# Aviation Institute ofMaintenance

... 3001 Grant Ave • Philadelphia, PA• J:e)ephone (215)676-7700 August 26, 2014

U.S. Department ofTransportation DocumentManagement System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 ,. ,..**~**
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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 orMadam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Philadelphia, PA, under Air Agency Certificate AR9T018R. 

### 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 portion ofthe curriculum. 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass a written test, "after meeting the 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 orrating. 

### 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, priorto meeting the experience requirements of §65.77. · 

### Person(s) to be covered 

### by the exemption: AIM, Air Agency AR9T018R 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 withboththe Airframe and Powerplant curriculums, butis not allowed at the completion ofthe General curriculum. Students attending the school are enrolled inthe 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. AIM has established a procedure with the Philadelphia, PA Flight Standards District Office to identify andreport graduates who are eligible to take the FAA written, oral, and practical tests to both the FSDO andthe school's on-site written test center. The same procedure used to identify and report students who qualify to take the AMG written test after completion ofthe General curriculum, wouldbe used to identify those eligible to take the AMA written test after completion ofthe Airframe curriculum and the AMP written test after completion ofthe Powerplant curriculum. A graduation certificate or certificate ofcompletion would onlybe issued after the successful completion ofthe entire program inwhich the student is enrolled (Airframe 

### & Powerplant). The exceptional circumstances encounteredby students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 which permits a studentto take the oral and practical tests prescribedby §65.79 before they meetthe applicable experience requirements of§65.77. The time penalty**inc~ed** by beginningthe testing process before the completion ofthe entire curriculum would be more than offsetby the academic soundness ofimmediate testing. '

### Public Interest: The public interest willbe servedby allowing aviation maintenance technician students totake the FAA written tests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforced bythe immediate feedback provided bythe 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 in place to identify and report students who are eligible to take the FAA written, oral and practicaltests. This information is distributed to the Philadelphia, PA 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 be no impact on the economy.



### SUMMARY OF PETITION The purpose ofthis petition is to allow the Aviation Mechanic written test (AMG, AMA, AMP) to be administered priorto 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 may be able to provide us in accomplishing these petitions.

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