I enjoyed both perspectives in the July issue of Flying [Dogfight]. Who can argue with the goal of preventing the tragedy described by Mr. King, and, of course, Mr. Machado makes a lot of sense with his call for some evidence showing ACS efficacy prior to wide-scale adoption. But neither viewpoint touched on my biggest concern. Staying objective while conducting a practical test can be quite challenging. Because so many of the risk-management elements are so subjective, discussion is the only way they can be broached. So the risk-management section becomes a discussion; it becomes teaching, not testing. And once this framework is established, my experience tells me that a slippery-slope effect will allow this subjectivity to creep into both the skill and knowledge areas of each task. ACS may seem like a step toward safety, but I fear the long-term damage it will inflict on the testing process will more than negate any positive fruits it brings to aviation.
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