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December 31, 2014

 Exemption No. 10836A

 Regulatory Docket No. FAA-2013-0495

Mr. Fred Dyen

Coordinator, Blue Ridge Community College

43 Aviation Circle, Hangar 4 East Suite 101

Shenandoah Valley Regional Airport

Weyers Cave, VA 24486

Dear Mr. Dyen:

This letter is to inform Blue Ridge Community College (BRCC) that the Federal Aviation 

Administration (FAA) has reassessed and amended its July 30, 2013, decision to grant

Exemption No. 10836. This letter also explains the basis for our decision, describes its effects, 

and lists the revised conditions and limitations.

The Basis for Our Decision

By letter dated May 30, 2013, Mr. Fred Dyen petitioned the FAA on behalf of BRCC for an 

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

necessary to allow BRCC students to take the Aviation Mechanic General (AMG), Aviation 

Mechanic Airframe (AMA) and Aviation Mechanic Powerplant (AMP) written tests after

completing the corresponding portion of the curriculum, prior to meeting the experience 

requirements of § 65.77. 

Our Decision

The FAA has reassessed its prior grant of exemption to BRCC. On July 30, 2013, the FAA 

granted the “exemption from 14 CFR § 65.75(a) so that BRCC students may take the airframe 

and powerplant written tests after completing the corresponding portion of the curriculum, 

before they meet the experience requirements of § 65.77.” In the past, the FAA has granted

similar § 65.75 exemptions to enable a few Aviation Maintenance Technical Schools (AMTS) 

to administer the airframe and powerplant written tests to students immediately following 
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successful completion of the airframe and/or powerplant curriculums but before meeting the

§ 65.77 experience requirements.

Upon further consideration, the FAA has concluded that certain aspects of this type of 

exemption could adversely affect safety. In particular, allowing students to take the AMA or 

AMP test in advance of meeting the experience requirements could result in a scenario in 

which an individual is able to obtain his or her airframe and/or powerplant certificate prior to 

meeting the § 65.77 experience requirements. Under § 65.80, when an AMTS shows the FAA 

that any student has made satisfactory progress and is prepared to take the appropriate oral and 

practical test, that student may test prior to meeting the applicable experience requirements of 

§ 65.77. Permitting a student who has passed the oral and practical skill requirements of 

§ 65.79 to also take the AMA and AMP written test, before completing the experience 

requirements in § 65.77, could enable students to circumvent our eligibility requirements. The 

FAA is therefore taking action to amend our previous AMTS § 65.75(a) exemptions by 

re-issuing each of them as a partial grant of exemption.

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

in the Federal Register because the amendment would not set a precedent, and any delay in 

acting on this amendment would be detrimental to public interest.

In consideration of the foregoing, I find that a partial grant of exemption would best serve the

public interest. Therefore, pursuant to the authority contained in 49 U.S.C. §§ 106(f), 40113, 

and 44701, delegated to me by the Administrator, Blue Ridge Community College is granted 

an amended exemption from 14 CFR § 65.75(a) to the extent necessary to provide Blue Ridge 

Community College the ability to administer the AMG written test to students immediately 

following successful completion of the general curriculum, and before meeting the experience 

requirements of 14 CFR § 65.75(a), subject to the conditions and limitations listed below.

Conditions and Limitations:

1. Develop written procedures for administering the AMG written test to BRCC students 

immediately following successful completion of the general curriculum.

2. Ensure these procedures are available for use in the BRCC’s approved operating 

procedures or curriculum procedures document, or manual, as applicable.

3. Before retesting after failure, BRCC must require a student to repeat the entire 

instructional unit associated with the failed test and receive authorization from BRCC 

to retake the test. BRCC must have procedures for documenting and tracking 

compliance with all retesting procedures.
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4. Before exercising the privileges of this exemption, BRCC must provide the revised 

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

The Effect of Our Decision

The FAA amends our prior exemption (Exemption No. 10836) and denies BRCC the 

authority to administer the AMA and AMP written test to any student who does not satisfy the 

experience requirements of § 65.77. This amended exemption is effective immediately and

terminates on June 30, 2015, unless sooner superseded or rescinded.

Sincerely,

/s/

John S. Duncan

Director, Flight Standards Service