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DPE reform report reflects 'clean sheet' approach

The FAA’s system for managing its designated pilot examiners could be in for a 12-point overhaul proposed in a study released June 17.

A surge in demand for pilots, slowed by the coronavirus pandemic, is making a comeback, and the FAA should upgrade its designated pilot examiner (DPE) program to meet industry’s needs, says a working group that was encouraged to “think with a clean sheet” about how to modernize the DPE system.

On June 17, the working group, led by Experimental Aircraft Association Vice President Sean Elliott, issued a report with 12 recommendations to the group’s parent body, the FAA’s Aviation Rulemaking Advisory Committee. The committee has approved the report and passed it along to FAA management, said Christopher Cooper, AOPA senior director of regulatory affairs, who led one of three subgroups examining a range of DPE-system reforms.

“Although COVID-19 slowed the pilot shortage, the concern is now coming back as strong as before,” the report said. “To continue to meet the industry demands, the reliance on the DPEs will continue to increase. The [working group] doesn’t want DPE availability to hold us back from achieving the pilot needs nationally.”

The Designated Pilot Examiner Reforms Working Group proposed mold-breaking revisions to a stodgy system that is widely viewed as having made the pre-2020 pilot shortage worse.

Focusing on three broad categories of actions defined in the working group’s congressionally mandated charter, the report included recommendations for the selection of future DPE candidates, DPE training and mentorship, and the deployment and oversight of the examiner workforce. Preliminary screening and testing of DPE applicants would be tightened, but some medical requirements that have shortened some DPEs’ careers would be relaxed, with BasicMed playing a role. The report also wrestled with complicated questions of DPE currency and eligibility to administer specialized flight tests.

The DPE selection recommendations led off with a proposed eight-step “selection flow” process to establish “a standardized and structured flow for DPE selection,” ranging from basic qualifications to a practical test and follow-up oversight.

A second recommendation to work with an “updated and enhanced base criteria set” for DPE selection would introduce pre-application knowledge tests and flight proficiency demonstrations for DPE candidates, along with enhanced experience requirements “for service in additional categories and/or classes of aircraft or when seeking to provide testing for some advanced ratings such as the CFI certificate.”

In the DPE training and mentorship subject realm, the recommendations would steer the FAA toward creating a system providing “cradle-to-grave” training records for practical test applicants that would make auditing their experience more efficient. The system, possibly based on the FAA’s Integrated Airman Certification and Rating Application (IACRA) system, could “generate standardized reports for documents such as Notices of Disapproval or Discontinuances by properly documenting satisfactory and unsatisfactory performance,” the working group said, noting that “these reports are traditionally not standardized and are open to interpretation,” complicating retests.

Another recommendation urges the FAA to deploy an automated survey system to track DPE performance and merit by collecting feedback from test-takers.

A recommendation notes that guidance for DPEs who perform flight checks in multiple aircraft types, or DPEs considered specialty aircraft examiners, should be updated to purge inconsistences, clarify concerns about DPEs’ currency and type rating requirements, and ensure “continuity for all examiners.”

The working group recommended allowing medically disqualified DPEs to continue providing service—a step that would be possible if a structure allowing ground-only or flight-only practical tests were implemented. A related recommendation would streamline testing by allowing all practical tests to use the “segmented examination” concept that now allows the ground and flight components of airline transport pilot practical tests to be considered separate activities. (In other words, a practical test could be begun without having to be finished during the same session.)

In the workforce deployment and oversight topic area, the subgroup proposed a recommendation for mentorship of DPEs in which the FAA would establish a formal program “utilizing experienced DPEs to serve as a resource for FAA. This program would benefit all DPEs, especially newly designated DPEs,” it said.

The limited availability of DPEs in localities where the FAA previously addressed scarcity of examiners by waiving geographic constraints on their testing authority could find a permanent fix under a recommendation to “develop and implement a national level oversight structure that focuses on the selection, training, deployment, and oversight of DPEs.” (Noting no expectation of “significant costs” to implement the recommendation, the subgroup requested that the FAA determine its needs within a year of the report’s submission.)

Under another recommendation that could disseminate more information on DPEs’ geographic distribution, the subgroup urged the FAA to improve and promote its centralized designee locator service.

The report saw a potential BasicMed solution for another medical-eligibility concern. Examiners “are presently required to maintain the appropriate medical certification for the performance of pilot in command responsibilities, despite being discouraged while conducting an evaluation flight. Consideration needs to be given to expansion of BasicMed parameters to allow examiners, who may not necessarily be able to presently obtain a Class II medical, to continue conducting evaluations.” The recommendation notes that regulations currently allow flight instructors to perform duties without a current flight physical in some instances. “This ‘common-sense’ approach needs to be carried over to the examiner corps as well,” it said—following up with extensive discussion of the “challenges” posed by the recommendation.

In an effort to balance the supply of examiners against demand for practical tests, the subgroup proposed in a concluding recommendation that examinations by DPEs be limited to six “testing events” per day—the limit necessary “due to safety and quality concerns.” The recommendation acknowledged the difficulty of determining the “appropriate number of examinations” because test lengths vary based on “the type and unique circumstances of each examination.”

The report informally urged the FAA to encourage the aviation industry to develop a DPE code of conduct, noting that it would add professionalism.

AOPA reported in recent years on FAA actions to patch the DPE system, where possible, without extensive overhaul; the working group said it believes that addressing the “gaps” its report identified will ensure that the system can meet aviation’s future needs.

Noting that all working group members “were encouraged to ‘think with a clean sheet’ and not get hung up with previous frameworks and systems that have been in place for decades,” the report concluded by asserting that the recommendations “represent reform that will enable the current cadre of DPEs to continue to provide both expertise and a level of safety assurance for GA.”

AOPA will continue working closely with the FAA to find short-term solutions for the implementation of these important recommendations, assisted by the work of the recently activated AOPA Designated Pilot Examiner Advisory Board, a six-member group of experts assembled to guide AOPA’s advocacy on reform of the FAA’s designee program.

Dan Namowitz

Dan Namowitz

Associate Editor Web
Associate Editor Web Dan Namowitz has been writing for AOPA in a variety of capacities since 1991. He has been a flight instructor since 1990 and is a 30-year AOPA member.
Topics: Advocacy, Training and Safety, Flight Instructor

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