# Aviation Institute ofMaintenance

7651 AirportBlvd. • Houston, TX • Telephone (713)644-7777 August 26,2014

U.S. Department ofTransportation DocumentManagement System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 .... ··

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Subject: Petition for exemption from Code ofFederal Regulations 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completingthe corresponding portion ofthe curriculum. Dear Sir or Madam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Houston, TX, under Air Agency Certificate X88T585K. PETITION: AIM is requesting an exemption from 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion ofthe curriculum. 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass a written test, "after meeting the experience requirements ofPart 65.77." §65.77 requires applicants to complete training and, "present either an appropriate graduation certificate or certificate ofcompletion from a certificated aviation maintenance technician school" before being eligible to take the written test for a certificate or rating. ReliefSought: AIM is seeking exemption from 14 CFRPart 65.75(a) to allow students enrolled in its Part 147AviationMaintenance Technician School to take the Aviation Mechanic written tests (AMG, AMA, AMP) after completingthe corresponding portion ofthe curriculum, priorto meeting the experience requirements of§65.77. Person(s) to be covered bythe exemption: AIM; Air Agency X88T585K and students enrolled in its AMTS program inthe Airframe and Powerplant curricula. Information, views, or arguments to sunnort the action sought: Testing immediately after learning is a universally accepted instructional principle thatreinforces learning, and is academically sound. This is currently allowed with boththe Airframe and Powerplant curriculums, but is not allowed at the completion ofthe General curriculum. Students attending the school are enrolled in the combined Airframe & Powerplant curriculum. This petition is structuredto provide an opportunity for testing after the completion ofany section ofthe curriculum (General, Airframe, Powerplant) regardless ofthe type of enrollment. AIMhas established a procedure withtheHouston, TX FlightStandards District Office to identify and report graduates who are eligible to take the FAA written, oral, andpractical tests to boththe FSDO and the school's on-site written test center. The same procedure used to identify and report students who qualify to take the AMG written test after completion ofthe General curriculum, would be used to identify those eligible to take the AMA written test after completion ofthe Airframe curriculum and the AMP -written test after completion ofthe Powerplant curriculum. A graduation certificate or certificate ofcompletion would only be issued after the successful completion ofthe entire program in whichthe student is enrolled (Airframe & Powerplant). The exceptional circumstances encountered by students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 which permits a studentto take the oral and practical tests prescribed by §65.79 before they meetthe applicable experience requirements of§65.77. The time penalty incurred by beginning the testing process before the completion ofthe entire curriculum would be more than offsetby the academic soundness ofimmediate testing.Public Interest: The public interest will be servedby allowing aviation maintenance technician students to take the FAA writtentests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforced by the immediate feedback providedbythe testing experience. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and increase retentionrates. This petition does not differ materially from others onrecord, specifically Exemption number 10836, and those requests have been deemedto be in the public interest. Impact on Safety: 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 Houston, TXFSDO and the on-site written test center. The same procedure would be usedto identify andreport students who would qualify to take the Aviation Mechanic writtentests after the completion ofthe corresponding portion ofthe curriculum. All otherrequirements governing written testing, including time requirements for licensure completion would remain unchanged. A level ofsafety equal to that provided bythis rule would be provided. Economic Impact: There will be no impact onthe economy.

SUMMARY OF PETITION Thepurpose ofthis petition is to allow the AviationMechanic written test (AMG, AMA, AMP) to be administered priorto graduating fromthe entire curriculum. 14 CFR, Part 65.75(a) Knowledge Requirements: ReliefRequested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow students to take each written examination after completingthe correspondingportion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you may be able to provide us in accomplishing these petitions.

erald Y agen, Pr side :A.viation Institute aintenance Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757) 490-3151