AFS-15-2881-E 

September 24, 2015 

 Exemption No. 10886A 

 Regulatory Docket No. FAA-2013-0808 

Mr. Timothy P. Kissel 

Vice President of Education 

MIAT College of Technology 

2955 S. Haggerty Road 

Canton, MI 48188 

Dear Mr. Kissel: 

This letter is to inform you that we have partially extended Exemption No. 10886. It explains 

the basis for our decision, describes its effect, and lists the conditions and limitations, 

including the date it ends. 

The Basis for Our Decision 

By letter dated June 18, 2015, you petitioned the Federal Aviation Administration (FAA) on 

behalf of the MIAT College of Technology (MIAT) for an extension of Exemption 

No. 10886. That exemption from § 65.75(a) of Title 14, Code of Federal Regulations (14 

CFR) allows MIAT to administer the Aviation Mechanic General (AMG) written test to 

students immediately following successful completion of the general curriculum, prior to 

meeting the experience requirements of 14 CFR § 65.77. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested amendment of the exemption would not set a 

precedent. 
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Our Decision 

The FAA is in the process of withdrawing or amending all previously granted exemptions to 

14 CFR § 65.75(a), which enabled certain Aviation Maintenance Technician Schools 

(AMTSs) to administer the AMG, Aviation Mechanic Airframe (AMA), and Aviation 

Mechanic Powerplant (AMP) written tests immediately following a student’s successful 

completion of the corresponding curricula. The FAA’s new and revised exemptions will only 

permit an AMTS to authorize students to take the AMG examination immediately after 

completing the corresponding curriculum, but will not allow students to take the AMA or 

AMP examinations before completing the corresponding curricula. 

In consideration of the foregoing, I find in the present case that a partial grant of exemption is 

in the public interest. Specifically, certain conditions and limitations have been included in 

this exemption to ensure an equivalent level of safety with 14 CFR § 65.75(a). The 

conditions and limitations require MIAT to develop written testing procedures, include those 

procedures in its operating document or manual, and obtain approval of those procedures 

from its Certificate Holding District Office (CHDO) to ensure that MIAT’s educational 

program and curricula continue to meet FAA regulatory standards. 

The additional conditions and limitations of this exemption also require that MIAT must 

retrain any student on the specific instructional items associated with a failed AMG test and 

authorize the student to retake the test. This would be applicable prior to any MIAT retesting 

of a student who has failed the AMG test and who also does not meet the experience 

requirements of 14 CFR § 65.77. 

To be clear, any student who is eligible to take the AMG test on the basis of his or her own 

experience, and who does not need to rely on this exemption, may retrain according to 14 

CFR § 65.19 - including with any appropriately certificated airmen. However, this exemption 

also creates a population of students who do not satisfy the 14 CFR § 65.77 experience 

requirements and who are eligible to retake the AMG test only because of the exemption 

granted to MIAT. To maintain an equivalent level of safety, this exemption requires MIAT to 

retrain those students itself, using its written procedures, its FAA-approved curricula, and in 

accordance with the FAA’s AMTS standards, including the quality of instruction standards, 

codified in 14 CFR § 147.38(a). 

The FAA has determined that the justification for the issuance of Exemption No. 10886 

remains valid with respect to this exemption and is in the public interest. Therefore, under the 

authority provided by 49 U.S.C. §§ 106(f), 40113 and 44701, which the FAA Administrator 

has delegated to me, I grant MIAT College of Technology an exemption from 14 CFR 

§ 65.75(a) to administer the AMG written test to students immediately following successful 

completion of the general curriculum, prior to meeting the experience requirements of 14 

CFR § 65.77, subject to the conditions and limitations listed below. 
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Conditions and Limitations 

1. MIAT must develop written procedures for administering the AMG written test 

following successful completion of the general curriculum. 

2. MIAT must ensure these procedures are available for use in its approved operating or 

curriculum procedures document or manual. 

3. Before retesting a student who has failed the AMG examination, and also does not 

meet the experience requirements of 14 CFR § 65.77, MIAT must require the student 

to repeat each instructional item associated with the failed test and receive 

authorization from MIAT to retake the test. MIAT must have procedures for 

documenting and tracking compliance with all retesting procedures. 

4. Before exercising the privileges of this exemption, MIAT must provide revised 

procedures to its CHDO for review and approval. 

The Effect of Our Decision 

Our decision extends the termination date of Exemption No. 10886, as amended, to 

October 31, 2017, unless sooner superseded or rescinded. 

Sincerely, 

//s// 

John Barbagallo 

Deputy Director, Flight Standards Service