From: Douglas.Lundgren@faa.gov [mailto:Douglas.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 Petition for Exemption FAA 

2014-0377

Dear Rex:

First let me apologize on behalf of the agency for how long it is taking 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 ChandlerGilbert has a close working relationship 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 instructors teach the UND provided content of 

the part 141 ground school courses.An issued raised by the CGCC petition is the FAA 

interpretation of the meaning 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 education...” 

The agency’s interpretation is that this means that the institution of higher education must hold at 

least a part 141 ground school certificate. We acknowledge CGCC’s position on this issue, and 

also acknowledge the importance placed upon the concept of CGCC aviation students being able 

to transfer to UND’s 4-year program. We also acknowledge the UND now has partnering 

arrangements with University of Minnesota-Crookston and Spokane Falls Community College in 

which UND provides part 141 ground and flight training in conjunction with the academic 

aviation education at those schools, and that UND accepts 100% transfer credits for those 

students moving on to the UND 4-year program. We also acknowledge that UND-Phoenix is a 

part 141 satellite pilot school of the UND-Grand Forks main pilot school. In responding to 

CGCC’s petition, we have been reviewing the intent and direction of the 61.160 rule and of 

Advisory Circular 61-139, Paragraph 12. Transferring Students. Currently, the policy is

that students pursuing an aviation major can only transfer from 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 considered “co-enrolled” 

in effect, as UND students?

2) If this is not the case at present, is it possible, even considering the possible constraints 

of accreditation bodies and state higher education regulations, 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 with 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.

Sincerely
Douglas J. Lundgren

Aviation Safety Inspector

Airman Certification and Training Branch 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: 240-422-7007