Regulatory Brief -- Part 141 changes cost students over $1,000 for additional complex aircraft training

Regulatory Brief

Part 141 changes cost students over $1,000 for additional complex aircraft training

The issue:

The FAA�s 1997 change to part 141 added language that restricts the type of complex aircraft used for commercial single-engine training. The changes to the regulatory language of part 141 require an applicant for a commercial pilot certificate with a single-engine rating to engage in 10 hours of training in a complex single-engine aircraft, regardless of previous complex multi-engine experience.

The importance to our members:

A student who completes training toward their commercial multi-engine pilot certificate and accrues the appropriate number of hours in a complex multi-engine aircraft is required to complete an additional 10 hours of training in a complex single-engine aircraft in order to qualify for a commercial single-engine additional rating. To many students, completing their training at flight schools operating under part 141 means an additional expense of over $1000 in order to meet the minimum experience requirements for a single-engine additional rating.

Significant provisions:

  • During the April 1997 rewrite of parts 61 and 141, two words were added to part �141 D(4)(b)(1)(ii) that appeared to be clarifying in nature and were not believed to have any substantive impact. This supposed clarification changed the reference to the type of aircraft required for "complex" training from an " airplane that has retractable gear, flaps, and a controllable pitch propeller�" to "a single-engine aircraft that has retractable landing gear�"
  • Prior to the language change of �141 D(4)(b)(1)(ii), a number of part 141 schools routinely conducted initial commercial training in multi-engine aircraft. Students could then add their commercial single-engine rating with little additional training. The required 10 hours of complex airplane flight was fulfilled by the complex multi-engine time accrued during initial commercial pilot training.
  • The language contained in �141 D(4)(b)(1)(ii) is inconsistent with unchanged language contained in similar commercial pilot aeronautical experience requirements of part 61. The language of similar sections of part 61 is identical to the language found in part 141 prior to the April 1997 rewrite.

AOPA position:

AOPA opposes the changed regulatory language contained in the April 1997 rewrite of parts 61 and 141. The new regulatory language of �141 D(4)(b)(1)(ii) places a substantial financial burden upon some airman and flight schools operating under part 141 and is inconsistent with long-standing requirements contained in part 61.


On January 26, 1999 AOPA submitted a petition for rulemaking to the FAA requesting that the regulatory language of �141 D(4)(b)(1)(ii) be changed back to its pre- April 1997 rewrite format. On March 11, 1999 the FAA notified AOPA that the petition for rulemaking had been received and was entered into public docket number 29476. AOPA will notify members when the proposal becomes available for public comment.

Related documents:

AOPA petition for rulemaking, January 26, 1999

AOPA Press Release 99-1-042, February 4, 1999

FAA assignment of docket number, March 11, 1999 (requires Adobe Reader)