$ 

CCPS 

Collier Counr; PubUc Schools 

February 18, 2015 

LORENZO WALKER INSTITUTE OF TECHNOLOGY 

3702 Estey Avenue 

Naples, FL 34104-4405 

(239) 377-0900 

(239) 377-1000 FAX 

U.S. Department of Transportation 

Docket Operations, M-30 

West Building ground floor 

Room W12-140 

1200 New Jersey Avenue, 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 practical tests to be conducted as an integral P.art of an approved 

curriculum, and to allow the aviation mechanic general (AMG) written test to be 

administered after completing the 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 under Air Agency Certificate Number WT5T076K. 

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 

meet the FAA oral and practical testing requirements as part of the instructional program. The 

school is therefore petitioning the Federal Aviation Administration for renewal of the 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. 

COLLIER COUNTY CHARACTER EDUCATION TRAITS 

Citizenship Cooperation Honesty Kindness Patriotism Perseverance 

Respect Responsibility Self-Control Tolerance 

THE COLLIER COUNTY PUBLIC SCHOOL SYSTEM IS AN EQUAL ACCESS/EQUAL OPPORTUNITY INSmUTION FOR EDUCATION AND EMPLOYMENT 
U.S. Department of Transportation 

Docket Operations, 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 of Technology 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, Air Agency #WT5T076K 

Public Interest: Lorenzo Walker Institute of Technology is seeking authority to 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 of the completion requirements of each the five major instructional areas: 

General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and 

Powerplant Systems. It will expedite the evaluation process while maintaining a level of safety 

equal to that of the existing rule, and it will significantly reduce the cost to the students for FAA 

oral and practical tests. Direct involvement with the Miami Flight Standards District Office 19 in 

approving a system for administering and monitoring oral and practical tests will also add 

uniformity and consistency to the testing process. The concep~ of allowing Part 147 schools to 

conduct FAA "self testing" has also been recognized and proposed by the Part 651661ARAC 

working group. 

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 of oral and practical tests will not be changed, a level of safety equal to that 

provided by this 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 by the South Florida Flight Standards District Office 19. 
U.S. Department of Transportation 

Docket Operations, M-30 

February 18, 2015 

Page 3 

Economic Impact: There would be a positive economic impact on the general public. By 

incorporating oral and practical tests as part of the overall cost of operations for Lorenzo Walker . 

Institute of Technology, students will realize a substantial savings as they will not be required to 

pay a Designated Mechanic Examiner to administer oral and practical exams. 

b. Exemption from CFR Title 14 Part 65.19(b) Retesting after failure: 

Code of Federal Regulations CFR Title 14 Part 65.19{b) specifies that an applicant for a written, 

oral, or practical test for a certificate and rating, or for an additional rating under this part, may 

apply for retesting before the 30 days have expired, if the applicant presents a signed 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 of the subjects failed and that the 

airman considers the applicant ready for retesting. 

Relief Sought: CFR Title 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 that additional instruction has been given in the failed area be 

obtained prior to 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 practical testing will be an integral part of the 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 in the public interest to allow Lorenzo Walker Institute of Technology to 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 to document and track compliance. 

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 CFR Title 14 Part 65.19{b). A level 

of safety equal to or greater than that provided by this rule would be provided. 

Economic Impact: This will result in cost saving to the student. 
U.S. Department of Transportation 

Docket Operations, M-30 

February 18, 2015 

Page 4 

CFR Title 14Part 65.75(b) Knowledge Requirements:Code of Federal Regulations CFR Title 14 

Part 65.75(b) prescribes that an "applicant must pass each seCtion of the (written) test before 

applying for the oral and practical tests prescribed by Part 65. 79. 

Relief Sought: CFR Title 14 Part 65. 75(b): Lorenzo Walker Institute of Technology is 

petitioning exemption from this rule to allow it to conduct oral and practical testing as an integral 

part of the aviation maintenance technician 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 of the completion requirements for each instructional area 

through the administration of FAA oral and practical tests. Student learning would be enhanced 

and reinforced by the immediate feedback provided through incremental oral and 

practical testing. 

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 of the 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 ·rather than 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: There will be no negative impact on the economy. 

SUMMARY OF PETITION 1: 

The purpose of Petition I is to allow FAA oral and practical tests to be conduct~d as an integral· · 

part of Lorenzo Walker Institute of Technology's approved curriculum. 

CFR Title 14 Part 65.17(a) Tests: General Procedure 

Relief Requested: 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. Department of Transportation 

Docket Operations, M-30 

CPR Title 14 Part 65.19(b): Retesting After Failure: 

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. 

CFR Title 14 Part 65.75(b): Knowledge Requirement: 

Relief Requested: Lorenzo Walker Institute of Technology is petitioning exemption from 

this rule to allow it to meet the oral and practical testing requirements contained in FAR Part 

65 to be done increment~lly as part of its approved curriculum. 

PETITION II: 

An exemption to allow the Aviation Mechanic General (AMG) Written Test to be 

administered after completing the general curriculum: 

CFR Title 14 Part 65.75(a) and 65.77 Knowledge and Experience Requirements: 

Code of Federal Regulations CFR Title 14, Part 65.75(a) prescribes that 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 a written test for a certificate or rating. 

Relief Sought: Lorenzo Walker Institute of Technology 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 after completing the General 

curriculum, prior to meeting the experience requirements of CFR Title Part 65.77 .. 

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 of the General 

curriculum. To test immediately following 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 academic soundness of immediate testing. 
U.S. Department of Transportation 

Docket Operations, 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 take the Aviation Mechanic General written test after completion of the 

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 of Technology appreCiates any assistance you may be able to 

provide us in accomplishing these petitions. 

Respectfully submittr~· 

lf>&a--~~ 

Yolanda Flores, Principal 

Lorenzo Walker Institute of 

Technology and 

Lorenzo Walker Technical High School 

YF:jk 

cc: Carlos R Grillo 

Principle Maintenance Inspector 

Flight Standards District Office 

2895 S.W. 145th Ave, Suite 120 

Miramar Florida, 33027