800 Independence Ave., S.W.

Washington, DC 20591

AFS-15-3754

December 15, 2015

Mr. James Doran

12760 Walker Ave

Kansas City, KS 66901

Dear Mr. Doran:

This is in response to your letter dated August 24, 2015, posted to the public docket 

(No. FAA-2015-3213) petitioning the Federal Aviation Administration (FAA) on behalf 

of seventy-one students to initiate rulemaking to amend part 65 Certification: Airmen 

Other Than Flight Crewmembers of Title 14 Code of Federal Regulations (14 CFR). In 

your petition, you request to change current policy to allow current and future part 147 

Aviation Maintenance Technician School (AMTS) students to take the written exam for a 

General (AMG), Airframe (AMA), and Powerplant (AMP) certificate after satisfactorily 

completing the subject requirements outlined in part 147 Appendices B, C, and D with 

the understanding that the oral and practical test requirements remain in effect under 

§ 65.75(b), unless otherwise approved by § 65.80. 

It is the intent of parts 65 &147 to provide well educated aviation maintenance 

technicians for the aircraft maintenance industry. In recent months, the FAA has 

reevaluated § 65.75(a) exemptions prompted by our discovery of a loophole that 

potentially allows students to circumvent our experience requirements. Students must 

take written, oral, and practical tests to obtain a mechanic’s certificate. Under § 65.80, an 

AMTS may under some circumstances administer a student’s required oral and practical 

tests before the student satisfies the experience requirements of § 65.77. However, under 

§ 65.75(a), all students must satisfy § 65.77 before taking any written tests.

Granting an exemption to § 65.75(a) to allow students to take the AMA and AMP written 

tests before completing the experience requirements in § 65.77, could allow those 

students to circumvent our eligibility requirements. Therefore, the FAA’s new and 

revised exemptions will only permit students to take the AMG examination immediately 

after completing the corresponding curriculum, and not allow students to take the AMA 

or AMP written examinations until they have completed the corresponding curricula and 

met the experience requirements. 
2

In accordance with 14 CFR § 11.73, the FAA must use the following criteria when 

making a decision as to whether or not to amend current regulations based on a petition 

for rulemaking:

1) The immediacy of the safety or security concerns you raise;

2) The priority of other issues the FAA must deal with; and 

3) The resources we have available to address these issues.

On October 2, 2015, the FAA published a notice of proposed rulemaking (NPRM)

entitled “Aviation Maintenance Technician Schools (80 FR 59674).” This NPRM 

proposes to amend the regulatory requirements concerning curriculum, operating rules, 

exemptions, and appendices associated with FAA-certificated AMTSs. These 

amendments would modernize and reorganize the required curriculum subjects in the 

appendices of the current regulations. The FAA proposes to add a new paragraph (f) to 

§ 147.31 that would permit a student who had successfully completed the General 

curriculum to take the general written knowledge test even if the student had not met the 

experience requirements of 14 CFR § 65.77. 

This NPRM is posted to the public docket (FAA-2015-3901)

(http://www.regulations.gov), where you can review and comment on it. The comment 

period for this NPRM closes on February 2, 2016. After the comment period closes, the 

FAA evaluates and disposes of all received comments. You can track the status of this 

NPRM in the DOT’s semi-annual regulatory agenda, through the Office of Management 

and Budget’s (OMB) Office of Information and Regulatory Affair’s (OIRA) Unified 

Agenda website http://www.reginfo.gov/public/do/eAgendaMain). 

Based on the existence of the NPRM and the FAA’s actions associated with AMTS 

exemptions as noted above, the FAA does not believe that any further action is necessary 

in response to your petition. 

For the reasons above, we are dismissing your petition for rulemaking.

Sincerely,

/s/

John Barbagallo

Deputy Director, Flight Standards Service