' ' 

November 2, 2015 

Docket Management Facility 

US Department of Transportation 

1200 NewJersey Avenue, SE 

West Building Ground Floor 

RoomW 12-140 

Washington, DC 20590 

; ; 

\"fl' ... , • ~ ! 

Subject: Renew.~l of petition, 10945, for exemption from Code of Federal Regulations 14 CFR, Part 

65.7 5( a) to allow tlw Aviation Mechanic General ( AMG). written e:X:am to be· administereo after· 

successful completion of the corresponding curriculum. · t ~ · ·· · 

Dear Sir or Madam, 

St. Philip's College (SPC) operates an approved Aviation Maintenance Technician School (AMTS) on its South 

West Campus under Air Agency Certificate PHJT009K. The school is seeking to renew its current exemption, 

10945, from Title 14 CFR Part 65.75(a). Our current exemption,10945 terminates February 28, 2016. 

Title 14 CFR Part 65.75(a), Knowledge Requirements, states that applicants for a mechanic certificate, or rating, 

must pass a written test after meeting: the applicable experience requirements ofPart 65.77. Part 65.77 requires that 

applicants must "present either an appropriate graduation certificate or certificate of completion from a certificated 

av'iatiort maintenanctHe'chniCian schdol'1 tohi: eligible tb take the w~itten exam for a certificate orrating. 

Relief being sought 

The AMTS at DMC is seeking relief from Title 14 CFR Part 65.75(a) to aliow students in its Part 147 program to be 

able to take the aviation mechanic general (AMG) written test after successfully completing the General curriculum, 

but prior to me€ting the experience requirements of Part 65.77. 

Public interest 

The public's interest would be served by permitting DMC AMTS students to take their FAA AMG written exam 

after successful completion of the General curriculum. The immediate feedback to the student would both enhance 

their learning as well as provide a sense of accomplishment. In tum, it would be expected that this would further 

encourage students to continue studying and be a positive influence to keep students in the program. 

Safety impact 

An existing procedure is in place to report students who are eligible to take the FAA written, oral, and practical tests 

to the San Antonio, TX FSD. This same procedure would be used to report DMC AMTS students who would be 

eligible to take the AMG written exam. A level of safety equal to what currently exists would be provided. 

Additional information, views, or arguments to support our request 

The testing of students immediately after learning is an accepted instructional principle that is both academically 

sound and reinforces learning. This practice is currently allowed for at the end of both the Airframe and the 

Powerplant curriculums, but not at the end of the General curriculum. 

Currently, 14 CFR Part 65.80 permits students at an AMTS who have made satisfactory progress at the school to 

take their oral and practical exams before meeting the applicable experience requirements of Part 65.77. 
Summary of request for publication in the Federal Register 

The purpose of this petition is to renew exemption,10945 for St. Philip's College Aviation Maintenance Technician 

School (AMTS) on its South West Campus operating under Air Agency Certificate PHJT009K. This exemption 

allows Aviation students who have completed all the AMG classes to take the AMG written test prior to completing 

the AMA or AMP training. The AMTS at DMC is seeking relief from Title 14_CFR Part 65.75(a) which requires 

students to pass a written test after meeting the applicable experience requirements of Part 65.77. 

St. Philip's College appreciates your consideration and assistance in granting this petition. 

s~· rei , .· /J .. Rodney 

' . Cotter r)Yl ~ 

Aircraft Program Director, 

St. Philip's College -South West Campus 

1800 Quintana Road 

San Antonio, Tx 

(210)486-7201 

Cc: Randall Kaser, PMI . 

San Antonio Flight Standards District Office