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 Administration (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 training 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 requested 
2 

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 

Administrator 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