The following information is being provided in accordance with Title 14, Part 11 Subpart 

A Section 11.81

(A) Contact Information:

 Peter H Lee

 5600 South MacArthur Blvd.

 Oklahoma City, Oklahoma 73179

 Phone: 405-605-5500

 Fax: 405-681-5644

 Email: pete.lee@metrotech.edu

(B) Section of 14 CFR from which we are seeking exemption:

 14 CFR Part 65.75 Paragraph (a)

(C) Metro Technology Centers is seeking an extension to Exemption No. 9846B; 

Regulatory Docket No. FAA-2008-1121 dated 20 November 2012 which expires 

April 30, 2015. It is an extension 9846 granted in 2009.

(D) Previously, students who completed the AMT curriculum provided by our Part 

147 approved school had to wait until they completed General and Airframe 

courses or General and Powerplant courses to be eligible to take the FAA General 

written test. We were granted an exemption that allowed students to take the 

written test upon completion of the General courses. The 24- month limitation 

contained in Section 65.71 paragraph (a)3 remains unaffected and the time limit 

commences with the passing of the General written test. Also, Section 65.75 

Paragraph (b) remains unchanged. In summary, the exemption allows individuals 

who complete all of the courses contained in our Part 147 General Studies 

curriculum to be permitted to take the FAA General written test upon completion.

(E) The public interest will be served by approving the extension to the exemption, 

because we at Metro Technology Centers will be able to continue to provide a 

higher quality of instruction. 

As a part of our ongoing quality initiative, Metro Tech seeks continuous 

improvement. As part of our continuous improvement process we gather test 

results data from the FAA Norms data site. We share that data with our faculty so 

they can identify areas where there are opportunities for improvement. Because 

of the timing of the posting, the data provided is “stale” and may not be 

completely useful. The General test data in particular might be 9 to 15 months 

old. In the meantime, three to nine classes could have completed the General 

curriculum before meaningful changes are implemented. 

Metro Tech students take the written tests at an FAA-approved test site that Metro 

Tech operates. Once the student completes the test and test results are published,

we record the areas that were missed. We compile this information and share it 

with our faculty. This data is also considered to be “stale” because the material 
might have been taught from 6 months to 12 months before the FAA written test 

was administered. 

We document and track our test results based upon data from the FAA Norms 

report. 

Continuing to allow students to take the FAA General test after completing the 

part 147 General curriculum will result in testing them on material that was 

presented in a time range of from a few days to no more than 6 months from the 

test date. By using the data collected from the printed test results, we are be able 

to emphasize, update, and/or change material with the then current General class. 

This will result in better trained and academically better equipped Aviation 

Maintenance Technicians. 

The public interest will be served by having a portion of the workforce receive 

training that was subject to a timely continuous improvement process. 

(F) Why safety will not be affected:

There will be no adverse affect on safety because students will still have to 

complete the applicable written test (Airframe or Powerplant) before being 

eligible to take the oral and practical examinations that lead to certification. 

Additionally, a completion certificate for the FAA General test has printed on the 

certificate that the certificate is valid only for testing at the FAA approved test site 

located on premises. This quality control measure ensures that General only tests 

cannot be attempted at any other test location. Should a test applicant fail a 

general written test, the completion certificate is retained and the individual must 

retake the pertinent courses of missed subject material. 

Certificated Aviation Maintenance Technicians (AMT) will contribute to the 

overall aviation safety in the United States. The process that we propose will

continue to ensure that graduates from Metro Technology Centers will work as 

certificated AMTs only after completing the applicable written tests and the 

applicable oral and practical examinations administered by a Designated 

Mechanic Examiner (DME). In order to take the oral and practical examinations 

an individual must present test results from the General test and the Airframe or 

Powerplant tests. The DME is not permitted to administer any test until the 

applicable test results are presented. If Metro Tech students wish to test with a 

DME that is not affiliated with Metro Tech, the student must present their course 

completion certificates and test results to the local Flight Standards District Office 

for approval as is documented on FAA 8610-2.

(G) Summary for the Federal Register:

1. Metro Technology Centers seeks an extension to exemption 

9846B which allows an individual to take an GAA general 
knowledge test prior to fulfilling the requirements contained in

14 CFR Part 65.75 Paragraph (a).

2. If approved, the exemption extension will continue to allow 

students of Metro Technology Centers, a Part 147 school 

(BE9T031R), to take the FAA General Studies written test after 

completing all of the General Studies curriculum consisting of 

495 hours. The 24-month time limit contained in Section 67.71 

Paragraph (a)3 will begin upon the successful completion of the 

General Test. The requirement in Section 65.75 (b) to have 

completed the written exams prior to taking oral and practical 

exams will remain unchanged.