March 16, 2012

U.S. Department of Transportation

Document Management System

400 7th 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) written tests to be administered after completing the corresponding portion of the 

curriculum.

Dear Sir or Madam,

Spartan Aviation Industries 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 administered 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 written test, “after meeting the experience requirements of Part 65.77.”

§65.77 requires applicants to complete training and, “present either an appropriate graduation certificate 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 experience 

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, Powerplant, or Airframe and Powerplant curricula.

Information, 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 Powerplant 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 & Powerplant 

curriculum. The vast majority opts for the combined curriculum. This petition is structured to provide an opportunity 

for testing after the completion of any section of the curriculum (General, Airframe, Powerplant) 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 written test center. The same procedure would be used to identify and report students who would 
U.S. Department of Transportation: Page 2

qualify to take the AMG written test after completion of the General curriculum, the AMA written test after completion 

of the Airframe curriculum, and AMP after completion of the Powerplant curriculum. A certificate of completion 

would be issued after the successful completion of each of major subject areas, ie the general, airframe and powerplant 

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 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.

Public Interest: The public interest will be served by allowing aviation maintenance technician students to take the 

FAA written 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 experience. 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 the affiliated written 

test center. The same procedure would be used to identify and report students who would qualify to take the Aviation 

Mechanic written tests after the completion of the corresponding portion of the 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: There will be no impact on the economy.

SUMMARY OF PETITION

The purpose of this petition is to allow the Aviation Mechanic written 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 Aeronautics 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 you may be able to provide us in 

accomplishing these petitions.

Respectfully Submitted,

Ryan Goertzen

Vice President, Education

Spartan College of Aeronautics and Technology

8820 E. Pine St.

Tulsa, OK 74158-2833

(918) 836-6886