### March 18, 2014

Docket Management Facility US Department ofTransportation 1200NewJersey Ave, SE WestBuilding Ground Floor Room W12-140 Washington, D.C. 20590 RE: Petition for 14 C.F.R. § 61.160(c) exemption \


### To whom it may concern: 

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My name is Lucas Parmer and I am a Flight Instructor at Auburn University with nearly 8 years ofexperience as a pilot. I am writing to request an exemption from the requirements of 14 C.F.R. § 61.160(c) so as to be eligible for a restricted airline transport pilot certificate upon reaching 1,250 flight hours. Specifically, Irequestexemptionfrom the 30 credithourrequirement of§ 61.160(c)(2) and therequirementthatmy pilottrainingbe completed atapart 141 pilot school pursuant to§ 61.160(c)(3). 

### A. Reasons forthe requested exemptions Before the newrequirements of§ 61.160(c) were written into law, I chose to go to Airline Transport Professionals Incorporated ("ATP"), a highly acclaimed flight school, for financial reasons. Shortly thereafter, I received my commercial multi-engine, commercial single engine, CFI, CFII and MEl certificates from ATP. My decision to attend this flight school was based purely on my financial situation and was in no way a reflection ofmy ability as a pilot. In fact, I completed one semester at Auburn priorto enrolling and completing my certificates at ATP. Also during this period of time Auburn University was demoted to part 61 due to a few mishaps involving an incident that occurred. This was also a part ofmy decision making process. Ifthe currentregulation would have been in place at that time, and Auburn University was still part 141 my decision may havebeen different. Unfortunately, that is notthe case. I am requesting exemption for several reasons. Auburn University recently received authorizationto allowits students to receive a restricted airline transportpilotcertificate with only 1,250 hours. Although, Irecently graduated from Auburn with adegree inAviationManagement, this degree does not include the 30 credit hours required by § 61.160(c). Since I earned my certificates outside ofAuburn, I received only twenty-two credit hours in aviation and aviationrelated coursework. Had I received any pilot certificate at Auburn, I would currently have the required 30 .hours. However, due to the timing of this new rule and where I completed my certificates, I was unable to complete both the degree and certificates at Auburn. Ifthe current
1requirements hadbeeninplace at thetime andAuburn Universitymaintained its 141 certification, I would have done everything at Auburn University. Asnoted above, I currentlyteach at anapproved 141 school whose students are eligible for the reduced minimum hour requirements under § 61.160(c). I request exemption from the 1,500 hours due to my qualifications as a 141 flight instructor and a current recipient of an aviation degree from anAABI accrediteduniversity. I have been flying since 2006 and have been a flight instructor since 2011. The new regulations require that I attain my instrument and commercial certificatefrom an accredited 141 flight school accompaniedby anaviation degree. See 14 C.F.R. § 61.160(c)(3). However, the fact that I completed my degree and certificates at different institutions does not make me less ofa pilot. Although I currently teach students who will be eligible forthereduction in flight hours upongraduation, withoutthis exemptionI will berequired to reach 1,500 flight hours before I am compliant with § 61.160(c) despite having accumulated over 500 hours as an instructor and over 200 hours at a part 141 institution. Section 61.160(c) allows my students to attain their restricted airline transport pilot certificate with 250 fewer flight hours than I. Furthermore, Arizona State University, a part 141 approved institution, contracts its flight instructingoperations outtoATP. Underthisregulation, ASU graduates-whoreceivetheir flight training from the same flight training company that I did-become eligible for a restricted airline transport pilot certificate upon reaching 1,250 flight hours. It is fundamentally unfair to allowthese students eligibility for the reduced minimum hourrequirement while excluding pilots like myselfwho received their certificates from this same company. I also request an exemption because ofthe financial burden I face by having to reach the 1,500hourrequirement. Underthe newrule, it willtake me atleast anotheryearto reachthe 1,500 hour mark. Financially, this will make it really hard for me,to manage. Being a flight instructor inhibits my abilityto consistentlypaymybills ontime. Belowis a list ofreasons:

• Student Load: My pay is predicated based onhow many flight and ground hours I instruct. Ifmy student load is lowthen I instruct less hours. • Weather: When the weather is not permitting, then flight instructing is postponed and I make no money. • Availability ofStudents: Whenthe weather does notpermitflying, thenwe haveto reschedule flight lessons and that is based on the availability ofthe students. Ifthe studentshavenomore availabilityotherthantheirnormalflightblocks, I amunable tomake up thatevent, therefore notmaking anymoneyforthatmissed flightblock.


### B. Granting this exemption will benefit the public By granting this exemption, the public will be benefited in many ways. I will uphold professionalism and competency as a pilot in the airlines. My quality ofhours proves to be the foundation ofa great pilot. By allowing me to be eligible for the reduced minimums you will be adding a successful and hungry individual to a field that needs more people like that. I believe in 2

### quality overquantity and believethatthe morehours youhave as aninstructordoesnotnecessarily meanyou're abetterpilotbutcouldmeanyou're a more complacentone. I amnot complacent and still hungry for success and believe that I deserve to servethe public as an airline pilot. C. Granting this exemption will provide a level of safety greater than that provided by 14 C.F.R. § 61.160 

### By granting this exemption, the safety goals ofthe new regulations will in no way be adversely affected. To the contrary, my experience as a pilot and an instructor ensure that in my case an exemption will provide a level of safety at least equal to that provided for under 

### § 61.160(c). In fact, the**fl~ght** 

### community will be gaining a pilot with more training and flight experience than many, ifnot all, other pilots becoming eligible for the 1,250 hour minimum. For example, to be eligible under the 1,250 hour minimum a pilot must only have their instrument rating and a commercial rating. In addition to those required ratings, I have attained both single and multi-engine commercial ratings, a certified flight instructor rating, certified flight instructor instrument rating, and multi-engine instructor rating. Further, I have over 550 hours as a flight instructor. Ifanything, the fact that Iteach students who will becomeeligibleto receive arestricted airline transport pilot certificate upon the completion of 1,250 flight hours, demonstrates that my knowledge and skill as apilot are greaterthanthat ofthe students Iteach. Duringmy entire career as a pilot and instructor, I have never been involved in an incident or accident and have an impeccable safety record. D. Conclusion 

### I have enclosed a printed out copy ofmy academic transcript at Auburn, and the summary required under 14 C.P.R. § 

### 11.81(f). 

### I really hope that you consider my request and allow me to be eligible for the reduced minimUin flight hours. I have worked so hard to get to this point and respectfully request an exemption.

Enclosures 3 

### Respectfully,

# ~ ::so:9 -
LaGrange, GA 30240 lucas _parmer@yahoo.com 706-957-2374

### SUMMARY FORPUBLICATION IN THE FEDERAL REGISTER Petitioner: Philip Lucas Parmer Rule from which exemption is sought: 14 C.F.R. 

### § 61.160(c) Nature ofExemption Sought: Petitioner seeks exemption from the 30 credit hour requirement of§ 61.160(c)(2) and the requirement that pilot training be completed at a part 141 flight school. Petitioner requests exemption due to his position as a flight instructor at a part 141 flight school with over 500 flight hours as an instructor and an aviation degree from an FAA approved degree program.

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Curriculum Information
Program: College: Campus: Major: BSBA Aviation Management College of Business Auburn Main Campus Aviation Management

TRANSFER CREDIT ACCEPTED BY INSTITUTION
08/08-12/10: Southern Union State CC Subject Course Title Grade
ACCT 2110 Prin Of Financial Acct A ACCT 2210 Prin Of Managerial Acct A ACCT 2990 Business Law A COMP 1000 Personal Computer B Applications ECON 2020 Prin Of Microeconomics A ECON 2030 Prin Of Macroeconomics A ENGL 1100 English Composition I A ENGL 1120 English Composition II A ENGL 2250 Survey ofAmerican Lit B I GEEL 1000 General Elective-COMP B GEEL 1000 General Elective-OR! A HIST 1020 World History II A MATH 1000 College Algebra A MATH 1120 Pre-Calculus Algebra A MATH 1130 Pre-Calculus Trig A MATH 1680 Calculus Business Apps A I MUSI 2730 Appreciation Of Music A PHIL 1020 Introduction To Ethics A PHYS 1500 General Physics I B PHYS 1501 General Physics I Lab B PSYC 2010 Intro To Psychology B STAT 2610 Stats For Business & A Economics -TopCredit Hours 3.000 3.000 3.000 2.000
3.000 3.000 3.000 3.000 3.000
1.000 1.000 3.000 3.000 3.000 3.000 3.000
3.000 3.000 4.000 0.000 3.000 3.000 Attempt Passed Earned GPA Hours Hours Hours Hours Current Term: 59.000 59.000 59.000 59.000
Unofficial Transcript
INSTITUTION CREDIT -TopTerm: Spring 2011 College: College of Business Major: Pre- Business

· Academic Standing: Good Standing

Subject Course Level Title
AVMG 1010 UG Introduction to Aviation MNGT 3100 UG Principles Of Management

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Quality Points R
12.00 12.00 12.00 6.00
12.00 12.00 12.00 12.00 9.00
3.00 4.00 12.00 12.00 12.00 12.00 12.00
12.00 12.00 12.00 0.00 9.00 12.00 Quality GPA Points

223.00 3.78

Grade**Cre~lit Quality~**  Hours Points A 2.000 8.00 B 3.000 9.00

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3 of4 SCMH SCMN 1010 3150 UG UG Concepts Of Science Ops: Mngt of Business Proces 

### c A 4.000 2.000 8.00 8.00 Term Totals (Undergraduate)

Current Term: Cumulative:
Unofficial Transcript

Term: Fail 21U2 College: Major: Attempt Passed Earned GPA Quality GPA Hours Hours Hours Hours Points 11.000 11.000 11.000 11.000 33.00 3.00 11.000 11.000 11.000 11.000

College of Business Pre-Business 33.00 3.00

Academic Standing: Good Standing Subject Course Level Title Grade Credit Quality

..**~** Hours Points AVMG FINC HRMN 3050 3610 3420 UG UG UG Weather Disruptions Principles Of Business Finance Human Resource Management A 3.000 12.00 XF 

### c 3.000 3.000 0.00 6.00 Term Totals (Undergraduate)

CurrentTerm: Cumulative:
Unofficial Transcript

Term: Spring 2013 College: Major: Academic Standing: Attempt Passed Earned GPA Quality GPA Hours Hours Hours Hours Points 9.000 6.000 6.000 6.000 18.00 20.000 17.000 17.000 17.000 51.00

College of Business Pre- Business Good Standing 3.00 3.00

Subject Course Level Title Grade Credit**Quality~** Hours Points AVMG 4810 UG Professional Develop in Aviati A 1.000 4.00 AVMG 5180 UG Global Air Trans Mgt A 3.000 12.00 BUSI 1010 UG Contemp Issues In Bus Admin I B 1.000 3.00 ENGL 3080 UG Business Writing B 3.000 9.00 HIST 1010 UG World History I B 3.000 9.00 MKTG 3310 UG Principles Of Marketing 

### c 3.000 6.00 SCMN 3720 UG Trans: Mngt of Product Flows B 3.000 9.00 Term Totals (Undergraduate)

Current Term: Cumulative:
Unofficial Transcript

Term: Summer 2013 College: Attempt Passed Earned GPA Quality GPA Hours Hours Hours Hours Points 17.000 17.000 17.000 17.000 52.00 3.06 37.000 34.000 34.000 34.000 103.00 3.03

College of Business

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4 of4 Major: Pre-Business Academic Standing: Good Standing Subject Course Level Title Grade Credit Quality! Hours Points ENGL 2210 UG World Literature II B 3.000 9.00 FINC 3610 UG Principles Of Business Finance A 3.000 12.00 ISMN 3140 UG Intro to Mngt Information Syst 

### c 2.000 4.00 SCMN 3710 UG Logs: Mngt of Fulfillment Proc A 3.000 12.00 Term Totals (Undergraduate) Attempt Passed Earned GPA Quality GPA Current Term: Cumulative:
Unofficial Transcript

Term: Fall 2013 College: Major: Academic Standing: Last Academic Standing: Hours Hours Hours Hours Points 11.000 11.000 11.000 11.000 37.00 3.36 48.000 45.000 45.000 45.000 140.00 3.11

College of Business Aviation Management Good Standing Good Standing Subject Course Level Title Grade Credit Quality! Hours Points AVMG 3200 UG Applied Analysis in Trans A 3.000 12.00 AVMG 4060 UG Transportation Safety A 3.000 12.00 AVMG 4190 UG Air Space Mgt A 3.000 12.00 AVMG 5090 UG Aviation Law and Policy B 3.000 9.00 AVMG 5970 UG Spedal Topics Aviation Mngt A 1.000 4.00 MNGT 4800 UG Strategic Management B 3.000 9.00 NTRI 2000 UG Nutrition And Health B 3.000 9.00 Term Totals (Undergraduate) Attempt Passed Earned GPA Quality GPA Hours Hours Hours Hours Points CurrentTerm: 19.000 19.000 19.000 19.000 67.00 3.53 Cumulative: 67.000 64.000 64.000 64.000 207.00 3.23 Unofficial Transcript
TRANSCRIPT TOTALS (UNDERGRADUATE) -TopTotal Institution: Total Transfer:

' Unofficial Transcript

RELEASE: 8.4.1 Attempt Passed Hours Hours 67.000 64.000 59.000 59.000 Earned GPA Quality GPA Hours Hours Points

64.000 64.000 207.00 59.000 59.000 223.00 3.23 3.78

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