# ALA M 0 COLLEGES ST. PHILIP'S COLLEGE

November 19, 2013

Docket Management Facility US Department ofTransportation 1200 New Jersey Avenue, SE West Building Ground Floor Room W 12-140 Washington, DC 20590 

### Subject: Petition for exemption from Code ofFederal Regulations 14 CFR, Part 65.75(a) to allow the Aviation Mechanic General (AMG) written exam to be administered after successful completion ofthe corresponding curriculum.
Dear Siror Madam, ' ! :, J St. Philip's College (SPC) ·operates an approved AviationMaintenancv Technician School.(AMTS) on its Southwest Campus under Air Agency Certificate PHJT009K. The school is seeking an exemption from Title 14·CFRPart 65.75(a). Title 14 CPRPart 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 ofPart 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 programto be able to take the aviation mechanic general (AMG) writtentest after successfully : · ··

### compl~ting the General

### c~culum, but prior to meeting the

### ~xperience requirements ofPart 65.77.'.· Public: int€rest Thepublic's interest wouldbe servedbypermitting DMCAMJS

### st~dentsto take their-FAA AMG · ,. written exam after successful completion ofthe General curriculum. The immediate feedback to the student would both enhance their learning as well as provide a sense ofaccomplishment. 

### 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.**.~** t r ' I**~** \ ',

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### Safety impact An existing procedure is in place to report students who are eligible to take the FAAwritten, oral, and practical tests to the San Antonio, TX FSD. This same procedure would beused to report DMC AMTS students who would be eligible to take the AMG written exam. A level ofsafety equal to what currently exists would beprovided. Additional information, views, or arguments to support our request The testing ofstudents immediately after learning is an accepted instructional principle that is both academically sound and reinforces learning. This practice is currently allowed for atthe end ofboth the Airframe andthe Powerplant curriculums, but not at the end ofthe General curriculum. Currently, 14 CFRPart 65.80 permits students at an AMTS who have made satisfactoryprogress at the school to take their oral and practical exams before meeting the applicable experience requirements of Part 65.77.
Summary ofrequest for publication in the Federal Register The purpose ofthis petition is to allow the Aviation Mechanic General (AMG) written exam to be taken by students inDMC's AMTS after successfully completing the General curriculum. The AMTS at DMC is seeking relieffrom Title 14 CFRPart 65.75(a) which requires students to pass a written test after meeting the applicable experience requirements ofPart 65.77. St. Philip's College appreciates your consideration and assistance in granting this petition. Sincerely,

# ~tm~ Rodney M. Cotter Aircraft ProgramDirector, St. Philip's College -Southwest Campus 1800 

### Quintana Road San Antonio, Tx (210)486-7201


### C: Randall Fasar, PMI San Antonio Flight Standards District Office