AFS-15-4041-E 

January 22, 2016 

 Exemption No. 14592 

 Regulatory Docket No. FAA-2013-0495 

Mr. Fred D. Dyen 

Professor & Coordinator 

Aviation Maintenance Technology Program 

Blue Ridge Community College 

43 Aviation Circle, Hangar 4 East 

Shenandoah Valley Regional Airport 

Weyers Cave, VA 24486 

Dear Mr. Dyen: 

This letter is to inform you that we are granting your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter dated March 30, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of BRCC for an extension of Exemption No. 10836, as amended. That exemption 

from 14 CFR § 65.75(a) allowed BRCC to administer the AMG written test to students 

immediately following successful completion of the general curriculum, and before meeting 

the experience requirements of § 65.77. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to BRCC. 

Although you requested an extension of Exemption 10836, as amended, that exemption 

expired on June 30, 2015. Therefore, we are issuing BRCC a new exemption. 

The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 10836, as amended (copy 

enclosed), the FAA agrees that learning will be enhanced and reinforced by immediate testing 

after learning and is a universally accepted instructional principle. 
AFS-15-4041-E 

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Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously granted in Exemption No. 

10836, as amended; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 10836 

also apply to the situation you present; and 

 a grant of exemption is in the public interest. 

Our Decision 

In consideration of the foregoing, I find in the present case that a grant of exemption is in the 

public interest. Specifically, certain conditions and limitations have been included in this 

exemption to ensure an equivalent level of safety with 14 CFR §65.75(a). The conditions and 

limitations require Blue Ridge Community College (BRCC) to develop written testing 

procedures, include those procedures in its operating document or manual, and obtain 

approval of those procedures from its Certificate Holding District Office (CHDO) to ensure 

that BRCC’s educational program and curricula continue to meet FAA regulatory standards. 

The additional conditions and limitations of this exemption also require that BRCC must 

retrain any student on the specific instructional items associated with a failed AMG test and 

authorize the student to retake the test. This would be applicable prior to any BRCC retesting 

of a student who has failed the AMG test and who also does not meet the experience 

requirements of 14 CFR § 65.77. 

To be clear, any student who is eligible to take the AMG test, on the basis of his/her own 

experience, and who does not need to rely on this exemption, may retrain according to 14 

CFR § 65.19 - including with any appropriately certificated airmen. However, this exemption 

also creates a population of students who do not satisfy the experience requirements of 

§ 65.77 and who are eligible to retake the AMG test, only because of the exemption granted to 

BRCC. To maintain an equivalent level of safety, this exemption requires BRCC to retrain 

those students itself, using its written procedures, its FAA-approved curricula, and in 

accordance with the FAA’s AMTS standards, including the quality of instruction standards, 

codified in §147.38(a). 

The FAA has determined that the justification for the issuance of Exemption No. 10836, as 

amended, remains valid with respect to this exemption and is in the public interest. 

Therefore, under the authority provided by 49 U.S.C. 106(f), 40113 and 44701, which the 

FAA Administrator has delegated to me, I grant Blue Ridge Community College (BRCC) an 

exemption from 14 CFR § 65.75(a) to the extent necessary to allow BRCC to administer the 

Aviation Mechanic General (AMG) written test to students immediately following successful 

completion of the general curriculum, and before meeting the experience requirements of 14 

CFR § 65.77, subject to the conditions and limitations below. 

Conditions and Limitations 
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1. BRCC must develop written procedures for administering the AMG written test 

following successful completion of the general curriculum. 

2. BRCC must ensure these procedures are available for use in its approved operating or 

curriculum procedures document or manual. 

3. Before retesting a student who has failed the AMG examination, and also does not 

meet the experience requirements of 14 CFR § 65.77, BRCC must require the student 

to repeat each instructional item associated with the failed test and receive 

authorization from BRCC to retake the test. BRCC must have procedures for 

documenting and tracking compliance with all retesting procedures. 

4. Before exercising the privileges of this exemption, BRCC must provide revised 

procedures to its CHDO for review and approval. 

The Effect of Our Decision 

This exemption is effective immediately and terminates on January 31, 2018, unless sooner 

superseded or rescinded. 

Sincerely, 

//s// 

John Barbagallo 

Deputy Director, Flight Standards Service 

Enclosure: 

Exemption No. 10836