AFS-14-448-E

November 2, 2015

 Exemption No. 13476

 Regulatory Docket No. FAA-2014-0716

Mr. Wayne Ceynowa

Auburn University

700 Airport Road

Auburn, AL 36830

Dear Mr. Ceynowa:

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends.

The Basis for Our Decision

By letter posted September 12, 2014, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Auburn University (AU) 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) to the extent

necessary to 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).

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to AU.

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Exemption No. 11022 (copy enclosed), the FAA found 

that the petitioner’s supporting information meets an equivalent level of safety and is in the 

public interest.
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The FAA’s analysis is as follows:

The petitioner stated that AU’s Bachelor of Science-Business Administration degree program,

with options in Aviation Management and Professional Flight Management, is nationally 

accredited by the Aviation Accreditation Board International (AABI). AU also holds a Letter 

of Authorization for Institutional Authority (LOA) issued by the FAA on September 10, 2013.

The FAA notes that this is in every way equivalent to the LOA held by the petitioner in 

Exemption No. 11022.

AU further stated that it held its FAA-approved 14 CFR part 141 pilot school certificate until 

August 2010. At that time, AU voluntarily surrendered its pilot school certificate after it was 

unable to replace its Chief Flight Instructor within the 60-day period required by 14 CFR part 

141. AU had hired a new Chief Flight Instructor by October 2010 and was able to get its pilot 

school certificate reinstated in August 2011. From August 2010 to August 2011, AU 

continued to provide training under 14 CFR part 61, using identical Jeppesen curriculums and 

standards as it did under Part 141. During this interim period, required hours of flight training 

were increased and identical levels of safety were maintained. AU provided a table of 

program comparisons supporting these assertions. The FAA notes that AU’s experience in 

operating with the same level of safety and effectiveness under part 61 is equivalent to 

Exemption No. 11022. 

The FAA has determined that AU may certify graduates for an ATP certificate with reduced 

aeronautical experience only after that graduate has been found to meet the criteria in AU’s 

LOA, which the FAA notes in Condition/Limitation #1.

The FAA has also considered AU’s request for exemption as a request to revise its LOA. 

Concurrent with issuing this grant of exemption, the FAA has amended the LOA to permit 

AU to certify graduates that have completed the requisite ground and flight training under part 

61 training provided by AU. AU must revise its certifying statement for these graduates to 

indicate they are eligible for an ATP certificate with reduced aeronautical experience as a 

result of the relief provided by this exemption. This requirement is reflected in 

Condition/Limitation #2.

AU must also provide a copy of this exemption to each student for whom the relief is 

necessary and direct that student to provide a copy of the exemption along with the official 

transcript and certifying statement at the time of application for the practical test for the ATP 

certificate with restricted privileges under § 61.160. This is reflected in Condition/Limitation 

#3.

Since AU has received certification under part 141 to conduct commercial pilot and 

instrument training, the relief for this exemption is only applicable to students that have 

graduated in 2010, 2011, 2012, 2013, 2014, and for those that expect to graduate in the years 
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2015 or 2016. As such, the relief provided in this exemption is limited to only those students 

that have graduated, or expect to graduate, during these years. This limitation is reflected in 

Condition/Limitation #4.

Any students who graduate after the year 2016 must have accomplished their commercial pilot 

certificate and instrument rating flight and ground training under AU’s approved part 141 

pilot school certificate to meet the requirements of § 61.160(b)(3). This limitation is reflected 

in Condition/Limitation #5. The FAA has issued this exemption for a two year period in order 

to provide AU adequate time to certify those students that graduate in the year 2016.

Our Decision

Having reviewed your reasons for requesting an exemption, I find that—

• Your request is similar in all material respects to relief previously requested in 

the enclosed Exemption No. 11022;

• The reasons stated by the FAA for granting the enclosed Exemption No. 11022 

also apply to the situation you present; 

• A grant of exemption is in the public interest; and

• A two year term for this exemption is appropriate in order to accommodate the 

affected AU graduates.

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Auburn University (AU) an exemption from 

14 CFR §§ 61.160(b)(3)i, 61.160(b)(3)(ii) and 61.169(b) to the extent necessary to 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), 

subject to the conditions and limitations described below.

Conditions and Limitations 

1. AU must adhere to all the conditions and limitations listed within its letter of 

authorization (LOA) granting authorization for AU to certify its graduates for an 

airline transport pilot (ATP) certificate with reduced aeronautical experience. 

2. In exercising the relief provided in this exemption, AU must reference Exemption 

No. 13476 on the certifying statement issued to those affected graduates for an 

ATP certificate with reduced aeronautical experience. The certifying statement 

must note that the requirements of § 61.160(b) are met in conjunction with the 

relief provided in this exemption. 

3. AU must provide a copy of this exemption to each student for whom the relief is 

necessary and direct that student to provide a copy of the exemption along with the 
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official transcript and certifying statement at the time of application for the 

practical test for the ATP certificate under § 61.160.

4. AU may utilize this grant of exemption only for students who have graduated 

between August 1, 2010, and December 31, 2016 and completed the integrated 

commercial and instrument courses under 14 CFR part 61 at AU for an ATP 

certificate with reduced aeronautical experience. 

5. The authority (in the LOA) to certify graduates who received training from AU 

under 14 CFR part 61 terminates upon expiration of this exemption.

This exemption terminates on November 30, 2017 unless sooner superseded or rescinded.

Issued in Washington, DC on November 2, 2015.

Sincerely,

//s//

John Barbagallo

Deputy Director, Flight Standards Service

Enclosure[s]
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Project No.: AFS-14-484-E

Project Officer: Doug Lundgren

ARM-201:SLong:9/22/14:Doc#40821

ARM-1/200/201:Program Office AFS-800

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