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 contained 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 programs 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 

end 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 clarification, 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>; Alphonso.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 Authority.

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 ATP 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 that 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 section 

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 cooperation.

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