ME add-on training experience minimums: 61.109(b) Vs 61.63 (c)

8 Answers

1. 
   

   
   

   John D Collins on Aug 09, 2019

   Here is the relevant portion of 61.63:

   Sec. 61.63
   Additional aircraft ratings (other than for ratings at the airline transport pilot certification level).
   (a) General. For an additional aircraft rating on a pilot certificate, other than for an airline transport pilot certificate, a person must meet the requirements of this section appropriate to the additional aircraft rating sought.
   (b) Additional aircraft category rating. A person who applies to add a category rating to a pilot certificate:
   (1) Must complete the training and have the applicable aeronautical experience.
   (2) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.
   (3) Must pass the practical test.
   (4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.
   (c) Additional aircraft class rating. A person who applies for an additional class rating on a pilot certificate:
   (1) Must have a logbook or training record endorsement from an authorized instructor attesting that the person was found competent in the appropriate aeronautical knowledge areas and proficient in the appropriate areas of operation.
   (2) Must pass the practical test.
   (3) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought; unless, the person only holds a lighter-
   than-air category rating with a balloon class rating and is seeking an airship class rating, then that person must receive the specified training time requirements and possess the appropriate aeronautical experience.
   [(4) Need not take an additional knowledge test, provided the applicant holds an airplane, rotorcraft, powered-lift, weight-shift-control aircraft, powered parachute, or airship rating at that pilot certificate level.

   The section you quoted is 61.56(b) and it does not apply to adding a multi-engine rating to a pilot who holds a pilot rating for single engine land. Adding multi-engine land is an adding an additional class, not an additional aircraft category rating. So if your private pilot was for category “helicopter” and you wanted to add an additional category “airplane”, you would need the relevant training for the “airplane” category.

   From FAR 1.1 definitions:

   Category:
   (1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a broad classification of aircraft. Examples include: airplane; rotorcraft; glider; and lighter-than-air.

   Class:
   (1) As used with respect to the certification, ratings, privileges, and limitations of airmen, means a classification of aircraft within a category having similar operating characteristics. Examples include: single engine; multiengine; land; water; gyroplane; helicopter; airship; and free balloon

   You are seeking an additional class rating for airplane and 61.63(c) applies, not 61.63(b). Note that 61.63(c)(3) states in part:
   (3) Need not meet the specified training time requirements prescribed by this part that apply to the pilot certificate for the aircraft class rating sought;

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2. 
   

   
   

   Kris Kortokrax on Aug 09, 2019

   I agree completely with John’s post. I would add one thing, though.

   61.39(a)(6)(i) requires that you log training time in the past 2 months in preparation for the test. It does not specify a number of hours. The intent is that you have some recent training (i.e. you aren’t showing up for the test and the last instruction you had was a year ago).

   I always performed a mock checkride with an applicant to make sure he was proficient in every maneuver required for the test. Some people might need 3 hours, others not. The main goal for me as a flight instructor is that when I sign the endorsement stating that you are proficient and prepared to take the test, I have actually flown with you and objectively made that determination.

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3. 
   

   
   

   MChartier on Aug 09, 2019

   Digging deeper:

   Had a look at the guidance material for examiners on FSIMS, Volume 5 section 382:

   http://fsims.faa.gov/wdocs/8900.1/v05%2 … 07rev1.htm

   E. Establish Eligibility. Determine if the applicant meets the specific eligibility, knowledge, and experience requirements for certification as a private pilot (§§ 61.103, 61.105, 61.107, and 61.109).
   1) If the applicant is applying for a powered aircraft rating, ensure that the applicant’s medical certificate is current.
   2) Inspect the applicant’s medical certificate and SODA, if applicable, to ensure that it does not bear any limitation that would make a special medical flight test necessary. (See volume 5, chapter 8, if a special medical flight test is necessary.)
   3) Check the record of flight time in section III of the application to determine if the applicant has the minimum flight experience required for the certificate and ratings sought (§ 61.109). The applicant must list at least the aeronautical experience required for the airman certificate and rating sought. Graduates of part 141 pilot schools or part 142 training centers must provide their aeronautical experience in section III of the application even though the graduation certificate is evidence of having completed the course of training. If aeronautical experience has no bearing on the airmen certification action being sought, it is not necessary for an applicant to complete section III of the application. For example, flight instructor renewal applications, flight instructor reinstatement applications, ground instructor qualification applications, and pilot type rating applications would be examples where aeronautical experience would not have a bearing on the airmen certification action. However, all applicants are encouraged to complete section III of the application. The FAA Forms 8710-1 and 8710-11 applications remain on file with the FAA and can be used to substantiate past aeronautical experience if an individual ever loses his or her logbook.
   4) If the applicant is applying for a test on the basis of graduation from an approved pilot school, inspect the applicant’s graduation certificate to verify that the applicant meets the requirements of § 61.71.
   5) Examine the applicant’s logbook and/or other reliable record(s) to verify that all aeronautical knowledge, aeronautical experience, and required instructor endorsements are recorded.
   6) If the applicant is located on an island from which the required flights cannot be accomplished without flying more than 10 nm over water, refer to § 61.111.
   7) Examine the knowledge test report or test report from an approved school with knowledge test authority, as applicable.
   8) If the applicant has checked the “Yes” box of section IV, verify that the applicant meets the requirements of § 61.49.

   F. Requirements for an Additional Category/Class Rating. The requirements are the same as in paragraph E above; however, the knowledge test is not required if the applicant already has a powered aircraft rating.

   So, according to the above, the examiner is actually required to make sure the student has the aeronautical experience listed in 61.109 (b) !

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4. Best Answer
   
   

   
   

   John D Collins on Aug 09, 2019

   FSIMS is not a regulation, it is guidance. 61.109(b) has a lot of stuff in it. Sections (b)1, b(2) and b(3) are training time requirements to be conducted in a multi engine class aircraft. They are excused by 61.63(c)(3). 61.109(b)(4) and (5) apply because (4) is the requirement for recent experience by an authorized instructor and (5) applies to airplane category. So the mere fact that FSIMS requires the specific eligibility, knowledge, and experience requirements for certification as a private pilot (§§ 61.103, 61.105, 61.107, and 61.109) be determined, the examiner is expected to know the relevant sections of 61.109 that are applicable.

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5. 
   

   
   

   MChartier on Aug 09, 2019

   OK, that’s very clear to me.

   So why is this DPE imposing requirements that clearly are not ?

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6. 
   

   
   

   John D Collins on Aug 09, 2019

   All sorts of folks misinterpret the regulations and DPE are not immune. If you can’t get the DPE to correct the situation, he reports to an FAA inspector who oversees his work. You could get the inspector involved, who will undoubtedly get the situation rectified. DPE who decide to make policy that is not in compliance with the FAA guidelines and regulations will end up loosing business. The pilot community is small and instructors will start not recommending pilots to use a DPE. On the other hand, we are all human and make mistakes, and if the DPE is reasonable, the situation will get corrected.

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7. 
   

   
   

   MChartier on Aug 09, 2019

   Unfortunately this is the ONLY DPE that is authorized to conduct tests in Europe.

   Testing with another DPE is going to require multiple days off and a trip across the Atlantic …

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8. 
   

   
   

   Kris Kortokrax on Aug 09, 2019

   The DPE still has an FAA inspector that he reports to. Ultimately, the DPE needs to be educated. You may be reluctant to contact the FAA because of potential repercussions during the test, but eventually, the DPE needs some retraining.

   Also, Order 8900.1 is guidance for an FAA Inspector conducting a practical test. For DPEs, it has been Order 8900.2, which is also available on FSIMS. I believe that with the advent of the new Designee Management System (DMS), there is a new guidance document for DPEs, but I have not seen it yet.

   That said, the guidance cannot overrule the content of the regulations.

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