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 

May 12,2015 

U.S. Department of Transportation 

Document Management System 

400 7th Street, SW., Room PL 401 

Washington, DC 20591-0001 

Dear Sir or Madam, 

Aviation Institute of Maintenance (AIM) previously submitted an appeal (reconsideration) to a Partial Grant ofExemption No. 11118 

issued under Regulatory Docket No. FAA -2014-0660 in accordance with 14 CFR part 11.101. This prior appeal was dated December 

19, 20 14 and was submitted in part to seek clarification from FAA for an issued limitation statement within the grant related to 

retesting after a failure of a general knowledge test. 

The referenced partial grant (attached) is for clarification purposes. When AIM reviewed the Exemption Partial Grant No. 11118, page 

3, Conditions and Limitations Section, this Limitation, item# 2 states "Before testing after failure, AIM must require a student to 

repeat the entire instructional unit associated with the failed test." This one limitation "statement" in the eyes of a 147 school is 

considered to require a student to retake 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 FAA to require a complete repeat of the general 

curriculum upon failure of individual general subject arears. Reference 14 CFR part 65.19. However without a rewrite of this grant or 

a clarifying statement from FAA in the form of a letter issued to AIM addressing this troublesome limitation, AIM believes it cannot 

exercise the privileges of this partial grant without a student repeating the general curriculum upon a failure. 

Aviation Institute of Maintenance (AIM), as a corporation, operates eleven separate 14 CFR Part 147 schools (Air Agencies) under 

various separate FAA certificates located in many major U.S. cities. Aviation Institute of Maintenance first and foremost strives to 

operate all of its FAA certificated 14 7 schools in compliance with all applicable FAA regulatory requirements. The schools 

collectively have a long history of providing superior aviation maintenance training in preparation for airman A&P testing and 

certification. 

Thank you in advance for your consideration of this 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, or practical test for a certificate and rating, or for an additional rating under this 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 statement from an airman holding the certificate and rating 

sought by the applicant, certifying that the airman has given the applicant additional instruction in each of the subjects failed and that 

the airman considers the applicant ready for retesting. 

Gerald Yag resident 

Aviation Institute of Maintenance 

Corporate Offices 

4455 South Boulevard 

VirginiaBeach, VA 23452-1159 

(757)490-3151 

cc: Mr. Kevin Morgan 

California • Florida • Georgia • Indiana • Missouri • Nevada • Pennsylvania • South Carolina • Texas • Virginia • Washington, DC 
Exemption No. 11118 

UNITED STATES OF AMERICA 

DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

WASHINGTON, DC 20591 

In the matter of the petition of 

AVIATION INSTITUTE OF 

MAINTENANCE 

for an exemption from§ 65.75(a) 

ofTitle 14 Code of 

Federal Regulations 

Regulatory Docket No. F AA-20 14-0660 

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 Aviation Administration (FAA) for an exemption from 

§ 65.75(a) of Title 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 of the 

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

The petitioner requested relief from the following regulation: 

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

or rating must present either an appropriate graduation 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, materials, 

tools, machine tools, and equipment generally used in constructing, maintaining, or altering 

airframes, or powerplants appropriate to the rating sought. 

The petitioner supported its request with the following information: 

AFS-14-456-E 
2 

The petitioner stated in its 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 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 qualify to take 

the Aviation Mechanic written tests after the completion ofthe corresponding portion ofthe 

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 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 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, the FAA has concluded this type of exemption 

could provide scenarios which may permit an individual 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 issuing 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, 

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

The FAA's Decision 

In consideration of the foregoing, 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 Aviation 

Institute of Maintenance in Casselberry FL, is granted an exemption from 14 CPR 

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

Certificate (QV5T572K) to administer the AMG written test to students immediately 

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

requirements of 14 CPR§ 65.77, subject to the conditions and limitations listed below. 
3 

Conditions and Limitations 

1. Before exercising the privileges ofthis 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 an exemption to take the Aviation Mechanic Airframe (AMA) and 

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

portion ofthe curriculum, prior to meeting the experience requirements of 14 CPR§ 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