Request for Clarification Regarding Petition for Exemption FAA 2014

- 0461 (EMAIL 27JAN 2016)

Dear Mr. Ritchie:

Thank you for your response. This will be factored into our decision document and added to the docket for exemption project FAA 2014

- 0461.

Sincerely,

Douglas J. Lundgren Aviation Safety Inspector Airman Certification and Training Branch AFS

- 810 Federal Aviation Administration HQ 800 Independence Avenue Washington, DC 20591 Douglas.lundgren@faa. gov Office: 202

- 267

- 0150
Telework office: 301

- 969

- 0536

From: Ritchie, Scott D. [ mailto:ritchis1@erau.edu ] Sent: Wednesday, January 27, 2016 11:19 AM
To: Lundgren, Douglas (FAA); Bowen, Brent D. Cc: Pendergrass, Alphonso (FAA) Subject: RE: Request for Clarification Regarding Petition for Exemption FAA 2014

- 0461

Mr. Lundgren,

Thanks for the response! Here are the answers to your questions:

1. We are seeking exemption for FAR 61.160(d). The rationale is as follows:

a. ERAU

- Prescott does not offer any associates degrees so we are not seeking exemption for FAR 61.160(c).
b. The students to whom the exemption for FAR 61.160(d) will apply are students in

non

- aviation degree programs that are not conta ined in our LOA. However, these students may complete at least 2 aviation minors. By completing at least 2 aviation minors, these students could complete 30 aviation credits that are contained on the

LOA.

For example, students in the bachelor degree progr ams for Aerospace Engineering and Aviation Business Administration may complete one or more aviation minors as part of their degree (i.e. Aviation Safety,
Fixed

- wing Flight, Applied Meteorology). In the course of completing those minors, the students may

e nd up with 30 credits of aviation credit and all of the flight and ground training that are required by the LOA. So while the student does not meet the criteria for 61.160(d) because they have not received an aviation bachelor’s degree contained in the LOA (Aeronautical Science, Aeronautics, Air Traffic Management, Applied Meteorology), we would like them to be eligible for the ATP

- R under 61.160(d) based on having completed 30 credits of aviation courses contained on the LOA.If you need further clarifica tion, please let me know. Thanks so much!



### Respectfully, 

# Scott Ritchie

Scott Ritchie
Academic Advisor

- College of Aviation Building 74 (AC

- 1) Room 237 Embry Riddle Aeronautical University

- Prescott
3700 Willow Creek Rd. Prescott, AZ

86314

928

- 777

- 3898 ritchis1@erau.edu

From: Douglas.Lundgren@faa.gov [ mailto:Douglas.Lundgren@faa.gov ]

Sent: Wednesday, January 27, 2016 9:04 AM

To: Bowen, Brent D. < bowenb6@erau.edu >
Cc: Ritchie, Scott D. < ritchis1@erau.edu >; Alph onso.Pendergrass@faa.gov Subject: Request for Clarification Regarding Petition for Exemption FAA 2014

- 0461

Dear Mssrs. Bowen and Ritchie:

We are in the final stages of processing your petition for exemption dated July 7, 2014,

in which Embry

- Riddle Prescott is asking for graduates of certain aviation minor degree programs to be eligible for restricted

- privileges Airline Transport Pilot Certificates (ATP) under the ERAU

- Prescott Campus Letter of Authorization for Institutional Auth ority.

We have come to a point in which we need to request clarification of Embry

- Riddle Prescott’s specific request for regulatory exemption. In the attached petition, Embry

- Riddle Prescott asks for an exemption to 14CFR 61.160(b)(1) and 61.160(d), and on page 2 points to 61.160(c)(1) and (c)(2).

- 61.160(b) graduates would need 60 hours from the ERAU

- Prescott LOA and a bachelor degree to qualify
for the restricted

- privileges ATP at 1000 hours total flight time,

- 61.160(d) graduates would need at least 30 hours from the ERAU

- Prescott LOA and a bachelor degree to qualify for the restricted

- hour ATP at 1250 hours total time.

- 61.160 (c) graduates would need 30 hours from the ERAU

- Prescott LOA and an associates degree to qualify for the restricted

- hour A TP at 1250 hours total time.

It appears however that this petition does not actually ask for an exemption to section CFR 61.160(b),

since ERAU

- Prescott is not proposing that covered students would have 60 LOA credit hours upon graduation.

It appears th at this petition also does not ask for an exemption to section 61.160 (c)(2), since no relief is sought for the requirement for 30 LOA credit hours.Please clarify which specific regulation for which relief is sought. It appears that this would be sectio n

61.160(c)(1) or 61.160(d), or both.

Per the FAA rulemaking process, a copy of this message and your response will be placed in the docket for exemption project FAA 2014

- 0461, which can be accessed on Regulations.gov.

Thanks in advance for your cooperat ion.

Sincerely,

Douglas J. Lundgren Aviation Safety Inspector Airman Certification and Training Branch AFS

- 810 Federal Aviation Administration HQ 800 Independence Avenue Washington, DC 20591 Douglas.lundgr en@faa.gov
Office: 202

- 267

- 0150
Telework office: 301

- 969

- 0536