Examiner Question

[Phil Squares]

I have asked the FAA/Examiners/CFIs the following question and I can't seem to get a straight answer.

I have a FAA ATP Mulit-engine, several type ratings from 727 through 747-400 I also have a private pilot single engine (ex military). I would like to do the any of the following:

1) Upgrade the single engine to ATP or
2) Upgrade the single engine to Commercial

My question is what do I have to do? I have been told I need to do the entire single engine ATP flight, while others have said, no, just the maneuvers specific to the single engine because I have already demonstrated the complex and instrument portion on the multi-engine and type rating rides.

Others have said just go for the commercial and leave it at that.

Any thoughts or others in the same situation.

Thanks in advance!!

[weasil]

One option you have is to take a flight test for the addition of a single engine class rating to your certificate. You can find this in the commercial pilot practical test standards located at

http://www.faa.gov/education_research/testing/airmen/test_standards/pilot/media/FAA-S-8081-12B.pdf

See the additional rating task table on page 1-v and reference the column for the ratings you already hold. It will tell you which tasks you have to perform on the checkride.

You will note that the PTS specifically says you do not have to redemonstrate complex aircraft procedures. In other words you can take the checkride in a fixed pitch propeller aircraft if you so desire.

You could also add the single class to your ATP. The appropriate regulation is 61.165..

(b) Airplane category rating with a single-engine class rating. A person applying for an airline transport certificate with an airplane category and single-engine class rating who holds an airline transport pilot certificate with another aircraft category rating must:

(1) Meet the eligibility requirements of §61.153 of this part;

(2) Pass a knowledge test on the aeronautical knowledge areas of §61.155(c) of this part;

(3) Comply with the requirements in §61.157(b) of this part, if appropriate;

(4) Meet the applicable aeronautical experience requirements of §61.159 of this part; and

(5) Pass the practical test on the areas of operation of §61.157(e)(1) of this part.
________________________________________

61.157 states...

e) Areas of operation. (1) For an airplane category—single-engine class rating:

(i) Preflight preparation;

(ii) Preflight procedures;

(iii) Takeoff and departure phase;

(iv) In-flight maneuvers;

(v) Instrument procedures;

(vi) Landings and approaches to landings;

(vii) Normal and abnormal procedures;

(viii) Emergency procedures; and

(ix) Postflight procedures.

[westhawk]

(b) Airplane category rating with a single-engine class rating. A person applying for an airline transport certificate with an airplane category and single-engine class rating who holds an airline transport pilot certificate with another aircraft category rating must:

Please note that the above quoted regulation applies specifically to a person who holds an ATP in another category other than airplane. As the holder of ATP with multi-engine class rating in the airplane category, Phil Squares need not take the knowledge test to qualify for the addition of a SEL class rating to his Airplane, MEL ATP. Further down in FAR 61.165 is paragraph (e) which describes the requirements to add SEL class rating to an airplane category ATP:

(e) Additional class rating within the same aircraft category. A person applying for an airline transport certificate with an additional class rating who holds an airline transport certificate in the same aircfaft category must—

(1) Meet the eligibility requirements of §61.153, except paragraph (f) of that section;

(2) Comply with the requirements in §61.157(b) of this part, if applicable;

(3) Meet the applicable aeronautical experience requirements of subpart G of this part; and

(4) Pass a practical test on the areas of operation of §61.157(e) appropriate to the aircraft rating sought.

Note that there is no requirement to receive an endorsement or any specific training to qualify for the addition of a class rating to the ATP. 61.39 (http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=28c4a0982a1981c8502428119cbdfaea&rgn=div8&view=text&node=14:2.0.1.1.2.1.1.24&idno=14) states in part:

(c) A person is not required to comply with the provisions of paragraph (a)(6) of this section if that person:

(1) Holds a foreign-pilot license issued by a contracting State to the Convention on International Civil Aviation that authorizes at least the pilot privileges of the airman certificate sought;

(2) Is applying for a type rating only, or a class rating with an associated type rating; or

(3) Is applying for an airline transport pilot certificate or an additional rating to an airline transport pilot certificate in an aircraft that does not require an aircraft type rating practical test.

Note: Para (a)6 is the one that requires an endorsement. Does not apply in this case.

So just train to proficiency in a SEL airplane and complete an 8710. The ATP PTS contains a matrix which stipulates the required Areas of operation that apply. This can be used as an outline for your test preparation. Confer with a local DPE to verify the correctness of what I have stated here and arrange to take your ATP SEL checkride. Good luck!

Best regards,

Westhawk

[weasil]

Hey thanks for the correction. I haven't instructed in a while so getting a bit rusty on that stuff.

[Phil Squares]

Thanks for the replies. However, those replies don't help at all. The basic problem is every examiner/FSDO/school I speak with has a different intrepretation of what is required.

I have gone as far as contacting the FAA in DC and talking with the person who is responsible for PTS. His response was, "it depends on who you talk to". Simply but, Washington won't impose their interpretation and they leave it up to each region/FSDO to decide.

Not having flown a SE on a consitent basis in a number of years, I am looking for the quickest and least expensive option.

[westhawk]

Phil:

I shared your story with an aquaintence of mine today. He is a recently retired FAA inspector and agreed with my assessment of your situation and what you must do under the regulations to upgrade your SEL rating to ATP privileges. He said if you came to him, he would have given you the ATP SEL checkride and issued the certificate if you passed. When I mentioned that you had gotten different answers from several different sources, he smiled and said he was not surprised! He saw this alot in his 35 year career. His suggestion was simply to find an examiner who agrees that (s)he can give you the checkride. I agree. Not all examiners or inspectors interpret the rules uniformly. Some discretion will sometimes be exersized when rules appear to be contradictory or ambiguous.

In your case, as the holder of an ATP certificate, you only seek to add a class of aircraft within the airplane category to your ATP privileges. Since you are allready an ATP, you do not need a knowledge test, any required training or an endorsement from a CFI. Just a checkride. The rules are right there to read. It's just a matter of finding an examiner who understands and interprets the rules in this way.

I suggest contacting some examiners directly by phone and presenting your situation to them. Seaplane examiners probably encounter this situation more often than most other examiners since they do so many additional class rating flight tests. When you find one who will agree to give the ATP SEL checkride as an additional class rating on your existing ATP certificate, make an appointment for next month. Obtain a current PTS and assure that you are flight and knowledge proficient in all required areas of operation. Even though it is not required, it's still a good idea to get an objective assessment (practice checkride) from a senior CFI as soon as you feel you are ready to begin your preparations for the test. Then you will have a better idea how much study and practice would be prudent before proceeding with the test.

Here is a LINK (http://av-info.faa.gov/DesigneeSearch.asp) to the FAA designee locator page. Search for ATP examiners in your area by selecting ATPE and the FSDO office in the area you desire. The search will return names, addresses and phone numbers.See what you can find out that way.

Best of luck,

Westhawk