Part 141 Vs Part 61: A DPE’s Take

Part 141 Vs Part 61: A DPE’s Take

I often get asked the question by prospective flight school students on the best places to go for flight school. There are so many options and so many different paths to obtaining a career in aviation, and it’s often hard to determine the best course of action. However, one of the most common questions I get asked is whether or not to go part 61 (informal instruction) or part 141 (formal and highly regulated).

I will preface this with the fact that there are many part 61 flight schools that operate like 141 schools but without issuing a graduation certificate at the end. For example, ATP and American Flyers have part 61 students involved in a rigid training program that has “checks and balances”, although not required legally by the FAA. The students get the benefit of a rigid, formal training program but still have to meet the aeronautical experience requirements which are often much more hours than a part 141 program.

For the sake of this article, I will address the observations I have had when comparing a typical part 61 student from an independent, smaller flight school to a part 141 student in a formal, FAA approved training program.

I will start by comparing the aeronautical experience requirements:

This image is a bit oversimplified as there are specific requirements for both that aren’t mentioned in the paragraph, but you can see that 141 programs have less total hours. I will say this about my general observations during practical exams: more experience (often equated to hours at these lower levels) generally means better overall performance. While this isn’t always the case, applicants who come with 70 hours for a practical exam usually do better than those who come with exactly 40.5 hours for their private pilot exam. For the commercial, I don’t see much of a difference in hours as I do see a difference in preparation. People who have flown more with a flight instructor recently do better than those who worked toward their commercial over several years and are pulling out old logbooks to show cross countries. Recent experience and amount of training tends to be the biggest indicator of performance with commercial.

Instrument is a completely different situation as it highly depends on the applicant and training. For example, under part 61, an applicant needs only 15 hours with an instrument instructor and the other 25 can be with a safety pilot. When I see applicants with the minimum with an instrument instructor (which is usually earlier on in training so they can gain the skills to go fly with a safety pilot), the performance usually isn’t as good as an applicant who got all 40 hours with an instrument instructor. Since part 141 requires the entirety of the training to be with an instructor, even though it’s less hours than that of part 61, they tend to do better on exams.

I also often get asked about the role of simulator training. I have seen this go both ways. If the applicant has a quality instructor, the simulator time often results in better performance specifically for instrument. While some applicants use simulator time to count toward the 35 or 40 hours for instrument, I often see the best performance when the simulator time is in addition to the time in the airplane. When I see an applicant for an instrument rating with 20+ hours of simulator time and 40 hours of training with an instructor, I usually see a recipe for success. The problem that most people have for an instrument exam is getting behind the airplane, and simulators help an applicant learn to manage the airplane and procedures. However, simulator training is never an equal substitute for time spent in the airplane navigating real world challenges like weather, ATC, etc. In a controlled environment, I believe almost everyone could probably pass an instrument exam on the first try. But real world flying is rarely that easy, and often missteps due to weather, ATC, etc often lead to threats and mismanaged errors that result in exam failures. I wrote about this phenomenon in a previous article on Check Ride Threat and Error Management (https://fullthrottleaviation.wordpress.com/2022/02/24/dpe-hot-spots-threat-and-error-management-for-unexpected-ifr-scenarios%ef%bf%bc/).

So while this isn’t a clear answer on whether or not to go part 61 or 141, I will summarize the following general observations:

  1. Part 61 students often have more actual flight hours, and I see a general trend that more experience leads to better performance.
  2. Part 141 students rarely come to an exam missing aeronautical experience requirements.
  3. Part 141 students have more time with an instructor overall, and usually more recent experience as there are specific requirements for graduating from 141 programs.
  4. Part 141 students usually are working on flight training full time compared to part 61 students who often have other careers, jobs, or obligations.
  5. If I have two students, one of which is part 61 and the other 141, and they have the exact same amount of hours and experience (same hours with a CFI, same recent experience, same aeronautical experience requirements), then the performance is generally the same.
  6. I see the best performance from applicants who have recent flight training experience with a CFI, regardless of part 61 or 141.
  7. I see the best performance from applicants who have flown more with a CFI and less on their own to get the total hours required, regardless of part 61 or 141.

It’s a hard decision to make on which route to take. I see success with both, but it often depends on the applicant and school. If a student is proactive and goes above and beyond the minimum, they do very well part 61. If a student doesn’t pay attention and takes many breaks during training and does the absolute minimum, there’s no checks and balances in place to make sure they are prepared for an exam under part 61 like there is under 141.

Please feel free to leave any feedback about your training experience. I have seen wonderful applicants from both 61 and 141, and these are general observations I have seen over the past few years of practical exams I have administered.

Sarah is currently a FAA Safety Team Lead Representative, NAFI Master Instructor, Gold Seal Flight Instructor, and 737 captain for a Major U.S. airline. Sarah holds an ATP, CFI, CFII, MEI and has flown over 8800 hours. She holds a pilot license in 4 different countries (USA, Canada, Belize and Iceland – EASA) and has flown over 150 different types of airplanes in 25 different countries including oceanic crossings in small aircraft. Since aviation for work isn’t enough, she also lives in a hangar home on the west side of Houston! Although much of her flying is now professional in nature, she enjoys flying her Super Cub, Patches, on her days off. As a regular attendee of Oshkosh and local fly-ins, she enjoys the company and camaraderie that general aviation brings and is passionate about aviation safety and flight training. 

Oh no! My Flight Instructor Certificate Expired! Anything I can do?

It’s an unfortunate story I hear all too often as a DPE. A flight instructor missed renewing by their expiration date. Perhaps it was a technical issue and it wasn’t processed like it should have been in IACRA. Perhaps they forgot the exact month due to the month of the year changing at some point in their long tenure as a CFI. Now you’re stuck and trying to figure out how to get it back… so what are the options?

While I have heard of either local (FSDO) or national (Airmen Certification Branch) stepping in to help, it is very rare. The only way to resolve this would be if there was some sort of issue that was the fault of the DPE, FSDO, or Airmen Certification Branch. An example of this might be if the application for renewal was submitted by the applicant, signed by the certifying official, and then the airmen certification branch sent a correction notice (perhaps a wrong date of birth or other clerical error) that wasn’t forwarded properly or was missed. In that case, the activity was complete and documented, but required further action. In scenarios as such, the applicant is generally safe and after correcting the issue, the certificate can be issued. However, in cases where the FAA had never received any of the paperwork (application not submitted and certified), there is no way to “go back” and fix it clerically.

So now the applicant is left with the only options being a practical exam with an examiner as detailed in FAR 61.199:

§ 61.199 Reinstatement requirements of an expired flight instructor certificate.

(a) Flight instructor certificates. The holder of an expired flight instructor certificate who has not complied with the flight instructor renewal requirements of § 61.197 may reinstate that flight instructor certificate and ratings by filing a completed and signed application with the FAA and satisfactorily completing one of the following reinstatement requirements:

(1) A flight instructor certification practical test, as prescribed by § 61.183(h), for one of the ratings held on the expired flight instructor certificate.

(2) A flight instructor certification practical test for an additional rating.

(3) For military instructor pilots, provide a record showing that, within the preceding 6 calendar months from the date of application for reinstatement, the person—

(i) Passed a U.S. Armed Forces instructor pilot or pilot examiner proficiency check; or

(ii) Completed a U.S. Armed Forces’ instructor pilot or pilot examiner training course and received an additional aircraft rating qualification as a military instructor pilot or pilot examiner that is appropriate to the flight instructor rating sought.

Out of all of these options for civilian pilots, the reinstatement practical exam is probably the shortest and easiest to accomplish. The PTS governs the activities required, and is very specific as to the requirements for reinstatement. For example, an applicant looking to reinstate all of their flight instructor ratings by taking a flight instructor airplane single engine practical exam will need only the following:

When we break down above, it only comes down to a fairly short exam. Here is an excerpt from my plan of action for a CFI reinstatement exam:

While it is a fairly short exam, the examiner can pick from any of those areas so being proficient in all of them is important. The same goes for a flight instructor instrument reinstatement:

While preparation is important, the reinstatement exam doesn’t require nearly as many tasks as an initial practical exam or adding a new rating. However, many people might want to use the opportunity to gain a new rating (such as multi engine instructor), which has its own additional task matrix in the PTS when adding an additional rating to an existing flight instructor certificate. Upon completion of the exam, an applicant would have all of their ratings back and it resets the clock for 2 years from the date of the exam for the expiration date.

An applicant doesn’t need a flight instructor to endorse them for the exam, but if an applicant fails the exam, then FAR 61.49 (retesting after failure) would apply, which requires an instructor to endorse the applicant for a retest.

Sarah is currently a FAA Safety Team Lead Representative, NAFI Master Instructor, Gold Seal Flight Instructor, and 737 captain for a Major U.S. airline. Sarah holds an ATP, CFI, CFII, MEI and has flown over 8700 hours. She holds a pilot license in 4 different countries (USA, Canada, Belize and Iceland – EASA) and has flown over 150 different types of airplanes in 25 different countries including oceanic crossings in small aircraft. Since aviation for work isn’t enough, she also lives in a hangar home on the west side of Houston! Although much of her flying is now professional in nature, she enjoys flying her Super Cub, Patches, on her days off. As a regular attendee of Oshkosh and local fly-ins, she enjoys the company and camaraderie that general aviation brings and is passionate about aviation safety and flight training. 

What Leads to Practical Exam Failures: Threat and Error Management

What Leads to Practical Exam Failures: Threat and Error Management

I am often asked what areas applicants struggle the most on, and where most failures occur. While the answer to this question ranges dramatically from the type of exam to the student, it usually begins with a threat that leads to an error, and eventually an undesired aircraft state and/or exceedance from the ACS or PTS standard. While the concept of Threat and Error Management is somewhat foreign to the new private pilot, it applies very well to our daily operations and I see it in action on a regular basis as a designated pilot examiner.

I will start by discussing the definitions:

Threats are events that occur beyond the influence of the pilot(s), increase operational complexity, and which must be managed to maintain the margins of safety.

Errors are defined actions or inactions by the flight crew that lead to deviations from pilot intentions or expectations. 

Undesired Aircraft States are pilot induced aircraft position or speed deviations, misapplication of flight controls, or incorrect systems configuration, associated with a reduction in margins of safety.

While the entire Threat and Error Management concept is lengthy, I will simplify it for this brief discussion. Threats exist everywhere in our operation. Weather, a busy controller, a busy airport, and heavy training traffic are just a few that we often encounter on practical exams. These are threats that can lead to errors if not caught. As part of my briefing to applicants, I often tell them that “perfection is not the standard.” Even as airline pilots we are not immune to making mistakes and errors. However, we are trained to use our toolbox which includes procedures, crew resource management, and aeronautical decision making to keep us from ending up in an Undesired Aircraft State (UAS). While the UAS definition can vary, most deviations from the ACS standard for the purposes of the practical exam are considered a UAS. The importance of this model is to realize that uncorrected errors lead to a UAS, and recovery is paramount to avoid exceeding the standards. An uncorrected UAS will likely lead to an accident, incident or violation; and for practical exam purposes, a notice of disapproval.

That being said, the reason I bring this up is because the areas I see applicants struggle the most on are threats that lead to errors. Sometimes this is because of a lack of training, nerves, fatigue, or a plethora of other factors. 

I will bring up an example to illustrate this point:

On a practical exam, an applicant failed to descend on the glideslope on an ILS approach. Realizing the mistake after trying to descend and recognizing the approach was unstable due to being so high, the applicant used good judgement and decided to execute a missed approach. However, the applicant had never practiced a missed approach from an altitude above the minimums on the plate, and was confused about when to turn and what altitude to fly. In this scenario, a busy controller and task saturation led to a late descent, which resulted in an error of being too high and unstablized, and the lack of knowledge and training led to an undesired aircraft state of flying past the missed approach point at an inappropriate altitude.

The ACS is meant to be scenario based, but in real life instrument procedures are rarely like we practice. I have rarely gone missed off an instrument approach due to weather. After all, we normally don’t attempt an approach when the real-life weather is below minimums. There are exceptions to this rule, but generally we would look at diverting when weather drops below minimums. I have been instructed to execute a missed approach by ATC more times than executing a missed approach due to weather.

If applicants apply the Threat and Error Management concepts to their single pilot operation and practical exam, they would see improvement in their performance. Understanding the threats they encounter and having tools to recognize and recover from errors is key to mitigating problems before they become tolerance exceedances or undesired aircraft states.

The key takeaway from this article is that real life (and even practical exams) are not always like the training environment. We try to do our best to put controls in place to make the evaluation as easy as possible; but we can’t control variables such as busy controllers, traffic, and other situations that lead less than desirable conditions. By recognizing these threats an applicant can work to increase their situational awareness and develop methods to reducing errors and recovering from a UAS. It’s usually threats that lead to errors and errors that lead to UAS that make a practical exam unsatisfactory. This applies to many of the practical exams I have given, and my hope is that applicants can prepare for real world flying in their training. After all, my job is the gatekeeper before the real world, and the ACS demands that the applicant is prepared to exercise those privileges at the end of the practical exam.

If you want more reading on Threat and Error Management, check out:

Free FAA Safety Presentation on Threat and Error Management (for WINGS Credit): https://www.faasafety.gov/gslac/ALC/course_content.aspx?cID=556&sID=983

https://skybrary.aero/articles/threat-and-error-management-tem

Sarah is currently a FAA Safety Team Lead Representative, NAFI Master Instructor, Gold Seal flight instructor, and 737pilot for a Major U.S. airline. Sarah holds an ATP, CFI, CFII, MEI and has flown over 7300 hours. She holds a pilot license in 4 different countries (USA, Canada, Belize and Iceland – EASA) and has flown over 150 different types of airplanes in 25 different countries including oceanic crossings in small aircraft. Since aviation for work isn’t enough, she also lives in a hangar home on the west side of Houston! Although much of her flying is now professional in nature, she enjoys flying her Super Cub, Patches, on her days off. As a regular attendee of Oshkosh and local fly-ins, she enjoys the company and camaraderie that general aviation brings and is passionate about aviation safety and flight training.

A DPE’s Take on Deciphering the ACS: Emergency Descent

A DPE’s Take on Deciphering the ACS: Emergency Descent

When I begin my briefings with applicants, I often begin with stating that the ACS is the standard. Sometimes I have students and flight schools asking me how I want to see certain maneuvers, and I always point them to FAA published materials to answer their question. There is no certain “way” that I want to see a maneuver – if the maneuver is compliant with the ACS and the applicant demonstrates proficiency, risk management, and good judgement – then it is satisfactory. However, there are times where the ACS does leave a lot to the discretion of the applicant and/or examiner, so I figured I’d discuss the process for determining how to complete a task.

The question came up on a group on social media where a student was asking the community how to perform the Emergency Descent maneuver (PA.IX.A). The student began with saying that his instructor had told him to accelerate to VNE (never exceed speed). He then asked if this was how you were supposed to complete the maneuver, to which I would say as a DPE “it depends.” The ACS task states that the applicant demonstrates the ability to: 

  • • PA.IX.A.S1 Clear the area. 
  • • PA.IX.A.S2 Establish and maintain the appropriate airspeed and configuration appropriate to the scenario specified by the evaluator and as covered in POH/AFM for the emergency descent. 
  • • PA.IX.A.S3 Maintain orientation, divide attention appropriately, and plan and execute a smooth recovery. 
  • • PA.IX.A.S4 Use bank angle between 30° and 45° to maintain positive load factors during the descent. 
  • • PA.IX.A.S5 Maintain appropriate airspeed +0/-10 knots, and level off at a specified altitude ±100 feet. 
  • • PA.IX.A.S6 Complete the appropriate checklist.

The emphasis on “how” really falls under skills section 2, where the ACS directs the applicant to: “Establish and maintain the appropriate airspeed and configuration appropriate to the scenario specified by the evaluator and as covered in POH/AFM for the emergency descent.” One important thing to note is that the evaluator should be providing a scenario which requires the use of this maneuver. If the examiner doesn’t specify, then it might be prudent of the applicant to ask since the emergency may impact the configuration chosen by the applicant. That being said, many small general aviation airplanes do not have a specific emergency descent procedure detailed in the POH/AFM. So the question becomes, how do we perform the maneuver without direct guidance from the manufacturer? 

While not an all-encompassing list, the accomplishment of any task generally falls within the following guidance or priority: 

  1. Airplane manufacturer specifies through the POH/AFM.
  2. Approved procedures by the operating certificate holder (such as a 121 or 135 operator, or 142 training center approved syllabus).
  3. Recommended procedures through FAA published material (Advisory Circular, Airplane Flying Handbook, etc).

When we don’t have options 1 or 2, we then must revert to option 3. There are several resources for the maneuver through FAA published material.

The Airplane Flying Handbook, Chapter 17, discusses the maneuver: “Emergency descent training should be performed as recommended by the manufacturer, including the configuration and airspeeds. Except when prohibited by the manufacturer, the power should be reduced to idle, and the propeller control (if equipped) should be placed in the low pitch (or high revolutions per minute (rpm)) position… The pilot should not allow the airplane’s airspeed to pass the never-exceed speed (VNE), the maximum landing gear extended speed (VLE), or the maximum flap extended speed (VFE), as applicable. In the case of an engine fire, a high airspeed descent could blow out the fire. However, the weakening of the airplane structure is a major concern and descent at low airspeed would place less stress on the airplane. If the descent is conducted in turbulent conditions, the pilot must also comply with the design maneuvering speed (VA) limitations. The descent should be made at the maximum allowable airspeed consistent with the procedure used. This provides increased drag and, therefore, the loss of altitude as quickly as possible. The recovery from an emergency descent should be initiated at a high enough altitude to ensure a safe recovery back to level flight or a precautionary landing.”

Advisory circular AC 25-20 also discusses emergency descent procedures specific to pressurized aircraft. While pressurized aircraft operations are generally not evaluated through this maneuver on a private pilot practical exam, it’s important that an applicant understands WHY we would use an emergency descent procedure and can accomplish it based on the scenario presented by the evaluator. As mentioned above, turbulence and type of emergency (such as a fire) can and will dictate the speeds and configuration to use.

So the question still persists: what speed and configuration to use when we don’t have manufacturer’s guidance?

Many students often don’t read the foreword and after words of the ACS. In the very first page after the table of contents, the ACS goes on to say:

“Safe operations in today’s National Airspace System (NAS) require integration of aeronautical knowledge, risk management, and flight proficiency standards…The ACS integrates the elements of knowledge, risk management, and skill listed in 14 CFR part 61 for each airman certificate or rating…The flight portion of the practical test requires the applicant to demonstrate knowledge, risk management, flight proficiency, and operational skill in accordance with the ACS.”

At the end of the ACS, there is a paragraph on Aeronautical Decision-Making:

“Throughout the practical test, the evaluator must assess the applicant’s ability to use sound aeronautical decision-making procedures in order to identify hazards and mitigate risk. The evaluator must accomplish this requirement by reference to the risk management elements of the given Task(s), and by developing scenarios that incorporate and combine Tasks appropriate to assessing the applicant’s risk management in making safe aeronautical decisions.”

As an examiner, I’m looking for mastery of the ACS task through evaluation. Risk management and decision making is paramount to the successful execution of any task, and I look for that in every maneuver. If an applicant chooses a configuration and airspeed that is appropriate for the scenario according to the manufacturer, approved course/operation, or FAA published guidance; then that maneuver will be satisfactory as long as all of the elements of the ACS task are met.

References:

Click to access AC25-20.pdf

Click to access 19_afh_ch17.pdf

Click to access private_airplane_acs_change_1.pdf

Sarah is currently a FAA Safety Team Lead Representative, NAFI Master Instructor, Gold Seal flight instructor, and 737 pilot for a Major U.S. airline. Sarah holds an ATP, CFI, CFII, MEI and has flown over 7300 hours. She holds a pilot license in 4 different countries (USA, Canada, Belize and Iceland – EASA) and has flown over 150 different types of airplanes in 25 different countries including oceanic crossings in small aircraft. Since aviation for work isn’t enough, she also lives in a hangar home on the west side of Houston! Although much of her flying is now professional in nature, she enjoys flying her Super Cub, Patches, on her days off. As a regular attendee of Oshkosh and local fly-ins, she enjoys the company and camaraderie that general aviation brings and is passionate about aviation safety and flight training.