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.2

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 en sure 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 fo r administering the AMG written test following successful completion of the general curriculum.3

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