Documenting proficiency prior to commercial practical test

16 Answers

1. 
   

   
   

   Kris Kortokrax on Feb 18, 2020

   Prior to the practical test beginning, the DPE must determine that you are qualified, i.e. that you have completed all the training required by the regulations.

   He will do this by reviewing your logbook to find each qualifying entry that matches a requirement in the regulations.

   To answer your question, no, the endorsements are not sufficient. Not only does 61.127 require logging the training, 61.51(a)(1) also requires logging” training and aeronautical experience used to meet the requirement for a certificate”.

   61.51(h) deals with logging training time and requires a description of training given and an endorsement by the instructor.

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2. 
   

   
   

   KDS on Feb 19, 2020

   As with many things, the answer can change from examiner to examiner. I’ve seen both ends of the spectrum. If your recommending instructor has worked with the examiner before, then they know what is accepted. If not, it wouldn’t hurt to contact the examiner. They would rather take a minute or two explaining what they feel they need to see than to come out and determine that you’re not qualified to take the test. It’s hard to say given the variances in human personalities, but it might be best to have your instructor present that question to the examiner rather than you.

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3. 
   

   
   

   Kris Kortokrax on Feb 20, 2020

   The answer had best not change from examiner to examiner.

   DPEs are now governed by Order 8000.95. It references Order 8900.1 for guidance on conducting each practical test. This is the same guidance used by FAA inspectors. A practical test given by a DPE in any state or given by any FAA inspector should look the same (with regard to procedure) as any other examiner.

   Order 8900.1, Volume 5, Chapter 2 contains the guidance for practical tests. Section 7 discusses the Private Pilot test. Paragraph 5-374E requires the applicant to “present a pilot logbook training record or other reliable records as evidence of meeting the required aeronautical experience” (i.e. 61.109).

   On the back of the 8710-1, there is a box that the DPE must check. Next to it is the following statement:

   “I have personally reviewed this applicant’s pilot logbook and/or training record, and I certify that the individual meets the applicable requirements of 14 CFR Part 61 for the certificate or rating sought.”

   If the DPE checks this box without reviewing the applicant’s logbook, he would be falsifying the application and would be subject to the same penalty as anyone else who violates 61.59(a)(1).

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4. 
   

   
   

   Mark Kolber on Feb 20, 2020

   As Kris said, the DPE is required to determine whether the requirements have been met. For the commercial, without even getting into the detail of the 61.127 list, the “ready for the test” is not enough to show any DPE I have ever heard of that you completed the major requirements such as the long solo cross country, the two dual cross countries, the night solo landings, or have the number of required hours.

   I know a guy who went for his commercial checkride. Asked to point to his long solo cross country, the DPE noted it wasn’t logged as “solo” and sent him home. A bit over the top but justified by the FAA’s general, “if it wasn’t logged, it didn’t happen” stance.

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5. 
   

   
   

   Eric Gleason on Feb 20, 2020

   I’m amused by the idea that there wouldn’t be some variability between DPEs. Despite the regulations that are meant to standardize examinations, human factors and gray area in the regs mean that there is room for a lot of variability. The DPE for my instrument check ride is a nationally-known CFI with a good reputation. Despite this, my checkride lasted all day, and it wasn’t because I struggled. I arrived at 10 am and left at 5 pm. I was extremely well-prepared. Scored in the 90s on my written and earned good praise from him for both the oral and practical portions. He even wrote “very nice checkride” in my logbook.

   He just takes a LONG time, and has particular ways of doing things.

   The most helpful response was to ask the examiner in advance, and that’s exactly what I’ll do. (I’ll likely be using a new DPE that works out of my home area.)

   Thanks to everyone for your input.

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6. 
   

   
   

   Kris Kortokrax on Feb 20, 2020

   I allowed for variability. I only stated that the procedure should be standard.

   The DPEs are free to construct the scenario for the test and to select maneuvers to be tested. When all tasks of a given Area of Operation are not required (i.e. for Ground Reference Maneuvers the DPE is instructed to select at least one of the three options, S-Turns, Turns around a Point or Rectangular Course).

   Further, multiple tests given by one DPE should not look the same. The FAA wants them to have multiple scenarios, so that a CFI cannot debrief a student after a check and know what will be coming on the next check.

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7. 
   

   
   

   KDS on Feb 20, 2020

   What Kris and Mark suggest would be very nice. However, the written word and the real world are not mirror images. That’s why very learned judges disagree.

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8. 
   

   
   

   Kris Kortokrax on Feb 20, 2020

   Although judges may disagree, they are still bound to follow the process (rules of evidence and procedures for conducting a trial).

   Same thing for DPEs. They must follow the process. There are periodic observations and follow-up interviews conducted with applicants to help determine that the process is adhered to.

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9. 
   

   
   

   KDS on Feb 20, 2020

   Kris, I’d love to agree with you and I would except for one thing. I’ve seen it happen time and again on many levels.

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10. 
    

    
    

    Eric Gleason on Feb 21, 2020

    The law and court procedures allow for a a HUGE amount of variation among judges, even within the same court. To lay people it seems like it should be straightforward, but the reality is much different. Even when the law seems very black and white, judges have their own way of implementing it.

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11. 
    

    
    

    Mark Kolber on Feb 23, 2020

    KDS, so you think normal variability includes a DPE who places his own ticket in jeopardy by not verifying completion of requirements? And an DPE being “over the top” is not the real world?

    I guess I have to disagree with you on both.

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12. 
    

    
    

    KDS on Feb 28, 2020

    Mark, you’re certainly welcome to disagree with those words since they are yours and not mine.

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13. 
    

    
    

    Eric Gleason on Feb 28, 2020

    After re-reading my initial question, I can see how I may have been a bit vague. I thought using the phrase “areas of operation” (since it appears in the reg) would have made the distinction that I was asking about the training areas/topics, not the required flight experience. I wasn’t clear enough that I was really wondering specifically about the ground instruction.

    61.127(b) lists those area of operation:

    – Preflight preparation
    – Preflight procedures
    – Airport and seaplane base operations
    – Takeoffs, landings, and go-arounds
    – Performance maneuvers
    – Ground reference maneuvers
    – Navigation
    – Slow flight and stalls
    – Emergency operations
    – High-altitude operations
    – Postflight procedures

    Surely flight instruction and experience will be logged, but I’ve never had a log of any ground instruction.

    I happened to go out with my CFI for other proficiency last week, and asked him this question. His response was that the DPE he usually uses would be satisfied with the logbook endorsement for the ground instruction, and obviously the flight instruction would be noted in the comments for each flight.

    Another (newer) DPE comes from the 141 world, where the students do get logs for ground instruction, and he likely wouldn’t be satisfied with the endorsement.

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    KDS on Feb 28, 2020

    No doubt if your instructor has used the DPE before and the DPE was happy with what he did, the DPE will be happy when he does the same thing with you.

    Just relax on the day of the test and I\’m sure everything will work out to your satisfaction.

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15. 
    

    
    

    Kris Kortokrax on Mar 01, 2020

    Eric,

    Yes, your original question seemed to address flight time, because you cited 61.129 and used the phrase “identify actual flights”.

    Now you have said you were mainly concerned about logging ground instruction. You correctly quoted the requirement to “receive and log ground and flight training”. That is an explicit statement of a requirement to log the ground training. As I noted in my first post, 61.51(a) also contains a requirement to log “training and aeronautical experience”. The fact that no one has logged ground training for you in the past, does not mean that there is not a requirement to do so. It merely means that your past flight instructors were either ignorant of the requirement or deliberately chose to ignore it. The idea that some DPEs might not perform their job according to guidance, does not mean there is no reason to log ground training. I am not talking about the ground training in preparation for the knowledge test. That can be accomplished and documented by completing a course such as Gleim, ASA or King. The ground training I refer to is the ground training prior to a flight lesson, such as an explanation of how to perform a maneuver such as a chandelle or power off 180 approach.

    KDS,

    You state that you cannot agree with me (presumably my thoughts concerning abiding by regulation and policy) because you have “seen it happen time and again on many levels”. I take this to mean that you support the idea of not worrying about logging ground instruction because you have seen instances in the past where pilots have been certificated without having ground instruction logged. If I have mischaracterized your position, please clarify it for me.

    If I understood it correctly, would you then support things like low level buzzing, flying without a medical or student pilots carrying passengers? Those are some of the things I have seen in the last 50 years of flying and would not condone merely because I had seen it done.

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16. 
    

    
    

    KDS on Mar 03, 2020

    Kris, you have indeed both mischaracterized and understood incorrectly what I wrote.

    It would be a better world if everyone followed rules. That would eliminate jails and make driving much safer along with many other benefits. However, we see on a daily basis that is not the case. Some excursions from the rules are intentional and some are inadvertent. Either way, it happens. That human behavior runs through all socioeconomic groups. Government employees are not exempt from it. FAA inspector are not exempt from it. DPE’s are not exempt from it. Humans make mistakes. No amount of training and checking is going to prevent that. The FAA has definitely become more standardized over time, but it is not perfect and never will be. Every DPE is not perfect. That is why I suggest that if the applicant and their instructor are not comfortable with some requirement related to an upcoming test that they contact the examiner in advance and inquire about it.

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