Does the Complex Plane Requirement Matter? (in 2020)

It used to be that if you wanted to earn your commercial pilot certificate (CPL) with single-engine rating or your certified flight instructor certificate (CFI) with single-engine rating, you had to fly a complex plane for your check ride.

What is a complex airplane?

The FAA’s CFR definition of a complex airplane is an airplane that has:

• A retractable landing gear
• Flaps
• A controllable pitch propeller

The definition also includes “airplanes equipped with an engine control system consisting of a digital computer and associated accessories for controlling the engine and propeller, such as a full authority digital engine control; or, in the case of a seaplane, flaps and a controllable pitch propeller, including seaplanes equipped with an engine control system consisting of a digital computer and associated accessories for controlling the engine and propeller, such as a full authority digital engine control.”

Complex airplane requirements pre-2018

As the AOPA and other groups saw it, this requirement “often proved to be a costly and time-consuming impediment to advanced certification for many pilots.”

After receiving and reviewing multiple petitions, in April of 2018, the FAA officially eliminated this requirement stating that they would allow “applicants to use less-expensive airplanes on the practical test that are not complex or turbine-powered.”

So, no more complex airplane requirements, right? Not so fast.

Complex airplane requirements post-2018

You may not need to fly a complex plane for your CPL or CFI check ride, but that doesn’t necessarily mean that you are completely off the hook.  The FAA’s final rule still requires you to spend a minimum of 10 hours training on a more advanced aircraft.

Here’s the thing: to fulfill your 10-hour training requirement, you can fly either a complex airplane or a technologically advanced airplane (TAA)

The FAA defines a technologically advanced airplane in 61.129(j) as:

• (j) Technically advanced airplane. Unless otherwise authorized by the Administrator, a technically advanced airplane must be equipped with an electronically advanced avionics system that includes the following installed components:
  
  (1) An electronic Primary Flight Display (PFD) that includes, at a minimum, an airspeed indicator, turn coordinator, attitude indicator, heading indicator, altimeter, and vertical speed indicator;
  
  (2) An electronic Multifunction Display (MFD) that includes, at a minimum, a moving map using Global Positioning System (GPS) navigation with the aircraft position displayed;
  
  (3) A two axis autopilot integrated with the navigation and heading guidance system; and
  
  (4) The display elements described in paragraphs (j)(1) and (2) of this section must be continuously visible.

Newer aircraft that are equipped with a full glass cockpit qualify as TAA, as do older aircraft that have been retrofitted with the appropriate new avionics. If you have a TAA, you can train in that and still avoid the need for a complex airplane.

At this point, you may be wondering, “Does the complex plane requirement even matter anymore? Who is actually required to train in a complex plane in 2020?”

Who needs to train in a complex plane?

The bottom line is that as of 2018, only pilots who are pursuing a complex aircraft rating must actually train in a complex plane, and even then, the FAA has allowed some leeway to use a simulator.

FAR Part 61 Sec. 61.31e states that in order to act as pilot in command (PIC) of a complex airplane, a pilot must have:

• Received and logged ground and flight training from an authorized instructor in a complex airplane or a flight simulator/flight training device that is representative of a complex airplane.
• Been found to be proficient in the operation and systems of the airplane
• Received a one-time logbook endorsement from the instructor

Summary

If you are pursuing your commercial pilot certificate (CPL) with single-engine rating or your certified flight instructor certificate (CFI) with single-engine rating, you can train in and use for your check ride any aircraft that qualifies as technologically advanced. The complex plane requirement no longer applies to you.

Pilots who want a complex airplane endorsement may train and prove competency in either a complex airplane or a simulator.

Want to learn more? ASA Aircraft Systems for Pilots by Dale De Remer does a great job of covering advanced aircraft systems.