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U.S. Department of Transportation - Docket Operations • •'^pOPiTATi^ Ji 1 ^ 

West Building Ground Floor, Room WI2-140 , r ; "ji^rKnl iCi -S 

1200 New Jersey Avenue SE 

Washington, DC 20590 MJ ;;.;1 \2 '\ 'v 3'^1 

John D. Odegard School for Aerospace Sciences 

Attn: Dick Schultz - Director of Flight Operations 

2784 Airport Drive 

Box 9051 - Flight Operations 

Grand Forks, ND 58203-9051 

(701)777-7846 

schult2(fl).aero.und.edu 

SUBJECT: PETITION FOR GRANT OF EXEMPTION 

Pursuant to title 14 of the Code of Federal Regulations (14 CFR) Federal Aviation 

Regulation (FAR) 11.61, the John D. Odegard School of Aerospace Sciences at the 

University of North Dakota (UND) is petitioning for exemption from the complex 

airplane requirement stated in the FUghi Instructor Airplane Single-Engine Practical Test 

Standards, to the extent necessary to permit UND to conduct all tasks required on the 

flight instructor airplane single-engine practical test in a noncomplex single engine 

airplane. 

In August 2009, the FAA published the final rule to 14 CFR Parts 61, 91, and 141, "Pilot, 

Flight Instructor, and Pilot School Certification" (Docket No. FAA-2006-26661). 

Referencing that final rule, revision No. 99 Part 141 allows "the commercial pilot 

certification course for the single engine airplane rating to be approved with the use of 

either a complex single engine airplane or a complex multiengine airplane." No complex 

airplane training is required for flight instructor certification in either Part 61 or Part 141. 

Only the Practical Test Standards have this requirement. 

NATURE AND EXTENT OF RELIEF 

The Flight Instructor Airplane Single-Engine Practical Test Standards (FAA-S-8081-

6CS), under the title Aircraft and Equipment Required for the Practical Test, on page 10, 

subpart (3), states; 

"Be capable of performing all appropriate TASKS for the flight instructor rating 

sought and have no operating limitations, which prohibit the performance of those 

TASKS. A complex airplane must be fiamished for the performance of takeoff 

and landing maneuvers, and appropriate emergency procedures." 
The extent of relief requested, is to allow UND to conduct the *takeoff and landing 

maneuvers, and appropriate emergency procedures" in a noncomplex single-engine 

airplane while performing the Flight Instructor Airplane Single-Engine Land end of 

course stage check in our approved Part 141 training course outline. 

PUBLIC INTEREST AND EQUIVALENT LEVEL OF SAFETY BENEFITS 

The complex single engine airplane has become a financial burden to most flight training 

organizations without providing a great benefit to flight training and safety. Today, most 

aircraft manufacturers are no longer offering complex single engine airplanes. As a 

result, flight training organizations bear the financial burden of maintaining older less 

reliable airplanes in order to meet FAA requirements. This financial burden is then 

passed down to the student in the form of increased flight training fees. 

High levels of student debt are a great concern in today's aviation industry. The cost of 

flight training is influencing the levels of aviation interest in tomorrow's student pilots. 

We all have the shared responsibility to provide quality aviation education at a reasonable 

cost and promote aviation. One way to reduce that cost is to allow the use of a lower 

costing noncomplex single engine airplane in flight instructor training and certification. 

In UND's specific case, we are asking to replace the training required in a PA28R-201 

Piper Arrow with a Cessna 172S. The 75% best power setting allows the Cessna 172S to 

bum 25.2% less fiiel than the PA28R-201 Piper Arrow. This reduced fiael bum results in 

an overall reduced consumption of fossil fiaels and lower operafing cost passed on to the 

student. This benefits, the environment, the University, and the student. 

As an aircraft ages the maintenance hours tend to increase. At UND, the PA28R-201 

Piper Arrows currenriy have a 208% higher maintenance labor hour to flight hour ratio 

than the Cessna 172S, This again translates into higher operating costs that are passed 

onto the student. Replacing the aircraft to avoid these higher maintenance expenses is 

not always favorable because the replacement cost of complex single-engine aircraft is 

also higher than that of the Cessna 172S. 

Not providing complex airplane experience in the flight instructor certification course is 

not a hazard to safety. The FAA currently allows a flight instructor to issue a high 

performance airplane endorsement as long as they possess the same endorsement. Most 

of these flight instructors did not receive any high performance airplane experience in 

their flight instructor training. Yet, they are providing the instruction and issuing an 

endorsement. A complex airplane endorsement could be handled the same. 
SUMMARY 

As required by FAR 11.81(f), a summary of the petition is as follows: 

The John D. Odegard School of Aerospace Sciences at the University of North Dakota 

requests an exemption fi^om the complex airplane requirement stated in the Flight 

Instructor Airplane Single-Engine Practical Test Standards authorizing UND to conduct 

all tasks required on the flight instructor airplane single-engine end of course stage check 

in a noncomplex single-engine airplane. 

Sincerely, 

Dick Schultz 

Director of Flight Operations 

University of North Dakota