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 granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the 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 the Aviation Technology Center to administer the 

Aviation Mechanic General (AMG) examination immediately after students complete the 

corresponding curriculum and prior to satisfying the experience 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 circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 9846B (copy enclosed), the FAA 

found that testing immediately after learning was a universally accepted instructional 

principle that reinforces learning. 
2 

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

 they are similar in all material respects to relief 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 situation you present; and 

 for the reasons stated in Grant of Exemption No. 9846B a grant of exemption is in the 

public interest. 

In addition, certain conditions and limitations included 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 obtain approval of those procedures from its 

Certificate Holding District office – will ensure that the school’s educational program and 

curricula continue to meet FAA regulatory standards. The other condition of this exemption 

requires that, before the petitioner may retest any student who has failed the AMG test and 

who also does not meet the experience requirements 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, any student who is eligible to take 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 appropriately certificated airman. However, this 

exemption also creates a population of students 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 hereby grant Aviation Technology Center of Pima 

Community College an exemption from 14 CFR § 65.75(a) to allow the Aviation Technology 

Center to administer the AMG examination immediately after its students complete the 

corresponding curriculum and prior to satisfying the experience requirements of § 65.77, 

subject to the conditions and limitations described below. 

Conditions and Limitations 

1. Aviation Technology Center must develop written procedures for administering the 

AMG written test to Aviation Technology Center students immediately following 

successful completion of the general curriculum. 
3 

2. Aviation Technology Center must ensure these procedures are available for use in 

Aviation Technology Center’s approved operating or curriculum procedures document 

or manual. 

3. Before retesting any student who has failed the AMG examination and also does not 

meet the experience requirements of 14 CFR § 65.77, Aviation Technology Center 

must require the student to repeat 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 compliance with all retesting procedures. 

4. Before exercising the privileges of this exemption, Aviation Technology Center must 

provide revised procedures to its Certificate 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