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 an y of the AKT’s. The exe mption we are seeking is to allow students from SSAMT to take their General Knowledge Test, prior to completing the Airframe curriculum. Specificall y we are requesting that the students from SSAMT be allowed to take the General Knowledge Test , 60 day s or l ess , 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 proces s 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 ini tially 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 day s of training . Airframe is 900 ho urs, which is 139 training day s, minimum

. We are a State of Connecticut adult vocational program. Our teaching ye ar is governed by state law. We provide approximately 186 day s per school year. The school is closed for July and August. We enroll 3 classes every

two years. The enrollments are in S eptember and March of one school year, and December of the following school ye ar. 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 ye ar. 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 ye ar

. 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 i n possession of the Airframe Certificate, in the earl y 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 requeste d exemption, will be evident, when Knowledge Test sco res for all the curriculums decrease

. This will be due to the lack of recency , and the multiplication of inform ation 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 an y 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 key s to helping students determine whether or not to test. Wi thout 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 s tudents 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 S ys tem. We are a fairl y inexpensive alternative to the for profit school s. 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 earl y 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 safet y 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

.