Columbus State Community College, Aviation Maintenance Technology DL9T090R 

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Aviation Maintenance Technology

5355 Alkire Road

Columbus Ohio 43228

Air Agency Certificate DL9T090R

(614) 287-7100

Fax (614) 287-7103

February 19, 2013

Docket Management Facility

US Department of Transportation

1200 New Jersey Avenue, SE

West Building Ground Floor

Room W12-140

Washington DC 20590

Subject: petition for exemption from the Code of Federal regulations 

14CFR65.75(a) to allow the Aviation Mechanic General (AMG) written tests to be 

administered after completing the corresponding portion of the curriculum.

Dear Sir or Madam,

The Columbus State Community College Aviation Maintenance Technology operates a 

FAA Approved Maintenance technician School (AMTS) in Columbus, Ohio under Air 

Agency Certificate DL9T090R.

PETITION:

Columbus State is requesting an exemption from 14CFR65.75(a) to allow the Aviation 

Mechanic written tests (AMG, AMA, AMP) to be administered after completing the 

corresponding portion of the curriculum.

14CFR65.75(a) Knowledge Requirements: Title 14 of the Code of Federal Regulations 

Part 65.75(a) prescribes that applicants must pass a written test, “after meeting the 

experience requirements of 14CFRPart 65.77”

14CFR65.77 requires applicants to complete training and, “present either an appropriate 

an appropriate graduation certificate or certificate of completion from a certified aviation 

maintenance technician school” before being eligible to take the written test for a 

certificate or rating.

Relief Sought: Columbus State is seeking exemption from 14CFR65.75(a) to allow 

students enrolled in its 14CFR147 Aviation Maintenance School to take the Aviation 

Mechanic written tests (AMG, AMA, AMP) after completing the corresponding portion 

of the curriculum, prior to meeting the experience requirements of 14CFR65.77.
Columbus State Community College, Aviation Maintenance Technology DL9T090R 

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Person(s) to be covered by the exemption: Columbus State Community College Aviation 

Maintenance Technology DL9T090R and students enrolled in its AMTS program in the 

Airframe, Powerplant curricula.

Information, 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 a single or double rating program. This 

petition is structured top provide an opportunity for testing after the completion of any 

section of the curriculum (general, Airframe, Powerplant) regardless of the type of 

enrollment.

Columbus State has established a procedure with the Columbus FSDO (CMH – GL07) to 

identify and report graduates who are eligible to take the FAA written, oral, and practical 

tests to the FSDO and the schools affiliated written testing centers and Designated 

Mechanic Examiners (DME). The same procedure would be used to identify and report 

students who would qualify to take the AMG written test after completion of the General 

curriculum, the AMA written test after completion of the Airframe curriculum, and the 

AMP after completion of the Powerplant Curriculum. A graduation certificate or 

certificate of completion would only be issued after successful completion of the entire 

program in which the student is enrolled (Airframe, Powerplant). 

The exceptional circumstances encountered by students enrolled in a 14CFR146 AMTS 

are recognized and provided for by 14CFR65.80 which permits a student to take the oral 

and practical tests prescribed by 14CFR65.79 before the meet the applicable experience 

requirements of 14CFR65.77.

The time penalty incurred by beginning the testing process before the completion of the 

entire curriculum would be more than offset by the academic soundness of immediate 

testing.

Public Interest: The public interest will be served by allowing aviation maintenance 

technician students to take the FAA written test 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 reduce dropout rates. 

This petition does not differ materially from others on record, 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 Columbus FSDO and affiliated written testing centers and designated 
Columbus State Community College, Aviation Maintenance Technology DL9T090R 

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mechanic examiners. 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 Certification 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.

14CFR65.75(a) Knowledge Requirements:

Relief requested: Columbus State Community College Aviation Maintenance Technology 

is petitioning for an exemption from this rule to allow students to take the written 

examination after completing the corresponding portion of the curriculum.

Columbus State Community College Aviation Maintenance Technology appreciates any 

assistance you may be able to provide us in accomplishing these petitions.

Respectfully Submitted,

Jeffrey S. Gruber

Associate Professor/Program Coordinator

Columbus State Community College

Aviation Maintenance Technology