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 C ertification : A irmen

O ther T han F light C rewmembers 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 ( AMT S ) 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 unde rstanding 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 maintenan ce 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 obtai n 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 sat isfy § 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 re quirements. 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 rulemak ing:

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 ( NP RM )

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 AMTS s . These

amendments woul d 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 t he 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

- 390 1) ( 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 regulator y 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 o n 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 fo r rul emaking.

Sincerely,

/s/ John Barbagallo Deputy Director, Flight Standards Service