**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 exempti on 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 a nother 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 ritchis 1@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 ratin g 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 def ined 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 imp rove 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 pr ogram... this AC language is drawn from the Preamble to 14CFR part 160:

**Message Page**  **2 0f 6 “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 t**  **he 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 opportu nity 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 requi res 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 co mplete 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 discussi ng 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 se nt 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- ap proved 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 progra m. However, only the Flight (Fixed Wing) minor requires the completion of flight training. Message Page 4 of 6Please 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 20 th 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 - 046 1 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 app roval 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
- appr oved 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