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 complete d the AMT curriculum provided by our Part 147 approved school had to wait until they co mplete d G e neral and Airframe courses or G eneral and Powerplant courses to be el igible to take the FAA General written t est. We were granted an exemption that allow ed students to take the written test upon completion of the General c ourses . T he 24

- month limitation contained in Sectio n 65.71 paragraph (a) 3 remain s unaffected and the time limit commence s with the passing of the General written test. Also, Section 65.75 Paragraph (b) remain s unchanged. In summary , the exemption allow s individuals who complete all of the courses contain ed 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 b y approving the extension to the exemption, because we at Metro Technology Centers will be able to cont inue to provide a higher quality

of instruction. As a part of our ongoing quality initiative, Metro Tech seek s continuous improvement. As part of our continuous improvement process we gather test results data from the FAA N orms 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. T he General test data in particular might be 9 to 15 months old. Inthe meantime, three to nine classes could have completed the G eneral 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 co mpletes the test and test results are published , we record the areas that were missed. We compil e this information and share it with our faculty. This data is also considered to be “stale” because the materialmight have been taught from 6 months to 12 mo nths before the FAA written test was administered. We document and track our test results based upon data from the FAA Norms report. C ontinuing to allow students to take the FAA General t est after c ompleting the part 147 General c urriculum will result in test ing them on material that was presented in a time range of from a few day s 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 academicall y better equipped Aviation Maintenance Technician s
. The public interest will be served b y having a portion of the workforce receive training that was subject to a timely conti nuous 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 mate rial. 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 AMT s onl y after completing the applicable written tests and the applicable oral and practical examinations administered b y 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 certificate s 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 ex emption 9846B which allows an individual to take an GAA generalknowledge test prior to fulfilling the requirements contained in 14 CFR Part 65.75 P aragraph (a).
2. If approved , the exemption extension will continue to allow s tudents of Metro Technology Centers , a Part 147 school (BE9T031R) , to take the FAA General Studies written test after complet ing all of the General Studies curriculum consisting of 495 hours. The 24

- month time limit contained in Section 67.71 P aragraph (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.