# Aviation Institute ofMaintenance

2211 South Military Highway • Chesapeake, VA 23320 • Telephone (757) 363-2121 August 26,2014

U.S. Department ofTransportation DocumentManagement System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001**~···.**

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. Dear Sir or Madam, ( ..

Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Chesapeake, Virginia, under Air Agency Certificate LQPT037K. 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**por~ion** ofthe curriculum. 

### 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants niustpass a written test, "after meetingthe 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 completing the correspondingportion ofthe curriculum, prior to meeting the experience requirements of§65.77. Person(s) to be covered by the exemption: AIM, Air Agency LQPT037K and students enrolled in its AMTS program in the Airframe and Powerplant curricula. Information, views, or arguments to supportthe 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 atthe 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 Richmond Flight Standards District Office to identify and report graduates who are eligible to take the FAA written, oral, andpractical tests toboth the FSDO and the school's on-site written test center. The same procedure used to identify and report students who qualify to**taketh~** AMG written test 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 written test after completion ofthe Powerpiant curriculum. A graduation certificate 'or certificate ofcompletion would onlybe issued after the successful completion ofthe entire program in whichthe student isenrolled (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 student to take the oral and practical tests prescribed by §65.79 before they meetthe applicable experience requirements of§65.77. Thetime penalty incurred by beginning the testing pr.ocess before the completion ofthe entire curriculum would be more than offsetby the academic soundness ofimmediate testing. ·Public Interest: The public interest will be servedby allowing aviation maintenance technician students to take the FAA writtentests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforcedbythe immediate feedback providedbythe 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 onrecord, specifically Exemption number 10836, and those requests have been deemedto be in the public interest. Impact on Safety: A procedure is currently inplace to identify and report students who are eligible to take the FAA written, oral and practicaltests. This information is distributed to the Richmond 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 ofthe corresponding portion ofthe curriculum. All other requirements governing written testing, including time requirements for licensure completion wouldremain unchanged. A level ofsafety equal to thatprovided bythis rule would be provided. Economic Impact: There will beno impact onthe economy.

SUMMARY OF PETITION Thepurpose ofthis petition is to allowthe 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: ReliefRequested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow students to take each written examination after completing the corresponding portion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you maybe able to provide us in accomplishing these petitions.

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