Complex Aircraft No Longer Required for Practical Tests

FAA has published Notice N8900.463, which removes the requirement for applicants to provide a complex aircraft (i.e., an airplane with retractable landing gear, a controllable-pitch propeller, and flaps) for the commercial pilot SEL and flight instructor-airplane practical tests.

Note, however, that this change in policy affects only practical tests, not the training and experience requirements for commercial pilots and flight instructors. Those requirements, which are specified in 14 CFR Part 61, may change if an NPRM from May 2016 is enacted as a final rule.

FAA published the final rule associated with that NPRM on June 27, 2018. You can read about it here. The change to 14 CFR Part 61 included in the new “addresses changing technologies by accommodating the use of technically advanced airplanes as an alternative to the use of older complex single engine airplanes for the commercial pilot training and testing requirements.”

For more background on these proposed regulatory changes, see FAA Proposes Significant Rule Changes here at BruceAir.

Specifically, [this notice] outlines the policy which no longer requires applicants for a commercial pilot certificate with an airplane single-engine rating to provide a complex or turbine-powered airplane for the associated practical test and no longer requires applicants for a flight instructor certificate with an airplane single-engine rating to provide a complex airplane for the practical test…[T]here are far fewer single-engine complex airplanes available to meet the ACS/PTS requirement, and the single-engine complex airplanes that are available are older airplanes that are expensive to maintain. Additionally, the FAA finds that removing the commercial pilot ACS requirement to furnish a complex or turbine-powered airplane and removing the flight instructor PTS requirement to furnish a complex airplane will achieve the same objectives. The FAA has determined that removing these ACS/PTS requirements will significantly reduce costs for persons pursuing a commercial pilot or flight instructor certificate by allowing applicants to utilize less-expensive airplanes on the practical test that are not complex or turbine-powered.

The notice continues:

The FAA has determined that any airplane may be used to accomplish the tasks prescribed in the initial commercial pilot with an airplane single-engine rating practical test or a flight instructor with an airplane single-engine rating practical test, provided that airplane is capable of accomplishing all areas of operation required for the practical test and is the appropriate category and class for the rating sought. Therefore, the airplane used for the practical test must still meet the requirements specified in § 61.45.

However, the notice also explains that:

There is no change to the complex airplane training and endorsement requirements of § 61.31(e) or to the commercial pilot aeronautical experience requirements of § 61.129(a)(3)(ii) or part 141 appendix D.

As noted above, flight schools will still need complex aircraft so that commercial students can acquire 10 hours of complex time.

But commercial students won’t necessarily need to spend those 10 hours practicing lazy 8s, chandelles, power-off 180 landings, etc. to prepare for the practical test. Instead, they can use the complex aircraft to fly cross-countries, build night-flying hours, and so forth. They just need to log 10 hours and get the complex–and, depending on the airplane used–high-performance endorsements. They can then practice and prepare for the checkride in any aircraft that is capable of all the areas of operation in the ACS and that meets the requirements for the practical test. This change should help with the maintenance and other costs incurred when operating complex aircraft for training.

CFI candidates, who presumably have acquired the 10 hours of complex time as part of their training for the commercial certificate, can accomplish all of their training and preparation for the initial CFI-A with a SEL rating in any suitable aircraft.

This flexibility will save CFI candidates money, and it will make it much easier for flight schools to provide aircraft both for training and practical tests. Many flight schools have only one or two complex aircraft available, making scheduling difficult. And saving wear-and-tear on complex aircraft will probably improve their dispatch availability and lower maintenance costs.

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