AFS-13-194-E

May 21, 2013

 Exemption No. 10775

 Regulatory Docket No. FAA-2013-0100

Mr. Tim Palcho

Chief Instructor

Kent State University

College of Technology

P.O. Box 5190

Kent, OH 44242-0001

Dear Mr. Palcho:

This letter is to inform you that we have denied your petition for exemption. It transmits our 

decision and explains its basis.

The Basis for Our Decision

By letter dated January 24, 2013, and supplemental information dated February 20, 2013, you 

petitioned the Federal Aviation Administration (FAA) on behalf of Kent State University

(KSU) for an exemption from §§ 61.43(a)(1) and 61.45 of Title 14, Code of Federal 

Regulations (14 CFR) to the extent necessary to allow KSU students to use a noncomplex 

aircraft when taking a FAA practical test to add an airplane single-engine rating to their 

Certified Flight Instructor (CFI) certificates.

The FAA has determined that good cause exists for not publishing a summary of the petition

in the Federal Register because this is not a precedent-setting petition, and any delay in acting 

on this petition would be detrimental to KSU.

The FAA has issued denials of exemption in circumstances similar in all material respects to 

those presented in your petition. The petitioners in Denial of Exemption Nos. 9651 and 

10442 (copies enclosed) also cited increasing aircraft scarcity and operating costs for certain 

single-engine complex aircraft. In the FAA’s response to those petitions, we found that the 

petitioners were unable to show that their proposed operations met an equivalent level of 

safety to that of the rule. The FAA has found that applicants for the CFI certificate with a 

single-engine rating need to demonstrate that they have the skills to execute and teach 

preflight inspection, takeoff, landing, and emergency procedures for single engine aircraft 

(which includes complex single-engine aircraft). The only way to fulfill this requirement is 

to demonstrate the skill in an actual complex single-engine aircraft.
2

In your petition, you asked if applicants adding a single-engine rating to their CFI certificates 

are required to provide a complex single-engine aircraft for the practical test. Page 11, 

paragraph 3 of the FAA Practical Test Standards (PTS) describes the aircraft and equipment 

required for the practical test, “...be capable of performing all appropriate Tasks for the flight 

instructor rating sought...” and “a complex airplane must be furnished for the performance of 

takeoff and landing maneuvers and appropriate emergency procedures.” The applicant must 

demonstrate the ability to perform and instruct appropriate emergency procedures (that is, 

single-engine emergency procedures) in a complex airplane.

We find that a complex aircraft is required for any CFI practical test for an airplane singleengine rating (initial or added single-engine airplane rating). The PTS rating table (found on 

page 21 of the Flight Instructor Practical Test Standards, FAA-S-8081-6D) shows that certain 

procedures requiring a complex airplane are required on the practical test for both the initial 

CFI certificate and the practical test for an added single-engine airplane rating. 

Having reviewed your reasons for requesting an exemption, I find that:

• They do not differ materially from those presented by the petitioners in the enclosed 

Denials of Exemption Nos. 9651 and 10442;

• The reasons stated by the FAA for denying the enclosed Denials of Exemption 

Nos. 9651 and 10442 also apply to the situation you present; and

• A grant of exemption would not be in the public interest.

Our Decision

Under the authority contained in 49 U.S.C. 40113 and 44701, which the FAA Administrator 

has delegated to me, I hereby deny the petition of Kent State University for an exemption 

from 14 CFR §§ 61.43(a)(1) and 61.45.

Sincerely,

/s/

John S. Duncan

Deputy Director, Flight Standards 

 Service

Enclosures