2-1 CHAPTER 2. CERTIFICATION REQUIREMENTS FOR A PART 147 AMTS
2.1 AMTS Ratings. An AMTS may be FAA-certificated with the following ratings:
• Airframe,
• Powerplant, and/or
• Airframe and Powerplant.
2.1.1 Certificate of Completion. The ratings issued to an AMTS indicate what curriculum(s) the school is authorized to deliver, and subsequently issue a certificate of completion for.
An AMTS may only issue a certificate of completion upon a student’s graduation from a specific curriculum, consistent with the school’s ratings (refer to § 147.21). The general portion of a curriculum is not a rating, but must be completed as a required part of any rating, pursuant to regulation.
Note: See paragraph 2.7.2, Curriculum, and Table 2-1, Curriculum Design Examples, for additional discussion on the relationship between AMTS ratings, curriculum structure/delivery, and when the AMTS can issue a completion document for a completed curriculum or portion of a curriculum.
2.1.2 Early Testing. The AMTS may choose to issue a document that indicates the student has completed the general portion of the school’s curriculum. This document can be used to demonstrate the student’s preparedness to take the mechanic general written test in accordance with 14 CFR part 65, § 65.75(c). Early testing under § 147.31 is discussed in paragraph 3.7.
2.2 AMTS Operations Specifications (OpSpecs).
2.2.1 Part 147 OpSpec Paragraphs. OpSpecs are authorizing documents issued to an AMTS by which an AMTS must comply, pursuant to § 147.3. Part 147 OpSpec templates and policy are developed by the Office of Safety Standards, Aircraft Maintenance Division.
The responsible Flight Standards office works with the AMTS to populate the OpSpecs with information and authorizations specific to the AMTS.
• The FAA issues “Required” OpSpecs to all AMTS.
• The FAA issues an “Optional” OpSpec to an AMTS depending on specific operations of the school.
2.2.2 Issuing Part 147 OpSpecs. OpSpecs for part 147 AMTSs will be issued utilizing the following paragraphs, as appropriate and applicable to the AMTS ratings and operations.
2-2 Note: Asterisk (*) items are OpSpecs that include information specifically required by Section 135 of the Aircraft Certification, Safety, and Accountability Act in Public Law (P.L.) 116-260, Consolidated Appropriations Act, 2021.
1. A001, Issuance and Applicability (Required).* Lists the AMTS’s name, physical address and mailing address of the primary location for operation, primary point of contact (POC), and the school’s Air Agency Certificate number.
2. A002, Definitions and Abbreviations (Required). Lists definitions of words or phrases used in the part 147 OpSpecs. These definitions are intended to enhance understanding between the FAA and the aviation industry in regards to part 147 AMTSs.
3. A003, Ratings (Required).* Lists the ratings held by the AMTS.
4. A004, Summary of Special Authorizations and Limitations (Required). Identifies all optional/nonrequired OpSpec paragraphs applicable to the AMTS.
5. A005, Exemptions (Optional).* Lists any exemptions used by the AMTS.
6. A007, Designated Persons (Required). Lists persons the AMTS has designated to officially apply for and receive OpSpecs on behalf of the AMTS.
7. A008, Additional Training Locations (Optional).* Lists the additional training locations of the AMTS.
8. A013, Instructors (Required).* Includes a description of the manner (or a reference to the description) in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19.
9. A015, Facilities, Equipment, and Materials (Required).* Includes a description of the facilities, equipment, and materials used at the primary school location, and at each additional training location, or a reference to that description.
10. A025, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals/Documents (Optional). Identifies AMTS’s use of, and quality control (QC) system procedures for the use of, electronic signatures, electronic recordkeeping, or electronic manuals.
11. A027, Quality Control System (Required). Authorizes how the AMTS meets the QC system requirements of § 147.23(a). If the AMTS uses accreditation to meet § 147.23(a), then Table 1 will list the accrediting agency of the school. The AMTS should notify the FAA of changes to its accreditation to ensure the school’s OpSpecs show the school is meeting the QC system requirements. If the AMTS obtains an FAA-approved QC system, then Table 2 will list the AMTS’s FAA-approved manuals, documents, or sections containing procedures that make up the FAA-approved QC system.
12. B001, Curriculum (Required).* Includes a description of the manner (or reference to the description) 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.
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2.2.3 Web-Based Operations Safety System (WebOPSS). Part 147 OpSpecs are processed and issued electronically through WebOPSS by the Flight Standards office responsible for the AMTS. AMTS personnel responsible for part 147 OpSpecs can request access to their OpSpecs in WebOPSS through the responsible Flight Standards office. AMTS personnel approved for access to WebOPSS and authorized to accept OpSpecs on behalf of the AMTS (see paragraph 2.2.4 below) can purchase a digital certificate to sign their OpSpecs electronically through the Digital Certificate Service (DCS) at https://dcs.faa.gov/.
2.2.4 Receiving and Maintaining OpSpecs. The AMTS should designate at least one person as authorized to sign and receive OpSpecs and who will be identified in OpSpec A007. Only individuals listed on A007 are authorized to receive/sign OpSpecs. This applies to the use of electronic signatures or pen-and-ink signatures applied to an OpSpec.
2.2.5 AMTS Manually Signing OpSpecs. If the certificated entity does not have a person authorized to sign/receive OpSpecs (A007) with access and a digital certificate to sign OpSpecs electronically in WebOPSS, the responsible Flight Standards office will prepare the OpSpecs for manual signature by the AMTS. The signature block will include the name and title of the authorized AMTS representative (A007) who will sign the OpSpecs.
2.2.5.1 AMTSs should retain copies of all current, signed OpSpecs, being diligent in ensuring they always use and maintain the most recently approved amendment to each issued OpSpec.
2.2.6 AMTS Responsibility for OpSpecs. Pursuant to § 147.3, an AMTS may not operate without, or in violation of, its OpSpecs. The AMTS has the responsibility to review and maintain each OpSpec paragraph for correctness and should conduct regular reviews to ensure all information is correct.
2.2.7 Transition to Part 147 Interim Final Rule (IFR). The promulgation of the part 147 IFR has resulted in revised, added, and removed OpSpecs for part 147 certificate holders.
Upon the effective date of the IFR, an AMTS may not operate under the former part 147 regulations and OpSpecs issued under those former regulations. In order to ensure continuous training operations at the AMTS, the school must demonstrate compliance with the new part 147 requirements prior to the effective date of the IFR.
2.2.7.1 To demonstrate compliance with the IFR, the AMTS must provide the following information to the AMTS’s responsible Flight Standards office (see Chapter 4, paragraph 4.2.3.4):
2.2.7.1.1 The descriptions required by § 147.5:
1. A description of the AMTS facilities at the primary location, and each additional training location.
2. A description of the AMTS equipment used at the primary location, and each additional training location.
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3. A description of the AMTS materials used at the primary location, and each additional training location.
4. 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.
5. A description of the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19 (refer to § 147.5(b)(3)).
2.2.7.1.2 The school’s curriculum, that aligns with the Mechanic Airman Certification Standards (ACS) as required by § 147.17.
2.2.7.1.3 Evidence of accreditation, if the AMTS intends to meet the QC system requirements using accreditation as provided in § 147.23(a)(1).
2.2.7.1.4 A QC system, if the AMTS intends to meet the QC system requirements using a QC system as provided in § 147.23(a)(2).
Note: The AMTS must allow a reasonable amount of time for the FAA to review and approve requests for approval of a QC system.
2.2.7.1.5 Any other information applicable to the school’s training operations such as additional training locations or regulatory exemptions.
Note: AMTSs that are certificated prior to the effective date of the new part 147 (see paragraph 1.7.4) are not required to submit a new application for certification; however, the FAA must ensure that the new and changed requirements of part 147 can be met by the AMTS prior to conducting training.
Therefore, the certificated AMTS must work with their assigned Flight Standards office to provide all requisite information.
2.2.7.2 If co mpliance is demonstrated prior to the effective date of the IFR, the FAA will review the AMTS submission to ensure compliance with the new regulations and issue OpSpecs that are effective upon the effective date of the IFR. The AMTS may continue to conduct training operations.
2.2.7.3 If compliance is demonstrated after the effective date of the IFR, the FAA will issue OpSpecs once it has verified the part 147 requirements have been met.
In this instance, the AMTS will not be permitted to operate as a certificated AMTS during the period of time between the effective date of the IFR and the date upon which the FAA determines the new part 147 requirements have been met and issues new OpSpecs.
2.3 AMTS Certificate Requirements.
2.3.1 Duration of Certificate. Pursuant to § 147.7, an AMTS’s FAA certificate remains in effect until it is surrendered, suspended, or revoked.
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2.3.2 Display of Certificate. Pursuant to § 147.29, an AMTS is required to display its FAA Air Agency Certificate in a location that is visible by and normally accessible to the public.
The certificate must be displayed in this manner at the primary location of the AMTS and at any additional fixed location.
Note: It is acceptable to display a copy of the Air Agency Certificate.
2.3.3 Advertising. Part 147 no longer addresses advertising requirements of an AMTS. The AMTS should ensure it complies with all Federal and state laws, as well as accreditation requirements, as applicable, that are in place to protect the public from false and misleading advertising.
2.3.4 FAA Inspection. Pursuant to § 147.27, an AMTS must allow the FAA access to its facilities for inspection for the purposes of determining the school’s compliance with the requirements of part 147. This includes access to the primary AMTS location and each additional training location. When a formal application is made to the FAA for certification, the applicant will be required to allow the FAA to inspect its facilities and equipment as part of the certification process. After certification, FAA inspections are conducted as determined by FAA surveillance program requirements. Typically, inspections are conducted at least annually, with additional inspections to be conducted as determined by the FAA. An FAA inspection may also be conducted when a school requests to add an additional training location.
2.4 Descriptions Required by § 147.5. An AMTS must develop and submit to the FAA the following descriptions relative to its training operations:
• A description of the facilities, including the physical address of the applicant’s primary location for operation of the school, and any additional fixed locations where training will be provided, and the equipment and materials to be used at each location.
See paragraph 2.8.
• 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. See paragraph 2.7.1.
• A description of the manner in which the school will ensure it provides the necessary qualified instructors to meet the requirements of § 147.19. See paragraph 2.9.
2.4.1 Inclusion in AMTS OpSpecs. The descriptions provided to the FAA, pursuant to § 147.5, will be documented in the AMTS OpSpecs. Additionally, if descriptions are changed, the AMTS must provide the changes to the FAA in order for the documented changes to be updated in the OpSpecs to maintain compliance with their OpSpecs, pursuant to § 147.3.
The descriptions 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.
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2.5 AMTS Quality Control System. As stated in § 147.23(a), each certificated AMTS must have a QC system by either:
• Being accredited within the meaning of Title 20 of the United States Code (20 U.S.C.) § 1001(a)(5) (see paragraph 2.5.1), or
• Establishing and maintaining a QC system approved by the FAA (see paragraph 2.5.2).
2.5.1 Accreditation. To be accredited within the meaning of 20 U.S.C. § 1001(a)(5) requires a school to be accredited by a Department of Education nationally recognized accrediting agency or association. Pursuant to 20 U.S.C. § 1001(c), the Secretary of Education publishes a list of all nationally recognized accrediting agencies or associations determined to be a reliable authority as to the quality of the education or training offered.
The list can be found on the Department of Education website. A school can become accredited by seeking recognition from one of the accrediting agencies recognized by the Department of Education. The accreditation may be for the entire institution (institutional accreditation) or limited to a part of an institution or the AMTS program itself (specialized or programmatic accreditation).
2.5.1.1 The Department of Education’s recognition of accrediting agencies is limited by statute to accreditation activities within the United States. As such, in order to be accredited within the meaning of 20 U.S.C. § 1001(a)(5), an AMTS must have its primary location within the United States.
• For an AMTS with the primary location located within the United States, the AMTS’s accreditation extends to any additional training locations, whether located within or outside the United States.
• For an AMTS whose primary location is outside of the United States, accreditation is not recognized by the Department of Education and therefore does not satisfy § 147.23(a)(1). The AMTS must establish and maintain a QC system pursuant to § 147.23(b), for the primary location and any additional training locations whether located within or outside the United States.
2.5.1.2 In order to demonstrate accreditation under § 147.23(a), a school should have documentation that shows the school’s accrediting agency and the school’s current accreditation status. The AMTS should notify the FAA when there are changes to its accreditation, such as changes to the accrediting agency or a lapse in accreditation.
Note: If the AMTS is not accredited, it must have and use a QC system that is FAA approved.
2.5.1.3 Pre-accreditation does not meet the requirements of § 147.23(a), since the regulation specifically requires “accreditation.”
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2.5.2 FAA-Approved QC System. Schools that are not accredited within the meaning of 20 U.S.C. § 1001(a)(5) must obtain FAA approval of a QC system; however, the regulation does not preclude an accredited school from obtaining an FAA-approved QC system should they choose that manner of compliance with § 147.23. An AMTS with an FAA-approved QC system must continually maintain that system under § 147.23(a)(2).
For new applicants for AMTS certification, the QC system must be submitted to the FAA for approval during the certification process, and any subsequent revisions to the system must be submitted for approval. Pursuant to § 147.23(b), the QC system must include procedures for the following, which are discussed in detail in paragraphs 2.5.3 through 2.5.10:
• Recordkeeping,
• Assessment,
• Issuing credit,
• Issuing of final course grades,
• Attendance,
• Ensuring sufficient number of instructors,
• Granting of graduation documentation, and
• Corrective action for addressing deficiencies.
2.5.3 Recordkeeping. The AMTS recordkeeping procedures should describe the types of records the school will produce and retain, and for how long. Recordkeeping procedures should encompass all records produced within the QC system to include:
1. Records of assessment of a student’s knowledge and skill, as applicable to the curriculum for which the student is enrolled. Records should clearly distinguish between successful performance and unsuccessful performance.
2. Records showing credit granted for previous experience and/or previous instruction, including supporting transcripts, when applicable. Records should clearly show what subject areas were credited to the student based on the school’s evaluation of previous experience or training using the school’s crediting procedures.
3. Records of the student’s grades, to include final course grades, as applicable. Records should clearly distinguish between successful performance and unsuccessful performance.
4. Records of student attendance relative to the school’s attendance policy.
5. Records of curriculum completion and records showing issuance of graduation documentation, and/or records showing general curriculum course content completion and issuance of general curriculum course content completion documentation.
6. Records showing identified deficiencies of the QC system and records showing the school’s corrections of those deficiencies. If follow-up audits are performed to validate corrective actions, those records should also be retained.
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7. Examples of the forms the school will use for records described above.
8. Record retention procedures should state how long the school will retain its records. It is recommended the school retain records for at least 2 years after the end of the student’s enrollment. Any record archival policy should also be described in the school’s recordkeeping procedures.
2.5.3.1 Electronic/Digital Recordkeeping. If the AMTS chooses to use electronic/digital recordkeeping for any of the records described in the school’s QC system, it is recommended that the school incorporate the guidelines put forth in AC 120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals, in developing its electronic/digital recordkeeping procedures. The FAA will issue OpSpec A025 to authorize digital/electronic recordkeeping.
2.5.4 Assessment. AMTS course testing/assessment (not FAA-administered tests), including preparation and post-test reviews, is an important part of the learning process and is considered part of the teaching validation process. Testing should be directly related to the subject matter and consistent with the expected learning outcome. Assessment procedures should include:
• When and how the school will assess its students;
• How the school ensures testing integrity in all testing environments (e.g., classroom, shop, computer-based testing, distance learning testing, etc.);
• How the school ensures test security; and
• How the school handles instances of cheating on tests.
2.5.4.1 It is recommended that upon completion of each curriculum subject area, a test should be scheduled. In addition, quizzes may be scheduled at the school’s discretion at any time. When testing for subjects that have many hours of instruction, an AMTS should consider planning more than one test or quiz during the instructional unit.
2.5.4.2 Test security procedures should include provisions for regular test revisions and the secure storage of tests and quizzes.
2.5.5 Issuing Credit. The school must have procedures that describe how and when the AMTS will issue credit for a subject or course. These procedures should include:
• How the AMTS issues credit for its courses delivered as a part of its part 147 curriculum.
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• If, and under what circumstances, the school credits a student’s prior instruction or experience.
• How the school will determine the amount of credit to be given that ensures the student’s prior experience or training is equivalent to the curriculum for which the student is receiving credit.
2.5.5.1 Crediting Prior Instruction. The AMTS should only grant credit for previous instruction that has been satisfactorily completed at:
• An accredited university, college, community college, or junior college;
• An accredited vocational, technical, trade, or high school;
• A military technical school; or
• Another certificated AMTS.
2.5.5.2 Crediting Prior Experience. The AMTS should only credit previous maintenance experience after examining documents that verify that experience.
2.5.5.3 Determining Issuance of Credit. The AMTS should determine the amount of credit to be given as it relates to the training requirements provided in § 147.17. An AMTS should utilize the following methods:
• An evaluation of an authenticated transcript from the student’s former AMTS (applicable for prior instruction),
• A qualifying entrance test equal to one given to students who complete the corresponding curriculum content at the crediting AMTS (applicable to either prior instruction or prior experience), or
• Another method that verifies the student’s previous training or experience meets the crediting school’s curriculum requirements.
2.5.5.3.1 When basing credit on an evaluation of an authenticated transcript, the crediting AMTS should ensure the individual has completed training comparable (i.e., meets or exceeds the curriculum content) of that offered by the crediting school. The AMTS should be able to show documented evidence of the evaluation. Evaluation of a transcript could be based on a combination of the following:
• Detailed transcripts.
• The course catalog description of the course that was completed by the student.
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• Audits of the class for which the credit is to be based when crediting a specific course on a routine basis. In this circumstance, the AMTS should define its audit schedule within the QC procedures.
• Other documents showing the course content on which the credit is being based.
2.5.5.3.2 When using an entrance test to determine the credit to be granted, the test should be equal to one given to students who complete the corresponding curriculum content at the school. This is applicable to either prior instruction or prior experience. The entrance test should include both knowledge and skill components of the curriculum to which credit is being granted.
2.5.5.3.3 Generally, creditable previous mechanic experience should be aviation maintenance experience comparable to the required AMTS curriculum subject areas.
• Example 1: An individual with substantial powerplant experience (no airframe experience) gained while working in the military or at an airline should be considered as having previous experience only within powerplant subject areas.
• Example 2: An uncertificated mechanic working for an airline for 5 years only in the tire shop should not be considered to have experience relating to all airframe subjects.
2.5.5.4 Credit for the General Curriculum. A school may credit a student seeking an additional mechanic certificate rating with previous satisfactory completion of the general curriculum content. If an individual has obtained a mechanic certificate with either an airframe rating or a powerplant rating, that rating indicates the individual has met the knowledge requirements for issuance of a mechanic certificate, which includes knowledge and skills that would be required within the general portion of an AMTS curriculum. Therefore, a student who is seeking an added rating to their mechanic certificate may be issued graduation documentation by the AMTS upon completion of the applicable curriculum, even though the student did not complete the general portion of the AMTS curriculum.
2.5.5.5 Exceptions to Crediting Procedures.
• If an AMTS Air Agency Certificate has been suspended by the FAA, courses taught during the suspension period cannot be credited retroactively, even if the school becomes re-certificated later, because the AMTS would be operated in violation of § 147.7.
• An AMTS applicant may not teach students as an AMTS before receiving an FAA certificate and then give credit for that training after the school becomes certificated, because the AMTS would be operating in violation of § 147.3.
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2.5.6 Issuing of Final Course Grades. The AMTS QC system must include procedures that describe how the AMTS will issue final course grades. The procedures should describe the AMTS’s standards for passing grades to include:
• The minimum passing grade sufficient to achieve the required knowledge and skills of the school’s curriculum;
• How grade weighting (percentage) and/or grade averaging will be used to determine the final course grade, as applicable;
• Forms or samples of electronic records the AMTS will use for recording grades;
• Any other procedures the school uses to determine final course grades; and
• A description of any audit or verification procedures the AMTS will use to ensure accuracy of the final grade.
2.5.6.1 A common academic standard for passing is a minimum score of 70 percent, and the FAA written, oral, and practical tests have a 70 percent minimum passing standard in accordance with § 65.17. The AMTS should define its standard for a passing final course grade in its QC system procedures (refer to § 147.23(b)). However, it is recommended that the school does not implement a passing standard lower than 70 percent, to support the school in meeting the quality of instruction requirements of § 147.25.
2.5.6.2 Theoretical portions of the curriculum may have different grading standards from those required in laboratory and shop classes.
2.5.7 Attendance. The QC system must include attendance procedures. Procedures should include the following:
• The AMTS attendance policy for courses that are required for curriculum completion.
• How the AMTS will track student attendance when required by its attendance policy.
• Any limitations on student attendance or enrollment, such as limiting class hours in a day/week, or limiting enrollment in additional courses.
Note: Depending on the basis of the curriculum, attendance policies can vary greatly. For example, schools basing their curriculum on hours may have more strict or detailed attendance requirements than schools basing their curriculum on credit-hours or competency.
2.5.8 Ensuring Sufficient Number of Instructors. The school must have QC system procedures describing how the school will ensure it maintains a sufficient number of instructors to achieve the school’s training requirements. Procedures should include the following:
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• A description of how the AMTS will ensure the 25:1 student-to-instructor ratio required by § 147.19(c) is maintained.
• A description of any other requirements the AMTS is placing on student-to-instructor ratios for the purpose of achieving the school’s training requirements.
2.5.9 Granting of Graduation Documentation. The school must have QC system procedures describing how it grants graduation documentation under § 147.21 and completion documentation required for early testing under § 147.31.
2.5.9.1 Section 147.21, Certificate of Completion. Under § 147.21, when a student satisfactorily completes the required curriculum content for graduation, the school must issue an authenticated document to the graduating student. A graduation document may only be issued consistent with the school’s ratings.
The procedures for issuing the authenticated document should include the following:
2.5.9.1.1 A description of the document to be issued and what information will be included on the document. At a minimum, the following information should be included on the document in order to meet the requirements of § 147.21(a):
• Student name, indicating who the document was issued to.
• School name and Air Agency Certificate number, to indicate who issued the document and that the document was issued by an FAA-certificated AMTS.
• Authentication, using the method of authentication determined by the school to show the document was issued legitimately.
• The student’s date of graduation.
• The name of the curriculum completed by the student (i.e., either “Airframe”, “Powerplant”, or “Airframe and Powerplant”).
2.5.9.1.2 A description of the authentication process used by the school to ensure the document was legitimately issued by the school, and a description of designated school personnel authorized to authenticate the document. For example, schools may use a signature, an embossed seal, or some other method to indicate authentication, and may limit the performance of authentication to certain school officials.
2.5.9.1.3 The process used to verify the student has passed the curriculum based on the school’s standards for issuing final course grades, any attendance requirements, and/or crediting of the AMTS curriculum that was based on prior instruction or experience.
2.5.9.1.4 How the school ensures the student is eligible to receive the graduation certificate.