# Aviation Institute ofMaintenance
9636 Earhart Road• Oakland, CA 94621**~ ~elephone**  (510)553-9600 August 26, 2014
U.S. Department ofTransportation Document Management System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 ! . I

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Subject: Petition for exemption from Code ofFederal 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. DearSir or Madam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Oakland, CA, underAir Agency Certificate 2AQT602K. PETITION: AIMis requesting an exemption from 

### 14 CFR, Part 65.75(a) to allow theAviation Mechanic written tests (AMG, AMA, AMP) to be administered after completingthe corresponding portion ofthe curriculum. 

### 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass a written test, "after meeting the experience requirements ofPart 65.77." §65.77 requires applicants to complete training and, "present either an appropriate graduation certificate or certificate ofcompletion from a certificated aviation maintenance technician school" before being eligible to take the written test for a certificate or rating. ReliefSought: AIM is seeking exemption from 14 CFRPart 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 completingthe 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 instructionalprinciple thatreinforces learning, and is academically sound. This is currently allowed with boththe Airframe and Powerplant curriculums, but is not allowed at the completion ofthe 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 ofany section ofthe curriculum (General, Airframe, Powerplant) regardless ofthe type of enrollment. AIMhas 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 practicaltests to boththe 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 writtentest after completion ofthe General curriculum, would be used to identifythose eligible to take the AMA written test after completion ofthe Airframe curriculum and the AMP writtentest after completion ofthe Powerplant curriculum. A graduation certificate or certificate ofcompletion would only be issued after the successful completion ofthe entire program in which the student is enrolled (Airframe & Powerplant). The exceptional circumstances encountered by students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 which permits a studentto take the oral and practical tests prescribedby §65.79 before they meet the applicable experience requirements of§65.77. The time penalty incurred by beginning the testing process before the completion ofthe entire .curriculum would be more than offsetby the academic soundness ofimmediate testing:·

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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 ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforcedbythe 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 deemedto be in the public interest. Impact on Safety: A procedure is currently in place to identify andreport students who are eligible to take the FAA written, oral and practicaltests. This information is distributed to the Oakland, CA FSDO and the on-site writtentest center. The same procedure would be used to identify and report students who would qualify to take the AviationMechanic writtentests after the completion ofthe correspondingportion ofthe curriculum. All otherrequirements governing written testing, including time requirements for licensure completion would remain unchanged. A level ofsafety equal to thatprovidedbythis rule wouldbe provided. Economic Impact: There will be no impact on the economy.
SUMMARY OF PETITION The purpose ofthis petition is to allow the Aviation Mechanic written test (AMG, AMA, AMP) to be administered priorto graduating from the entire curriculum. 14 CFR, Part 65.75(a) Knowledge Requirements: ReliefRequested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow students to take eachwritten examination after completingthe corresponding portion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you may be able to provide us in accomplishing these petitions.

erald Yagen, Pr side**~**viation Institute aintenance Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757) 490-3151