AFS-12-191-E April 18, 2012 Exemption No. 10511 Regulatory Docket No. FAA-2012-0081

Mr. Fred D. Dyen Coordinator, Aviation Maintenance Technology Program Blue Ridge Community College 43 Aviation Circle, Hangar 4 East Shenandoah Valley Regional Airport Weyers Cave, VA 24486

Dear Mr. Dyen:

This letter is to inform you that we have denied your petition for exemption. It transmits our decision and explains its basis.

The Basis for Our Decision

By letter dated January 25, 2012, you petitioned the Federal Aviation Adm inistration (FAA) on behalf of Blue Ridge Community College (BRCC) for an exemption from § 147.21(b)(1), (2) and (3) of Title 14, Code of Federal Regulations (14 CFR). The proposed exemption, if granted, would allow it to redistribute the overall 1900 mandated hours of instruction within the General, Airframe and Powerplant curriculum.

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

in the Federal Register because this is not a precedent-setting petition, and any delay in acting on this petition would be detrimental to BRCC.

The FAA issued denials of exemption in circumstances similar in all material respects to those presented in your petition. In Denial of Exemption Nos. 2955, 2955A and 3899 (copies enclosed) the FAA found that the hours of instruction, as a minimum, contained within 14 CFR § 147.21 continue to prepare a student to meet the FAA testing requirements established by 14 CFR part 65 and student trai ning standards as sought out by industry. The FAA continues to disagree that advances in teaching delivery methods would offset a reduction in any portion of current curriculum hourly requirements as established by rule.

The redistribution requested by BRCC would result in an increase of 50 hours to the General section and resulting subject area requirements of part 147 Appendix B. The requested2

Airframe redistribution would result in an increase of 50 hours to the Airframe section and resulting subject area requirements of part 147 Appendix C. The Powerplant redistribution would result in a loss of 100 hours to the Powerplant section and resulting subject area requirements of part 147 Appendix D.

The FAA disagrees that a reduction and or redistribution of the overall minimum curriculum hours would have any measurable positive impact on either the existing subject area requirements of part 147 Appendices B, C and D or enhancing the knowledge in those subjects without actually increasing the minimum 1900-hour curriculum requirements of § 147.21(b)(3).

A school is not prevented or restricted by part 147 from improving its curriculum in order to introduce new technological developments, teach a more current and relevant curriculum, permit the use of more efficient instructional technology, or enhance the professionalism of the curriculum as long as the minimum curriculum requirements are met. The petitioner has not shown that the current regulations prevent it from adopting the advanced instructional technology it wishes to use.

The FAA would however have no objection nor require any additional rulemaking activity or requirements in allowing a part 147 school, in the interest of advancing student knowledge, to increase the FAA minimum 1900 overall curriculum hour standards for learning or increase the teaching levels identified as level 1, 2 and or 3 specified within part 147 Appendix A and as applied to the subject area requirements of part 147 Appendix B, C and D.

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

 they do not differ materially from those presented by the petitioner in the enclosed Denials of Exemption Nos. 2955, 2955A and 3899;

 the reasons stated by the FAA for denying the enclosed Denial of Exemption Nos. 2955, 2955A and 3899 also apply to the situation you present; and

 for the reasons stated in Denial of Exemption Nos. 2955, 2955A, 3899, and in this letter, a grant of exemption would not be in the public interest.3

Our Decision

Under the authority contained in 49 U.S.C. §§ 40113 and 44701, which the FAA

Adm inistrator has delegated to me, I hereby deny Blue Ridge Community College an exemption from 14 CFR § 147.21(b)(1), (2) and (3).

Sincerely,

/s/

John S. Duncan Acting Director, Flight Standards

Service

Enclosures