U.S. Department 

of Transportation 

Federal Aviation 

Administration 

Advisory 

Circular 

Subject: Institution of Higher Education’s 

Application for Authority to Certify its 

Graduates for an Airline Transport 

Pilot Certificate with Reduced 

Aeronautical Experience 

Date: 7/12/13 

Initiated by: AFS-800 

AC No: 61-139 

Change: 

1. PURPOSE. This advisory circular (AC) provides instructions for institutions of higher 

education on how to obtain authority to certify students who graduate from the institution’s 

degree program with an aviation major and otherwise meet the requirements of Title 14 of the 

Code of Federal Regulations (14 CFR) part 61, § 61.160(b), (c), or (d). Graduates of an 

institution of higher education that has received Federal Aviation Administration (FAA) 

authorization to certify graduates may be eligible to apply for a restricted privileges airline 

transport pilot (ATP) certificate. The total flight time requirements for a restricted privileges 

ATP Certificate based on a degree with an aviation major are: 

• 1,000 hours for a graduate who holds a bachelor’s degree with an aviation major and 

meets the remaining requirements of § 61.160(b); 

• 1,250 hours for a graduate who holds an associate’s degree with an aviation major and 

meets the remaining requirements of § 61.160(c); and 

• 1,250 hours for a graduate who holds a bachelor’s degree with an aviation major and 

meets the remaining requirements of § 61.160(d). 

2. RELATED 14 CFR SECTIONS. Sections 61.1, 61.39, 61.55, 61.153, 61.155, 61.156, 

61.157, 61.159, 61.160, 61.165, 61.167, 61.169 and part 141, §§ 141.26 and 141.27. 

3. DEFINITIONS. 

a. Accredited. As defined by the Department of Education in Title 34 of the Code of 

Federal Regulations (34 CFR) part 600, § 600.2, the status of public recognition that a nationally 

recognized accrediting agency grants to an institution or educational program that meets the 

agency’s established requirements. 

b. Academic Areas. The aviation courses that should be satisfactorily completed at an 

institution of higher education for a student to meet the requirements of § 61.160. 

c. Aviation Coursework Mapping. This is the requirement on the application for an 

institution of higher education to list all of its aviation and aviation-related courses offered that 

will improve and enhance the knowledge and skills of a person seeking a career as a professional 

pilot. In addition, a description of each course, the number of semester credits, and identifying 
7/12/13 AC 61-139 

Par 3 Page 2 

which academic area, identified in paragraph 9 of this AC, the course addresses must also be 

included. 

d. Institution of Higher Education. As defined in 34 CFR part 600, § 600.4. An institution 

of higher education must be listed in the Database of Accredited Postsecondary Institutions and 

Programs. The list is administered by the U.S. Department of Education Office of Postsecondary 

Education and can be found at http://ope.ed.gov/accreditation/. 

e. Restricted Privileges ATP Certificate. An ATP Certificate that is subject to the 

limitations set forth in § 61.167(b). To be eligible a pilot must meet the requirements in 

§§ 61.153 and 61.160. 

f. Substantial Change. Any information on the letter of authorization (LOA) issued by the 

FAA to the institution of higher education that changes and therefore requires a revised LOA to 

be issued. This includes the removal, addition, or modification of a degree program with an 

aviation major, and changes to aviation and aviation-related coursework, that affects the LOA or 

the certifying statement that an institution of higher education places on a graduate’s transcript or 

other authorized document. A revised application must be submitted for a substantial change as 

described in paragraph 18 of this AC. 

g. Training Agreement. A statement signed by both an institution of higher education and 

a part 141 pilot school that describes the terms for which academic training and flight training 

will be provided to a student. 

h. Training Course Outline (TCO). An overview document that details the form, 

methodology, and content of a course of training. The document meets the requirements of 

part 141 subpart C and is submitted to the FAA for the issuance of a pilot school certificate or 

provisional pilot school certificate and ratings. 

4. PROGRAM REQUIREMENTS. Section 61.160 prescribes the minimum requirements that 

a student must complete as part of a degree program with an aviation major to be eligible for a 

restricted privileges ATP Certificate. The program must include flight and ground training for a 

commercial pilot certificate in the airplane category and an airplane instrument rating. To receive 

the authority from the FAA to certify eligible students, the institution of higher education must 

demonstrate its degree program(s) can satisfy the following: 

a. Bachelor’s Degree with an Aviation Major (§ 61.160(b)). 

(1) The institution of higher education must be accredited; and 

(2) Include at least 60 semester credit hours of aviation and aviation-related coursework 

that has been recognized by the Administrator as coursework designed to improve and enhance 

the knowledge and skills of a person seeking a career as a professional pilot and outlined in 

paragraph 9 of this AC; and 

(3) Hold either of the following: 
7/12/13 AC 61-139 

(a) A part 141 pilot school certificate with a TCO(s) approved for flight and ground 

training; or 

(b) A part 141 pilot school certificate with a TCO(s) approved for ground training 

only and have a formal training agreement with a part 141 pilot school with a TCO approved for 

flight training. 

b. Associate’s Degree with an Aviation Major (§ 61.160(c)). 

(1) The institution of higher education must be accredited; and 

(2) Include at least 30 semester credit hours of aviation and aviation-related coursework 

that has been recognized by the Administrator as coursework designed to improve and enhance 

the knowledge and skills of a person seeking a career as a professional pilot and outlined in 

paragraph 9 of this AC; and 

(3) Hold either of the following: 

(a) A part 141 pilot school certificate with a TCO(s) approved for flight and ground 

training; or 

(b) A part 141 pilot school certificate with a TCO(s) approved for ground training 

only and have a formal training agreement with a part 141 pilot school with a TCO approved for 

flight training. 

c. Bachelor’s Degree with an Aviation Major (§ 61.160(d)). 

(1) The institutions of higher education must be accredited; and 

(2) Include at least 30 semester credit hours of aviation and aviation-related coursework 

that has been recognized by the Administrator as coursework designed to improve and enhance 

the knowledge and skills of a person seeking a career as a professional pilot and outlined in 

paragraph 9 of this AC; and 

(3) Hold either of the following: 

(a) A part 141 pilot school certificate with a TCO(s) approved for flight and ground 

training; or 

(b) A part 141 pilot school certificate with a TCO(s) approved for ground training 

only and have a formal training agreement with a part 141 pilot school with a TCO approved for 

flight training. 

5. RELATED READING MATERIALS (current editions). 

a. AC 61-138, Airline Transport Pilot Certification Training Program. This AC 

provides the aeronautical knowledge that must be obtained by the applicant in order to meet the 

prerequisites for an ATP knowledge test that is taken after July 31, 2014. 

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7/12/13 AC 61-139 

NOTE: If the ATP knowledge test is satisfactorily completed prior to 

August 1, 2014, the ATP Certification Training Program (CTP) need not be 

completed, provided the practical test is successfully completed within 

24 calendar-months of completing the ATP knowledge test. 

b. AC 61-65, Certification: Pilots and Flight and Ground Instructors. Stakeholders can 

find additional information regarding original pilot certification and addition of category, class, 

and type ratings in AC 61-65. 

c. AC 61-89, Pilot Certificates: Aircraft Type Ratings. Guidance on advanced training 

criteria is available in AC 61-89. The FAA, commercial sources, and industry associations 

provide other media on pilot certification and eligibility. 

d. AC 141-1, Pilot School Certification. Institutions may need to apply for a part 141 pilot 

school certificate. Guidance on the certification process for a pilot school is contained in 

AC 141-1. 

e. Airman Knowledge Test Guides. Institutions may choose to incorporate elements of the 

airman knowledge test guides into a degree program with an aviation major. The information 

contained in the guides is critical for an applicant to have a thorough understanding of the 

concepts and tasks that are associated with the minimum aeronautical knowledge for a certificate 

or rating. 

f. Practical Test Standards (PTS). Institutions may choose to incorporate elements of the 

PTS into the coursework of a degree program with an aviation major. The applicant should have 

a thorough understanding of the concepts and tasks outlined in the PTS that are associated with 

the minimum knowledge and skill level for a certificate or rating. 

6. BACKGROUND. 

a. Public Law (PL). The Airline Safety and Federal Aviation Administration Extension Act 

of 2010 (PL 111-216) mandated that all pilots in 14 CFR part 121 operations hold an 

ATP Certificate by August 2, 2013. PL 111-216 also required the FAA revise the 

ATP Certificate requirements and included a provision that permitted the Administrator to allow 

specific academic training courses to be credited towards the minimum aeronautical experience 

requirements for an ATP Certificate. 

b. FAA Regulations. As a result of the PL, the FAA created § 61.160, Aeronautical 

Experience – Airplane Category Restricted Privileges, which enables a pilot, in certain 

situations, to obtain an ATP Certificate with reduced total time as a pilot based on academic 

experience. Specific paragraphs in § 61.160 enable a graduate of a degree program with an 

aviation major to be eligible for a restricted privileges ATP Certificate, provided they receive a 

certifying statement from the institution of higher education. Section 61.169 provides the 

requirements for the institution of higher education to obtain the authority from the FAA to issue 

a certifying statement to its graduates. Without a certifying statement from the institution of 

higher education, a student may not apply for a restricted privileges ATP Certificate under the 

total time as a pilot requirements of § 61.160(b), (c), or (d). 

Par 5 Page 4 
7/12/13 AC 61-139 

7. GENERAL PROCESS FOR AN INSTITUTION OF HIGHER EDUCATION 

SEEKING AUTHORIZATION. 

a. Requirements. In accordance with § 61.160, an institution of higher education must 

hold: 

(1) A part 141 pilot school certificate with a TCO(s) approved for ground and flight 

training; or 

(2) A part 141 pilot school certificate with a TCO(s) approved for ground only and have 

a formal training agreement in accordance with § 141.26(b) with a part 141 pilot school that 

provides the flight training for the institution of higher education. 

b. Submit Application. Any institution of higher education that chooses to obtain authority 

to certify its students for an ATP Certificate under the requirements in § 61.160 must submit an 

application to the FAA demonstrating that its degree program(s) has met all of the program 

requirements listed in § 61.160 and paragraph 4 above, as applicable. The aviation coursework 

mapping section of the application must be fully documented and retained by the institution of 

higher education and the FAA. 

c. LOA Issued. The FAA will issue an LOA based on a determination that the information 

supplied in the application meets the regulatory requirements of § 61.160. The institution of 

higher education must receive an LOA from the FAA which grants authority to give its graduates 

a certifying statement. The institution of higher education must determine that the graduate has 

met the applicable requirements of § 61.160 before the certifying statement can be placed on the 

transcript or other document authorized by the FAA. 

d. Continued Compliance. In an effort to ensure that an institution of higher education 

maintains the level of competency for which they were initially authorized, the FAA will 

revalidate the LOA on a regular basis, and may conduct ad hoc evaluations as needed, as 

described in paragraph 18 below. In addition, in accordance with § 61.169(c), the FAA may 

rescind or amend an LOA if the institution of higher education is not complying with or is unable 

to comply with the provisions of the LOA. This includes any substantial changes made by the 

institution of higher education to the academic program or changes that affect the LOA that 

requires notification to the FAA. 

e. Electronic Format. To the extent possible, institutions of higher education should use an 

electronic format for submissions and correspondence. 

8. INSTITUTION OF HIGHER EDUCATION REQUIREMENTS. In accordance with 

§ 61.169, an institution of higher education must be accredited, as defined in § 61.1, by a 

nationally recognized accrediting agency. Accreditation ensures that education provided by 

institutions of higher education meets acceptable levels of quality. Accrediting agencies, which 

are private educational associations of regional or national scope, develop evaluation criteria and 

conduct peer evaluations to assess whether or not those criteria are met. According to the 

Council of Higher Education Accreditation (CHEA), accredited status is a signal to students and 

the public that an institution meets at least threshold standards for its faculty, curriculum, student 

services, and libraries.

Par 7 Page 5 
7/12/13 AC 61-139 

9. ACADEMIC AREAS. A graduate from a degree program with an aviation major who meets 

the requirements of § 61.160(b), (c), or (d) is eligible to apply for a restricted privileges 

ATP Certificate. Section 61.160(b), (c), or (d) requires that a graduate complete a specific 

number of credit hours in aviation coursework that has been recognized by the FAA as 

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

career as a professional pilot.

a. Aviation and Aviation-Related Courses and Subject Areas. To assist institutions of 

higher education in determining whether a course meets the requirements, the FAA has identified 

several aviation and aviation-related courses and subject areas that are essential to prepare a 

student for a career as a professional pilot. The institution of higher education should offer, at a 

minimum, coursework in the academic areas listed in this section. The institution of higher 

education will then be responsible for certifying that a graduate has successfully completed the 

coursework and he or she meets the requirements of the appropriate paragraph of § 61.160. The 

following list includes key academic subject areas in aviation that a graduate should have 

completed as part of their degree program with an aviation major: 

(1) Ground and Flight Training for Certificates and Ratings. 

(a) Courses listed within this academic area should be designed to develop the 

knowledge and skills necessary to safely and proficiently exercise the privileges and 

responsibilities of an FAA certificate and/or rating. 

(b) General areas that should be discussed in ground and flight training include the 

aeronautical knowledge areas identified for the specific certificate or rating sought. Those areas 

may include, but are not limited to, the following: 

• Instructor-led discussions concerning aeronautical decision-making (ADM), 

crew resource management (CRM), aerodynamics, airworthiness, aeromedical 

factors, night and high altitude operations, weather hazards and reports, 

airport operations, flight planning, weight and balance (W&B), aircraft 

performance and limitations, aircraft systems and abnormal/emergency 

procedures. Additionally, the courses should include scenario based training 

to simulate more closely the actual flight conditions known to cause most fatal 

General Aviation (GA) accidents. 

• An introduction and overview to the 14 CFR sections governing the 

applicable parts and subparts to the certificate or rating being instructed. 

(c) General topics that can be considered under this academic area should result in 

the student being administered an FAA knowledge test or practical test for a certificate or rating. 

NOTE: To be eligible for a restricted privileges ATP Certificate under 

§ 61.160(b), (c), or (d), a student is required to complete the ground and 

flight training for a commercial pilot certificate (airplane category) and 

airplane instrument rating as part of an aviation degree program in 

accordance with § 61.160(b)(3) or (c)(3). 

Par 9 Page 6 
7/12/13 AC 61-139 

(2) Aerodynamics and Aircraft Performance. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand the principles of airplane aerodynamics and aircraft performance. 

(b) General courses such as physics may satisfy this academic area requirement 

provided the course description clearly indicates that aerodynamics and/or aircraft performance 

are the primary focus of the course. 

(c) General areas that should be discussed for aerodynamics and aircraft performance 

include but are not limited to the following: 

• Aerodynamics and terminology with emphasis on lift, weight, thrust, and drag 

forces acting upon an airplane in flight; calculation of stall speed; W&B; 

stability and control; operating data; low speed aerodynamics, fundamentals 

associated with transonic and supersonic flight. 

• Aircraft performance requirements; performance of aircraft powered by 

reciprocating, turboprop, or jet turbine engines; special flight conditions often 

experienced by commercial pilots of fixed-wing aircraft; configuration 

changes. 

(3) Aircraft Systems. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and explain basic and advanced aircraft systems. 

(b) Courses may include aircraft systems associated with aircraft that are powered by 

reciprocating, turbine, or jet engines. 

(c) General areas that should be discussed for aircraft systems may include but are 

not limited to the following: 

• Engines. 

• Systems such as propeller, electrical, environmental, hydraulic, pneumatic, 

fuel, ignition, lubrication, and pressurization systems, hydraulic systems, 

air conditioning and heating systems, oxygen systems, landing gear systems, 

brake systems, ice and rain detection/protection systems, fire 

detection/extinguishing systems, fuel systems, and flight controls. 

(4) Aviation Human Factors. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and identify human performances that affect aviation. 

(b) General areas that should be discussed throughout an aviation human factors 

course may include but are not limited to the following: 

Par 9 Page 7 
7/12/13 AC 61-139 

• Decision-making, situational awareness, crew coordination, communication, 

human error, fatigue, fitness, attitudes, training devices, controls, workload 

management. 

• CRM. 

• Man/machine interference that may include pilot/aircraft interference or 

flight deck/cockpit design. 

(5) Air Traffic Control (ATC) and Airspace. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and apply critical elements of ATC within the National Airspace System (NAS). 

(b) General areas that should be discussed throughout a course of the NAS may 

include but are not limited to the following: 

• A fundamental knowledge of the ATC system in the United States. 

• Navigational aids; airspace; communications; the Code of Federal Aviation 

Regulations; ATC procedures; control tower operations; nonradar operations; 

radar operations; and differing types of environmental concerns within a 

geographic area. 

(6) Aviation Law and Regulations. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and apply 14 CFR. 

(b) General areas that should be discussed throughout a course in aviation law and 

regulations may include but are not limited to: constitutional law, administrative law, 

enforcement actions, and international law affecting aviation. Additionally, courses may include 

the consideration and analysis of aviation regulatory environments and processes, such as 

regulatory certifications, rulemaking, and legislation. 

(7) Aviation Weather. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and apply weather as it relates to operation of an aircraft. 

(b) General areas that should be discussed throughout a course of aviation weather 

may include but are not limited to a study of weather, concepts of weather, weather hazards, 

meteorological flight planning, aviation weather equipment, and consideration of weather 

conditions as they relate to aircraft and flight performance. 

(8) Aviation Safety. 

(a) Courses listed within this academic area should be designed for a pilot to 

understand and identify safety issues affecting the operation of flight. 

Par 9 Page 8 
7/12/13 AC 61-139 

(b) General areas that should be discussed throughout a course in aviation safety may 

include but are not limited to a review of incidents, accidents, safety studies, and accident 

investigations with a focus on causal and contributing factors to those investigated events and 

any resulting changes to mitigate future risk. It may also include lectures on CRM, aviation 

safety programs, and risk management. 

(c) The focus of the course could be aviation safety within an airline, flight school, 

airport, aircraft, and ATC system. 

b. Validating a Graduate’s Academic Coursework. The institution of higher education 

must validate that a student has completed the requisite amount of aviation semester credit hours 

prescribed in § 61.160 in courses that were recognized by the FAA, as part of the aviation 

coursework mapping process, as coursework designed to enhance and improve the knowledge 

and skills of a person seeking a career as a professional pilot. If the institution of higher 

education determines that all of the requirements have been met, it should provide the certifying 

statement through an official transcript or other authorized means to the graduate of the degree 

program with an aviation major or the FAA. 

10. INTEGRATED FLIGHT TRAINING. Section 61.160 requires a student to complete 

commercial and instrument ground training from an approved part 141 curriculum at the 

institution of higher education. It also requires the student to complete commercial and 

instrument flight training 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 with the 

institution of higher education. The purpose of this requirement is to have comprehensive flight 

training curricula integrated with a student’s ground training as part of an FAA-approved 

part 141 program. It also ensures the ground and flight training are integrated into the student’s 

broader academic education as part of a degree program with an aviation major. 

a. Information Provided by an Institution of Higher Education. As part of the 

application, an institution of higher education should provide the following information in 

accordance with § 61.160: 

(1) A part 141 pilot school certificate with a TCO(s) approved for ground and 

flight training; or 

(2) A part 141 pilot school certificate with a TCO(s) approved for ground only and have 

a formal training agreement in accordance with § 141.26(b) with a part 141 pilot school that 

provides the flight training for the commercial pilot certificate and instrument rating on behalf of 

the institution of higher education. 

NOTE: If the institution of higher education uses a separate part 141 

pilot school to provide the flight training for students enrolled in their degree 

program, the formal training agreement must be in place and submitted to 

the FAA at the time of application. 

b. Integrated Ground and Flight Training. The ground and flight training will be 

considered integrated with the broader academic curriculum if: 

Par 9 Page 9 
7/12/13 AC 61-139 

(1) The institution of higher education provides ground training on the appropriate 

aeronautical knowledge areas, according to their approved TCO at the part 141 pilot school. 

(2) The institution of higher education provides training on the aeronautical knowledge 

areas utilizing instructors employed by the institution of higher education. 

(3) The flight instructors providing the flight training required by § 61.160 will be 

employed by the institution of higher education or the part 141 pilot school associated with the 

institution of higher education that is conducting the flight training. 

(4) The flight training should be conducted concurrently with the aeronautical knowledge 

training. The flight training for the commercial pilot certificate and instrument rating should be 

taken concurrently with the associated ground training—academic credit should be obtained 

within the same semester. For example, an institution of higher education should ensure that a 

student enrolled in flight training for a commercial pilot certificate is also enrolled in the 

institution of higher education’s commercial pilot ground school during the same semester. 

(a) The institution of higher education should ensure the course description in the 

application specifically states it is the commercial pilot ground school or instrument rating 

ground school and how the associated flight training is linked. The FAA understands that not all 

programs organize their ground and flight training courses the same way. The FAA recognizes 

some schools require students to register for a ground school course and a separate flight lab for 

credit while others incorporate it all into one course. In some cases the ground and flight training 

for a commercial pilot certificate are spread out over several courses. Be sure the application 

provides enough detail for the FAA to understand how the ground and flight training meet the 

requirements of § 61.160. 

(b) The FAA recognizes that unforeseen circumstances may prevent a student from 

completing the flight training in the same semester as the ground school. For example, weather, 

maintenance, or another situation that is out of the control of the student and the institution of 

higher education, may cause the flight training to extend into the next semester, which may 

overlap the academic portion of another certificate or rating. While it is expected that an 

institution of higher education will make every effort to adhere to the proposed program, a 

student should not be considered ineligible for a restricted privileges ATP Certificate as a result 

of the circumstances described in this paragraph. 

11. GRADUATES OF A DEGREE PROGRAM WITH AN AVIATION MAJOR. 

a. Graduates with a Bachelor’s Degree with an Aviation Major.

(1) A graduate with a bachelor’s degree in an aviation major is eligible to make 

application for a restricted privileges ATP Certificate with a minimum of 1,000 hours total time 

as a pilot if the graduate has satisfied the requirements of § 61.160(b). The graduate must have 

obtained a commercial pilot certificate with an airplane category and instrument rating from a 

part 141 pilot school associated with an institution of higher education and completed at least 

60 semester credit hours including the academic areas outlined in paragraph 9 of this AC. An 

official transcript or other document acceptable to the Administrator from the institution of 

higher education certifying the graduate has met the requirements in § 61.160(b) is also required. 

Par 10 Page 10 
7/12/13 AC 61-139 

(2) A graduate with a bachelor’s degree in an aviation major is eligible to make 

application for a restricted privileges ATP Certificate with a minimum of 1,250 hours total time 

as a pilot if the graduate has satisfied the requirements of § 61.160(d). The graduate must have 

obtained a commercial pilot certificate with an airplane category and instrument rating from a 

part 141 pilot school associated with an institution of higher education and completed at least 

30 semester credit hours including the academic areas outlined in paragraph 9 of this AC. An 

official transcript or other document acceptable to the Administrator from the institution of 

higher education certifying the graduate has met the requirements in § 61.160(d) is also required. 

(3) Once a student has completed the aviation coursework and the associated flight 

training and graduated with a degree in an aviation major from an institution of higher education 

with the authority to certify its students under § 61.169, the graduate will have gained the 

knowledge on the subject areas the FAA has determined justifies a reduction in aeronautical 

experience for a restricted privileges ATP Certificate. The minimum aeronautical experience for 

a restricted privileges ATP Certificate for a graduate of a bachelor’s degree program at an 

institution of higher education is described in § 61.160(e). 

b. Graduates with an Associate’s Degree with an Aviation Major. 

(1) A graduate with an associate’s degree in an aviation major is eligible to make 

application for a restricted privileges ATP Certificate with a minimum of 1,250 hours total time 

as a pilot if the graduate has satisfied the requirements of § 61.160(c). The graduate will need to 

obtain a commercial pilot certificate with an airplane category and instrument rating from a 

part 141 pilot school associated with an institution of higher education and completed at least 

30 semester credit hours including the academic areas outlined in paragraph 9 of this AC. An 

official transcript or other document acceptable to the Administrator from the institution of 

higher education certifying the graduate has met the requirements in § 61.160(c) is also required.

(2) Once a student has completed the aviation coursework and the associated flight 

training and graduated with a degree in an aviation major from an institution of higher education 

with the authority to certify its students under § 61.169, the graduate will have gained the 

knowledge on the subject areas the FAA has determined justifies a reduction in aeronautical 

experience for a restricted privileges ATP Certificate. 

(3) The minimum aeronautical experience for a restricted privileges ATP Certificate for a 

graduate of an associate’s degree program at an institution of higher education is described in 

§ 61.160(e). 

12. TRANSFERING STUDENTS. 

a. Alternative Paths. The FAA acknowledges students follow a number of different paths 

for completing post-secondary education at a college or university. Some students start at 

community colleges and transfer to 4-year degree programs while other students transfer 

between different 4-year institutions of higher education. The FAA does not want to deter 

individuals from seeking alternative paths to achieving a degree with an aviation major and 

therefore has determined that students who transfer into a 2-year or 4-year degree program with 

an aviation major could be eligible for a restricted privileges ATP Certificate. These graduates 

Par 11 Page 11 
7/12/13 AC 61-139 

would be eligible for a restricted privileges ATP Certificate provided they complete the 

applicable requirements of § 61.160, including the semester credit hours and specified ground 

and flight training. 

b. Transferring Between Authorized Institutions of Higher Education.

(1) In some cases, a student may transfer from one institution of higher education that has 

authorization to certify its graduates per § 61.169 to another institution of higher education that is 

also authorized to certify its graduates per § 61.169. If the receiving institution of higher 

education grants the student credit for coursework completed at the prior institution of higher 

education and can determine that the coursework has been recognized by the FAA as meeting the 

requirements in § 61.160, the institution may certify the student for a restricted privileges 

ATP Certificate so long as the student has completed the remaining requirements. 

(2) If applicable, the student must verify that the institution of higher education initially 

attended has documented all of the academic coursework that may be transferred. That institution 

of higher education will provide official documentation (e.g., official transcript or other 

authorized means), indicating it has the authority to certify students from the FAA and that the 

coursework was successfully completed by the student. The institution of higher education that 

ultimately provides the degree to the student must certify that the coursework accepted through 

the transfer as well as the additional aviation coursework completed as part of its degree program 

meets the appropriate requirements of § 61.160. The certifying statement must be on an official 

transcript or other approved document and presented at the time of application for a restricted 

privileges ATP Certificate by the graduate. 

13. APPLICATION INSTRUCTIONS. In its application, an institution of higher education 

must provide sufficient information to demonstrate that its students can graduate having satisfied 

the requirements of § 61.160. The FAA will assess the institution of higher education to ensure it 

offers as part of its degree program(s), aviation and aviation-related coursework designed to 

improve and enhance the knowledge and skills of a person seeking a career as a professional 

pilot. The application addresses the following areas regarding the institution of higher education.

a. Application Type. 

(1) Initial. Utilized if an application for the authority to certify graduates for a restricted 

privileges ATP Certificate has never been submitted to the FAA by the institution of higher 

education. 

(2) Revision. Utilized if an institution of higher education has the authority to certify its 

graduates and is making a substantial change as described in subparagraph 3f and further 

described in subparagraph 18c. 

(a) If the institution of higher education chooses to remove, revise, or add a degree 

program or aviation major, to include changes in aviation and aviation-related coursework, a new 

aviation coursework mapping section must be completed within the application. 

(b) If the data contained within the LOA that was issued by the FAA has changed and 

there are no changes to the aviation and aviation-related coursework, you may indicate 

Par 12 Page 12 
7/12/13 AC 61-139 

“no change” on the application in the coursework mapping section; however the date of the last 

application must be noted. 

(3) Reinstatement. Utilized if an institution of higher education previously held the 

authority to certify its graduates for the purpose of that graduate obtaining a restricted privileges 

ATP Certificate and is seeking reinstatement of the same degree program with an aviation major. 

b. Date of Application. The date the application is submitted.

c. Institution of Higher Education Information. The name of the institution of higher 

education, phone number, and physical address should be provided. 

d. Point of Contact (POC). The primary POC and their email address should be provided. 

e. Degree Program(s). 

(1) The institution of higher education should indicate the type of degree(s) offered 

(e.g., bachelor’s degree and/or associate’s degree). 

(2) An institution of higher education should list the specific degree program with an 

aviation major a graduate will have displayed on their transcript or other approved document 

(e.g., Bachelor of Science with a major in commercial aviation). 

f. Part 141 Pilot School Name, Certificate Number, and Location of Main Operation. 

(1) In accordance with § 61.160, an institution of higher education should hold: 

(a) A part 141 pilot school certificate with a TCO(s) approved for ground and flight 

training; or 

(b) A part 141 pilot school certificate with a TCO(s) approved for ground only and 

have a formal training agreement in accordance with § 141.26(b) with a part 141 pilot school that 

provides the flight training for the institution of higher education. 

(2) An institution of higher education must provide the part 141 pilot school information 

for both schools if it meets the requirements of subparagraph 13a(2) above. 

g. Accreditation. 

(1) Any institution of higher education that is seeking the authority to certify its 

graduates must be accredited by the U.S. Department of Education, as described in 34 CFR 

part 600, § 600.2. 

(2) The Department of Education maintains a database of accredited postsecondary 

institutions and programs electronically (see http://ope.ed.gov/accreditation/). The accreditation 

must be listed on the institutional evaluation and must comply with the Department of Education 

requirements. 

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7/12/13 AC 61-139 

h. Substantial Change to a Degree Program. 

(1) The institution of higher education must state in its initial or reinstatement application 

if the degree program has had a substantial change within the previous 5 years from the date of 

application. If an application for revision, the applicant must explain the substantial change 

driving the revision. 

(2) Based on the information provided on the initial or reinstatement application, the 

FAA will determine whether or not prior graduates of the degree program(s) listed on the 

application may also be eligible for a restricted ATP Certificate with a certifying statement 

should the institution receive authorization. 

i. Status of the Part 141 Pilot School Certificate(s) and Association. 

(1) The institution of higher education must indicate in its application if there has been a 

change in the status of the part 141 pilot school certificate(s) in the previous 5 years. If it has 

changed, the institution must explain when and why the interruption occurred. 

(2) The institution of higher education must indicate in its application if the part 141 pilot 

(flight) school association changed within the previous 5 years from the date of application. If it 

has changed, an explanation of when and why the interruption occurred is needed. 

j. Aviation Coursework Mapping. An applicant for a restricted privileges ATP Certificate 

under § 61.160(b), (c), or (d), is eligible based on the academic coursework that the applicant has 

completed. To determine how many credits a graduate completed in aviation and aviation-related 

coursework, the institution of higher education may reference only those courses designed to 

enhance and improve the knowledge and skills of a person seeking a career as a professional 

pilot recognized by the Administrator through this mapping process. 

(1) In order to ensure that the aviation coursework incorporates the academic areas listed 

in paragraph 9 of this AC, the institution of higher education should provide a description of the 

curriculum covered in the course. The following information is required as part of the aviation 

coursework mapping (see the example in Appendix 1, Sample Application): 

(a) Course number. 

(b) Course title. 

(c) Course catalog description (to be attached to the application as a separate 

document). 

1. A course catalog description should be validated by the institution of higher 

education to ensure that the academic areas covered are designed to improve and enhance the 

knowledge and skills of a person seeking a career as a professional pilot, as stated in § 61.160. 

An academic area should be the primary focus of a course for the majority of the semester. The 

FAA does not expect that the courses will be the exact title of the academic areas listed. 

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7/12/13 AC 61-139 

2. The FAA will rely upon the course description provided by the institution of 

higher education to determine the relationship of the course subject matter to the academic areas. 

An insufficient description of the course may result in the FAA asking for additional information 

and may cause a delay in processing the application. 

(d) Credit hours for each corresponding course. The FAA assumes semester credit 

hours unless otherwise stated. 

(e) Academic area identification. Referencing paragraph 9 of this AC, an institution 

of higher education should document (“map”) how the specific courses listed are designed to 

improve and enhance the knowledge and skills of a person seeking a career as a professional 

pilot. The institution of higher education may reference the specific subject area or the associated 

number listed below on the application: 

1. Pilot ground and flight training; 

2. Aerodynamics and aircraft performance; 

3. Aircraft systems; 

4. Aviation human factors; 

5. Air traffic control and airspace; 

6. Aviation law and regulations; 

7. Aviation weather; and 

8. Aviation safety. 

(2) The coursework mapping should clearly indicate which commercial pilot and 

instrument rating courses (Academic Area “1”), satisfy the requirements of § 61.160(b)(3) 

or (c)(3). 

(3) The academic areas may be within the aviation department, such as Aviation Law or 

Advanced Aircraft Systems. Courses outside the aviation department may also satisfy the 

academic area requirements. For example, a physics course may satisfy the academic area 

requirement for aircraft performance and aerodynamics provided the course description clearly 

indicates that this is the primary focus of the course. The institution should demonstrate that it 

offers courses that satisfy all of the academic areas. Because a student must complete 

30/60 semester credit hours to be eligible for a restricted privileges ATP Certificate, a student 

should complete coursework in each subject area by the time the student graduates. 

NOTE: In determining whether a course is designed to improve and 

enhance the knowledge and skills of a person seeking a career as a 

professional pilot, the institution should consider the objective and purpose 

of the course. For instance, an introductory course on ATC could be designed 

to provide a foundation for both pilots and for students intending to pursue a 

Par 13 Page 15 
7/12/13 AC 61-139 

career as an air traffic controller. On the other hand, an upper level or 

advanced ATC course is primarily intended to prepare a person to work as 

an air traffic controller with little additional benefit to a person seeking a 

career as a pilot. Although knowledge of tower operations is instructive, an 

upper level ATC course is not generally designed with the goal of improving 

and enhancing the knowledge and skills of a person seeking a career as a 

professional pilot. 

k. Signature of the POC. The signature of the POC to the FAA for the institution of higher 

education and the date signed. 

14. FAA AUTHORIZATION TO CERTIFY GRADUATES. 

a. Application Processing. The FAA will respond to the applicant within 120 days of the 

FAA receiving the completed application for processing.

b. LOA. Once an institution of higher education is issued its LOA, the FAA will list the 

institution of higher education on the following FAA Web site: 

www.faa.gov/go/InstitutionalAuthority. 

c. Web Site. The Web site will contain the following information: 

(1) The name of the institution of higher education; 

(2) Location of the institution of higher education; 

(3) The degree program(s) with aviation major listed on the LOA; 

(4) The accrediting agency; and 

(5) Date the LOA was issued. 

15. ON-SITE EVALUATION. The FAA may choose to validate the information that an 

institution of higher education has submitted to the FAA by conducting an on-site evaluation. An 

on-site evaluation may be held at any facility used by the institution of higher education and may 

encompass various aspects of the degree program(s) and the course syllabi.

16. LOA. Once an institution of higher education completes the application, provides the FAA 

with the documentation that is required, and the FAA has determined all of the requirements 

have been met, an LOA will be issued by the General Aviation and Commercial Division 

(AFS-800). This indicates the institution of higher education has the authority to certify its 

graduates of the degree programs listed in the LOA for a restricted privileges ATP Certificate. 

The LOA will include the following information:

• Name of institution of higher education; 

• Degree program(s) with the specific aviation major(s); 

• Name of the accrediting agency; 

• Name of the part 141 pilot school(s); 

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7/12/13 AC 61-139 

• Authorizing statement; and 

• Signature of FAA approving official. 

17. CERTIFYING STATEMENT. AFS-800 will issue the LOA by digitally signing it and 

sending it electronically to the institution of higher education. The LOA grants the institution of 

higher education authority to add a certifying statement to a graduate’s transcript or other 

document deemed acceptable by the Administrator. 

a. Indicate Eligibility. The certifying statement must denote whether the student is eligible 

to apply for a restricted privileges ATP Certificate based on the applicable criteria in 

§ 61.160(b), (c), or (d). A graduate will then be required to present the certifying document, 

along with all other documentation required in § 61.39, when applying for the practical test for a 

restricted privileges ATP Certificate. 

b. Sample Statement. The LOA will indicate the certifying statement that the institution of 

higher education has been authorized to issue. The following statement may be used: The [insert 

institution’s name] certifies that the recipient of this degree has successfully completed all of the 

aviation coursework requirements of § 61.160[(b), (c) or (d)] and therefore meets the academic 

eligibility requirements of § 61.160[(b), (c) or (d)]. 

c. Available List of Institutions of Higher Education. Once AFS-800 has issued the LOA 

to the institution of higher education, AFS-800 will update its Web site which contains the list of 

institutions of higher education that have received authorization to certify their students for 

restricted privilege ATP Certificates provided those students meet the applicable academic 

requirements of § 61.160. 

d. Presenting the Required Documentation. All applicants for a restricted privileges 

ATP Certificate will need to present an official transcript with a certifying statement or an 

official transcript with other authorized document containing a certifying statement to the FAA 

inspector or designee to validate that the applicant meets the applicable aeronautical experience 

requirements of § 61.160 for a restricted privileges ATP Certificate. If the certifying statement is 

not present on the graduates’ official transcript, a letter from the institution of higher education 

with the above statement and a copy of their official transcript will be accepted at the time of 

application for the restricted privileges ATP Certificate. 

18. CONTINUED COMPLIANCE. 

a. Revalidation. In order to ensure that the institution of higher education continues to 

comply with the LOA issued by the FAA, a revalidation will occur at the time of the institution’s 

part 141 pilot school renewal by an FAA assigned inspector to the school. 

(1) In accordance with § 141.27, a pilot school may have its certificate and ratings 

renewed for 24 calendar-months if the Administrator determines the school’s personnel, aircraft, 

facility and airport, approved training courses, training records, and recent training ability and 

quality meet the requirements in part 141. 

(2) The FAA will ensure that an institution of higher education’s LOA is being complied 

with at the time of the associated part 141 pilot school certificate renewal. 

Par 16 Page 17 
7/12/13 AC 61-139 

b. On-Site Inspections. The FAA may conduct periodic on-site inspections to ensure the 

institution of higher education continues to comply with the LOA. 

c. Revising an Existing Degree Program with an Aviation Major. If the institution of 

higher education revises any portion of a degree program, including coursework (or the data 

contained within the LOA that was issued by the FAA changes), the institution should notify 

AFS-800 prior to implementing the substantial change so a revised LOA can be issued to the 

institution of higher education. 

(1) An application marked “revision” should be submitted by the institution of higher 

education so the FAA can issue an updated LOA. See paragraphs 3 and 13 of this AC. If the 

FAA determines that the degree program meets the applicable requirements with the proposed 

changes, a new LOA will be issued to the institution of higher education. 

(2) If the FAA disapproves the changes requested by the institution of higher education, 

it will notify the institution via a formal letter (an electronic copy also will be sent to the email 

address listed on the application) and inform the institution of the reasons for disapproval. 

Guidance to assist the institution of higher education can be provided by AFS-800. 

19. REMOVAL OF AN AVIATION MAJOR AND SUSPENSION OF AN LOA. An 

aviation major may be removed by an institution of higher education. To remove the major, the 

institution of higher education should submit an application marked “revision.” An LOA may be 

suspended by the FAA. The institution of higher education may reapply for the aviation major to 

be reinstated with an application marked “reinstatement.” 

a. Institutional Initiated Degree Program or Aviation Major Removal. 

(1) An institution of higher education may remove a degree program or aviation major 

for a variety of reasons. An application marked “revision” should be submitted by the institution 

of higher education and an updated LOA should be issued by the FAA. See paragraphs 3 and 13 

of this AC. In addition, all stakeholders should be notified of the removal by the institution. 

(2) Documentation of the removal, an explanation of the removal, and/or proof of 

notification to former, current, and prospective students may be requested by AFS-800. 

b. FAA-Initiated LOA Suspension. 

(1) An institution of higher education may have its LOA suspended by the FAA if the 

institution’s program no longer meets either regulatory requirements or the conditions of the 

LOA. The reasons for noncompliance may include but are not limited to: 

(a) Requirements of the LOA are no longer met; 

(b) Loss of a part 141 certificate to the institution of higher education or the 

associated flight school (the institution of higher education may retain limited authority to 

continue to issue a certifying statement to graduates of the degree program that completed the 

required ground and flight training through the institution’s part 141 pilot school certificate prior 

to the institution losing the certificate; or 

Par 18 Page 18 
7/12/13 AC 61-139 

(c) The institution of higher education’s lack of documentation on the eligibility of 

graduates for a restricted privileges ATP Certificate (e.g., a certifying statement on the graduates 

official transcript or letter from the institution of higher education stating the applicant’s 

eligibility). 

(2) The institution of higher education may appeal the suspension of the LOA to 

AFS-800 within 30 days. The FAA will respond within 60 days by reissuing the LOA or by 

stating the reasons why the program still fails to meet the requirements. Guidance to assist the 

institution of higher education may be provided by AFS-800. 

(3) Students that are enrolled at the institution of higher education at the time of the LOA 

suspension may continue to be eligible for a restricted privileges ATP Certificate. Conditions of 

eligibility for a graduate will need to be determined by AFS-800. The institution of higher 

education would retain the requirement to validate a graduate meets the applicable requirements 

of § 61.160 under the conditions established. 

(4) The FAA will conduct assessments of the LOA suspension on a case-by-case basis. In 

the event that the FAA believes that the institution of higher education acted in a manner that 

jeopardized the student’s ability to meet the eligibility requirements of a restricted privileges 

ATP Certificate, the LOA may be suspended. The institution of higher education may appeal the 

suspension of the LOA as described in subparagraph 19b(2) above.

20. FAA CONTACT INFORMATION. 

a. Whom to Contact. All institutions of higher education who seek the authority to certify 

graduates for an ATP Certificate under § 61.160 should contact the General Aviation and 

Commercial Division (AFS-800) with all preliminary inquiries. 

b. To Apply. The institution of higher education should submit the following 

documentation to AFS-800: 

(1) Completed application (FAA Form 8700-1); 

(2) Additional pages, as necessary, to complete the documentation required by the 

“Aviation Coursework Mapping” section of the application; 

(3) If the required flight training is completed in accordance with § 61.160(b)(3) 

and (c)(3), as applicable, an institution of higher education must submit a formal training 

agreement as prescribed in § 141.26(b) with a part 141 pilot school that provides the flight 

training for the commercial pilot certificate and instrument rating on behalf of the institution of 

higher education. 

c. Contact Information. Institutions of higher education may submit inquiries or 

documentation to AFS-800 via any of the following methods: 

(1) Email address: InstitutionalAuthorityApp@faa.gov. 

(2) AFS-800 fax: 202-385-9597. 

Par 19 Page 19 
7/12/13 AC 61-139 

(3) U.S. Postal Service or other conventional physical document transfer service to: 

Federal Aviation Administration 

General Aviation and Commercial Division, AFS-800 

800 Independence Avenue, SW 

Washington, DC 20591 

/s/ for 

John M. Allen 

Director, Flight Standards Service

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7/12/13 AC 61-139 

Appendix 1 

APPENDIX 1. SAMPLE APPLICATION 

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7/12/13 AC 61-139 

Appendix 1 

Page 2