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KENT STATE® 

UNIVERSITY 

Docket Management Facility January 24, 2013 

US Department of Transportation 

1200 New Jersey Avenue SE 

West Building Ground Floor 

Room W12-140 

Washington, DC 20590 

To whom it may concern: 

.·-

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 of training 

aircraft. Throughout the past two years the program has been working on, and implanting, a strategic 

plan for all five of its program areas. One key component of our findings is a projected increase in 

student enrollment in the area of flight training. In fact, the program has already seen an increase in 

enrollment. 

Because of the changing needs within 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 our students needs in the future. Not only must we 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 of these needs; we are requesting your assistance with one aspect of this plan. Our vision 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 aircraft with the addition of a singleengine land class rating in a fixed gear Cessna 172S. We feel that the Commercial PTS makes it not 

only possible but acceptable to provide training in this way. 

College of Technology 

P.O. Box 5190 • Kent, Ohio 44242-0001 

330-672-2892 • Fax: 330-672-2894 • http://www.kent.edu/tech 
When majoring in Flight Technology our students are required to complete training for the Certified 

Flight Instructor (CFI) certificate. As I am sure you are aware, this is also highly encouraged by the 

airline. Our strategic plan study determined that, if the 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-engine flight time upon graduation. The problem lies in the 

additional single-engine rating. Can it be done in a fixed-gear, single-engine airplane, or does an 

applicant have to once again demonstrate competency in a complex aircraft? We feel that the answer 

lies in the interpretation of the Certified Flight Instructor Practical Test Standards (FAA-S-8081-6C) 

Aircraft and Equipment Required for the Practical Test section. 

Aircraft and Equipment Required for the Practical Test 

The flight instructor applicant is required by 14 CFR part 61, section 61.45 to provide an airworthy, 

certificated aircraft for use during the practical test. This section further requires that the aircraft must: 

1. Be of U.S., foreign, or military registry of the same category, class, and type for the certificate and/or 

rating for which the applicant is applying. 

2. Have fully functioning dual controls except as provided in 14 CFR part 61, section 61.45(c) and (e). 

3. 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 

furnished for the performance of takeoff and landing maneuvers and appropriate emergency 

procedures. A complex land plane is one having a retractable landing gear, flaps, and 

controllable propeller. A complex seaplane is one having flaps, floats, and a controllable 

propeller. Airplanes that are equipped with a full11 FAA-S-8081-60 authority digital engine control 

(FADEC) system are considered to 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 for the CFI certificate, or may it be accomplished on any check 

ride? We understand that some pilot training schools currently are operating under the assumption that 

a complex aircraft is only needed for the 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 that they believe the complex aircraft is only needed on the initial check ride. Since we are in the 

process of changing our curriculum and are not sure of the correct answer, we are seeking your 

answer. We would also like to take the opportunity to explain our thoughts on why the 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 for the flight training environment, required for the CFI 

single-engine check ride. is only available from one aircraft manufacturer (Piper Aircraft 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 that we 

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 of flying old, outdated aircraft with known gear failures that extend beyond our 

control. In our current fleet of single-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 of these actuator bodies. Per the Cessna bulletin, the initial required 

inspection is due at 3000 hours' time-in-service. In our operation, we have seen catastrophic failures 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 catastrophic failures occur, it is a real threat that the landing gear will 

be unable to fully extend (multiple instances of this situation have been documented with the NTSB). 

This unnecessarily places our flight instructors and students at risk by forcing them to operate these 

single engine complex aircraft. In our operation, we perform inspections at 1000 hours' time in service. 

Approximately half of these inspections reveal the start of cracking 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 of their 

usable life for this type of operation. In this training environment, these aircraft are subjected to an 

extremely high number of takeoff and landing cycles which subject the aircraft to high loading and 

stress over a short time period, compared to what is normally seen by most aircraft. As a result of the 

loads placed on these high-time airframes, we have encountered multiple instances of cracked skin and 

bulkheads which have required major repairs to correct these issues. 

Third, complex aircraft competency was previously demonstrated in the multi-engine aircraft. Our 

thoughts behind the exemption is if an applicant does his/ her initial CFI certificate as an MEl in a 

complex multi-engine, aircraft, then this will satisfy the statement in number 3 under Aircraft and 

Equipment Required for the 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 takeoff and 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 necessary for the addition of the airplane 

single engine to the CFI certificate. 

The situation is similar when 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 aircraft to be allowed to give dual instruction in a multi-engine airplane. Our belief is that if an 

applicant has proven the ability to fly a complex aircraft what is the reason for the 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: For instructor renewals or reinstatements, at the discretion of the examiner, a non-complex 

airplane may be used." If an instructor is renewing or reinstating their certificate and it is up to the 

examiner whether a complex aircraft is used for the check ride, I would think that the same type of 
decision could be given to a flight school towards the airplane single engine land additional rating by 

their local FSDO. It goes back to the applicant has proven their competency already by flying the 

complex multi-engine aircraft for the 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 of Ohio to be accredited by the Aviation Accreditation Board International (AABI). We operate 

25 aircraft out of the Kent State University airport (1G3) located in Stow, Ohio. The Aeronautics 

program has over two hundred students enrolled in flight training and five hundred in four other 

disciplines which include a College Training Initiative (CTI) Air Traffic Program. 

The Aeronautics program is part of the College of Applied Engineering, Sustainability, and Technology, 

which itself is one of ten 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 our flight 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 to the requirement for using a single-engine, complex 

aircraft when adding another class rating to a Certified Flight Instructor certificate for the reasons stated 

above. Without the exemption we have two options. The first option is that we can keep operating the 

1984 Cessna 172RG aircraft with a known problem which we feel compromises the safety of the 

program. The second option is the purchase of new Piper Arrows; 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 meet the needs of the aviation industry. 

Thank you for your time and consideration in this matter. We look forward to hearing from you. 

Sincerely, 

Tim 

~~ Palcho 

Chief instructor 

Kent State University