To be eligible for the ATP-R:
On the contrary, ERAU was an integral part of the rule-making process and initially requested Part 142 be included in our exemption.
ERAU lobbied the FAA during the rule-making process to include training under Part 142. When the rule was issued with Part 142 not included, ERAU discussed this with the FAA and was given instructions to submit a request to have Part 142 included during the degree-approval process.
Upon receiving the initial Letter of Approval, the FAA communicated that the Part 142 training needed to be approved through the exemption process. At that point, ERAU immediately submitted an exemption request.