October 1

Docket M

US Depart

1200 New

West Buil

Room W 1

Washingt

Subject:  

Dear Sir o

Embry‐Rid

School (A

seeking an

Title 14 C

rating, mu

65.77 req

of comple

written ex

Relief bei

The AMTS

program t

completin

Public inte

The public

exam afte

would bot

expected

keep stud

Safety im

An existin

practical t

1, 2011

anagement F

tment of Tran

w Jersey Aven

ding Ground

12‐140

on, DC 20590

Petitio

the Av

compl

or Madam,

ddle Aeronau

MTS) on its D

n exemption

FR Part 65.75

ust pass a wri

uires that ap

etion from a c

xam for a cert

ng sought

S at ERAU is s

to be able to

ng the Genera

erest

c’s interest w

er successful c

th enhance th

that this wou

dents in the p

pact

ng  procedure

tests to the O

Facility

nsportation

ue, SE

Floor

0

on for exempt

viation Mecha

etion of the c

utical Universi

Daytona Beach

from Title 14

5(a), Knowled

itten test afte

plicants must

certificated av

tificate or rat

seeking relief

take the avia

al curriculum,

would be serve

completion o

heir learning

uld further en

rogram.  

e is in place to

Orlando, FL FS

tion from Cod

anic General (

correspondin

ity (ERAU) op

h, FL campus

4 CFR Part 65.

ge Requirem

er meeting th

t “present eit

viation maint

ting.  

from Title 14

ation mechan

, but prior to

ed by permitt

of the Genera

as well as pro

ncourage stud

o report stude

SDO and on‐si

de of Federal

(AMG) writte

g curriculum.

perates an ap

under Air Ag

75(a).  

ents, states t

e applicable e

her an appro

tenance techn

4 CFR Part 65.

ic general (AM

meeting the

ting ERAU AM

l curriculum.

ovide a sense

dents to cont

ents who are

ite written te

Regulations

n exam to be

.  

proved Aviati

gency Certifica

hat applicant

experience re

priate gradua

nician school”

75(a) to allow

MG) written t

experience re

MTS students

The immedia

e of accomplis

inue studying

eligible to ta

sting center a

14 CFR, Part 6

e administere

ion Maintena

ate NX4T404

ts for a mecha

equirements

ation certifica

” to be eligibl

w students in

test after succ

equirements

to take their

ate feedback t

shment. In tu

g and be a po

ke the FAA w

at ERAU. This

Charles Taylor D

Aviation Mainten

600 S. Clyde Mo

Daytona Beach, F

Toll Free: 877.90

T: 386.226.6779

F: 386.226.6778

65.75(a) to al

d after succe

ance Technici

M. The schoo

anic certificat

of Part 65.77

ate or certific

le to take the

its Part 147

cessfully

of Part 65.77

FAA AMG wr

to the studen

rn, it would b

sitive influen

written, oral, a

s same proced

Department of 

nance Science 

rris Blvd. 

FL 32114-3900 

04.3746

llow

ssful

an

ol is

te, or

. Part

ate

7.

ritten

nt

be

ce to

and

dure
would 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