Guest Opinion: DPE Experience Requirements Updated

Photo credit FlugKerl2 via Wikipedia Creative Commons

Most pilots haven't given much thought to the requirements that the examiner must meet in order to qualify as a Designated Pilot Examiner (DPE). However, recent changes to the PIC requirements for examiners may have a direct impact on pilots trying to schedule a check ride.

Historically, experience requirements for PIC qualifications for examiners were not stringently applied or were unclear. A little over a year ago, interpretation of verbiage in the FAA Order 8900.2 resulted in the belief that in order to remain an examiner, an examiner must have at least 300 hours of PIC flight time within the preceding year in each category and class of aircraft for which he holds examining authority — think 300 hours in single-engine, 300 more hours in a multiengine, and perhaps additionally 300 more hours in a rotorcraft if an examiner was so qualified as to be a multiengine, single-engine and rotorcraft examiner, for a total of 900 hours PIC time each year. Keep in mind that the time that an examiner spends conducting practical tests does not count toward these numbers. Accumulating these hours on a yearly basis can be very difficult for many examiners to meet, and if they did, would probably result in them not having any extra available time to actually conduct practical tests. Fortunately, a re-interpretation and revised qualification requirements were issued in the FAA Order 8900.2A that was released last week.

The new requirement indicates that in airplanes, an examiner must have logged at least 60 hours PIC (with 10 hours in each category and class of aircraft authorized) to remain current as an examiner within the preceding year to the renewal of their examiner authorization (most examiners renew their authorizations yearly). Other requirements are designated for light-sport aircraft, rotorcraft, gliders, etc., which can be found in FAA Order 8900.2A available on

Although the requirements to remain active as an examiner have been reduced to what seems a much more logical experience level, it has raised some debate in the examiner community, as some do not feel that this is a reasonable requirement and expectation of examiners. Others would argue that if an examiner is not actively flying a minimum number of hours in the categories and classes in which they are authorized to conduct practical tests, they are not likely keeping current enough to properly administer tests.

I am personally aware of some long term examiners who have served the industry for 20, 30, or even 40 or more years as examiners that will not meet the new requirements. They will probably be forced to relinquish their examiner qualifications.

You may be asking what this has to do with you as a pilot. Well, that depends on whether you will need to take a practical test sometime in the future.

There is concern that the result may be some loss of some capacity of practical test availability in some areas. It's just math: If we have fewer examiners, fewer practical tests can be given. Unless other examiners are brought into the system, which is time consuming and difficult, capacity is likely to be affected. In some places, practical tests may become more difficult to schedule. Some examiners who have many years of experience may also be eliminated.

There are some discussions in the examiner community that may allow for mitigation, however. One consideration could be to allow examiners to "count" time as they conduct practical tests toward the requirement. Even if it was allowed in a 2-to-1, 3-1, or 4-to-1 ratio, it might solve the problem for many examiners. Another consideration would be to allow instruction time given as a simulator instructor or to allow SIC flight time to count for examiners. But at this time these are just discussions. I am aware of no official FAA consideration that is being given, or in fairness, that has officially been requested for alternate means of experience qualification.

The effects of the changes won't be immediate. They will become effective throughout the next year as examiners come up for authorization renewal. But they will slowly become a reality.

A question is at hand. Are the changes that have been made appropriate? Do the new requirements make sense? Do they give us better examiners or do they remove a group of experienced examiners that still has much to give to the aviation community?

What do you think?

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Jason Blair is a flight instructor and an FAA designated pilot examiner, and an active author in the general aviation and flight training communities.

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