Aviation Institute of Maintenance 

9636 Earhart Road• Oakland, CA 94621 ~ ~elephone (510)553-9600 

August 26, 2014 

U.S. Department of Transportation 

Document Management System 

400 7th Street, SW., Room PL 401 

Washington, DC 20591-0001 

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Subject: Petition for exemption from Code of Federal Regulations 14 CFR, Part 65.75(a) to allow the Aviation 

Mechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion 

ofthe curriculum. 

Dear Sir or Madam, 

Training Services Inc., d/b/a Aviation Institute of Maintenance (AIM) operates an FAA Approved Aviation Maintenance Technician 

School (AMTS) in Oakland, CA, under Air Agency Certificate 2AQT602K. 

PETITION: 

AIM 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: AIM 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 ofthe 

curriculum, prior to meeting the experience requirements of §65.77. · . 

Person(s) to be covered by the exemption: AIM, Air Agency 2AQT602K and students enrolled in its AMTS program in the Airframe 

and Powerplant curricula. 

Information, views, or arguments to suooort 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 are enrolled in the combined Airframe & Powerplant 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. 

AIM has established a procedure with the Oakland, CA Flight Standards District Office 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 on-site written test center. The same procedure used 

to identify and report students who qualify to take the AMG written test after completion of the General curriculum, would be used to 

identify those eligible to take the AMA written test after completion of the Airframe curriculum and the AMP written test after 

completion of the Powerplant curriculum. A graduation certificate or certificate of completion would only be issued after the successful 

completion of the entire program in which the student is enrolled (Airframe & Powerplant). 

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:· .· ·~~ . ~· :. . . ~ .. :: ·!; }'·t,; ''.' \:' 

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

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 increase retention rates. 

This petition does not differ materially from others on record, specifically Exemption number 10836, 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 Oakland, CA FSDO and the on-site 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: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow 

students to take each written examination after completing the corresponding portion of the curriculum. 

Aviation Institute ofMaintenance appreciates any assistance you may be able to provide us in accomplishing these petitions. 

erald Y agen, Pr side 

~ viation Institute aintenance 

Corporate Offices 

4455 South Boulevard 

Virginia Beach, VA 23452-1159 

(757) 490-3151