Aviation Institute of Maintenance Corporate Headquarters 

4455 South Boulevard • Suite 250 • Virginia.Beach, VA 23452 • Telephone: (757) 456-5065 • Toll Free: (877) 604-2121 • Fax: (757) 497-6503 

December 19,2014 

U.S. Department of Transportation 

Document Management System 

400 7th Street, SW., Room PL 401 

Washington, DC 20591-0001 

Subject: Appeal of Partial Grant of Exemption No 11118 issued under Regulatory Docket NO. FAA -2014-0660. RePetition for exemption from Code of Federal Regulations 14 CFR, Part 65.75(a) to allow the Aviation 

N,lechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion 

of the curriculum. 

Dear Sir or Madam, 

Aviation Institute of Maintenance (AIM) wishes to appeal a Partial Grant of Exemption No 11118 issued under Regulatory Docket 

NO. FAA -2014-0660. 

This partial grant No 11118 is being appealed in accordance with Title 14 CFR part 11.101 due to inconsistent application of existing 

rule language usage and inconsistent application of65.19(a) and (b) within the Conditions and Limitations Section 2 ofthe issued 

exemption regarding retesting. In addition, AIM feels a significant additional fact was omitted in the original submission and wish,ed 

to reiterate that no student would be deemed by AIM as eligible to test for any rating without first having completed the corresponding 

curriculum as required by 14 CFRpart·147 Appendix B, C, and D a!,ld theii.approved curricuhp:n requirements. 

14 CFR part 65.19, the referenced rule, establishes retesting ,after failure criteria which is found to be inconsistent with and less 

restrictive by rule than the more restrictive condition and limitation placed on the school/ schoois by exemption'partial grant No 

11118. Retesting after failure simply states an applicant for written, oral, or practical test for a certificate and rating or for an 

additional rating under this part may apply for retest after 30 days after the appli~ant failed the test or before the 30 days have expired, 

if the applicant presents a statement certifying the applicant has received additional' instruction in each of the subjects failed. It is 

acknowledged, how.ever, that general is not a rating; however, the condition and limitation that requires a student to repeat the entire 

instructional unit (General) associated with the failed test is inconsistent with a general test failed as taken as part of a normal rating 

application and places a decisive disadvantage to this individual school in exercising this exemption over other 147 schools. This rule 

65.19 is applicable to all test and all applicants under 65 whether they are a school applicant or testing based on experience previously 

evaluated by an FAA representative. 

In Grant of Exemption No. 7926, the FAA previously agreed with the petitioner that testing immediately after learning is a universally 

accepted instructional principal that reinforces learning and that such testing is academically sound. Therefore, the FAA allowed the 

petitioner to test students immediately after they successfully complete the general curriculum but before they meet the experience 

requirements of§ 65.77. 

Aviation Institute of Maintenance is one of eleven 147 schools under the same ownership. These schools have operated under 

numerous existing 14 CFR part 65.77 exemptions materially similar to the requested and fully previously granted exemptions for 

several years, successfully and in accordance with prior limitations allowing students to test immediately after completion of the 

General curriculum as approved by FAA . . . ~ 

65.77 provides that a Certificated Aviation Maintenance Technician (AMTS) school must present either an appropriate graduation 

certificate or certificate of completion to each mechanic applicant for a certificate or rating in orderto establish eligibility to test for 

the Know ledge (written) test. 

In accordance with previously issued exemption limitations, each school has issued a Certificate of Completion for the General 

curriculum completion only upon completion of the 14 CfR part 14 7 Appendix A General curriculum, as approved. A Graduation 

certificate is issued by the respective schools only upon completion of the Airframe and or P.owerplant ratings in accordance with 14 

CFR part 65.73. AIM will continue to issue a Certificate of Cpmpletion and or Graduate Certificat~ ,in accon\ance with 65:77. 

AIM wishes to clarify that under exemption No 11118 AIM requested that a certificate of c01:npletion would be issued to students 

enrolled in a combined curriculum (Airframe and Powerplant) at the completion.ofeach individual rating in order to test immediently 

following completion of e.ach respective rating. This would be consist~ntwith that of a student.enrolled in a mdivi4ual singular rating. 

California • Florida • Georgia • Indiana • Missouri • Nevada • Pennsylvania • South Carolina • Texas • Virginia • Washington, DC 
Therefore, the issue of an Airframe and or combined Airframe/ Powerplant Graduation Certificate issued by the school and in 

accordance with these prior issued exemptions can only be issued at the completion of the respective rating in accordance with 14 

CFR 65.73 and 65.77. The experience requirements as stated in the exemption as providing scenarios which may permit an individual 

to obtain their Airframe and or Powerplant Certificate prior to meeting the eligibility requirements of 65.77 is a misread of the intent 

of the requested exemption and of65.77 as a rule. No student could become eligible to test for a mechanic certificate with airframe 

and or powerplant certificate without first completing the curriculum requirements of 14 CFR Appendix B, C, and D and being issued 

a Graduation Certificate or Certificate of Completion by this or any 147 school, so stating. 

Lastly 14 CFR part 65.80 establishes that a Certificated Aviation Maintenance Technician School may, with certain conditions, allow 

a student to take the Oral and practical test prescribed by 65.79 during the final subjects ofhis training before he he meets the 

applicable experience requirements of65.77 and before he passes each section ofthe written test prescribed by 65.75. 

Allowing for a general test to be taken prior to meeting the experience requirements of65.77 is consistent with that of65.80 and the Oral and Practical test provision. Also and without additional limitations on retesting after failure as imposed by the Partial Exemption 

Grant no 1118. The retesting after failure under 65.80 remains consistent with 65.19 and further shows the inconsistent application to this exemption. 

Corporate Offices 

4455 South Boulevard 

Virginia Beach, VA 23452-1159 

(757) 490-3151