AFS-15-727-E June 24, 2015

Exemption No. 11894 Regulatory Docket No. FAA-2015-0501

Mr. Thomas Hinman Aviation Advanced Program Manager Aviation Technology Center of Pima Community College

7211 South Park Avenue Tucson, AZ 85709-6185

Dear Mr. Hinman:

This letter is to inform you that we have gran ted your request for exemption. It transmits our decision, explains its basis, and gives you th e conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated February 16, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Aviation Technology Center of Pima Community College (Aviation Technology Center) for an exemption from §§ 65.75(a) and 65.77 of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow th e Aviation Technology Center to administer the Aviation Mechanic General (A MG) examination immediately af ter students complete the corresponding curriculum and prio r to satisfying the experi ence requirements of § 65.77.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to Aviation Technology Center.

The FAA has issued a grant of exemption in circ umstances similar in all material respects to those presented in your petition. In Grant of Exemption No. 9846B (copy enclosed), the FAA found that testing immediatel y after learning was a univers ally accepted instructional principle that reinforces learning.2

Having reviewed your reasons for reque sting an exemption, I find that:

 they are similar in all material respects to re lief previously requested in the enclosed Grant of Exemption No. 9846B;

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 9846B also apply to the situ ation you present; and

 for the reasons stated in Grant of Exempti on No. 9846B a grant of exemption is in the public interest.

In addition, certain conditions and limitations incl uded in this partial grant are necessary to ensure an equivalent level of safety with § 65.75(a). The majority of these conditions – requiring the petitioner to develop written testing procedures to include those procedures in its approved operating document or manual, and to ob tain approval of those procedures from its Certificate Holding District office – will ensure that the school’s educational program and

curricula continue to meet F AA regulatory standards. The other condition of this exemption requires that, before the petiti oner may retest any student wh o has failed the AMG test and who also does not meet the experience requireme nts of § 65.77, the petitioner must retrain the

student on each instructional item associated with the failed test and authorize the student to retake the test. To be clear, a ny student who is eligible to ta ke the AMG test on the basis of his or her own experience, who does not need to rely on this exemption, may retrain according to § 65.19-including with any appropriate ly certificated airman. However, this exemption also creates a population of stude nts who do not satisfy the § 65.77 experience requirements, and who are eligible to retake the AMG test only because of the petitioner’s exemption. To maintain an equivalent level of safety, this exemption requires the petitioner to retrain these students itself, using FAA- approved curricula and in accordance with the FAA’s AMTS standards, including the quality of instruction standards codified in § 147.38a.

Our Decision

Under the authority contained in 49 U. S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator has delegated to me, I here by grant Aviation Technology Center of Pima Community College an exemption from 14 CF R § 65.75(a) to allow the Aviation Technology

Center to administer the AMG examination immediately after its students complete the corresponding curriculum and prio r to satisfying the experi ence requirements of § 65.77, subject to the conditions and limitations described below.

Conditions and Limitations

1. Aviation Technology Center must develop wr itten procedures for administering the

AMG written test to Aviation Technol ogy Center students immediately following successful completion of the general curriculum.3

2. Aviation Technology Center must ensure thes e procedures are available for use in Aviation Technology Center’s approved opera ting or curriculum procedures document

or manual.

3. Before retesting any student who has faile d the AMG examination and also does not meet the experience requirements of 14 CFR § 65.77, Aviation Technology Center must require the student to repe at each instructional item associated with the failed test

and authorize the student to retake the test. Aviation Technology Center must have procedures for documenting and tracking co mpliance with all retesting procedures.

4. Before exercising the privileges of this exemption, Aviation Technology Center must provide revised procedures to its Certif icate Holding District Office (CHDO) for review and approval.

This exemption terminates on June 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service

Enclosure Exemption No. 9846B