# Aviation Institute ofMaintenance

4100 Raytown Road • Kansas City, MO 64129 • Telephone (816)753-9920 August26, 2014

U.S. Department ofTransportation DocumentManagement System 400 7th Street, SW., Room PL 401 Washington, DC 20591-0001 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 corresponding portion ofthe curriculum. Dear Sir or Madam, \.:

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Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Kansas City, MO, under Air Agency Certificate U5ET092K. 

### 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 CFR Part 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants must**pas~** a written test, "after meeting the experience requirements ofPart 65.77." §65.77 requires applicants to complete training 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 orratirig. 

### ReliefSought: AIM is seeking exemption from 14 CFRPart 65.75(a) to allow students enrolled in its Part 147 Aviation Maintenance Technician School to take the Aviation Mechanic written tests (AMG, AMA, AMP) after completingthe corresponding portion ofthe curriculum, prior to meeting the experience requirements of§65.77. 

### Person(s) to be covered by the exemption: AIM, Air AgencyU5ET092K and students enrolled in its AMTS programjnthe Airframe and Powerplant curricula. 

### Information, views, or arguments to suooort the action sought: Testing immediately after learning is a universally accepted instructionalprinciple that reinforces learning, and is academically sound. This is currently allowed with boththe Airframe and Powerplant curriculums, but is not allowed atthe 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 testing after the completion ofany section ofthe curriculum (General, Airframe, Powerplant) regardless ofthe type of enrollment. AIMhas estabUshed aprocedure with the Kansas City, MO Flight Standards District Office to identify and report graduates who are eligible to take the FAA written, oral, and practicaltests to both the FSDO and the school's on-site written test center. The same procedure used to identify and report students who qualify to take the AMG written test after completion ofthe General curriculum, would be used to identify those eligible to take the AMA written test after completion ofthe Airframe curriculum andthe AMP written test after completion ofthe Powerplant curriculum. A graduation certificate or certificate ofcompletion would onlybe issued after the successful completion ofthe entire program inwhichthe student is enrolled (Airframe 

### & Powerplant). The exceptional circumstances encounteredby students enrolled in a 14CFRPart 147 AMTS are recognized and providedfor by 14CFR 65.80 which permits a student to take the oral and practicaltests prescribed by §65.79 before theymeetthe applicable experience requirements of§65.77. Thetime penalty incurredby beginningthe testingprocess before the completion ofthe entire curriculum would be more than offsetby the academic soundness ofimmediate testing.

### 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 reinforcedbythe immediate feedback provided bythe testing experience. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and increase retention rates. Thispetition does not differ materially from others onrecord, 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 Kansas City, MO FSDO and the on-site 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 other requirements governing writtentesting, including time requirements for licensure completion would remain unchanged. A level ofsafety equalto that provided by this rule would beprovided. 

### Economic Impact: There will beno impact on the economy.



### SUMMARY OF PETITION The purpose ofthis petition is to allow the AviationMechanic written test (AMG, AMA, AMP) to be administered priorto 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 examination after completing the correspondingportion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you maybe able to provide us in accomplishing these petitions.

Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757) 490-3151