-• 

- ENTERPRisEI0"''sTATE 

COMMUNITY COLLEGE ~ALABAMA AVIATION CENTER 

OFFICE OF THE PRESIDENT 

November 30, 2015 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE 

Washington, DC 20590 

SUMMARY: Alabama Aviation Center (AAC) is seeking an exemption/relief from Title 14 CFR 

Part 65.77 to allow students to enter written examination at the completion of the General subject 

matter as described in CFR Part 147 Appendix B. The AAC has three separate training facilities 

in Alabama operated by Enterprise State Community College, all three of which are requesting 

this exemption. This request is for the facility located at 197 5 A venue C, Mobile, AL 36615-

1403. 

To whom it may concern: 

Alabama Aviation Center, air agency QLAT006K, is seeking an exemption from Title 14 

CFR Part 65.77. Alabama Aviation Center is an AMTS that is approved to offer the Airframe 

and Powerplant curriculum. Currently, our students are required to complete the General portion 

of the curriculum as well as the Airframe or Powerplant portions before being allowed to take the 

College exit examination and enter FAA written examinations. This procedure requires our 

students to complete our exit exam up to a full year after completing the General curriculum and 

subsequent Airframe curriculum. If granted the exemption, students completing the General 

curriculum, typically after the first semester, would be allowed to take the exit examination and 

enter FAA written, not the Oral and Practical, testing immediately after the subject matter is 

completed and while the information is current. This change in process would provide the 

students with an opportunity to focus solely on the subject matter following in subsequent 

semesters in the Airframe and/or Powerplant curriculum. 

The College understands the value of teaching the subject matter and applies sound 

educational principles to ensure our graduates are able to demonstrate the knowledge, skills, and 

ability as prescribed by CFR Part 147 appendicies. Currently, the semester in which the students 

are preparing to take the College exit examinations and enter FAA testing provides less than an 

600 Plaza Drive • Enterprise, AL 36330 • (334) 347-2623 • escc.edu • facebook.com/weevils • @EnterpriseSrate 
optimal learning environment because of student concerns about the volume of information in 

upcoming examinations. The students tend to focus a great deal of their time and effort engaging 

in rote memorization drills rather than truly learning the material being presented. We feel that 

allowing the students to enter their exit examinations and FAA written tests as they finish each of 

the required curriculums in CFR Part 147 appendicies B,C, and D would diminish the stress 

involved in looking back over a year of material thus producing graduates that have been 

afforded the opportunity to place more focus on learning the subject matter and being able to 

apply the information. The College feels that we could produce graduates with improved 

knowledge, skills, and ability which would lead to an increase in public safety. 

The College feels that an exemption would not adversely affect safety. We feel that 

allowing our students to test as they complete each section ofthe curriculum will lead to 

increased learning and decrease the need to focus on rote memorization as a means to pass the 

exams. CFRPart 65.75, 65.77, and 65.79 ensures that no student could enter the Oral and 

Practical portion of the certification until the General and Airframe and/ or Powerplant portions 

of the curriculmn have been completed. The College would communicate, in writing, with our 

affiliated written test center and DMEs to ensure only the students that met the requirements 

would be able to complete the certification process. 

Thank you in advance for your time and consideration. 

Sincerely, 

Vicky Ohlson, PhD 

Interim President 

vohlson@escc.edu 

334-347-2623, ext. 2262