October 1

Docket M

US Depar t

1200 Ne w

West Buil

Room W 1

Washingt

Subject :

Dear Sir o

Embry

‐ Ri d

School (A

seeking a n

Title 14 C

rating, m u

65.77 req

of compl e

written e x

Relief bei

The AMT S

program t

completi n

Public int e

The publi c

exam aft e

would bo t

expected

keep stu d

Safety im

An existi n

practical t 1

, 2011

anagement F

t ment of Tra n

w Jersey Ave n

ding Ground

1 2

‐ 140

on, DC 2059 0

Petiti o

the A v

compl

o r Madam,

d dle Aerona u

MTS) on its D

n exemption

FR Part 65.7 5

u st pass a wr i

uires that ap

e tion from a c

x am for a cer t

ng sought

S at ERAU is s

t o be able to

n g the Gener a

e rest

c ’s interest w

e r successful c

t h enhance t h

that this wo u

d ents in the p

pact

n g procedur e

t ests to the O F acility

n sportation

ue, SE

Floor

0

o n for exemp t

v iation Mech a

etion of the c

u tical Univers i

D aytona Beac h

from Title 1 4

5 (a), Knowled

i tten test aft e

plicants mus t

c ertificated a v

t ificate or ra t

s eeking relief

take the avi a

a l curriculum

,

w ould be serv e

c ompletion o

h eir learning

u ld further e n

rogram.

e is in place t o

O rlando, FL F S t ion from Co d

a nic General (

c orrespondin

i ty (ERAU) o p

h

, FL campus

4 CFR Part 65.

ge Requirem

e r meeting th

t “present eit

v iation main t

t ing.

from Title 1 4

a tion mechan

, but prior to

e d by permit t

o f the Genera

as well as pr o

n courage stu d

o report stud e

S DO and on

‐ s i d e of Federal

( AMG) writte

g curriculum

.

p erates an ap

under Air A g

75(a).

ents, states t

e applicable e

her an appro

t enance tech n

4 CFR Part 65.

ic general (A M

meeting the

t ing ERAU A M

l curriculum.

o vide a sens e

d ents to cont

e nts who are

i te written te Regulations

n exam to b e

.

proved Aviat i

g ency Certific a

hat applican t

e xperience r e

priate gradu a

n ician school ”

75(a) to allo w

M G) written t

experience r e

M TS students

The immedi a

e of accompli s

inue studyin g

eligible to ta

sting center a 14 CFR, Part 6

e administere

i on Mainten a

a te NX4T404

t s for a mech a

e quirements

a tion certific a

” to be eligib l

w students in

t est after suc c

e quirements

to take their

a te feedback t

s hment. In tu

g and be a po

ke the FAA w

a t ERAU. Thi s Charles Taylor D

Aviation Mainte n

600 S. Clyde Mo

Daytona Beach, F

Toll Free: 877.9 0

T: 386.226.6779

F: 386.226.6778

6 5.75(a) to a l

d after succe

a nce Technici

M. The scho o

a nic certifica t

of Part 65.77

a te or certific

l e to take the

its Part 147

c essfully

of Part 65.7 7

FAA AMG w r

t o the stude n

rn, it would b

sitive influen

w ritten, oral, a

s same proce d D epartment of

n ance Science

rris Blvd.

F L 32114-3900

0 4.3746

l low

ssful

an

o l is

t e, or

. Part

ate

7

.

r itten

n t

b e

ce to

a nd

d urewould be used to report ERAU 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 curriculums, 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 ERAU’s AMTS after successfully completing the General curriculum. The AMTS at ERAU 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.

Embry

‐ Riddle Aeronautical University appreciates your consideration and assistance in granting this

petition.

Sincerely,

Charles E. Horning

Department Chairman, Aviation Maintenance Science

Embry

‐ Riddle Aeronautical University

600 South Clyde Morris Blvd

Daytona Beach, FL 32114

(386) 226

‐ 7693

Cc: Al Kimball, PMI

Orlando Flight Standards District Office