AFS

- 14

- 456

- E Exemption No. 11118

UNITED STATES OF AMERICA

DEPARTMENT OF TRANSPORTATION

FEDERAL AVIATION ADMINISTRATION

WASHINGTON, DC 20591

In the matter of the petition of

AVI ATION INSTITUTE OF Regulatory Docket No. FAA

- 2014

- 0660

MAINTENANCE

for an exemption from § 65.75(a)

of Title 14 Code of

Federal Regulations

PARTIAL GRANT OF EXEMPTION

By letter dated August 20, 2014, Mr. Gerald Yagen, President, Training Services Inc.,

d/b/a Aviation Institute of Maintenance (AIM), 4455 South Boulevard, Virginia Beach, VA,

23452, petitioned the Federal Av iation Administration (FAA) for an exemption from

§ 65.75(a) of Title 14 Code of Federal Regulations (14 CFR). The proposed exemption, if

granted, would allow students enrolled in AIM’s part 1 47 Aviation Maintenance Technician

School (AMTS) in Casse lberry, FL, under Air A gency Certificate ( Q 5V T572K), to take the

Aviation Mechanic General (AMG), Aviation Mechanic Airframe (AMA) and Aviation

Mechanic Powerplant (AMP) written tests after completing the corresponding portion of the

curriculum, prior to m eeting the experience requirements of 14 CFR § 65.77.

The petitioner requested relief from the following regulation:

Section 65.77 prescribes, in pertinent part, that e ach applicant for a mechanic certificate

or rating must present either an appropriate g raduation certificate or certificate of completion

from a certificated aviation maintenance technician school or documentary evidence,

satisfactory to the Administrator, of

—

(a) At least 18 months of practical experience with the procedures, practices, mat erials,

tools, machine tools, and equipment generally used in constru cting, maintaining, or altering

airframes, or powerplants appropri ate to the rating sought.

The petitioner supported its request with the following information:2

The petitioner stated in i ts August 20, 2014 petition that the public interest would be

served by allowing aviation maintenance technician students to take the FAA written test

covering a body of knowledge immediately following completion of their studies of that

material. Student learning will be enhanced and reinforced by the immediate feedback

provided by the testing experience. This immediate feedback, coupled with a sense of

accomplishment, is expected to encourage students to continue their studies and reduce

dropout rates

.

The petitioner also stated that a level of safety equal to that provided by this r egulation

would be provided. A procedure is currently in place to identify and report students who are

eligible to take the FAA written, oral

, and practical tests. This inf ormation is distributed to the

Casselberry, FL

, F light S tandards D istrict O ffice (FSDO) and the affiliated written test center.

The same procedure would be used to identify and report students who would qualify to take

the Aviation Mechanic written tests a fter the completion of the corresponding portion of the

curriculum. All other requirements governing written testing, including time requirements for

licensure completion

, would remain unchanged.

The FAA's analysis is as follows:

In your request, you sta ted this petition does not differ materially from others on record,

and those requests have been deemed to be in the public interest. T he FAA acknowledges that

it did grant a small number of § 65 .75 exemptions to the extent that it enabled a few AMTS to

ad minister the airframe and powerplant written tests to students immediately following the

successful completion of the airframe and or powerplant curriculums, but before meeting the

experience requirement of § 65.77

. However, t he FAA has concluded this type of exemption

could provide scenarios which may permit an individu al to obtain their Airframe and/ or Powerplant Certificate prior to meeting the eligibility requirements of § 65 .77

. The FAA is

taking action to amend these exemptions

, and will consider issu ing these AMTS’s a Partial

Grant of Exemption on a case by case basis.

The FAA has also determined that good cause exists for not publishing a summary of the

petition in the Federal Register because the relief granted herein would not set a precedent,

an d any delay in acting on this petition would be detrimental to AIM.

The FAA’s Decision

In consideration of the f

oregoing, I find that a partial grant of exemption is in the public

interest. Therefore, pursuant to the authority contained in 49 U.S.C. § § 106(f), 40113,

and 44701, delegated to me by the Administrator, Training Services Inc., d/b/a Av iation

Institute of Maintenance in Casselberry FL

, is granted an exemption from 14 CFR

§ 65.75(a) to the extent necessary to allow AIM in Cassel berry, FL , under Air Agency

Certificate (Q V 5 T572K) to administer the AMG written test to students immediately

following successful completion of the general curriculum , and before meeting the experience

requirements of 14 CFR § 65.77, subject to the condi tions and limitations listed below.3

Conditions and Limitations

1. Before exercising the privileges of this exemption, AIM must present this exemption

along with its exemption policies and procedures to its certificate holding district

office (CHDO) in order to receive approval

.

2. Before retesting after failure, AIM must require a student to repeat the entire

instructional unit associated with the failed test and receive authorization from AIM to

retake the test. AIM operations handbook must contain procedures for documenting

and tracking compliance with all retesting procedures.

This request for a n e xemption to take the Aviation Mechanic Airframe (AMA) and

Aviation Mechanic Powerplant (AMP) written tests after completing the corresponding

portion of the curric ulum, prior to meeting the experience requirements of 14 CFR § 65.77 is

denied.

This exemption terminates on 31 December

, 2016 unless sooner superseded or rescinded.

Issued in Washington, DC, on

/s/

John Barbagallo

Acting Deputy Director, Flight Standards Service

.