October 1, 2013

U.S. Department of Transportation Document Management System

400 7 th 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 Mecha nic (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 cor responding 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 certif icate 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 correspond ing 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, vi ews, 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 curr iculums, 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 complet ion of the General curriculum. A graduation certificate or certificate ofcompletion would only be issued after the successful completion of the entire program in which the student is enrolled (Airframe, Powerplant, or Airframe & Powerplant).

The excepti onal 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 require ments 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 a llowing 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 provi ded 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 thos e 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 ot her 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 I nstitute of Maintenance is petitioning for an exemption from this

rule to allow students to take the G eneral 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