# Aviation Institute ofMaintenance

7251 West McCarty Street • Indianapolis, IN 46241 • Telephone (317)243-4519 August 26, 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 completing the corresponding portion ofthe curriculum. Dear Sir orMadam, Training Services Inc., d/b/a Aviation Institute ofMaintenance (AIM) operates an FAA Approved Aviation Maintenance Technician School (AMTS) in Indianapolis, IN, under Air Agency Certificate USBT077S. 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

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### 14 CFRPart 65.75(a) Knowledge Requirements: Title 14 ofthe Code ofFederal Regulations, Part 65.75(a) prescribes that applicants mustpass 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 or rating. 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 writtentests (AMG, AMA, AMP) after completingthe correspondingportion ofthe curriculum, priorto meeting the experience requirements of§65.77. · Person(s) to be covered bythe exemption: AIM, Air Agency USBT077S and students enrolled in its AMTS program in theAirframe and Powerplant curricula. Information, views, or arguments to supportthe action sought: Testing immediately after learning is a universally accepted instructional principle thatreinforces learning, and is academically sound. This is currently allowed withboththe 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 structuredto provide an opportunity for testing after the completion ofany section ofthe curriculum (General, Airframe, Powerplant) regardless ofthetype of enrollment. AIMhas established a procedure with the Indianapolis, IN Flight Standards District Office to identity and report graduates who are eligible to take the FAA written, oral, and practical tests to boththe 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, wouldbe used to identify those eligible to take the AMA written test after completion ofthe Airframe curriculum and the AMP written test after completion ofthe Powerplant curriculum. A graduation certificate or certificate ofcompletion would only be issued after the successful completion ofthe entire program inwhichthe student is enrolled (Airframe & Powerplant). The exceptional circumstances encountered by students enrolled in a 14CFRPart 147 AMTS are recognized and provided for by 14CFR 65.80 whichpermits a student to take the oral and practical tests prescribed by §65.79 before they meetthe applicable experience requirements of§65.77. Thetime penalty incurred by beginning the testing process before the complet_ion ofthe entire curriculum would be more than offset by the academic soundness ofimmediate testing. · · ·

'·'Public Interest: The public interest will be servedbyallowing aviation maintenance technician students to take the FAA writtentests covering a body ofknowledge immediately following completion oftheir studies ofthat material. Student learning will be enhanced and reinforced bythe immediate feedback providedbythe testing experience. This immediate feedback, coupled with a sense of accomplishment, is expected to encourage students to continue their studies and increase retention rates. This petition does not differ materially from others on record, specifically Exemption number 10836, and those requests have been deemedto be inthe public interest. Impact on Safety: A procedure is currently in place to identify andreport students who are eligible to take the FAA written, oral and practical tests. This information is distributed to the Indianapolis, IN 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 written testing, including time requirements for licensure completion would remain unchanged. A level ofsafety equalto thatprovided by this rule wouldbe provided. Economic Impact: There will be no impact on the economy.
SUMMARY OFPETITION The purpose ofthis petition is to allow the Aviation Mechanic 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 corresponding portion ofthe curriculum. Aviation Institute ofMaintenance appreciates any assistance you may be able to provide us in accomplishing these petitions.

erald Yagen, Pr side**~**viation Institute Corporate Offices 4455 South Boulevard VirginiaBeach, VA 23452-1159 (757) 490-3151