Desk of Alex C. Anderegg 

Date: March 18,.2014 

From: Alex C. Anderegg 

2261 N. Hilltop Dr. 

Muskegon MI, 49441 

Mobile: (231) 215-0293 

E-Mail: alex.c.anderegg@wmich.edu 

To: Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE West 

Building Ground Floor Room W12-140 

Washington; DC 20590 

RE: Exemption From Title 14 of the Code of Federal Regulation I Section 61.160 [ 14 CFR 61.1601 

Dear Reviewing Officer: 

Executive Summary 

An exemption to Title 14: Code of Federal Regulation, Part 61.160 (14 CFR 61.160) is sought with appropriate 

justification. An apparent gap in codifying restrictive privileges has been identified with an appropriate corrective 

action resulting in a de minimus effect with regard to aviation safety. Although the corrective action has been 

specified as a clarifying change to 14 CFR 61.160; the immedia~e relief sought is a simple exception relieving 

aspiring professional pilots of undue hardship consequently set in motion by an apparent oversight in addressing 

realistic extenuating circumstances. · 

The following justification supports relief [exemption] specific to 14 CFR 61.160(b)(3)(i) and (ii): 

§61.160 Aeronautical experience-airplane category restricted privileges. 

(b) A person may apply for an airline transport pilot certificate with an airplane category multiengine class rating or an airline 

transport pilot certificate concurrently with an airplane type rating with a minimum of 1,000 hours of total time as a pilot if 

the person: 

(1) Holds a Bachelor's degree with an aviation major from an institution of higher education, as defined in §61.1, that has 

been issued a letter of authorization by the Administrator under §61.169; 

(2) Completes 60 semester credit hours of aviation and aviation-related coursework that has been recognized by the 

Administrator as coursework designed to improve and enhance the knowledge and skills of a person seeking a career as a 

professional pilot; 

(3) Holds a commercial pilot certificate with an airplane category and instrument rating if: 

(i) The required ground training was completed as part of an approved part 141 curriculum at the· institution of higher 

education; and · 

(ii) The required flight training was completed as part of an approved part 141 curriculum at the institution of higher 

education or at a part 141 pilot school that has a training agreement under § 141.26 of this chapter with the institution 

of higher education; and 

(4) Presents official transcripts or other documentation acceptable to the Administrator from the institution of higher 

education certifying that the graduate has satisfied the requirements in paragraphs (b)(1) through (3) of this section. 

(g) An airline transport pilot certificate obtained under this section is subject to the pilot in command limitations set forth in 

§61.167(b) and must contain the following limitation, "Restricted in accordance with 14 CFR 61.167." The pilot is entitled to 

an airline transport pilot certificate without the limitation specified in this pa~agraph when the applicant presents satisfactory 

evidence of having met the aeronautical experience requirements of §61.159 and the age requirement of §61.153(a)(1 ). 
The specific relief I seek is to qe declared eligible to apply for the restricted Airline Transport Pilot (ATP) · 

certificate in accordance with 14 CFR 61.160(b) upon my graduation from Western Michigan University's (WMU) 

College of Aviation on April26, 2014 with a Bachelor of Science-Aviation Flight Science. WMU's College of 

Aviation is an FAA approved Part 141 institution of higher education and holds a current letter of authorization 

(LOA) by the Administrator under §61.169 [FAA school number JX8S258Q]. (See WMU College of Aviation 

transcript attached). . 

Background 

I completed iny full instrument ground and flight training at Baker College's Professional Pilot Program located in 

Muskegon, Michigan (see attached certificate and letter from Baker College's Chief Flight Instructor Douglas E. 

Purdue). Baker College is accredited by The Higher Learning Commission of the North Central Association of 

Colleges and Schools. Although Baker College's flight program is an FAA approved Part 141 institution (FAA 

school number ECJS463D), their administration has not yet pursued an LOA by the Administrator under §61.169 to 

issue the restricted ATP certificate. 

I fully meet all requirements as stated in 14 CFR 61.160(b) with my pending graduation from WMU's College of 

Aviation, with the sole exception of completing instrument ground and flight course work. The confounding issue 

surrounds "~here" I completed instrument ground and flight course work, which was Baker College's Professional 

Pilot Program. I have been informed by WMU that because Baker College does not hold an LOA, WMU is unable 

to consider the coursework and training taken at Baker College, and therefore cannot issue a statement certifying · 

my compliance with 14 CFR 61.160(b). Without this certifying statement, it negates my ability to apply for a 

restricted ATP certificate at the reduced aeronautical experience minimum of 1,000 total flight hours. 

. . 

The aeronautical experience I currently hold fully meets the spirit and intent of the restrictive privileges outlined in 

14 CFR 61.160 ensuring an appropriate level of training to "improve and enhance the knowledge [base] and skills 

of a person seeking a career as a professional pilot" [14 CFR 61.160 (b)(2)]. (See attached transcript for 

substantiation of a minimum of 60-semester credit hours of aviation related coursework). In addition, I have further 

enhanced my knowledge and skills by attaining certified flight instructor (CFI), certified flight instructorinstrument (CFII) and multi-engine instructor (MEl) status. Furthermore, I am employed at WMU and have 

subsequently instructed visual flight rules (VFR) student pilots and instrument flight rules (IFR) student pilots-in 

essence, I am teaching the aviation knowledge and skills specified in 14 CFR 61.160(b)(i) and (ii) at WMU's 

College of A viaiion. 

A reasonable person would conclude I have not only met but exceeded the spirit and intent of 14 CFR 61.160(b)(i) 

and (ii). It is my contention the constraint "where the instrument ground and flight coursework" was completed is 

overridden by the fact that I currently am certified to teach (and currently teach) instrument flight coursework at an 

approved Part 141 institution of higher education which also holds a current LOA by the Administrator under 

§61.169 [FAA school number JX8S258Q] to issue a restricted ATP certificate. The proposed stipulation below to 

14 CFR 61.160(b)(3) would relieve the undue hardship placed on those professional pilots who clearly meet the 

spirit and intent of 14 CFR 61.160(b). 

(iii) Or, the required flight training was completed as part of an approved part 141 curriculum at the institution of higher 

education absent approval to issue a letter of authorization by the Administrator under §61.169; however achieves 

and maintains a certified flight instructor (CFI) and certified flight instructor-instrument (CFII) ratings at an 

institution of higher education so authorized to also issue a letter of authorization as outlined by the Administrator 

under §61.169; and receives a written recommendation from the Chief Flight Instructor. 

The approval of this exception does not deviate from the spirit and intent of 14 CFR 61.160(b). As well, it rectifies 

a gap in the federal regulation - and the additional requirement of receiving a written recommendation from the 

Part 141 institution's Chief Flight Instructor standardizes and substantiates the de minimus impact on aviation 

safety. 

2 
Justification For Exception 

If granted an exception to 14 CFR 61.160, safety would not be adversely affected due to the following reasons: 

1. I completed my full instrument ground and flight training at Baker College's Professional Pilot Program; an 

FAA approved Part 141 program (FAA school number ECJS463D). (See attached certificate and letter 

from Baker College's Chief Flight Instructor Douglas E. Purdue). 

2. Since August of 2012, I have been qualified and responsible for safely teaching students enrolled in 

WMU's College of Aviation (FAA school number JX8S258Q), an institution that holds a LOA to issue the 

restricted ATP certificate that I seek. The instrument flight course that I teach is the exact FAA authorized 

aviation coursework that I would have completed at WMU. In fact, one of the students at WMU, under my 

instruction from start to finish, successfully completed his instrument flight course through WMU. 

3. I have undergone extensive training while earning my Flight Instructor Airplane Single and Multi-Engine; 

and Instrument Instructor Airplane ratings which contribute to a level of safety no less than equal to that of 

my graduating peers at WMU who are eligible for the restricted ATP certificate by meeting the 

requirements of 14 CFR 61.160(b) .. 

4. I have received full support and a written recommendation affirming justification in this exception from 

WMU's College of Aviation (FAA school number JX8S258Q) Chief Flight Instructor (See attached 

recommendation letter from Mr. Thomas C. Grossman). 

As evidenced above, I have demonstrated that I fully meet the equivalent level of safety a11d proficiency a graduate 

of an FAA approved part 141 program is required to attain in accordance with 14 CFR 61.160(b). I have presented 

evidence of a gap in the spirit and intent of 14 CFR 61.160(b)(3). As well, I have presented appropriate 

justification in granting this exemption with a de minimus effect on safety. Specific to my point, approval of this 

exception corrects an undue hardship to aspiring professional pilots. 

Additional Information I Views or Arguments 

The undue hardship entails the interpretation that I am currently declared ineligible to apply for a restricted Airline 

Transport Pilot certificate absent "retaking as a student" an aviation related course that I am certified to teach. I 

believe the aeronautical knowledge and practical experience required to be a successful instructor of this FAA 

approved part 141 instrument flight course, at an institution that holds a LOA, should qualify me for the restricted 

ATP certificate along with my peers. I believe that my training at Baker College, the earning of multiple flight 

instructor certificates, and my experience as a flight instructor at WMU demonstrate a level of knowledge and 

safety at least equivalent to that of other students completing their instrument ground and flight training at WMU .. 

Forcing me to retake these ground and flight courses to qualify for the restricted ATP certificate would not result in 

an increased level of safety and would result in undue expense and an unnecessary waste of time. 

Thank you for your time and consideration. I shall look forward to your response. 

Sincerely, 

A-£4---e 

Alex C. Anderegg 

Certified Flight Instructor 

Western Michigan University 

3 
The Graduate has completed the cross-country 

Trait:ting specified in FAR Part 141. . 

1 Instrument Rating Course- Appendix C, 

Paragraph 4(cXIXii) 

·Commercial Pilot Certification CourseAppendix D, Paragraphs 4 & 5 

_ Multi Engine Rating CourseAppendix I, Paragraph 4 

! 

Chief Instructor 

Air Agency Certificate Number ECJS463D 

~bL~~ 
March 6, 2014 

To whom it may concern: 

~er College 

"-..._/ ;ince 1911 

Baker College 

1903 Marquette Avenue 

Muskegon, Michigan 49442-1490 

Telephone (231) 777-8800 

Fax (231) 777-5265 

The records of Baker College indicate that Alex C. Anderegg, Pilot Cert# 3421703, satisfactorily 

completed the following coursework at Baker College of Muskegon: 

Program: Associate of Applied Science, Professional Pilot/Aviation Technology, Version 2008A 

UIN 104-55158: 

• Private Pilot Ground School, AVT 111,4 quarter hours 

• Instrument Ground School, AVT112, 4 quarter hours 

• Commercial Ground School, AVT113, 2 quarter hours 

The above ground training courses were completed under the FAR141 Approved school certificate held 

by Executive Air Transport, Inc., Muskegon Ml, Certificate #ECJS463D; Executive Air is the exclusive 

ground and flight training partner of Baker College of Muskegon. 

In addition, Alex satisfactorily completed and holds graduation certificates for the following courses in 

accordance with Executive Air Transport's Approved Flight School #ECJS463D: 

• Private Pilot Flight Training: FAR141 Graduation July 7, 2009 

• Instrument Rating Flight Training: FAR141 Graduation July 7, 2010 

Please feel free to contact me if you have any questions. 

Douglas E. Purdue 

Program Director, Aviation, Baker College of Muskegon, (231) 777-5282 

Chief Flight Instructor, Executive Air Transport, Muskegon, Ml, (231) 798-2126 

Email: dpurdu01@baker.edu 

Baker College I Allen Park • Auburn Hills • Cadillac • Cass City • Clinton Township • Flint • Fremont • Jackson • Muskegon • Owosso • Port Huron 

Accredited by The Higher Learning Commission and a member of the North Central Association 

30 North LaSalle Street, Suite 2400, Chicago, IL 60602-2504/800-621-7440 I www.ncahigherlearningcommission.org 
WESTERN MICHIGAN UNIVERSITY .. 

••• •• 

,, ,, 

. . . 

College of Aviation 

March 10, 2014 

To whom it may concern, 

Mr. Alex Conner Anderegg, pilot certificate 3421703, is petitioning the FAA for exemption from 14 CFR 61.160. As 

the Chief Flight Instructor for Western Michigan University (WMU) and the responsible person for WMU's Letter of 

Authority (LOA) authorizing WMU to certify its graduates for an Airline Transport Pilot Certificate with reduced 

Aeronautical Experience, I can offer you the following factual information. 

• Mr. Alex Conner Anderegg is currently a student and flight instructor at Western Michigan University; 

• Upon successful completion of the coursework Mr. Anderegg is registered for this semester he will meet 

all the degree requirements and will be issued a Bachelor of Science degree in Aviation Flight Science, one 

of WMU's approved degree programs under the LOA; 

• Upon successful completion of the coursework Mr. Anderegg is registered for this semester he will have 

completed 60 credit hours of FAA approved aviation related coursework at WMU; 

• Mr. Anderegg has completed his commercial pilot ground and flight training at WMU's FAA approved Part 

141 training program (Approved School JX8S258Q); 

• Upon successful completion of his current registered coursework, Mr. Anderegg will have met all of the 

requirements to make him eligible for WMU to issue a statement certifying he meets all ofthe 

requirements of 14 CFR 61.160(b) except for the fact that he completed his instrument training 

elsewhere; 

• Mr. Anderegg completed his instrument pilot training at Baker College in Muskegon, Ml and their flight 

training partner, Executive Air Transport, Inc., under their Part 141 approved curriculum (Approved School 

ECJS463D); and 

• Mr. Anderegg's employment responsibilities as a flight instructor at WMU include the responsibility to 

teach the instrument flight course, AVS 2520. 

From a personal perspective, I feel that Mr. Anderegg has obtained credentials and has demonstrated a level of 

safety that outweighs his lack of completing the instrument training at WMU. This includes the following. 

• Mr. Anderegg has acquired his flight instructor certificate with airplane single engine, airplane multi 

engine and instrument airplane ratings; 

• Mr. Anderegg has completed his instrument training through an accredited university in adherence to an 

FAA approved curriculum; and 

• Mr. Anderegg has demonstrated through a combination ofWMU course AVS 4970 and flight instructor 

employee standardization that he meets the aeronautical knowledge and skill that he would have 

acquired at WMU if he had completed his instrument training at WMU. 

Based on the above, I fully support Mr. Anderegg's petition for relief from 14 CFR 61.160. Please feel free to 

contact me at (269) 964-4029 or thomas.grossman@wmich.edu if you have any questions concerning this letter of 

support. 

Sincerely, 

~~~,__ Thomas c. Grossman 

Chief Flight Instructor 

Western Michigan University 237 Helmer Rd N, Battle Creek, Ml49037 

PHONE: (269) 964-6375 FAX: (269) 964-6473