AFS

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May 7 , 2015

Exemption No. 11497 Regulatory Docket No. FAA

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- 1352

Mr. Richard L. Naves Training Director

Toledo C ity School District d.b.a. Aerospace Center

11791 West Airport Service Road Swanton, OH 43558

Dear Mr. Naves :

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

The Basis for Our Decision

By letter dated November 16 , 201 4

, you petitioned the Federal Aviation Administ ration (FAA) on behalf of Toledo City School District d.b.a. Aerospace Center (Aerospace) for an

extension o f Exemption No. 9814 . That ex emption granted relief from § 65.75(a) of Title 14

of the Code of Federal Regulati ons (14 CFR), and allow ed students enrolled in Aerospace’s part 147 Aviation M aintenan ce T echnic ian S chool (AMTS)

, in Swanton, OH , operating under Air Agency Certificate AE9T 005R , to take the Aviation Mechanic General (AMG), Aviation Mechanic Airframe (AMA), and Aviation Mechanic Powerplant (AMP) written tests after completing the corresponding portion of the curriculum, but prior to meeting the experience

r equirements of 14 C FR § 65.77 . Exemption No. 9814 , as amended, expired on January 31,

2015 ; therefore

, we treat your request for an extension as a petition for a new exemption

. We

also amend the con ditions and limitations of your prior exemption , in accordance with our

ong oing efforts to standardize § 65.75 exemptions, and as described in greater detail below.

On January 29, 2009, the FAA granted Aerospace an “exemption fro m 14 CFR § 65.75(a) so that Aerospace students may take the airframe and powerplant written tests aft er completing2

the corresponding portion of the curriculum, before they meet the expe rience requirements of § 65.77.” In the past, the FAA granted this and similar § 65.75 exemptions to enable AMTSs

to administer the AMG, AMA, and AMP written tests to stude nts immediately following successful completion of the airframe and/or powerplant curriculums but before meeting the § 65.77 experience requirements. The FAA has reassessed its prior grant s of exemption to § 65.75(a)

, including the grant to Aerospace

.

The FAA’s reevaluation of § 65.75(a) exemptions stemmed from our discovery of a loophole that could potentially have allowed students to totally circumvent our experience requirements. Students must, among other things, take written, oral, and practi cal tests to

obtain a mechanic certificate. U nder § 65.80, an AMTS may under some circumstances administer a student’s required oral and practical tests before the student satisfies the experience requirements of § 65.77. Under § 65.75(a), however, all s tudents must satisfy § 65.77 before taking any written tests. By gran ting Aerospace’s request to allow students to take the AMA and AMP written tests before completing the experience requirements in § 65.77, we could inadvertently enable those students to totally circumvent our experience requirements, because a student could obtain a copy of his or her academic record indicating that the student has passed the AMA or AMP examinations, and provide that record to another school without disclosing that the s tudent never satisfied the appropriate experience requirements. The FAA is therefore taking action to amend our previous AMTS § 65.75(a) exemptions by re

- issuing each of them as a partial grant of exemption.

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

Our Decision

In consideration of the foregoing, I fin d that a partial grant of exemption would best serve the public interest. Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40113, and 44701, delegated to me by the Administrator, I grant Toledo City School District d.b.a. Aerospace C enter

, operating under Air Agency Certificate AE9T005R, an exemption from

14 CFR § 65.75(a) to administer the AMG written test to students immediately following successful completion of the general curriculum, and before meeting the experience requirements of 14 CFR § 65.75(a), subject to the conditions and limitations below.

Conditions and Limitations

1. Aerospace must develop written procedures for administering the AMG written test to Aerospace students immediately following successful completion of the g eneral

curriculum.

2. Aerospace must ensure these procedures are available for use in Aerospace’s approved operating or curriculum procedures document or manual.3

3. Before retesting any student who has failed the AMG examination and also does not meet the exp erience requirements of § 65.77, Aerospace must retrain the student on

the entire instructional unit associated with the failed test and authorize the student to

retake the test. A erospace must have procedures for documenting and tracking compliance with all retesting procedures.

4. Before exercising the privileges of this exemption, Aerospace must provide the revised procedures to its Certificate Holding District Office for review and approval.

Aerospace’s request f

or an exemption from § 65.75(a) to enable Aerospace to administer the AMA and the AMP written tests to a student after that student has completed the corresponding portion(s) of the curriculum, but prior to meeting the experience requirements of 14 CFR § 65.77, is denied.

The Effect of Our Decis ion

This e x e mp t ion t e rmin a tes on May 30 , 201 7 , unless soon e r sup e rs e d e d or re s c inded.

Sincerely,

/s/

Michael J. Zenkovich Deputy Director, Flight Standards Service