AFS-14-224-E

July 18, 2014

 Exemption No. 10957A

 Regulatory Docket No. FAA-2013-0758

Mr. Tim Brady

Embry-Riddle Aeronautical University

600 S. Clyde Morris Blvd

Daytona Beach, FL 32114

Dear Mr. Brady:

This letter is to inform you that we have granted your petition to amend Exemption No. 

10957. It explains the basis for our decision, lists the revised conditions and limitations, and

describes its effect.

The Basis for Our Decision

By letter dated April 1, 2014, you petitioned the Federal Aviation Administration (FAA) on 

behalf of Embry-Riddle Aeronautical University (ERAU) located at Daytona Beach, FL for an 

amendment to Exemption No.10957. That exemption granted ERAU relief from § 

61.160(b)(3)(i) and (b)(3)(ii) of Title 14, Code of Federal Regulations (14 CFR) to allow 

certain students who completed their instrument rating and/or commercial pilot training under 

part 142 at ERAU to be eligible for the restricted privilege airline transport pilot (ATP) 

certificate in accordance with § 61.160(b) and (d). The grant of exemption limits relief to 

graduates of ERAU’s Aeronautical Science degree program. 

At the time of the initial request, the Bachelor of Science in Aeronautical Science was the 

only degree program contained in ERAU’s letter of authorization (LOA) that granted 

authority to certify graduates for an airline transport pilot (ATP) certificate with reduced 

aeronautical experience. Since this original petition for exemption, ERAU’s LOA has been 

revised to include the following degree programs:

 Bachelor of Science in Aeronautical Science

 Bachelor of Science in Aeronautics

 Bachelor of Science in Aerospace Studies
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 Bachelor of Science in Aviation Maintenance Science

 Bachelor of Science in Air Traffic Management

 Bachelor of Science in Applied Meteorology

The amendment you are requesting would allow graduates of any authorized degree program

currently listed in ERAU’s LOA, who have completed their instrument rating and/or

commercial pilot training under part 142 at ERAU, to be eligible for the restricted privilege 

ATP certificate in accordance with § 61.160 (b) and (d).

You indicate that the reason for this amendment is that the initial petition for exemption, 

submitted on August 22, 2013, only requested relief for students that had enrolled in ERAU’s 

Bachelor of Science in Aeronautical Science degree program.

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested amendment to the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to ERAU.

Our Decision

The FAA has determined that the justification for the amendment of Exemption No. 10957

remains valid with respect to this exemption and is in the public interest.

The FAA agrees that Exemption No. 10957 was limited to students who had initially enrolled 

in the Aeronautical Science degree program. Since the petition was filed, additional courses 

have been added to ERAU’s LOA. ERAU currently holds authority from the FAA to certify

graduates of the degree programs listed above to be eligible for an ATP certificate with 

reduced aeronautical experience. The FAA finds that the relief provided by Exemption 10957 

should extend to all of the degree programs currently listed on ERAU’s LOA.

As noted in Exemption No. 10957, ERAU may certify these graduates if they meet all of 

criteria contained within the LOA, to include completion of the training for the instrument 

rating and the commercial pilot certificate under part 141. The FAA finds that ERAU’s 

authorized aviation degree programs satisfy the requirements in § 61.160 and are consistent 

with Advisory Circular 61-139: Institution of Higher Education’s Application for Authority to 

Certify its Graduates for an Airline Transport Pilot Certificate with Reduced Aeronautical 

Experience. As such, ERAU provides courses, within those authorized aviation degree 

programs, designed to improve and enhance the knowledge and skills of a person seeking a 

career as a professional pilot. Given ERAU’s previous applications for authority to certify its 

graduates for an ATP certificate with reduced aeronautical experience and the FAA’s 

subsequent issuance of an LOA, the FAA finds that the training for a graduate of one of the 

programs listed in its LOA received under part 142 is substantively similar to the training an 

ERAU student would receive under part 141.
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The FAA has amended Condition/Limitation No. 2 to reflect the updated exemption number. 

In addition, Condition/Limitation No. 4 has been amended to include the degree programs 

listed in ERAU’s LOA. 

In this amendment, the FAA is also revising the original grant of exemption to include relief 

from the requirements of § 61.169(b). Section 61.169(b) states, in pertinent part, that an 

institution of higher education may not certify a graduate for an airline transport pilot 

certificate under the requirements of § 61.160 unless it determines that the graduate has 

satisfied the requirements of § 61.160.

Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113, 44701 and 44703,

which the FAA Administrator has delegated to me, I hereby grant ERAU’s petition for relief,

from 14 CFR §§ 61.160(b)(3)(i) and (ii) and 61.169(b) to the extent necessary to allow 

students who matriculated into one of the University’s degree program listed in ERAU’s letter 

of authorization before the state of the 2012 academic year, and who subsequently completed 

their instrument rating and/or commercial pilot certificate training under part 142 at ERAU to 

be eligible for the restricted privilege ATP certificate, subject to the following conditions and 

limitations.

Conditions and Limitations

1. ERAU must adhere to all the conditions and limitations listed within its letter of 

authorization (LOA) granting authorization for ERAU to certify its graduates for an 

airline transport pilot (ATP) certificate with reduced aeronautical experience. 

2. In exercising the relief provided in this exemption, ERAU must include the following 

certifying statement on the graduate’s transcript: 

“Embry-Riddle Aeronautical University certifies that, in conjunction with the relief 

provided in Exemption No. 10957A, the requirements of § 61.160[(b) or (d)] for an 

Airline Transport Pilot Certificate with Reduced Aeronautical Experience have been 

met.” 

3. ERAU must provide a copy of this exemption to each student for whom the relief is 

necessary and direct that student to provide a copy of the exemption along with the 

official transcript and certifying statement at the time of application for the practical test 

for the ATP certificate under § 61.160. 

4. ERAU can only exercise this exemption for its students who initially enrolled in the 

following Bachelor of Science degree programs between 2003 and 2011 and subsequently

completed the commercial pilot certificate and instrument rating ground and flight 

training under ERAU’s part 142 training center certificate:
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a. Aeronautical Science

b. Aeronautics

c. Aerospace Studies

d. Aviation Maintenance Science

e. Air Traffic Management

f. Applied Meteorology

5. The authority (in the LOA) to certify graduates who received training under ERAU’s part 

142 training center certificate terminates upon expiration of this exemption. 

The Effect of Our Decision

This exemption terminates on March 31, 2016, unless sooner superseded or rescinded.

Sincerely,

//s//

John Barbagallo

Acting Deputy Director, Flight Standards Services