# 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
May 12,2015 U.S. Department ofTransportation DocumentManagement System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 Dear Sir or Madam, Aviation Institute ofMaintenance (AIM) previously submitted an appeal (reconsideration) to a Partial Grant ofExemptionNo. 11118 issued under Regulatory DocketNo. FAA -2014-0660 in accordance with 14 CFRpart 11.101. This prior appeal was dated December 19, 20 14 and was submitted in partto seek clarification from FAA for an issued limitation statement within the grant related to retesting after a failure ofa general knowledge test. Thereferenced partial grant (attached) is for clarification purposes. When AIM reviewed the Exemption Partial GrantNo. 11118, page 3, Conditions and Limitations Section, this Limitation, item# 2 states "Before testing after failure, AIM mustrequire a student to repeatthe entire instructional unit associated withthe failed test." This one limitation "statement" inthe eyes ofa 147 school is considered to require a studenttoretake the entire general curriculum before being allow to retake the general knowledge test upon a failure. We believe this limitation as previously written was not intended by FAAto require a complete repeat ofthe general curriculum upon failure ofindividual general subject arears. Reference 14 CFRpart 65.19. However without a rewrite ofthis grant or a clarifying statement from FAA in the form ofa letter issued to AIM addressing this troublesome limitation, AIM believes it cannot exercise the privileges ofthis partial grant without a student repeating the general curriculum upon a failure. Aviation Institute ofMaintenance (AIM), as a corporation, operates eleven separate 14 CFRPart 147 schools (Air Agencies) under various separate FAA certificates located in many majorU.S. cities. Aviation Institute ofMaintenance first and foremost strives to operate all ofits FAA certificated 147 schools in compliance with all applicable FAAregulatoryrequirements. The schools collectivelyhave a long history ofproviding superior aviation maintenance training inpreparation for airman A&P testing and certification. Thankyou in advance for your consideration ofthis matter as all my prior experiences working with the Office ofRulemaking have been outstanding. Reference. §65.19 Retesting after failure.
An applicant for a written, oral, orpractical test for a certificate and rating, or for an additional rating underthis part, may apply for retesting- (a) After 30 days after the date the applicant failed the test; or (b) Before the 30 days have expired ifthe applicant presents a signed statementfrom an airman holding the certificate and rating soughtbythe applicant, certifying thatthe airmanhas given the applicant additional instruction in each ofthe subjects failed and that the airman considers the applicantready for retesting.

Gerald Yag resident Aviation Institute ofMaintenance Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757)490-3151

cc: Mr. Kevin Morgan

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### ExemptionNo. 11118 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION WASHINGTON, DC 20591

In the matter ofthe petition of AVIATION INSTITUTE OF MAINTENANCE 

### for an exemption from§ 65.75(a) ofTitle 14 Code of Federal Regulations Regulatory Docket

### No. FAA-2014-0660

PARTIAL GRANT OF EXEMPTION 

### By letter dated August 20, 2014, Mr. Gerald Yagen, President, Training Services Inc., d/b/aAviation Institute ofMaintenance (AIM), 4455 South Boulevard, VirginiaBeach, VA, 23452, petitionedthe Federal Aviation Administration (FAA) for an exemption from § 65.75(a) ofTitle 14 Code ofFederal Regulations (14 CFR). The proposed exemption, if granted, would allow students enrolled in AIM's part 147 Aviation Maintenance Technician School (AMTS) in Casselberry, FL, under Air Agency Certificate (Q5VT572K), to take the Aviation Mechanic General (AMG), Aviation Mechanic Airframe (AMA) and Aviation Mechanic Powerplant (AMP) written tests after completing the corresponding portion ofthe curriculum, priorto meeting the experience requirements of 14 CFR § 65.77. The petitioner requested relieffrom the following regulation: 

### Section 65.77 prescribes, in pertinentpart, that each applicant for a mechanic certificate orrating must present either an appropriate graduation certificate or certificate ofcompletion from a certificated aviation maintenance technician school or documentary evidence, satisfactoryto the Administrator, of- (a) At least 18 months ofpractical experience with the procedures, practices, materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, orpowerplants appropriate to the rating sought. The petitioner supported its requestwith the following information: AFS-14-456-E2 Thepetitioner stated in its August 20, 2014 petitionthatthe public interest would be served by allowing aviation maintenance technician students to take the FAAwritten test covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced andreinforced bythe immediate feedback provided bythe testing experience. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and reduce dropoutrates. Thepetitioner also stated that a level ofsafety equal to thatprovidedbythis regulation 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 information is distributed to the Casselberry, FL, Flight Standards District Office (FSDO) and the affiliated written test center. The same procedure would be used to identify and report students who would qualifyto take the Aviation Mechanic written tests after the completion ofthe correspondingportion ofthe curriculum. All other requirements governingwritten testing, including time requirements for licensure completion, would remain unchanged. 

### The FAA's analysis is as follows: In your request, you stated this petition does not differ materially from others on record, and those requests have been deemed to be in the public interest. The FAA acknowledges that it did grant a small number of§ 65.75 exemptions to the extent that it enabled a few AMTS to administer the airframe and powerplantwritten tests to students immediately following the successful completion ofthe airframe and orpowerplant curriculums, butbefore meeting the experience requirement of§ 65.77. However, the FAA has concludedthis type ofexemption could provide scenarios which may permit an individual to obtain their Airframe and/or Powerplant Certificate prior to meetingthe eligibilityrequirements of§ 65.77. TheFAA is taking action to amendthese exemptions, and will consider issuing these AMTS's a Partial Grant ofExemption on a case by case basis. TheFAAhas also determined that good cause exists for notpublishing a summary ofthe petition in the Federal Register because the reliefgranted herein would not set a precedent, and any delay in acting on this petition would be detrimental to AIM. 

### The FAA's Decision In consideration ofthe foregoing, I find that a partial grant ofexemption is in the public interest. Therefore, pursuantto the authority contained in 49 U.S.C. §§ 106(f), 40113, and 44701, delegated to me bythe Administrator, Training Services Inc., d/b/a Aviation Institute ofMaintenance in CasselberryFL, is granted an exemption from 14 CPR § 65.75(a) to the extentnecessaryto allow AIM in Casselberry, FL, under AirAgency Certificate (QV5T572K) to administerthe AMG written testto students immediately following successful completion ofthe general curriculum, and before meetingthe experience requirements of 14 CPR§ 65.77, subjectto the conditions and limitations listed below.3


### Conditions and Limitations 1. Before exercisingthe privileges ofthis exemption, AIM must presentthis 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 repeatthe entire instructional unit associated with the failed test and receive authorization from AIMto retake thetest. AIM operations handbook must contain procedures for documenting and tracking compliance with all retesting procedures. This request for an exemptionto take the Aviation Mechanic Airframe (AMA) and Aviation Mechanic Powerplant (AMP) written tests after completingthe corresponding portion ofthe curriculum, prior to meeting the experience requirements of 14 CPR§ 65.77 is denied. This exemptionterminates on 31 December, 2016 unless sooner superseded or rescinded. Issued in Washington, DC, on /s/ John Barbagallo Acting DeputyDirector, Flight Standards Service