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# - ENTERPRisEI0"''sTATE COMMUNITY COLLEGE**~ALABAMA** AVIATION CENTER
OFFICE OF THE PRESIDENT

November 30, 2015
U.S. Department ofTransportation, 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/relieffrom Title 14 CFR Part 65.77 to allow students to enter written examination at the completion ofthe 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 ofwhich are requesting this exemption. This request is for the facility located at 1975 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 ofthe 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. Ifgranted 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 ofteaching 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 • @EnterpriseSrateoptimal learning environment because ofstudent concerns about the volume ofinformation in upcoming examinations. The students tendto focus a great deal oftheir time andeffort engaging inrotememorization drills rather thantruly learning the material being presented. Wefeel that allowing the students to entertheir exit examinations and FAA writtentests as they finish each of the required curriculums in CFRPart 147 appendicies B,C, and D would diminishthe stress involved inlookingbackover a year ofmaterial thus producing graduatesthat have been affordedthe opportunity to place more focus onlearningthe subject matter andbeing able to apply the information. The College feels thatwe could produce graduates withimproved knowledge, skills, and abilitywhichwould leadto an increase inpublic 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 curriculumwill leadto increased learning and decrease the need to focus onrote memorization as a means to pass the
exams. CFRPart 

### 65.75, 65.77, and 

### 65.79 ensures thatno student could enter the Oral and Practicalportion ofthe certificationuntil the General and Airframe and/ or Powerplantportions ofthe curriculmnhave beencompleted. The College would communicate, inwriting, with our affiliatedwritten test center andDMEs to ensure onlythe students that metthe requirements would be able to complete the certificationprocess.
Thank youin advance for your time and consideration.
Sincerely,

Vicky Ohlson, PhD InterimPresident vohlson@escc.edu 334-347-2623, ext. 2262