# Aviation Institute ofMaintenance

5870 South Eastern Ave • Las Vegas, NV 89119 • Telephone (702)798-5511 August26, 2014

U.S. Department ofTransportation Document Management System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 ........

'·•' I Subject: Petition for exemption from Code ofFederal Regulations 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completingthe correspondingportion ofthe curriculum. Dear Sir orMadam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Las Vegas, NV, under Air Agency Certificate 9VMT610K. PETITION: AIM is requesting an exemption from 

### 14 CFR, Part 65.75(a) to allow the Aviation Mechanic written tests (AMG, AMA, AMP) to be administered after completing the corresponding portion ofthe curriculum. 

### 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass a written tt<st, "after meeting the experience requirements ofPart 65.77." §65.77 requires:applicants to completetraining and; "present either an appropriate graduation certificate or certificate ofcompletion from a certificated aviation maintenance technician school" before being eligible to take the written test for a certificate or rating. ReliefSought: AIM is seeking exemption·from 14 CFRPart 65.75(a) to allow students enrolled inits Part 147 Aviation.Maintenance Technician School to take the Aviation Mechanic writtentests (AMG, AMA, AMP) after completing·the c.orresponding portion ofthe. curriculum, priorto meeting the experience requirements of §65.77. Ferson(s) to be covered by the exemption: AIM, Air Agency 9VMT610K andstudents enrolhed in its.AMTS program in the Airframe and Powerplant curricula. Iilrorm:ation,views, or arguments to support the action:sought: Testing immediately after learning is a universally accepted instructionalprinciple thatreinforces learning, and is academically sound. This is currently allowed with boththe Airframe and Powerplant curriculums, but is not allowed at the completion ofthe General curriculum. Students attending the school are enrolled in the combined Airframe 

### & Powerplant curriculum. This petition is structured to provide an opportunity'for'te'stiii.g

### ;afterthe coinpletiori. 

### ofaii)isecliori 

### ofthe, c'urriculum (General, Airframe, Powerplant) regardless ofthe type of enrollment. 

### AiM has established a procedure with the Las Vegas, NV Flight Standards District Officeto identify andrep\)rt graduates who are eligible to take the FAA written, oral, and practical tests to boththe FSDO and the school's off-site affiliated written test center. The same procedure usedto identify and report studentswho qualify to take the AMG written test after completion ofthe General curriculum, wouldbe usedto identify those eligible to take the AMA written testafter completion ofthe Airframe curriculum and the AMP written test aftercompletion ofthe Powerplant curriculum. A graduation c.ertificate or certificate ofcompletion vyould onlybe issued after the successful completion ofthe entire program inwhichthe student is enrolled (Airframe 

### & Powerplant). The exceptional.circumstances encountered by students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 which permits a student to take the oral and practical tests prescribed by§65.79 before they meetthe applicable experience requirements of§65.77.

'**~** • j ' The time penalty incurred by beginningthe testing process before the completion ofthe entire curriculum would be more than offsetby the academiC souncfuess ofhnmediatetesting. '

### Public Interest: The public interest will be served by allowing aviation maintenance technician students to take the FAA written tests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforced bythe immediate feedback provided by the testing experience. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and increase retention rates. This petition does not differ materially from others onrecord, specificallyExemption number 

### 10836, and those requests have been deemed to be in the public interest. 

### Impact on Safety: A procedure is currently in place to identify and report students who are eligible to take the FAA written, oral and practical tests. This information is distributed to the Las Vegas, NV FSDO and the off-site, affiliated written test center. The same procedure would be used to identify and report students who would qualify to take the Aviation Mechanic written tests after the completion ofthe corresponding portion ofthe curriculum. All otherrequirements governing written testing, including time requirements for licensure completion would remain unchanged. A level ofsafety equal to that providedbythis rule wouldbe provided. 

### Economic Impact: There will be no impact onthe economy.


### SUMMARY OF PETITION The purpose ofthis petition is to allow the AviationMechanic written test (AMG, AMA, AMP) to be administered prior to graduating from the entire curriculum. 

### 14 CFR, Part 65.75(a) Knowledge Requirements: ReliefRequested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow students to take each written exami11ation after completing the corresponding portion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you may be able to provide us in accomplishing these petitions.

Corporate Offices 

### 4455 South Boulevard Virginia Beach, VA 

### 23452-1159 (757) 490-3151