AFS-16-7536-E March 28, 2016

Exemption No. 15841 Regulatory Docket No. FAA-2012-1338

Mr. Charles Hilton Aviation Department Head

Connecticut Aero Tech Center 500 Lindbergh Drive Hartford, CT 06114

Dear Mr. Hilton:

This letter is to inform you that we have granted your request for exemption. It transmits our decision, explains its basis, and gives you the conditions and limitations of the exemption, including the date it ends.

The Basis for Our Decision

By letter dated November 5, 2015, you petitioned the Federal Aviation Administration (FAA) on behalf of Connecticut Aero Tech Center (CATC) for an exemption from § 65.75(a) of Title 14, Code of Federal Regulations (14 CFR) to the extent necessary to allow CATC students to take the Aviation Mechanic General (AMG) written test at an affiliated test center immediately following successful completion of the general curriculum, prior to meeting the experience requirements of 14 CFR § 65.77.

The FAA has determined that good cause exists for not publishing a summary of the petition in the Federal Register because the requested exemption would not set a precedent, and any delay in acting on this petition would be detrimental to CATC.

Although you requested an extension of Exemption No. 10695, that exemption expired on December 31, 2015. Therefore, we are issuing CATC a new exemption.

The FAA has issued a grant of exemption in circumstances similar in all material respects to those presented in your petition. In Grant of Exemption No. 10695 (copy enclosed), the FAA2

found that testing immediately after learning was a universally accepted instructional principle that reinforces learning.

Having reviewed your reasons for requesting an exemption, I find that—

 They are similar in all material respects to relief previously requested in the enclosed Grant of Exemption No. 10695;

 The reasons stated by the FAA for granting the enclosed Grant of Exemption No. 10695 also apply to the situation you present; and

 For the reasons stated in Grant of Exemption No. 10695, a grant of exemption is in the public interest.

Our Decision

The FAA is in the process of withdrawing or amending all previously granted exemptions to 14 CFR § 65.75(a), which enabled certain Aviation Maintenance Technician Schools (AMTSs) the ability to administer the AMG, Aviation Mechanic Airframe (AMA), and Aviation Mechanic Powerplant (AMP) written tests immediately following a student’s successful completion of the corresponding curricula. The FAA’s new and revised exemptions will only permit an AMTS to authorize students to take the AMG examination immediately after completing the corresponding curriculum, but will not allow students to take the AMA or AMP examinations before completing the corresponding curricula.

In consideration of the foregoing, I find in the present case that a partial grant of exemption is in the public interest. Specifically, certain conditions and limitations have been included in this exemption to ensure an equivalent level of safety with 14 CFR § 65.75(a). The conditions and limitations require CATC to develop written testing procedures, include those procedures in its operating document or manual, and obtain approval of those procedures from its Certificate Holding District Office (CHDO) to ensure that CATC’s educational program and curricula continue to meet FAA regulatory standards.

The additional conditions and limitations of this exemption also require that CATC must retrain any student on the specific instructional items associated with a failed AMG test and authorize the student to retake the test. This would be applicable prior to any CATC retesting of a student who has failed the AMG test and who also does not meet the experience requirements of 14 CFR § 65.77.

To be clear, any student who is eligible to take the AMG test, on the basis of his or her own experience, and who does not need to rely on this exemption, may retrain according to 14 CFR § 65.19 - including with any appropriately certificated airmen. However, this exemption also creates a population of students who do not satisfy the 14 CFR § 65.77 experience requirements, and who are eligible to retake the AMG test, only because of the exemption granted to CATC. To maintain an equivalent level of safety, this exemption requires CATC to retrain those students itself, using its written procedures, its FAA-approved3

curricula and in accordance with the FAA’s AMTS standards, including the quality of instruction standards, codified in 14 CFR § 147.38(a).

Under the authority contained in 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator has delegated to me, I hereby grant Connecticut Aero Tech Center an exemption from 14 CFR § 65.75(a) to the extent necessary to allow CATC students to take the Aviation Mechanic General (AMG) written test at an affiliated test center immediately following successful completion of the general curriculum, prior to meeting the experience requirements of 14 CFR § 65.77, subject to the conditions and limitations described below.

Conditions and Limitations

1. CATC must develop written procedures for administering the AMG written test following successful completion of the general curriculum.

2. CATC must ensure these procedures are available for use in its approved operating or curriculum procedures document or manual.

3. Before retesting a student who has failed the AMG examination, and also does not meet the experience requirements of 14 CFR § 65.77, CATC must require the student to repeat each instructional item associated with the failed test and receive

authorization from CATC to retake the test. CATC must have procedures for documenting and tracking compliance with all retesting procedures.

4. Before exercising the privileges of this exemption, CATC must provide revised procedures to its CHDO for review and approval.

This exemption terminates on March 31, 2018, unless sooner superseded or rescinded.

Sincerely,

//s//

John S. Duncan Director, Flight Standards Service

Enclosure Exemption No. 10695