1 

### A**VIATION** 

### P **ROGRAM**

122	Sill	Hall Ypsilanti,	MI	48197 Phone:	734

- 487

- 1161					Fax:	734

- 487

- 7690 Eastern Michigan University Exemption Request for Regulatory Relief ( 11/20 /2013 ) Petition for e xemption requested b y: Philip M. Tartalone, Ph.D. Associate Professor, Aviation Flight Technology Eastern Michigan University School of Technology

Studies, 122 Sill Hall Ypsilanti, Michigan 48197 ptartalone@emich.edu 734.487.1162 ext 275 Fax: 734.487.7690 Eastern Michigan University (EMU) is petitioning for an exemption from the fol lowing sections of **Title 14 of the Code of Federal Regulations (CFR): 61.160(b**  **) (3**  **) (i)** 

– The required ground training was completed as part of an approved part 141 curriculum at the institution of higher education; and **61.160(b)(3)(ii)**

– The required flight training was completed as part of an approved part 141 curriculum at the institution of higher education or at a part 141 pilot school that has a training agreement under 141.26 of this chapter with the institution of higher educatio n. **Ad ditional Requests**  **11.63(d) and**  **11.85**

– Due to the costs associated, disruption of training activities, and university course scheduling, EMU requests a waiver under the good cause exception of the 120 day

requirement as stated in 14 CFR 11.63(d) and a waiver for the Federal Register publication requirement as stated in 14 CFR 11.85. The requested exemptions would apply to the students who received a Bachelor of Science Degree prior to our p rogram’s flight curriculum receiving FAA approval under Part 141. Additionally , we request the exemption to apply to those students who continued their flight instruction through December 2013 under Part 61. Eastern Michigan University is accredited by the North Central Association of Colleges and Schools and holds 42 professional association affiliations. Eastern Michigan University also holds FAA authorization to conduct an Aircraft Dispatch Course in accordance with 14 CFR, 65 Subpart A & C, Section 65.61 and Part 65 Appendix A (see attachment E). This petition discusses the following:

 Reasons for the exemption from 14 CFR 61.160(b)( 3 )(i) and (ii)
 The positive effects of this exemption on certain Aviation Flight Technology graduates
 M eeting of FAA standards for Part 121 first officer candidates prior to August 1, 2013
 Assurance of public safety2

The time period between August 2008 and December 201 3 the Eagle Flight Centre had a cadre of students who graduate d and will graduate from our P art 61 program and we anticipate that all will be affected b y this exemption. The FAA Part 121 first officer standards prior to August 1, 2013 were a Commercial certificate with an Instrument rating. Two of our EMU graduates, meeting these standards, were given conditional offers of employ ment as first officers with a 121 Air Carrier . Their offers had to be rescinded after the August 1, 2013 regulation change due to lack of Airline Transport Pilot ratings. These two prospective first officer candidates (who have less than 1,500 flight hours) will benefit substantially

from this exemption. All EMU flight students exceed the minimum requirements for the Commercial rating as they are required to complete additional training and receive their Multi

- engine Certificate and their Certificated Flight Instructor’s rating as part of the curriculum to receive their Bachelor of Science Degree. In June of 2010 the Eagle Flight Centre (EFC) received its Part 141 approval for Commercial and Instrument ratings. EMU, in concert with the Eagle Flight Centre, has continued to administer both the Part 141 and Part 61 training , concurrently , since June 2010. Beginning in January of 2014, all Instrument and Commercial training for EMU’s Aviation Flight Technology students will be conducted under Part 141 training only

. A review of our Part 61 Syllabus for Instrument and Commercial training (see attachments A & C) reflects that the Part 61 program is as structured and demanding as their counterparts in the Eagle Flight Centre’s FAA approved Part 141 training (see attachments B & D) . Additionally , the Part 61 students were taught b y the same instructors and administered by the same supervisors as the Part 141 students. The quality of training is the same. The public benefit gained with this exemption will allow a cadre of additional qualified candidate ’ s earl y entry

into the job market for Airline First Officer pos itions that might go unfilled due to the prediction of a future pilot shortage. As stated previousl y, the quality of flight and ground training in EMU/EFC’s program is the same in both Part 61 and Part 141. The assurance of public safety is of the highest level due to the structure , training demands, and supervisory oversight of all of our programs.3

**Summary for the Federal Register**  **:** Eastern Michigan University (EMU) is seeking an exemption from the regulatory requirements of 14 CFR 61.160(b)( 3 )(i) and (ii) , which would enable graduates of EMU’s Aviation Flight Technology

program, who completed flight training under Part 61, to qualify for the 1,000 hours restricted ATP certificate. This exemption would apply to those graduates from August 2008 through Dece mber 2013. EMU’s Aviation Flight Technology students complete the required ground and flight training under an agreement with the Eagle Flight Centre (EFC), a subsidiary of Suburban Aviation, Ottawa Lake, MI . Currently , EFC offers both Part 61 and Part 1 41 training. All required ground school courses are taught under Part 141. EMU will require all its flight students to complete Part 141 flight training commencing on January 1, 2014

. Inaddition, EMU is requesting exemptions to 14 CFR 11.63(d) and 14 CFR 11.85 . Approval will enable Eastern Michigan University aviation students to seamlessly continue training. Sincerel y,

Philip M. Tartalone, Ph.D. Associate Professor, Aviation Flight Technology Eastern Michigan University Attachments: Attachment A (Commercial Part 61 curriculum) Attachment B (Commercial Part 141 curriculum) Attachment C (Instrument Part 61 curriculum) Attachment D (Instrument Part 141 curriculum) Attachment E (Dispatcher Course Certificate) Attachment F (Application Letter)