2-25
• 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.
2-28
2.8.3.2 Technical Data. An AMTS should provide suitable technical data reference access. The technical data should be appropriate to the AMTS ratings and to the instructional equipment used by the school. At a minimum, the technical data should include the following:
• Title 14 CFR parts 1 through 199.
• Aircraft, engine, propeller, and Type Certificate Data Sheets (TCDS) and specifications.
• Airworthiness Directives (AD).
• Aircraft maintenance manuals, relative to the equipment used by the school.
• Supplemental Type Certificates (STC), relative to the equipment used by the school.
• ACs.
• Other instructional materials, such as textbooks on basic physics, math, hydraulics, powerplants, etc.
2.8.4 Additional Training Locations. Section 147.15 allows the AMTS to provide training at additional training locations. Additional training locations are any fixed location other than the school’s primary location. The additional location must meet all part 147 requirements and be listed in the AMTS OpSpecs, pursuant to § 147.15.
Note: If an AMTS is, or will be, conducting training at a location different from the address listed on the AMTS Air Agency Certificate and OpSpec A001, the school must consider these locations as additional training locations and notify the FAA to add these locations to the AMTS OpSpecs. Buildings co-located on a campus do not need to be considered separate training locations.
2.8.4.1 Notif y the FAA. Prior to conducting any training at an additional training location, the AMTS must notify the FAA so that the location can be added to the AMTS OpSpecs. Additionally, the facilities, equipment, and materials for each location are included in the AMTS OpSpecs. See paragraph
2.7.1 for additional information.
2.8.4.2 Curriculum Taught at Additional Location. All or a portion of the AMTS curriculum may be taught at an additional training location.
Note: Part 147 states each certificated AMTS must establish, maintain, and utilize a curriculum; both “AMTS” and “curriculum” are stated in the singular. While an AMTS may only have one curriculum, it may have separate curriculum components (i.e., general, Airframe, Powerplant) for the ratings that the AMTS holds.
2-29
2.8.4.3 Procedures. As previously stated, should an AMTS make changes to their FAA-approved QC system, such changes would need to be submitted to the FAA for updated approval.
2.8.4.4 FAA Surveillance. Pursuant to § 147.27, the FAA may inspect each additional training location requested by the AMTS, prior to adding the location to the AMTS OpSpecs.
2.8.5 AMTS Located Outside of the United States. Part 147 does not prohibit AMTS having a primary AMTS location, or additional training locations, from being located outside of the United States.
2.8.5.1 Certification and subsequent surveillance of AMTS primary or additional training locations outside of the United States are subject to fees in accordance with 14 CFR part 187. Refer to AC 187-1, Flight Standards Service Schedule of Charges Outside of the United States, for information on fees.
2.8.5.2 FAA certification and surveillance activities may be a coordinated effort between FAA offices depending on the location of the primary facility and any additional training locations.
2.8.5.3 The Department of Education recognition of accrediting agencies is limited by statute to accreditation activities within the United States as discussed in paragraph 2.5.1.1:
2.8.5.3.1 AMTS having a primary location within the United States and that are accredited within the meaning of 20 U.S.C. § 1001(a)(5) are recognized as having institutional accreditation which carries over to all additional training locations, whether located within or outside the United States
2.8.5.3.2 As previously discussed in paragraph 2.5.1, the Department of Education’s recognition of accrediting agencies is limited by statute to accreditation activities within the United States. As such, AMTS having a primary location outside of the United States must obtain FAA approval of a QC system meeting the requirements of § 147.23. Although the school may hold accreditation, the FAA will not recognize accreditation that is not within the scope of 20 U.S.C. § 1001(a)(5).
2.9 AMTS Instructor Requirements. Pursuant to § 147.5(b)(3), the AMTS must have a description of the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19. This description will be included in the AMTS OpSpecs. The requirements of § 147.19 include the following areas discussed in paragraphs 2.9.1 through 2.9.3:
Note: The instructor 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
2-30 document’s title, revision level, and revision date will be listed in the OpSpec, and the FAA will retain a copy of the document.
2.9.1 Positive Educational Outcomes. Each school must provide qualified instructors to teach in a manner that ensures positive educational outcomes are achieved, as required by § 147.19(a). Positive educational outcomes to refer to the training standards set forth in § 147.17, which are geared toward ensuring the AMTS provides training of a quality that satisfies the pass rate requirement specified in § 147.25 and equips students with the knowledge and skills needed to be prepared to test for a mechanic certificate and associated ratings under part 65.
2.9.1.1 The AMTS is responsible for ensuring the effectiveness of its instructors. The AMTS may decide to do this by a periodic internal evaluation of the instructor, or by some other method(s).
2.9.1.2 The FAA will assess instructor competency periodically during inspections by observing instructors in their teaching environment. Should the FAA have concerns with an instructor’s abilities to achieve positive educational outcomes, the concerns and observations will be provided to the AMTS to address the concern.
2.9.2 Instructor Qualifications. Section 147.19(b) requires that AMTS instructors either:
• Hold an FAA mechanic certificate, with one or more appropriate ratings; or
• Be otherwise specifically qualified to teach their assigned content.
2.9.2.1 Instructors Holding an FAA Mechanic Certificate. When using instructors that hold an FAA mechanic certificate, the AMTS must ensure that the instructor has the appropriate mechanic certificate rating relative to the specific subject(s) or course content they teach. Additionally, during certification or other FAA inspection, the AMTS must be able to show the FAA that the instructor holds an FAA mechanic certificate, with appropriate ratings.
2.9.2.2 Specifically Qualified Instructors (Instructors Not Holding an FAA Mechanic Certificate). The AMTS must ensure that any instructor who has not been issued an FAA mechanic certificate is specifically qualified to teach their assigned subject(s) or course content. The specifically qualified instructor should have specific qualifications relative to their intended area of instruction. Some examples for showing qualifications include:
• Documentation of practical experience in the procedures, practices, inspection methods, materials, tools, machine tools, and equipment. In most cases, this should reflect aviation maintenance experience.
2-31
• Documented evidence of formal training designed to qualify the applicant for the specific area of instruction (e.g., a specialized course, webinar, or symposium).
2.9.2.3 Qualifying and Authorizing Instructors. The AMTS should make a determination that all of its instructors are competent to instruct students in the areas where they will be assigned teaching responsibilities. The AMTS should ensure it is maintaining and following its description of the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19. Failure to follow this description could be a violation of AMTS OpSpecs.
Note: During certification and surveillance, the FAA will verify the requirements of § 147.19 for each of the AMTS instructors. It may be beneficial to the AMTS to maintain a list of all instructors, their qualifications, and their assigned teaching content. This documentation may save an AMTS time during FAA inspection; however, a list is not required by regulation.
2.9.3 Student/Teacher Ratios. Section § 147.19(c) requires at least one instructor for every 25 students in any shop class. The AMTS may choose to provide a lower student-to-teacher ratio (i.e., additional instructors, according to the needs of the class or subject).
3-1 CHAPTER 3. OPERATING REQUIREMENTS
3.1 Operation After Certification. Title 14 CFR part 147 specifies the requirements for the certification and operation of FAA-certificated AMTSs. An AMTS must continue to meet all of the requirements of part 147 following initial certification and after the AMTS has added or removed a rating. Initial certification requirements are continuing and ongoing;
therefore, the certification requirements discussed in Chapter 2 are not repeated in this chapter. The following additional topics are discussed below related to operation following certification:
• Amending the FAA Air Agency Certificate (§ 147.5).
• Other Changes Requiring Application.
• Changes Requiring Notification to the FAA.
• Minimum Passage Rate (§ 147.25).
• FAA-Approved Quality Control (QC) System (§ 147.23(b)).
• Early Testing (§ 147.31).
3.2 Amending the Air Agency Certificate. An AMTS is required to operate in accordance with its AMTS certificate and its OpSpecs, which are issued by the FAA, pursuant to § 147.3. Therefore, should any of the elements that formed the basis for original certification change, the AMTS must apply for an amended certificate. Therefore, the AMTS must submit an FAA Form 8310-6, Aviation Maintenance Technician School Certificate and Ratings Application, in the following situations:
• When there is a requested change in the AMTS rating(s) (i.e., adding or removing a rating);
• Change of location of the primary school location;
• Change of name of the AMTS;
• Changes of ownership, if the AMTS is requesting a new certificate number.
Note: The AMTS is responsible for submitting proposed amendments to the FAA, while allowing the FAA a reasonable amount of time to evaluate and respond to the changes, based on the scope of the proposed amendment(s). The FAA recommends that the AMTS contact its responsible FAA office to coordinate a reasonable timeframe for evaluation of the proposed amendment.
3.2.1 Adding/Removing Ratings.
3.2.1.1 The ratings issued to an AMTS are displayed on the FAA-issued Air Agency Certificate. Therefore, either adding or removing a rating results in an amendment to the certificate. When adding a rating, § 147.5(c) states the application must only include the information necessary to substantiate the
3-2 change; therefore, the school does not have to submit information substantiating a rating already held.
3.2.1.2 The school’s operations specifications (OpSpecs) will list the AMTS ratings.
Therefore, changes to AMTS ratings will also require revision to OpSpec A003 by the FAA.
3.2.2 Change of AMTS Primary Location.
3.2.2.1 The address of the primary location of the AMTS is displayed on the FAA-issued Air Agency Certificate. Therefore, changing the location of the AMTS primary location requires an amendment to the certificate. When changing the primary location, § 147.5(c) states the application must only include the information necessary to substantiate the change; the school does not have to submit information regarding other training locations not relevant to the change.
3.2.2.2 The school’s OpSpecs will list the physical address of the school’s primary location. Therefore, changes to the AMTS primary location address will also require revision to OpSpec A001, Issuance and Applicability, by the FAA.
3.2.3 Change of AMTS Name. The name of the AMTS is displayed on the FAA-issued Air Agency Certificate. Therefore, changing the AMTS name results in an amendment to the certificate. When changing the name, § 147.5(c) states the application must only include the information necessary to substantiate the name change.
3.2.3.1 Each of the school’s issued OpSpec paragraphs include the name of the school. Therefore, the FAA will reissue all OpSpecs paragraphs upon change of an AMTS name.
3.2.3.2 Additional business names (doing business as (DBA)) are also displayed on the FAA-issued Air Agency Certificate. Therefore, requests for addition or removal of a DBA results in an amendment to the certificate, and the AMTS must make the request by submitting FAA Form 8310-6.
3.2.4 Change in Ownership/Sale or Transfer of Assets. There is no express provision in part 147 that addresses a change of ownership of an AMTS. A change of ownership does not require application for a new certificate if there has been no change to location, facilities, or personnel. If the new owner amends the Air Agency Certificate rather than obtaining a new certificate, that owner could be held responsible for regulatory noncompliance that occurred by the air agency under the original owner.
3.2.4.1 Change of AMTS Certificate Number. When there are changes in AMTS ownership that include a change of location, facilities, equipment, materials, personnel, or curriculum, the FAA recommends that the new owner request a new certificate number by undergoing the certification process. Doing so would ensure the new owner is not subject to a Freedom of Information Act (FOIA) request and liability issues.
3-3
3.2.4.1.1 If a new owner requests to retain the existing certificate number, that owner could be held responsible for any actions that were taken by the air agency under the original owner. New owners will be asked to stipulate in writing that they clearly understand the potential of release of information under the FOIA.
3.2.4.1.2 A request for a new Air Agency Certificate number requires amendment of the AMTS certificate and the owner will be directed to make the request on FAA Form 8310-6. The request will be reviewed by the FAA to ensure the air agency continues to meet all part 147 requirements.
3.2.4.1.3 If the new owner elects to retain the original certificate number, and is permitted to do so, the revised FAA Form 8000-4, Air Agency Certificate, will show the original certification date in the “Date issued” field.
3.2.4.1.4 If a new certificate number is issued, the Air Agency Certificate will show the issuance date of the new certificate number.
Note 1: The “Date issued” should always reflect the original certification date of the certificate number on the Air Agency Certificate.
Note 2: The FAA will reissue all OpSpecs following an approved change of the certificate number.
3.3 Changes Requiring Notification to the FAA.
3.3.1 Adding Training Locations. When adding training locations, a certificated AMTS is not required to submit FAA Form 8310-6, because adding locations is neither an initial certification nor an amendment to a certificate. However, § 147.15 requires each additional training location to be listed in the AMTS OpSpecs. Therefore, the AMTS must notify the FAA of its additional location being requested. The school may not use an additional training location unless the FAA has listed the location on OpSpec A008, Additional Training Locations.
3.3.1.1 The AMTS should expect the FAA to conduct inspections to determine the additional location meets all part 147 requirements prior to adding the location to OpSpec A008.
3.3.1.2 Additionally, the AMTS must provide a description of the facilities, equipment, and materials for each location as required by § 147.5(b)(1); this description will be included in the AMTS OpSpecs. Therefore, the AMTS must provide descriptions (or reference to those descriptions) of the facilities, equipment, and materials, for each location, to the FAA for inclusion in OpSpec A015, Facilities, Equipment, and Materials (see Chapter 2, paragraph 2.4).
3-4
3.3.2 Changes to the AMTS Description of Facilities, Equipment, or Materials. Since a description of AMTS facilities, equipment, and materials are included in the AMTS OpSpec, and because an AMTS may not operate contrary to its OpSpecs pursuant to § 147.3, any changes to the AMTS facilities, equipment, or materials must be submitted to the FAA so that the OpSpecs can be revised.
3.3.3 Changes to the AMTS Description of Curriculum. Since a description of the AMTSs’ curriculum is included in the AMTS OpSpec, and because an AMTS may not operate contrary to its OpSpecs pursuant to § 147.3, any changes to the AMTS curriculum description must be submitted to the FAA so that the OpSpecs can be revised.
3.3.4 Changes to the AMTS Description on Instructors. Since a description of how the AMTS ensures it provides the necessary qualified instructors is included in the AMTS OpSpec, and because an AMTS may not operate contrary to its OpSpecs pursuant to § 147.3, any changes to the AMTS instructor description must be submitted to the FAA so that the OpSpecs can be revised.
3.3.5 Transfer of a Part 147 Certificate Oversight. Transfers of certificates can occur as a result of an AMTS request, or could be FAA initiated. Transfers between FAA offices typically occur if the AMTS changes its location; however, other instances could also result in a transfer of FAA office of responsibility.
3.3.5.1 Whenever there is a change to the AMTS location that results in a change to the responsible Flight Standards office, the AMTS should coordinate with its current responsible office to outline a plan for the transfer that ensures school operations and the impact on students is minimal.
3.3.5.2 If the transfer is the result of an AMTS location change, the responsible Flight Standards office will coordinate with and forward a copy of the application (FAA Form 8310-6) and the plan to the receiving responsible Flight Standards office.
3.3.5.2.1 The receiving responsible Flight Standards office will review the application for a change in location and is responsible for the reissuance of the Air Agency Certificate and OpSpecs, if required.
3.3.5.3 When transfers occur for reasons other than a change to AMTS location, the AMTS should coordinate with both its current and new office to ensure a smooth transition of information between offices.
3.3.6 AMTS Exemptions. Exemptions that are granted to and/or used by an AMTS will be listed in the AMTS OpSpecs.
3.3.6.1 Exemptions to 14 CFR requirements cannot be granted by the responsible Flight Standards office. The AMTS must make a request for exemptions using the procedures outlined in 14 CFR part 11. The AMTS should notify its responsible Flight Standards office of any exemption issued to the AMTS so that it can be added to the AMTS OpSpec A005, Exemptions.
3-5
3.3.6.2 Prior to listing an exemption in OpSpec A005, the FAA will ensure the school has appropriate procedures developed to ensure compliance with any specified conditions and limitations of the exemption, as necessary.
3.3.6.3 The FAA will add the exemption number to the AMTS assigned exemptions and issue OpSpec A005, prior to the school using the exemption.
3.3.6.4 Exemptions typically expire every 2 years. The AMTS must make a request for an extension (as specified in part 11), and be granted an extension to the exemption. This will result in a revised exemption number; therefore, the AMTS must again notify the FAA of the exemption grant, and request the update to OpSpec A005 prior to using the exemption extension.
3.4 Minimum Passage Rate. AMTS must meet the minimum passage rate requirements of § 147.25. The minimum passage rate is an important indicator of whether the school’s curriculum content is sufficient, if curriculum design and delivery methods are appropriate, and if instructors are providing quality instruction.
3.4.1 Pass Rate Metric. A certificated AMTS shall maintain a pass rate of at least 70 percent of students who took a written, oral, or practical (or any combination thereof) FAA mechanic test within 60 days of graduation for the most recent 3-year period.
3.4.2 Pass Rate Reports.
3.4.2.1 The passage rate is based on the results of FAA tests; therefore, the FAA will provide quarterly reports based on 3 years of test data, for each AMTS. The reports will be publicly available on https://www.faa.gov.
3.4.2.2 Students that fail a test within the 60-day window after graduation, and then retest and pass that same test within the same 60-day window, are counted as passing students towards the AMTS pass rate.
3.4.3 Noncompliance With Pass Rate.
3.4.3.1 Because § 147.25 requires a data collection period of 3 years, compliance with the pass-rate requirement will be evaluated after there is 3 years of data collected on the school’s students who are testing within 60 days of graduation.
Note: While an AMTS is required to meet the pass rate in § 147.25, an AMTS is also generally required to ensure students have the knowledge and skills necessary to be prepared to test for a mechanic certificate and associated ratings, pursuant to § 147.17(a)(3). As part of the FAA’s general inspection authority in § 147.27, the FAA may review an AMTS’s pass rate data as a whole, not only as it pertains to those students who test 60 days after graduation, to ensure that students are prepared with the knowledge and skill to test for the applicable certificate and/or rating.