RECORD OF COMMUNICATION BY EMAIL: REQUEST FOR ADDITONAL INFORMATION FROM 

PETITIONER IN DOCKET FAA 2014-0461

Dear Mr. Ritchie:

Thank you for the information. This clarifies how the affected students would undergo their integrated 

ground and flight training, without 

necessarily having to take the Flight (Fixed Wing) Minor course of study.

We will continue to work on this exemption request. Thank you for your cooperation and patience in 

this process.

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

Wash FSDO office: 703-230-7664 ext 274

AFS-810 office: 202-267-0150

Telework: 240-578-3180

From: Ritchie, Scott D. [mailto:ritchis1@erau.edu] 

Sent: Friday, January 16, 2015 3:27 PM

To: Lundgren, Douglas (FAA)

Subject: RE: Discussion of Question 3 and a new Question 4, regarding petition for exemption, Docket # 

FAA 2014-0461

Mr. Lundgren,

Sorry I missed your phone call this afternoon. We would require all students who apply for an ATP-R to 

either complete Instrument and Commercial ground and flight training here at ERAU-PRC (LOA 

Paragraph 3.c) or if we awarded them transfer credit based on flight/ground training that they 

completed at another institution with their own LOA (LOA Paragraph 3.c.1-3). We don’t envision any 

other means of students fulfilling the requirements of the LOA. Hope that helps to clarify! We can 

certainly talk on Tuesday if you’re available.

Respectfully,

Scott Ritchie

Scott Ritchie

Academic Advisor-College of Aviation

Building 74 (AC-1) Room 237

Message Page 1 of 6
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: Friday, January 16, 2015 12:46 PM

To: Ritchie, Scott D.

Subject: Discussion of Question 3 and a new Question 4, regarding petition for exemption, Docket # FAA 

2014-0461

Dear Scott:

Thanks for the information.

What we are focusing on is how ERAU-Prescott will ensure that those students completing at least 2 

aviation minors comply with part 61.160 (b)(3) and (c)(3) with regard to ground and flight training 

integrated into the student’s broader academic background:

“....(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...”

The AC 61-139, Paragraph 10, pages 9-10 also describe the integration of flight and ground training with 

the student’s broader academic education as part of a degree program... this AC language is drawn from 

the Preamble to 14CFR part 160:

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“10. INTEGRATED FLIGHT TRAINING. Section 61.160 requires a student to complete commercial and 

instrument ground training from an approved part 141 curriculum at the institution of higher 

education. It also requires the student to complete commercial and instrument flight training 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 with the institution of higher education. The purpose of 

this requirement is to have comprehensive flight training curricula integrated with a student’s ground 

training as part of an FAA-approved part 141 program. It also ensures the ground and flight training 

are integrated into the student’s broader academic education as part of a degree program with an 

aviation major...”

So to probe a bit deeper on your response to our Question #3, here is a new Question #4:

3. Would these minors contain the opportunity, or would they require, completion of the “integrated 

ground and flight training” which is inherent in ERAU-P’s 4-year bachelor major programs, listed on the 

FAA-approved LOA?

a. All aviation minors contain the opportunity to complete our ground and flight training program as 

an elective credit(s) in their degree program. However, only the Flight (Fixed Wing) minor requires the 

completion of flight training.

4. If Flight (Fixed Wing) is the only Minor which requires flight training:

 a. Will any student wishing to take advantage of this exemption be required to take Flight 

(Fixed Wing) as a minimum, among the 5 minor offerings?

b. Does this petition envision some other means that the student must complete the required 

integrated ground and flight training, so as to be in compliance with its own Letter of 

Authorization Paragraph B300 and 14CFR part 61.160 (b) and (c), which essentially have the 

same wording.

We certainly would be amenable to discussing this with you, with an eye to adding this 

additional information to the docket for Petition for Exemption 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

Wash FSDO office: 703-230-7664 ext 274

AFS-810 office: 202-267-0150

Telework: 240-578-3180

Message Page 3 of 6
From: Ritchie, Scott D. [mailto:ritchis1@erau.edu] 

Sent: Friday, January 16, 2015 12:49 PM

To: Lundgren, Douglas (FAA)

Subject: RE: Request to set up appointment to discuss petition for exemption, Docket # FAA 2014-0461

Mr. Lundgren,

When I was reviewing the current LOA, I noticed that SF 335 and SF 350 were approved during our July 

2014 revision request but they are not included on our current LOA.

Let me give you some preliminary answers to the questions you sent and then please feel free to contact 

me if you need more information/clarification:

1. What combination of courses and their corresponding credit hours are proposed for the 

aviation minors in question? In other words, would any combination of these courses that 

results in 30 hours of academic credit be permitted, or only certain combinations?

We would allow students to take the following aviation minors:

a. Aeronautical Studies

b. Air Traffic Control

c. Applied Meteorology

d. Aviation Safety

e. Flight (Fixed Wing)

*All of the above-listed minors are composed partly of courses that are included on our 

current LOA. These minors also include some courses that are not included on our current 

LOA. The students would only be awarded credit for courses that are included on our 

current LOA.

*The students would be required to complete at least two aviation minors for a total of at 

least 30 credits. The 30 credits must come from courses that are included on our current 

LOA.

2. Would the courses proposed for credit for these aviation minors be drawn from the current 

FAA-approved Letter of Authorization LOA), Paragraph B300, Table 2, for ERAU-Prescott? Or are 

there additional courses that would be submitted for approval to support this petition?

 Students would only be awarded credit toward the Restricted ATP for courses that are drawn 

from our current LOA. We will submit further revisions if we want to add additional courses to 

the LOA. 

3. Would these minors contain the opportunity, or would they require, completion of the 

“integrated ground and flight training” which is inherent in ERAU-P’s 4-year bachelor major 

programs, listed on the FAA-approved LOA?

a. All aviation minors contain the opportunity to complete our ground and flight training 

program as an elective credit(s) in their degree program. However, only the Flight (Fixed 

Wing) minor requires the completion of flight training.

Message Page 4 of 6
Please let me know if you need any more clarification. I’m available today or next week. Let me know 

what works for you and I’m flexible. 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: Friday, January 16, 2015 9:57 AM

To: Ritchie, Scott D.

Cc: Bowen, Brent D.

Subject: FW: Request to set up appointment to discuss petition for exemption, Docket # FAA 2014-0461

Dear Scott:

I received the signed LOA paragraph B300.

Next topic: I sent this request for more information to Dr. Bowen yesterday. I note in the docket that 

you are listed as his representative for this petition.

Are you able to speak about this today or next week, Tuesday the 20th onward?

Thanks

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

Wash FSDO office: 703-230-7664 ext 274

AFS-810 office: 202-267-0150

Telework: 240-578-3180

Message Page 5 of 6
From: Lundgren, Douglas (FAA) 

Sent: Wednesday, January 14, 2015 7:39 PM

To: 'brent.bowen1@erau.edu'

Subject: Request to set up appointment to discuss petition for exemption, Docket # FAA 2014-0461

Dear Dr. Bowen:

Hello, my name is Doug Lundgren. I am a specialist in the FAA headquarters General Aviation and 

Commercial Division assigned to do a technical analysis of the petition for 

rulemaking by the Embry Riddle Aeronautical University-Prescott (ERAU-P) campus, in a letter dated July 

7, 2014. This petition has been assigned Docket number FAA 2014-0461 in Regulations.gov.

In order for us to proceed further in our review, we would like to get some more details on ERAU’s 

proposal:

1) What combination of courses and their corresponding credit hours are proposed for the 

aviation minors in question? In other words, would any combination of these courses that 

results in 30 hours of academic credit be permitted, or only certain combinations?

2) Would the courses proposed for credit for these aviation minors be drawn from the current 

FAA-approved Letter of Authorization LOA), Paragraph B300, Table 2, for ERAU-Prescott? Or are 

there additional courses that would be submitted for approval to support this petition?

3) Would these minors contain the opportunity, or would they require, completion of the 

“integrated ground and flight training” which is inherent in ERAU-P’s 4-year bachelor major 

programs, listed on the FAA-approved LOA?

I would appreciate the opportunity to discuss these items with you at your earliest convenience.

Please note that any conversation we have or any additional material submitted will be noted and 

added to the open docket on Regulations.gov for this petition for exemption.

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

Wash FSDO office: 703-230-7664 ext 274

AFS-810 office: 202-267-0150

Telework: 240-578-3180

Message Page 6 of 6