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 FAA 
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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-approved 
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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