U.S. Department of Transportation

FEDERAL AVIATION

ADMINISTRATION

FINAL REGULATORY EVALUATION

Pilot in Command Proficiency Check and Other Changes to 

the Pilot and Pilot School Certifications Rules

(14 CFR 61, 91, and 141)

OFFICE OF AVIATION POLICY AND PLANS

OPERATIONS REGULATORY ANALYSIS BRANCH

APO-300

November 4, 2010
TABLE OF CONTENTS

I. The Final Rule – Introduction and Background______________________ 1

II. Benefits and Costs of Compliance _________________________________ 7

III. Summary of Total Net Costs and Benefits_________________________55
1

I. The Final Rule – Introduction and Background

The FAA has determined the final rule amendments for parts 61, 91 and 141 are needed 

to respond to changes in the aviation industry and to further reduce unnecessary

regulatory burdens.

This section describes the changes that were analyzed. Section II examines the changes 

with a more detailed look at costs, cost savings and benefits. Section III summarizes

costs and benefits. 

The FAA examined benefits and costs over a 10 year period because this time period is 

sufficient to evaluate the benefits and costs of the final rule.

This final rule amends the FAA’s regulations concerning pilot, flight instructor, and pilot 

school certification by

A. Requiring proficiency checks for a pilot who acts as pilot in command (PIC) of 

single-piloted turbojet type certificated powered airplanes and for a pilot who acts 

as pilot in command of a multi-seat experimental turbo jet-powered jets carrying 

passengers 1;

B. Allowing conversion of a foreign pilot license to a U.S. pilot certificate; 

C. Allowing pilot schools to use Internet-based training without requiring the schools 

to have a physical ground training facility, but including several requirements that 

those schools must fulfill; 
2

D. Allowing applicants to apply for a private pilot certificate and instrument rating 

concurrently and allowing pilot schools and provisional pilot schools to apply for 

a combined private pilot certification and instrument rating course.

E. Expanding the use of airplanes with a single, functioning throwover control wheel 

for providing expanded flight training. This change to § 91.109 parallels the long 

standing grants of exemptions that the FAA has issued to many petitioners for use 

with certain airplanes with a single functioning throwover control wheel. 

F. Revising the definition of “complex airplane” in § 61.1 to include airplanes that 

are equipped with a full authority digital engine control system.

Changes with Minimal Cost and Benefit Impacts that Are Not Quantified

In this final regulatory evaluation, the FAA estimates costs for changes B, C, E and F as 

minimal. There are no costs to implementing the Implementation Procedures for 

Licensing (IPL) and minimal costs to allowing conversion of a foreign pilot license to a 

U.S. pilot certificate (B). It is hoped that these agreements will lead to less work for both 

the pilots and the aviation authorities and more cooperation could engender cost savings 

and maintain the existing level of safety. The change allowing pilot schools to use 

Internet-based training programs without a physical ground training facility (C) will 

relieve part 141 schools from having to meet heating, lighting, ventilation, and location 

requirements for ground training space and is therefore cost relieving. This change also 

codifies current practice by adding reporting, tracking and security requirements to part 

141 that the FAA currently requires Internet providers adhere to. The change to §91.109 

(E) will relieve the petitioner and the FAA of the paperwork burden associated with 

 

1 Unless the passengers are authorized designees, instructors, or FAA personnel.
3

requesting and granting exemptions. The change in definition of “complex airplane” 

could result in cost savings if flight schools will no longer have to keep an inventory of 

two different types of airplanes to meet the commercial pilot certification and flight 

instructor certification requirements. Instead flight schools may be able to purchase or 

lease only one type of airplane to meet these certification requirements because many 

newly manufactured aircraft will satisfy the new definition of complex airplane. 

However, the FAA did not estimate cost savings of this provision since it had insufficient 

data to estimate the number of flight schools that will benefit from this change in 

definition.

Changes that Have Quantified Cost and Benefit Impacts

The following paragraphs describe in more detail those changes that have quantified cost 

and benefit impacts.

The current § 61.58 PIC proficiency check is only required of PICs in aircraft that are 

type certificated for and are designed for more than one required pilot. This rule will 

extend the § 61.58 proficiency check requirement to pilots of single-piloted turbojet 

powered aircraft and to pilots of multi-seat experimental jets that are carrying 

passengers.

2

When § 61.58 was originally adopted, very light jets (VLJs) and other single-piloted 

turbojet-powered aircraft did not exist nor were they conceived of by manufacturers or by 

the FAA. Now there are a number of type certificated turbo-jets that can be flown with a
4

single pilot. The rule will not require pilots of single-seat experimental jets or pilots of 

multi-seat experimental jets not carrying passengers or carrying authorized designees, 

instructors, or FAA personnel to undergo proficiency checks. 

This change will affect pilots who serve as PICs in turbojet powered aircraft that are type

certificated for single pilot operations. It will also affect pilots in command of multi-seat 

experimental jets carrying passengers.

The rule as proposed by the NPRM would have required that every 24 months the 

proficiency check be in the experimental jet aircraft that the pilot is serving in as pilot in 

command.

This caused concern among commenters to the NPRM that the rule could prove 

expensive to those experimental jet pilots who were authorized in several experimental 

jets. 

Under the final rule, pilots of experimental turbojet aircraft that possess more than a 

single seat either by original design, or through modification, or who carry passengers 

will be allowed to perform their annual proficiency checks in any turbojet-powered 

aircraft, and will not be required to have the check in an experimental jet, nor will the 

proficiency check examiner have to be an Experimental Aircraft Examiner (EAE). Pilots 

of experimental turbojet aircraft that, through original design, possess only a single seat, 

will be exempt from this rule when operating such aircraft. This should alleviate the 

 

2 Unless the passengers are authorized designees, instructors, or FAA personnel.
5

commenters’ concerns since one check annually in any turbojet aircraft by any authorized 

examiner will fulfill the requirement. This rule change corresponds to Proposal 2 in the 

NPRM Preamble and will modify § 61.58(a)(1) and (2), (d)(1) through (d)(4) and add 

§61.58(d)(5) and §61.58(e).

The Agency will allow an applicant for an instrument rating to apply concurrently for a 

private pilot certificate that is appropriate to the instrument rating sought. This change 

corresponds to Proposals 3 and 16 listed in the NPRM Preamble and will modify

§ 61.65(a)(1), (d)(1), (e)(1), and (f)(1), and add new paragraph (g) as well as introduce a 

new Appendix, Appendix M, to Part 141, which will establish a combined private pilot 

certification and instrument rating course at part 141 flight schools.

In this final regulatory evaluation, the Agency quantifies the cost of proficiency checks, 

and the cost savings associated with allowing applicants to obtain a combined private 

pilot and instrument rating certification concurrently. Over ten years (2011 through 

2020), the estimated net total costs sum to approximately $36.6 million ($25.3 million 

discounted by 7% and $31.0 million discounted by 3%). Total estimated benefits over 

the ten years are approximately $96.5 million ($66.7 million discounted by 7% and $81.8 

million discounted by 3%). 
6

The results of this analysis are summarized in the table below.
7

II. Benefits and Costs of Compliance

Section I described changes to parts 61 and 141. In this section, these changes will be 

further discussed and their cost and benefit impact analyzed. The lettering schema used 

in the previous section, of A. through E., with each letter corresponding to a specific 

change, will be used in this section.

In this analysis, the FAA estimated future costs for a 10-year period, from 2011 through 

2020 because this time period is sufficient to evaluate the benefits and cost of the final 

rule. As required by the Office of Management and Budget, the present value of this 

stream of costs was calculated using discount factors of 3% and 7%. Benefits and costs 

in this analysis are in 2010 dollars.

Benefit Estimates of Changes to the Current Code of Federal Regulations

Benefits of avoiding accidents are expected to be $96.5 million ($66.7 million discounted 

by 7% and $81.8 million discounted by 3%.).

Cost Estimates of Changes to the Current Code of Federal Regulations

Total quantifiable costs of the changes, over 10 years, sum to approximately $38.4 

million, with cost savings of approximately $1.8 million for a net cost of $36.6 million

($25.3 million discounted by 7% and $31.0 million discounted by 3%).
8

Part 61 only Changes – § 61.58 Proficiency checks

The rule will require proficiency checks for PICs of single-piloted type certificated 

turbojet-powered aircraft and for pilots of multi-seat experimental jet aircraft carrying 

passengers. Currently only persons serving as PIC of aircraft that are type certificated for 

more than one required pilot flight crewmember are required to take annual proficiency

check rides. This proficiency check ride change corresponds to Proposal 2 in the NPRM 

Preamble and will modify § 61.58 to require that pilots of single-piloted certificated 

turbojet powered aircraft and pilots of multi-seat experimental turbojet powered aircraft 

carrying passengers complete annual proficiency checks. 

The final rule change differs from the change proposed in the NPRM by lessening the 

burden on pilots of experimental jets by allowing these pilots to complete their 

proficiency checks in any turbojet powered aircraft and by no longer requiring that the 

proficiency checks be in the particular experimental aircraft in which the pilot will serve 

as pilot in command. The addition of § 61.58(d)(5) allows experimental pilots these 

additional options. The final rule also differs from the NPRM by: (1) permitting pilots 

of multi-seat experimental jets who have not received a proficiency check within the past 

12 months to continue to operate these aircraft as long as they don’t carry passengers 

other than persons authorized by the Administrator and (2) excluding single-seat 

experimental jets from the requirement. These changes are indicated in § 61.58 (e) and 

(f).
9

To estimate total costs of the proficiency checks we multiplied the estimated number of 

pilots taking proficiency check rides in an aircraft by the estimated cost of the check ride. 

Assumptions and Data

Not every pilot who acts as pilot in command of a single-piloted turbojet-powered 

aircraft will incur the costs of a check ride as a result of this rule. Many pilots of typecertificated aircraft take recurrent training to meet insurance requirements and take this 

training at part 142 training centers where the training occurs in a simulator and the 

school will offer the pilot a free proficiency check at the conclusion of the training3. We 

estimate that this applies to 90% of the pilots operating single pilot certified typecertificated jets. The remaining 10% of these pilots will take proficiency checks in an 

aircraft. The assumptions below apply to pilots who are taking proficiency checks in an 

aircraft. 

The following assumptions are independent of whether the aircraft is type-certificated or 

experimental. 

 Time required for proficiency check– 2 hours ground, 1- 2 hours flight;

 $37.20 – airman’s time per hour;

4

 

3 Annual recurrent training is required by insurers. Most of the time insurance companies require the 

recurrent training take place at a school, in a simulator. If this is the case, the cost to add proficiency check 

is minimal or zero. Sometimes insurers will accept that pilots take recurrent training in a airplane. The 

cost to add a proficiency check for the pilots training in an aircraft will not be minimal because the costs of 

an examiner and time in the aircraft will be incurred.

4

Economic Values for FAA Investment and Regulatory Decisions, A Guide, GRA, Inc., Final Report, 

Revised October 3, 2007, pg. EJ-3. 
10

 Travel costs for the pilot and examiner will be the same. We use an average 

estimated round trip airfare of $3445, $92 for lodging and $44 for food per day. 

 50% of pilots are due for a flight review every year and will substitute the 

proficiency check for the flight review.

The following data and assumptions are associated with proficiency check rides in single 

pilot type-certificated turbojets and apply to the 10% of pilots of type certificated jets

who complete checks in aircraft (and not those completing their recurrent training at a 

part 142 training center.)

Assumptions for those taking proficiency checks in a type certificated aircraft with an 

examiner;

 Average operating cost per hour for type-certificated jets = $832 6

 Examiner cost for proficiency check in a type certificated aircraft can range from 

$800 to $3,000, average = $1,630 per check ride7;

 Of the pilots who complete the check in an aircraft, 90% take the check in their 

own aircraft, or an aircraft they have access to, 10% rent the aircraft; 

 Aircraft rental cost for proficiency check ranges from $1,800 to $4,800 for 

checkride including fuel8, average = $3,200;

 

5

FAA Forecast Branch.

6

Source: Aviation Week Intelligence Network, Aircraft Operating Costs Guide, Business & Commercial 

Aviation, August 1, 2009. We took a weighted average of the variable operating cost for each of the type 

certificated aircraft. 

7 Data is based on discussions with Pilot Proficiency Examiners (PPE).

8 Discussion with PPEs.
11

The following data and assumptions are relevant to check rides in experimental jet 

aircraft. 

Experimental Jets

As the rule allows pilots to take the tests in any jet aircraft we expect pilots will choose 

minimal cost compliance, i.e., only use an experimental jet if cheaper.

 Operating costs for a proficiency check in an experimental jet range from $930 to 

$3,250 9;

 Examiner cost for a proficiency check in an experimental jet aircraft can range 

from $750 to $2000 per check with an average of $1,273 10 per checkride

 Ninety percent of pilots take a proficiency check in their own aircraft, or an 

aircraft they have access to, 10% rent the aircraft; 

 Cost to rent an experimental jet aircraft for a proficiency checkride ranges from 

$1,400 to $7,250 for the proficiency check including fuel, with an average of 

about $4,000 per check ride 11;

Cost of Proficiency Checks

Existing FAA requirements for a § 61.58 proficiency check are detailed in 8900.2 

To complete a proficiency check, the pilot has to hire a pilot proficiency examiner (PPE), 

rent time in an aircraft or complete the check in a simulator as part of the recurrent 

training, or if using his or her own aircraft, incur operating costs including fuel and 

 

9 Based on comments to the NPRM and discussions with examiners.

10 Based on data offered from comments to the NPRM and discussions with Experimental Pilot Examiners.
12

maintenance. Some pilots will need to travel to the test site and will therefore incur 

travel costs, or pay for the costs of the examiner traveling to the pilot’s location. Time 

spent by the pilot taking the proficiency check also has a cost as does time traveling to 

the site of the check ride. Discussions with examiners indicated that an examiner might 

charge up to $1,000 or more for a travel day not including expenses such as airfare or 

lodging. 

Cost of Proficiency Check Ride in Type Certificated Jets

We estimated low, high and most likely compliance cost for those pilots taking the check 

in a type certificated turbojet powered aircraft. The lowest cost would occur if a pilot 

uses their own aircraft, for the check ride and lives close enough to the examiner such 

that no travel costs were incurred. The examiner cost would be at the low end of the 

range of data we collected ($800), a check ride would only take an hour of flight time so 

the cost of using one’s own aircraft would be $830 and the value of the time to take the 

check ride would be $149 (4 hours total time for the pilot). The low cost is estimated at 

$1,780 per check ride. 

The high cost uses the high end of the examiner cost range ($3,000), and assumes the 

pilot rents an aircraft at $4,800 for the check ride. The examiner will have to travel to the 

pilot and will take a total of 3 days (one day out, one day back when giving the check

ride). The travel expenses will include two nights lodging and three days food. The 

 

11 Ibid.
13

high cost is an estimate of $10,730 per check ride providing plenty of incentive for a pilot 

to reduce costs.

For the most likely estimate we use an average charge for the examiner to give the check

ride 12 of $1,630, and we assume the examiner travels an average of 5 hours to get to the

location that the check ride will be given, at an additional hourly rate of $100. We 

assume the examiner can do this in one day and only incurs expenses for round trip 

transportation and food for one day. We estimate that ninety percent of check rides

completed in an aircraft are given in the pilot’s aircraft and 10% completed in an aircraft 

are given in a rental aircraft so we weight the average aircraft operating cost by 90% and 

the average aircraft rental by 10%. The details of the costs are presented in the Table 1.

Table 1 Costs of Proficiency Checkrides in Type Certificated Jets
14

Cost of Proficiency Check in Experimental Jets

We estimated low, high and most likely cost for check rides in experimental jets. The 

lowest cost (best case) would occur if a pilot used their own aircraft for the check ride 

and lived close enough to the examiner and the airport that no travel costs were incurred. 

The examiner cost would be at the low end of the range of data collected ($750), the cost 

of using one’s own aircraft would be at the low end of the data collected ($930 for the 

check ride) and the value of the time to take the check ride would be $149 (four hours 

total time for the pilot). The low cost is estimated at $1,830 per check ride. 

The high cost uses the high end of the examiner cost range ($2,000), the pilot will rent an 

aircraft at $7,250 for the check ride. The examiner will have to travel to the pilot and will 

take a total of 3 days (one day out, one day back when giving the check ride). The travel 

expenses will include two nights lodging and three days food. The high cost is estimated 

at $12,059 per check ride.

For the most likely estimate, we use an average charge for the examiner to give the check

ride 13 of $1,270 if the check ride is given in an experimental jet, and we assume the 

examiner travels an average of 5 hours to get to and from the location that the check ride 

will be given, at an additional hourly rate of $100. We assume the examiner can do this 

in one day and only incurs expenses for round trip transportation and food for one day. 

Ninety percent of the time the check ride is given in the pilot’s aircraft and 10% of the 

 

12 Based on discussions with Pilot Proficiency Examiners.

13 Based on discussions with Pilot Proficiency Examiners.
15

time the check ride is given in a rental aircraft, so we weight the average aircraft 

operating cost plus the cost of an EAE by ninety percent and the average experimental jet 

aircraft rental charge plus the cost of a PPE by 10%. The details of the costs are 

presented in Table 2.

Table 2 Costs of Proficiency Checkrides in Experimental Jets

Flight Reviews Offsetting the Costs of Proficiency Checks

However, since a proficiency check ride can satisfy the two hour flight review required 

biennially by § 61.56 (c) of the CFR, pilots taking an annual proficiency check ride will 

not have to incur the costs of the flight review. We assume that every year, 50% of the 

pilots who will have to have a proficiency check will be due for their flight review. 

These pilots will save the costs of the flight review because they can use the proficiency

check to fulfill the flight review requirement. In calculating costs of the flight review we 

use the average cost of an instructor and the average cost of a non-complex aircraft, (such 
16

as a Cessna 172). We estimate the cost of the flight review is $255 as indicated in Table

3. Further, since the pilot will no longer need to take time to do the flight review we 

subtract two hours of pilot time cost ($74.40 14) from the total cost of the proficiency

check. Therefore since this cost will not have to be incurred because the pilot will be 

taking a proficiency check and will not need a flight review, to derive the net cost 

attributed to the rule in a year the pilot is required to take a flight review we subtract $329

($255+$74) from the cost of the check ride ($4,079 - $329 = $3,750 for a type 

certificated jet and $4,694-329 = $4,365 for an experimental jet). 

Table 3 Cost of a Flight Review

Therefore, every year 50% of the pilots incur the full costs of the check ride, and 50% of 

pilots incur incremental cost of the check ride which is the cost of the check ride less the 

cost of a flight review.

15

 The net costs of the proficiency checks in the year a pilot is 

taking a flight review is $3,750 for a type certificated jet and $4,365 for an experimental 

jet. 

 

14 $37.20 times 2.

15 We assume that a pilot taking a flight review would take the flight review at a school close to home and 

would incur little or no travel expenses. Therefore, travel expenses associated with a proficiency check are 

still included as a cost of the rule even in the year the pilot would have taken the flight review. 
17

Estimates of the Number of Additional Pilot in Command Proficiency Checks

In the following paragraphs we estimate the number of additional pilot in command 

proficiency checks that will be required because of this rule. Pilots who act as pilot in 

command of a single-piloted, turbojet-powered type certificated aircraft are not currently

required by the Code of Federal Regulations (CFR) to undergo proficiency checks, but 

will be with this rule. Also pilots of multi-seat experimental jets will be required to 

undergo proficiency checks with this rule but are not currently required to do so. We 

present our logic and assumptions for estimating proficiency checks for pilots of type 

certificated jets and pilots of multi-seat experimental jets below.

The paragraphs immediately below discuss our methodology for estimating the number 

of additional pilot proficiency checks in type certificated jets that will be required 

because of this rule.

Methodology for Type Certificated Jets

 Estimate total number of type certificated jets certified for single pilots that 

are registered in the U.S. and increase by 4.3% annually; 

 Subtract jets that are operated under provisions that require annual proficiency

checks that will satisfy § 61.58;

 Multiply resulting number of jets by 1.5 16 (average pilots per jet) to derive 

number of proficiency checks required by rule;

 

16 As we received no comments to the contrary, we accept our NPRM assumption that that each turbojet 

would be flown by 1.5 pilots on average.
18

 Determine that insurance requirements result in an estimate 90% of pilots who 

at conclusion of insurance-required recurrent training may be able to take 

proficiency checks for minimal or zero cost;

 Multiply number of proficiency checks required by rule by 10% to derive 

number of proficiency checks to be completed in an aircraft;

 Estimate cost of proficiency checks in a type certificated aircraft;

 Estimate net cost of proficiency checks in year of flight review;

 Multiply 50% of estimated number of proficiency checks to be completed in 

an aircraft by estimated cost of proficiency in an aircraft and 50% by net cost 

of proficiency check in flight review year.

Estimated Number of Proficiency Checks for Pilots of Type Certificated Jets:

To estimate the number of pilot proficiency checks we first identified type certificated 

turbo-jets that are certificated to be flown single-pilot. GAMA provided us the number of 

deliveries of each of these models as of the end of 2009. This list does not include the 

Cessna 550 Bravo and the Cessna 560, which are not certificated to be flown single pilot, 

but which both operate under single pilot exemptions. Pilots of aircraft (Cessna 550 and 

560) operating under the single-pilot exemptions undergo annual proficiency checks 

under the terms of the exemptions, therefore the rule will not impose additional costs to 

these pilots. The table below indicates deliveries as of the end of 2009 of aircraft 

registered in the U.S. 

 
19

Table 4 Number of Single Pilot Type-Certificated Turbojets Registered in U.S.

As of December 2009

Source: GAMA

Some of the aircraft identified above are operated under current provisions that require the 

pilot in command of that aircraft to undergo proficiency checks that will satisfy § 61.58 
20

(61.58 (c)). Aircraft that are operated under these provisions will be removed from the 

single pilot certificated aircraft count under the assumption that they will only be piloted 

by those pilots who are required to have annual proficiency checks under the current 

regulations. 17 

Using the Operations Safety System database (OPSS) we procured a count of aircraft that 

are operated under provisions of the current CFR that require proficiency checks for 

single pilot in command that will satisfy §61.58. These provisions include: parts 135, 

and 91 K. Since pilots operating these aircraft under those provisions are required to 

complete proficiency checks that will satisfy § 61.58, we subtract these aircraft from the 

aircraft count. For instance, 18 of the 159 Cessna 510 airplanes delivered by the end of 

2009 are used in operations that require proficiency checks of single pilots in command 

as well as multiple pilots in command. Operation of those aircraft will not cost more 

with this rule because pilots of those aircraft have to have proficiency checks currently 

that satisfy § 61.58 (given our assumptions). Based on the analysis of OPSS data, we 

estimate that 15.6% 18 of the 1,869 aircraft delivered by the end of 2009 are used in 

operations where the pilots have to have proficiency checks that may be used to satisfy

§61.58 pilot-in-command proficiency check (see Table 5 below).

The remaining number of aircraft represent those that are certificated to be operated by a 

single pilot in an operation that the current Federal regulation does not require a § 61.58 

 

17 For instance, we assume an aircraft operated by a part 135 certificate holder will only be flown by those 

pilots that have met the proficiency check requirements of § 61.58 (a) through the testing requirements 

found in part 135.
21

check ride for single pilots who operate those aircraft. There are about 1,600 of these 

aircraft in 2010 as indicated in Table 5 below.

 

18 291/1869
22

Table 5 Estimate of Proficiency Checks

[1] Source: GAMA

[2] Source: Operations Safety System Database, FAA
23

As we assumed in the initial regulatory evaluation, we assume each aircraft will be 

operated by 1.5 pilots on average. We estimate that about 2,400 pilots who are not 

currently required by regulation to undergo annual proficiency checks to operate these 

single piloted aircraft will operate these jets in the base year. 

We assume the number of these jets will grow 4.3% annually from 2010 to 2020, which 

is the average annual growth rate of general aviation and air taxi fixed wing turbine 

turbojet.

19

 We also assume that the number of jets for which a proficiency check is 

already required grows at the same rate of 4.3% annually. Given our assumptions, by

2020 there will be 3,606 pilots who would not be required by the current regulations to 

complete an annual proficiency check. 

However, some pilots not currently required by the CFR to take proficiency check rides 

may be required by provisions of their insurance policies to complete a proficiency check 

or to take recurrent training that includes a proficiency check. The FAA called for 

comments on the assumption that insurance carriers require pilots to undergo PIC 

proficiency checks. The Experimental Aircraft Association commented that current 

insurance policies require proficiency checks for the pilots/owners of most, if not all VLJs, 

making the additional requirement under §61.58 redundant. The FAA received other 

responses indicating that insurance underwriters require the pilot take annual recurrent 

training. Inquiries to the insurance industry have led us to conclude that about 90% of 

pilots of single pilot-type certificated turbojets take annual recurrent training at flight 

schools to comply with insurance requirements.
24

Inquiries to part 142 training centers indicate that the schools already include or will 

include a proficiency check at no additional charge. Therefore, the cost of complying 

with the rule is expected to be zero for those pilots who complete annual recurrent 

training in a simulator at a part 142 training center. As indicated in Table 6 below, we 

estimate 2,222 proficiency checks will be completed at the conclusion of recurrent 

training at a part 142 training center in 2011. The costs of these checks will be minimal 

or zero; we assume they will be zero. 

 

19 FAA Aerospace Forecasts 2010-2030, Table 27 Active General Aviation and Air Taxi. 
25

Table 6 Annual Projections of Small Single Pilot Certified Turbojets and 

Number of Proficiency Checks Expected to be Taken in Simulator and 

Number Taken in Aircraft

Notes: [1] GAMA provided the number of Business jets that can be flown single pilot and deliveries through 2009 

Year End, starting point for 2010.

[1] Annual average growth 2010 - 2020 is 4.3%, FAA Aerospace Forecasts 2010-2030, Table 27 Active General 

Aviation and Air Taxi.

[2] Of the business jets that can be flown single pilot and are registered in the U.S., the number that are operated 

under a provision that currently requires proficiency checks.

[3] Estimated 1.5 pilots per aircraft.

We estimate that 10% of the pilots will take annual proficiency checks in an aircraft. 

These pilots will incur costs for the proficiency checks. We estimate 247 such 

proficiency checks in 2011 will be needed because of the rule. As indicated in the pilot 

proficiency cost section above, we estimate that each proficiency check in a type 

certificated aircraft ranges from about $1,780 to $10,730 with a most likely value of 

$4,079. However, as explained above, since every other year pilots have to take a flight 
26

review, the net cost attributed to this rule for a proficiency check ride is $3,750 for 50% 

of the pilots each year (those who would be due for the flight review). 

Cost of § 61.58 Proficiency Checks for Pilots of Type Certificated Aircraft

To estimate the costs of amending § 61.58 to require proficiency checks of pilots in 

command of single pilot type certificated jets we multiply the estimated number of 

proficiency checks that will be completed in an aircraft by the costs of each proficiency

check. We derive a cost estimate using the low, high and most likely costs. The most 

likely value incorporates the assumption that the pilot will substitute the proficiency

check ride for the flight review requirement. To estimate total most likely costs we 

assumed that 50% of the pilots each year incur the full most likely cost of the proficiency

check ($4,079) and 50% incur the incremental cost of the proficiency check –

incremental to the flight review ($3,750). Total costs over the ten years of the analysis 

could range from about $5.4 million to $32.3 million with a most likely value of $11.8

million as indicated in the table below. 20 Since we believe that the low and high are the 

most extreme cases we apply discount rates to the most likely values for use in this 

analysis. The most likely value is $11.8 million ($9.9 million discounted by 3%) and 

($8.1 million discounted by 7%). Results are found in Table 7 below.

 

20 Only in the most likely value do we assume that pilots will substitute proficiency checks for the flight 

review.
27

Table 7 Number and Cost of Additional Proficiency Checkrides for Single Pilots of Type Certificated Jets Resulting from the 

Rule
28

The following paragraphs describe how we estimated the number of proficiency checks 

for pilots of experimental jets that will be required because of this rule.

Methodology for Experimental Jets

 We took the total number of pilots certificated to fly an experimental jets: 

 We applied the annual growth rate forecast by the FAA for experimental aircraft 

to estimate number of such pilots over the next ten years;

 We reviewed the type ratings of these pilots and estimated that 57% percent of 

these pilots are already taking annual check rides and therefore 43% are not 

currently taking the check ride. We assume that all of those pilots not taking the 

check ride will incur the costs of check rides due to the rule 21;

 We estimated the cost of proficiency checks in an experimental aircraft;

 We estimated the net cost of proficiency checks in year of the flight review;

 We multiplied 50% of the estimated number of experimental pilots incurring costs 

proficiency checks by the estimated cost of proficiency in an experimental aircraft 

and 50% by net cost of proficiency check in flight review year.

Estimated Number of Proficiency Checks for Pilots of Experimental Jets:

Table 8 lists the experimental jet powered aircraft with two or more seats.

22 There are 

1,188 active airmen who are authorized to fly one or more of the experimental jet aircraft 

whose pilots will be subject to this rule (experimental jets with more than one seat). This

 

21 This is a conservative assumption which may overestimate costs, because some of those not currently 

taking check rides may actually operate solo, in which case, they will not be required to take a check ride.
29

list of active pilots may include some who will not act as pilot in command of that 

aircraft; in other words, they may have the rating but they may not be active in that 

specific aircraft and will not need the check ride. In addition, some of the airmen on the 

list may already be taking proficiency check rides without the rule.

 

22 These aircraft could be reconfigured to have only a single seat but to be conservative we include them on 

the list of experimental jet powered aircraft whose pilots will have to have proficiency checks under the 

rule (i.e. pilots of multi-seat experimental jets). 
30

Table 8 List of Experimental Jet Aircraft with More than One Seat

With the rule, pilots who act as pilot in command of an experimental jet will be able to 

complete their annual proficiency check in any jet powered aircraft. The provision for 

pilots in command of experimental jets is less stringent than that for pilots commanding 

type certificated jets because every 24 months, the proficiency check ride required of the 

latter has to be in the particular type of aircraft of which they are pilot in command

(whereas every 12 months the check ride can be in any jet aircraft). The check ride for 
31

the PIC of the experimental jet can be in any jet aircraft, and be given by any examiner

qualified in the specific aircraft in which the pilot is taking the check.

Some of the pilots identified may be required to undergo annual proficiency checks 

through their employment; if they work for an airline for example. Since the revised 

provision as it applies to a PIC of an experimental jet does not require the proficiency

check be in the particular type of aircraft that they operate, any proficiency check in a jet 

that meets § 61.58 will fulfill the requirement and the rule will have no costs vis-à-vis 

these pilots.

To estimate the number of proficiency check rides over the ten years of the analysis we 

increased the number of proficiency checks by the percent growth 23 in experimental 

aircraft forecast by the FAA for each year of the analysis. 

 

23Table 27, Active General Aviation and Air Taxi Aircraft, FAA Aerospace Forecasts FY 

2010-2030.
32

Table 9 Estimated Proficiency Check Rides For Pilots of Experimental Jets

If an experimental jet pilot determines that the cost of performing the proficiency check 

would be less in a type certificated jet such as a Cessna, then that pilot can choose to do 

the check in the type certificated jet (or in any other jet, or in an approved simulator at a 

part 142 training center). Check rides that the pilot might take regardless of the rule, for 

instance if the pilot works for a part 135, part 121, part 125 or part 91K operator and 
33

takes a pilot in command proficiency check in accordance with those parts, can be

counted in fulfillment of this rule. We reviewed the type ratings of the experimental 

pilots and concluded that about 57% of these pilots are already taking annual proficiency

check rides in jets and these check rides will satisfy the requirements of this rule. 

According to our estimates, the remaining 43% are not currently taking annual 

proficiency check rides and therefore this rule will cause them to incur the cost of an 

annual check ride. Some of these pilots may operate solo in which case they would not 

have to take a proficiency check. However, to be conservative we assume that the rule 

will cause them to all undergo annual proficiency checks. 

As we did for type certificated jets, our calculation of most likely cost incorporates the 

assumption that the pilot will substitute the proficiency check ride for the flight review 

requirement. To estimate total most likely costs we assumed that 50% of the pilots each 

year incur the full cost of the proficiency check ($4,694) and 50% incur the incremental 

cost of the proficiency check – incremental to the flight review ($4,365).

Cost of § 61.58 Proficiency Checks for Pilots of Experimental Aircraft

To estimate the costs of amending § 61.58 to require proficiency checks of pilots in 

command of experimental jets we multiply the estimated number of proficiency checks 

by the costs of each proficiency check. We derived costs estimate using the low, high 

and most likely costs and presented the estimates in Table 2. The most likely value 

incorporates the assumption that the pilot will substitute the proficiency check ride for the 
34

flight review requirement. To estimate total most likely costs we assumed that 50% of 

the pilots each year incur the full most likely cost of the proficiency check ($4,694) and 

50% incur the incremental cost of the proficiency check – incremental to the flight review 

($4,365). Total costs over the ten years of the analysis could range from about $10.8

million to $70.9 million with a most likely value of $26.6 million as indicated in the table 

below. 24 Since we believe that the low and high are the most extreme cases we apply 

discount rates to the most likely values for use in this analysis. The most likely value is 

$26.6 million ($22.6 million discounted by 3%) and ($18.5 million discounted by 7%). 

Results are found in Table 10 below.

 

24 Only in the most likely value do we assume that pilots will substitute proficiency checks for the flight 

review.
35

Table 10 Estimated Cost of Proficiency Check Rides for Pilots of Experimental Jets
36

Benefits of Proficiency Checks for Type Certificated and Experimental Jet Pilots

By extending the annual proficiency requirement to turbojet powered aircraft, the 

revision to § 61.58 is expected to increase safety because it will ascertain that pilots of 

these aircraft have the skills to continue to operate safely. The benefits of this rule are

the dollar value of accidents that may be prevented by this rule. 

To estimate the benefits of these proficiency checks we reviewed accidents over the past 

10 years to determine whether the accident might have been prevented if the pilot had 

had the proficiency check required by this rule.

The Office of the Secretary of Transportation (OST) provides us with the following 

values to use in estimating the benefits of preventing fatalities and injuries.

1 Maximum Abbreviated Injury Scale
37

OST also prescribes per victim medical and legal costs as follows:

We estimate benefits by adding the values per MAIS injury level and the per victim 

medical and legal costs and multiplying the result by the corresponding number of 

injuries (at each injury level). In addition, we determined the value of destroyed and 

damaged type certificated aircraft and multiplied that value by the number of destroyed 

and damaged type certificated aircraft and included that value in the estimates of benefits 

of avoiding accidents in type certificated aircraft.25

Sources: Economic Values for FAA Investment and Regulatory Decisions, A Guide, GRA, Inc., Final 

Report, Revised October 3, 2007, pgs. 5-7, 5-10.

Budget of the United States Government: Historical Tables Fiscal Year 2011, Table 10.1—Gross Domestic 

Product and Deflators Used in the Historical Tables: 1940–2015, GDP Chained Price Index 2010/2003 

=1.18, used to convert from 2003 to 2010 dollars.

 

25 We estimated the value of damaged and destroyed type certificated airplanes using replacement and 

restoration data from the “Economic Values for FAA Investment and Regulatory Decisions: A Guide,” 

which were estimated based on data from sources such as the Aircraft Blue book and Aircraft Types and 

Price Guidelines. We found no comparable data sources for the values of experimental aircraft. Initial 

searches for sales prices of used experimental aircraft indicate that the range of values for experimental 

aircraft varies widely and are in flux. Therefore, we do not estimate the benefits of avoiding damages to 

experimental aircraft. 
38

Benefits of Proficiency Checks for Type-certificated Jet Pilots

Twenty-one accidents of jets that have been certificated for single pilot operation26 that

occurred over the 10 year period June 30, 2000 through July 1, 2010 are reported in the 

National Transportation Safety Board database. We eliminated those accidents of

aircraft with more than one pilot. We also removed accidents that were likely caused by 

mechanical problems. If the accident report indicated that the pilot had a proficiency

check ride within the year preceding the accident, we removed the accident from

inclusion in a list of preventable accidents. After we screened out accidents that would 

likely not have been prevented by a proficiency check ride we had a list of 12 accidents 

that resulted in 3 fatalities, no serious injuries and 5 minor injuries. 

Table 11 Preventable Accidents of Type Certificated Jets 27

Using the values of preventing injury and the medical and legal costs that would not be 

incurred if we prevented similar accidents with the amendment to § 61.58 we estimate 

 

26 Including Cessna 510, Cessna 525, Cessna 501, Cessna 551, Phenom 100, Eclipse 500, and Hawker 

Beechcraft 390 Premier I/IA.
39

that the benefits of this amendment to § 61.58 would be about $30.2 million over ten 

years if there were no increase in type certificated jet aircraft. 

Table 12 Value of Avoiding Accidents – Type Certificated Single Piloted Aircraft

However, since we expect the number of single piloted type certificated jet aircraft to 

grow over the next ten years, if we do not promulgate this rule we might expect the 

benefits foregone to increase as well. There were approximately $30.2 million worth of 

damages that occurred over the past 10 years that might have been prevented by this rule. 

If we do not promulgate this rule, we assume these damages will grow at the same annual 

rate as general aviation and air taxi jets are forecast to grow (4.3% per year) from 2011 to 

2020, resulting in $38.3 million in total benefits and $26.3 million in present value 

benefits. 28. 

 

27 Note: this list includes the accident of a Cessna 500 which appears to have been operated by a single 

pilot. This aircraft is not on the list of aircraft requiring a single pilot but we include it as a preventable 

accident because it was operated by a single pilot.

28 The estimated benefits for 2011 is the average dollar value of damages over ten years - $3.020 million 

increased by 4.3%. Potential damages grow by 4.3% by year to represent estimated benefits of the rule. 
40

Table 13 Estimated Benefits of the Rule to Pilots of Type Certificated Aircraft
41

Benefits of Proficiency Checks for Experimental Jet Pilots

Thirty-nine accidents of multi-seat experimental jet aircraft (those experimental jet 

aircraft whose pilots will be subject to this rule) that occurred over the ten year period 

June 30, 2000 through July 1, 2010 are reported in the National Transportation Safety

Board database. Accidents that were likely caused by mechanical failure and accidents 

caused by factors that would not have been checked during a proficiency check ride were 

removed from further consideration. We also removed the accident if the accident report 

indicated that the pilot had a proficiency check ride within the year preceding the 

accident. After we screened out accidents that would likely not have been prevented by a 

proficiency check ride we had a list of eleven accidents that resulted in eight fatalities, 

one serious injury and three minor injuries. 
42

Table 14 Preventable Accidents of Experimental Jets

Using the values of preventing injury and the medical and legal costs that would not be 

incurred if we prevented similar accidents with the amendment to § 61.58 we estimate 

that the benefits of this amendment to § 61.58 would be about $50 million over 10 years 

if there were no increase in experimental jet aircraft. 

Table 15 Value of Avoiding Accidents in Multi-seat Experimental Jets

However, since we expect the number of experimental jet aircraft to grow over the next 

10 years, if we do not promulgate this rule we might expect the benefits foregone to 
43

increase as well. There were $50.6 million worth of damages that occurred over the 

past 10 years that might have been prevented by this rule; which is approximately $5 

million per year. If we do not promulgate this rule, we assume this rate would grow at 

the same rate as experimental jets are forecast to grow. 

Table 16 Estimated Benefits of the Rule to Experimental Jets

Costs and Benefits Summary of § 61.58

The next tables summarize costs and benefits of § 61.58 to pilots of type certificated jets 

and to pilots of experimental jets. 
44

We estimate that this change to § 61.58 will cost pilots of type certificated jets $11.8

million ($8.1 million, discounted by 7% and $9.9 million discounted by 3%). We 

estimate benefits of $38.3 million ($26.3 million discounted by 7% and $32.4 million 

discounted by 3%). These results are presented in Table 17.

We estimate the cost to experimental pilots will be $26.6 million ($18.5 million if 

discounted by 7% and $22.6 million if discounted by 3%). Benefits are estimated at 

$58.2 million ($40.4 million discounted by 7% and $49.4 million if discounted by 3%). 

These results are indicated in Table 18.
45

Table 17 Summary of Costs and Benefits of Changes to § 61.58 – Pilots of Type Certificated Jets
46

Table 18 Summary of Costs and Benefits of Changes to § 61.58 – Pilots of Experimental Jets
47

Section 61.65 and Part 141 Changes – Combined Private Pilot Certificate and 

Instrument Rating 

Assumptions and Data

 Average hourly cost of average pilot flight instructor - $70 ;

29

 Average hourly cost of renting an airplane - $140 –;

30 31 and

 Per hour Administrative and clerical staff - $23.27 –.

32

 Average hourly loaded cost for FAA Airmen Certification Branch examiners to 

process application for private pilot and instrument rating - $46.69 33 

 Original private pilot certificates issue per year - 20,000;

 FAA applicants for combined certificate will save 20 hours;

 

29 The average cost for a pilot instructor in the air for pilot training was estimated in the 

NPRM to average $65 per hour. We converted this estimate to 2010 $.

30 The average cost for renting a general aviation airplane including fuel costs was 

estimated in the NPRM to average $135 per hour. We converted this estimate to 2010$. 

31 The FAA acknowledges that there may be minor differences in what part 61 and part 

141 applicants pay for both pilot instruction and airplane rental in the same parts of the 

country and that there would be different rates in different parts of the country. The FAA 

also acknowledges that some flight clubs are able to undercut the prices charged by the 

Fixed Base Operators (FBOs). Flight clubs require the person to be a dues paying 

member and then they get a reduction in aircraft and instructor costs. However, for this 

analysis, the FAA assumes that applicants under part 61 and part 141 would pay the 

same.

32 Source: Bureau of Labor Statistics, Department of Labor, News Release, June 9, 2010. 

Use of ‘Office and administrative support’ from Table 2: Employer costs per hour 

worked for employee compensation and costs as a percent of total compensation: Civilian 

workers, by occupational and industry group, June 9, 2010. Use of ‘Office and 

administrative support’. The fully loaded wage is $23.27. 

ftp://ftp.bls.gov/pub/special.requests/ocwc/ect/ececrlse.pdf

33 Average hourly rates for FG-12 step 5 ($37.37) and FG 11 step 5 ($31.17) in the rest of 

the country times 1.3625 to include fringe benefit factor.
48

 Average cost savings to the FAA of administering a combined private pilot 

instrument rating rather than administering separately = $260. 34

 

34 In the NPRM, the FAA estimated the costs of administering a private pilot certificate and administering 

an instrument rating at $275 and $375, respectively or a total of $650. The FAA also estimated the costs of 

performing a combined private pilot certificate and instrument rating would be $400. The differential of 

$250 was the cost savings. This has been converted to 2010 $. 
49

There will not be a reduction in aeronautical experience requirement hours for applicants 

obtaining combined private pilot certification and an instrument rating from a part 141 

pilot school. However, as was discussed in the initial regulatory evaluation, experience at 

Middle Tennessee State University (MTSU) has shown that applicants that complete the 

combined rating do so in less time than those who do not take the combined course, thus 

saving the former applicants time and money. Most take more than the required 70 

hours. Consistent with our assumption in the NPRM, we assume that pilots obtaining the 

combined private pilot certificate with an instrument rating will save 20 hours compared 

to those obtaining them separately. Applicants will also save money in that they will

have to complete only one, rather than two, application forms and take one combined 

practical test (meaning, a combined private pilot certification and instrument rating 

practical test). The FAA will save a minimal amount because it will not have to process 

the additional application.

Over the calendar years 2005 through 2009, an average of about 20,000 original private 

pilot certificates, were issued annually.

35

 Overall this level has been declining since 

2000; for the purpose of this analysis we assume they remain level over the analysis 

period. We do not know how many entities operating under part 61 offer both private 

pilot certification and instrument ratings, so we assume only pilots training at a part 141 

school will take the combined course. 

 

35 Source: Table 17 Original Airmen Certificates Issued by Category, 2009 U.S. Civil Airmen Statistics, 

FAA Aeronautical Center, Oklahoma City, Oklahoma, FAA.
50

Of the 653 part 141 schools, 386 36 schools provide courses for private pilot airplane 

certification and instrument airplane ratings. About 15% of all applications for pilot 

certification have been graduates from Part 141 pilot schools. If we assume that the same 

percent of private pilot certificates are issued from Part 141 schools as total pilot 

certificates, then about 3,000 37 private pilots will graduate per year from part 141 pilot 

schools given our assumptions and approximately 1,770 38 will graduate from schools 

providing both private pilot airplane certification and instrument airplane ratings. The 

FAA estimates that only about 2% 39of the estimated 1,770 (35 annually) will obtain a 

combined private pilot and instrument rating under this new rule from a part 141 school. 

 

36 There are 386 schools that offer private pilot airplane and instrument airplane, and 83 that offer private 

pilot helicopter and instrument helicopter. There may some schools on both lists so to be conservative we 

use the 386 schools as a conservative estimate. Source: NVIS database, 07-27-10.

37 20,000 times 30%.

38 59% of the part 141 schools offer both courses (private pilot and instrument rating) so we take 59% of 

the estimated 6,000 private pilots produced by part 141 schools.

39 The estimate that 2% of graduates from part 141 schools will obtain a combined private pilot certificate 

with instrument rating was used in the NPRM. The FAA now believes the actual percent will be higher, 

but uses 2% here as a conservative estimate. 
51

For the purposes of this analysis we assume all students who take advantage of these rule 

changes will be enrolled in part 141 pilot schools, but the FAA believes that there will

also be Part 61 schools who will offer the combined courses. Applicants obtaining this 

combined private pilot certification and instrument rating will save on overall training 

time and airplane rental. To calculate this cost savings, the FAA will use figures 

discussed above, $70 per hour for pilot flight training, $140 per hour for airplane rental, 

$37.20 per hour for the cost of an airman’s time, and the FAA assumption of a savings of 

20 hours. Cost savings to the applicant would be about $4,944 [calculation: ($70 + $140

+$37.20) x 20 hours]. Total annual cost savings would be $173,000 [calculation: 35

applicants x ($70 + $140 + $37.20) x 20 hours], while 10-year cost savings would be $1.7

million.

The FAA estimated that it could save $260 for each combined private pilot certificate and 

instrument rating it performed These savings sum to $9,100 annually [calculation: $260

x 35 applicants]. Ten-year cost savings sum to $91,000. 

Each applicant would have to fill out one less application form; the FAA estimates that 

the application form for both the private pilot certificate and instrument rating each takes 

15 minutes to fill out. Using the aforementioned $37.20 per hour for an airman’s time, a 

quarter hour savings from filling out one less form would be $9.30 per applicant. These 

savings sum to $326 annually [calculation: $9.30 x 35 applicants]. Ten-year cost savings

sum to $3,260.
52

Annual total cost savings for the applicants sums to approximately $182,000. 

The FAA would save an additional minimal amount because it would not have to process 

two applications. As discussed above, each applicant getting a combined private pilot 

and instrument rating will have to submit one less FAA Form 8710-1 application form to 

the FAA for approval. Thus, FAA examiners will have to process one less application 

for each of these applicants. It takes, on average, 10 minutes for FAA Airman 

Certification Branch examiners to process each application.40 The applicable examiners 

earn at the FG-11 and FG-12 level; as shown above, their hourly wages are $46.69 per 

hour including fringe benefits. FAA Airman Certification Branch examiners reviewing 

35 fewer applications per year equals annual cost savings of about $272 [calculation: 35

applicants x 10 minutes x $46.69 per hour]. Ten-year cost savings sum to $2,720.

Schools who offer the combined courses would have to incur costs in modifying 

syllabuses. The FAA does not know how many of the schools will apply for this 

combined private and instrument course and called for comments as to how many of 

these schools would seek to offer such a course. The FAA did not receive comments that 

it could use in this analysis indicating how many schools would apply. Since we did not 

receive comments on how many schools will modify syllabuses we do not develop a total 

cost estimate for modifying syllabuses.

Total cost savings of combining the private pilot certification and instrument rating, over 

 

40 Source – AFS-760
53

10 years sum to $1.8 million ($1.3 million, discounted by 7% and $1.6 million 

discounted by 3%) as indicated in Table 21.
54

Table 21 Total Cost Savings Due to Applicants Applying Concurrently for Private Certification and Instrument Rating
55

III. Summary of Total Net Costs and Benefits

The total ten year estimated cost of the rule is approximately $38.4 million, ten year cost savings is $1.8 million and the total net cost 

41 of the rule over ten years is $36.6 million ($25.3 million discounted by 7% and $31.0 million discounted by 3%). The total 

estimated benefit over ten years is $96.5 million ($66.7 million discounted by 7% and $81.8 million discounted by 3%).

Table 22 Net Costs of the Final Rule

 

41 Cost less cost savings.
56

Table 23 Benefits of the Final Rule
A