# Aviation Institute ofMaintenance 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 ofTransportation Document Management System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 Subject: Appeal ofPartial Grant ofExemption No 11118 issued under Regulatory Docket NO. FAA -2014-0660. RePetition for exemption from Code ofFederal 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 ofthe curriculum. Dear Sir or Madam, Aviation Institute ofMaintenance (AIM) wishes to appeal a Partial Grant ofExemptionNo 11118 issued under Regulatory Docket NO. FAA -2014-0660. This partial grantNo 11118 is being appealed in accordance with Title 14 CFRpart 11.101 due to inconsistent application ofexisting rule language usage and inconsistent application of65.19(a) and (b) within the Conditions and Limitations Section 2 ofthe issued exemptionregarding 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 totest for anyrating 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 CFRpart 65.19, the referencedrule, establishesretesting ,after failure criteria which is found to be inconsistent with and less restrictive byrule than the more restrictive condition and limitation placed onthe school/ schoois by exemption'partial grant No 11118. Retesting after failure simply states an applicant for written, oral, orpracticaltest for a certificate and rating or for an additional rating under this partmay apply for retest after 30 days after the

**appli~ant** failed the test orbefore the 30 days have expired, ifthe applicant presents a statement certifying the applicant has received additional'instruction in each 

### of the subjects failed. Itis acknowledged, how.ever, that general is not a rating; however, the condition and limitationthat 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 ofanormal 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 ortesting based on experience previously evaluated by an FAA representative. In Grant ofExemptionNo. 7926, the FAA previously agreed with thepetitioner that testing immediately after learning is a universally accepted instructional principal thatreinforces learning and that such testing is academically sound. Therefore, the FAA allowed the petitioner to test students immediately after they successfully complete the general curriculumbutbefore they meetthe experience requirements of§ 65.77. Aviation Institute ofMaintenance is one ofeleven 147 schools under the same ownership. These schools have operatedunder numerous existing 14 CFRpart 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 ofthe General curriculum as approvedbyFAA
. . .

**~** 65.77 provides that a Certificated Aviation Maintenance Technician (AMTS) school must present either an appropriate graduation certificate or certificate ofcompletionto each mechanic applicant for a certificate or rating in orderto establish eligibility to test for theKnowledge (written) test. In accordance with previously issued exemptionlimitations, each school has issued a Certificate ofCompletion for the General curriculum completion only upon completion ofthe 14 CfRpart 147 AppendixA General curriculum, as approved. 

### A Graduation certificate is issued bythe respective schools only upon completion ofthe Airframe and or P.owerplant ratings in accordance with 14 CFRpart 65.73. AIM will continue to issue a Certificate ofCpmpletion and orGraduate



### Certificat~,in accon\ance with 65:77. AIMwishes to clarify that under exemption No 11118 AIMrequested that a certificate ofc01: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 ofe.ach respective rating. This would be

**consist~ntwith** that ofa student.enrolled in a mdivi4ual singularrating.



### California •Florida • Georgia •Indiana •Missouri •Nevada •Pennsylvania • South Carolina •Texas •Virginia •Washington, DCTherefore, the issue ofan Airframe and or combined Airframe/ Powerplant Graduation Certificate issued bythe school and in accordance with these prior issued exemptions can only be issued atthe completion ofthe respective rating in accordance with 14 CFR65.73 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 priorto meeting the eligibility requirements of65.77 is a misread ofthe intent ofthe requested exemption and of65.77 as a rule. No student could become eligible to test for a mechanic certificate with airframe and orpowerplant certificate without first completing the curriculum requirements of 14 CFRAppendix B, C, and D and being issued a Graduation Certificate or Certificate ofCompletionbythis or any 147 school, so stating. Lastly 14 CFRpart 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 meetingthe experience requirements of65.77 is consistent with that of65.80 and the Oral and Practical test provision. Also and without additional limitations onretesting after failure as imposed bythe 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.

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