Auburn University 

Petition for Exemption

Auburn University (AU), Auburn, Alabama, petitions 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 instrument-airplane rating or commercial pilot 

certificate training under Part 61 while 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 the state of Alabama and 

accredited by the Southern Association of Colleges and Schools (SACS). In addition, its 

Bachelor of Science, Business Administration degrees, with an option in either Aviation 

Management or Professional Flight Management, 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 graduate in the 2014, 2015, or 2016, or those students who graduated in 

2010, 2011, 2012, and 2013, and who, through no fault of their 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 students would meet all the requirements for the 

ATP certificate with reduced aeronautical experience and be eligible 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 employment with AU and the school was 

unable to find a replacement Chief Flight Instructor within the 60-day period allowed by Part 

141. AU hired a new Chief Flight Instructor by October 2010, applied for reinstatement of it 

pilot school certificate, and achieved reinstatement 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 – Airplane or Commercial Pilot Certification courses to complete 

their training under Part 61. In addition, students 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 approved by the FAA under Part 141. The only changes 

made to that curriculum were those necessary to accommodate Part 61 requirements. 

Specifically, hours were increased to meet instrument time and pilot-in-command cross-country 

experience for the instrument-airplane rating, and total time requirements for commercial pilot 

certification. In no way was any other change made to the previously approved training course 
content. In addition, the training 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 the 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.