The letter goes on to argue that the university's graduation rate — which ranks among the top 10 for Division I programs — is evidence that "Penn State clearly places the education of its student-athletes ahead of football."

"Thus, arbitrarily eliminating 40 scholarships to Penn State is undeniably and inexcusably punitive to young people who had absolutely nothing to do with Jerry Sandusky's mortal crimes," the letter reads.

In July, the NCAA imposed the scholarship restriction as part of sweeping sanctions against the university's football program in the wake of the scandal. In addition to the 40 scholarship reductions, the NCAA imposed a four-year postseason ban and a $60 million fine, and demanded the university vacate all wins between 1998 and 2011.

Earlier this month, Pennsylvania Gov. Tom Corbett announced he was suing the NCAA on behalf of the state, arguing the penalties amounted to an antitrust violation. Corbett said the collegiate athletic governing body imposed the unprecedented penalties without going through normal investigative channels, and argued Penn State was forced to accept the punishment.

Donald Remy, the NCAA's  executive vice president, criticized that move in a statement posted to the organization's website.

"We are disappointed by the Governor's action today," Remy said. "Not only does this forthcoming lawsuit appear to be without merit, it is an affront to all of the victims in this tragedy — lives that were destroyed by the criminal actions of Jerry Sandusky. While the innocence that was stolen can never be restored, Penn State has accepted the consequences for its role and the role of its employees and is moving forward. Today's announcement by the Governor is a setback to the University's efforts."