AFS-15-164-E

May 7, 2015

 Exemption No. 11497

 Regulatory Docket No. FAA-2008-1352

Mr. Richard L. Naves

Training Director

Toledo City 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 date it ends.

The Basis for Our Decision

By letter dated November 16, 2014, you petitioned the Federal Aviation Administration 

(FAA) on behalf of Toledo City School District d.b.a. Aerospace Center (Aerospace) for an

extension of Exemption No. 9814. That exemption granted relief from § 65.75(a) of Title 14

of the Code of Federal Regulations (14 CFR), and allowed students enrolled in Aerospace’s 

part 147 Aviation Maintenance Technician School (AMTS), in Swanton, OH, operating under

Air Agency Certificate AE9T005R, 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 

requirements of 14 CFR § 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 conditions and limitations of your prior exemption, in accordance with our 

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

On January 29, 2009, the FAA granted Aerospace an “exemption from 14 CFR § 65.75(a) so 

that Aerospace students may take the airframe and powerplant written tests after completing 
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the corresponding portion of the curriculum, before they meet the experience 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 students 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 grants 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 practical tests to 

obtain a mechanic certificate. Under § 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 students must satisfy 

§ 65.77 before taking any written tests. By granting 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 student 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 find 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 Center, 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 general 

curriculum. 

2. Aerospace must ensure these procedures are available for use in Aerospace’s approved 

operating or curriculum procedures document or manual.
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3. Before retesting any student who has failed the AMG examination and also does not 

meet the experience 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. Aerospace 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 for 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 Decision

This exemption terminates on May 30, 2017, unless sooner superseded or rescinded.

Sincerely,

/s/

Michael J. Zenkovich

Deputy Director, Flight Standards Service