edit.

I feel for you a bit, I took the FAA instrument written and let it expire three times before finally getting around to taking the checkride.
 
For various reasons I’ll refrain from weighing in on the merits of the petition, but I commend the OP on at least attempting to put some thought and effort. That said, understand that any rulemaking effort requires use of scarce resources, and this petition will compete against a long list of other proposals for priority.
 
I took the knowledge test for CFI-I and not much later, moved to a new job in a new state. The two years flew by quickly and, since no one had inquired about instrument instruction, I assumed that I would not have much use for it. In recent years there has been quite a bit of demand for the IFR training, but I can't do it.
 
I’m not sure how any of this causes one to refrain from studying unless they’re simply looking for an excuse not to study.

As to the difference with the ATP written, when having the written done so you can start looking for a job that will provide the training and checking for Private, Instrument, or Commercial becomes a thing, you might have a case.
 
It can take a year just to fix the plane! Order parts, wait. Schedule shop, wait for them to work through backlog etc. Plane logs etc, missing poh, whatever.

Illness, money, work, kids, etc. There’s a million things to delay the initial schedule.
 
I am not in favor of increasing the time limit. But I am also not favor in giving a private company a monopoly on test administration. Maybe if written tests weren't so expensive people wouldn't complain about having to take them again.

Not taking the test because it might expire before you use it is a good strategy. Not studying because you don't want the test to expire is not a good strategy. Never understood why people see tests as obstacles standing in their way instead of part of the journey of learning.
 
Randomskylane said:
It can take a year just to fix the plane! Order parts, wait. Schedule shop, wait for them to work through backlog etc. Plane logs etc, missing poh, whatever.

Illness, money, work, kids, etc. There’s a million things to delay the initial schedule.
Click to expand...
I get it, 100%, but the current 2 year limit is pretty reasonable, and stretching the retention limits. People forget stuff. Flight instructors see this a lot on flight reviews.
 
The limit as is makes perfect sense to me. Anybody that wants to be a safe and knowledgeable pilot should be reviewing the content on a regular basis anyway.

I’m good with losing potential pilots that don’t think they need to know the information anymore two years after studying it. You need to know the information. Either you knew it well and a retest is no big deal, or you need to be reviewing it regularly anyway.
 
The written should expire in 5 days. Between scheduling DPE’s and testing sites, hilarity will ensue….
 
FixedWing said:
Why this matters to our members is that the two year limit often means
that they need to refrain from studying until they are closer to their
practical check-ride
Click to expand...
Nothing stops you from studying. What’s the big problem with taking the test when you have actually learned and applied the material as opposed to cramming and guessing before you take your first flight lesson so you can forget it all by the time of the checkride?

Sounds to me like a solution in search of a self-created problem.
 
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2 years, no issue. Work on fixing the practical testing issue if you want to spend your time on something. It’s a soup sandwich….
 
Gilbert Buettner said:
I took the knowledge test for CFI-I and not much later, moved to a new job in a new state. The two years flew by quickly and, since no one had inquired about instrument instruction, I assumed that I would not have much use for it. In recent years there has been quite a bit of demand for the IFR training, but I can't do it.
Click to expand...
So?

Get off your rear and take the written and practical. :D

Sorry, couldn't resist poking you. :D

The part that gets me is the concept that a student cannot study just because the don't want to take the test yet. You can study before you start flying. During your flying for your PP. And for the rest of your flying career. Aviation is NOT pass the test and ram dump your brain and forget everything type of endeavor. At least unless you want to be the subject of an NTSB report.
 
The issue, for me, is the irrelevant stuff (helicopter questions) and the ones which have either unclear questions or answers, etc.

Sheppard lists them out but it’s annoying, time consuming, and a frustrating waste of time.

The other issue is that they’ve added x hundred more questions in the two years…did they delete irrelevant questions about crap from the 30s or whatever?

I’m sure it’s obvious from my whining that I’m approaching the two year mark on IR test so ignore me lol
 
Randomskylane said:
The issue, for me, is the irrelevant stuff (helicopter questions) and the ones which have either unclear questions or answers, etc.
Click to expand...
If you ignore the irrelevant stuff and unclear questions/answers, but know the material, that will have you down to, what, 93% on the written?
 
Thank you everyone for posting your thoughts! I'm surprised by the uniformity of the responses. I wouldn't have guessed that. But now I at least know.

With gliders we do face a period when we have to tell them that they have to delay in preparing for and taking the written. And no, that doesn't mean that they shouldn't study, but human nature is what it is. I suppose the better answer would be to not make the students wait two years before they can take the practical.

Stephen
 
FixedWing said:
With gliders we do face a period when we have to tell them that they have to delay in preparing for and taking the written. And no, that doesn't mean that they shouldn't study, but human nature is what it is. I suppose the better answer would be to not make the students wait two years before they can take the practical.
Click to expand...
If you give them practical things to study between solo and checkride time, somehow being knowledgeable sneaks up on them, and you’ve tricked them into studying for the written.
 
MauleSkinner said:
If you ignore the irrelevant stuff and unclear questions/answers, but know the material, that will have you down to, what, 93% on the written?
Click to expand...
That’s what happened 20 months ago but it’s mostly luck of the draw. I only had one or two “I’ve got no clue” questions

College Football is ending so I can finally focus
 
I see no problem with 2 years. Once the pilot has the certificate, a flight review will be required every 2 years and no one seems to think that's too frequent (it isn't).
 
FixedWing said:
Thank you everyone for posting your thoughts! I'm surprised by the uniformity of the responses. I wouldn't have guessed that. But now I at least know.

With gliders we do face a period when we have to tell them that they have to delay in preparing for and taking the written. And no, that doesn't mean that they shouldn't study, but human nature is what it is. I suppose the better answer would be to not make the students wait two years before they can take the practical.

Stephen
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Gee. I’m obviously uninformed. I’ve studied and tested on the same information for at least three checkrides now, across a decade, and somehow it wasn’t a big deal. I’m going to request you don’t inform me, as I have enough real problems. Thanks.
 
Salty said:
Gee. I’m obviously uninformed. I’ve studied and tested on the same information for at least three checkrides now, across a decade, and somehow it wasn’t a big deal. I’m going to request you don’t inform me, as I have enough real problems. Thanks.
Click to expand...
I don't understand how that relates to what he wrote, did you quote the wrong message?
 
IMG_2089.gif

As a CFI, who has given dozens of sign offs over the past couple years for written exams, I find two-year-expiry date to be capricious and arbitrary. In fact, I find the exams themselves to be capricious and arbitrary. They are chock full of trick questions, The best answer/the least worst answer, and outdated terminology.
 
Half Fast said:
I see no problem with 2 years. Once the pilot has the certificate, a flight review will be required every 2 years and no one seems to think that's too frequent (it isn't).
Click to expand...
Yeah, I personally have been an advocate for annual flight reviews. The big boys do it, why shouldn’t we?
 
RyanB said:
Yeah, I personally have been an advocate for annual flight reviews. The big boys do it, why shouldn’t we?
Click to expand...

I don't have an objection to that, but I'm not sure it would have much impact. If so, the insurance companies would probably already require it.
 
Half Fast said:
I don't have an objection to that, but I'm not sure it would have much impact. If so, the insurance companies would probably already require it.
Click to expand...
If you fly something expensive enough, they do…
 
Half Fast said:
I don't have an objection to that, but I'm not sure it would have much impact. If so, the insurance companies would probably already require it.
Click to expand...
The pilots who are going to learn from it will find ways to learn regardless of how often the training is required.
The pilots who won’t learn from it won’t learn from it regardless of how often the training is required.
 
FixedWing said:
Over the weekend I drafted and filed with the FAA a petition for
rule making asking that they extend the validity of FAA written tests
from the current two years to something more reasonable.

https://downloads.regulations.gov/FAA-2024-0001-0001/attachment_1.pdf

As explained in the petition, two years is incredibly arbitrary. It's
been in place since 1961 without modification, despite that the newer
ATP written is good for five years.

Why this matters to our members is that the two year limit often means
that they need to refrain from studying until they are closer to their
practical check-ride. Otherwise, they risk having the written expire
before they can take the check-ride forcing them to repeat it. This is
especially true for our younger members who can solo at 14 but cannot
take the check-ride until 16. At that stage, it can be difficult to
force yourself to hit the books again. We've lost a lot of members this
way. Having to refrain from studying hardly fosters learning and
aviations safety.

If this sounds like something you care about, and I hope you do, you can
help by posting a comment. Personalized comments that explain how this
effects you are the best. To comment:

https://www.regulations.gov/commenton/FAA-2024-0001-0001

HNY!

Stephen
Click to expand...
Your attitude is one senior flight instructors discuss often about young students. Pilot training isn’t a short term test you study for and then forget.

24 months is not arbitrary. You must be current and that is the number the FAA has determined based on the human propensity to forget.

The FAA requires ground instructors to obtain training or demonstrate they have given ground training each 12 months.

A CFI must either obtain 16 hours ground training or demonstrate they have endorsed 5 students within 24 months to renew maintain their CFI certificate.

The requirement for a flight review sets 24 months to obtain more flight and ground training for light sport pilots and up.

All the above is for a concept called currency.

As a CFI, I would like all my students to pass the written knowledge test prior to solo and require all my students to have passed the written knowledge test prior to XC endorsement. Unless you hide under a rock, the time from solo to practical test is about 10 flights.

Your assertion you must refrain from study is bogus. Short term memorization does not make good pilots and you will have to re-memorize the information as you progress through certificates.

So rather than do the hard work, you get this bright idea to ask the FAA to lower the standard for you. Put away the test prep and crack open the text books. There is plenty you don’t know.
 
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Clip4 said:
Unless you hide under a rock, the time from solo to practical test is about 10 flights.
Click to expand...
Except that the OP is talking about glider students for whom 2 years is necessary if they solo when they’re legally old enough.
 
ja_user said:
The written should expire in 5 days. Between scheduling DPE’s and testing sites, hilarity will ensue….
Click to expand...
You have to propose this like the FAA, within 5 days preceding the day of the practical test.
 
MauleSkinner said:
Except that the OP is talking about glider students for whom 2 years is necessary if they solo when they’re legally old enough.
Click to expand...
The issue is maturity to act as PIC solo vs PIC with passengers, not maturity to study. The applicant needs to be current on practical test day beyond the oral topics because with temporary in hand they can carry a passenger.
 
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