Columbus State Community College, Aviat ion Maintenance Technology DL9T090R Page 1 of 3 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 Jers ey 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 th e 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.

PETI TION: 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

a n 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 1 4CFR65.77.Columbus State Community College, Aviation Maintenance Technology DL9T090R Page 2 of 3 Person(s) to be covered by the exemption: Columbus Stat e Community College Aviation Maintenance Technology DL9T090R and students enrolled in its AMTS program in the Airframe, Powerplant curricula.

Information, views, or arguments to support th e action sought: testing immediately after learning is a universally accepted instructional principle that re inforces learning, and is

acad emically sound. This is currently allowed with both the Airframe and Powerplant curriculums, but is not allowed at th e 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, Air frame, 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 th e 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 writte n 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 bef ore 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 enhance d 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 d iffer 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 tes ts. This information is distributed to the Columbus FSDO and affiliated written testing centers and designatedColumbus State Community College, Aviation Maintenance Technology DL9T090R Page 3 of 3 mechanic examiners. The same procedure would be used to identify and report students who would qualify to take the Aviation Mechanic written test s 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

,

Jeff rey S. Gruber

Associate Professor/Pro gram Coordinator Columbus State Community College Aviation Maintenance Technology