FAA knowledge tests -- 24 calendar month time limit

RyanB said:
Yeah, I personally have been an advocate for annual flight reviews. The big boys do it, why shouldn’t we?
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Nothing's stopping you from doing one annually if you feel that strongly about it. ;)

Nauga,
on the clock
 
Clip4 said:
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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True…but 10 flights over two years seems a little scant.
 
MauleSkinner said:
True…but 10 flights over two years seems a little scant.
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He did not petition to change any ages. So let’s see if I understand your argument . He completes a pre-solo knowledge test administered by his CFI at age 13 and 11 months and it is burden to wait 6 to take the FAA written knowledge test leaving a 5 month safety window for the practical test because he now has to study for the oral too?

If this is too great a burden, the kid can sit on the ground.
 
Clip4 said:
He did not petition to change any ages. So let’s see if I understand your argument . He completes a pre-solo knowledge test administered by his CFI at age 13 and 11 months and it is burden to wait 6 to take the FAA written knowledge test leaving a 5 month safety window for the practical test because he now has to study for the oral too?

If this is too great a burden, the kid can sit on the ground.
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I’m just trying to figure out what rock does one have to live under to solo at 14 and take a Private Pilot checkride at16?
 
Clip4 said:
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.
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Speaking of studying ... try reading the linked Petition before commenting on it. From what I can tell, so far only one, or maybe two pilots posting a comment on this thread actually took the time to read it first.

The duration was set when the rule implementing the written was first promulgated in 1961. No public comment proceeded implementation. There is no evidence that 24 calendar months was based upon any sort of scientific consideration. And if it was, then why make the ATP written valid for 60 months when that would clearly be 36 months longer than it reasonable? Or are ATP brains somehow superior brains?

Stephen
 
FixedWing said:
Speaking of studying ... try reading the linked Petition before commenting on it. From what I can tell, so far only one, or maybe two pilots posting a comment on this thread actually took the time to read it first.

The duration was set when the rule implementing the written was first promulgated in 1961. No public comment proceeded implementation. There is no evidence that 24 calendar months was based upon any sort of scientific consideration. And if it was, then why make the ATP written valid for 60 months when that would clearly be 36 months longer than it reasonable? Or are ATP brains somehow superior brains?

Stephen
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By the time you get to ATP, you’ve already studied most of the material and passed the tests on it at least three times, as well as three oral exams on said material.
 
FixedWing said:
And if it was, then why make the ATP written valid for 60 months when that would clearly be 36 months longer than it reasonable?
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Note that the 60 months applies to the multi engine ATP and not the single engine ATP. it costs $5k to get qualified to take the multi ATP written, after which many pilots start looking for a job that will provide the flight training. Apparently the FAA believes that the current pilot market isn’t indefinite.

And no, I didn’t read the petition. Did the OP present statistics to support a change?
 
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I'm just trying to understand - in what world is studying confined to the period of time directly preceding the written test? Studying should be for learning, and there's no time limit for learning. Especially not in the "pilot world". Maybe if you frame it as positive, instead of "time to cram for your written test", your young pilots would be more likely to engage in studying throughout the two years they're waiting. Or you could try what my CFI and I did while I waited six months for my checkride to be rescheduled - have oral quiz times, talk about more advanced things based on simpler concepts, and things like that. If you have a lot of young pilots waiting for their sixteenth or seventeenth birthday, maybe make it a competition between them to see which one can maintain the longest "high score" streak to motivate them to keep studying.

For background, after I took an introductory flight, I immediately started reading all the free FAA books about pilot training. It was 10 months later before I took my first flight lesson, about 11 months after I started studying before I took my written, and I took my checkride 28 months after my first introductory flight. If you learn the material, you only need to review before the written test and before the checkride. I thought I was going to fail so hard when I walked into the classroom to begin my oral because I hadn't done much studying except casually reviewing stuff in the previous two or three months. Afterwards, the DPE told me that if he had to give grades for orals, he would have given me a 95%. I would never have been able to do that if I hadn't spent the previous two years studying.
 
SkyChaser said:
I'm just trying to understand - in what world is studying confined to the period of time directly preceding the written test? Studying should be for learning, and there's no time limit for learning. Especially not in the "pilot world". Maybe if you frame it as positive, instead of "time to cram for your written test", your young pilots would be more likely to engage in studying throughout the two years they're waiting. Or you could try what my CFI and I did while I waited six months for my checkride to be rescheduled - have oral quiz times, talk about more advanced things based on simpler concepts, and things like that. If you have a lot of young pilots waiting for their sixteenth or seventeenth birthday, maybe make it a competition between them to see which one can maintain the longest "high score" streak to motivate them to keep studying.

For background, after I took an introductory flight, I immediately started reading all the free FAA books about pilot training. It was 10 months later before I took my first flight lesson, about 11 months after I started studying before I took my written, and I took my checkride 28 months after my first introductory flight. If you learn the material, you only need to review before the written test and before the checkride. I thought I was going to fail so hard when I walked into the classroom to begin my oral because I hadn't done much studying except casually reviewing stuff in the previous two or three months. Afterwards, the DPE told me that if he had to give grades for orals, he would have given me a 95%. I would never have been able to do that if I hadn't spent the previous two years studying.
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True, but keep in mind that we ARE primarily talking about 14- and 15-year-olds here who have a studying problem. They probably still require direction and guidance in study techniques, which it appears the OP and his circle of pilots isn’t providing.
 
FixedWing said:
Speaking of studying ... try reading the linked Petition before commenting on it. From what I can tell, so far only one, or maybe two pilots posting a comment on this thread actually took the time to read it first.

The duration was set when the rule implementing the written was first promulgated in 1961. No public comment proceeded implementation. There is no evidence that 24 calendar months was based upon any sort of scientific consideration. And if it was, then why make the ATP written valid for 60 months when that would clearly be 36 months longer than it reasonable? Or are ATP brains somehow superior brains?

Stephen
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I did read the petition.

I still can't find any real reason to support it.

Yes, the 24 month window may have been arbitrary. But it seems reasonable, and similar to many other time limits in the regs (as discussed by others). Lots of other rules are also arbitrary - why 3 landings and why 90 days for currency? Why not 4 or 5, or 60 days or 120 days? Why a minimum of 40 hours for Private? Why 6 approaches in 6 months for instrument currency? Why 6 months/1 year/2 years/5 years for medical certificates? Etc. Lots of arbitrary rules out there, but you can't study and subject everything to extensive scientific review, as much as we'd like to.

If you're going to propose that the 24 month rule should be changed because it wasn't scientifically determined, then what scientific analysis did you do for your proposal? I assume none, it appears that the main thrust of your argument is that "the ATP was changed to 5 years, therefore the others should be too". But if science is your basis of argument, then you should be requesting the ATP be changed to a length based on scientific review as well. Perhaps such review would show it should be shortened back to 2 years... Or maybe such review would show they all should be 1 year, or 6 months. If you want to use "there was no science" as your argument, then you have to present some science to support your change.

The ATP Multiengine knowledge test 5-year duration is likely a concession to practical realities. To take the ATP Multi knowledge test, you must take a roughly $5000 prep course consisting of simulator time and CRM training. And many pilots are getting their ATP as part of their initial type rating in the airliner they will fly. There is so much extra training involved in this route that the ATP knowledge test is pretty much just a formality. So it doesn't seem unreasonable to me to extend the time on this one, preventing people from having to respend $5000 if they don't get hired within 2 years.

You keep referring to the 24-month window as "short". I just can't get behind this. 2 years is "short"? Heck, schools routinely run pilots through from zero time to CFI/II/MEI and actively teaching at the school in less than 2 years. 2 years is plenty of time to pass the written and the checkride. You mention scheduling of DPEs - yes that is a problem recently, but a problem measured in months, not years.

For your 14-year olds glider students, I think it's great that they are excited about aviation. But are you having them take the knowledge exam prior to solo (thus it expires before they're 16)? There's no requirement to do that, and if it's your policy as a CFI, then you need to look at alternate ways to have them learn the material. And you keep mentioning that they "have to delay studying". Really? I get that it would be hard to maintain a teen's interest if you said "here, study this test book/software for the next 2 years" - but there are other options for training and studying. Such as providing them with periodic quizzes on things that actually are important to the solo flying they're (hopefully) still doing those 2 years, and then hit the knowledge test maybe at 15 1/2 years old.
 
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.
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They do for older pilots. Annual Flight Review and Annual IPC, even if maintaining instrument currency.
 
FixedWing said:
Speaking of studying ... try reading the linked Petition before commenting on it. From what I can tell, so far only one, or maybe two pilots posting a comment on this thread actually took the time to read it first.

The duration was set when the rule implementing the written was first promulgated in 1961. No public comment proceeded implementation. There is no evidence that 24 calendar months was based upon any sort of scientific consideration. And if it was, then why make the ATP written valid for 60 months when that would clearly be 36 months longer than it reasonable? Or are ATP brains somehow superior brains?

Stephen
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You ask why ATP applicants are allowed 60 months. Minimally, an ATP applicant must be 23 year old and applicant passed the required FAA written knowledge and practical tests for private, the instrument, commercial and usually a multi engine add on. Most have passed 2 additional written knowledge tests for CFI(s) and another practical test(s) before applying for ATP.


Your argument is 16 year old glider applicant with 10 hours of flight time is equivalent and also should qualify for 5 years. Seriously?

I did read your petition. It is not compelling.

The glider test is the easiest test the FAA has. You are not being burdened. And if you knew any thing about FAA regulations you would realize your glider flight time qualifies as flight time for an airplane commercial certificate at age 18.
 
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MauleSkinner said:
I’m just trying to figure out what rock does one have to live under to solo at 14 and take a Private Pilot checkride at16?
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A rock with money under it. The age to solo a glider is 14 and 16 for the PPL.
 
MauleSkinner said:
You really don’t pay attention to what you post, do you?
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Obviously you read them…. “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.”

There is no XC requirement for a glider certificate and I was not referencing gliders.
 
Clip4 said:
Obviously you read them…. “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.”

There is no XC requirement for a glider certificate and I was not referencing gliders.
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Yup…that’s why I mentioned it.
 
Clip4 said:
No, you made a bad assumption. Where is he asking for a glider exemption to the 24 month rule? He is not, so my remarks are valid.
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So my assumption that you weren’t including gliders was invalid. Have a nice day.
 
RussR said:
I still can't find any real reason to support it.
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Fair enough. Everyone's entitled to their own opinion. As I said before, I appreciate that you and others here have disaffected me of the belief that most would have had a similar viewpoint to my own. I really should have known better.

But I'm also surprised at how many argue that the ATP student should receive different standards. The reasons given just seem like excuses to me. But then, what do I know? Clearly, I've been wrong before.

Stephen
 
FixedWing said:
Fair enough. Everyone's entitled to their own opinion. As I said before, I appreciate that you and others here have disaffected me of the belief that most would have had a similar viewpoint to my own. I really should have known better.

But I'm also surprised at how many argue that the ATP student should receive different standards. The reasons given just seem like excuses to me. But then, what do I know? Clearly, I've been wrong before.

Stephen
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Here's my opinion, worth exactly what you paid for it:

If your argument is that the time frame needs to be longer than 24 months as it can create a "squeeze" for young pilots who don't want to study - part of the responsibilities of being a pilot is having the proper amount of maturity to make good decisions. If a pilot is not mature enough to study even though he doesn't like it, I would argue he may not be mature enough to make PIC decisions like staying on the ground when he wanted to go somewhere and the weather turns bad. I would definitely encourage their CFIs or other mentor pilots to help make studying and retaining knowledge fun, but at the end of the day, maturity to make decisions to do things you don't want to do or to not do things you want to do is a very, very important skill for a pilot to have.

As far as the ATP, I have no personal knowledge of said training, but I have heard a little about it. ATP training is a completely different ballgame and I can understand why the rules might be different. In private pilot training, you have, in effect, three tests. Pre-solo, written, and checkride. In ATP training, you're getting tested a lot more often than that. Maybe the FAA should extend the private pilot expiry out to five years, and then require satisfactory completion of weekly or monthly quizzes to keep your knowledge current, to mimic ATP standards?
 
FixedWing said:
But I'm also surprised at how many argue that the ATP student should receive different standards. The reasons given just seem like excuses to me. But then, what do I know? Clearly, I've been wrong before.

Stephen
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You may have misunderstood me/us. I, at least, do not argue that the rules SHOULD be different for ATPs. I just acknowledge that they ARE, and suggest some reasons they may have been made that way. I would prefer them all to be the same, but don't lose sleep over the ATP one being different. I recognize it's likely just another example of practical realities affecting rulemaking, much like the whole "performing duties of PIC" allowance instead of "solo" for Commercial applicants. I don't like it, but I understand why it is.
 
FixedWing said:
Fair enough. Everyone's entitled to their own opinion.
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Thats the thing…as far as I can tell, you’re not presenting any real data to support a regulatory change, just your opinion.
And I’d be willing to bet that the FAA could come up with data as to what percentage of written tests expire and are retaken.
FixedWing said:
As I said before, I appreciate that you and others here have disaffected me of the belief that most would have had a similar viewpoint to my own. I really should have known better.

But I'm also surprised at how many argue that the ATP student should receive different standards. The reasons given just seem like excuses to me. But then, what do I know? Clearly, I've been wrong before.

Stephen
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I guess you should‘ve Responded to the NPRM.

1704892153065.jpeg
 
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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
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Can you tell me who "our members" is - in context?
 
FixedWing said:
But I'm also surprised at how many argue that the ATP student should receive different standards. The reasons given just seem like excuses to me. But then, what do I know? Clearly, I've been wrong before.
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I do not have an opinion on the 5-year ATP written expiration. Although it seems odd, when you consider the amount of training someone must go through [correction: usually goes through] to take a multiengine ATP practical test, the written is probably the easiest part. You could take that idea, and turn it into an argument for or against an increased time limit, depending on how you see it.
 
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dmspilot said:
I was thinking of the 121 environment. My mistake.
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The fact is that most pilots do their ATP-multi in conjunction with an air carrier training program, which is one of the stated reasons for the 60-month expiration.
 
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
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I agree with you sir my instrument written test is going to be expired sooner and I'm on Fireball to wrap my IFR check ride. Common FAA have mercy or us
 
pilotshashi said:
I agree with you sir my instrument written test is going to be expired sooner and I'm on Fireball to wrap my IFR check ride. Common FAA have mercy or us
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I’m confused; you’re trying to finish your IR and yet you’re still having trouble finding the downwind leg at an airport? Do I have that right?

How on earth did you pass your checkride for Private if you can’t enter a landing pattern?
 
Half Fast said:
I’m confused; you’re trying to finish your IR and yet you’re still having trouble finding the downwind leg at an airport? Do I have that right?

How on earth did you pass your checkride for Private if you can’t enter a landing pattern?
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You took the words out of my mouth..
 
Rgbeard said:
Can you tell me who "our members" is - in context?
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Poor cut-n-paste job. Guess I should have spent a few more seconds editing the post before clicking "post." Members are my fellow members at the Connecticut Soaring Association which operates out of KIJD. You're welcome to drop by almost any nice summer weekend.

Home | Connecticut Soaring Association

www.ctsoaring.org www.ctsoaring.org

Stephen
 
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