l 

November 16,2015 

-- ENTERPRrsEI!f'sTATE 

COMM;UNITY COLLEGE 

_.--==;;,---,ALABAMA AVIATION CENTER 

U.S. Department of Transportation, Docket Operations 

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590 

: i-"; 

SUMMARY: Alabama Aviation Center is seeking an exemption/relief from Title 14 CFR Part 

65.77 to allow students to enter written examination at the completion of the General subject 

matter as described in CFR Part 147 appendix B. 

To Whom It May Concern, 

Alabama Aviation Center, air agency EN4Tl60M, is seeking an exemption from Title 14 

CFR Part 65.77. Alabama A via:tion C~nter is an ~MTS approYed to offer the Airfra,me and 

Powerplant curriculum. CULTel);tly, our students are reqpired to. complete the General portion of 

the curriculum as well as :the .~irframe or Powerp1Mt. portions before being allowed to take, the 

College exit examination and enter FAA written examinations. This procedure requires our 

students to complete our exit exam up to. a fu~l y~ar after completing the General curriculum and 

subsequent Airframe curriculum. If granted the exemption, students completing the General 

curriculum, typically after the first semester, would be allowed to take the exit examination and 

enter FAA written, not the Oral and Practical, testing immediately after the subject matter is 

completed and while the information is current. This change in process would provide the 

students with an opportunity to focus solely on the subject matter in subsequent semesters in the 

Airframe and/or Powerplant curriculum. 

The College understands the value of teaching the subject matter and applies sound 

educational principles to ensure our graduates are able to demonstrate the knowledge, skills, and 

ability as prescribed by CFR Part 14 7 appendicies. Currently, the semester in which the students 

are preparing to take the College exit examinations and enter FAA testing provides less than an 

optimal learning environment because of student concerns about the volume of information in 

upcoming examinations.· The students tend to focus a great deal of their, time and effort engaging 

in rote memorization; drills rather than truly learning the .material being presented. We feel that 

allowing. the students to enter th~ir exit examinations at}d FAA written tests as they finish each of 

the required curricl!llums in CFRPart 147 appendicies B,c, ~d D would diminish the. stress 

3405 South U.S. Highway 231 • Ozark, AL 36360 • (334) 774-5113 • escc.edu • facebook.com/ ozaac • @EnterpriseSrate 
-- ENTERPRisE 1 rr--'s:rATE 

COMMUNITY COLLEGE ~ALABAMA AVIATION CENTER 

involved in looking back over a years worth of material thus producing graduates that have been 

afforded the opportunity to place more focus on learning the subject matter and being able to 

apply the information. The College feels that we could produce graduates with improved 

knowledge, skills, and ability which would lead to an increase in public safety. 

The College feels that an exemption would not adversely affect safety. We feel that 

allowing our students to test as they complete each section of the curriculum will lead to 

increased learning and decrease the need to focus on rote memorization as a means to pass the 

exams. CFR Part 65.75, 65.77, and 65.79 ensures that no student could enter the Oral and 

Practical portion of the certification process until the General and Airframe and/or Powerplant 

portions of the curriculum have been completed. The College would communicate, in writing, 

with our affiliated written test center and DMEs to ensure only the students that met the 

requiremnets would be able to complete the certification process. 

Thank you in advance for your time and consideration. 

Sincerely, 

Vicky Ohlson, PhD 

Interim President 

Enterprise State Community College 

Alabama Aviation Center 

3405 S US highway 231 

Ozark, AI. 36353 

1{334) 347-2623 ext. 2262 

3405 South U.S. Highway 231• Ozark, AL 36360 • (334) 774-5113 • escc.edu • facebook.com/ozaac • @EnterpriseStare