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Baylor University 

Institute for Air Science 

Aviation Science Program 

One Bear Place #97 413 

Waco, TX 76798-7413 

PETITION FOR EXEMPTION 

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28 April2014 

U.S. Department of Transportation 

Docket Management System 

400 7th Street, SW. 

RoomPL401 

Washington, DC 20591-0001 

SUBJECT: PETITION FOR GRANT OF EXEMPTION 

Pursuant to Section 11.25 of the Federal Aviation Regulation (FAR), Baylor University's Aviation 

Science Program, housed within the Baylor Institute for Air Science, hereby petitions the Federal 

Aviation Administration (FAA) for exemption from 14 CFR 61.160(b) to the extent necessary to permit 

Baylor University to issue a letter of authorization certifying its graduates for an Airline Transport Pilot 

Certificate with reduced aeronautical experience. 

NATURE AND EXTENT OF RELIEF 

Certifying graduating students who have earned the Bachelor of Science in Aeronautical Science 

(B.S.A.S.) degree for an Airline Transport Pilot Certificate with reduced aeronautical experience will 

require exemption to 14 CFR 61.160(b). 

FAR §61.160(b) states, in pertinent part: 

"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 of 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; 

(2) Completes 60 semester credit hours of aviation and aviation-related coursework that has been 

recognized by the Administrator as coursework designed to improve and enhance the knowledge 

and skills of a person seeking a career as a professional pilot; 

(3) Holds a commercial pilot certificate with an airplane category and instrument rating if: 
(i) The required ground training was completed as part of an approved part 141 curriculum at the 

institution of higher education ... " 

This relief is requested in order to allow Baylor University to certify its graduates for an Airline Transport 

Pilot Certificate with reduced aeronautical experience, specifically due to the fact that the required ground 

and flight training, leading to the Instrument Pilot Rating and the Commercial Pilot Certificate, are all 

conducted via FAA approved Training Course Outlines (TCO's) attached to Part 141 Certificate Number 

FT8Sl50Q, maintained by Texas State Technical College. Furthermore, TSTC has recently been awarded 

a letter of authorization to certify its graduates for an airline transport pilot certificate with reduced 

aeronautical experience. 

PUBLIC INTEREST 

Granting of this petition for exemption to permit Baylor University to certify its graduates for an Airline 

Transport Pilot Certificate with reduced aeronautical experience is in the public interest for reasons of 

economy of resources, cost effectiveness for the student, and synergy with the student's flight training 

experience. If Baylor were to teach the Part 141 ground school courses for our curriculum, we would 

essentially be duplicating the efforts ofTSTC's Part 141 ground school course (which our students 

currently take). This would mean duplicating manpower and instructional time beyond what is currently 

required. The courses at Baylor would also be more expensive than the courses at TSTC (since Baylor 

tuition is much higher than TSTC's), effectively increasing the cost of the degree for our students. 

Finally, TSTC's ground school courses are designed to work in tandem with their flight courses to 

provide their students an integrated curriculum experience. That synergy would be broken if Baylor is 

teaching the ground school courses while the flight courses are taught at TSTC. 

EQUIVALENT LEVEL OF SAFETY 

Considering the fact that ground and flight education requirements under question are provided by Texas 

State Technical College (TSTC), Part 141 Certificate Number FT8S150Q, the level of safety is at least 

equivalent. 

The following courses, both flight and ground, are the courses that were considered by the FAA in the 

recent 8700-1 application that led to a letter of authority being awarded to TSTC. 

Part 141 Flight Courses and Course Descriptions 

AIRP 2250 Instrument Pilot Flight 

Preparation for completion of the Federal Aviation Administration Instrument Pilot rating 

with mastery of all instrument procedures. 

AIRP 2239 Commercial Pilot Flight 

Flight instruction necessary to qualify for the Federal Aviation Administration 

Commercial Pilot Certificate. Instruction includes both dual and solo flight training to 

prepare the student for mastery of all commercial pilot maneuvers. 

Part 141 Ground Courses and Course Descriptions 

AIRP 1451 Instrument Pilot Ground School 
A study of basic instrument radio and navigation fundamentals used in instrument flight. 

Topics include a description and practical use of navigation systems and instruments, 

charts used for instrument flight, and Federal Aviation Administration regulations. 

Qualifies as part of a program leading to Federal Aviation Administration certification. 

AIRP 2337 Commercial Pilot Ground School 

A study of advanced aviation topics that can be used for federal aviation administration 

certification at the commercial pilot level. Includes preparation for the commercial 

airplane written test. 

It is important to note that Baylor students who complete these courses do so at TSTC, on the TSTC 

campus, taught by TSTC faculty members in TSTC classrooms and in TSTC aircraft. The Baylor 

students are also required to submit application to TSTC and be accepted into TSTC. Grades are awarded 

at TSTC and officially recorded on TSTC transcripts . 

. Additional Courses Taught at Baylor University Possessing Safety Related Content 

Arguably, the additional safety related coursework that is completed by a Baylor graduate provides 

additional levels or layers of safety insight, safety awareness, and an overall safety-first mindset. 

Examples of courses which are heavily laden with safety topics include, but are not limited to: 

A VS 3311 Aircraft Accident Investigation and Prevention 

A comprehensive overview of the procedures and methods used and the skills required to 

investigate an aircraft accident with emphasis placed on accident prevention. 

AVS 3315 Advanced Aviation Meteorology 

Physical and chemical processes in the atmosphere which affect aviation including 

atmospheric motion, climatic conditions, and pollution. Weather map analysis and forecasts. 

AVS 3320 Aviation Operations 

Airline, corporate, and military flight operations with emphasis placed on daily operational 

environments. 

AVS 4305 Crew Resource Management 

A study of cognitive processing theory, organizational behavior, interpersonal relationship. 

skills, and other critical behavioral dynamics of professional flight crews. Specific CRM 

topics to be studied include information processing, human error, human reliability, error 

management, fatigue and workload management, situational awareness, CRM phase 

development, and CRM specific federal regulations as they pertain to aviation. 

The added depth and scope of coursework completed by Baylor students in addition to the existing Part 

141 ground and flight training curriculum administered at TSTC warrant granting the requested ability to 

reduce the graduate's required aeronautical experience. 

SUMMARY 

As required by FAR Section 11.25( d), a summary of the petition is as follows: 
Baylor University's Aviation Science Program housed within the Baylor Institute for Air Science requests 

an exemption from FAR Section 61.160(b) to grant Baylor University authority to certify its graduates for 

an Airline Transport Pilot Certificate with reduced aeronautical experience. 

Sincerely, 

Timothy James Compton 

Assistant Director 

Institute for Air Science 

Baylor University