TO: U.S. Department ofTransportation 

Docket Operations 

West Building Ground Floor Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

PETITION FOR EXEMPTION FROM CERTAIN REQUIREMENTS OF 14 C.F.R. 

PARAGRAPH 61.160 THAT WILL ALLOW JACKSONVILLE UNIVERSITY TO SEEK 

AUTHORITY TO CERTIFY GRADUATES FOR AN AIRLINE TRANSPORT CERTIFICATE 

PETITIONER: 

WITH REDUCED AERONAUTICAL EXPERIENCE 

JACKSONVILLE UNIVERSITY 

2800 University Blvd. N. 

Jacksonville, FL 32211 

(904) 256-7894 

jmerkt@ju.edu 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 

Page2 

Section of the FAR Affected: 

14 CFR paragraph 61.160(b or c )(3)(i) states: 

"The required ground training was completed as part of an approved part 141 curriculum at the 

institution of higher education ... " 

Background: 

On September 9, 2013, Jacksonville University submitted, as prescribed in CFR 14 61.169, FAA Form 

8700-1 "Institution of Higher Education's Application for Authority to Certify its Graduates for an 

Airline Transport Pilot Certificate with Reduced Aeronautical Experience". The graduates that we are 

seeking to certify are those completing a Bachelor of Science Degree in Aviation Management & Flight 

Operations. 

Jacksonville University received a letter (see attached) dated December 20, 2013 from the FAA signed by 

James A. Viola, General Aviation and Commercial Division, AFS-800, stating that the FAA had 

completed a review of the above application and determined that the minimum regulatory requirements 

were not met. 

The FAA letter cited the FAR affected and stated that Jacksonville University does not hold a part 141 

pilot school certificate with an approved course outline for the commercial pilot and instrument rating 

ground training. 

The FAA letter then stated that in order for Jacksonville University to obtain institutional authority to 

certify students who graduate from the institution's degree program with aviation major, the institution 

may proceed with one of the following actions: 

1. Jacksonville University may apply for a part 141 pilot school certificate for commercial pilot and 

instrument rating ground training only. In addition, a formal training agreement with another part 

141 pilot school for commercial and instrument flight training would also need to be in place. 

2. Jacksonville University may apply for a part 141 pilot school certificate for commercial pilot and 

instrument rating ground and flight training. 

3. File a petition for exemption from the applicable regulation. 

The FAA letter concluded by saying that once Jacksonville University has completed one of the options 

listed above, an FAA Form 8700-1 application may be resubmitted. 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 

Page 3 

After careful consideration of the three options provided by the FAA, Jacksonville University has decided 

to proceed with action #3: petition for exemption from the applicable regulation. 

Extent of Relief and Reason: 

fu order to proceed with our application for authority to certify graduates from our aviation degree 

program for an Airline Transport Pilot Certificate with Reduced Aeronautical Experience as specified in 

14 CFR paragraph 61.160, Jacksonville University is submitting a petition for partial exemption from this 

regulation, specifically 14CFR paragraph 61.160(b or c )(3)(i) as it relates to Jacksonville University not 

holding a part 141 pilot school certificate with an approved course outline for the commercial pilot and 

instrument rating ground training (as stated in the attached letter from the FAA dated December 20, 

2013). 

Jacksonville University offers two bachelor aviation degree programs, Aviation Management & Flight 

Operations (AVO) and Aviation Management (A VM), which are accredited by the Aviation 

Accreditation Board futemational (AABI). As part of the AVO degree program, students receive ground 

and flight training under a Part 141 Certificate (CE8S0570) held by our sole flight school contractor, 

Aerosim Flight Academy. The exclusive relationship with Aerosim Flight Academy, a professional 

airline-oriented academy, has been in place since 1996 when they first operated as Comair Aviation 

Academy (owned by Comair Airlines) and later as Delta Connection Academy (as a subsidiary of Delta 

Air Lines). From the start of the relationship, Aerosim Flight Academy established a satellite base at 

Craig Airport in Jacksonville, FL, for the exclusive use by Jacksonville University. It should be noted that 

Jacksonville University was the first university in the nation to ''join forces" with an airline academy to 

offer high quality professional flight training as part of its aviation degree program. 

Reviewing the regulation in question, 61.160(b or c )(3)(i) states that: 

"The required ground training was completed as part of an approved Part 141 curriculum at the institution 

of higher education ... " 

Jacksonville University believes that it meets the intent of the rule for the following reasons: 

1. Jacksonville University students are enrolled in ground school that follows the FAA-approved 

TCOs under the Part 141 certificate issued to our exclusive flight school contractor, Aerosim 

Flight Academy. 

2. Jacksonville University's ground school is wholly conducted at the institution in Jacksonville 

University facilities approved by the FAA under the Part 141 certificate held by Aerosim Flight 

Academy. 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 

Page4 

3. Jacksonville University's ground school is taught by Jacksonville University professors each of 

whom are individually approved by FAA under the Part 141 certificate held by Aerosim Flight 

Academy. 

4. The fact that both ground school and flight training are under a single FAA Part 141 certificate 

allows us to seamlessly interphase the ground courses conducted by the University with the flight 

training conducted by Aerosim. In addition, should the ground school and flight training be under 

two separate Part 141 certificates, the FAA would require Jacksonville University to have a 

formal FAA-approved training agreement with Aerosim Flight Academy for students to transfer 

between the two entities within our aviation program (see letter from the FAA dated December 

20, 2013). Having a single certificate for both ground and flight training makes the need to have a 

training agreement unnecessary. 

Jacksonville University is committed to provide students with the upmost quality education and training 

that meets not only the full intent ofF AA regulations but also criteria established by our accreditor AABI. 

Thus, in addition to basic ground and flight training that allows students to earn FAA Private Pilot 

through Flight Instructor certificates, our curriculum incorporates airline-level courses such as Advanced 

Aircraft Systems, Crew Resource Management and Jet Transition Training, made possible partly through 

the recent acquisition of a Level-5 certifiable Bombardier CRJ700 Flight Training Device. 

As a testament to the quality of the education and training provided by our aviation program, Jacksonville 

University has been singled out by four regional airlines for pilot hiring agreements. Three of these 

agreements lead qualified candidates to guaranteed interviews with Delta Air Lines, JetBlue, and 

American Airlines. As of today, JU is one few selected universities in the nation possessing such career 

pathway agreements. Our flight school, Aerosim Flight Academy, has also signed pilot hiring agreements 

with several airlines. 

In sum Jacksonville University is proud to be one of only 30 universities in the nation to have aviation 

degree programs that are accredited by AABI and one ofhandful of institutions selected by the airlines 

for career pathway agreements. 

Request for expedited consideration: 

As stated above, Jacksonville University submitted the original application (Form 8700-1) to the FAA on 

September 9, 2013. Jacksonville University did not hear back from the FAA until December 20, 2013. As 

we weighed in on the FAA decision and the options that they provided, Jacksonville University 

considered the option of applying for a Part 141 certificate for its ground school. Accordingly, we 

consulted with Orlando FSDO, who advised us that there is a long list of flight schools waiting for 

approval of Part 141 and other certificates. We were told that, through a directive from Washington, 

under no circumstances would they be able to expedite our application which may take a long time to be 

reviewed and processed. In addition, even if Jacksonville University were to be granted a separate Part 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 

Page 5 

141 certificate for our ground schools, current students and graduates, who have completed training under 

Aerosim Flight Academy's Part 141 certificate, would then need an exemption from the affected 

regulation. 

Given that there are over 100 graduates and current students being directly affected by the FAA's 

decision, we respectfully request expedited consideration for granting our petition for exemption from the 

affected regulation. Any further delays will cause many individuals unduly personal and economic 

hardship. 

Public Benefit: 

Multiple sources have predicted a significant pilot shortage in the aviation industry. The shortage of 

qualified pilots is already affecting the airlines and could soon affect the flying public. For example, from 

discussion with several regional airlines, Jacksonville University has learned that several of these airlines 

were unable to meet their training class targets for new pilot hires in 2013. Pilot shortages in 2014 may be 

even greater. Exercising the privileges of this exemption will be in the public interest because it would 

establish an efficient process for many qualified pilots graduating from Jacksonville University to be 

hired by the airlines expeditiously under the new hiring regulations established by 14 CFR 61.160 and 

61.169. Without an exemption there will be a delay in the hiring of qualified pilots that could negatively 

impact the airlines and the flying public. 

No Adverse Effect on Safety: 

The current arrangement of having the ground and flight training under a single certificate held by our 

exclusive flight training provider Aerosim Flight Academy has been in place since 1996. This 

arrangement has been providing the level of safety and regulatory compliance that is intended by 14 CFR 

61.160. In fact, in all eighteen years since Jacksonville University began its relationship with Aerosim 

Flight Academy, the University's aviation degree program has had an impeccable safety record without a 

single serious or fatal accident. In addition, Jacksonville University, following the guidelines from our 

accreditor AABI, has recently implemented an Aviation Safety Program that further promotes a safety 

culture and encompasses all aspects of the flight training program. This program complements Aerosim 

Flight Academy's own Aviation Safety Action Program (ASAP) endorsed by the Florida FSDO. 

Summary for Federal Register: 

Jacksonville University is petitioning exemption from certain requirements of 14 CFR 61.160 (b or 

c)(3)(i). Specifically, Jacksonville University is seeking relief from having to hold a Part 141 Certificate 

for its commercial pilot and instrument rating ground schools. Currently, these ground schools are held 

under the Part 141 Certificate of Jacksonville University's exclusive flight school contractor. As intended 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 · 

Page 6 

by the regulation, the above ground schools follow FAA-approved TCOs, are conducted in FAAapproved facilities, and are taught by FAA-approved Jacksonville University faculty in compliance with 

Part 141. In addition, the current 18-year arrangement of having both ground and flight training under a 

single FAA Part 141 Certificate has allowed Jacksonville University to seamlessly interphase the ground 

courses conducted by the University with the flight training conducted by our flight school contractor. 

Please contact Juan Merkt, Director of Jacksonville University's Davis Aviation Center, at (904) 256-

7894 or e-mail at jmerkt@ju.edu, if you have and questions or need additional information. 

Sincerely, ') !1;--- t.:erb 

Director 

Davis Aviation Center 

Jacksonville University 

Cc: Dr. Don Capener, Dean, Davis College of Business 

Dr. Bill Crosby, Acting Chief Academic Officer 

Attachments: 

Letter from the FAA, dated December 20, 2013 
Petition for Exemption- (FAR) §61.160(b)(3)(i) 

Jacksonville University 

January 28, 2013 

Page 7 

DEC 2 0 2013 

Mr. Jwm Merkt 

Jacksonville University 

Davis Aviation Center 

2800 Unh•crsity Blvd. North 

Jacksonville, FL 32211 

Dear Mr. Merk1: 

000 11\dierlendence Am .• S.W 

Vle$.1lh;Jton. DC. 20591 

The FAA bas compleced a review of Jacksonville University's FAA Form 8700-1 ''Institution 

of Higher Education's Application for Authority to Certify its Groduates for an Airline 

Transport Pilot Certificate with Reduced Aeronautical Experience" dated September 9, 2013. 

This review allows the FAA to determine if the minimum regulatory requirements of part 61 

are met, and is conducted in aooordance with guidance described in Advisory Circular (A C) 

61-139. After a review of Jacksonville University's FAA Fotm 870Q-l appli«ltion for 

institutio11al authority, the FAA has detennined that the minimum regulatory requirements are 

not met. 

14 CFR paragraph 61.160(cX3)(i) states: 

"The rl!([uired ground training was- OOmJ>leted as parl of an apprbl'ed part 141 curriculum 

at tlze institution of higher edJ.1cotfon ... '·' · 

Jacksonville University does not hold a part 141 pilot school e<:rtificatc with an approved 

training course outline for the commercial pilot and instrument rating ground training .. In order 

for Jacksonville University to obtain institutional authority to certify students wbo gmduatc 

from the institution•s degree progrnm with aviation major, the institution may proceed with 

one of the follow actions: 

1. Jacksonville University may apply for a part 141 pilot school certificate for commercial 

pilot and instrument rating ground training only. In addition~ a formal training 

agreement with aoolhc.r part 141 pilot school for commercial and instnunent flight 

training would also on need to be place. · 

2. Jacksonville University ma)' apply for a part 14 I pilo1 school certificate for commercial 

pilot and instrument rating ground and flight training. 

3. File a petition for exemption from the applicable regulation. Please reference 

http://www.faa.gov/rc:gulations_policicslrulcmakinglpetitionl for instructions on filing 

a petition for exemption. 
Petition for Exemption - (FAR) §61.160(b )(3)(i) 

Jacksonville University 

January 28, 2013 

Page 8 

2 

Please .note that if JacksonviUe UniYersity seeks to apply for a 14 I pi1ot school certificate that 

applications must be made through the local 1:-Jight Standards District Office (FSDO). For 

rcferen.ce, a list of FSDO locations cru1 be found on the following web site: 

http://www.faa.gov/about/office_org/field_officeslfsdo/ for FSDO locations. 

Once Jacksonville University bas completed one of the options listed above, an FAA fom1 

8700-1 8J)plication may be resubmitted in the fonn and manner prescribed in AC 61-139. 

Please contact that General Aviation and Commercial Division for any assistance in the future 

on this matter at (202) 385-9600. 

Sincerely, 

/~ ~~~----- P1'ames A. Viola 

Manager. General Aviation and Commercial D.ivision, AFS-800