March 18, 2014 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Ave, SE 

West Building 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: 

- ·.:. r;T>:ENT Qi= ·~~:~PORTATION 

':. ·= l OPERATIONS 

~J. 111 ,, 'R '>b P ~ 'I I ~ l t ,_ I : 5 8 

My name is Lucas Parmer and I am a Flight Instructor at Auburn University with nearly 8 

years of experience 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, I request exemption from the 30 credit hour requirement 

of§ 61.160( c )(2) and the requirement that my pilot training be completed at a part 141 pilot school 

pursuant to§ 61.160(c)(3). 

A. Reasons for the requested exemptions 

Before the new requirements 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 of my ability as a pilot. In fact, I 

completed one semester at Auburn prior to enrolling and completing my certificates at A TP. 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 of my decision making process. If the 

current regulation would have been in place at that time, and Auburn University was still part 141 

my decision may have been different. Unfortunately, that is not the case. 

I am requesting exemption for several reasons. Auburn University recently received 

authorization to allow its students to receive a restricted airline transport pilot certificate with only 

1 ,250 hours. Although, I recently graduated from Auburn with a degree in Aviation Management, 

this degree does not include the 30 credit hours required by § 61.160( c). Since I earned my 

certificates outside of Auburn, 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. If the current 

1 
requirements had been in place at the time and Auburn University maintained its 141 certification, 

I would have done everything at Auburn University. 

As noted above, I currently teach at an approved 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 an AABI accredited university. 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 

certificate from an accredited 141 flight school accompanied by an aviation 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 of a pilot. Although I currently teach students who will be 

eligible for the reduction in flight hours upon graduation, without this exemption I will be required 

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 instructing operations out to A TP. Under this regulation, ASU graduates-who receive their 

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 

allow these students eligibility for the reduced minimum hour requirement while excluding pilots 

like myself who received their certificates from this same company. 

I also request an exemption because of the financial burden I face by having to reach the 

1,500 hour requirement. Under the new rule, it will take me at least another year to reach the 1,500 

hour mark. Financially, this will make it really hard for me,to manage. Being a flight instructor 

inhibits my ability to consistently pay my bills on time. Below is a list of reasons: 

• Student Load: My pay is predicated based on how many flight and ground hours I 

instruct. If my student load is low then I instruct less hours. 

• Weather: When the weather is not permitting, then flight instructing is postponed 

and I make no money. 

• Availability of Students: When the weather does not permit flying, then we have to 

reschedule flight lessons and that is based on the availability of the students. If the 

students have no more availability other than their normal flight blocks, I am unable 

to make up that event, therefore not making any money for that missed flight block. 

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 of hours proves to be the 

foundation of a 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 over quantity and believe that the more hours you have as an instructor does not necessarily 

mean you're a better pilot but could mean you're a more complacent one. I am not complacent and 

still hungry for success and believe that I deserve to serve the 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 of the 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, if not 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. If anything, the fact that I teach students who will become eligible to receive a restricted 

airline transport pilot certificate upon the completion of 1 ,250 flight hours, demonstrates that my 

knowledge and skill as a pilot are greater than that of the students I teach. During my 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 of my 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 FOR PUBLICATION 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. 

4 

L-------------
Academic Transcript 

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 of American 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 

2 of4 

https://ssbprod.aubum.edu/pls/PROD!bwskotrn.P _ ViewTran 

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 

2/18/2014 8:14AM 
Academic Transcript https:/ /ssbprod.aubum.edu/pls/PROD/bwskotrn.P _ ViewTran 

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) 

Current Term: 

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 

2118/2014 8:14AM 
Academic Transcript https:/ /ssbprod.aubum.edu/pls/PROD/bwskotrn.P _ ViewTran 

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 

Current Term: 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 

2118/2014 8:14AM