James Doran 

12760 Walker Ave• Kansas City, KS 66901 

Phone: 503-313-2775 • E-Mail: james.daniel.doran@gmail.com 

PETITION FOR RULEMAKING 

Purpose: To change current policy to allow current and future Part 147 AMT students to take the written exam for General, 

Airframe, and Powerplant, after satisfactorily completing the subject requirements outlined in Part 147 Appendix B, C, and D. 

With the Understanding that the Oral and Practical test requirements remain in effect under Part 65.75 subpart B, unless 

otherwise approved by Part 65.80. 

Explanation: There are currently waivers issued by the FAA to Part 147 schools, which allow students to take the written test 

when the subject requirements have been met. This is a temporary and case-by-case situation. If this policy is made permanent 

and all encompassing, it has the potential to greatly improve the retention rate, graduation rate, and certification of Aviation 

Maintenance Technicians. The aviation industry is currently undermanned in certified mechanics. The needs of the aviation 

industry are not being met due to outdated policy. By allowing a student to test immediately following the completion of the 

subject matter it will greatly improve the success of certifying Airframe and Powerplant Mechanics. Under current policy, 

students must study 18 months (or more) of cumulative subject material before taking the required tests. The methods of 

education and knowledge retention are changing rapidly and the policies must change too. 

Proposed Language: Changes Highlighted 

§65.75 Knowledge requirements. 

(a) Each applicant for a mechanic certificate or rating must, after meeting the applicable experience requirements of §65.77, pass 

a written test covering the construction and maintenance of aircraft appropriate to the rating he seeks, the regulations in this 

subpart, and the applicable provisions of parts 43 and 91 of this chapter. The basic principles covering the installation and 

maintenance of propellers are included in the powerplant test. 

(b) The applicant must pass each section of the test before applying for the oral and practical tests prescribed by §65.79. A report 

of the written test is sent to the applicant. 

§65.77 Experience requirements. 

Each applicant for a mechanic certificate or rating must present either an appropriate graduation certificate or certificate of 

completion from a certificated aviation maintenance technician school or documentary evidence, satisfactory to the 

Administrator, of-

(a) At least 18 months of practical experience with the procedures, practices, materials, tools, machine tools, and equipment 

generally used in constructing, maintaining, or altering airframes, or powerplants appropriate to the rating sought; or 

(b) At least 30 months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant 

ratings. 

OLD: §65.80 Certificated aviation maintenance technician school students. 

Whenever an aviation maintenance technician school certificated under part 147 of this chapter shows to an FAA inspector that 

any of its students has made satisfactory progress at the school and is prepared to take the oral and practical tests prescribed by 

§65.79, that student may take those tests during the final subjects of his training in the approved curriculum, before he meets the 

applicable experience requirements of §65.77 and before he passes each section of the written test prescribed by §65.75. 

NEW: §65.80 Certificated aviation maintenance technician school students. 
(a) Whenever an aviation maintenance technician school certificated under part 147 of this chapter shows to an FAA inspector 

that any of its students has satisfactorily completed the curriculum outlined in §147 appendix B, C, and D, and is prepared to take 

the written test, that student may take the written test before the student meets the applicable experience requirements of §65.77. 

With the Understanding that the Oral and Practical test requirements remain under §65.75 subpart B, unless otherwise approved 

by §65 .80 subpart B. 

(b) Whenever an aviation maintenance technician school certificated under part 147 of this chapter shows to an FAA inspector 

that any of its students has made satisfactory progress at the school and is prepared to take the oral and practical tests prescribed 

by §65.79, that student may take those tests during the final subjects of his training in the approved curriculum, before he meets 

the applicable experience requirements of §65 .77. 

Included with this petition are signatures collected voluntarily in support of policy change. 

Thank you for your consideration. 

Sincerely, 

James Doran 

FutureA+P 

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