March 16 , 201 2

U.S. Department of Transportation Document Management System 400 7 th Street, SW., Room PL 401 Washington, DC 20591

- 0001
Subject: Petition for exemption from Code of Federal Regulations 14 CFR, Part 65.75(a) to allow the Aviation Mechanic (AMG) w

ritten tests to be administered after completing the corresponding portion of the curriculum. Dear Sir or Madam, Spartan Aviation Industr ies Inc, d/b/a Spartan College of Aeronautics and Technology operates an FAA Approved Aviation Maintenance Technician School (AMTS), in Tulsa, Oklahoma , under Air Agency Certificate CB9T054R **PETITION: Spartan College of Aeronautics and Technology is**  **requesting an exemption from 14 CFR, Part 65.75(a) to allow**  **the Aviation Mechanic written tests (AMG, AMA, AMP) to be adm inistered after completing the corresponding**  **portion of the curriculum. 14 CFR Part 65.75(a) Knowledge Requirements:**  Title 14 of the Code of Federal Regulations, Part 65.75(a) prescribes that applicants must pass a w ritten test, “after meeting the experience requirements of Part 65.77.” § 65.77 requires applicants to complete training and, “present either an appropriate graduation certi ficate or certificate of completion from a certificated aviation maintenance technician school” before being eligible to take the written test for a certificate or rating. **Relief Sought:** Spartan College of Aeronautics and Technology is seeking exemption from 14 CFR Part 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 completing the corresponding portion of the curriculum, prior to meeting the exper ience requirements of §65.77. **Person(s) to be covered by the exemption:** Spartan College of Aeronautics and Technology , Air Agency CB9T054R and students enrolled in its AMTS program in the Airframe, Pow erplant, or Airframe and Pow erplant curricula. **Infor ma**  **tion, views, or arguments to support the action sought:** 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 Pow er

plant curriculums, but is not allowed at the completion of the General curriculum. Students attending the school may be enrolled in a single

- rating program, or the combined Airframe & Pow erplant curriculum. The vast majority opts for the combined curricu lum. This petition is structured to provide an opportunity for testing after the completion of any section of the curriculum (General, Airframe, Pow erplant) regardless of the type of enrollment. Spartan College of Aeronautics and Technology has established a procedure with the Oklahoma City FSDO

- 15 to identify and report graduates who are eligible to take the FAA written, oral, and practical tests to both the FSDO and the school’s affiliated w

ritten test center. The same procedure would be used to identify and report students who w ouldU.S. Department of Transportation: Page 2

qualify to take the AMG written test after completion of the General curriculum, the AMA w ritten test after completion of the Airframe curriculum, and AMP after co mp letion of the Pow erplant curriculum. A certificate of completion wo uld be issued after the successful completion of each of major subject areas, ie the general, airframe and pow erplant portions of the curriculum. The exceptional circumstances encountered by students enrolled in a 14CFR Part 147 AMTS are recognized and provided for by 14CFR 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 tim e penalty incurred by beginning the testing process before the completion of the entire curriculum would be mo re than offset by the academic soundness of immediate testing. **Public Interest:** The public interest will be served by allowing aviation maintena nce technician students to take the FAA w ritten test covering a body of knowledge immediately following completion of their studies of that material. Student learning will be enhanced and reinforced by the immediate feedback provided by the testing experi ence. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and reduce dropout rates. This petition does not differ materially from others on record, and those requests have been deemed to be in the public interest. **Impact on Safety:** A procedure is currently in place to identify and report students who are eligible to take the FAA written, oral and practical tests. This information is distributed to the Oklahoma City FSDO and th e affiliated w ritten test center. The same procedure w ould be used to identify and report students who w ould qualify to take the Aviation Mechanic w

ritten tests after the completion of the corresponding portion of the curriculum. All other requirements g overning 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:** There w ill be no impact on the economy. **SUMMARY OF PETITION** The purpose of this petition is to allow the Aviation Mechanic w ritten test (AMG, AMA, AMP) to be administered prior to graduating from the entire curriculum. **14 CFR, Part 65.75(a) Knowledge Requirements:**

**Relief Requested** : Spartan College of Aeronaut ics and Technology is petitioning for an exemption from this rule to allow

students to take the written examination after completing the corresponding portion of the curriculum. Spartan College of Aeronautics and Technology appreciates any assistance yo u may be able to provide us in accomplishing these petitions. Respectfully Submitted,

Ry an Goertzen Vice President, Education Spartan College of Aeronautics and Technology 8820 E. Pine St. Tulsa, OK 74158

- 2833 ( 918 ) 836

- 6886