November25, 2014

Docket Management Facility US Department ofTransportation 1200 NewJerseyAvenue, SE West Building Ground Floor Room W 12-140 Washington, DC 20590
Subject: Petition forexemption from Code of Federal Regulations 14 CFR, Part 65.75(a) to allow theAviation Mechanic General (AMG) written exam to be administered after successful completion ofthe 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 underAirAgency 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, statesthat applicantsfor a mechanic certificate, or rating, must pass awritten test after meeting the applicable experience requirements of Part 65.77. Part 65.77 requires that applicants must "present eitheran appropriate graduation certificate or certificate ofcompletion from a certificated aviation maintenancetechnician school" to be eligible totake the written
exam for a certificate or rating.

Relief being sought The AMTS at Midland College is seeking relieffrom 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 aftersuccessfully completing the General curriculum, but priorto meeting the experience requirements of Part 65.77.

Public Interest The public's interestwould be served by permitting Midland College AMTS students to take their FAAAMGwritten exam after successful completion ofthe General curriculum. The immediatefeedback to the studentwould both enhancetheir learning as well as provide a sense ofaccomplishment. In turn, it would be expected that this would further encourage students to continue studying and be a positive influenceto 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 CollegeAMTS students who would be eligible totake the AMG written exam. A level of safety equal to what currently exists would be provided.

Additional information. views. or argumentsto support our request The testing ofstudents immediately after learning is an accepted instructional principle that is both academically sound and reinforces learning. This practice is currently allowed for atthe end ofboth the Airframe and the Powerplant curricula, but not atthe end ofthe General curriculum.
Currently, 14 CFR Part65.80 permits students at an AMTS who have made satisfactory progress atthe school to take their oral and practical exams before meeting the applicable experience requirements of Part65.77.

Summary of request for publication in the Federal Register The purpose ofthis petition is to allowthe Aviation Mechanic General (AMG) written
exam to be taken by students in Midland College'sAMTS aftersuccessfully completing the General curriculum. TheAMTS at Midland College is seeking relieffrom Title 14 CFR Part 65.75(a) which requires students to pass awritten test after meeting the applicable experience requirements of Part 65.77.

Midland CollegeAMTS appreciates your consideration and assistance in granting this petition.

# ~~ Tommy Branon Program Chair Midland CollegeAMTS 2405 Windecker Hanger "E" Midland, Texas 79711 432.563.8952

cc: Mona Roberts, PMI Lubbock Flight Standards District Office