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AVIATION	PROGRAM

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 exemption requested by: 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 following 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 education.

Additional 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 program’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

 Meeting of FAA standards for Part 121 first officer candidates prior to August 1, 2013

 Assurance of public safety
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The time period between August 2008 and December 2013 the Eagle Flight Centre had a cadre 

of students who graduated and will graduate from our Part 61 program and we anticipate that all 

will be affected by 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 employment 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 by 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 early entry into the job market for Airline First Officer positions that might go 

unfilled due to the prediction of a future pilot shortage.

As stated previously, 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.
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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 December 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 141 

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. In addition, 

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.

Sincerely,

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)