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June 51h,2014

Rex Ginder

Chandler Gilbert Community College

Restricted ATP Representative

7360 East Tahoe Ave.

Mesa, AZ 85212

Phone number: 480-988-822 1

Fax number: 480-988-8224

Email : ginder@aero.und.edu

RE: Petition for Exemption of 14 CFR paragraph 61.160(c)(3)(i)

This petition of exemption is for 14 CFR paragraph 61.160(c)(3)(i) which states: "The required

ground training was completed as part of an approved part I4I curriculum at the institution of

higher education..."

The following petition for exemption is formatted to match bulleted guidance provided on

www. faa. gov/re gulationsJolicies/rulemaking/petition .

'fhe extent of relief you seek and the reason you seek the relief

Chandler Gilbert Community College, which provides an A.A.S. degree in

Airway Science Technology, has a relationship with the University of North

Dakota (UND) and L-IND Aerospace Foundation, known as IIND Aerospace,

since 1995, This partnership has included using [IND's Part 141 Air Agency

certificate to provide integrated Part 141Flight and Academic (ground) education

for CGCC students. In addition to providing all training material for Parl 141

flight; IIND Aerospace provides all the Part 141 content for the academic

(ground) schools, to include syllabi, PowerPoints, online training aids, and

guidance to CGCC academic instructors. CGCC academic instructors maintain all

Part 14i requirements under IIND Aerospace's Part l4l certificate. Furlhermore,

the FAA approved LIND Part I4I courses already reference that all the academic

courses are taught in conjunction with Chandler Gilbert Community College.

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ZrrNCurrently, the process is seamless to the student. AVIATION NIVISION

We are requesting that the FAA recognize, that since CGCC is physically written into each

UND FAA approved training course outline offered with CGCC, and offered for CGCC

college credit, that this be accepted to meet the requirements stated in 14 CFR paragraph

61.160(c)(3)(i) ooground training was completed as part of an approved part 141 curriculum

at the institution of higher education. . . "

Because of the close relationship and CGCC using the same approved, integrated flight and

ground syllabi; LIND allows 100% articulation of aviation courses, !f students transfer from

CGCC to [IND. If this exemption is not allowed, it would not only affect students who would

transfer in the future but it would immediately affect many stpdents who have already transferred

by not allowing them to count the credits taken at CGCC towards their restricted ATP at [IND.

To further make this point, as stated in Advisory Circular 6I-139 paragraph I2.a; "The FAA

acknowledges students follows a number of dffirent paths for completing post-secondary

education at a college or university. Some students start at community colleges and transfer to 4-

year degree programs while other students transfer between dffirent 4-year institutions of

higher education. The FAA does not want to deter individuals from seeking alternative paths to

achieving a degree with an aviation ma.ior and therefore has determined that students who

transfer into a 2-year or 4-year degree program with an aviation major could be eligible for a

restricted privileges ATP Certificate. "

While an unintended consequence, this rule will surely do what the FAA has indicated they do

NOT want to do.

. How your request would benefit the public as a whole.

Immediately the benefit would be to all students who have obtained or plan on

obtain a2 year degree at CGCC in Airway Science Technology and also to those

students who plan on transfeming to UND for a 4 year degree. Many high school

students are also part of our dual enrollment program at CGCC. These high school

students would also be given the benefit of including CGCC courses they took to

be transfened and accepted at CGCC andlor LrND for the restricted ATP. About

1/3 of our CGCC students are veterans, many veterans would also be able to

benefit from the restricted ATP approval if this exemption was allowed.

The public wouldfurther benefit because it would allow strategic partnerships

and not deter individuals from seeking alternative paths to achieving a degree

with an aviation major. Experienced Part 141 Approved Pilot Schools, such as

IIND Aerospace, would more likely partner with other institutions of higher

learning to provide the highest level of aviation education while students would

be able to receive college credit and obtain financial aid as they pursue their

aviation career. The likelihood of institutions of higher education wanting to start

aviation programs is very low. Through our experience at CGCC we have seen it

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is much more advantageous and less risk as an organization to partner with AVIATION IllvlSloN

aviation experts, such as LIND Aerospace. UND Aerospace has the expertise to

paftner with us and help ensure the flight:nil academic (ground) education meets

applicable FAA requirements.

The public benefits from this proven approach to aviation education. The FAA Approved LIND

Part 141 training courses currently used by CGCC are integrated. These courses are the same

content that is offered at UND and has been accepted for the restricted ATP. Integrated courses

mean the flight training and related academic courses are combined to provide the highest level

of aviation education. Through our Aviation Information Management System (AIMS), we

monitor student progress and correlate their flight and ground performance. Experts at IIND

Aerospace had been doing this successfully in partnership with CGCC for nearly 20 years. To

make CGCC create a new, separate Part I4l certfficate to accomplish the same goal would be

very infficient, unproductive and have no academic benefit $aving the flight and academic

(ground) training linked under the same TCO, helps to ensure good communication between

flight operations and academic personnel. We have observed many programs where the flight

and ground are separated; it creates an atmosphere of "Lts and them " versus "we". This approach

helps CGCC ensure we serve our public (students) well.

Currently, UND Aerospace has this same partnership not only with CGCC but also University of

Minnesota Crookston (UMC). In the recent past, UND Aerospace has conducted FAA approved

Pafi I4I flight and academic (ground) training, using IIND curriculum with Spokane Falls

Community College (SFCC) as well. Students from ALL these institutions (assuming UMC and

SFCC submitted applications are not denied as well) would benefit because without this approval

past qtudents from all these institutions, who are now at IIND or have recently graduated would

not be able to count any courses taken at these partner institutions of higher education, that hold

articulation agreements, will be allowed to meet LIND ATP restricted requirements.

Reasons why the exemption would not adversely affect safety, or how the

exemption would provide a level of safety at least equal to the existing rule.

Over the last 10 years, the Part 141 approved training program, through the

partnership of UND Aerospace and CGCC has an excellent safety record and

CGCC is included in UND's FAA SMS program that has been accepted as

Level3 by the FAA. UND Aerospace has provided the Part 141 expertise and

CGCC employs the academic professors who teach the IIND approved Part I4I

academic or ground training portion.

This exemption would not adversely affect safety, in fact requirins the change

would result in an increase risk to both organizations.

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2)

Without the exemption the following items would occur: AV|ATTOT\ nivrStoN

r) Flight and Ground Training would no longer be integrated or students would be denied

the opportunity to transfer credits due to this rule. IIND has conducted the flight training

and academic training since 1968 in Grand Forks, ND and since 1995 in Phoenix in

partnership with CGCC. UND Aerospace is the expert relied heavily upon by CGCC.

CGCC being required to obtain a new Part 141 certificate in the partnership would be

directly contrary to good business practices. It would increase our liability and be

negative on the very positive partnership in place.

Separate Part 14I bhief Instructors would need to be employed. This would decrease

efficiency and reduce the obligation and liability of IIND to maintain close quality

control on the integrated ground portion. Currently a UND employee is assigned as the

Chief Flight Instructor and Principle Ground Instructo,r for the FAA approved training

courses offered in partnership with UND Aerospace and CGCC. This IIND chief

instructor coordinates with IIND and CGCC to ensure high level of aviation education is

provided and standardization is maintained. CGCC does not want the ground schools to

be independent from the flight training; it will naturally cause discontinuity in the

training experience,

Currently LIND Aerospace, under the FAA SMS Pilot Program, has been accepted as

Level 3 SMS. Due to the fact that ALL Part l4l training, flight and academic (ground), is

FAA approved through UND; CGCC program has been included in the Pilot Study and is

also Level 3 SMS accepted. Changing CGCC to hold an additionalPart 141 certificate

would change this relationship.

UND Aerospace SMS experts have concluded that requiring such a significant

'change to the system' would cause an increase in risk to both CGCC and UND

Aerospace.

A summary we can publish in the Federal Register stating:

Chandler Gilbert Community College (CGCC) has requested a petition for

exemption from 14 CFR paragraph 61.160(c)(3)(i) which states: "The required

ground training was completed as part of an approved part I4l curriculum at the

institution of higher education... "

CGCC's FAA approved Part 141 flight training provider has an integrated

curriculum that integrates both the flight and academic (ground) requirements of

Part l4L The FAA approved courses explicitly reference CGCC as offering

the academic (ground) school portion of the training but still under the

auspices of the provider's FAA Part 141 approved training courses.

The exemption would allow CFR paragraph 61.160(cX3Xi) to be met since

CGCC is listed in the FAA Part 14i training corrses as the institution of higher

learning who is actually providing the acudemic (ground) courses.

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AVIATION N:VISION

The rule from which you seek the exemption

i4 CFR paragraph 61.160(c)(3)(i) which states: "The required ground trainingwas completed as

part of an approved part I 4 I cuniculum at the institution of higher education .., "

Any additional information, views, or arguments available to support your request

Excerptsfrom FAA Appro.ved Part I4l UND Private Pilot Airplane - SEL course Edition l2

Revision 1, page 3, used in partnership with CGCC;

..GROLINID TRAINING

The course consists of at least 35 hours of training; as required by FAR 141, Appendix B,

paragraph 3(b), (1) through (13). Ground training is conducted at the Chandler Gilbert

Community College, and/or at the Phoenix-Mesa Gateway Airport, prior to, or concurrent

with the flight training. Briefings and preflight/postflight discussions conducted by each

student's flight instructor are included in the ground

training. Descriptions of these briefings are contained in the flight training syllabus."

Excerpts from FAA Approved Part I4I UND Commercial/Instrument Airplane - SMEL course

Edition 13, page 3, used in partnership with CGCC;

..GROLIND TRAINING

This pourse will consist of at least 80 hours of training; as required by FAR 141, Appendix C,

paragraph 3.(b) Appendix D, paragraph 3.(b), and Appendix I, paragraph 3.(c). This ground

training will be

conducted at the Chandler Gilbert Community College, and/or at the Phoenix-Mesa

Gateway Airporto prior too or concurrent with, the flight training. Briefings and

preflight/postflight discussions conducted by each student's flight instructor are included in the

ground training. Descriptions of these briefings ar.e contained in the flight training syllabus."

Excerpts from FAA Approved Part l4l UND Commercial/Instrument Airplane - SMEL course

Edition 13, page 3, used in partnership with CGCC. These course numbers arefrom CGCC

Course Catalog embedded in UND Approved Part 141 Course.

"Academic Courses

Commercial/Instrument Pilot Airplane - SMEL Certification Course Ground

Training conducted at Phoenix consists of five academic courses:

Phoenix AET 207; AET 217; AET 213; AET 203; AET 237"

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ZrrNThank you for consideration of our petition. If you have any fu{her questions, please do not

hesitate to call or email. This matter is of utmost importance to bur CGCC student aviation body,

CGCC, and UND Aerospace.

Sincerely,

Rex Ginder il-/J

CGCC

Restricted ATP Representative

r A brief description of the exemption you seek. AVIATION I]IVISION

I-IND FAA approved Part 14I Courses have been written to include the unique relationship with

institutions of higher learning such as with CGCC in regard to the flight as well as academic

(ground) courses.

The exemption would allow IIND's Part 141 approved academic (ground) courses to suffice for

CGCC as long as CGCC is listed in the FAA approved training course outlines. By being listed

in the Part 141 approved courses it shows that the courses are truly offered "at the institution of

higher education" which is CGCC.

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