Auburn University Petition for Exemption

Auburn University (AU), Auburn, Alabama, pe titions the Federal Aviation Administration (FAA) for an exemption from § 61.160(b)(3)(i), 61.160(b)(3)(ii), and § 61.169(b) of Title 14, Code of Federal Regulations (14 CFR). This petition for exemption, if granted, would allow certain AU graduates who completed their inst rument-airplane rating or commercial pilot certificate training under Part 61 whil e enrolled at AU to be eligible for an airline transport pilot (ATP) certificate with reduced aeronautical experience in accordance with § 61.160(b).

Auburn University is a public university operated on behalf of th e state of Alabama and accredited by the Southern Association of Co lleges and Schools (SACS). In addition, its Bachelor of Science, Business Administration degrees, with an option in either Aviation Management or Professional Flight Manageme nt, are fully-accredited by the Aviation

Accreditation Board International (AABI). The graduates of either degree program with aviation option develop strong technical skills, with an emphasis on critical thinking, decision-making,

and communication abilities.

AU seeks relief from the current rule to be able to provide a certifying statement to students who are either anticipated to gra duate in the 2014, 2015, or 2016, or those students who graduated in 2010, 2011, 2012, and 2013, and who, through no fault of th eir own, had to start or complete the integrated instrument and commercial pilot courses offered by AU and conducted under 14 CFR Part 61. With granting an exemption, these st udents would meet all th e requirements for the

ATP certificate with reduced aeron autical experience and be elig ible for the issuance of a certifying statement for coursework completed through either of two FAA-approved Bachelor’s degree programs with aviation option offered by AU.

In support of our request, AU was an FAA-approved pilot school operating in accordance with 14 CFR Part 141 until August 2010. In August 2010, AU voluntarily surrendered its pilot school certificate after its Chief Flight Instructor terminated employm ent with AU and the school was unable to find a replacement Chief Flight Instruct or within the 60-day period allowed by Part 141. AU hired a new Chief Flight Instructor by October 2010, a pplied for reinstatement of it pilot school certificate, and achieved reinstatem ent and designation as an FAA-approved Part 141 pilot school in August 2011. During the period between pilot school certificate surrender in August 2010 and its reinstatement in August 2011, AU continued to operate its pilot training program under 14 CFR Part 61. This 12-month lapse of time forced students already enrolled in the Part 141 Instrument Rating – Ai rplane or Commercial Pilot Cer tification courses to complete their training under Part 61. In addition, student s who started instrument rating – airplane or commercial pilot courses during that period had to do so under Part 61.

In conducting training under Part 61, however, AU continued to use the Jeppesen ground and flight training curriculums previously appr oved by the FAA under Part 141. The only changes

made to that curriculum were those necessa ry to accommodate Part 61 requirements. Specifically, hours were increased to meet instrument time and pilot-in-command cross-country experience for the instrument-air plane rating, and total time requirements for commercial pilot certification. In no way was any other change ma de to the previously approved training coursecontent. In addition, the trai ning conducted during this period was accomplished at the same level of safety as the training that had been conducted at AU in accordance with Part 141.

AU believes its request for exemption is within th e public interest as granting the exemption will add additional qualified pilots to meet the work force needs of the aviation industry. A positive

economic benefit will be realized where the continuity and level of service offered to the public will be better supported and maintained.