Encouragement & Reality for Part 65 Petitioner

On Sept. 5, ARSA commented on a petition for exemption from the qualifications for a mechanic’s certificate defined in part 65 subpart D. The association applauded the petitioner’s commitment to aviation but cited the practical reality of the qualifications upheld by the rules.

Gregory Kruse lost his sight in a 2021 car accident. A private pilot with self-professed dreams of commercial aviation, Kruse has pivoted his ambition to aviation maintenance. In May, he submitted his petition for exemption from the § 65.71(a)(2) requirement that a person must “read, write, speak, and understand the English language” to be eligible for a mechanic certificate.

ARSA’s comments noted that Kruse can already meet the English language requirements of the cited paragraph. There are no regulatory limits on the reading aids, like prescription glasses, available to certificate holders. Whatever tools he chooses to support his text comprehension would constitute reading English. An exemption from this portion of the rule is unnecessary.

The association explained it instead would be necessary for Kruse to be exempted from § 65.79, which requires “demonstrating…the skill elements…contained in the Aviation Mechanic General, Airframe, and Powerplant Airmen Certification Standards.” Such a petition should not be granted. Meeting this standard is not only a challenge in comprehending written regulatory standards but also understanding complex technical instructions, drawings, and other data necessary in performance of work that itself demands visual acuity.

“Applicants must demonstrate, and certificate holders must maintain, the capability on a multitude of skills,” ARSA’s comments said. “The strictness and variety of the Standard’s demonstrations ensure the individual holds the basic knowledge as well as the physical skills and mental capability to find and appropriately rectify multiple and assorted technical issued during aviation maintenance.”

From detailed visual inspections required by airworthiness directives to supervision of others’ task completion, the comments explain a mechanic must be capable of confirming and certifying the satisfactory performance of work. Highlighting Kruse’s point about needed checks and balances in technical employment, ARSA concluded: “[The] mechanic is the check and balance that assures ‘everyone is doing their job correctly.’”

The regulatory standards for mechanic competency must be upheld, but ARSA also recognizes Kruse’s commitment to the industry despite a significant personal setback. In his petition, Kruse stated: “My passion is still heavily in the aviation field and should not be held back simply because I am blind.”

The association agreed but has encouraged him to expand his thoughts about potential careers beyond individual certification. Its comments concluded there are hundreds of other jobs that would allow Kruse to pursue a fulfilling career in aviation. In her message directly to Kruse, which ARSA Executive Director Sarah MacLeod sent along with a copy of ARSA’s comments, she applauded his determination to find a way no matter the odds.

ARSA stands up for the plain language standards of the rules, supports creative approaches to compliance, and is available to help anyone interested in an aviation career explore job opportunities consistent with their abilities. To see the association’s resources related to aviation careers, visit

To visit the FAA’s docket for the petition, click here.

To read ARSA’s comments, click here.

ARSA Training – Part 65: Getting a Mechanic’s Certificate

This session reviews the requirements of 14 CFR part 65 subpart D, which concerns aviation mechanics. It walks through the requirements for an individual to apply for a mechanic’s certificate, then defines the privileges and limitations bestowed on that individual by his or her certificate. Finally, it covers the enhancements to a mechanic’s privileges produced by obtaining Inspection Authorization.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

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