April 23 rd , 2014 Embry

- Riddle Aeronautical University Flight Department 3700 Willow Creek Road Prescott, Arizona 86301 U.S. Department of Transportation, Docket Operations West Building Ground Floor, Room W12

- 140 1200 New Jersey Avenue, SE. Washington, DC 20590 To Whom It May Concern : Embry

- Riddle Aeronautical University, holder of Air Agency Certificate Number BF8S032Q, is requesting exemption from 14 CFR Part 61 § 4 5 Paragraph ( a )(1)(i). The referenced rule requires a practical test applica nt provide an aircraft of the category, class, and type, if applicable, for which the applicant is applying for a certificate or rating. Embry

- Riddle requests authorization to conduct a portion of the end

- of

- course test for a Flight Instructor Certificate with an Airplane Single Engine class rating in a multiengine airplane. The latest version of FAA

- S

- 8081

- 6C requires a complex airplane be provided for the performance of takeoff and landing maneuvers, and appropriate emergency procedures. Embry

- Riddle feels that conducting such maneuvers in a multiengine airplane provides at least an equivalent level of safety as the current regulation and practical test standards provide. Specifically, Embry

- Riddle proposes teaching and evaluating the following tasks i n a multiengine airplane:
• AREA OF OPERATION: TAKEOFFS, LANDINGS, AND GO AROUNDS o Normal and Crosswind Takeoff and Climb o Short

- Field Takeoff and Maximum Performance Climb o Normal and Crosswind Approach and Landing o Go

- Around/Rejected Landing o Short

- Field Appro ach and Landing At a minimum, two takeoff and two landing tasks will be evaluated in the complex multiengine airplane, meeting the requirements of the practical test standards. As an option, the remaining tasks appropriate to a single

- engineU.S. Department of Transportation, Docket Operations April 17 th , 2014 Page 2 airplane may be conducted during the portion of the test conducted in a single

engine non

- complex aircraft.
• AREA OF OPERATION: EMERGENCY OPERATIONS o Systems and Equipment Malfunctions

 The applicant will exhibit instructional knowledge of at least three (3) of the equipment malfunctions, appropriate to the complex multiengine airplane used for the end

- of

- course test by describing recommended pilot action for:
• Smoke, fire, or both during ground or flight operations
• Fuel starvation
• Hydraulic malfunction
• Electrical mal function
• Door or window open in flight
• Inoperative or “runaway” trim
• Landing gear or flap malfunction The remaining required two (2) equipment malfunctions will be chosen from the list included in the practical test standards and conducted in a single

- engi ne non complex aircraft. The combined result of the test will include five (5) distinct equipment malfunctions across both complex and non

- complex aircraft. Embry

- Riddle feels strongly that conducting the portion of the evaluation as described above in a multiengine airplane provides, at a minimum, an equivalent level of safety. Embry

- Riddle’s rationale for requesting this exemption is an attempt to provide the safest learning environment to our students. Single

- engine complex aircraft suitable to flight training are all but nonexistent in the current market. The advent of composite aircraft and efforts to reduce drag in landing gear systems has made single

- engine complex aircraft an item of our past. Schools are required by law to provide students with single

engine complex aircraft, many of which are much older than the students and instructors flying them, have amassed several thousand flight hours, and are being forced out of operation by poor product support and high operating costs, to mention noth ing of the increased risk of operating older, higher

- time aircraft. We appreciate your attention to this matter. If you have any questions or care to discuss this matter further, please contact me at 928.777.4358 or testaj@erau.edu. Thank you ,

Jared T esta Chief Instructor