# PimaCountyCommunityCollegeDistrict

U.S. Department ofTransportation Docket Operations West Building Ground Floor, RM W12-140 1200 NewJersey Av, SE. Washington, DC 20590

Re: 

### Petitionfor Exemptionfrom theexperiencerequirementsof *Title 14subpart65.77and65.75(a)
Sir or Madam Aviation Technology Center
7211 South ParkAvenue 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 underTitle 14, FAR 147. 

### Petition Extent I am petitioningyou at this time because we would like to adoptthe practice ofallowing our students to be administered the FAA AMG Written Knowledge Test immediatelyfollowing their successful completion ofour

### generalcurriculum, but before meeting the experience requirements ofTitle 14 FAR 65.77 and FAR 65.75 

### Reason Currently, ourtypical student must wait until they have finished eitherthe "general" and 

### "airframe curriculum" orthe "general" and 

### "powerplantcurriculum" 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. 

### Benefittothepublic We feel that it is in the public interest forthe students to test on the general subject matter immediatelyfollowing their successful completion ofthe 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 ParkAvenue Tucson, Arizona 85709-6185

Telephone (520) 206-5910 Fax (520) 206-5911 www.pima.edu
immediately after learning. This gives a clearer measurement oftheir understanding and retention of the topics. We can then use this information to improve our curriculum and teaching techniques to the benefit ofthe aviation public in general. Additionally, and rather importantly, the adoption oftesting upon completion ofthe general curriculum reinforces the learning experience forthe student. Levelofsafety We believe that adopting this practice would provide a level ofsafety 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 priorto 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 MissionaryAviation Technology" have been granted the exemption authorityto 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 relieffrom the 14 CFR Part 65.75 and 65.77 experience requirement. This will enable us to issue a "General" Completion Certificate allowing ourstudents to sit for the FAA AMG written test immediately aftertheir successful conclusion ofour general curriculum, but priorto meeting the experience requirements of FAR Part 65.77 and FAR 65.75 Feel free to contact me ifyou 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