# sl CHnNoIBn-GTLBERT 

# CovuuNrry Cou-Bcp

# ZrrNAVlr\Tl{}N DlvlStON

June 51h,2014

Rex Ginder Chandler 

### Gilbert Community College Restricted 

### ATP Representative 7360 EastTahoe 

### 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 14CFR paragraph

### 61.160(c)(3)(i) This 

### petition of exemption 

### is

### for 14CFR paragraph 

### 61.160(c)(3)(i) 

### which states: "The 

### required ground

### training was completed as

### part of an approved 

### part 

## I4I curriculum atthe 

### 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-INDAerospace 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, 

### onlinetraining 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. )'l:{.-(.i5 (-iMl}ll5 2{rri) Lnil f'r,lcr Ro;ii {,h;rndler, AZ ilS2rli-:l ri!q

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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, 

### thatthis 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 atthe 

### institution of higher education.

. .

## "

Because 

### ofthe 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, 

### itwould not only affect students 

### whowould transfer in the

### future but 

### itwould 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 

### wantto deter individuals 

### from seeking 

### alternative paths to achieving a degree 

### with an 

### aviation ma.ior and therefore has determined that students who 

### transfer into a2-year 

### or 4-year degree

### program with an

### aviation major could beeligible

### 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. Immediatelythe 

### benefitwould 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 a4year

### 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 betransfened and accepted at 

### CGCC andlor 

### LrND for the restricted 

### ATP. About 1/3 

### of our 

### CGCC students areveterans, many veterans 

### would also be able to benefit 

### from the restricted 

### ATP approval 

### if this exemption wasallowed.

The

### public wouldfurther benefit because 

### it would allow strategic 

### partnerships and not deter individuals 

### from seekingalternative 

### 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 ableto receive college 

### credit and obtain 

### financial aid asthey 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 

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is much more advantageous and less 

### risk as

### an organizationto 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 contentthat is 

### offered at 

### UND and has been accepted 

### for the restricted 

### ATP. Integrated courses mean the

### flight training and related academic courses arecombined 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 

### doingthis successfully 

### in partnership 

### with CGCCfor nearly20years. To make CGCC create a new, separate 

### Part 

## I4l certfficate to accomplish the same

### goal would be very 

### infficient, unproductive and have noacademic 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 "Ltsand 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 hasconducted 

### 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 beable 

### to count any courses taken at these partner 

### institutions of higher education, that 

### hold articulation agreements, 

### will be

### allowedto 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. riiji'i:iii ll:;ri'l' ' ::t:r;::tt: :;;t,t!t:tt
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2) 

### Without theexemption 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 totransfer credits dueto

### this 

### rule. 

### IIND hasconducted the

### flight training and academic 

### training since 1968 

### in Grand Forks, 

### ND and since 1995 

### in Phoenix 

### in partnership 

### with CGCC. UND Aerospace isthe expert 

### relied heavily upon 

### by CGCC. CGCC being required 

### to obtain a new 

### Part 141

### certificate inthe partnership 

### would be 

### directly contrary to

### good business 

### practices. Itwould increase 

### our 

### liability and be negative on thevery positive 

### partnership in 

### place. Separate 

### Part 

### 14I 

### bhief Instructors 

### would need

### to be employed. 

### This would decrease 

### efficiency and reducethe 

### obligation and 

### liability of 

### IIND to maintain close

### quality control on the integrated ground 

### portion. Currently a 

### UND employee is assigned asthe 

### 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, underthe 

### FAA SMS 

### Pilot Program, has been accepted as 

### Level 3 SMS. Due 

### tothefact 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 14CFR 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 

### ofthe 

### 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 asthe 

### institution of 

### higher learning who is

### actually 

### providing 

### the acudemic 

### (ground) courses. 3)

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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 atthe 

### institution of 

### higher education .., 

### " Any additional 

### information, views, 

### or arguments available 

### to support 

### your request Excerptsfrom FAA Appro.ved 

### Part 

# I4l UND 

### Private 

### PilotAirplane 

## - SEL course 

### Edition 

## l2 Revision 1,

### page 3, used in 

### partnership 

### with CGCC; ..GROLINID 

### TRAINING The course consists 

### of at least 35 hours 

### oftraining; as required 

### by 

### FAR 141,

### Appendix B, paragraph 

### 3(b), (1) 

### through (13). 

### Groundtraining is 

### conducted at

### the Chandler 

### Gilbert Community College, 

### and/or atthe Phoenix-Mesa Gateway 

### Airport, prior to, 

### or concurrent 

### with the

### flighttraining. Briefings and

### preflight/postflight discussions conducted 

### by each student's 

### flight instructor are 

### included inthe ground 

### training. Descriptionsof these 

### briefings arecontained 

### inthe

### 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 

### oftraining; 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 atthe 

### 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.econtained 

### 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 

### PilotAirplane - 

### SMEL Certification Course Ground 

### Training conducted at Phoenix consists

### of 

### five academic courses: 

### Phoenix AET 

### 207; AET 217; 

### AET 213; 

### AET 203; AET 

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## _s\l CHaNpI-Bn-GTLBERT 

# CouvruNrry 

# Colr-ecp

# ZrrNThank you 

### for consideration 

### of our 

### petition. 

### If you have any

### fu{her questions, please do 

### not hesitate 

### tocall 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 includethe unique 

### relationship

### with institutions of higher 

### learning such as

### with CGCC 

### in regard 

### tothe

### 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 thatthe courses are

### truly offered "at the 

### institution 

## of higher education" which is CGCC.

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