The Hardest Part of the Practical Test
Article No. 7 in “From the Examiner's Chair”
The practical test doesn't begin when the oral examination starts. It begins when an applicant, a flight instructor, and an examiner each fulfill their responsibility to ensure the applicant is truly qualified to take it.
Introduction
One of my favorite things to tell applicants comes immediately after we've completed the qualification review.
I'll smile and say,
"The hardest part is over."
It usually gets an awkward laugh.
Most applicants assume I'm joking.
I'm not.
Before we can discuss regulations...
Before we can evaluate aeronautical decision-making...
Before the engine ever starts...
The applicant must first be qualified to take the practical test.
If they aren't, none of the rest matters.
Qualification Isn't a Formality
The FAA requires every examiner to determine that an applicant meets all eligibility requirements before beginning a practical test.
That responsibility isn't optional.
It's one of the most important duties a Designated Pilot Examiner has.
Likewise, when a flight instructor signs the required endorsements, they're certifying that the applicant has received the required training, acquired the required experience, and is prepared for the practical test.
Those signatures aren't simply paperwork.
They're professional certifications.
A Story I'll Never Forget
Several years ago, an applicant scheduled a Commercial Pilot Airplane Single-Engine Land add-on practical test with me.
His story immediately caught my attention.
He had recently retired from the U.S. Army after flying helicopters.
Through the military competency provisions, he had already been issued an FAA Commercial Pilot Certificate with Rotorcraft-Helicopter privileges.
He then completed training for a Commercial Airplane Single-Engine Land add-on and successfully passed that practical test.
Shortly afterward, he also passed his Flight Instructor Airplane practical test.
Everything appeared to be going exactly as planned.
Then a letter arrived from the FAA Airmen Certification Branch.
After reviewing his records, they determined he had not actually met the eligibility requirements for the Commercial ASEL practical test.
The examiner had processed the application using a paper FAA Form 8710-1 rather than IACRA, allowing the application to move forward despite the missing qualification.
As a result, his Commercial Airplane Single-Engine Land privileges were revoked.
His newly issued Flight Instructor certificate was also affected because it depended upon a Commercial certificate that should never have been issued.
The practical tests he had paid for and successfully completed no longer counted.
None of this happened because he failed a practical test.
It happened because the practical test should never have begun.
He later completed the additional required training, moved to Kentucky, became properly qualified, and successfully completed the Commercial ASEL practical test with me.
His flying ability wasn't the problem.
The qualification process was.
That experience has stayed with me ever since.
When IACRA Says "No"
One lesson from that story deserves special attention.
Occasionally instructors become frustrated because IACRA won't process an application.
The temptation is to assume IACRA is the problem.
Sometimes it is.
Often it isn't.
IACRA has prevented countless practical tests from beginning when an applicant wasn't actually eligible.
Before looking for a workaround, ask a different question.
"What requirement is IACRA trying to protect me from overlooking?"
Sometimes the software is pointing to a real qualification issue.
Everyone Has a Responsibility
Qualification isn't solely the examiner's responsibility.
It belongs to everyone involved.
The applicant is responsible for maintaining accurate records.
The instructor is responsible for ensuring the required training and experience have been completed and properly documented.
The examiner is responsible for independently determining that everything required by the regulations is present before beginning the practical test.
When everyone fulfills those responsibilities, the certification process works remarkably well.
Common Problems I See
Some qualification issues appear again and again.
Private pilot applicants whose cross-country flights don't meet the definition found in 14 CFR §61.1.
Commercial applicants whose required solo experience has been improperly combined with duties performed as PIC, even though §61.129(a)(4) and FAA legal interpretations don't permit it.
Instrument applicants who logged PIC time when they weren't qualified to act as PIC.
Missing endorsements.
Incomplete ground training records.
Aircraft maintenance discrepancies.
Airworthiness issues.
The specific problems vary.
The underlying cause usually doesn't.
Someone assumed instead of verifying.
The Numbers Are Eye-Opening
The FAA has recognized that applicant qualification has become a widespread issue.
In a 2024 FAA Safety Briefing article published by the General Aviation and Commercial Division's Delegation Group, the FAA reported that approximately 50,000 practical tests during the previous year ended before they ever began, due in part to applicant qualification and aircraft airworthiness issues.
Think about that for a moment.
Fifty thousand applicants prepared for a practical test, scheduled a DPE, and never reached the first question.
Most of those situations were preventable.
For Flight Instructors
Flight instructors play a critical role in protecting applicants from one of the most disappointing outcomes imaginable—a practical test that can't even begin.
When you endorse an applicant, you're doing far more than certifying that they fly well enough to pass.
You're certifying that they've received the required training, logged the required experience, and meet the eligibility requirements established by regulation.
Treat those endorsements with the seriousness they deserve.
Develop a qualification checklist.
Audit logbooks before recommending the practical test.
Don't assume previous instructors documented everything correctly.
And don't rely solely on software to catch mistakes.
Most importantly, if you discover something was missed, fix it the right way.
If the training occurred but wasn't documented, correct the documentation appropriately.
If the training never occurred, complete it before scheduling the practical test.
Never attempt to solve a qualification problem by creating experience after the fact.
The FAA has been remarkably consistent when it comes to falsification.
No practical test is worth risking your certificates—or your integrity.
Putting It Into Practice
Before scheduling your next practical test, take a few extra minutes to verify that you're truly ready.
Applicants
Ask yourself:
Have I independently verified that I meet every aeronautical experience requirement?
Are all required endorsements complete, accurate, and current?
If IACRA isn't allowing my application to proceed, have I determined why instead of assuming the software is wrong?
Is my logbook organized well enough that another instructor or examiner could quickly verify my qualifications?
Is the aircraft airworthy, with all required inspections and documents in order?
Flight Instructors
Before recommending a practical test, ask yourself:
Have I audited—not simply reviewed—the applicant's aeronautical experience?
Do all endorsements accurately reflect the training that actually occurred?
Have I verified that every regulatory requirement has been satisfied?
Would I be comfortable explaining every endorsement and every required flight experience to an FAA inspector?
A careful qualification review before scheduling the practical test can prevent weeks—or even months—of disappointment afterward.
From the Examiner's Chair
When I determine an applicant is qualified before a practical test begins, I often tell them,
"The hardest part is over."
I mean it.
Qualification isn't paperwork.
It's the foundation that allows the rest of the certification process to have meaning.
Mistakes happen.
Everyone involved occasionally overlooks something.
But repeated qualification problems shouldn't become routine.
Professionalism means taking the time to verify—not assume—that every requirement has been met before the practical test begins.
When applicants, instructors, and examiners each fulfill that responsibility, everyone benefits.
And that's exactly how the certification process is supposed to work.
— Brad Kramer
FAA Designated Pilot Examiner
About the Author
Brad Kramer is an FAA Designated Pilot Examiner based in Evansville, Indiana. He has over 25 years of aviation experience and has conducted FAA practical tests for more than a decade. Through From the Examiner's Chair, he shares lessons from practical testing to help applicants, flight instructors, and certificated pilots better understand the principles of sound aeronautical decision-making, professionalism, and the Airman Certification Standards.
