AFS-15-955-E 

September 1, 2015 

 Exemption No. 12755 

 Regulatory Docket No. FAA-2013-0184 

Mr. Mark Reed 

Program Coordinator 

Columbus State Community College 

5355 Alkire Road 

Columbus, OH 43228 

Dear Mr. Reed: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains its basis, and gives you the conditions and limitations of the exemption, 

including the date it ends. 

The Basis for Our Decision 

By letter posted to the docket on March 26, 2015, you petitioned the Federal Aviation 

Administration (FAA) on behalf of Columbus State Community College (CSCC) for an 

exemption from § 65.75(a) of Title 14, Code of Federal Regulations (14 CFR) to the extent 

necessary to allow CSCC to administer the aviation mechanic general (AMG) written test to 

students immediately following successful completion of the general curriculum, prior to 

meeting the experience requirements of § 65.77. 

Although you requested an extension of Exemption No. 10725 (copy enclosed), that 

exemption expired April 30, 2015. Thereafter, we are treating your request as a new petition 

and issuing CSCC a new exemption. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to CSCC. 
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The FAA has issued a grant of exemption in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption No. 10725, the FAA found that 

testing immediately after learning was a universally accepted instructional principle that 

reinforces learning. 

Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously requested in the 

enclosed Grant of Exemption No. 10725; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption No. 

10725 also apply to the situation you present; and 

 a grant of exemption is in the public interest. 

In addition, certain conditions and limitations included in this partial grant are necessary to 

ensure an equivalent level of safety with § 65.75(a). The majority of these conditions— 

requiring the petitioner to develop written testing procedures to include those procedures in 

its approved operating document or manual, and to obtain approval of those procedures from 

its Certificate Holding District office— will ensure that the school’s educational program and 

curricula continue to meet FAA regulatory standards. The other condition of this exemption 

requires that, before the petitioner may retest any student who has failed the AMG test and 

who also does not meet the experience requirements of § 65.77, the petitioner must retrain the 

student on each instructional item associated with the failed test and authorize the student to 

retake the test. To be clear, any student who is eligible to take the AMG test on the basis of 

his or her own experience, who does not need to rely on this exemption, may retrain 

according to § 65.19— including with any appropriately certificated airman. However, this 

exemption also creates a population of students who do not satisfy the § 65.77 experience 

requirements, and who are eligible to retake the AMG test only because of the petitioner’s 

exemption. To maintain an equivalent level of safety, this exemption requires the petitioner 

to retrain these students itself, using FAA-approved curricula and in accordance with the 

FAA’s AMTS standards, including the quality of instruction standards codified in § 147.38a. 

Our Decision 

Under the authority contained in 49 U.S.C. 106(f), 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Columbus State Community College an 

exemption from 14 CFR § 65.75(a) to the extent necessary to allow CSCC to administer the 

aviation mechanic general (AMG) written test to its students immediately following 

successful completion of the general curriculum, prior to meeting the experience requirements 

of § 65.77, subject to the conditions and limitations described below. 

Conditions and Limitations 

1. CSCC must develop written procedures for administering the AMG written test 

following successful completion of the general curriculum. 
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2. CSCC must ensure these procedures are available for use in its approved 

operating or curriculum procedures document or manual. 

3. Before retesting a student who has failed the AMG examination, and who also 

does not meet the experience requirements of 14 CFR § 65.77, CSCC must 

require the student to repeat each instructional item associated with the failed test 

and receive authorization from CSCC to retake the test. CSCC must have 

procedures for documenting and tracking compliance with all retesting 

procedures. 

4. Before exercising the privileges of this exemption, CSCC must provide revised 

procedures to its Certificate Holding District Office (CHDO) for review and 

approval. 

This exemption terminates on September 30, 2017, unless sooner superseded or rescinded. 

Sincerely, 

//s// 

John Barbagallo 

Deputy Director, Flight Standards Service 

Enclosure 

Exemption No. 10725