# l

November 16,2015 

# -- ENTERPRrsEI!f'sTATE COMM;UNITY COLLEGE _.--==;;,---,ALABAMA AVIATION CENTER

U.S. Department ofTransportation, Docket Operations West Building Ground Floor, Room W12-140 1200 NewJersey Avenue, SE. Washington, DC 20590 : i-";

SUMMARY: Alabama Aviation Center is seeking an exemption/relieffrom Title 14 CFRPart 65.77 to allow students to enter written examination at the completion ofthe General subject matter as described in CFR Part 147 appendix 

### B.

To Whom ItMay Concern, Alabama Aviation Center, air agency EN4Tl60M, is seeking an exemption from Title 14 CFRPart 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 Generalportion of the curriculum as well as:the**.~irframe** orPowerp1Mt.portions before being allowed to take,the College exit examination and enter FAA written examinations. This procedure requires our students to complete ourexit exam up to. a**fu~l y~ar**  after completing the General curriculum and subsequentAirframe curriculum. Ifgranted the exemption, students completing the General curriculum, typically after the first semester, would be allowed to take the exit examination and enterFAA written, 

### not the Oral and Practical, testing immediately afterthe subject matter is completed and while the information is current. This change inprocess would provide the students with an opportunity to focus solely on the subject matter in subsequent semesters inthe Airframe and/orPowerplant curriculum. The College understands the value ofteaching 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 147 appendicies. Currently, the semesterin which the students
are preparing to take the College exit examinations and enterFAA testing provides less than an optimal learning environment because ofstudentconcerns about the volume ofinformation in upcoming examinations.·

### The students tend to focus a great deal oftheir,time and effort engaging in rote memorization;drills ratherthantruly learning the.material beingpresented. 

### We feel that allowing.the students to enter**th~ir** exitexaminations 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 COMMUNITYCOLLEGE**~ALABAMA** AVIATION CENTER involved in looking back over a years worth ofmaterial 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 ofthe curriculum will lead to increased learning and decrease the need to focus on rote memorization as a means to pass the
exams. CFRPart 65.75, 65.77, and 65.79 ensures that no student could enterthe Oral and Practical portion ofthe certification process until the General and Airframe and/or Powerplant portions ofthe 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