# Aviation Institute ofMaintenance

10640 Davidson Place • Manassas, VA 20109,, Telephone (703)257-5515 August26, 2014

U.S. Department ofTransportation Document Management System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 / :··] •.. ,1' Subject: Petition for exemption from Code ofFederal Regulations 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion ofthe curriculum. Dear Sir or Madam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Manassas, VA, under Air Agency Certificate U6ET095K. PETITION: AIM is requesting an exemption from 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion ofthe curriculum. 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass a written test, "after meeting the experience requirements ofPart 65.77." §65.77 requires applicants to comp1ete training and, "present either an appropriate graduation certificate orcertificate ofcompletion from a certificated aviation maintenance technician school" before being eligible to take the written test for a certificate orrating. Relier'Sought: AIM is seeking exemption from 14 CFRPart 65.75(a) to allow students enrolled in its Part 147 Aviation Maintenance Technician School to take the Aviation Mechanic written tests (AMG, AMA, AMP) after completingthe correspondingportion ofthe curriculum, prior to meeting the experience requirements of§65.77. Person(s) to be covered bythe exemption: AIM, Air Agency U6ET095K and students enrolled in its AMTS program in the Airframe and Powerplant curricula. Information, views, or arguments to support the action sought: Testing immediately after learning is a universally accepted instructionalprinciple thatreinforces learning, and is academically sound. This is currently allowed with both the Airframe and Powerplant curriculums, butis not allowed at the completion ofthe General curriculum. Students attending the school are enrolled in the combined Airframe & Powerplant curriculum. This petition is structured to provide an opportunity for testing after the completion ofany section ofthe curriculum (General, Airframe, Powerplant) regardless ofthe type of enrollment. AIM has established a procedure with the Washington, DC Flight Standards District Office to identify and report graduates who are eligible to take the FAA written, oral, and practical tests to boththe FSDO and the school's on-site written test center. The same procedure used to identify and report students who qualify to take the AMG written test after completion ofthe General curriculum, wouldbeused to identifythose eligible to take the AMA written test after completion ofthe Airframe curriculum and the AMP written test after completion ofthe Powerplant curriculum. A graduation certificate orcertificate ofcompletion would onlybe issued after the successful completion ofthe entire program in which the student i.s enrolled (Airframe & Powerplant). The exceptional circumstances encountered by students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 whi<;h permits a student to take the oral and practical tests prescribed by §65.79 before they meetthe applicable experience requirements of§65.77. Thetime penalty incurred by beginning the testing process before the completion ofthe entire curriculum would be more than offsetby the academic soundness ofimmediate testing.

:' .**~-** .Public Interest: The public interest will be servedby allowing aviation maintenance technician students to take the FAA writtentests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforcedbythe immediate feedback provided bythe testing experience. This immediate feedback, coupled with a sense of accomplishment, is expectedto encourage students to continue their studies and increase retention rates. This petition does not differ materially from others onrecord, specifically Exemption number 10836, and those requests have been deemedto be in the public interest. Impact on Safety: A procedure is currently inplace to identify and report students who are eligible to take the FAA written, oral and practical tests. This information is distributed to the Washington, DC FSDO and the on-site written test center. The same procedure would be used to identify and report students who would qualify to take the Aviation Mechanic written tests after the completion ofthe corresponding portion ofthe curriculum. All otherrequirements governing written testing, including time requirements for licensure completionwould remain unchanged. A level ofsafety equalto thatprovided by this rule would beprovided. Economic Impact: There will be no impact on the economy.

SUMMARY OF PETITION Thepurpose ofthis petition is to allow the Aviation Mechanic written test (AMG, AMA, AMP) to be administeredpriorto graduating from the entire curriculum. 14 CFR, Part 65.75(a) Knowledge Requirements: ReliefRequested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow students to take each written examination after completingthe correspondingportion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you maybe able to provide us in accomplishingthese petitions.

erald Yagen, Pr side**~**viation Institute aintenance Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757) 490-3151