Written Comments re: providing advice and recommendations on the implementation of the changes to the Title IV, HEA programs included in Pub. L. 119-21 Aviation Stakeholder Coalition

August 28, 2025 

Submitted via Regulations.gov - Docket ID ED-2025-OPE-0151 

The Honorable Nicholas Kent 

Under Secretary 

U.S. Department of Education 

400 Maryland Avenue, SW 

Washington, DC 20202 

Re: Comments on implementation of Title IV, HEA programs in the One Big Beautiful  Bill Act, Docket ID ED-2025-OPE-0151 

Dear Under Secretary Kent, 

As a broad coalition of aviation and aerospace stakeholders, we write to express our strong  support for a targeted regulatory clarification under the One Big Beautiful Bill Act (OBBBA) to  ensure that students enrolled in qualified undergraduate and Federal Aviation Administration  (FAA)-certificated Part 141 flight training programs have appropriate access to federal student  loan limits for professional students in professional degree programs. 

The nation is facing a pilot workforce crisis that poses serious consequences for transportation  access, economic vitality, and national competitiveness. Over the next 15 years, nearly 50% of  commercial airline pilots will be forced to retire due to mandatory age requirements.1 At the  same time, the current training pipeline is insufficient to meet projected demand. Since the  pandemic, more than 250 airports—representing nearly half of all U.S. airports with commercial  air service—are still operating below their pre-2020 flight levels, with dozens experiencing  declines of 50% or more in scheduled flights.2 This is not just a transportation concern—it is an  economic emergency, particularly for small and rural communities. 

We are taking decisive steps to address this shortage. Airlines and operators have raised starting  salaries, created education, training, and development programs, and expanded partnerships with  high schools, training providers, and higher education institutions. However, this challenge  cannot be solved by stakeholders alone. There are structural impediments to accessing the pilot  profession because of its incredibly high cost. The solution requires strong, sustained  collaboration with higher education and federal policymakers, particularly to address  affordability and access to education and training. 

(1) See 2024 Regional Airline Association Annual Report, https://raa.org/content-hub/raa-2024-annual-report/.

(2) See OAG Published schedules May 2019 vs. May 2025.

FAA flight training programs3—accredited and federally regulated—represent the foundation of  the pilot workforce pipeline. While these programs equip students with the professional  skills and licenses necessary to begin flying commercially, they are offered exclusively at  the undergraduate level or at FAA-certificated Part 141 pilot schools. After graduation  from either, students must continue training to earn the FAA-required Airline Transport  Pilot (ATP) certificate, which requires up to 1,500 flight hours. 

These requirements result in education and training costs that often exceed $80,000 to $100,000  beyond standard tuition. Yet federal student aid policies currently limit these students to standard  undergraduate loan caps, leaving them without access to the same federal support available to  students pursuing other professional degrees in fields like law, medicine, and veterinary science. 

The OBBBA restructured the federal loan system by eliminating the Grad PLUS loan program  and implementing new lifetime borrowing caps for graduate and professional students. The Act  defines “professional students” by referencing the existing regulatory definition at 34 CFR  §668.2, which describes a professional degree as one that requires professional licensure and a  level of skill beyond that normally required for a bachelor’s degree. As outlined above,  accredited and FAA-certificated Part 141 flight training programs fit squarely within this  definition. However, because the regulation fails to expressly identify such programs and is  written ambiguously, further regulatory clarification or guidance from the Department is  urgently needed to ensure they are explicitly included. 

Therefore, we respectfully urge the Department to issue clarifying regulations or guidance that explicitly include qualified undergraduate and FAA-certificated Part 141 flight  training programs—those accredited by an accreditor recognized by the U.S. Department  of Education and certified by the FAA—within the definition of a “professional degree”  under 34 CFR §668.2. The specific language should ensure that “accredited programs  providing the training described in 14 CFR §141 (or any successor regulations)” are  covered. 

This clarification would allow students in these programs to access the professional student loan  limits established under the OBBBA, enabling them to complete training, enter the workforce,  and repay loans with strong earnings in a high-demand profession. According to the Bureau of  Labor Statistics, as of May 2024, the median salary for airline pilots now exceeds $226,000.4 

This is not a request for new authority or special treatment. It is a narrowly tailored clarification  that aligns longstanding regulatory language with the realities of pilot education and training and  supports the nation’s economic competitiveness. These students—and the communities that will  

ultimately rely on them for air service—deserve equitable access to the same federal tools  already available to peers in other professions that require professional licensure and advanced  training beyond a bachelor’s degree. We are not asking to create new programs or schools  eligible for student loans. Rather, we are requesting clarification that existing accredited and  FAA-certificated Part 141 programs fall within the definition of a “professional degree,” more  

(3) 14 CFR §141. 

(4) See https://www.bls.gov/ooh/transportation-and-material-moving/airline-and-commercial-pilots.htm#tab-5.

accurately reflecting the level of commitment and competency certification required of student  pilots in these programs. 

We urge the Department to act swiftly and decisively to make this requested clarification in  support of student pilots, to strengthen the pilot pipeline, and to uphold the integrity of the  nation’s air transportation system. 

Sincerely, 

Airlines and Other Related Businesses 

Air Wisconsin Airlines 

Alaska Airlines 

American Airlines 

Atlas Air 

Cape Air 

CommuteAir 

Delta Air Lines 

Endeavor Air 

Empire Airlines 

Envoy Air 

GoJet Airlines 

Hawaiian Airlines 

Horizon Air 

JetBlue Airways 

Piedmont Airlines 

PSA Airlines 

Republic Airways 

SkyWest Airlines 

Southwest Airlines 

Textron Aviation 

United Airlines 

Education and Training Institutions 

California Aeronautical University 

Delaware State University 

Indiana State University Aviation 

Leadership in Flight Training Academy LLC 

Lewis University - Department of Aviation and Transportation 

The University of Memphis - Herff College of Engineering 

University of Dubuque – Department of Aviation 

University of Oklahoma School of Aviation 

Vaughn College of Aeronautics and Technology 

Trade Associations 

Airlines for America (A4A)  

American Association of Airport Executives (AAAE) 

Association of Value Airlines (AVA) 

Cargo Airline Association (CAA)  

General Aviation Manufacturers Association (GAMA)  International Air Transport Association (IATA)  National Air Carrier Association (NACA)  

National Air Transportation Association (NATA)  National Association of State Aviation Officials (NASAO) National Business Aviation Association (NBAA) 

National Flight Training Alliance (NFTA) 

Regional Air Cargo Carriers Association (RACCA)  Regional Airline Association (RAA)  

University Aviation Association (UAA)  

Vertical Aviation International (VAI)