To:

U.S. Department of Transportation, 

Docket Operations, 

West Building Ground Floor, Room W12-140, 

1200 New Jersey Avenue, SE, Washington, DC 20590. 

From:

Stratford School for Aviation Maintenance Technicians (SSAMT)

Air Agency Certificate No. TF5T221N

200 Greatmeadow Rd.

Stratford, CT 06615

203-381-9250

Joe.Scarduzio@ct.gov

The Stratford School for Aviation Maintenance Technicians (SSAMT), is seeking an exemption to 

14CFR Part 65, § 65.75(a).

In accordance with Order 8080.6G, Chapter 5, Section 9 (b), it is required that applicants for Airman 

Knowledge Testing (AKT) must complete both the General curriculum, and either the Airframe or Powerplant 

curriculum prior to taking any of the AKT’s. The exemption we are seeking is to allow students from SSAMT 

to take their General Knowledge Test, prior to completing the Airframe curriculum. Specifically we are 

requesting that the students from SSAMT be allowed to take the General Knowledge Test, 60 days or less, from 

the scheduled date for the completion of the Airframe curriculum.

The initial reason we are seeking relief from the ruling is the burden it imposes on the student. The 

requirement to test while they are in the last portion of training, on curriculum they have completed, while in 

the process of trying to learn new subject matter that is inherently different from that they have already learned, 

is the issue. This problem is compounded by the fact that they will be tested on knowledge they initially learned 

a year prior, or more. 

Our program is 2400 hours in length. The initial 650 hours allows the student to complete the General 

curriculum. This is equivalent to 100 days of training. Airframe is 900 hours, which is 139 training days, 

minimum. We are a State of Connecticut adult vocational program. Our teaching year is governed by state law. 

We provide approximately 186 days per school year. The school is closed for July and August. We enroll 3 

classes every two years. The enrollments are in September and March of one school year, and December of the 

following school year. A class that begins in September, finishes the General curriculum in January of that 

school year. These students will not complete the Airframe curriculum until December of the following school 

year. The class that begins in March does not complete the Airframe curriculum until June of the following 

school year. The class that begins in December does not complete the Airframe curriculum until March of the 

following school year.

Before the current rule came into effect, students were allowed to qualify for a Graduation Certificate 

for the General curriculum, within two months of their scheduled completion date of the Airframe curriculum. 

The students that took advantage of this completed their General AKT, before the end of the Airframe 

curriculum. This allowed them to focus on preparation for the Airframe Knowledge Test, as well as the 

oral/practical test for both General and Airframe. Students who took advantage of this were in possession of the 

Airframe Certificate, in the early stages of their Powerplant curriculum. This resulted in less distraction during 

the balance of the Powerplant curriculum. It also allowed them more preparation time for Powerplant 

Knowledge Test, and the Powerplant oral/practical test.
The negative effects from not being granted the requested exemption, will be evident, when Knowledge 

Test scores for all the curriculums decrease. This will be due to the lack of recency, and the multiplication of 

information that must be mastered in a shorter period of time.

Another side effect that will grow is the number of students who will not test for certification. For the 

average student, their level of frustration was being projected before the rule change. The school philosophy is 

that students should be so well prepared for AKT’s that the likely hood of them failing, when they have to pay

for the actual test, is less than 5%. We will not issue a Graduation Certificate for any curriculum until the 

student score a 90% or higher on a simulated AKT. Due to the shortened time frame, from when students can 

begin the testing procedure, students may not be able to qualify to test until mid-way or toward the end of the 

Powerplant curriculum. If this happens they are left with an uncomfortable choice. 

It causes confusion because students are completing Powerplant. So do the students continue to prepare 

for Airframe Certification, or should they wait to complete their Powerplant Curriculum? With either choice 

they make, they will have more difficulty with the certification they delay. Once students complete the program, 

they lose the support of the staff, and the support of their fellow students. These both are keys to helping 

students determine whether or not to test. Without the aid of other students, who are preparing to test, or 

students that have succefully completed Certification, many of the students are afraid to test, feeling they are 

not prepared enough and will fail.

The fear of failure has more impact on the students in our program, than it does in other 147 schools. We 

are not a for profit school. As previously mentioned, we are part of the State of Connecticut Vocational 

Technical School System. We are a fairly inexpensive alternative to the for profit schools. This means that we 

draw a number of students that have little to no education resources. 30% or more of the students are on Pell 

Grants. At the start of the program, we inform the students of the expenses they face, when they go for testing. 

The cost of testing, itself, is a deterrent to a percentage of the students. 

Many of the students, who are aware of the testing expense, begin funding it early in the program. Most 

of them scrape together enough funds to be able to take each test, once. If for some reason they are not 

successful on their first attempt, this only prolongs the period of time to complete the testing. It makes them use 

money that would be used for the next test, which means it takes more time to build the funds back up, to 

continue the testing process.

There are no safety concerns that correlate to this exemption.

I ask that you consider what was stated here, as a basis to grant the exception.

Respectfully,

Joseph J Scarduzio

Joseph J Scarduzio

Department Head, Lead Instructor, SSAMT

Do the students continue to prepare for the Airframe Certification? Or because they are close to the end of 

Powerplant, do they wait until they finish Powerplant curriculum, and prepare for the Powerplant Certification, 

because this is fresh in their minds.