Changes to 65.80 early testing?

​Q: We heard that the new part 147 also makes changes to early testing under 14 CFR 65.80. Is early testing going away?
 
A: Section 65.80 is not going away. The regulation will be revised to align with some of the new verbiage in part 147, but not in a way that will impact early testing. Here’s the explanation out of the preamble to the new rule:

Section 65.80 allows AMTS students to take the oral and practical tests prescribed by § 65.79 before meeting the applicable experience requirements of § 65.77, and before the student passes each section of the written test prescribed by § 65.75. The school must show an FAA inspector the student has made satisfactory progress at the school and is prepared to take the oral and practical tests. Additionally, § 65.75 states the student may take the tests prescribed by § 65.79 during the final subjects of the student's training in the approved curriculum. The reference to “approved curriculum” in § 65.80 refers to a certificated AMTS's approved curriculum, which was required under § 147.21 as it existed prior to this interim final rule.
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In accordance with Section 135 of the statute, AMTS curriculums under part 147 will no longer require FAA approval, as reflected in new § 147.17. As a result, the FAA is making a conforming amendment to § 65.80 by removing reference to an AMTS's “approved” curriculum. This amendment will allow AMTS students to continue testing under § 65.80.

Further, § 65.80 permits students to take the oral and practical test prescribed by § 65.79 during the final subjects of the student's training in the part 147 curriculum before the applicable experience requirements of § 65.77 are met and before the student passes each section of the written test required by § 65.75 when the AMTS shows the student's satisfactory progress to an FAA inspector. In the interest of regulatory standardization, the FAA is revising the language from “an FAA inspector” to “the Administrator.” Additionally, the FAA is removing gender references within the regulatory text.
 
Here is how the new 65.80 will read as of Sept. 21, 2022 (the effective date of the new part 147), in line with the edits as described in the preamble to the new direct rule:
 
§ 65.80 Certificated aviation maintenance technician school students.
Whenever an aviation maintenance technician school certificated under part 147 of this chapter shows to the Administrator 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 the student's training in the curriculum required under part 147, before the student meets the applicable experience requirements of § 65.77 and before the student passes each section of the written test prescribed by § 65.75.