LORENZOWALKER INSTITUTE OF TECHNOLOGY 3702 EsteyAvenue Naples, FL 34104-4405 (239) 377-0900 (239) 377-1000 FAX

March 7, 2013, Revised May 30, 2013

U.S. DepartmentofTransportation Docket Operations, M-30 West Building ground floor Room W12-140 1200 NewJerseyAvenue, SE Washington, DC 20590 Subject:

DearSirs: Petition forexemption extension docketnumberFAA -2005-22015 from Code of FederalRegulations (CFR) Title 14 Part 65.17(a), Part65.19 (b), andPart 65.75 to allow FAA oral andpractical tests to be conducted as an integralpart ofan approved curriculum, and to allow the aviation mechanic general (AMG) written testto be administeredaftercompletingthe generalcurriculum.

Lorenzo Walker Institute of Technology, a Collier County Public School, offers the Federal Aviation Administration approved airframe and powerplant aviation maintenance technology curriculum underAirAgency Certificate NumberWT5T076K. Lorenzo Walker Institute of Technology is requesting a renewal of exemption number 86298, approved on August 10, 2011. This exemption authorizes students completing the FAA approved airframe and powerplant aviation maintenance technology curriculum to concurrently meet the FAA oral and practical testing requirements as part ofthe instructional program. The school is therefore petitioning the Federal Aviation Administration for renewal of the following exemptions:



### I. Exemption from the CFR Title 14, Parts 65.17(a), 65.19(b) and65.75(b) to allow the FAA oral and practical tests to be conducted as an integral part ofan approved curriculum. Lorenzo Walker Institute of Technology's curriculum is currently divided intoforty instructional subjects; however, the oral and practical tests would be reviewed and documented at the completion of each ofthe following five areas: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems.

COLLIERCOUNTYCHARACTER EDUCATION TRAITS Citizenship Cooperation Honesty Kindness Patriotism Perseverance Respect Responsibility Self-Control Tolerance

THE COLLIERCOUNTY PUBLIC SCHOOL SYSTEM ISAN EQUALACCESS/EQUAL OPPORTUNITYINSTITUTION FOR EDUCATION AND EMPLOYMENTU.S. DepartmentofTransportation Docket Operations, M-30 March 7, 2013, Revised May 30, 2013 Page2



### II. Exemption from CFR Title 14, Part 65.75 (b) and 65.77 to allow the Aviation Mechanic General(AMG) written tests to be administeredaftercompleting the Generalcurriculum. PETITION 

### 1:



### a. Exemption from CFR Title 14, Part65.17(a) Tests, GeneralProcedures ReliefSought: CFR Title 14, Part 65.17(a) Lorenzo Walker Institute of Technology is petitioning to administer the oral and practical tests to its students "at times and places" identified in its approved Operations Handbook. 

### Person to be Coveredby the Exemption: Lorenzo Walker Institute of Technology and students, AirAgency#WT5T076K 

### PublicInterest: LorenzoWalker Institute ofTechnology is seeking authorityto conduct oral and practical tests as an integral part of the aviation maintenance technician educational process. This request is in the public interest. It will allow students to demonstrate FAA required competence as part of the completion requirements of each the five major instructional areas: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. It will expedite the evaluation process while maintaining a level of safety equal to that ofthe existing rule, and itwill significantly reduce the cost to the students for FAA oral and practical tests. Direct involvement with the Miami Flight Standards District Office 19 in approving a system for administering and monitoring oral and practical tests will also add uniformity and consistency to the testing process. The concept ofallowing Part 147 schoolsto conduct FAA "selftesting" has also been recognized and proposed bythe Part65/66/ARACworking group. 

### Impact on Safety: Current FAA oral and practical testing requirements are to remain in place, exceptforthe manner in which the tests are administered. Ratherthan administering one lengthy oral and practical mechanic test over an entire body of knowledge. Lorenzo Walker Institute ofTechnology is seeking to administer oral and practical tests incrementally during each of the five major components of instruction: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. Each component is 480 hours in length. The scope of the FAA oral and practical test will be completed in its entirety when a student graduates from the airframe and/or powerplant curriculum. Since the scope and nature of oral and practical tests will not be changed, a level ofsafety equal to that provided bythis rule will be maintained. The time, place and manner in which oral practical tests are managed will be contained in the school's approved Operations Handbook and curriculum, and will be subject to review and approval bythe South Florida Flight Standards DistrictOffice 19. 

### Economic Impact: There would be a positive economic impact on the general public. By incorporating oral and practical tests as part of the overall cost of operations for Lorenzo Walker Institute ofTechnology, students will realize a substantial saVings as they will not be required to pay a Designated Mechanic Examinerto administeroral and practical exams.U.S. Department ofTransportation DocketOperations, M-30 March 7, 2013, Revised May30, 2013 Page3



### b. Exemption from CFR Title 14Part65.19(b) Retestingafterfailure: Code of Federal Regulations CFR Title 14 Part 65.19(b) specifiesthat an applicantfor awritten, oral, or practical test for a certificate and rating, orfor an additional rating underthis part, may applyfor retesting beforethe 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 ofthe subjects failed and that the airman considersthe applicant ready for retesting. 

### Relief Sought: CFR Title 14 Part 65.19(b): Lorenzo Walker Institute of Technology is petitioning for exemption from the requirement that a signed statement from an appropriately rated "certificate holder" certifying that additional instruction has been given in thefailed area be obtained priorto retesting. 

### Person to be Covered by the Exemption: Lorenzo Walker Institute of Technology, Air Agency, and students enrolled in its Aviation Maintenance Technology Airframe and/or Powerplant curricula. 

### Public Interest: Proposed oral and practical testing will be an integral part ofthe curriculum and will take place in progressive increments as astudent advances through training. Should a student fail an oral or practical test, retesting will be permitted based on the requirements for additional instruction contained in Lorenzo Walker Institute of Technology's approved Operations Handbook. It is in the public interestto allow Lorenzo Walker Institute ofTechnologyto control and monitor the retesting criteria for students who fail oral and practical testing under this proposal. The retesting criteria will be contained in its approved Operations Handbook with procedures in placeto document and track compliance. 

### Impact on Safety: Approval to retest will be authorized by the school as approved in its Operations Handbook, and not by individuals as required by CFR Title 14 Part 65.19(b). A level ofsafety equal to orgreaterthan that provided bythis rulewould be provided. 

### Economic Impact: Thiswill result in cost saving tothe student. 

### CFR Title 14Part65.75(b) Knowledge Requirements: Code of Federal Regulations CFR Title 14 Part65.75(b) prescribesthat an "applicant must pass each section ofthe (written) test before applying for the oral and practical tests prescribed by Part 65.79. 

### Relief Sought: CFR Title 14 Part 65.75(b): Lorenzo Walker Institute of Technology is petitioning exemptionfrom this rule to allow itto conduct oral and practicaltesting as an integral partofthe aviation maintenancetechnician educational process.U.S. Department ofTransportation Docket Operations, M-30 March 7, 2013, Revised May 30, 2013 Page4



### Person to be Covered by the Exemption: Lorenzo Walker Institution of Technology, Air Agency #WT5T076K, and students enrolled in its Aviation Maintenance Technology Airframe and/or Powerplant curricula. 

### Public Interest: Exemption from this rule would be in the public interest. A level of safety equal to that provided by the rule would be maintained while allowing students to demonstrate FAA required competency as part of the completion requirements for each instructional area through the administration of FAA oral and practical tests. Student learning would be enhanced and reinforced by the immediate feedback provided through incremental oral and practical testing. 

### Impact on Safety: Lorenzo Walker Institute of Technology curriculum is competency based. Rather than testing for competency at the conclusion of the entire body of knowledge for airframe or powerplant technician, as is required by CFR Title Part 65.75(b), oral and practical testing is to be conducted incrementally as an integral part of the instructional process and documented at the conclusion ofeach ofthe five major blocks of instruction: General, Airframe Structures, Airframe Systems, Powerplant Theory and Maintenance, and Powerplant Systems. This proposal will not adversely affect public safety. An oral and practical test over the entire body of knowledge for a mechanic certificate or added rating would be administered, but in smaller subdivisions ratherthan in one inclusivetest. Thiswould provide a level ofsafety equal tothat provided bythe rule from which this exemption is sought. 

### EconomicImpact: Therewill be no negative impact on the economy.

SUMMARYOF PETITION 

### 1:
The purpose of Petition I is to allow FAA oral and practical tests to be conducted as an integral part ofLorenzoWalker InstituteofTechnology's approved curriculum. CFRTitle 14Part65.17(a)Tests: 

### GeneralProcedure ReliefRequested: Lorenzo Walker Institute ofTechnology is petitioning to administer written, oral and practical tests at times and places designated in its approved Operations Handbook. CPR Title 14 Part65.19(b): 

### RetestingAfterFailure: Relief Requested: Lorenzo Walker Institute of Technology is petitioning to allow retesting of students "before 30 days have expired" based on the requirements for additional instruction outlined in its approved Operations Handbook.

### U.S. Department ofTransportation Docket Operations, M-30

CFRTitle 14 Part65.75(b): 

### Knowledge Requirement:March 7, 2013, Revised May 30, 2013 PageS



### ReliefRequested: Lorenzo Walker Institute of Technology is petitioning exemption from this rule to allow it to meet the oral and practical testing requirements contained in FAR Part 65to be done incrementallyas part ofits approved curriculum.

PETITION II: 

### An exemption to allow the Aviation Mechanic General (AMG) Written Test to be administeredaftercompleting thegeneralcurriculum: CFR Title 14Part65.75(a) and65.77Knowledge andExperience Requirements: Code of Federal Regulations CFR Title 14, Part 65.75(a) prescribes that applicants must pass a written test "after meeting the experience requirements of Part 65.77. Part 65.77 requires applicants to complete training and "present.

..an appropriate graduation certificate or certificate of completion from a certified aviation maintenance technician school" before being eligible to take awritten testforacertificate or rating. 

### ReliefSought: LorenzoWalker InstituteofTechnology is seeking exemptionfrom CFR Title 14 Part 65.75(a) to allow students enrolled in its Part 147 aviation maintenance technology program to take the Aviation Mechanic General (AMG) written test after completing the General curriculum, priorto meetingthe experience requirements ofCFRTitle Part 65.77

.. 

### Person to be Covered by the Exemption: Lorenzo Walker Institute of Technology, Air Agency and students enrolled in its Aviation Maintenance Technology Airframe and/or Powerplant curricula. 

### Public Interest: The public interestwill be served by allowing aviation maintenance technician students to take the FAA written test over a body of knowledge immediately following the successful completion of that body of knowledge. This is currently allowed with both the Airframe and Powerplant curricula, but is not allowed following the completion of the General curriculum. To test immediately following learning is a universally accepted instructional principle which reinforces learning and is academically sound. The time penalty incurred by beginning the testing process prior to completing the entire curriculum would be more than offset byacademicsoundness ofimmediatetesting.U.S. DepartmentofTransportation DocketOperations, M-30 March 7, 2013, Revised May 30, 2013 Page6


### Impact on Safety: Lorenzo Walker Institute ofTechnology has established a procedure with the Miami Flight Standards District Office 19 to identify and report graduates who are eligible to take the FAA written, oral, and practical tests with affiliate Designated Mechanic Examiners. This same procedure would be used to identify and report students who would qualify to take the Aviation Mechanic General written test after completion ofthe General curriculum. All other requirements governing written testing, including time requirements for licensure completion, would remain unchanged. A level of safety equal to that provided by this rule would be provided. 

### Economic Impact: None SUMMARYOF PETITION II: The purpose of Petition II is to allow the Aviation Mechanic General (AMG) written test to be administered priorto graduation from the entire curriculum. CFRTitle 14 Part65.75(a): 

### Knowledge Requirements: Relief Requested: Lorenzo Walker Institute of Technology is petitioning for an exemption from this rule to allow students to take the general written examination after completing the general curriculum.
Lorenzo Walker Institute ofTechnology appreciates any assistance you may be able to provide us in accomplishing these petitions.

YF:jk cc: Carlos RGrillo Principle Maintenance Inspector FlightStandards District Office 2895 S.W. 145thAve, Suite 120 Miramar Florida, 33027 Respectfullysubmitted,

Yolanda Flores, Principal LorenzoWalker Institute ofTechnology and LorenzoWalkerTechnical High School