U .S. Department of Transportation Federal Aviation Administration Advisory Circular Subject: Certification and Operation of Aviation Maintenance Technician Schools Date: 3/22/22 AC No: 147-3C Initiated by: AFS-300 Change:
This advisory circular (AC) provides guidance to assist persons in obtaining and maintaining Federal Aviation Administration (FAA) certification of an Aviation Maintenance Technician School (AMTS). This guidance is not legally binding in its own right and will not be relied upon by the FAA as a separate basis for affirmative enforcement action or other administrative penalty. Conformity with the guidance is voluntary only and nonconformity will not affect rights and obligations under existing statutes and regulations.
D avid H. Boulter Executive Director, Flight Standards Service
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CONTENTS Paragraph Page
Chapter 1. Introduction1-1
1.1 Purpose of This Advisory Circular (AC)1-1
1.2 Audience1-1
1.3 Where You Can Find This AC1-1
1.4 What This AC Cancels1-1
1.5 Principal Changes1-1
1.6 Applicability1-1
1.7 Background1-1
1.8 Discussion1-4
1.9 AC Feedback Form1-4
Chapter 2. Certification Requirements for a Part 147 AMTS2-1
2.1 AM TS Ratings2-1
2.2 AMTS Operations Specifications (OpSpecs)2-1
2.3 A MTS Certificate Requirements2-4
2.4 Descriptions Required by § 147.52-5
2.5 AMTS Quality Control System2-6
2.6 Other AMTS Procedures2-14
2.7 Curriculum/Training Requirements2-17
Table 2-1. C urriculum Design Examples2-23
2.8 F acilities, Equipment, and Materials2-24
2.9 AMTS Instructor Requirements2-29
Chapter 3. O perating Requirements3-1
3.1 O peration After Certification3-1
3.2
Amending the Air Agency Certificate3-1
3.3 Changes Requiring Notification to the FAA3-3
3.4 Minimum Passage Rate3-5
3.5 Records3-6
3.6 Graduation Documentation3-6
3.7 Early Testing3-7
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Chapter 4. Certification Procedures4-1
4.1 G eneral Information on Certification Procedures4-1
4.2 Preapplication Phase4-3
4.3 Formal Application Phase4-10
4.4 Design Assessment (DA) (Document Compliance) Phase4-10
4.5 Performance Assessment (PA) (Demonstration and Inspection) Phase4-11
4.6 Administrative Functions (i.e., Certification) Phase4-12
Appendix A. G lossary of TermsA-1
Appendix B. Related ReferencesB-1
Appendix C. Sample Facility LayoutC-1
Appendix D. Sample Letter of Compliance (i.e., Statement of Compliance, Compliance
Statement)D-1
List of Figures
Figure 4-1. Part 147 Certification Process Flowchart4-2
Figure 4-2. Preapplication Statement of Intent4-4
Figure 4-3. Sample Part 147 Schedule of Events (SOE)4-8
Figure 4-4. F AA Form 8310-6, Aviation Maintenance Technician School Certificate and
Ratings Application4-9
1-1 CHAPTER 1. INTRODUCTION
1.1 Purpose of This Advisory Circular (AC). This AC provides guidance to assist persons in obtaining and maintaining Federal Aviation Administration (FAA) certification of an Aviation Maintenance Technician School (AMTS). This guidance is not legally binding in its own right and will not be relied upon by the FAA as a separate basis for affirmative enforcement action or other administrative penalty. Conformity with the guidance is voluntary only and nonconformity will not affect rights and obligations under existing statutes and regulations.
1.2 Audience. The primary audience for this AC is currently certificated Title 14 of the Code of Federal Regulations (14 CFR) part 147 AMTSs and persons desiring to obtain certification of an AMTS. The secondary audience includes Flight Standards (FS) personnel who have certification and surveillance responsibilities for part 147 certificated AMTSs.
1.3 Where You Can Find This AC. You can find this AC on the FAA’s website at https://www.faa.gov/regulations_policies/advisory_circulars and the Dynamic Regulatory System (DRS) at https://drs.faa.gov.
1.4 What This AC Cancels. AC 147-3B, Certification and Operation of Aviation Maintenance Technician Schools, dated June 5, 2015, is canceled.
1.5 Principal Changes. This AC incorporates new and revised content to reflect the changes to part 147 that were made in accordance with Section 135, Promoting Aviation Regulations for Technical Training, of the Aircraft Certification, Safety, and Accountability Act in Public Law (P.L.) 116-260, Consolidated Appropriations Act, 2021.
1.6 Applicability. This AC applies to currently certificated AMTSs and to applicants seeking FAA certification of an aviation maintenance school.
1.6.1 Guidance Information. Guidance information is information considered advisory in nature and will contain terms such as “should” or “may.”
1.7 Background.
1.7.1 History of Part 147. Part 147 prescribes the requirements for the certification and operation of FAA-certificated AMTSs, including the curriculum requirements. Part 147 originated as Civil Air Regulations (CAR) part 53 in 1940.1 In 1962, the CARs were recodifed; CAR 53 became 14 CFR part 147.2 In 1970, the FAA issued a final rule that changed the name of “mechanic schools” to “aviation maintenance technician schools,” provided more specific guidelines for the certification and operation of schools, increased the required core curriculum hours from 1,500 to 1,900, and further defined teaching
1 Final Rule, “Providing for the Rating and Certification of Civilian Schools giving Instruction in Aircraft and Aircraft Engine Mechanics,” 5 FR 673 (Feb. 15, 1940).(amending the Civil Air Regulations by adding new part 53, effective May 1, 1940).
2 Final Rule, “Schools and Other Certificated Agencies,” 27 FR 6655 (Jul. 13, 1962).
1-2 guidelines and subject content to reflect technological advancements in the aviation industry.3 In 1992, the FAA revised part 147 by adding a definition in appendix A for “teaching materials and equipment” to include the use of computers in the training environment. The FAA also revised the headings of several subjects in part 147 appendices B, C, and D to better reflect course content, added course content items within several subject areas, and added two new subject headings with related course content items for “Unducted Fans” and “Auxiliary Power Units”.4 Subsequently, in 1992, the FAA made a minor amendment to § 147.21 as part of another rulemaking.5 Specifically, the FAA added a provision to § 147.21 that allowed AMTS to apply for and receive approval of special courses in the performance of inspection and maintenance on primary category aircraft, and authorized the school to issue certificates of competency to persons successfully completing such courses.6 3 Final Rule, “Name, Operations, and Curriculum,” 35 FR 5531 (Apr. 3, 1970).
4 Final Rule, “Revision of Aviation Maintenance Technician Schools Regulations,” 57 FR 28952 (Jun. 29, 1992).
5 Final Rule, “Primary Category,” 57 FR 41360 (Sept. 9, 1992).
6 57 FR 41366 and 41370.
1.7.2 Notice of Proposed Rulemaking (NPRM).
1.7.2.1 On October 2, 2015, the FAA published an NPRM titled, “Aviation Maintenance Technician Schools.”7 I n the NPRM, the FAA proposed to amend t he regulations governing the curriculum and operation of FAA-certificated AMTSs. The FAA proposed to modernize and reorganize the required curriculum subjects found in the appendices of the current regulations, remove the course content items from the appendices and relocate them to each school’s operations specifications (OpSpecs), and revise the curriculum requirements to include an option for schools to use a credit hour curriculum as an alternative to an instructional hour curriculum.
7 80 FR 59674.
1.7.2.2 After considering the comments to the NPRM, and the potential benefits to industry, the FAA decided to expand the scope of the rulemaking by issuing a Supplemental Notice of Proposed Rulemaking (SNPRM), published on April 16, 2019.8 The SNPRM proposed: (1) to allow curriculums using competency-based training (CBT) programs as a curriculum delivery; (2) to allow the establishment of satellite training locations; and (3) to remove the national passing norm requirements in § 147.37 and replace them with a standard pass rate.
8 83 FR 15533.
1.7.3 Interim Final Rule (IFR). While the FAA was in the process of completing the final rule, which would have responded to all significant comments received on the NPRM and SNPRM, Congress passed legislation requiring the FAA to replace part 147, as in effect on the date of enactment of Section 135, with new regulations that conform to the statutory requirements. Specifically, on December 27, 2020, Congress passed the Consolidated Appropriations Act, 2021 (P.L. 116-260), which includes the Aircraft Certification, Safety, and Accountability Act (the “Act”). In Section 135 of the Act, titled
1-3 “Promoting Aviation Regulations for Technical Training,” Congress directed the FAA to issue interim final regulations, no later than 90 days after the date of enactment of the Act, to establish requirements for issuing AMTS certificates and associated ratings and the general operating rules for the holders of those certificates and ratings.
1.7.3.1 Additionally, the statute states that the current part 147 regulations and any regulations issued under Section 624 of the FAA Reauthorization Act of 2018 shall have no force or effect on or after the effective date of the IFR. As a result, the IFR repealed and replaced former part 147 upon the effective date of the IFR.
1.7.3.2 Upon review of Section 135, the FAA determined that the proposed requirements in the NPRM and SNPRM would have significantly exceeded the scope of the statutory mandate. Therefore, to comply with Section 135, the FAA published a Federal Register (FR) Notice withdrawing the NPRM (Notice No. 15-10) and SNPRM (Notice No. 19-02). Instead of finalizing these proposals, the FAA issued the IFR to establish requirements for certificated AMTSs in accordance with Section 135 of the Act.
1.7.4 Statutory Mandate. Pursuant to Section 135(a)(1) of the Act, the FAA issued the interim final regulations in accordance with the requirements set forth in Section 135. The provisions of Section 135, which are discussed further below, include requirements pertaining to:
• When an AMTS certificate is required;
• Applications for AMTS certificates and associated ratings, additional ratings, and changes to certificates;
• OpSpecs and the contents thereof;
• The duration of a certificate or rating issued under part 147;
• The ratings that an AMTS may obtain under part 147;
• AMTS facilities, equipment, and material;
• Training provided at another location;
• AMTS training and curricula;
• Instructors;
• Certificates of completion;
• Quality control (QC) systems;
• The minimum passage rate each school must maintain;
• FAA inspections;
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• The display of part 147 certificates; and
• A student’s ability to take the FAA’s mechanic general written test prior to satisfying the experience requirements of 14 CFR part 65, § 65.77, provided certain conditions are met.
1.8 Discussion. An AMTS is an educational facility certificated by the FAA under part 147 to train students in the knowledge and skills required for careers in the aviation maintenance industry. When all other eligibility requirements are met, a certificate of completion issued by a part 147 AMTS can be used by a mechanic applicant to show eligibility to test for a mechanic certificate airframe and/or powerplant rating, as applicable to the curriculum from which the applicant graduated/completed. The goal of any AMTS should be to prepare students with the basic knowledge, skills, and attitude to be successful in an aviation maintenance career.
1.8.1 From the initiation of the AMTS certification process to the issuance of the certificate, the amount of time and capital for required facilities, equipment, and curriculum development can be significant.
1.8.2 Frequently, the AMTS program is only part of a school’s overall instruction program (for example, programs that include AMTS curriculum in addition to other curriculum content to achieve a bachelor’s or other degree). The requirements of part 147 should not be interpreted as applicable for any courses other than those required by the part 147 curriculum.
1.9 AC Feedback Form. For your convenience, the AC Feedback Form is the last page of this AC. Note any deficiencies found, clarifications needed, or suggested improvements regarding the contents of this AC on the Feedback Form.
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.