RI C HARD G. R HOQA. E'xecuuw**D~ree~or**



### Via US Mail and Email Mr. Ravi S. Virdi President STATE OF T ENNESSEE HIGHER EDUCATION C O MMI SS ION P A RKW.A.Y T OW ERS, SU ITE 1 900 N AS H V I LLE, T E NNESSEE 3724 3-0830 (6 15 ) 7 41 - 5293 FAX : (6 15) 532- 884 5

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 ofthe 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 , 20I4 , 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 ofthe exemption test, AAI asserts that it does not require students to enter into written or oral contracts ofindebtedness. 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 ofthe exemption standard has been satisfied. As a result ofthe 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 f or Regulatory Affairs & 

### Compliance
c : Dr. Stephanie Bellard Chase , Associate Executive Director for DPSA Julie M
. Woodruff, Director of DPSA & 

### Lead Attorney