### TO: U.S. Department ofTransportation Docket Operations West Building Ground Floor Room W12-140 1200 New Jersey Avenue, SE. Washington, DC 20590



### PETITIONFOREXEMPTIONFROM CERTAIN REQUIREMENTS OF 14 C.F.R. PARAGRAPH 61.160 THAT WILL ALLOWJACKSONVILLE UNIVERSITY TO SEEK AUTHORITY TO CERTIFY GRADUATES FORAN AIRLINE TRANSPORT CERTIFICATE

PETITIONER: WITHREDUCED AERONAUTICAL EXPERIENCE

JACKSONVILLE UNIVERSITY 2800 University Blvd. N. Jacksonville, FL 32211 (904) 256-7894 jmerkt@ju.eduPetition for Exemption- (FAR) §61.160(b)(3)(i) Jacksonville University January 28, 2013 Page2 

### Section ofthe FARAffected: 14 CFRparagraph 61.160(b or c)(3)(i) states: 

### "The requiredground training was completedaspartof an approvedpart141 curriculum atthe institution of highereducation

..." 

### Background: On September 9, 2013, Jacksonville University submitted, as prescribed in CFR 14 61.169, FAAForm 8700-1 "Institution ofHigherEducation's Application for Authorityto 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 ofScience Degree in Aviation Management & Flight Operations. Jacksonville University received a letter (see attached) dated December 20, 2013 from the FAA signedby James A. Viola, General Aviation and Commercial Division, AFS-800, stating that the FAAhad completed a review ofthe 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 mayproceed with one ofthe 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 anotherpart 141 pilot school for commercial and instrument flight training would also need to be inplace. 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 concludedby saying that once Jacksonville University has completed one ofthe options listed above, an FAAForm 8700-1 application may beresubmitted.Petition for Exemption- (FAR) §61.160(b)(3)(i) Jacksonville University January 28, 2013 Page 3 After careful consideration ofthe three options provided bythe FAA, Jacksonville University has decided to proceed with action #3: petition for exemption from the applicable regulation.



### Extent ofReliefand Reason: fu orderto proceed with our application for authorityto certify graduates from our aviation degree program for an Airline Transport Pilot Certificate with Reduced Aeronautical Experience as specified in 14 CFRparagraph 61.160, Jacksonville University is submitting a petition for partial exemption from this regulation, specifically 14CFRparagraph 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 December20, 2013). Jacksonville University offers two bachelor aviation degree programs, Aviation Management & Flight Operations (AVO) and Aviation Management (A VM), which are accredited bythe Aviation Accreditation Board futemational (AABI). As part ofthe 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 inplace since 1996 when they first operated as ComairAviation Academy (owned by Comair Airlines) and later as Delta Connection Academy (as a subsidiary ofDelta AirLines). Fromthe start ofthe relationship, Aerosim Flight Academy established a satellitebase at Craig Airport in Jacksonville, FL, for the exclusive use byJacksonville University. It shouldbe noted that Jacksonville University was the first university inthe nation to ''join forces" with an airline academy to offerhigh quality professional flight training as part ofits aviation degree program. Reviewing the regulation in question, 61.160(b or c)(3)(i) states that: "Therequired ground training was completed as part ofan approved Part 141 curriculum at the institution ofhigher education

..." Jacksonville Universitybelieves that it meets the intent ofthe rule for the following reasons: 1. Jacksonville University students are enrolled in ground school that follows the FAA-approved TCOs underthe Part 141 certificate issued to ourexclusive flight school contractor, Aerosim Flight Academy. 2. Jacksonville University's ground school is wholly conducted at the institution in Jacksonville University facilities approved bythe FAAunderthe 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 byJacksonville University professors each of whom are individually approved byFAAunder the Part 141 certificate heldby 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 conductedbyAerosim. In addition, should the ground school and flight training be under two separate Part 141 certificates, the FAAwould require Jacksonville University to have a formal FAA-approvedtraining 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 needto 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 AAregulations but also criteria establishedby 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 partlythrough the recent acquisition ofa Level-5 certifiable BombardierCRJ700 Flight Training Device. As a testament to the quality ofthe education and training provided by our aviation program, Jacksonville University has been singled out by four regional airlines for pilot hiring agreements. Three ofthese agreements lead qualified candidates to guaranteed interviews with Delta AirLines, JetBlue, and American Airlines. As oftoday, JU is one few selected universities in the nation possessing such career pathway agreements. Our flight school, Aerosim Flight Academy, has also signedpilot hiring agreements with several airlines. In sum Jacksonville University is proudto be one ofonly 30 universities inthe nation to have aviation degree programs that are accredited by AABI and one ofhandful ofinstitutions selected by the airlines for careerpathway 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 hearback from the FAAuntil December 20, 2013. As we weighed in on the FAAdecision and the options that they provided, Jacksonville University considered the option ofapplying for a Part 141 certificate for its ground school. Accordingly, we consulted with Orlando FSDO, who advised us that there is a long list offlight schools waiting for approval ofPart 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 ifJacksonville University were to be granted a separate PartPetition 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 bythe FAA's decision, we respectfully request expedited consideration for granting ourpetition 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 inthe aviation industry. The shortage of qualified pilots is already affecting the airlines and could soon affect the flying public. Forexample, from discussion with several regional airlines, Jacksonville University has learned that several ofthese airlines were unable to meet their training class targets for new pilot hires in 2013. Pilot shortages in 2014 maybe even greater. Exercising the privileges ofthis exemption will be inthe public interest because it would establish an efficient process for many qualified pilots graduating from Jacksonville University to be hiredbythe airlines expeditiously underthe new hiring regulations establishedby 14 CFR 61.160 and 61.169. Without an exemption there will be a delay in the hiring ofqualified pilots that could negatively impact the airlines and the flying public.



### No Adverse Effect on Safety: The current arrangement ofhaving the ground and flight training under a single certificate heldby our exclusive flight training provider Aerosim Flight Academy has been in place since 1996. This arrangement has beenproviding the level ofsafety and regulatory compliance that is intendedby 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 ofthe flight training program. This program complements Aerosim Flight Academy's own Aviation Safety Action Program (ASAP) endorsedby 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 relieffrom having to hold a Part 141 Certificate for its commercial pilot and instrument rating ground schools. Currently, these ground schools are held underthe Part 141 Certificate ofJacksonville University's exclusive flight school contractor. As intendedPetition 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 inFAAapproved facilities, and are taught byFAA-approved Jacksonville University faculty in compliance with Part 141. In addition, the current 18-year arrangement ofhaving both ground and flight training under a single FAAPart 141 Certificate has allowed Jacksonville University to seamlessly interphase the ground courses conducted bythe University with the flight training conducted by our flight school contractor. Please contact Juan Merkt, Director ofJacksonville University's Davis Aviation Center, at (904) 256- 7894 ore-mail atjmerkt@ju.edu, ifyou have and questions or need additional information. Sincerely,



# ') !1;--- 

# t.:erb

Director Davis Aviation Center Jacksonville University Cc: Dr. Don Capener, Dean, Davis College ofBusiness Dr. Bill Crosby, Acting ChiefAcademic Officer

Attachments: Letter from the FAA, dated December 20, 2013Petition for Exemption- (FAR) §61.160(b)(3)(i) Jacksonville University January 28, 2013 Page 7



## DEC 202013 Mr. Jwm 

### Merkt Jacksonville University Davis Aviation 

### Center 2800Unh•crsity Blvd. North 

### Jacksonville, FL 32211 

### Dear Mr. Merk1: 000 11\dierlendence Am.• S.W Vle$.1lh;Jton. DC. 20591

The

### FAA bas compleced areview ofJacksonville University's FAA Form 8700-1 ''Institution ofHigher Education's Application forAuthority to Certify its Groduates for an Airline TransportPilot CertificatewithReduced Aeronautical Experience" dated September9, 2013. Thisreview allows the FAA to determine ifthe minimum regulatory requirements of part 

### 61 are met, and is 

### conducted in aooordance with guidance described inAdvisory Circular (AC) 

### 61-139. After 

### areview ofJacksonville University's FAA Fotm 

### 870Q-l appli«ltion for institutio11al authority, the FAA 

### has detennined thatthe 

### minimum 

### regulatory requirements are not met. 14 CFRparagraph 

### 61.160(cX3)(i) states: "The rl!([uiredgroundtraining was- OOmJ>letedasparlof anapprbl'ed part 141 curriculum 

### at tlze institutionof higher edJ.1cotfon

... '·' · 

### Jacksonville University does not

### hold apart 

### 141 pilot

### school e<:rtificatc with 

### an approved 

### training 

### course outline 

### for thecommercial pilot and instrumentrating 

### 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 institutionmay proceedwith one 

### ofthe follow

### actions: 1. 

### Jacksonville University may 

### apply for 

### apart 

### 141 pilot 

### school certificate for commercial pilot and instrumentrating ground training only. In**addition~** 

### aformal 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 apart 14I 

### pilo1 school certificate 

### for commercial pilotand instrumentrating ground and flight 

### training. 3. Filea petition for exemption from 

### the applicable regulation. Please 

### reference http://www.faa.gov/rc:gulations_policicslrulcmakinglpetitionl 

### for instructions on filing 

### apetition for exemption.Petition for Exemption

- (FAR) §61.160(b)(3)(i) Jacksonville University January 28, 2013 Page 8



### 2 Please .note that

### ifJacksonviUe UniYersity seeks to apply for a 14Ipi1ot school certificate that applications must be

### made through the 

### local 1:-Jight Standards District Office (FSDO). For rcferen.ce, a listofFSDO 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 oftheoptions listed above, an FAA fom1 8700-1 

### 8J)plication may be 

### resubmitted in the fonn and mannerprescribed in AC 

### 61-139. Please contact that General Aviation and Commercial Division 

### for any assistance in the future 

### onthis matterat (202) 385-9600. 

### Sincerely,

# ~~~-----**/~** P1'amesA. 

### Viola 

### Manager. General 

### Aviation and Commercial D.ivision, AFS-800