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# KENT

# STATE®

UNIVERSITY

Docket Management Facility January 24, 2013
US Department ofTransportation

1200 New JerseyAvenue SE

West Building Ground Floor

Room W12-140 Washington, DC 20590

To whom it may concern:



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## Overview; Request for an exemption to the Practical Test Standards requirement for use of a single-engine, complex airplane for a CFI addition rating.

I am the Chief Flight Instructor, Designated Pilot Examiner, and a Faculty member in the College of Applied Engineering, Sustainability and Technology at Kent State University and associated with the Aeronautics Program. The Aeronautics Program is in the process of replacing its aging fleet oftraining aircraft. Throughout the pasttwo years the program has been working on, and implanting, a strategic plan for all five of its program areas. One key component ofourfindings is a projected increase in student enrollment in the area offlight training. In fact, the program has already seen an increase in enrollment.

Because ofthe changing needswithin the aviation industry (forecasted pilot shortage and increased flight hours before employment}, as well as the previously mentioned increase in enrollment, the Aeronautics Prowam feels that the training it provides can benefit from some improvements. What has worked in the past will not serve ourstudents needs in the future. Not only mustwe provide experience with technically advanced training aircraft but also we must provide students with more multi-engine flight time upon graduation. As a result, the Aeronautics Program has mapped out a plan to satisfy both ofthese needs; we are requesting your assistance with one aspect ofthis plan. Ourvision is to have students receive their Private certificate and Instrument rating in a Cessna 172S aircraft. The Commercial certificate will be completed in a multi-engine, complex aircraftwith the addition ofa singleengine land class rating in a fixed gear Cessna 172S. Wefeel thatthe Commercial PTS makes it not only possible but acceptable to provide training in this way.



### College ofTechnology P.O. Box 5190 • Kent, Ohio 44242-0001 330-672-2892 • Fax: 330-672-2894 • http://www.kent.edu/techWhen majoring in FlightTechnology ourstudents are required to complete training forthe Certified Flight Instructor (CFI) certificate. As I am sure you are aware, this is also highly encouraged by the airline. Ourstrategic plan study determined that, ifthe initial CFI certificate is completed in a multiengine aircraft, followed by the single-engine class rating addition once the initial certificate is issued, it would give the students more multi-engineflight time upon graduation. The problem lies in the additional single-engine rating. Can it be done in a fixed-gear, single-engine airplane, ordoes an applicant have to once again demonstrate competency in a complex aircraft? We feel that the answer lies in the interpretation ofthe Certified Flight Instructor Practical Test Standards (FAA-S-8081-6C) AircraftandEquipmentRequiredforthe Practical Test section.

AircraftandEquipmentRequiredforthe Practical Test The flightinstructorapplicantis requiredby 14 CFRpart61, section 61.45 toprovide an airworthy, certificatedaircraftforuse during the practicaltest. This section furtherrequires that the aircraftmust: 1. Be ofU.S., foreign, ormilitaryregistry ofthe same category, class, andtype forthe certificate and/or rating forwhich the applicantis applying. 2. Have fully functioning dual controls exceptasprovidedin 14 CFRpart 61, section 61.45(c) and(e). 3. Be capable of performing allappropriate Tasks forthe flight instructorrating soughtandhave no operatinglimitations, which prohibit the performance ofthose Tasks. A complexairplane mustbe furnishedfortheperformance oftakeoffandlanding maneuvers andappropriate emergency procedures. A complexlandplane is one having

### a retractable landing gear, flaps, and controllablepropeller. A complexseaplane is one having flaps, floats, and

### a controllable propeller. Airplanes thatare equippedwith 

### a full11 FAA-S-8081-60 authoritydigitalengine control (FADEC) system are consideredto have 

### a controllable propeller.

After reading this section, it is not specific as to when this requirement to supply a complex aircraft applies. Is it on the initial check ride forthe CFI certificate, or may it be accomplished on any check ride? We understand that some pilot training schools currently are operating underthe assumption that
a complex aircraft is only needed forthe initial check ride and have been training their students accordingly. I have also spoken with several other Designated Pilot Examiners (OPE) who have told
me thatthey believe the complex aircraft is only needed on the initial check ride. Since we are in the process ofchanging our curriculum and are not sure ofthe correct answer, we are seeking your answer. We would also like to take the opportunity to explain ourthoughts on whythe exemption could be granted.

First, there is a lack of new complex training aircraft being manufactured today. Currently, a new single-engine, complex aircraft which is suitable forthe flight training environment, required forthe CFI single-engine check ride. is only available from one aircraft manufacturer (PiperAircraft Inc.). The Piper Arrow is still in production, but is produced on a very limited basis and with limited manufacturer support. Only three Arrows were built last year. This makes the requirements in the Practical Test Standards for
a complex, single-engine aircraft tailored to a single source manufacturer. Not only do we feel thatwe are being tied to one specific manufacturer and one specific product, but also we are concerned with the idea that we must invest $414,900 per airframe on a products whose future is so uncertain.Second, the safety risk offlying old, outdated aircraft with known gearfailures that extend beyond our control. In our current fleet ofsingle-engine, complex aircraft (Cessna 172RG's), the main landing gear actuator bodies are subject to cracking. Cessna has a published service bulletin (SEB 01-2 R1 and R2) which deals with inspection ofthese actuator bodies. Perthe Cessna bulletin, the initial required inspection is due at 3000 hours' time-in-service. In our operation, we have seen catastrophicfailures of this part# 1281001-6 between 898 and 1500 hours' time in service. When these failures occur, due to the resulting damage, the cost to replace all damaged parts per landing gear side carries a list price of $11,940. In addition, when these catastrophicfailures occur, it is a real threat that the landing gearwill be unable tofully extend (multiple instances ofthis situation have been documented with the NTSB). This unnecessarily places ourflight instructors and students at risk by forcing them to operate these single engine complexaircraft. In our operation, we perform inspections at 1000 hours' time in service. Approximately halfofthese inspections reveal the start ofcracking which subsequently requires parts to be replaced.

Due to the single-engine, complex requirement, many flight training institutions are required to operate aircraft which are no longer in production, have high airframe hours, and are reaching the end oftheir usable life forthis type ofoperation. In this training environment, these aircraft are subjected to an extremely high number oftakeoffand landing cycles which subjectthe aircraft to high loading and stress over a short time period, compared to what is normally seen by most aircraft. As a result ofthe loads placed on these high-time airframes, we have encountered multiple instances ofcracked skin and bulkheads which have required major repairs to correct these issues.
Third, complex aircraft competencywas previously demonstrated in the multi-engine aircraft. Our thoughts behind the exemption is ifan applicant does his/ her initial CFI certificate as an MEl in a complex multi-engine, aircraft, then this will satisfy the statement in number3 underAircraftand Equipment Requiredforthe Practical Test. Then, at a later date, the applicant will add the ability of instructing in a single-engine aircraft by completing the check ride in the necessary category and class. Since the applicant has already demonstrated the takeoffand landings maneuvers and appropriate emergency procedures in the complex, multi-engine airplane, we feel that the procedure has been satisfied. Therefore, a complex, single-engine airplane is not necessaryforthe addition ofthe airplane single engine to the CFI certificate.

The situation is similarwhen an applicant, who holds a certified flight instructor (airplane single-engine) certificate with an instrument airplane rating, wants to complete an airplane multi engine land additional rating. In this case, the applicant does not have to complete an instrument approach in the multiengine aircraftto be allowed to give dual instruction in a multi-engine airplane. Our belief is that ifan applicant has proven the ability to fly a complex aircraft what is the reason forthe need to perform those tasks again? To highlight a similar situation, when an applicant wants to add an additional multiengine rating to his/her CFI certificate he/she can do so without performing another instrument approach.

I have recently learned that new Certified Flight Instructor FAA-S-8081-60 has added this statement: "Note: Forinstructorrenewals orreinstatements, atthe discretion ofthe examiner, 

### a non-complex airplane maybe used." Ifan instructor is renewing or reinstating their certificate and it is upto the examinerwhether a complex aircraft is used forthe check ride, Iwould think that the same type ofdecision could be given to a flight school towards the airplane single engine land additional rating by their local FSDO. It goes back tothe applicant has proven their competency already by flying the complex multi-engine aircraft forthe initial Certified Flight Instructor certificate.

Kent State's Flight Training has a rich history in aviation. It is a CFR Part 141 approved flight school (JU8S255Q) through the Federal Aviation Administration (FAA) and an accredited program through the Aviation Accreditation Board International (AABI). We are the only collegiate aeronautics program in the State ofOhio to be accredited by the Aviation Accreditation Board International (AABI). We operate 25 aircraft out ofthe Kent State University airport (1G3) located in Stow, Ohio. The Aeronautics program has overtwo hundred students enrolled in flight training and five hundred in four other disciplines which include a College Training Initiative (CTI) AirTraffic Program.

The Aeronautics program is part ofthe College ofApplied Engineering, Sustainability, and Technology, which itself is one often colleges at Kent State University. The University has more than 42,000 students on nine campuses, including more than 27,000 students in its main campus, the Kent Campus. In 2010 ourflight program was awarded the Loening Trophy by the National Intercollegiate Flying association (NIFA). It is awarded to the outstanding all around collegiate aviation program in the nation.

Please consider our request for an exemption tothe requirementfor using a single-engine, complex aircraft when adding another class rating to a Certified Flight Instructor certificate forthe reasons stated above. Withoutthe exemption we have two options. The first option is thatwe can keep operating the 1984 Cessna 172RG aircraft with a known problem which we feel compromises the safety ofthe program. The second option is the purchase ofnew PiperArrows; this options forces the program to work with a company on a product with an unstable future. Granting this exemption would allow us to provide training that will meetthe needs ofthe aviation industry.

Thank you for yourtime and consideration in this matter. We lookforward to hearing from you. Sincerely,

# ~~ Tim Palcho
Chief instructor

Kent State University