RICHARD G. R HOQA. 

E'xecuuw D~ree~or 

Via US Mail and Email 

Mr. Ravi S. Virdi 

President 

STATE OF T ENNESSEE 

HIGHER EDUCATION COMMISSION 

PARKW.A.Y T OW ERS, SUITE 1900 

N ASHV ILLE, T ENNESSEE 37243-0830 

(615) 741-5293 

FAX: (615) 532-8845 

October 27, 20I4 

Aero Academy International, LLC 

308 Grady Montgomery Drive 

Jackson, Tennessee 3830I 

ravi. virdi @aeroacademyinternational.com 

Re: Aero Academy International, LLC - Exemption Request for Jackson, Tennessee Facility 

Dear Mr. Virdi: 

BILL H ASLAM 

Gatc..'Tnor 

I am in receipt of your email of October I, 20I4, seeking an exemption for your 

institution, Aero Academy International, LLC (AAI), under Tenn. Code. Ann. § 49-7-2004(IO), 

which exempts aviation schools and aviation programs from regulation by the Tennessee Higher 

Education Commission if certain criteria are met. 

Tenn. Code. Ann.§ 49-7-2004(IO) requires institutions to meet all of the exemption 

criteria as follows: (I) the education offered does not lead to a degree; (2) the institution is 

regulated by the Federal Aviation Administration (FAA); and (3) the institution does not require 

that students who receive instruction enter into written or oral contracts of indebtedness. You 

have submitted an exemption request on behalf of your institution asserting that AAI meets the 

exemption criteria for the following FAA approved programs: Private Pilot Course and Private 

Pilot Airplane, Single Engine Land. 

Your email of October I, 20 I4, as well as the letter from Ms. Sheri L. Nichols of the 

FAA's Flight Standards District Office in Memphis, Tennessee establish that instruction for 

AAI's programs, as set forth above, do not lead to the award of a degree. Additionally, upon 

review ofthe provisions ofthe Code of Federal Regulation you cited in your letters, the Division 

of Postsecondary School Authorization (DPSA) concludes that these programs lead only to 

certification awarded by the FAA. 
Mr. Virdi 

October 27, 2014 

Page 2 of2 

After additional review of 14 CFR Parts 61 (Subparts B, C, E, F and G) and 141 , DPSA 

concludes that the FAA regulates AAI's operations as it relates to AAI's facilities, personnel, 

testing, and the qualifications of AAI's students. Specifically, 14 CFR 141 (Sections 141.1 

through 141 .95 and appendices) set forth the minimum requirements for the programs offered by 

your institution, the requirements for instructors and fix strict curriculum guidelines to 

accomplish such training. 

With regard to student indebtedness, which is the last criterion of the exemption test, AAI 

asserts that it does not require students to enter into written or oral contracts of indebtedness. 

You further stated that AAI requires students to pay for each class as they attend the same. Thus, 

based on your statements, the third criterion of the exemption standard has been satisfied. 

As a result of the above determinations, DPSA concludes that the programs offered by 

AAI are exempt under Tenn. Code. Ann. § 49-7-2004(1 0). However, if AAI changes its 

programs so that such programs fall outside of the exemption, AAI shall contact DPSA 

immediately to ensure any appropriate action can be taken and that AAI complies with relevant 

state statutes and rules. As always, please feel free to contact me with any questions regarding 

this correspondence at (615) 532-9758 or by e-mail at edward.phillips@tn.gov. 

r~;J....- _) 

._ __ .. . dward Phillips, Esq. 

Associate Director for Regulatory Affairs & Compliance 

c: Dr. Stephanie Bellard Chase, Associate Executive Director for DPSA 

Julie M. Woodruff, Director of DPSA & Lead Attorney