From: Douglas.Lundgren@faa.gov [ mailto:D ouglas.Lundgren@faa.gov ] Sent: Tuesday, July 28, 2015 8:44 AM To: Rex Ginder < ginder@aero.und.edu > Subject: Request for additional information for Chandler

- Gilbert P etition for Exemption FAA 2014

- 0377

Dear Rex:

First let me apologize on behalf of the agen cy for how long it is taki ng to respond to this exemption request. This case is still under review by the FAA and we are at a point where it would be useful to have some more information before proceeding. We are aware that Chandler

Gilbert has a close wor king relations hip with UND Aerospace, in that CGCC students receive ground and flight training in UND Part 141 curriculums and want to be able to transfer to the UND 4

- year degree program. CGCC academic in structors teach the UND provided content of the part 141 ground school courses. An issued raised by the CGCC petition is the FAA interpretatio n of the mea ning of 14CFR61.160 (b)(3)(i) “The required ground training was completed as part of an approved part 141 curriculum at the institution of higher educatio n...” The agency’s interpretat ion is that this means that the institution o f higher education must hold at least a part 141 ground school certificate. We acknowledge CGCC’s position on this issue, and also acknowl edge the importance placed upon the concept of CGCC aviation students being able to transfer t o UND’s 4

- year program. We also acknowledge the UND now has partnering arrangements with Un iversity of Minnesota

- Crookston and Spo kane Falls C ommunity College in which UND provides part 141 grou nd and flight training in conjunction with the academic aviation education at those sch ools, and that UND accepts 100% transfer credits for those students movin g on to the UND 4

- year program. We also acknowledge that UND

- Phoenix is a part 141 satellite pil o t school of the UND

- Grand Forks main pilot school. In responding to CGCC’s petition, we have been reviewing the int ent and direction of the 61.160 rule and of Advisory Circular 61

- 139, Paragraph 12. Transferring Students. Currently, the policy is that stu dents pursuing an aviation major can only transfer f rom one Letter of Authorization (LOA)

– holding institution to another.

To help us in our deliberation, we are requesting the following additional information: 1) In view of the close working relationship of UND with CGCC, could CGCC aviation students who are taking part 141 ground and flight training be conside red “co

- enrolled” in effect, as UND students? 2) If this is not the case at present, is it possible, even consider ing the possible constraints of a ccreditation bodies and state higher education regul ations, that CGCC and UND could have an agreement that stated that CGCC aviation students were co

- enrolled in UND? 3) Do you know if CGCC has pursued obtaining its own part 141 ground school certificate w ith the local (Scottsdale) FSDO?

Thanks in advance for your assistance. Any additional information that you will be posted in the docket for petition #2014

- 0377.

SincerelyDouglas J. Lundgren Aviation Safety Inspector Airman Certification and Training Bran ch AFS

- 810 Federal Aviation Administration HQ 800 Independence Avenue Washington, DC 20591 Douglas.lundgren@faa.gov Wash FSDO office: 703

- 230

- 7664 ext 274 (transfers to telework number) Telework: 240

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