Appendix 3
15. Question : AC 147-3 was last issued in 1991, and it put great emphasis on the Allen Study and how schools may use it to assist in the establishment of their curriculum. Again, this is a suggestion rather than the rule, and if a curriculum meets the FAA regulatory requirement, the Allen Study should not be used instead of the rule to say that the curriculums do not meet the requirements. Is there a more recent guideline, such as the Air Transportation Association of America (ATA) 104 Training Standard, in use that would be more current in its guidelines than the now quite old Allen Study?
Answer: Schools may choose to use the more current Job Task Analysis of the Aviation Maintenance Technician Northwestern University to help develop or update their curriculum. This is available at http://hfskyway.faa.gov. Select “Documents,” and under “Publications,” select “Bibliography of Publications 1989-1998,” then enter “job task analysis” into the search field. However, schools should be sure to meet the requirements of part 147.
16. Question : In the curriculum in Appendix C to part 147, under Airframe Systems and Components, Cabin Atmospheric Control Systems, items C34 and C35 have always presented a challenge for us. Both seem to be the same with the exception of item C33 mentioning air cycle machines. So, under item C33, we cover cabin atmospheric control systems for both large turbine engine aircraft with air cycle machines as well as smaller reciprocal engine aircraft that are supercharged/turbocharged along with combustion heaters. We suggest item C34 be deleted.
Answer: The redundancy has been previously identified. This will be addressed by the FAA at the next revision of the rule.
17. Question : Is 1,900 hours a minimum or maximum number of hours permitted under part 147?
Answer: One thousand nine hundred (1,900) hours is the minimum an AMTS must offer for a combined A&P curriculum. A school may provide additional hours at its discretion to meet institutional program objectives or align with specific industry needs.
18. Question : The FAA has the responsibility to enforce the content in a school’s Part 147 curriculum. Can the following items be omitted from the curriculum and kept on file at the school?
List of instructors.
Equipment list.
Forms created and used by the school.
Answer: The curriculum is the official document of the school.
The curriculum should reference the instructor list and where it is kept at the school. Upon request, the school should be able to provide the PMI a current list to the instructional staff. The curriculum should discuss the lesson plans and where they would be kept for availability to the PMI on an inspection visit.
The equipment list should be discussed in the curriculum, and should be kept current and available to the PMI upon his or her request. The student manuals Page 5
Appendix 3 should not be included as part of the curriculum. The methods of recording and tracking time and attendance should be in the curriculum, but the actual records should be kept separate.
The curriculum should also address the procedures for meeting the requirements of part 147. It should not include other student policies such as financial aid processing, add-drop policies, or other school activities.
19. Question : If a school and its PMI disagree on the interpretation/enforcement of a particular Part 147 regulation, will the part 147 FAA/ATEC panel resolve it?
Answer: No. All attempts should be made to resolve a disagreement at the local/regional level. The school should contact the local FSDO office manager or, if the dispute continues, contact FAA headquarters, Aircraft Maintenance Division (AFS), for additional guidance on application of the regulations. Some of the other clarifications in this document will be helpful in resolving a school PMI disagreement. The current FAA/ATEC panel may be brought together periodically to help clarify particular issues; it is an ad hoc advisory group.
The FAA Aircraft Maintenance Division will make all final determinations.
20. Question : Can the PMI be a member of the school’s advisory board?
Answer: The PMI may not be a member of the advisory board of a school. However, the school may invite the PMI to attend these meetings as a guest with no voting rights.
21. Question : When an inspector came in, he inspected our school as if we were a repair station returning everything to service. All of our gauges, the battery charger, torque wrenches, measuring instruments, and measuring tools are required to be calibrated. We are a school, not a repair station. All the gauges located on hydraulic boards must be calibrated. They are not required to be there, but if they are, they must be calibrated. Reciprocating engine overhaul is level 2. We overhaul the engine and operate it (not at all airworthy), but the gauges on the test stand must be calibrated. These additional costs and time-consuming activities make it very difficult to operate efficiently. Gauges and measuring instruments should be operational, but not necessarily calibrated at a school.
Clarification is needed regarding the use of precision tooling and its calibration requirements. All schools are learning institutions, and the student environment does not easily lend itself to keeping tools that require calibration. Students damage these types of tools without being responsible for them, in some cases. Clarification is needed as to exactly when, where, and what the specifics are regarding the use of these tools other than a simple statement in the AC or handbook stating that a calibrated tool procedure is a requirement; there is no mention in the rule regarding this.
Answer: Some level of calibration is necessary, depending on what level of simulated return to service is being taught. It is up to the school and FAA inspector to determine what these areas of instruction are. It is not mandatory for all tools/gauges to be calibrated.
Appendix 3
22. Question : Our school’s class schedule is based on a clock hour, which must be at least 50 minutes in length. In January 2001, the school requested approval to change the class schedule to 4 days per week, 30 hours per week.
During a recent inspection in July 2001, the FAA stated that approval was not given and stated the school must reverse the schedule. To do so would be an extreme hardship on students who have set work schedules by the new schedule as well as the school, which took a financial hit to start the schedule in January. After several discussions with the FAA, the decision regarding the 50-minute hour rule is under review by the FAA. The school did remain on the 4-day week, but adjusted the class schedule (which has been very inconvenient for many students) until an interpretation of the regulation can be made.
Answer: The 50-minute hour is based on the Carnegie rule of instruction that a 50-minute instructional period may be combined with a 10-minute break time to equate to an hour of instruction. The question relates to two items: the interpretation of the 50-minute hour and the approval of schedule change. Historically, the 50-minute hour must be tied to the 10-minute break time. An AMTS is not able to bank the break time and offer longer breaks at a greater time interval. A school may offer a 50-minute educational period with a 10-minute break time and then take a second 10-minute break time with the next 50 minutes of instruction tied to the second break time.
The second part of the question is based on approval of change. The school has a responsibility to request a change far enough in advance to allow the FSDO to research the request and then make a decision and convey it to the school with proper justification for the approval or disapproval. The request and approval must be in writing for the benefit of both parties and to avoid confusion and/or misunderstanding.
23. Question : An FSDO stated, one of our schools must graduate a student when he or she has completed the part 147 program, even though the student has not met his financial obligations to the school. The school’s catalog states that in addition to meeting all academic and administrative requirements for graduation, the student must satisfy all financial obligations to the school. Should the FSDO dictate policy that interferes with the administrative and financial operation of a school as long as the school is operating in compliance with part 147?
Answer: A school may require students to meet certain requirements and/or obligations before issuing a graduation certificate, diploma, or degree.
A common example is that many schools require that all financial obligations of a student be met before issuing transcripts of completion certificates, diplomas, or degrees.
However, those administrative requirements of the school may be in conflict with the regulation. The regulation is clear on this issue: section 147.35(a) states that, upon request, an AMTS must provide a transcript of student grades to a student who graduates or leaves the AMTS before graduation.
Appendix 3
24. Question : Course testing (not FAA exams), including preparation and post-test reviews, is an important part of the learning process. Are these activities part of the minimum 1,900 hours?
Answer: Yes. This is very clear. Reference AC 147-3, Paragraph 12g(3) and FAA Order 8300.10 Airworthiness Inspector’s Handbook, volume 2, Chapter 187, Paragraph 7. The rule states, however, that time spent to prepare or review for the FAA general, airframe, or powerplant test may not be included as part of the hours to satisfy a school’s approved curriculum requirements.
Appendix 4 APPENDIX 4. OPTIONAL AMT CURRICULUM This optional curriculum is based on the curriculum guidelines in appendixes B through D to Part 147. This suggested curriculum may be adopted partially or in whole as a means of compliance with Part 147. The number in parentheses indicates the level of proficiency at which a particular element must be taught. Items in italics indicate additions to what is currently found in appendixes B through D to Part 147.
Area of Study Subject Description Teaching Level General Curriculum Subjects
a. Basic electricity An AMTS may choose to incorporate training on circuits and devices for complex aircraft. The AMTS may choose to incorporate these subjects into the six subject areas of this section or add them as separate subjects.
1. Calculate and measure capacitance and inductance.................... (2)
2. Calculate and measure electrical power. ..................................... (2)
3. Measure voltage, current, resistance, and continuity. ................. (3)
4. Determine the relationship of voltage, current, and resistance in electrical circuits. .................................................................... (3)
5. Read and interpret aircraft electrical circuit diagrams, including solid-state devices and logic functions........................ (3)
6. Inspect and service batteries........................................................ (3)
b. Aircraft drawings An AMTS may reduce the overall complexity of this subject. An AMTS may teach this subject only to the proficiency required to perform normal aircraft inspection and typical repairs and alterations. For example, interpretation of drawings needed to perform an actual or simulated accomplishment of an airworthiness directive.
7. Use aircraft drawings, symbols, and system schematics............. (2)
8. Draw sketches of repairs and alterations..................................... (3)
9. Use blueprint information. .......................................................... (3)
10. Use graphs and charts.................................................................. (3)
c. Weight and balance An AMTS may place emphasis on out-of-center-of-gravity conditions and load calculations.
11. Weigh aircraft.............................................................................. (2)
12. Perform complete weight-and-balance check and record data.... (3)
d. Fluid lines and fittings An AMTS may choose to focus on fabricating rigid lines because most flexible fluid lines are purchased. Students should be instructed in the inspection of flexible lines.
13. Fabricate and install rigid and flexible fluid lines and fittings.... (3) Page 1
Appendix 4 Area of Study Subject Description Teaching Level
e. Materials and processes
14. Identify and select appropriate nondestructive testing methods. (1)
15. Perform dye penetrant, eddy current, ultrasonic, and magnetic particle inspections...................................................................... (2)
16. Familiarize students with basic heat-treating processes.............. (1)
17. Identify and select aircraft hardware, composites, and materials. ..................................................................................... (3)
18. Inspect and check welds. Familiarize students with welding and soldering processes through shop visits, demonstrations, and/or classroom instruction. ..................................................... (3)
19. Perform precision measurements. ............................................... (3)
f. Ground operation and servicing
20. Start, ground operate, move, service, and secure aircraft and identify typical ground operation hazards. An AMTS may use high fidelity simulators to duplicate ground operations in place of actual aircraft................................................................ (2)
21. Identify and select fuels from among the common types of aircraft fuels in current use......................................................... (2)
g. Cleaning and corrosion control
22. Identify and select cleaning materials and perform aircraft cleaning. ...................................................................................... (3)
23.a. Inspect for aircraft corrosion. .................................................. (3)
23.b. Identify, remove, and treat aircraft corrosion.......................... (3)
h. Mathematics An AMTS may elect to test students out of mathematics without teaching it as part of its AMT curriculum. (See section 147.31(c)(4).)
24. Extract roots and raise numbers to a given power....................... (3)
25. Determine areas and volumes of various geometric shapes........ (3)
26. Solve ratio, proportion, and percentage problems....................... (3)
27. Perform algebraic operations involving addition, subtraction, multiplication, and division of positive and negative numbers... (3) Page 2
Appendix 4 Area of Study Subject Description Teaching Level
i. Maintenance forms and records
28. Write descriptions of work performed, including aircraft discrepancies and corrective actions, using typical aircraft maintenance records.................................................................... (3)
29. Complete required maintenance forms, records, and inspection reports. ....................................................................... (3)
j. Basic physics An AMTS may elect to test students out of basic physics without teaching it as part of its AMT curriculum. (See section 147.31(c)(4).)
30. Use and understand the principles of simple machines; sound, fluid, and heat dynamics; basic aerodynamics; aircraft structures; and theory of flight. ................................................... (2)
k. Maintenance publications
31. Demonstrate ability to read, comprehend, and apply information contained in FAA and manufacturers’ aircraft maintenance specifications, ATA codes, air carrier background elements, minimum equipment lists, configuration deviation lists, data sheets, manuals, publications, and related Federal Aviation Regulations, AD, and advisory material. ........ (3)
32. Read technical data...................................................................... (3)
l. Mechanic privileges and limitations An AMTS may familiarize students with related regulations to include Parts 21, 23, 25, 43, 121, 135, and 145.
33. Exercise mechanic privileges within the limitations prescribed by Part 65 of this chapter. .......................................................... (3)
m. Human factors/ maintenance resource management (MRM) Human factors and MRM may be taught as a separate subject and/or incorporated throughout the curriculum. Emphasis should be placed on error management/mitigation and situational awareness.
34. Conduct a short computer-assisted instruction course in basic MRM principles followed by integrated applications................. (1) Page 3
Appendix 4 Area of Study Subject Description Teaching Level
n. Aircraft electrical introduction
35. Teach basic concepts of aircraft electronics, including digital electronics and operational principles. ........................................ (1)
o. Fire protection systems An AMTS may teach this subject in the general curriculum, instead of separately in the A&P curriculums, to avoid teaching the subjects twice. This may only be accomplished by a school teaching a combined A&P curriculum. A school teaching only airframe or powerplant as separate ratings may not follow this approach.
36. Inspect, check, and service smoke and carbon monoxide detection systems......................................................................... (1)
37. Inspect, check, service, troubleshoot, and repair aircraft fire detection and extinguishing systems. .......................................... (3)
p. General aircraft inspection principles
38. Perform a capstone inspection module. This module should include research into regulations, maintenance manuals, and other relevant documentation encountered during a normal inspection. Students should become familiarized with applications of TCDS, illustrated parts catalogs, structural repair manuals, AD, and similar documentation. Additional focus may be placed on human factors principles, such as norms, shift turnovers, situational awareness, and inspection integrity. Students may also receive initial training in principles of visual inspection, including defect recognition, detection, and classification........................................................ (2) or (3) Page 4
Appendix 4 Area of Study Subject Description Teaching Level Airframe Curriculum Subjects I. Airframe Structures
a. Wood structures An AMTS may focus on only familiarization with the basic concepts of this subject.
1. Service and repair wood structures. ............................................ (1)
2. Identify wood defects. ................................................................. (1)
3. Inspect wood structures............................................................... (1)
b. Aircraft covering An AMTS may focus on familiarization with the concepts of this subject.
4. Select and apply fabric and fiberglass covering materials. ......... (1)
5. Inspect, test, and repair fabric and fiberglass. ............................. (1)
c. Aircraft finishes
6. Apply trim, letters, and touchup paint......................................... (1)
7. Identify and select aircraft finishing materials............................ (2)
8. Apply finishing materials. An AMTS may primarily focus on application of corrosion prevention materials............................ (2)
9. Inspect finishes and identify defects. .......................................... (2)
d. Sheet metal and nonmetallic structures
10. Select, install, and remove special fasteners for metallic, bonded, and composite structures. .............................................. (2)
11. Inspect bonded structures. ........................................................... (2)
12. Inspect, test, and repair fiberglass, plastics, honeycomb, composite, and laminated primary and secondary structures, and focus on the detection and inspection of defects and the repair of damage, using manufacturer’s structural repair manual guidelines. ...................................................................... (2)
13. Inspect, check, service, and repair windows, doors, and interior furnishings. ..................................................................... (2)
14. Inspect and repair sheet metal structures..................................... (3)
15. Install conventional rivets. .......................................................... (3)
16. Form, lay out, and bend sheet metal............................................ (3) Page 5
Appendix 4 Area of Study Subject Description Teaching Level
e. Welding
17. Weld magnesium and titanium.................................................... (1)
18. Solder stainless steel.................................................................... (1)
19. Fabricate tubular structures. ........................................................ (1)
20. Solder, braze, gas-weld, and arc-weld steel. An AMTS may elevate soldering as a separate subject to teaching level 3. ....... (2)
21. Weld aluminum and stainless steel. ............................................ (1)
f. Assembly and rigging
22. Rig rotary-wing aircraft............................................................... (1)
23. Rig fixed-wing aircraft. ............................................................... (2)
24. Check alignment of structures..................................................... (2)
25. Assemble aircraft components, including flight control surfaces........................................................................................ (3)
26. Balance, rig, and inspect movable primary and secondary flight control surfaces. An AMTS may elect to focus specifically on FAA-required inspection items. .......................... (3)
27. Jack aircraft. ................................................................................ (3)
g. Airframe inspection An AMTS may move this subject to the end of the airframe curriculum, combine it with other elements, and teach it as a capstone inspection project.
28. Perform airframe conformity and airworthiness inspections. ..... (3) II. Airframe Systems and Components
a. Aircraft landing gear systems
29. Inspect, check, service, and repair landing gear, retraction systems, shock struts, brakes, wheels, tires, and steering systems. ....................................................................................... (3)
b. Hydraulic and pneumatic power systems
30. Repair hydraulic and pneumatic power systems components..... (2)
31. Identify and select hydraulic fluids. ............................................ (3)
32. Inspect, check, service, troubleshoot, and repair hydraulic and pneumatic power systems............................................................ (3) Page 6
Appendix 4 Area of Study Subject Description Teaching Level
c. Cabin atmosphere control systems
33. Inspect, check, troubleshoot, service, and repair heating, cooling, air conditioning, pressurization systems, and air cycle machines...................................................................................... (1)
34. Inspect, check, troubleshoot, service, and repair heating, cooling, air conditioning, and pressurization systems................. (1)
35. Inspect, check, troubleshoot, service, and repair oxygen systems. ....................................................................................... (2)
d. Aircraft instrument systems
36. Inspect, check, service, troubleshoot, and repair electronic flight instrument systems and both mechanical and electrical heading, speed, altitude, temperature, pressure, and position indicating systems to include the use of built-in test equipment. An AMTS that teaches a combined A&P curriculum may elect to combine this subject with the instruction of powerplant instrument systems............................. (1)
37. Install instruments and perform a static pressure system leak test. .............................................................................................. (2)
e. Communication and navigation systems
38. Inspect, check, and troubleshoot autopilot, servos, and approach coupling systems.......................................................... (1)
39. Inspect, check, and service aircraft electronic communication and navigation systems, including VHF passenger address interphones and static discharge devices, aircraft VOR, ILS, LORAN, Radar beacon transponders, flight management computers, and GPWS. An AMTS may also elect to instruct in GPS and integrated autoflight systems. ...................................... (1)
40. Inspect and repair antenna and electronic equipment installations.................................................................................. (2) Page 7
Appendix 4 Area of Study Subject Description Teaching Level
f. Aircraft fuel systems An AMTS may combine appropriate elements of this material with elements of the engine fuel system instruction located in the powerplant curriculum.
41. Check and service fuel dump systems......................................... (1)
42. Perform fuel management transfer and defueling. ...................... (1)
43. Inspect, check, and repair pressure fueling systems.................... (1)
44. Repair aircraft fuel system components. ..................................... (2)
45. Inspect and repair fluid quantity indicating systems................... (2)
46. Troubleshoot, service, and repair fluid pressure and temperature warning systems. ..................................................... (2)
47. Inspect, check, service, troubleshoot, and repair aircraft fuel systems. ....................................................................................... (3)
g. Aircraft electrical systems An AMTS may elect to combine aircraft electrical system subjects with the basic electricity subject in the general curriculum.
48. Repair and inspect aircraft electrical system components, crimp and splice wiring to manufacturers’ specifications, and repair pins and sockets of aircraft connectors. An AMTS may elect to increase the teaching level to 3 in repair of pins/sockets and crimping/splicing of wiring.............................. (2)
49. Install, check, and service airframe electrical wiring, controls, switches, indicators, and protective devices................................ (3)
50.a. Inspect, check, troubleshoot, service, and repair alternating and direct current electrical systems........................................ (3)
50.b. Inspect, check, and troubleshoot constant speed and integrated speed drive generators............................................. (1)
h. Position and warning systems
51. Inspect, check, and service speed and configuration warning systems, electrical brake controls, and antiskid systems............. (2)
52. Inspect, check, troubleshoot, and service landing gear position indicating and warning systems. ................................................. (3)
i. Ice and rain control systems
53. Inspect, check, troubleshoot, service, and repair airframe ice and rain control systems.............................................................. (2) Page 8