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CollierCounr; PubUc Schools February 18, 2015 LORENZOWALKER INSTITUTE OF TECHNOLOGY 3702 EsteyAvenue Naples, FL 34104-4405 (239) 377-0900 (239) 377-1000 FAX

U.S. DepartmentofTransportation DocketOperations, M-30 West Building groundfloor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590

Subject: Petition for exemption extension docket number FAA -2005-22015 from Code of Federal Regulations (CFR) Title 14 Part 65.17 (a}, Part 65.19 (b), and Part 65.75 to allow FAA oral and practicalteststo be conducted as an integral P.art ofan approved curriculum, and to allow the aviation mechanic general (AMG) written test to be administered aftercompletingthe general curriculum. Dear Sirs: Lorenzo Walker Institute of Technology, a Collier County Public School, offers the Federal Aviation Administration approved airframe and powerplant aviation maintenance technology curriculum underAirAgency Certificate NumberWT5T076K. Lorenzo Walker Institute of Technology is requesting a renewal of exemption number 8629, approved on August 10, 2011. This exemption authorizes students completing the FAA approved airframe and powerplant aviation maintenance technology curriculum to concurrently meetthe FAA oral and practical testing requirements as part ofthe instructional program. The school is therefore petitioning the Federal Aviation Administration for renewal ofthe following exemptions: I. Exemption from the CFR Title 14, Parts 65.17(a), 65.19(b) and 65.75(b) to allow the FAA oral and practical tests to be conducted as an integral part of an approved curriculum. Lorenzo Walker Institute of Technology's curriculum is currently divided into forty instructional subjects; however, the oral and practical tests would be reviewed and documented at the completion of each of the following five areas: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems.

COLLIERCOUNTYCHARACTEREDUCATION TRAITS Citizenship Cooperation Honesty Kindness Patriotism Perseverance Respect Responsibility Self-Control Tolerance

THECOLLIER COUNTY PUBLIC SCHOOL SYSTEM IS AN EQUALACCESS/EQUAL OPPORTUNITY INSmUTION FOR EDUCATIONAND EMPLOYMENT

### U.S. DepartmentofTransportation DocketOperations, M-30 February 18, 2015 Page 2

II. Exemption from CFR Title 14, Part 65.75 (b) and 65.77 to allow· the ·Aviation Mechanic General (AMG) written tests to be administered after completing the General curriculum. PETITION 1:

a. Exemption from CFR Title 14, Part 65.17(a) Tests, General Procedures Relief Sought: CFR Title 14, Part 65.17(a) Lorenzo Walker Institute ofTechnology ispetitioning to administer the oral and practical tests to its students "at times and places" identified in its approved Operations Handbook. Person to be Covered by the Exemption: Lorenzo Walker Institute of Technology andstudents, AirAgency#WT5T076K Public Interest: LorenzoWalker Institute ofTechnology is seeking authorityto conduct oral and practical tests as an integral part of the aviation maintenance technician educational process. This request is in the public interest. It will allow students to demonstrate FAA required ·competence as part ofthe completion requirements of each the five major instructional areas: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. Itwill expedite the evaluation process while maintaining a level ofsafety equal to that ofthe existing rule, and it will significantly reduce the costto the students for FAA oral and practicaltests. Direct involvementwith the Miami Flight Standards District Office 19 in approving a system for administering and monitoring oral and practical tests will also add uniformity and consistencyto the testing process. The**concep~**

### ofallowing Part 147 schoolsto conduct FAA "selftesting" has also been recognized and proposed by the Part 651661ARAC workinggroup. Impact on Safety: Current FAA oral and practical testing requirements are to remain in place, except for the manner in which the tests are administered. Rather than administering one lengthy oral and practical mechanic test over an entire body of knowledge. Lorenzo Walker Institute of Technology is seeking to administer oral and practical tests incrementally during each of the five· major components of instruction: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. Each component is 480 hours in length. The scope of the FAA oral and practical test will be completed 

# in its entirety when a student graduates from the airframe and/or powerplant curriculum. Since the scope and nature oforal and practical tests will not be changed, a level of safety equal to that provided bythis rule will be maintained. The time, place and manner in which oral practical tests are managed will be contained in the school's approved Operations Handbook and curriculum, and will be subject to review and approval bythe South Florida Flight Standards DistrictOffice 19.

### U.S. DepartmentofTransportation DocketOperations, M-30 February 18, 2015 Page 3

Economic Impact: There would be a positive economic impact on the general public. By incorporating oral and practicaltests as part ofthe overall cost ofoperationsfor LorenzoWalker

. Institute ofTechnology, studentswill realize asubstantial savings as theywill not be required to paya Designated Mechanic Examinertoadministeroral and practical exams. b. Exemptionfrom CFR Title 14 Part65.19(b) Retesting afterfailure: Code ofFederal Regulations CFRTitle 14 Part 65.19{b) specifies that an applicantfor awritten, oral, or practical test for a certificate and rating, orfor an additional rating underthis part, may applyfor retesting beforethe 30 days have expired, ifthe applicant presents asigned statement from an airman holding the certificate and rating sought by the applicant, certifying that the airman has given the applicant additional instruction in each ofthe subjects failed and that the airman considersthe applicant readyfor retesting. Relief Sought: CFRTitle 14 Part 65.19(b): Lorenzo Walker Institute of Technology is petitioning for exemption from the requirement that a signed statement from an appropriately rated "certificate holder"certifying thatadditional instruction has been given in the failed area be obtained priorto retesting. Pers.on to be Covered by the Exemption: Lorenzo Walker Institute of Technology, Air Agency, and students enrolled in its Aviation Maintenance Technology Airframe and/or Powerplant curricula. Public Interest: Proposed oral and practicaltesting will be an integral partofthe curriculum and will take place in progressive increments as a student advances through training. Should a student fail an oral or practical test, retesting will be permitted based on the requirements for additional instruction contained in Lorenzo Walker Institute of Technology's approved Operations Handbook. · It is inthe public interestto allow LorenzoWalker Institute ofTechnologyto control and monitor the retesting criteria for students who fail oral and practical testing under this proposal.

. The retesting criteria will be contained in its approved Operations Handbook with procedures in place todocumentand trackcompliance. Impact on Safety: Approval to retest will be authorized by the school as approved in its Operations Handbook, and not by individuals as required by CFRTitle 14 Part 65.19{b). A level ofsafetyequalto orgreaterthanthatprovided bythis rulewould be provided. Economic Impact: Thiswill result in cost savingto the student.U.S. DepartmentofTransportation Docket Operations, M-30 February 18, 2015 Page 4

CFR Title 14Part65.75(b) Knowledge Requirements:Code of Federal Regulations CFR Title 14 Part 65.75(b) prescribes that an "applicant must pass each seCtion ofthe (written) test before applying forthe oral and practicaltests prescribed by Part65.79.

Relief Sought: CFR Title 14 Part 65.75(b): Lorenzo Walker Institute of Technology is petitioning exemptionfrom this rule to allow it to conduct oral and practical testing as an integral part ofthe aviation maintenancetechnician educational process. Person to be Covered by the Exemption: Lorenzo Walker Institution of Technology, Air Agency #WT5T076K, and students enrolled in its Aviation· Maintenance Technology Airframe and/or Powerplant curricula. Public Interest: Exemption from this rule would be in the public interest. A level of safety equal to that provided by the rule would be maintained while allowing students to demonstrate FAA required competency as part ofthe completion requirements for each instructional area throughthe administration ofFAAoral and practical tests. Student learning would be enhanced and reinforced by the immediate feedback provided through incremental oral and practicaltesting. Impact on Safety: Lorenzo Walker Institute of Technology curriculum is competency based. Rather than testing for competency at the conclusion of the entire body of knowledge for airframe or powerplant technician, as is required by CFR Title Part 65.75{b}, oral and practical testing is to be conducted incrementally as an integral part of the instructional process and documented at the conclusion of each ofthe five major blocks of instruction: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. This proposal will not adversely affect public safety. An oral and practical test over the entire body of knowledge for a mechanic certificate or

. added rating would be administered, but in smaller subdivisions ·ratherthan in one inclusive test. This would provide a level of safety equal to that provided by the rule from which this exemption is sought. Economic Impact: Therewill be no negative impacton the economy. SUMMARY OF PETITION 1: The purpose of Petition I is to allow FAA oral and practical teststo be**conduct~d** as an integral· · part of LorenzoWalker InstituteofTechnology's approved curriculum. CFR Title 14 Part 65.17(a)Tests: GeneralProcedure ReliefRequested: Lorenzo Walker Institute of Technology is petitioning to administer written, oral and practical tests at times and places designated in its approved Operations Handbook.U.S. DepartmentofTransportation DocketOperations, M-30

CPR Title 14 Part 65.19(b): RetestingAfterFailure: February 18, 2015 Page 5

Relief Requested: Lorenzo Walker Institute of Technology is petitioning to allow retesting of students "before 30 days have·· expired" based on the requirements for additional instruction outlined in its approved Operations Handbook. CFRTitle 14 Part 65.75(b): Knowledge Requirement: Relief Requested: Lorenzo Walker Institute ofTechnology is petitioning exemption from this rule to allow itto meetthe oral and practical testing requirements contained in FAR Part 65to be done**increment~lly** as partofits approved curriculum.

PETITION II: An exemption to allow the Aviation Mechanic General (AMG) Written Test to be administered aftercompletingthegeneral curriculum: CFR Title 14 Part 65.75(a) and 65.77 Knowledge and Experience Requirements: Code of Federal Regulations CFRTitle 14, Part 65.75(a) prescribesthat applicants must pass a written test "after meeting the experience requirements qf Part 65.77. Part 65.77 requires applicants to complete training and "present.

..an appropriate·graduation certificate or certificate of completion from a certified aviation maintenance technician school" before being eligible to take awritten testfor acertificate or rating. Relief Sought: Lorenzo Walker Institute ofTechnology is seeking exemption from CFR Title 14 Part 65.75(a) to allow students enrolled in its Part 147 aviation maintenance· technology program to.take the Aviation Mechanic General (AMG) written test aftercompleting the General curriculum, priorto meetingthe experience requirements ofCFRTitle Part65.77

.. Person t9 be Covered by the Exemption: Lorenzo Walker Institute of Technology, Air

. 

### - Agency and students enrolled in its Aviation Maintenance Technology Airframe and/or Powerplant curricula. Public Interest: The public interest will be served by allowing aviation maintenance technician students to take the FAA written test over·a body of knowledge immediately following the successful completion of that body of knowledge. This is currently allowed with both the Airframe and Powerplant curricula, but is not allowed following the completion ofthe General curriculum. To test immediatelyfollowing learning is a universally accepted instructional principle which reinforces learning and is academically sound. The time penalty incurred by beginning the testing process prior to completing the entire curriculum would be more than

. offset by academicsoundness of immediatetesting.U.S. DepartmentofTransportation DocketOperations, M-30 February 18, 2015 Page 6

Impact on Safety: Lorenzo Walker Institute of Technology has established a procedure with the Miami Flight Standards District Office 19 to identify and report graduates who are eligible to take the FAA written, oral, and practical tests with affiliate qesignated Mechanic Examiners. This same procedure would be used to identify and report students who would qualify to takethe Aviation Mechanic General written test after completion ofthe General curriculum. All other requirements governing written testing, including time requirements for licensure completion, would remain unchanged. A level of safety equal to that provided by this rule would be provided. Economic Impact: None SUMMARY OF PETITION II: The purpose of Petition II is to allow the Aviation Mechanic General (AMG) written test to be administered prior to graduation from the entire curriculum. CFR Title 14 Part 65.75(a): Knowledge Requirements: Relief Requested: Lorenzo Walker Institute of Technology is petitioning for an exemption from this rule to allow students to take the general written examination after completing the general curriculum. Lorenzo Walker Institute ofTechnology appreCiates any assistance you may be able to provide us in accomplishing these petitions. Respectfully**submittr~·**

# lf>&a--~~ Yolanda Flores, Principal LorenzoWalker Institute of Technology and LorenzoWalkerTechnical High School

YF:jk cc: Carlos R Grillo Principle Maintenance Inspector Flight Standards DistrictOffice 2895S.W. 145thAve, Suite 120 MiramarFlorida, 33027