UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC

20591

In the matter of the petition of EMBRY-RIDDLE AERONAUTICAL UNIVERSITY for an 

exemption from §§61.160(b)(1) and 61.160(d) 

of Title 14, Code of Federal Regulations.

GRANT OF EXEMPTION

By letter dated July 07, 2014, Dr. Brent D. Bowen, Embry Riddle Aeronautical 

University (ERAU), 3700 Willow Creek Rd., Prescott, AZ 86301, petitioned the Federal 

Aviation Administration (FAA) on behalf of ERAU for an exemption from §§ 61.160(b)(1) and 

61.160(d) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if 

granted, would allow certain students that complete non-aviation degrees and at least one

aviation minor at ERAU to be eligible for the restricted privileges airline transport pilot (ATP) 

certificate in accordance with § 61.160(b) and (d).

The petitioner request relief from the following regulations:

Section 61.160(b)(1) states that 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 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;

Section 61.160(d) states that:

(d) A graduate of an institution of higher education who completes fewer than 60 semester 

credit hours but at least 30 credit hours and otherwise satisfies the requirements of paragraph 

(b) may apply for 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 1,250 hours of total time as a pilot.

The petitioner supports its request with the following information:

Embry Riddle-Prescott (ERAU-PRC) allows students who are pursuing a non-aviation 

degree to also complete an aviation-related minor. The aviation-related minors currently offered 

at ERAU-PRC are as follows:

Name Credits

1. Aeronautical Studies 18

2. Air Traffic Control 16-19

3. Applied Meteorology 15

4. Aviation Safety 15
5. Fixed-wing Flight 17-21

A student who completes only one aviation-related minor would not be eligible for the 

restricted ATP because they would not have completed 30 hours of approved coursework. 

However, those students who choose to complete more than one aviation-related minor would 

complete more than 30 credits but less than 60 credits of approved coursework and would, 

therefore, be eligible for the restricted ATP certificate granted under 14 CFR 61.160(d).

These students would complete non-aviation majors such as Aerospace Engineering, 

Aviation Business Administration, Cyber Intelligence and Security, Global Security and 

Intelligence Studies, Space Physics, Computer Engineering, Electrical 

Engineering, Mechanical Engineering, or Software Engineering to name a few. The number of 

students pursuing a non-aviation degree and more than one aviation-related minor is very small 

and could be approximated at less than 5 every year.

ERAU-PRC believes this exemption closely approximates the provision granted under 14 

CFR 61.160(c)(1) and 61.160(c)(2). A student who completes at least two aviation-related 

minors has essentially completed an associate degree in aviation-related coursework. These 

students enter the workplace as highly-trained professionals and competent aviators.

This exemption would benefit the public by supplying the aviation industry with highlytrained engineers, security professionals, and business innovators who are also trained as pilots 

according to the courses that have already been approved by the FAA. These forward-thinking 

professionals would lend invaluable insight and knowledge to the professional aviation career 

field and would increase aviation safety.