November 25, 2014 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W 12-140 

Washington, DC 20590 

Subject: Petition for exemption from Code of Federal Regulations 14 CFR, Part 

65.75(a) to allow the Aviation Mechanic General (AMG) written exam to be administered 

after successful completion of the corresponding curriculum. 

Dear Sir or Madam, 

Midland College operates an approved Aviation Maintenance Technician School 

(AMTS) at Midland International Air and Space Port, Midland, TX under Air Agency 

Certificate VMCT038K. The school is seeking an exemption from Title 14 CFR Part 

65.75(a). 

Title 14 CFR Part 65.75(a), Knowledge Requirements, states that applicants for a 

mechanic certificate, or rating, must pass a written test after meeting the applicable 

experience requirements of Part 65.77. Part 65.77 requires that applicants must 

"present either an appropriate graduation certificate or certificate of completion from a 

certificated aviation maintenance technician school" to be eligible to take the written 

exam for a certificate or rating. 

Relief being sought 

The AMTS at Midland College is seeking relief from Title 14 CFR Part 65.75(a) to allow 

students in its Part 147 program to be able to take the aviation mechanic general (AMG) 

written test after successfully completing the General curriculum, but prior to meeting 

the experience requirements of Part 65.77. 

Public Interest 

The public's interest would be served by permitting Midland College AMTS students to 

take their FAA AMG written exam after successful completion of the General curriculum. 

The immediate feedback to the student would both enhance their learning as well as 

provide a sense of accomplishment. In turn, it would be expected that this would further 

encourage students to continue studying and be a positive influence to keep students in 

the program. 
Safety Impact 

An existing procedure is in place to report students who are eligible to take the FAA 

written, oral, and practical tests to the Lubbock, TX FSDO and on-site written testing at 

an approved testing site. This same procedure would be used to report Midland 

College AMTS students who would be eligible to take the AMG written exam. A level of 

safety equal to what currently exists would be provided. 

Additional information. views. or arguments to support our request 

The testing of students immediately after learning is an accepted instructional principle 

that is both academically sound and reinforces learning. This practice is currently 

allowed for at the end of both the Airframe and the Powerplant curricula, but not at the 

end of the General curriculum. 

Currently, 14 CFR Part 65.80 permits students at an AMTS who have made satisfactory 

progress at the school to take their oral and practical exams before meeting the 

applicable experience requirements of Part 65.77. 

Summary of request for publication in the Federal Register 

The purpose of this petition is to allow the Aviation Mechanic General (AMG) written 

exam to be taken by students in Midland College's AMTS after successfully completing 

the General curriculum. The AMTS at Midland College is seeking relief from Title 14 

CFR Part 65.75(a) which requires students to pass a written test after meeting the 

applicable experience requirements of Part 65.77. 

Midland College AMTS appreciates your consideration and assistance in granting this 

petition. 

~~ Tommy Branon 

Program Chair 

Midland College AMTS 

2405 Windecker 

Hanger "E" 

Midland, Texas 79711 

432.563.8952 

cc: Mona Roberts, PMI 

Lubbock Flight Standards District Office