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School of Missionary Aviation Technology 

468ESpragueRd. D-175 

Ionia, MI 48846 

616-527-4160 

Fax 616-527-4180 

(a) Dean Thomas Peterson, Director of Part 147 Mechanics School 08-05-2011 

468 E. Sprague Rd. D-175 

Ionia, MI 48846 

e-mail, dpeterson@smat-aviation.org 

(b) FAA-2007-26739, Part 65.75 

Exemption from Part 65.75 or alternate to Part 147.35, allowing a student to take the 

General Written test before completion of Part 65.77 or Part 65.75. 

(c) The extent of relief would be to allow the student who completes the General section 

to take the written tests at that time. 

(d) The public interest would be to make taking the General test at a time when it is the 

freshest in their minds. There is so much to learn and remember that this exception, 

which is recommended in the ni-G: The Exemption Process would help those students to 

more successfiilly pass the General written test. 

(e) Granting this exemption would not affect safety because the student still needs to pass 

either the Powerplant or Airframe tests to complete the Certification. The student then 

needs to pass the Oral and Practical tests as well for either the Powerplant or Airframe 

Certification 

(f) (1) FAA-2007-26739 

(2) The permission to grant our students the opportunity to take the General Written 

test after successfully completing that portion of the A orP Certificate. 

(g) This exemption has been granted to other Schools such as the "Aviation Institute of 

Maintenance". We have been a part 147 School since 1981 for the Powerplant and 1983 

for the Airframe. We have a proven record vidth our FSDO with regular inspections to 

insure our appliance with the regulations. 

(h) We do not Avish to exercise the privilege of this exemption outside of the United 

States. 

Thank you, Dean Thomas Pearson 
<d 

us Department 800 independence Ave S w 

Of Transportation Washington, D C 20591 

Federal Aviation 

Administration 

JuJ y 8, 2011 

Dean T. Peterson 

Director of A&P School 

School of Missionary Aviation Technology 

468 East Sprague Road d-175 

Ionia, Ml 48846 

Dear Mr. Peterson: 

This letter is to inform you that we are unable to process your request. It explains why we 

can't process your request and what you should do in the next 30 days. 

Why Wc Can Not Process Your Request 

We entered your May 16, 2011, exemption request on behalf of School of Missionary 

Aviation Technology into the public docket (No. FAA-2011-0549), but we are unable to 

process your request any further. The information you sent does not comply with the 

requirements of 14 CFR 11.81 (copy enclosed). For us to consider the request any further, 

you must send us all of the following: 

• The specific section or sections of 14 CFR from which you seek relief, the extent of the 

relief you seek, and the reason you seek relief 

• The reasons why granting the request would be in the public interest; that is, how it would 

benefit the public as a whole. 

• The reasons why the exemption wouldn't adversely affect safety or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you 

seek an exemption. 

• Any additional information, views, or arguments available to support your request. 

What You Should Do 

If you want us to process your request any further, you must send the information described 

earlier to reach us within 30 days. We will consider the docket on your request open until we 

receive this required information from you. Please note that 14 CFR 11.63(d) requires you to 

send your petition for exemption at least 120 days before the proposed effective date of the 

exemption. 
If We Do Not Hear From You 

If we don't hear from you within 30 days, we will close the docket without notifying you 

further. If you have any questions or require additional time, you may call (202) 267-9677. 

Sincerely, 

Brenda D. Courtney ij ^ 

Manager, Aircraft and 

Airport Rules Division 

Enclosure 
HQip.; PaQt> Enocuiivo BiaiicM > Codo u( Fodotal Reouiaiions > Elocifomc Cods ol Podotal RoQuialions 

6/30/2011 11:05:46 AM 

TM 

e-CFR Data is current as of June 28, 2011 

Title 14: Aeronautics and Space 

PART n—GENERAL RULEMAKING PROCEDURES 

Subpart A—Ruleniakino Procedures 

Petitions tw RulemakiriQ and lor Exemplion 

Srowse Previous | Browse Next 

§ 11.81 What information must I include in my petition for an exemption? 

You must indude the following information in your petition for an exemption and submit it to FAA as 

soon as you know you need an exemption. 

(a) Your name and mailing address and, if you wish, other contact information such as a fax number, 

telephone number, or e-mail address; 

(b) The speafic section or sections of 14 CFR from which you seek an exemption; 

(c) The extent of relief you seek, and the reason you seek the relief; 

(d) The reasons why granting your request would be in the public Interest; that is, how it would benefit 

the public as a whole; 

(e) The reasons why granting the exemption would not adversely affect safety, or how the exemption 

would provide a level of safety at least equal to that provided by the rule from which you seek the 

exemption; 

(f) A summary we can publish in theFederai Register,stating: 

(1) The rule from which you seek the exemption; and 

(2) A brief description of the nature of the exemption you seek; 

(g) Any additional information, views or arguments available to support your request; and 

(h) If you wa« to exercise the privileges of your exemption outside the United States, the reason why 

you need to tto so. 

Browse Previcus I Browse Nexi 

For qiestions or comments regarding e-CFR editorial content, features, or design, email ecfr@nara.qov. 

F:r questions concerning e-CFR programming and delivery issues, email webleam(3>qpo.Qov. 

Section 508, Accessibility 

Electronictjode of Federal Regulati. 

Is. . ^ ifiiO ^ 
% 

/ ' 

III-G: The Exemption Process 

Testing exemptions have routinely been approved by the FAA based on Parts 65.75 

& 65.77. Ratlier than open Part 65 for review and ciiange, alternate language for Part 

147.35 has been crafted that allow a school to issue a certificate of completion allowing a 

student to sit for the General Knowledge Test before a student meets the applicable 

experience requirements of §65.77 and before he/she passes the Airframe and or 

Powerplant written knowledge test prescribed by §65.75. 

Whenever an AMTS certificated under part 147 of this chapter shows to an FAA 

inspector that any of its students has made satisfactory progress at the school and is 

prepared to take the oral and practical tests prescribed by §65.79, that student may take 

those tests during the final subjects of his training in the approved curriculum, before he 

meets the applicable experience requirements of §65.77 and before he passes each section 

of the written test prescribed by §65.75. Testing immediately after learning is a universally 

accepted instructional principle that reinforces learning, and is academically sound. This is 

currently allowed with both the Airframe and Powerplant curriculums, but is not allowed at 

the completion of the General curriculum. 

Students attending an AMTS may be enrolled in a single-rating program, or the 

combined Airframe & Powerplant curriculum. The vast majority opts for the combined 

curriculum. This change is structured to provide an opportunity for testing after the 

completion of any section of the curriculum (General, Airframe, Powerplant). 

Part 147 schools have established a procedure with their FSDO and with the 

Airman Certification Branch to identify and report graduates who are eligible to take the 

FAA knowledge, oral, and practical tests to both the FSDO, and the school's affiliated 

43 
r 

written test center. The same procedure would be used to identify and report students who 

would qualify to take the AMG knowledge test after completion of the General curriculum. 

A graduation certificate would only be issued after the successful completion of the entire^ 

program in which the student is enrolled (Airframe, Powerplant, or Airframe & 

Powerplant). 

The exceptional circumstances encountered by students enrolled in a Part 147 

AMTS are recogoiz>ed and provided for by fart 65,80 which permits a student to take the 

oral and practical tests prescribed by §65.79 before they meet the applicable experience 

requirements of §65.77. The time penalty incurred by beginning the testing process before 

the completion of the entire curriculum would be more than offset by the academic 

soundness of immediate testing. 

This process is currently being executed where multiple exemptions from the 

regulation have been granted. This change does not differ materially from those existing 

exemptions. The reasons stated by the FAA for granting those exemptions also apply to 

this change. Therefore the working group recommends the addition of new language, 

designated as 147.35(c) to formalize the exempts now being granted. 

Recommendation 7 - Formalizing the Exemption Process 

It is proposed to add Part 147.35(c) to read as follows: 

(c) Whenever an aviation AMTS certificated under part 147 of this chapter shows to an 

FAA inspector that any of its studehTs has made satisfactory progress at the school and is 

prepared to take the General Knowledge test prescribed by §65.75, that student may take 

the test during their subsequent training in the approved curriculum, before they meet the 

44 
applicable experience requirements of §65.77 and before he/she passes Airframe and/or 

Powerplant written test prescribed by §65.75. 

The school will prepare and issue a Certification of Completion to identify and 

report students who are eligible for testing under this part. An official of the school shall 

authenticate the certificate. The certificate must show the completion date and the 

approved curriculum title. The authority for a school to issue a certificate of completion 

for the General curriculum testing will be authorized in a Training Specificaiion paragraph.' 

Proposed Changes to CFR Part 147.35 

Current CFR Part 147.35 Proposed Changes to CFR Part 147.35 

(a) Upon request, each certificated aviation 

maintenance technician school shall provide 

a transcript of the student's grades to each 

student who is graduated from that school or 

who leaves it before being graduated. An 

official of the school shall authenticate the 

transcript. The transcript must state the 

curriculum in which the student was 

enrolled, whether the student satisfactorily 

completed that curriculum, and the final 

grades the student received. 

(a) Upon request, each certificated aviation 

maintenance technician school shall provide 

a transcript of the student's grades to each 

student who is graduated from that school or 

who leaves it before being graduated. An 

official of the school shall authenticate the 

transcript. The transcript must state the 

curriculum in which the student was 

enrolled, whether the student satisfactorily 

completed that curriculum, and the final 

grades the student received. 

No Changes 

(a) Upon request, each certificated aviation 

maintenance technician school shall provide 

a transcript of the student's grades to each 

student who is graduated from that school or 

who leaves it before being graduated. An 

official of the school shall authenticate the 

transcript. The transcript must statejhe 

curriculum in which the student was 

enrolled, whether the student satisfactorily 

completed that curriculum, and the final 

grades the student received. 

(a) UporTrequest, each certificated aviation 

maintenance technician school shall provide 

a transcript of the student's grades to each 

student who is graduated from that school or 

who leaves it before being graduated. An 

official of the school shall authenticate the 

transcript. The transcript must state the 

curriculum in which the student was 

enrolled, whether the student satisfactorily 

completed that curriculurti; and the final 

grades the student received. 

No Changes 

45 
^ 

Proposed Changes to CFR Part 147.35 continued 

(c) Whenever an aviation maintenance 

technician school certificated under part 147 

of this chapter shows to an FAA inspector 

that any of its students has made satisfactory 

progress at the school and is prepared to 

take the General Knowledge test prescribed 

by §65.75, that student may take the test 

during their subsequent training in the 

approved curriculum, before they meet the 

^plicable experience reguken^nts of 

§65.77 and before he/she passes Airframe 

and/or Powerplant written test prescribed by 

§65.75. 

The school will prepare and issue a 

Certification of Completion to identify and 

report students who are eligible for testing 

under this part. An official of the school 

shall authenticate the certificate. The 

certificate must show the completion date 

and the approved curriculum title. The 

authority for a school to issue a certificate of 

completion for the General curriculum 

testing will be authorized in a Training 

Specification paragraph. 

New Subpart & Language 

i:*if-fiJi»- ^ 

46