# 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 inPart 147 Appendix B,C, and D. With the Understanding that the Oral and Practical test requirements remain in effect under Part 65.75 subpartB,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. Ifthis policy is made permanent and all encompassing, it has the potential to greatly improve the retention rate, graduation rate, and certification ofAviation Maintenance Technicians. The aviation industry is currently undermanned in certified mechanics. The needs ofthe aviation industry are not being met due to outdated policy. By allowing a student totest immediately following the completion ofthe subject matter it will greatly improve the success ofcertifying Airframe and Powerplant Mechanics. Under current policy, students must study 18 months (or more) ofcumulative subject material before taking the required tests. The methods of education and knowledge retention are changing rapidly and the policies mustchange too. Proposed Language: Changes Highlighted §65.75 Knowledge requirements. (a) Each applicantfor a mechanic certificate or rating must, after meeting the applicable experience requirements of §65.77,pass a written test covering the construction and maintenance ofaircraft appropriate to the rating he seeks, the regulations in this subpart, and the applicable provisions ofparts 43 and 91 ofthis chapter. The basic principles covering the installation and maintenance ofpropellers are included in the powerplant test. (b) The applicant mustpass each section ofthe test before applying for the oral and practical tests prescribed by §65.79. A report ofthe written testis 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 tothe Administrator, of- (a) Atleast 18 months ofpractical experience with the procedures, practices,materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, orpowerplants appropriate to the rating sought; or (b) Atleast 30 months ofpractical experience concurrently performing the duties appropriate to boththe airframe and powerplant ratings. OLD: §65.80 Certificated aviation maintenance technician school students. Whenever an aviation maintenance technician school certificated under part 147 ofthis chapter shows to an FAA inspector that any ofits students has made satisfactory progress atthe 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 ofhis training in the approved curriculum, before he meets the applicable experience requirements of §65.77 and before he passes each section ofthe written testprescribed by §65.75.

NEW: §65.80 Certificated aviation maintenance technician school students.(a) Whenever an aviation maintenance technician school certificated underpart 147 ofthis chapter shows to an FAA inspector that any ofits students has satisfactorily completed the curriculum outlined in §147 appendix B,C,andD, and is prepared to take the written test, that student may take the written testbefore the student meets the applicable experience requirements of §65.77. With the Understanding that the Oral and Practical test requirements remain under §65.75 subpartB,unless otherwise approved by §65.80 subpart B. (b) Whenever an aviation maintenance technician school certificated under part 147 ofthis chapter shows to anFAA inspector that any ofits students has made satisfactory progress atthe school and is prepared to take the oral and practical tests prescribed by §65.79,that studentmaytake those tests during the final subjects ofhis training inthe 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

l. 

### 2. 

### 3. 4. 5. 6. 

### 7. 8. 9. 10. 11. 

### 12. 

### 13. 14. 15. 16. 17. 18. 19. 

### STATUS Page2

### Page3



### 20.

## ~fvl**~** 

## ,/l.q21. 

# St-I.Ac\**~V\**

# t22. 23. 

### 24. 25. 26. 27. 

### 28. 29. 30. 31. 32. 33. 34. 35. 36. 37. 38. 39. 

### 40. 41.

## lvd~ \.1 42.

# ~rv,t~-~.. 

# +- 43. 44. 45. 46. 47. 

### 48. 49. 50.

### Page4



### 51. 52. 53. 54. 55. 56. 57. 58. 59. 

### 60. 61. 62. 63. 

### 64.

## ...f'fvd-e~+ 65.

# :f~.l<v-f66. 

# .J.fvc/e 

# f

67. 68. 69. 70. 71. 72. 

### 73. 74. 75. 76. 77. 78. 79. 

### 80. 81.