Embry-Riddle Aeronautical University Exemption Request 

Petition for exemption requestor: Tim Brady 

600 S. Clyde Morris Blvd 

Daytona Beach, FL 32114

(386) 226-6457

bradyt@erau.edu

Embry-Riddle Aeronautical University is seeking an exemption from the following section of 

Title 14 of the Code of Federal Regulations (CFR): 

61.160(c)(1) – Holds an Associate’s degree with an aviation major from an institution of 

higher education, as defined in §61.1, that has been issued a letter of authorization by 

the Administrator under §61.169;

Rationale for the exemption request: 

Embry-Riddle Aeronautical University’s (ERAU) Master of Science in Aeronautics (MSA) 

Professional Pilot specialization is designed specifically to prepare an individual for a 

career as a commercial pilot. The Professional Pilot program is one of the only master’s 

degrees to integrate rigorous flight training with academic course work. 

It is the university’s intent to seek approval for MSA graduates who completed 

instrument and commercial flight training under ERAU’s Part 141 curricula to be eligible 

for the restricted privileges airline transport pilot (ATP) certificate in accordance with 

61.160(c). 

The university assumes that this is a reasonable request for the following reasons: 

1. Students in the Professional Pilot specialization of the MSA program who have 

completed their instrument and commercial ratings must go through the exact 

same training program (including ground labs and flight) as graduates of ERAU’s 

Aeronautical Science program, which has already been approved for the 

restricted privileges ATP. 

2. The coursework for the MSA Professional Pilot specialization consists of 36 

credits, and is geared specifically toward a career as a professional pilot. 

3. MSA Professional Pilot students must complete an undergraduate foundation 

consisting of several Aeronautical Science courses. 

4. MSA Professional Pilot students complete graduate coursework in advanced 

aerodynamics, advanced aircraft performance, and crew resource management.
5. In addition, these students receive instruction on flight crew techniques and 

procedures both in the classroom and in a CRJ-200 flight training device. This 

course combines material from several of the undergraduate Aeronautical 

Science courses, including Domestic and International Navigation (AS 350), Flight 

Technique Analysis (AS 420), Electronic Flight Management Systems (AS 435), 

and Airline Flight Crew Techniques and Procedures (FA 420). 

6. According to the public comment discussion in the final rule, nearly “36 

commenters stated that two-year college flight training programs should be 

eligible for an R-ATP certificate.” While the FAA did recognize associate degree 

programs in the final rule, there is no mention of master’s programs.

In summary, MSA Professional Pilot students must go through the same Part 141 flight 

training as Aeronautical Science students. MSA students complete fewer credits than 

students in the Aeronautical Science program; however, they are exposed to much of 

the same material. The university should be granted the authority to certify graduates 

of the MSA Professional Pilot program for the restricted ATP under the same conditions 

as approved associate degree programs.

Public benefit of exemption approval: 

Currently there are 15 students in the MSA Professional Pilot specialization. The 

majority of these students intend to pursue a career with a Part 121 air carrier, but do 

not meet the minimum requirement of 1500 hours. These students will meet all the 

requirements of 61.160(c), with the exception of 61.160(c)(1). While these students will 

not hold an associate’s degree, they will have completed at least 30 credits of aviationrelated coursework “designed to improve and enhance the knowledge and skills of a 

person seeking a career as a professional pilot.” Not granting this exception will delay 

our graduates’ entry into the industry, and could exacerbate the impending pilot 

shortage. 

Impact on Safety: 

MSA Professional Pilot students must complete the exact same flight training as 

students in the Aeronautical Science program. Additionally, MSA students must 

complete a minimum of 36 credits in aviation-related coursework before graduating. 

Professional Pilot students complete coursework that is designed to develop students 

into safe and effective flight crewmembers. Therefore, this exemption will not impact 

safety. 
Summary for Federal Register: 

Embry-Riddle Aeronautical University is seeking an exemption from 14 CFR part

61.160(c)(1). 

It is the university’s intent to seek approval for graduates of the Master of Science in 

Aeronautics degree program, who have completed their instrument and commercial 

training under FAA part 141 at Embry-Riddle Aeronautical University, to be eligible for 

the restricted privileges airline transport pilot certificate in accordance with 61.160(c). 

The university assumes that this is a reasonable request for the following reasons: 

1. Students in the Professional Pilot specialization of the MSA program who have 

completed their instrument and commercial ratings must go through the exact 

same training program (including ground labs and flight) as graduates of ERAU’s 

Aeronautical Science program, which has already been approved for the 

restricted privileges ATP. 

2. The coursework for the MSA Professional Pilot specialization consists of 36 

credits, and is geared specifically toward a career as a professional pilot. 

3. MSA Professional Pilot students must complete an undergraduate foundation 

consisting of several Aeronautical Science courses. 

4. MSA Professional Pilot students complete graduate coursework in advanced 

aerodynamics, advanced aircraft performance, and crew resource management.

5. In addition, these students receive instruction on flight crew techniques and 

procedures both in the classroom and in a CRJ-200 flight training device. This 

course combines material from several of the undergraduate Aeronautical 

Science courses, including Domestic and International Navigation (AS 350), Flight 

Technique Analysis (AS 420), Electronic Flight Management Systems (AS 435), 

and Airline Flight Crew Techniques and Procedures (FA 420). 

6. According to the public comment discussion in the final rule, nearly “36 

commenters stated that two-year college flight training programs should be 

eligible for an R-ATP certificate.” While the FAA did recognize associate degrees 

in the final rule, there is no mention of master’s programs.

In summary, MSA Professional Pilot students must go through the same Part 141 flight 

training as Aeronautical Science students. MSA students complete fewer credits than 

students in the Aeronautical Science program; however, they are exposed to much of 

the same material. The university should be granted the authority to certify graduates 

of the MSA Professional Pilot program for the restricted ATP under the same conditions 

as approved associate degree programs.