April 23rd, 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 § 45 Paragraph (a)(1)(i).

The referenced rule requires a practical test applicant 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 in 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 Approach 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-engine 
U.S. Department of Transportation, Docket Operations

April 17th, 2014

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airplane may be conducted during the portion of the test conducted in a singleengine 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 malfunction

• 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-engine noncomplex 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 singleengine 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 nothing 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 Testa

Chief Instructor