Robert A. Stewart

1907 Azure Drive

Dothan, Al 36303

Contact via VRS (Video Relay Service): 334-830-4599

Email: robertstewart@graceba.net

I, Robert Allen Stewart, am requesting consideration for partial exemption to 

CFR 65.71 (a) (2). I am hearing impaired and able to read, write, and understand 

the English language very well. Although due to my disability, I am unable to 

speak well. I have always been able to make myself understood one way or 

another, including when I was employed by IBM, GE, and SONY. I had an 

exemplary safety and production record with these employers. I, respectfully, 

desire for partial exemption to the rule written above. This is so I will be able to 

obtain my FAA Mechanic certificate with Airframe and Powerplant Ratings.

I have a Designated Mechanic Examiner to work with on the Oral & Practical 

Exam required by CFR 65.79. I will have the necessary interpreter present. I have 

consulted with my Designated Mechanic Examiner’s Principal Maintenance 

Inspector from Birmingham Flight Standards District Office and he has okayed this 

process and has the option to be present during the Oral and Practical Exam.

While my speech is, somewhat, difficult to understand, it has never been 

detrimental in my interactions with the public, customers, nor with co-workers. As 

to how this request would be in the public interest, my success in past jobs with 

IBM Federal Systems (Avionics Technician), GE, and SONY testifies to my 

success in making myself understood one way or another, hence my successful

job performance, because I performed my job well and in a safe 

manner...satisfying my employer and customer. By granting my request, allowing 

me to pursue certification and a job as Airframe and Powerplant maintenance 

technician, the public will be acquiring a technician who is knowledgeable, safety 

conscience, and diligent. My speech difficulties have not served as an 

impediment to past successful performance on the job. In my attempt to become 

an FAA certified Airframe and Powerplant maintenance technician, my excellent 

grades, training performance, and successful interactions with students and 

faculty, serves as evidence that I would be an asset to any company hiring me. 

As to safety concerns, the fact that my speech difficulty, has never been an issue 

in the successful and safe performance of my former jobs, as well as during the 

course of pursuing my Airframe and Powerplant training, there is nothing to 

indicate there would be safety issues in my future job that could not be remedied. 

There are many electronic devices and methods for assuring effective 

communication. I have always been able to work out procedures with my 

employers/co-workers/customers to assure successful interactions and address 

any safety issues. To be noted here, comparing to their hearing counterparts, the 

hearing impaired tend to have a better safety record because they tend to utilize 

their peripheral vision more, to compensate for difficulty hearing. The hearing 
impaired tend to notice subtle changes in their vision field, often overlooked by 

their hearing counterparts. This holds true for me.

Furthermore, as to the data pertaining to my current training, I have demonstrated 

a very capable knowledge in my applied studies as indicated by 3.68 GPA. May 7 

I completed the Airframe program a. May 8 I passed FAA Required Knowledge 

tests. May 10 I obtained A.A.S. degree in Airframe. I anticipate graduating with 

my A.A.S. degree in Powerplant December 2012.

Additional comments: The American Disabilities Act of 1990 indicates that one 

cannot presume that a qualified employee will not be able to perform their jobs in 

a successful and safe manner based on his/her hearing impairment or speech 

difficulty, that cannot be remedied with reasonable accommodations. 

In summary, I am requesting consideration for partial exemption to CFR 65.71 

(a)(2). I am hearing impaired and able to read, write, and understand the English 

language very well. Although due to my disability, I am unable to speak well, I 

have always been able to make myself understood. The reason why I feel I 

should receive this exemption is that I, have in the past utilized various 

Reasonable Accommodations as put forth in the Americans with Disabilities Act of 

1990, and expect to do so as an Airframe and Powerplant Maintenance 

Technician. I have demonstrated a very capable knowledge in my applied 

studies as indicated by 3.68 GPA. I completed the Airframe Program (May 7

th) 

with an AAS, and passed the FAA Required Knowledge tests May 8

th. I anticipate 

graduating with my AAS degree in Powerplant December 2012. I have been made 

aware that there are deaf people working L3 in Greenville, Texas. Also 6 deaf 

were certified last year as per AFS 640.

Thank you for your consideration in providing me with a partial exemption to 

CFR65.71 (a) (2).

Robert A. Stewart