AFS-16-14095-E October 21, 2016

Exemption No. 7926G Regulatory Docket No. FAA-2002-13291

Mr. Vince Gemmiti Director of Aerospace Pulaski Technical College 1600 West Maryland Avenue

North Little Rock, AR 72120

Dear Mr. Gemmiti:

This letter is to inform you that we have granted your petition to extend Exemption No. 7926, as amended. 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 August 8, 2016, you petitioned the Federal Aviation Administration (FAA) on behalf of Pulaski Technical College (PTC) for an extension of Exemption No. 7926, as amended. That exemption from § 65.75(a) of T itle 14, Code of Federal Regulations (14 CFR) allows PTC to administer the aviation mechanic general (AMG) written test to students immediately following their successful completion of the general curriculum but before they meet the experience requirements of § 65.77.

In this extension, the FAA updated the conditions and limitations to reflect what is currently being issued to similar exemptions from § 65.75(a).

In your petition, you indicate that there has been no change in the conditions and reasons relative to public interest and safety that were the basis for granting the original exemption.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested extension of the exemption would not set a precedent, and any delay in acting on this petition would be detrimental to PTC.2

Our Decision

The FAA is in the process of withdrawing or amending all previously granted exemptions to 14 CFR § 65.75(a), which enabled certain Aviation Maintenance Technician Schools (AMTSs) the ability to administer the AMG, Aviation Mechanic Airframe (AMA), and Aviation Mechanic Powerplant (AMP) written tests immediately following a student’s successful completion of the corresponding curricula. The FAA’s new and revised exemptions will only permit an AMTS to authorize students to take the AMG examination immediately after completing the corresponding curriculum, but will not allow students to take the AMA or AMP examinations before completing the corresponding curricula.

In consideration of the foregoing, I find in the present case that a partial grant of exemption is in the public interest. Specifically, certain conditions and limitations have been included in this exemption to ensure an equivalent level of safety with 14 CFR § 65.75(a). The conditions and limitations require PTC to develop written testing procedures, include those procedures in its operating document or manual, and obtain approval of those procedures from its Certificate Holding District Offi ce (CHDO) to ensure that PTC’s educational program and curricula continue to meet FAA regulatory standards.

The additional conditions and limitations of this exemption also require that PTC must retrain any student on the specific instructional items associated with a failed AMG test and authorize the student to retake the test. This would be applicable prior to any PTC retesting of a student who has failed the AMG test and who also does not meet the experience requirements of 14 CFR § 65.77.

To be clear, any student who is eligible to take the AMG test, on the basis of his or her own experience, and who does not need to rely on this exemption, may retrain according to 14 CFR § 65.19 - including with any appropriately certificated airmen. However, this exemption also creates a population of students who do not satisfy the 14 CFR § 65.77 experience requirements, and who are eligible to retake the AMG test, only because of the exemption granted to PTC. To maintain an equivalent level of safety, this exemption requires PTC to retrain those students itself, using its written procedures, its FAA-approved curricula and in accordance with the FAA’s AMTS standards, including the quality of instruction standards, codified in 14 CFR § 147.38(a).

The FAA has determined that the justification for the issuance of Exemption No. 7926, as amended, remains valid with respect to this exemption and is in the public interest. Therefore, under the authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator has delegated to me, I grant Pulaski Technical College (PTC) an exemption from 14 CFR § 65.75(a) to administer the aviation mechanic general (AMG) written test to students immediately following their successful completion of the general curriculum but before they meet the experience requirements of § 65.77, subject to the

conditions and limitations listed below.3

Conditions and Limitations

1. PTC must develop written procedures for administering the AMG written test following successful completion of the general curriculum.

2. PTC must ensure these procedures are available for use in its approved operating or curriculum procedures document or manual.

3. Before retesting a student who has failed the AMG examination, and also does not meet the experience requirements of 14 CFR § 65.77, PTC must require the student to repeat each instructional item associated with the failed test and receive authorization from PTC to retake the test. PTC must have procedures for documenting and tracking compliance with all retesting procedures.

4. Before exercising the privileges of this exemption, PTC must provide revised procedures to its certificate holding distri ct office (CHDO) for review and approval.

The Effect of Our Decision

This exemption terminates on November 30, 2018, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan Director, Flight Standards Service