The SAFE App was created to facilitate CFI/DPE collaboration and ensure a smoother, less stressful check ride experience (and ultimately smarter, safer pilots). Better communication among all parties involved prevents unfortunate surprises on check-ride day where an applicant encounters a "hard stop" due to errors or misunderstanding - missing endorsements, insufficient experience, or inadequate skill/knowlege). Here are a couple common problem areas (some recently clarified by the FAA).
The “long” student cross country can be confusing due to the incomplete description in 61.109. This regulation does not “stand-alone” but depends upon 61.1 (definitions) which requires a “landing at a distance greater than 50nm” to count as cross-country when training. The “push toward minimums” encouraged by many schools, can leave pilot applicants unqualified for their certificate on test day (a bad surprise)! Another subtlety in 61.109 is the requirement for “full-stop landings” in the regulation which also creates problems for unhappy applicants. Repeating expensive training due to a technical error is frustrating. CFIs and flight schools need to know these regulations and their subtlties.
It is not just students and CFIs who are confused by this regulation, there are DPEs who have been accepting the stand-alone description in the reg (with an insufficient cross country) as legal. That is why this subject is covered in the national DPE training for 2021.
Another recent check-ride “hard stop” involves confusion over logging the required instrument time for the commercial pilot certificate. DPEs have been advised to not simply accept an instrument rating as evidence of accomplishing the instrument training required in 61.129. Careful reading r
eveals unique flight elements and a different emphasis for commercial aircraft control vs original instrument flight training. CFIs should make sure the more comprehensive commercial training is correctly completed. Another legal problem is the CFI conducting the required instrument training in 61.129 (commercial) must possess a CFII. If completed by an airplane instructor it is invalic. At the end of this process, add the 61.129 endorsement to the original instrument training endorsement or add the additionally logged hours to satisfy the tegulation. The original guidance in the Hartzell Letter of Interpretation has been clarified in a more recent 2018 Letter of Interpretation to the AOPA.
The lack of a 61.39 “meta-endorsement” is another problem that will stop a flight test before it gets started. This required endorsement verifies that that the recommending flight instructor has flown the required time in preparation for the checkride (usually 3 hours in the last 2 calendar months). Also in 61.39 is the (required) assurance that the CFI corrected the items found to be deficient on the knowledge test.
§ 61.125 Aeronautical knowledge.(a) General. A person who applies for a commercial pilot certificate must receive and log ground training from an authorized instructor, or complete a home-study course, on the aeronautical knowledge areas of paragraph (b) of this section that apply to the aircraft category and class rating sought.
Failure to log required ground training is often a “hard stop” that will prevent a checkride from proceeding. All ratings and certificates specify some ground and flight training. This should logged and available for the examiner on test day. There is no specified number of hours in part 61 training, but the areas to be covered are listed and some recorded ground instruction (varies with the DPE) needs to be part of the application package. A ground school graduation is a perfect example, but part 61 training is often conducted one-on one. PDF formatted tables for logging ground time are available on the SAFE Toolkit App.
All these “gotchas” are also essentials for every CFI preparing for their initial check-ride. Aviation educators are supposed to know all these nuances (and much more) so they correctly prepare their applicants for flight tests.
In addition to the above cautions, SAFE has created a stand-alone (more comprehensive) product to clear up check-ride confusion called “Checkride Ready!™”available on the SAFE App. This material was also published in the blog for VFR and IFR (more on the way!) Fly safely out there (and often)!
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Thank you, David! Excellent information as always. One minor point: I don’t see where 61.109(a)(4) says that the 3 hours of instruction in the preceding 2 calendar months has to be conducted by the recommending instructor. Is there some sort of FAA letter to that effect?
Thanks for sharing this. I shared with out instructors in our school. Quick follow up question. On the cross country above if point C is 52 miles (other distances don’t change), the flight will count as cross country. This is supported by the Sisk LOI. Am I correct? Thanks!
This is a unique and confusing picture (I should have labeled “A” as “point of origination.”) If you start from “A” it does not qualify as a X-C because never goes the (required >50NM from origination. If you start at “B” or “C” it actually would be legal. And YES, you have it right…making either “B” or “C” > 50NM from start would create a legal X-C. New picture posted with “starting point!”