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11 Answers

Complex endorsement limited to specific aircraft

Asked by: 10668 views ,
Commercial Pilot, FAA Regulations, General Aviation

I did my initial commercial training as a multi in a Piper Apache.  I got my complex endorsement signed right after the commercial checkride by the examiner but under the endorsement he wrote "Limited to PA23-150 airplanes only."  I know I should have asked these questions at the time but I had just passed my commercial checkride and was distracted with excitement.  Now I have a job flying a complex airplane this summer, which is not an Apache, so Id like to clear up the confusion.

61.31 e 1(ii) says that in order to operate a complex airplane you must have, "Received a one-time endorsement in the pilot's logbook from an authorized instructor who certifies the person is proficient to operate a complex airplane." This airplane restriction seems to suggest I would need another endorsement to fly another complex aircraft, which would no longer make it a one-time endorsement.  

Given this situation where do you think my privileges stand?  Im inclined to see this as a misunderstanding by the person who signed my endorsement as to what the endorsement is for, which is demonstrating proficiency operating complex systems that can be found in a variety of airplanes.  However, I dont want to fly a different complex aircraft all summer and log the time just to find out later that my endorsement was no good. The real question is, can I legally fly and log time with this type of endorsement or will I need another endorsement that excludes this restriction?

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11 Answers



  1. Nathan Parker on Apr 14, 2012

    This is very odd.  Your instructor should have given you the complex endorsement before the checkride.
     
    I’m not aware of any regulatory basis for an instructor being able to provide a limitation on an endorsement, except for a student pilot.  Now that it’s there, though, I think it would be imprudent to pretend that it isn’t.  The possible solutions are 1) get your original instructor to give you a proper complex endorsement, 2) get the examiner to remove the restriction, 3)  get some other instructor to provide the endorsement (the regulation doesn’t say that the endorsing instructor needs to provide any instruction, but you may have trouble convincing them of that.)

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  2. Josh on Apr 14, 2012

    Thanks Nathan,
    I agree, it was very odd.  I had mentioned to my instructor that I needed the endorsement before the checkride and he told me thats not how they do it there.  At that point I was close enough to being done that I didnt want to stir the pot so I just went along with it leading to an even stranger situation with the endorsement.  After the checkride I had hoped to never have to deal with this instructor or examiner again as they seemed to just be doing what they thought was the best way to do things, getting defensive whenever I challenged it.
    That being said, Id rather not have to deal with them.  Would you as a CFI feel ok giving a proper endoresment seeing I have my commercial already and taking a short flight (<1 hour) demonstrating proficiency?

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  3. Nathan Parker on Apr 14, 2012

    “Would you as a CFI feel ok giving a proper endoresment seeing I have my commercial already and taking a short flight (<1 hour) demonstrating proficiency?”
     
    Probably, as long as you didn’t do anything that scared me.  Do you know the first question people ask when they hear someone geared-up an airplane? It’s “Who was his instructor?”
     
     

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  4. Bill Trussell on Apr 15, 2012

    As an alternative answer I would propose that the examiner granting a commercial certificate to an applicant that did not have a proper endorsement to begin with did indeed grant such an endorsement to the applicant through his signature on the application.  To think that having passed a practical test for commercial operations in a complex aircraft while not being considered competent for such operations is beyond even FAA logic.
    Successful completion of the practical test trumps the one time endorsement.  Shame on the instructor and the examiner for allowing you to take the practical test without an appropriate endorsement.
    Go forth and excercise your commercial certificate.

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  5. Nathan Parker on Apr 15, 2012

    “Successful completion of the practical test trumps the one time endorsement. ”
     
    Uh, what is your evidence for that, Bill?  61.31(e) does not support your contention.

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  6. Bill Trussell on Apr 15, 2012

    Nathan,
    It has been the practice of the FAA to allow for, in the event of a lost pilot log book, the use the last known application for a pilot certificate and all the information contained on it as a “point of record” for a pilot.  In the event that more pilot time is lost than what is on the application, that gets lost to history.  That which is documented on the application that results in a certificate being issued is retained, including all endorsements to get to that point, including flight reviews that might have been satisfied as a result of the practical test.  I have never heard of someone having to go back and get any one time endorsements redone in this situation in spite of 61.31(e) being silent on the issue.
    It is always advised that pilots should be as accurate as possible on thier applications for the above reason.

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  7. Nathan Parker on Apr 15, 2012

    Bill, that’s rampant speculation on your part, and unless you have an FAA Letter of Interpretating saying as much, I think it’s imprudent to represent it as fact. A complex endorsement isn’t documented on an application and the examiner isn’t required to check for it, so having a commercial certificate is no evidence the endorsement ever existed. For what it’s worth, AOPA’s interpretation is that you would need to gather all the endorsements again, but I don’t know the basis of their assertion.   Still, this would be in accordance with the regulations. See http://www.aopa.org/whatsnew/newsitems/2000/000201asd.html
     
    Regardless, this isn’t a case of a reconstructed logbook, since the OP never had the endorsement in the first place.

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  8. Matthew Waugh on Apr 16, 2012

    So I agree with Nathan – I believe that Bill is out on a limb, and a long way out to boot.
     
    The conversation on the ramp that goes “I have here a complex endorsement with a limitation, but it’s OK, because I have my commercial” is probably not going to go well with the inspector. I guess you could “lose” your logbooks, start afresh and thus not have to deal with the issue.
     
    However you look at it, you don’t have a complex endorsement that covers anything but one type. You might be willing to claim that the limitation shouldn’t have been placed, or that your commercial certificate trumps the endorsement, but……
     
    So I’d advise you get an endorsment unencumbered by the ignorance of CFIs or Examiners. And yes, unless you were a complete knucklehead, I’d endorse you after an hours flight (power off stalls, emergency procedures, 3 takeoff and landings – probably less than an hour).

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  9. Josh on Apr 16, 2012

    Thank you all for your responses.  I talked to the examiner that gave the endorsement today and he said that yes he intended it only to be good for the Apache.  He said he doesnt give out a blanket endorsement that applies to all complex airplanes because he doesnt want someone to go fly something else, like a Bonaza, without being trained on the systems in that airplane during the checkout.  I tried to read the reg and get his interpretation on it but he cut me off and said thats how he does the endorsement. I just get the feel hes trying to cover himself additionally from anyone having an issue in a different airplane that is complex. 
    He did, however, point out that the airplane Ill be flying this summer is not complex as it doesnt have retractable landing gear, just the constant speed and moveable flaps.  Doh.  
    I think what I will do is find a CFI that will redo the endorsement after I prove competency.  I just dont think Id ever feel right about the endorsement unless it is reworded/redone.

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  10. Nathan Parker on Apr 16, 2012

    Josh, depending on how much trouble you want to cause, you might bring up the issue with the local FSDO.  It’s their job to monitor the examiners and ensure uniform application of training standards.  This examiner is essentially implementing an airplane checkout policy that the FAA does not require.   It’s none of his business if you want to go out and fly a Bonanaza.  (The insurance company isn’t likely to allow it, though.)
     
    Then again, it’s not the examiner’s responsibility to provide this endorsement in the first place, so the relationship between the instructor and the examiner needs to be clarified, and the FSDO might be the place to see that it’s done.
     
    This isn’t necessarily “ratting” on these people; the conversations that FSDOs are likely to have is usually pretty cordial.  The sad fact is that without monitoring, examiners and flight schools start doing some crazy stuff.

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  11. Micah on Apr 17, 2012

    Josh, as others have commented, your instructor should have provided the endorsement. This appears to be an unusual (to me) relationship between the flight school and examiner. I’m actually with the examiner on this one–he didn’t provide you any training required for the complex endorsement so his checkride evaluation shouldn’t necessarily put him at risk for providing endorsements to pilots. (Also, any endorsement can be limited, so the examiner is not at fault in this case.)
     
    If I were an examiner (which, certainly, I’m not) I don’t think I would accept an applicant who wasn’t provided the endorsement by his/her instructor. If the flight school/instructor suggests that you’re ready to receive your license, why won’t they author the complex endorsement? (Not that I’m suggesting you should leave your training environment, but I think the deficiency/fault is clearly theirs). Still, if you came to me, we’d fly for a little bit in a complex airplane and given a few hours discussion and demonstration, I don’t expect that you would be unqualfied for a “full” endorsement from me. I think you should go back to your instructor/school and demand the endorsement; if they won’t provide it, find a local instructor who will fly with you. 

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