PimaCountyCommunityCollegeDistrict 

U.S. Department of Transportation 

Docket Operations 

West Building Ground Floor, RM W12-140 

1200 New Jersey Av, SE. 

Washington, DC 

20590 

Re: Petition for Exemption from 

the experience requirements of 

*Title 14 subpart 65.77 and 65.75(a) 

Sir or Madam 

Aviation Technology Center 

7211 South Park Avenue 

Tucson, Arizona 85709-6185 

Telephone (520) 206-5910 

Fax (520) 206-5911 

www.pima.edu 

February 16, 2015 

I am writing you from the Aviation Technology Center of Pima Community College in Tucson, Arizona. 

We are an FAA Certificated Aviation Maintenance Technician school (IZPT564X) providing Airframe and/ 

or Powerplant instruction under Title 14, FAR 147. 

Petition Extent 

I am petitioning you at this time because we would like to adopt the practice of allowing our students to 

be administered the FAA AMG Written Knowledge Test immediately following their successful 

completion of our general curriculum, but before meeting the experience requirements of Title 14 FAR 

65.77 and FAR 65.75 

Reason 

Currently, our typical student must wait until they have finished either the "general" and "airframe 

curriculum" or the "general" and "powerplant curriculum" before they can be administered the FAA 

AMG "general" Written Knowledge Test. This practice forces the student to wait many months after 

they have completed the general curriculum before taking the appropriate General test. 

Benefit to the public 

We feel that it is in the public interest for the students to test on the general subject matter 

immediately following their successful completion of the general curriculum when this information is 

freshest in their minds. Our teaching experience indicates that it is always preferable to test students 
PimaCountyCommunityCollegeDistrict 

Aviation Technology Center 

7211 South Park Avenue 

Tucson, Arizona 85709-6185 

Telephone (520) 206-5910 

Fax (520) 206-5911 

www.pima.edu 

immediately after learning. This gives a clearer measurement of their understanding and retention of 

the topics. We can then use this information to improve our curriculum and teaching techniques to the 

benefit of the aviation public in general. Additionally, and rather importantly, the adoption of testing 

upon completion of the general curriculum reinforces the learning experience for the student. 

Level of safety 

We believe that adopting this practice would provide a level of safety equal to the existing process. This 

is because the student would still have to complete the remaining airframe/powerplant curricula and 

pass the prescribed written, oral and practical tests prior to receiving their airmen's ratings. 

Supporting Information 

Further, we understand that several existing Part 147 schools such as the "Aviation institute of 

Maintenance" and the "Schools of Missionary Aviation Technology" have been granted the exemption 

authority to adopt this practice in regards to the AMG written exam. Please reference Dockets 

FAA-2014-0738-0001 and FAA-2011-0549 

In summary 

We therefore, petition you for relief from the 14 CFR Part 65.75 and 65.77 experience requirement. This 

will enable us to issue a "General" Completion Certificate allowing our students to sit for the FAA AMG 

written test immediately after their successful conclusion of our general curriculum, but prior to 

meeting the experience requirements of FAR Part 65.77 and FAR 65.75 

Feel free to contact me if you have any questions or comments. I can be reached at 520-206-5907 and at 

Thinman1@pima.edu. 

Thomas Hinman 

Aviation Advanced ogram Manager 

Desert Vista Campus 

Pima Community College 

7211 S. Park Avenue 

Tucson, Arizona 

*CFR Title 14, Chapter 1, Subchapter D, Part 65, Subpart D, 65.75 and 65.77