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2.6.3.1 Determine the Student Has Met the § 65.80 Requirements. When an AMTS has determined that a student has met the requirements of § 65.80, the AMTS must sign the appropriate block of FAA Form 8610-2 to show the student is prepared to take the oral and practical tests prescribed by § 65.79.
The requirements are as follows:
• The AMTS must show to the FAA that the student has made satisfactory progress,
• The student is prepared to take the oral and practical tests prescribed by § 65.79, and
• The student is in the final subjects of training in the curriculum (i.e., the AMTS must be prepared to show the FAA that the student is in the final subjects of training in the curriculum).
2.6.3.2 AMTS Signature. The AMTS procedures should describe how it will ensure that each student applying to take the FAA oral and practical tests prior to taking the FAA written knowledge tests has met the § 65.80 requirements.
The procedures should include who (by title) is authorized to sign FAA Form 8610-2 on behalf of the AMTS and the timeframe for submitting the form to the FAA.
2.6.4 Exemptions. Many exemptions granted by the FAA have associated conditions or limitations which the exemption holder must meet to be in compliance with the exemption. The AMTSs are encouraged to develop written procedures to ensure compliance with the conditions and limitations of the exemption it intends to use, and thereby ensure continued regulatory compliance and safety.
2.6.5 Technical Data. The use of appropriate technical data is a cornerstone of aviation maintenance. Accordingly, the FAA recommends that AMTSs describe procedures for ensuring access to appropriate technical data applicable to the school’s rating(s), training equipment, and training materials, to include chemicals used during training.
2.6.6 Special Tools and Hand Tools. The AMTS should describe procedures for how it will ensure the maintenance of precision/special tools and hand tools. If the school has a student hand tool policy, such as a requirement that the student supply certain hand tools, this should also be described.
2.6.7 Procedures for FAA Certification of Students (e.g., Taking the FAA Written, Oral, and Practical Tests After Graduation). Since the main goal of most AMTS graduates is to obtain an FAA mechanic certificate, it is recommended the AMTS provides students with procedures describing how the student will move forward to the FAA testing process following graduation. The procedures should also describe how the AMTS graduation certificate, or other appropriate documentation, will provide eligibility towards FAA testing.
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2.6.8 Additional Administrative Procedures. The FAA recommends the AMTS provides whatever additional procedures it deems necessary to ensure its personnel are conducting operations in accordance with the expectations of the AMTS, and the requirements of part 147.
2.7 Curriculum/Training Requirements. Part 147 contains the following curriculum requirements:
• Curriculum description (application requirements), as required by § 147.5(b)(2). See paragraph 2.7.1 for additional discussion.
• Curriculum document and training requirements, as required by § 147.17(a)(1). See paragraph 2.7.2 for additional discussion.
2.7.1 Curriculum Description. The AMTS OpSpecs include a description of the manner in which the school’s curriculum will ensure the student has the knowledge and skills necessary for attaining a mechanic certificate and associated ratings under part 65 subpart D, and, therefore, the description must be included in the AMTS’s application for a certificate and rating, as required by § 147.5(b)(2). The FAA recognizes that there are many methods of instruction available in the education industry, and part 147 allows the school to decide the best method for the structure and delivery of its curriculum. The FAA will include the curriculum description in the AMTS OpSpec B001. The description should include discussion in the following areas, as applicable:
• Curriculum Basis,
• Curriculum Delivery Methods, and/or
• Curriculum Focus.
2.7.1.1 FAA Oversight. Pursuant to the FAA’s authority to conduct inspection (§ 147.27), the FAA’s oversight includes:
• Ensuring the AMTS is delivering its curriculum in the manner stated in the description. If the school were not following the described manner, it would be in violation of its OpSpecs (refer to § 147.3).
• Ensuring the curriculum basis, delivery methods, and any curriculum focus are achieving the standards of § 147.17(a)(2) and (3).
2.7.1.2 OpSpec Paragraph B001. The curriculum that an AMTS must provide in accordance with § 147.5(b)(2) will be included in the AMTS OpSpecs.
Additionally, because an AMTS may not operate in violation of its OpSpecs, pursuant to § 147.3, whenever the AMTS changes the description of its curriculum basis or delivery, it must provide those changes to the FAA for amendment of OpSpec B001. The description may be included in the OpSpecs by reference to a document provided by the AMTS, rather than by including the description directly into the body of the OpSpec. In these instances, the
2-18 document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.
2.7.1.3 Curriculum Basis. The following are examples of a curriculum basis that may be used for AMTS curriculum. There may be other examples of a curriculum basis that are not discussed here. Appendix B, Related References (Current Editions), lists several references that may assist schools in determining and developing the curriculum basis.
2.7.1.3.1 Hours-Based Curriculum. An AMTS may choose to base its curriculum on requiring student completion of a defined number of curriculum hours. For example, the school could base its curriculum on curriculum hours defined by the school, for each of the school ratings:
• Airframe — 1,150 hours (400 hours of general content plus 750 hours of Airframe content).
• Powerplant — 1,150 hours (400 hours of general content plus 750 hours of Powerplant content).
• Combined Airframe and Powerplant — 1,900 hours (400 hours of general content plus 750 hours of Airframe and 750 hours of Powerplant content).
Note: Part 147 does not prescribe minimum curriculum hours.
2.7.1.3.2 Credit Hours-Based Curriculum. An AMTS may choose to base its curriculum on requiring student completion of a defined number of credit hours. Credit hours should be based on higher education criteria, such as the credit hour criteria of the school’s accrediting agency.
Note: Part 147 does not prescribe an amount of credit hours.
2.7.1.3.3 Competency-Based Training (CBT) Curriculum. An AMTS could choose to develop its curriculum using educational practices based on competency and assessment. A standard for CBT has been developed by the International Civil Aviation Organization (ICAO).
• ICAO Doc 9868, Procedures for Air Navigation Services—Training, defines CBT and assessment as: “Training and assessment that are characterized by a performance orientation, emphasis on standards of performance and their measurement, and the development of training to the specified performance standards.” The ICAO document describes and the training takes into account the competencies and behaviors that are considered fundamental for aircraft maintenance personnel.
• ICAO Doc 10098, Manual on Competency-Based Training and Assessment for Aircraft Maintenance Personnel, provides guidance on a new approach of applying competency-based training and assessment to
2-19 aircraft maintenance personnel in accordance with Part III of the PANS- TRG (Doc 9868).
Note: Part 147 does not prescribe CBT standards.
2.7.1.4 Curriculum Delivery Methods. The school must ensure that the curriculum delivery method used to teach the various knowledge and skills required to perform aircraft maintenance under 14 CFR will achieve the training requirements put forth in § 147.17. Additionally, the delivery method must ensure that each instructor is able to comply with the instructor requirement to teach in a manner that ensures positive educational outcomes are achieved (refer to § 147.19(a)).
Note: The FAA does not approve a school’s curriculum delivery method.
2.7.1.4.1 In-Person Delivery. Much of the knowledge and skill training relative to aircraft maintenance is suited to in-person delivery, where students can learn and experience aircraft maintenance in an environment that is similar to what individuals will experience as certificated mechanics.
2.7.1.4.2 Distance Learning Delivery. There are various methods a school could use to deliver curriculum content that enables access to learning when the source of information and the learners are separated physically by time or distance, or both. Schools should carefully consider what curriculum content is appropriate for distance delivery to ensure expected learning outcomes will be met.
2.7.1.4.3 Virtual Simulation. Many AMTS are incorporating virtual simulation for conducting practical application of certain skills. For example, virtual welding and virtual paint booths use simulation equipment and technology to provide near-real environments while minimizing the hazards associated with those activities. When virtual simulation is used, the school must ensure that the learning objectives for knowledge and skill are met, just as they would in real-world practical application. Additionally, while the simulated environment may reduce the hazards associated with the task, it is important that students are highly aware of hazards when conducting the real-world task, as well as how to mitigate those hazards, such as with personal protective equipment (PPE).
2.7.1.5 Curriculum Focus. An AMTS may enrich portions of its curriculum to develop graduates who are directed toward particular areas of the aviation industry. For example, schools may train graduates specifically for employment at commercial airlines, helicopter operations, repair stations, or agricultural aircraft operations. Schools must ensure that the curriculum does not omit content that is in the Mechanic ACS, as, pursuant to § 147.17(a),
2-20 curriculum must continually align with the Mechanic ACS (refer to paragraph 2.7.2). Examples of curriculum focus include:
2.7.1.5.1 Example 1. An AMTS in a rural area may wish to focus on preparing students for General Aviation (GA) and aircraft operations such as agricultural operations. In this case, airframe subjects such as wood, dope, fabric, welding, rigging, and corrosion control would be emphasized for these subjects.
Powerplant courses such as propellers and reciprocating powerplants, including radial and opposed, would also be emphasized in the same ways. On the other hand, turbine engines, electronics, and air conditioning may be deemphasized, while still ensuring all knowledge and skills required by the Mechanic ACS are taught in these areas.
2.7.1.5.2 Example 2. An AMTS in a metropolitan area may concentrate on preparing students for employment at major airlines. This AMTS would tend to emphasize areas such as turbine engines, nondestructive inspection (NDI), air conditioning systems, auto flight, electronics, and airline maintenance systems. This AMTS may want to de-emphasize its teaching of wood, dope, fabric, welding, and reciprocating engine subjects, while still ensuring all knowledge and skills required by the Mechanic ACS are taught in these areas.
2.7.2 Curriculum. An AMTS must establish, maintain, and utilize a curriculum designed to continually align with Mechanic ACS, as appropriate for the ratings held, pursuant to § 147.17. The “curriculum” refers to the curriculum document(s) that a school must develop, which must align with the Mechanic ACS, depending on the ratings issued to school under § 147.11. The school’s curriculum must be used at all training locations of the school (i.e., different locations may not use different curriculum). However, all or a portion of the curriculum may be taught at any of the school’s locations.
2.7.2.1 Mechanic ACS. The phrase “mechanic airman certification standards” in § 147.17(a)(1) refers to the standards that have been incorporated by reference in § 147.17(b). The Mechanic ACS contains several high-level subjects. For each subject, the ACS specifies the aeronautical knowledge, risk management, and skill standards that an applicant for a mechanic certificate must know. An AMTS curriculum is required to align with the subject areas and with each of the aeronautical knowledge, risk management, and skill standards included in the Mechanic ACS.
2.7.2.1.1 Because part 147 requires use of the Mechanic ACS, which was not already published in the CFR or another location that carries the full force and effect of the law, the FAA incorporated the Mechanic ACS by reference.
Incorporation by reference is a mechanism that allows Federal agencies to comply with the requirements of the Administrative Procedure Act (APA) to publish rules in the Federal Register (FR) and the CFR by referring to material published elsewhere. Material that is incorporated by reference has the same legal status as if it were published in full in the CFR.
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2.7.2.1.2 In accordance with 5 U.S.C. § 552(a) and 1 CFR part 51, the FAA makes the Mechanic ACS reasonably available to interested parties. The FAA provides free online public access to view read-only copies of the Mechanic ACS that is incorporated by reference. The Mechanic ACS is available to the public for free viewing online on the ACS web page at https://www.faa.gov/training_test ing/testing/acs. In addition to the free online availability of this material for viewing on the FAA’s website, hard copies and printable versions are available from the FAA.
2.7.2.2 Aligning the Curriculum with the ACS. As previously discussed, the Mechanic ACS includes high-level subjects (e.g., Fundamentals of Electricity and Electronics, Aircraft Drawings, etc.), and then breaks the high-level subjects into components that include knowledge, risk management, and skill elements relevant to that subject. The knowledge, risk management, and skill elements set forth the standards for certification. Because § 147.17(a)(1) requires a curriculum to align with the Mechanic ACS, the curriculum must align with the standards set forth under the high-level subjects.
2.7.2.2.1 An AMTS will be in compliance with § 147.17(a)(1) if the school designs its curriculum to include:
• The high-level subjects that are listed in the Mechanic ACS; and
• Broader course content items, concepts, and practical projects under each high-level subject, which may encompass several of the more detailed knowledge, risk management, and skill elements listed in the ACS. For example, one broad course content item in the curriculum may encompass several knowledge elements listed in the ACS, while still aligning with the ACS. Similarly, a school could develop a curriculum that includes more content than the ACS, and still be in alignment with the ACS.
Note: While a curriculum must align with the high-level subjects and the standards set forth under those subjects, this does not mean that an AMTS must copy and paste the entirety of the Mechanic ACS into its curriculum. The intent of the regulation is to remove the prescriptive curriculum requirements from part 147 and provide a more flexible, performance-based standard that enables an AMTS to develop a curriculum that coincides with the Mechanic ACS.
2.7.2.2.2 If the curriculum does not align with the knowledge and skill elements contained in the Mechanic ACS, the school would also be in violation of the § 147.17(a)(3) training requirement because the Mechanic ACS contains the knowledge and skill standards that will be evaluated on the FAA written, oral, and practical tests for a mechanic certificate under part 65.
2.7.2.2.3 The curriculum must provide the opportunity for the student to obtain and demonstrate skill, as will be required during mechanic certification testing and expected following certificate issuance. Skill components of the ACS which
2-22 specify the applicant demonstrate the ability to perform an action related to a subject area element should be included into the AMTS curriculum as practical projects with defined performance criteria and outcomes.
2.7.2.3 Curriculum Document Design. The regulation does not require a specific design/format for a curriculum. Based on the ratings issued to the AMTS, the AMTS has the flexibility to design its curriculum document structure as desired. The school can only issue a certificate of completion for a completed curriculum, which correspond to the AMTS ratings. The AMTS ratings, curriculum design, and the graduation/completion document issued by the AMTS will affect at what point a student may be eligible to take the FAA written, oral, and practical exams.
2.7.2.4 Examples of Curriculum Document Design. Examples of possible curriculum document design have been included in Table 2-1 below. There may be additional possibilities that have not been included in the table. The left column reflects the ratings referenced in § 147.11. The middle columns show the possible curriculum designs, standalone or combined. The three columns preceding the “General Early Testing” column show the graduation document (or completion document) a school can issue after the appropriate curriculum is completed. For the last column, please refer to the footnote.
2-23 Table 2-1. Curriculum Design Examples If the AMTS holds this rating… And curriculum document design is in this format… Then the AMTS may issue completion documentation referencing the following curriculum… Airframe (A) Powerplant (P) General (G) Airframe + General (A+G) Powerplant + General (P+G) Combined (A+P+G) Airframe (A) Powerplant (P) A & P (single certificate) General (early testing) Airframe & Powerplant X X X X X[1] X Airframe X X X X Powerplant X X X X [1] A “general” curriculum completion document should only be issued if the AMTS can clearly document completion of the general content of its curriculum.
2.7.2.5 Additional Curriculum Content. The requirement that curriculum content align with the Mechanic ACS is a minimum standard. AMTSs may include additional content in their curriculum that is above and beyond what is included in the Mechanic ACS.
2.7.2.5.1 Safety Information. The aviation maintenance environment can be dangerous, especially to those who are not knowledgeable of its hazards and risk. The FAA recommends that AMTS integrate additional safety policy and procedures referenced in paragraph 2.6.1 into its curriculum document(s).
Results of AMTS risk mitigations, such as safety briefings or references to appropriate safety procedures, should be included in the AMTS curriculum or otherwise be readily available to instructors and students to increase safety awareness prior to high risk training operations.
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2.7.2.5.2 Tests/Evaluations. AMTS may choose to include information in the curriculum on the tests and/or other evaluations that are related to the subjects in the curriculum.
2.7.2.5.3 Practical Project Information. AMTS may choose to include additional information in their curriculum related to practical projects, such as performance criteria, tools and equipment required for the project, and safety information.
2.7.3 Revisions to the Curriculum.
2.7.3.1 Section 147.17(a)(1) requires AMTS curriculum to align with the ACS.
Therefore, when the Mechanic ACS is revised, a corresponding revision to the AMTS curriculum must also be made, no later than the effective date of the change to those standards.
2.7.3.2 The curriculum document(s) should use a method to identify revisions to the curriculum, such as a revision level and date, change bars, and/or LEP.
2.7.3.3 There is no requirement for the school to submit a revised curriculum to the FAA for review; however, the requirement to maintain the curriculum aligned with the Mechanic ACS is ongoing. Therefore, AMTSs are encouraged to communicate curriculum changes with the FAA certificate management team, and the FAA will conduct routine surveillance on AMTS curriculum to ensure continued alignment with the Mechanic ACS.
2.8 Facilities, Equipment, and Materials. Under § 147.13, each AMTS must provide and maintain the facilities, equipment, and materials that are appropriate to the rating or ratings held by the school and the number of students taught. The term “appropriate” means that the facilities, equipment, and materials provide a safe and suitable learning environment that results in the ability to meet the training requirements of § 147.17 (see paragraph 2.6). If certain facilities, equipment, and materials are essential to support the school’s curriculum, then the school must have those facilities, equipment, and materials.
To illustrate, if the curriculum includes a skill requirement that an applicant must perform on a specific piece of equipment, the school must have that piece of equipment
(e.g., where a school’s curriculum requires a student to be able to perform a skill requirement to service a battery, the school must have an aircraft battery in a condition that will allow a student to demonstrate the appropriate servicing requirements in order to be considered to have equipment appropriate to the rating).
Note: The safety of students is of utmost importance. Aircraft maintenance tasks can be dangerous and schools must ensure their facilities, equipment, and materials prevent injury or death in the learning environment.
2.8.1 AMTS Facilities. The AMTS must provide an environment suitable for learning to ensure that learning objectives set forth in § 147.17 are met. Considerations should include:
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• Distractions from learning, such as excessive noise, dust and fumes (poor ventilation), heat and cold (temperature control), and clutter should be considered. For example, classrooms should be separated from the noise and activity of shop and/or hangar environments.
• Facilities should be of adequate size for the number of students in a classroom, or accomplishing any of the laboratory or shop projects as appropriate to the school’s instructional design (e.g., a certain area or piece of equipment cannot accommodate a large number of students, but the school’s instructional design ensures it is used by small groups of students at different times).
• Facilities should be located and classes scheduled so that students can travel between classes without cutting into instructional time.
• The school should ensure the laboratory and shop floors are free from clutter, such as extension cords and air hoses.
Note: All school facilities must conform to any local, state, and Federal standards including those imposed by local fire departments, health agencies, and other regulatory agencies. Discussion of those requirements is beyond the scope of this AC.
2.8.1.1 Facility Description. AMTS OpSpecs will include a description of the facilities that will be used for instruction, as required by § 147.5(b)(1). The description must be detailed enough to demonstrate that the AMTS can provide and maintain facilities that are appropriate to the rating or ratings requested, and the number of students taught.
Note 1: The facility description discussed above may be included in the OpSpecs by reference to a document provided by the AMTS, rather than including the description directly into the body of the OpSpec. In these instances, the document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.
Note 2: It is recommended that the AMTS provide the FAA with a detailed drawing showing the layout and dimensions of the facilities.
See Appendix C, Sample Layout Facility.
2.8.1.2 Additional Training Locations. Facility descriptions must be included for each additional training location. The facilities of each additional training location must meet the requirements of part 147 and be listed in the AMTS OpSpecs, pursuant to § 147.15.
Note: Sometimes a course of study may be offered at a separate facility due to standards from local, state, and Federal codes that the primary AMTS facility cannot meet (e.g., requirements relating to operation of aircraft and associated noise, fire, and safety hazards). If
2-26 the AMTS will instruct curriculum content at a separate facility, then the AMTS must consider this an additional training location.
2.8.2 AMTSs Equipment. AMTS equipment includes, but is not limited to, shop equipment, tools (including hand tools), and instructional aids such as aircraft, aircraft components, and mock-ups used for learning. The AMTS must provide equipment suitable for learning to ensure that learning objectives set forth in § 147.17 are met.
2.8.2.1 Shop Equipment. AMTS should consider the following guidelines for shop equipment:
• Have enough shop equipment in place and in satisfactory operating condition to adequately serve the student enrollment and support intended curriculum learning outcomes.
• Maintain an adequate ratio of instructional aids-to-students in each shop class to ensure safety and facilitates learning.
• Shop equipment should be maintained in good working order and be in a condition for safe operation. A system should be in place for routine preventive maintenance and/or replacement.
• Large standing equipment should be securely installed and located to provide sufficient aisle space so students can move about freely.
2.8.2.2 Tools. The AMTS should provide any necessary tools required to provide appropriate instruction. The tools should be in satisfactory working condition and of the proper kind for the purpose for which they are intended. The AMTS should either provide common hand tools or require students to furnish their own.
2.8.2.3 Instructional Aids. The instructional aids should be appropriate for the scope and depth of the school’s curriculum. The AMTS should ensure the complexity of instructional aids is appropriate to the level of knowledge and skill outcome of the subject element. The AMTS should maintain a ratio of instructional aids-to-students, which ensures safety and facilitates learning.
Broken or deteriorated instructional aids should be repaired or replaced.
Examples of instructional aids include:
• Diagrams;
• Visual aids;
• Computers;
• Interactive software;
• Aircraft and mock-ups of aircraft;
• Engines and engine accessories; and
• Components, such as hydraulic servos, accumulators, etc.
2-27 Note: Part 147 does not require that each school have at least one aircraft currently certificated by FAA for private or commercial operations with powerplant, propeller, instruments, navigation and communications equipment, landing lights, and other equipment and accessories on which a maintenance technician might be required to work and with which the technician should be familiar. However, an aircraft can often provide an all-in-one instructional aid opportunity and can assist in familiarizing students with the real-world aircraft maintenance environment.
2.8.2.4 Sharing Training Equipment. Sharing of training equipment is acceptable among locations of an AMTS as long as equipment is available when needed to deliver the school’s curriculum.
2.8.2.5 Equipment Description. The AMTS OpSpecs will include a description of the equipment that will be used for instruction as required by § 147.5(b)(1).
The description must be detailed enough to demonstrate that the AMTS will provide and maintain equipment that is appropriate to the rating or ratings requested/issued, and the number of students taught. Descriptions must be provided to the FAA relative to equipment located at each training location of the AMTS.
Note: The equipment description discussed above may be included in the OpSpecs by reference to a document provided by the AMTS, rather than including the description directly into the body of the OpSpec. In these instances, the document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.
2.8.3 AMTS Materials. The AMTS must describe the materials to be used for instruction. The school must have sufficient materials in stock and properly stored to provide for the student enrollment.
2.8.3.1 Materials Description. The AMTS OpSpecs will include a description of the materials that will be used for instruction as required by § 147.5(b)(1). The description must be detailed enough to demonstrate that the AMTS can provide and maintain materials that are appropriate to the rating or ratings requested and the number of students taught. Descriptions must be provided to the FAA for materials located at each training location of the AMTS.
Note: The materials description discussed above may be included in the OpSpecs by reference to a document provided by the AMTS, rather than including the description directly into the body of the OpSpec. In these instances, the document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.