If you are one of the 806,940 pilot certificate holders reported by the FAA in its 2023 airman statistics, you will probably be familiar with a DPE, or designated pilot examiner. Over the years the FAA has gradually shed its responsibilities for carrying out most practical tests in favor of independent designees who are appointed at the “pleasure” of the FAA administrator. In normal speech, this means they can appoint and fire them whenever they want for pretty much any or no reason.
Many years ago, when the FAA was conducting most of the tests, and a few DPEs were allowed to roam free, they were a popular alternative despite charging for their services. Legend has it that this willingness to pay was primarily due, depending on the storyteller, to give the applicant an easier ride or, later on, decreasing FAA willingness to conduct them.
Certainly, flying to a Flight Standards District Office (FSDO) location involved an aircraft inspection which led to many stranded aircraft deemed unairworthy. It would probably be fair to say that flight schools and instructors lacked enthusiasm for the FAA route despite it being free, thereby opening the way to a massive expansion of both DPEs and the tests they could conduct.
There was a time when supply and demand for DPEs appeared to be somewhat in balance with candidates able to access practical tests within reasonable periods of time. The FAA allows a candidate who has conducted training under Part 61 to remain eligible to start that test for a period of two months from the end of the month in which the sign off took place—so potentially close to three months.
Part 141 graduates are required to have passed their external check rides (ironically also under Part 61-61.71) within 60 days of completing their in-house final end-of-course flight test. Both periods of time seem pretty extended, given that everybody is likely to lose proficiency if they are not actively training/practicing for long periods of time.
Today’s challenge is that many candidates who have successfully completed their courses are waiting many months for a check ride and, with increasing frequency, are, in fact, timing out due to their inability to find an examiner. So what does this mean in practice?
- Significant extra costs to maintain currency and skills while waiting for the tests.
- Additional stress from having to wait.
- Degree students who are failing their course because they are not able to get an external examiner checkride within the time limits imposed by their colleges and Veterans Administration rules, despite successfully completing all of the required course work.
- Students are being turned away from being able to enroll in courses, not because of lack of training capacity, but because there is no DPE available to commit to a check ride when they are ready.
- Large numbers of candidates stuck in training but not testing limbo with no clear resolution in sight.
- Inability to run short/accelerated programs that depend on a check ride to be able to complete the process.
- Significant economic harm at all levels.
The DPE shortage has been the subject of a lot of heated debate. On September 25, 2024, five members of Congress and a U.S. senator wrote a letter to the FAA administrator outlining the many concerns regarding availability of DPEs and how the agency was proposing to deal with them. Here’s one telling passage in that letter:
“While the FAA currently authorizes 935 DPEs to administer tests, 75 percent of tests are administered by only 350 examiners, with 50 percent of tests administered by roughly only 200 DPEs. This gross lack of active examiners is exacerbating an already significant pilot and examiner shortage that threatens the stability of our national air service network, particularly for regional airlines and the communities they serve.”
The 2023 FAA Airman Statistics report shows that a total of 119,908 tests were conducted of which DPEs were responsible for 118,524, or 98.85 percent, of all tests. Including the data from the congressional letter, this would provide the following (rounded) numbers:
- Average number of tests per authorized examiner—127, or a little over two per examiner per week.
- There are 254 tests being carried out per year by around one-third of examiners or about five per week per examiner.
- About 200 DPEs are averaging 296 tests per year each.
- Most DPEs (approximately 585) are conducting about one test per week.
In a response to a specific information request, the FAA confirmed that it does not collect or maintain statistics on exactly how much is charged by the average DPE, so calculating the value of the current DPE “market” is more art than science.
When seeking out DPEs around the country, numbers are often quoted in the range of $600-$1,200, depending on location and type of test. Not surprisingly, the higher numbers seem to come from the areas of highest flight training activity such as Florida.
Suffice it to say that there are clearly financial incentives in place to attract additional DPEs and customers willing and able to pay them. So why is there still a shortage?
This is where, unfortunately, we move from objective assessment into urban legend because, despite the process being laid out in substantial detail in FAA Order 8000.95D, dated January 21, 2025, and many people wanting to become DPEs, the actual number of truly active ones remains very low. Perhaps surprisingly, an instructor with as few as 200 hours of dual given in the previous three years could meet the minimum qualifications required, assuming other criteria were also met.
So, on the face of it, with, according to the same FAA Airman Statistics, 131,577 pilots holding CFI certificates at the end of 2023, the choice does not seem excessively narrow. As previously noted, there are significant financial incentives in place to become a DPE, and apparently a lot of qualified people willing and able to take it on, so based on normal economic theory, there should be no shortage.
The FAA would likely argue that the shortage is due to a lack of candidates who can both meet the standards laid out in FAA Order 8000.95D and are able to convince an agency inspector that they have what it takes. The reality is that even in a highly prescriptive process, there will always be a degree of subjectivity. Some prospective candidates might argue that different FSDOs have different “standards,” and others might suggest a possible bias.
I requested specific data from the FAA on the numbers of applicants for DPE positions, statistics on how many of them met the minimum standards, how many were finally accepted, and whether data was kept in order to identify any differences between FSDO regions. The FAA responded that it does not “track some of your requested data” and that it has “…added more than 186 DPEs nationwide since October 2024.” The agency also indicated that the number of DPEs increased “by 10 percent in fiscal year 2024.”
In a subsequent response, the FAA Office of Communications provided additional detail : “…The FAA averaged 220 applications per year over the last five years…[Ninety-four] percent of DPE applicants meet the specific minimum eligibility requirements…The FAA appointed more than 60 qualified DPEs on average per calendar year over the last five years.”
At first sight the numbers seem to support the notion that each year has seen an increase in DPEs available for conducting tests. However, in response to a follow-up question, I got the following statement: “On average in each of the last five years, 58 designated pilot examiners (DPEs) left their positions for a variety of reasons.”
Based on the FAA numbers, of the qualified applicants assessed, only 29 percent, on average, were appointed as DPEs over the last five years. Unfortunately, without more detailed explanations of why 71 percent did not make the grade, it would be impossible to conclude one way or another whether this was the result of possible bias or simply a large number of poor applicants.
What Does the Future Hold?
The FAA and industry groups have talked long and hard about increasing DPEs with any number of DPE forums and similar, but the net results have been underwhelming and do not appear to have resolved, or come close to resolving the shortages.
This article was originally going to propose solutions but, in a major surprise, the FAA published Draft Order 8100.15C on July 22, 2024, and invited public comments. At 446 pages it was more likely to attract severe insomniacs looking for a definitive end to their sleepless nights, than the average pilot.
The comment period ended on October 21, 2024, leaving the FAA to review and weigh the very few comments made prior to issuing a final order in the Federal Register. Once that order has been published, there will be a phased implementation of the new rules. This order covers an area of policy that allows the FAA to delegate some of its responsibilities to qualified organizations, known as ODAs (organization designation authorization) as authorized under 14 CFR Part 183 subpart D.
These ODAs have long existed for type certification, STCs, PMAs, and other functions, but this revision includes one radical new ODA type (airman certification) and removes one (airman knowledge testing, or AKT). The FAA can, and does, also give delegations to individuals, including DPEs, and these would still exist and remain in force.
In section 2-2 of this order, the reasoning given by the FAA for having an ODA is that “managing organizations is more efficient for the FAA than managing the activity of many individual designees.” The FAA also goes on to say, in a roundabout way, that it expects this to eventually lead to fewer individual designees.
The Airmen Certification ODA (AC ODA) would have a prerequisite that the holder also has an “appropriate Air Carrier or Air Agency Certificate under 14 CFR Parts 121, 135, 141, 142, 145, or 147.” As we are only discussing DPE shortages, the focus of interest is on an ODA based on a Part 141 pilot school certificate.
Assuming a Part 141 pilot school was able to qualify as an ODA, it would be authorized to carry out check rides “in accordance with Part 61” as well as some other tasks relating to airmen certification activities. For those not familiar with Part 141, graduates of the courses would either go through a normal Part 61 check ride as provided for in 14 CFR Part 61.71, or be “self-examined” by the school if the course was so authorized.
There are a number of important takeaways from this:
- “Unit members” (examiners) conducting check rides under the ODA would have to meet all of the same experience and certification requirements as individual DPEs.
- An ODA cannot be used for self-examining under Part 141, meaning that a successful end of course would still be required prior to a formal check ride by an examiner/unit member.
- An ODA is not limited to testing only its own students. Indeed, the whole point is to widen the availability of check rides for all customers.
How Practical a Proposition Is This?
Success is usually determined by a combination of need, financial viability, and complexity. The need is well documented and proven. Without additional check ride capacity, there is no doubt that flight schools and students are being significantly, and adversely, financially affected. While the complexity is probably no more than is already present for most other certificates held such as Part 141.
Existing DPEs may not be entirely enthusiastic to see perceived competition in the form of ODAs, and FSDOs may also be reluctant to take on additional supervisory roles. There is certainly an envisaged outcome that would see much greater and faster access to check rides, lower fees for taking them, and substantially increased business for flight schools who can increase their capacity thanks to the availability of enough examiners.
The alternative viewpoint would be, as expressed by an anonymous commenter, a partial removal of the independent DPE diligently acting as the delegated eyes and ears of the FAA to monitor safety, leading to a substantial lowering of standards.
So Is an ODA Simply Multiple DPEs on Steroids?
Not exactly. An ODA will require a full-time administrator and FSDO-approved manuals/written procedures covering their operations from selecting examiners (unit members), ensuring they are qualified to the required minimums, training, scheduling, supervision and internal audit.
Unlike the FSDO, the ODA’s administrator will only be focusing on this activity knowing that they will also have to justify their continued existence to FSDO oversight and external audit. Unlike the FSDO, the ODA would be free to take on as many unit members as it believes it can usefully employ. It is probably expected, but not stated, that the role of examiner for an ODA could be only one part of that person’s employment, so we will probably see a broadening of current instructional experience by those holding unit member approvals.
What Are the Potential Downsides and How Can They be Mitigated?
As one very large school indicated in its comments, its resources would be entirely focused internally due to its own high demand. Arguably that could breach part of Order 8000.95D that covers the responsibilities of DPE’s.
These are laid out in Chapter 5 on pages 3-29, and specifically items (1) and (2) under “2.f”:
- (1) Provide FAA testing and certification activities without prejudice or discrimination in a fair and unbiased manner.
- (2) Honor appointments made as promptly as possible. The designee is also expected to make their services available to all applicants on an equitable basis.
However, while the ODA order references 8000.95D when it comes to qualifications required by a unit member (examiner) as being the same as for a DPE, it does not appear to specifically incorporate the same expectations for the ODA as would exist for an individual DPE. Perhaps, that is implied, but it would be better for it to be explicitly stated.
However, many people believe that these two expectations plus number (6),—“Charge no more than a reasonable fee for services”—are not being systematically enforced for DPEs. My questions to the agency:
- “Does the FAA keep any data on what DPEs charge for the tests?
- “Does the FAA maintain any data on the degree to which DPEs are meeting, or failing to meet, these criteria?
The FAA responded to the first with a “no,” and then an additional comment: “DPE fees are influenced by a variety of factors, including the cost of living in the region where the testing is taking place, infrastructure and equipment availability, and the concentration of applicants.”
In response to (b), the FAA indicated that the“…[agency] employs DPE managing specialists in most Flight Standards District Offices who routinely review each DPE performance to ensure they are meeting the requirements of FAA Order 8000.95D. These specialists also respond to failures of any DPE to meet the requirements of established FAA policy. For any representative of the FAA administrator (including DPEs), the FAA takes action to respond to issues related to prejudice and discrimination.”
Both answers really boil down to saying that the FAA does not collect or keep the data requested but that, even without it, it is able to ensure that all expectations are being met. It is notoriously difficult to prove compliance with anything if there is no data being compiled and analyzed. A couple of simple examples:
- Does a DPE who predominantly carries out tests for only one school in an area of general DPE shortages and turns down requests from other schools reasonably meet the test of, “The designee is also expected to make their services available to all applicants on an equitable basis.”? If no record is required to be made of requests for services, responses, and tests carried out, then, it would appear difficult to determine objectively if the DPE was meeting this requirement.
- If no data is kept for what is being charged for tests, there is really no objective basis for being able to conclude that those fees are, in fact, “reasonable.”
Conclusion
The FAA has decided to make a radical bet that creating ODAs for airmen certification (check rides mainly) will spur many existing Part 141 flight schools to jump on board and contribute to their own long-term health and growth while solving the problem of DPE shortages.
Based on discussions with a number of flight schools who are already planning to set up an ODA, the FAA may well have hit a home run. Some FSDOs and DPEs may not see this development as entirely favorable. The check ride has become the classic bottleneck in the whole flight training process, so any proposal that allows a controlled expansion of capacity should be given support. Potentially, this could, and probably should, lead to lower test prices and much shorter lead times while allowing FSDOs to concentrate their important oversight efforts on an accountable organization as opposed to many individuals.
As illustrated by the FAA’s own statistics, only 29 percent of DPE applicants make it through, so if that vetting process ends up with an ODA, that will release time for the FSDOs to supervise and audit the new ODAs.
