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O^^^^K 6225 Ulmerton Road 

Clearwater, Florida 33760 

800.659.2080 

New England 

Nationa l Aviatio n Academ y Bedford, Mfs!a"crusettTot73o 

800.292.3228 

www.naa.edu 

November 15,2010 

U.S. Department of Transportation j"i fbOjjc 

Docket Operations n ?^^>l5 

West Building Ground Floor ^ zzi^^~^ 

1200 New Jersey Avenue, SE, Room W12-140 ''^ g^s:- ^ 

Washington, DC 20591 2 ^ 

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

to allow the Aviation Mechanic General (AMG) written tests to be administered 

after completing the corresponding portion of the curriculum. 

Dear Sir or Madam, 

National Aviation Academy-New England (NAA-NE) operates an FAA Approved 

Aviation Maintenance Technician School (AMTS) in Bedford, Massachusetts under Air 

Agency Certificate EC6T068K 

PETITION. 

NAA-NE 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 AMTS students 

successfully complete the corresponding portion of the curriculum. 

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: 

NAA-NE 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 

written tests (AMG, AMA, AMP) 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: 

NAA-NE, Air Agency Certificate Number EC6T068K and students enrolled in its AMTS 

program in the Airframe, Powerplant and Airframe and Powerplant curricula. 
Exemption Request Page 2 of 3 

SUPPORT TO 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 are enrolled in the either the Airframe or Powerplant 

curriculum or the combined Airframe & Powerplant curriculum. This petition is 

structured to provide an opportunity for testing following the successful completion of 

the AMG (General), AMA (Airframe) or AMP (Powerplant) section of the curriculum. 

NAA-NE has established a procedure with the Boston Flight Standards District Office to 

identify and report to them in writing the graduates who are eligible to take the FAA 

written, oral, and practical tests and also to provide graduate information to the school's 

affiliated on-site written test center and the schools affiliated DME's. 

We are proposing that the same procedure would be used to identify and report to the 

Boston FSDO and the NAA-NE affiliated test center those students who are eligible to 

take the AMG written test after completion of the General curriculum. A Certificate of 

Completion is currently issued to the student who successfully completes the AMA 

and/or AMP curriculum. NAA-NE proposes to issue a Certificate of Eligibility to the 

students who have successfully completed the General (AMG) curriculum requirements. 

NAA-NE will continue to issue Certificates of Completion to students after the successful 

completion of the Airframe and/or Powerplant portions of the curriculum in which the 

student is enrolled. Additionally, the Certificate of Eligibility will be used to identify to 

the affiliated test center that the student is eligible to take the AMG written test. 

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. 
Exemption Request Page 3 of 3 

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 Boston 

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 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: 

By taking the written tests immediately after finishing the curriculum, the reduction of 

failed tests is expected to reduce the cost of testing to the students. 

SUMMARY OF PETITION: 

The purpose of this petition is to allow the Aviation Mechanic written test (AMG, AMA, 

AMP) to be administered prior to graduating from the entire curriculum. 

Therefore, an exemption to 14 CFR, Part 65.75(a) Knowledge Requirements is requested. 

National Aviation Academy-New England is petitioning for an exemption from this rule 

to allow students to take the written examination after completing the corresponding 

portion of the curriculum. 

National Aviation Academy-New England appreciates any assistance you may be able to 

provide us in accomplishing this petition. 

Respectfully Submitted, 

Paul M. Torpey 

Director of Education 

National Aviation Academy-New England 

CC: William J. Fullam, PMI 

Flight Standards District Office 

One Cranberry Hill, Suite 402 

Lexington, Massachusetts 02421 -73 94