October 1, 2013

U.S. Department of Transportation

Document Management System

400 7th Street, SW., Room PL 401

Washington, DC 20591-0001

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

Aviation Mechanic (AMG) written tests to be administered after completing the 

corresponding portion of the curriculum.

Dear Sir or Madam,

Technical Educational Services Inc., d/b/a Aviation Institute of Maintenance (AIM) operates an FAA 

Approved Aviation Maintenance Technician School (AMTS), in Las Vegas, Nevada under Air Agency 

Certificate 9VMT610K.

PETITION:

AIM is requesting an exemption from 14 CFR, Part 65.75(a) to allow the Aviation Mechanic 

GENERAL written test (AMG) 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 GENERAL written tests (AMG) 

after completing the corresponding portion of the curriculum, prior to meeting the experience requirements of 

§65.77.

Person(s) to be covered by the exemption: AIM, Air Agency 9VMT610K and students enrolled in its 

AMTS program in the Airframe and Powerplant curricula.

Information, views, or arguments to support 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 may be enrolled in a single-rating program, or the combined Airframe & 

Powerplant curriculum. The vast majority opts for the combined curriculum. This petition is structured to 

provide an opportunity for testing after the completion of the General section of the curriculum regardless of 

the type of enrollment.

AIM has established a procedure with the Las Vegas FSDO 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 affiliated written test 

center. The same procedure would be used to identify and report students who would qualify to take the 

AMG written test after completion of the General 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, or 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.

Public Interest: The public interest will be served by allowing aviation maintenance technician students to 

take the FAA written test 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 reduce dropout rates.

This petition does not differ materially from others on record, 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 Las Vegas, FSDO and the 

affiliated 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 General written test (AMG) to be administered 

prior to graduating from the entire curriculum.

14 CFR, Part 65.75(a) Knowledge Requirements:

Relief Requested: Aviation Institute of Maintenance is petitioning for an exemption from this 

rule to allow students to take the General written test (AMG) after completing the corresponding 

portion of the curriculum.

Aviation Institute of Maintenance appreciates any assistance you may be able to provide us in accomplishing 

these petitions.

Respectfully Submitted,

David L. Jones

Corporate Aviation Education Director

Aviation Institute of Maintenance

4455 South Boulevard

Virginia Beach, VA 23452