Aviation Institute of Maintenance 

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

August 26, 2014 

U.S. Department of Transportation 

Document Management System 

400 7th Street, SW., Room PL 401 

Washington, DC 20591-0001 ........ 

'·•' I 

Subject: Petition for exemption from Code of Federal Regulations 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. 

Dear Sir or Madam, 

Training Services Inc., d/b/a Aviation Institute of Maintenance (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 of the curriculum. 

14 CFR Part 65.75(a) Knowledge Requirements: Title 14 of the Code of Federal Regulations, Part 65.75(a) prescribes that applicants 

must pass a written tt<st, "after meeting the experience requirements of Part 65.77." 

§65. 77 requires:applicants to complete training and; "present either an appropriate graduation certificate or certificate of completion from 

a certificated aviation maintenance technician school" before being eligible to take the written test for a certificate or rating. 

Relief Sought: AIM is seeking exemption·from 14 CFR Part 65.75(a) to allow students enrolled inits Part 147 Aviation. Maintenance 

Technician School to take the Aviation Mechanic written tests (AMG, AMA, AMP) after completing· the c.orresponding portion ofthe. 

curriculum, prior to meeting the experience requirements of §65.77. 

Ferson(s) to be covered by the exemption: AIM, Air Agency 9VMT610K and students 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 

instructional principle that reinforces learning, and is academically sound. This is currently allowed with both the Airframe and 

Powerplant curriculums, but is not allowed at the completion of the 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 ;after the coinpletiori. of aii)isecliori of the, c'urriculum (General, Airframe, Powerplant) regardless of the type of 

enrollment. 

AiM has established a procedure with the Las Vegas, NV Flight Standards District Office to identify and rep\)rt graduates who are eligible 

to take the FAA written, oral, and practical tests to both the FSDO and the school's off-site affiliated written test center. The same 

procedure used to identify and report students who qualify to take the AMG written test after completion of the General curriculum, 

would be used to identify those eligible to take the AMA written test after completion of the Airframe curriculum and the AMP written 

test after completion of the Powerplant curriculum. A graduation c.ertificate or certificate of completion vyould only be issued after the 

successful completion of the entire program in which the student is enrolled (Airframe & Powerplant). 

The exceptional.circumstances encountered by students enrolled in a 14CFR Part 14 7 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 meet the applicable experience 

requirements of §65 .77. 

' ~ • j ' 

The time penalty incurred by beginning the testing process before the completion ofthe entire curriculum would be more than offset by 

the academiC souncfuess ofhnmediate testing. ' 
Public Interest: The public interest will be served by allowing aviation maintenance technician students to take the FAA written tests 

covering a body of knowledge immediately following completion of their studies of that material. Student learning will be enhanced and 

reinforced by the 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 on record, specifically Exemption 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 of the corresponding portion of the curriculum. All other requirements governing written testing, including time requirements 

for licensure completion would remain unchanged. A level of safety equal to that provided by this rule would be provided. 

Economic Impact: There will be no impact on the economy. 

SUMMARY OF PETITION 

The purpose of this petition is to allow the Aviation Mechanic written test (AMG, AMA, AMP) to be administered prior to graduating 

from the entire curriculum. 

14 CFR, Part 65.75(a) Knowledge Requirements: 

Relief Requested: Aviation Institute ofMaintenance is petitioning for an exemption from this rule to allow 

students to take each written exami11ation after completing the corresponding portion of the curriculum. 

Aviation Institute of Maintenance 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