ALA M 0 

COLLEGES 

ST. PHILIP'S COLLEGE 

November 19, 2013 

Docket Management Facility 

US Department of Transportation 

1200 New Jersey Avenue, SE 

West Building Ground Floor 

Room W 12-140 

Washington, DC 20590 

Subject: Petition for exemption from Code of Federal Regulations 14 CFR, Part 65.75(a) to allow 

the Aviation Mechanic General (AMG) written exam to be administered after successful 

completion of the corresponding curriculum. 

Dear Sir or Madam, ' ! :, J 

St. Philip's College (SPC) ·operates an approved Aviation Maintenancv Technician School.(AMTS) on its 

Southwest Campus under Air Agency Certificate PHJT009K. The school is seeking an exemption from 

Title 14·CFR Part 65.75(a). 

Title 14 CPR Part 65.75(a), Knowledge Requirements, states thatapplicants for a mechanic certificate, or 

rating, must.pass a written test after meeting the-appli(!able experience requirements of Part 65.77. Part 

6~.77 requires th,atapplicants inust·"present either an app~opri~te gradu<;ltion certificate or certi:ficate of 

completion from a certificated aviation maintenance technician school" to be eligible to take the Written 

exam for a certificate or rating. 

Reliefbeing sought 

TheAMTS at DMC is seeking relieffrmn Title 14 CFR·Part 65.75(a).to allow students in its,Part)47 

program to be able to take the aviation mechanic general (AMG) written test after successfully : · · · 

compl~ting the General c~culum, but prior to meeting the ~xperience requirements of Part 65. 77. '. · 

Public: int€rest 

The public's interest would be served by permitting DMCAMJS st~dentsto take their-FAA AMG · ,. 

written exam after successful completion of the General curriculum. The immediate feedback to the 

student would both enhance their learning as well as provide a sense of accomplishment. In turn, it would 

be expected that this would further encourage students to continue studying and be a positive influence to 

keep students in the program. 

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Safety impact 

An existing procedure is in place to report students who are eligible to take the FAA written, oral, and 

practical tests to the San Antonio, TX FSD. This same procedure would be used to report DMC AMTS 

students who would be eligible to take the AMG written exam. A level of safety equal to what currently 

exists would be provided. 

Additional information, views, or arguments to support our request 

The testing of students immediately after learning is an accepted instructional principle that is both 

academically sound and reinforces learning. This practice is currently allowed for at the end of both the 

Airframe and the Powerplant curriculums, but not at the end of the General curriculum. 

Currently, 14 CFR Part 65.80 permits students at an AMTS who have made satisfactory progress at the 

school to take their oral and practical exams before meeting the applicable experience requirements of 

Part 65.77. 

Summary of request for publication in the Federal Register 

The purpose of this petition is to allow the Aviation Mechanic General (AMG) written exam to be taken 

by students in DMC's AMTS after successfully completing the General curriculum. The AMTS at DMC 

is seeking relief from Title 14 CFR Part 65.75(a) which requires students to pass a written test after 

meeting the applicable experience requirements of Part 65.77. 

St. Philip's College appreciates your consideration and assistance in granting this petition. 

Sincerely, 

Rodney 

~tm~ M. Cotter 

Aircraft Program Director, 

St. Philip's College -Southwest Campus 

1800 Quintana Road 

San Antonio, Tx 

(21 0)486-720 1 

C: Randall Fasar, PMI 

San Antonio Flight Standards District Office