CHAPTER 2. CERTIFICATION REQUIREMENTS FOR SCHOOLS CERTIFICATED UNDER PART 147
1. AMTS RATINGS. An AMTS may be FAA-certificated for the following ratings: airframe, powerplant, or combined A&P. The general portion of the curriculum is not a rating, but it is a required part of all the ratings. Schools certificated for only combined A&P ratings cannot grant single ratings such as airframe or powerplant. Students enrolled in a combined curriculum are required to finish the entire combined curriculum before becoming eligible for FAA certification testing.
2. DURATION OF CERTIFICATE. An AMTS’s FAA certificate remains in effect until it is surrendered, suspended, or revoked. However, if an AMTS changes location, facilities, or ratings, or adds or deletes a rating, the school must be recertificated by the FAA.
3. DISPLAY OF CERTIFICATE. An AMTS is required to display its FAA certificate in a prominent location that is accessible and visible to the public. The AMTS must also make the certificate available for FAA inspection.
4. ADVERTISING. In all advertising and brochures, an AMTS is required to indicate that it is an FAA-certificated school. Course literature must clearly distinguish between those courses that have been approved by the FAA and those that have not. For example, an FAA-certificated AMTS that is part of a junior college system may offer courses in aviation management but must clearly state in its literature that those courses are not FAA-approved.
5. INSPECTION REQUIREMENTS. When an application is made to the FAA for certification, the applicant must be ready for the FAA to inspect its facilities and equipment.
Normally, after certification, FAA inspections are conducted annually to determine whether the school continues to meet its certification requirements. However, the FAA will perform more inspections if required (reference section 147.43).
6. CURRICULUM REQUIREMENTS. The AMTS curriculum is comprised of the courses needed to meet part 147 requirements. The curriculum is the single most important document an AMTS applicant will submit. Once approved by the FAA, the curriculum shows how the AMTS will train students for certification as AMTs, and how it will meet the academic and regulatory requirements of the regulations. Elements comprising an AMTS curriculum can vary widely.
However, many AMTSs include all or some of the required operating rule compliance documents in their curriculums. Because these documents must be supplied to the FAA in any case, this has an advantage in that it incorporates all part 147 school requirements in a single document. Because revisions may be required periodically and those revisions must be FAA- approved, curriculum documents should have a format that permits easy revision. The curriculum document should have a revision control chart or page that indicates the location of each revision and includes the approving FAA official’s signature.
a. Curriculum Background. Part 147, section 147.21 provides the minimum curriculum requirements. Maintenance of curriculum requirements is stated in part 147, section 147.38.
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(1) An AMTS is required to adhere to its approved curriculum. Any part 147 course material the school wishes to add must be incorporated into the approved curriculum and approved by the FAA before it may be used. This does not prohibit an AMTS from teaching non-FAA-approved courses such as refresher courses or academic courses required to complete a degree program. However, those courses must be clearly distinguishable from FAA-approved AMTS courses.
(2) An AMTS should strive to keep its approved AMTS curriculum current to meet industry needs by revising courses as appropriate. These revisions require FAA approval before they can be implemented.
(3) Practical projects, referred to in section 147.21(d), include all functions specified in the curriculum that involve hands-on tasks. Therefore, practical projects include virtually any task taught at level 2 or level 3, because all of these require some practical application, as specified in part 147 appendixes.
b. Curriculum Development. Curriculum development generally progresses through several stages, as discussed below. Practical examples may be found in Appendixes 4 and 6 to this AC.
(1) Stage 1. The first stage is to conceptualize the knowledge, skills, and abilities an aviation mechanic must acquire to become certificated by the FAA. To determine the knowledge, skills, and abilities requirements, the FAA commissioned a study of the AMT occupation. Some of the results of the study, A Survey of the Aviation Mechanic Occupation,” were used in developing part 147. This study is often called “The Allen Study,” after the chief researcher, Dr. David Allen. Although it does not constitute an AMTS curriculum, the Allen Study does provide a partial foundation for developing a sound curriculum that addresses the requirements of the regulations. The study also identifies the training, knowledge, skills, and abilities a student must acquire to qualify as an A&P mechanic.
NOTE: Al though useful, the Allen St udy is not technically curren t for all topics. You may also refer to th e Northwestern University study, Job Task Analysis of the Aviatio n Maintenance Technician, May 1999, w hich updated the tasks of the Allen Study.
(2) Stage 2. The second stage of curriculum development involves identifying which specific tasks must be performed, determining the specific performance standard that must be reached for each task in each subject area, and assigning the amount of instructional time in theory, laboratory, and shop that will achieve that performance standard.
(3) Stage 3. The third stage in curriculum development must produce a curriculum that contains all the elements required to teach, test, and conform to the rule. Stage 3 must also develop practical projects and objective project grading criteria. Practical projects and associated tests may be presented within the main body of the curriculum or in associated workbooks, workbook supplements, or project guides. Wherever the practical projects are presented, they ultimately must be submitted to the FAA for approval and become part of an Page 2 Par 6
FAA-approved curriculum. The testing and evaluation of practical projects may represent the most difficult task in curriculum development. No one method is “best.” Instead, there are a number of methods used by AMTSs that have proven to be valid. Appendix 6, Sample Curriculum Outlines, offers a brief description of practical project guides and the various methods AMTSs use to objectively grade practical projects. Minimally, a complete curriculum should:
(a) Conform to part 147.
(b) Provide a method to teach the knowledge, skills, and abilities an AMT student is required to learn.
(c) Have clearly expressed objectives.
(d) Provide objective test criteria that conform to subjects studied in the laboratory, shop, and in the classroom.
(e) Show the appropriate teaching level and number of required laboratory, shop, and theoretical hours to complete the program for a given rating.
(f) Include a complete description of each practical project and the methods and materials required to accomplish each one.
(g) Show the relationship of practical projects to the required subjects.
c. Curriculum Components. An acceptable part 147 curriculum consists of at least the following elements:
(1) Subjects conforming to part 147, appendixes B, C, and D.
(2) Course content conforming to part 147, appendixes A, B, C, and D.
(3) Teaching level requirements conforming to appendixes A, B, C, D, and to part 147.
(4) Objective testing and grading criteria.
(5) Classroom or theory hours conforming to section 147.21.
(6) Laboratory or shop hours conforming to section 147.21.
(7) Total number of hours conforming to section 147.21.
(8) A schedule of required tests that shows the sequence of examinations for each subject in the curriculum.
(9) The order of instruction for each subject.
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d. Additional Requirements.
(1) Each subject item must be taught at least at the indicated level of proficiency as defined in part 147 appendixes. When the school wishes to teach a subject item to a level beyond the requirements, the teaching level must be approved by the FAA and made part of the FAA-approved curriculum. As an example, a subject required by part 147 to be taught at level 1 may be taught at level 2 by a school that has obtained FAA approval at a level beyond the requirements. Subject items cannot be taught at a level less than that shown in the FAA- approved curriculum or less than those shown in the part 147 appendixes.
(2) Additional subjects/courses required by the school for its own purposes, e.g., degree program subjects such as geography, should not be submitted for FAA approval as part of the curriculum.
(3) Subjects such as basic aerodynamics or theory of flight can be taught within pertinent, related subjects such as physics and aircraft rigging. This would not necessarily increase required instruction hours.
(4) The teaching of additional subject material beyond the requirements of appendixes B, C, and D to part 147 may require additional instruction hours beyond those required to be offered by section 147.21.
e. Curriculum Focus.
(1) Many AMTSs enhance portions of their curriculums to develop graduates who are directed toward particular areas of the aviation industry. Examples are schools that tend to train graduates specifically for employment at commercial airlines, helicopter operations, repair stations, or agricultural aircraft operations. Enhancement of the curriculum generally results in a curriculum with more hours of instruction than the minimum that must be offered under section 147.21 for airframe and powerplant (A&P) ratings. Schools with directed curriculums may be permitted by the FAA to reduce teaching hours (but not teaching levels) in areas they want to deemphasize and increase teaching hours (and sometimes teaching levels) in areas targeted for enhancement. The following are two examples of focused curriculums:
(a) Example 1. A small AMTS in a rural area may want to direct AMT students toward general aviation and agricultural applicator aircraft operations. In this case, airframe subjects such as wood, dope, fabric, welding, rigging, and corrosion control would be emphasized by increasing the teaching hours and perhaps teaching levels for these subjects.
Powerplant courses such as propellers and reciprocating powerplants, including radial and opposed, would also be emphasized in the same ways and further by exploring better or more efficient instruction and/or methods. On the other hand, turbine engines, electronics, and air conditioning may be reduced in teaching hours. Part 147 does not permit a reduction in teaching level.
(b) Example 2. A large AMTS in a metropolitan area may concentrate on preparing AMT students for employment at major airlines. This AMTS would tend to emphasize areas Page 4 Par 6
such as turbine engines, nondestructive inspection, air conditioning systems, autoflight, electronics, and airline maintenance systems. This AMTS may want to reduce its teaching hours in wood, dope, fabric, welding, and reciprocating engine subjects.
(2) In both examples, the number of teaching hours for certain subjects may be either reduced or increased, as appropriate. However, course content cannot be lowered in teaching levels, and the number of teaching hours for each subject would require FAA approval. It is obvious from this discussion that it is permissible to concentrate curriculums toward certain areas to prepare the students for the appropriate service market. It is recommended that the AMTS develop its curriculum direction during the initial certification.
(3) It is important to note that the teaching level of each subject in the curriculum directly affects the number of hours required to teach that subject. An AMTS must offer a sufficient number of hours for each subject to permit an average student to perform at the required subject level.
f. Curriculum Format. There is not a format specifically required for a curriculum.
However, as testing is part of the teaching validation process, the curriculum is required to show testing and grading, as stated in section 147.21(d)(3).
g. Hours of Instruction. The number of hours of instruction offered for any rating must be at least the minimum specified by section 147.21. The school may offer more hours of instruction than the FAA requires. The following blocks of time are not to be included in calculating the minimum number of instructional hours specified in section 147.21:
(1) Time used to take the FAA oral and practical test.
(2) Time spent in taking the FAA knowledge test or time spent registering for the test.
(3) Time set aside for FAA test review and testing at the conclusion of the course. This is not to preclude review and testing for curriculum courses but to differentiate between the time spent in learning approved curriculum material and that spent in review for the FAA certification test.
(4) Time used for meals, breaks, or class changes.
h. Order of Instruction. The curriculum should list the order of course progression in a logical sequence for each rating offered. For example, basic electricity would be completed before taking aircraft electrical systems.
i. Curriculum Structure. An AMTS offering separate ratings of airframe or powerplant, but not combined A&P, is required to have a clearly defined general subject curriculum. It is recommended that the general curriculum follow the format prescribed in appendix B to part
147. This ensures a student graduating from one rating curriculum meets the FAA requirements to receive the same general curriculum courses a student graduating from another rating curriculum receives (see Appendix 7, Maintenance of the General Curriculum).
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j. Testing and Grading. Testing should be included as part of the required curriculum hours and must be directly related to the subject matter covered (see sample 3 in Appendix 6).
(1) Passing grades must be sufficient to achieve the required teaching level in part 147.
Within the requirements, an AMTS can set its own standards for passing grades in the laboratory, shop, and classroom. Theoretical portions may have different grading standards from those required in laboratory and shop classes. A common academic standard for passing is a minimum score of 70 percent. FAA written tests also use the 70-percent standard. An AMTS may choose to require a different minimum passing grade, although many AMTSs elect to use the 70-percent passing standard.
(2) All theoretical and practical portions of each subject listed in the curriculum are required to be individually passed to the AMTS-approved grading standard. Each practical project must also be separately passed to the approved standard. Students must complete all required laboratory and shop projects with passing grades. Practical project testing and grading criteria must be explicit. The requirements for successful completion must be sufficient to maximize objective grading and reduce any subjective project grading to a minimum.
(3) Upon completion of each curriculum subject, a test must be scheduled. In addition, at the school’s discretion, quizzes may be scheduled at any time. From an educational standpoint, it is more effective and appropriate to schedule a test after a subject unit such as welding rather than after a comprehensive subject such as airframe structures that contains welding and six other subject units. When testing for subjects that have many hours of instruction (for example, sheet metal structures), an AMTS should consider planning more than one test or quiz during the instructional unit.
(4) The AMTS should have a system to provide test security. This system may include provisions for regular test changes and secure storage of tests and quizzes.
k. Practical Application Projects.
(1) The curriculum must list each of the practical projects that must be completed for each subject item. There must be a sufficient number of practical projects to address the requirements of appendixes B, C, and D to part 147, as applicable. The curriculum should include enough detail to identify the practical projects for the correct teaching level and to clearly define performance standards and objective grading criteria.
(2) The AMTS must specify the teaching level (2 or 3) for each practical project to be covered in each subject item. The minimum teaching level is specified in part 147 appendixes.
If the teaching level for practical projects is to exceed those requirements, it must be specified as such in the curriculum.
(3) The curriculum must show an appropriate amount of time for an average student to complete each project. Data contained in the Allen Study provides useful information on project completion times. However, the Allen Study guidelines are only suggestions.
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(4) The curriculum should be designed so that each task in each subject item is accomplished. For example, if a subject element listed in the appendixes requires that the student inspect and repair to accomplish a level 2 or level 3 subject, a project requirement for both inspection and repair must be included in the curriculum. It is possible that one project may satisfy all the requirements for that subject element.
l. Makeup Provisions.
(1) An AMTS must specify its provisions for the evaluation of students after failure.
(2) The curriculum must show the number of hours of allowed absences.
(3) All classroom material missed during allowed absences must be made up in the same subject area.
(4) All practical projects missed during allowed absences must be made up. These must be either the same projects missed or those that are very similar. Projects must be completed according to the approved grading standards.
(5) Absences exceeding the number of excused hours allowed by the AMTS or absences not excused, require that portion of the curriculum to be retaken.
m. Revisions to the Curriculum. Changes to an approved curriculum must be approved by the FAA before an AMTS can implement them. Changes in the curriculum may include changes in any of the following:
(1) Teaching level (Appendix A to part 147).
(2) Hours of instruction.
(3) Business hours during which instruction is conducted.
(4) Testing/grading criteria.
(5) Makeup provisions.
(6) Course content.
(7) Equipment or facilities affecting instruction in theoretical subjects or the accomplishment of practical projects.
(8) Order of instruction, such as changes in the logical sequence of instruction.
(9) Addition or deletion of a rating.
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(10) Changes in the student-to-teacher ratio.
n. Crediting Procedures for Previous Instruction or Experience. The AMTS should use either a reliable method of evaluating a student’s instruction or an entrance test to ensure previous instruction is comparable to that offered by the crediting school. When not using an entrance test, an AMTS should use authenticated transcripts, catalogs, course descriptions, and other documents to determine the credit to be granted.
(1) Credit for the General Curriculum. When a student successfully completes a course of study for one rating and obtains that rating, that course of study will have included the general portion of the curriculum. When that student returns to the AMTS to study for a second rating after having graduated from the course and obtained the first rating, the student will not have to retake the general portion of the curriculum. This benefit applies provided the general portion is clearly separate and distinct from either the airframe or the powerplant portions and conforms to the requirements of appendixes A and B to part 147. (See Appendix 7.)
(2) Credit for Previous Instruction from Other Schools (Accredited Nonaviation Schools). In general, at schools that are not certificated under part 147, credit may be granted only for a limited range of subjects that apply to the general portion of the curriculum; that is, mathematics, basic physics, and similar subjects.
(3) Credit for Previous Instruction from U.S. Military Technical Schools. If an AMTS chooses to grant credit for previous instruction from U.S. military technical schools, it may be granted only on the basis of an entrance test, as specified in section 147.31(c)(2)(iii).
(4) Credit for Previous Experience (Military and Civilian). As a rule, creditable previous mechanic experience must be aviation maintenance experience comparable to the required AMTS curriculum subjects. For example, a person applying for credit for the aircraft weight and balance subject area on the basis of experience as a military aircraft loadmaster, might be granted experience credit in that specific area but not for the aircraft sheet metal structures subject area.
Credit for all previous AMT experience must be documented and demonstrated by testing. The test must be equal to the test given to students who complete AMTS-comparable required curriculum subjects.
(5) Exceptions to Crediting Procedures for Previous Instruction or Experience.
(a) Except for certain mitigating circumstances, if a certificated AMTS is under suspension by the FAA, courses taught during the suspension period cannot be credited retroactively, even if the school becomes recertificated later.
(b) An AMTS applicant may not teach students as an AMTS before receiving the FAA certification and then give credit for that training after the school becomes certificated.
(c) An AMTS may not credit a student with instruction received in a nonaviation course, even if it was satisfactorily completed at a teaching institution with an FAA-certificated AMTS. For example, this prohibits an institution teaching nonaviation courses (such as diesel Page 8 Par 6
mechanics) from granting those credits to students taking an aviation maintenance course at the same institution.
7. FACILITIES.
a. General Guidelines for Facility Development and Maintenance. The instructional aids, laboratory and shop equipment, and physical layout of the building must meet the requirements outlined in sections 147.15, 147.17, and 147.19. The applicant should keep in mind that the facility must constitute an environment suitable for learning. Distractions from learning, such as excessive noise, dust, fumes, heat, cold, and clutter must be considered during development of the AMTS facility.
(1) Facilities must be of adequate size for the number of FAA-authorized students to accomplish any of the laboratory or shop projects designated for that area and all classroom instruction.
(2) Facilities must be located and classes scheduled so that students can travel between classes without cutting into instructional time. An AMTS should avoid scheduling situations in which the students cannot go from one class to another within the time the school specifies for class transit.
(3) The school should ensure the laboratory and shop floors are free from clutter, such as extension cords and air hoses.
b. Facility Layout. All facilities must conform to local and state codes. Discussion of those requirements is beyond the scope of this AC. The layout of the AMTS facilities will be influenced by the ratings the school plans to obtain. The following sections provide basic information on facility layout according to the requirements of each subject area (see Appendix 8, Sample Facility Layout).
(1) General Subjects (Appendix B to Part 147). The facility layout should ensure lead-acid and nickel-cadmium battery charging stations are appropriately isolated from each other. Laboratory storage facilities and electrical/laboratory work stations must be appropriate.
Heat treatment furnaces and metal working equipment must be safe and well ventilated.
Nondestructive inspection equipment (including magnetic particle inspection equipment) should be a design suitable for inspection of aircraft components. High-pressure fluid line and pressure hose test devices must be safe to use.
(2) Airframe Subjects (Appendix C to Part 147). The shop layout must provide painting facilities that are temperature-controlled and force-ventilated. Paint spray booths should meet state, local, and industry standards. The aircraft assembly area should be adequate and clean.
The equipment for gear retraction demonstration and service (whether live aircraft or an instructional aid) should be in a clear area, safe to use, and accessible to a maximum of eight students. The sheet metal area must have a sufficient number of benches and vises, as well as an adequate air supply with built-in connectors. Facility layout should incorporate doors adequate to move aircraft in and out. This facility should constitute a learning environment appropriate Par 6 Page 9
for simulation of return to service.
(3) Powerplant Subjects (Appendix D to Part 147). The layout of the facility must provide appropriate and ventilated cleaning facility areas. A clean area for powerplant and accessory inspection and repair must be provided. There must be a safe engine run-up area and an engine test cell or engine run-up stand with appropriate test monitoring instrumentation. A propeller service and balancing area should be provided. As in the case of the airframe facility, the powerplant shop facility should constitute a learning environment appropriate for simulation of return to service.
8. TECHNICAL DATA LIBRARY REQUIREMENTS. An AMTS must provide a suitable technical data reference facility or area. The technical data reference area should have appropriate facilities for study and data examination. It should have an area isolated from high noise levels. Suitable bookshelves, microfiche readers and supplies, computers, and data files should be available. The technical data must be of a type appropriate for the AMTS ratings. As a minimum, the technical data should include the following:
a. Federal aviation regulations (14 CFR parts 1 through 199).
b. Aircraft, engine, propeller, and type certificate data sheets (TCDS) and specifications.
c. Airworthiness Directives (AD).
d. Supplemental Type Certificates.
e. Maintenance manuals.
f. ACs.
g. Other instructional materials, such as textbooks on basic physics, math, hydraulics, and powerplants.
9. INSTRUCTIONAL AIDS AND AIRCRAFT.
a. The instructional aids required by section 147.17 must be appropriate for the scope and depth of the curriculum of the school. The applicant should ensure the complexity of instructional aids is appropriate to the specific teaching level of the subject item. An inventory of instructional aids is required.
b. Section 147.17(a)(2) requires a school to have (for instructional purposes) an aircraft of a type currently certificated by the FAA. In this case, certification refers to FAA type-certification.
While many schools use surplus military aircraft to show compliance with this rule, at least one aircraft must be a type eligible for an FAA type certificate (TC). As an example, many light observation military aircraft have FAA TCs but most fighter aircraft do not; therefore, fighter aircraft would not meet the rule requirements. In some situations, an AMTS may choose to use an airworthy aircraft for certain instructional purposes in shop classes. This is permissible as long Page 10 Par 7
as the aircraft is on the school premises at the time of instruction. Active aircraft used to comply with section 147.17(d) become part of the approved instructional equipment; therefore, they must be listed in the instructional aids inventory.
c. An AMTS must comply with the requirements for the ratio of instructional aids to students in each shop course. Section 147.17(c) permits no more than eight students to work on any one unit of equipment at a time. This does not necessarily mean that a school must have each type of instructional aid for at least every eight students enrolled. However, as an example, if a school has an enrollment of 30 students in the powerplant course of study and has only 2 turbine engines, the school must clearly demonstrate in the curriculum what project the students who exceed the 16 permitted on the turbine engines at any one time will be doing, for example, projects on piston engines or carburetors. However, the FAA (or the AMTS) may determine that eight students may be too many to safely and competently conduct a certain project, for example, instruction on live aircraft used for the demonstration of gear retraction systems.
10. SHOP EQUIPMENT REQUIREMENTS.
a. An AMTS is required to have enough shop equipment in place and in satisfactory operating condition to adequately serve the student enrollment and meet shop/project subject requirements.
b. The equipment must be located so students can operate it in a safe and efficient manner.
Large, standing equipment must be securely installed. Placement of large shop equipment should provide sufficient aisle space so that students can move about freely. The equipment must be listed and the list maintained in the shop where the equipment is located.
11. SPECIAL TOOLS STANDARDS. The AMTS must provide an inventory of special tools required to provide instruction. For subjects taught at level 3, when meeting return to service standards, all special tools must be in satisfactory working condition, maintained in accordance with section147.19, and of the proper kind for the purpose for which they are intended. When meeting simulated return to service standards, all special tools must be in satisfactory working condition for the purpose for which they are to be used. Section 147.19 requires the AMTS to furnish an adequate supply of special tools appropriate to the ratings and curriculum of the AMTS. Special tools may be custom fabricated for the intended purpose and furnished by the AMTS.
12. STUDENT HANDTOOL REQUIREMENTS. The AMTS may either provide common handtools or require students to furnish their own. In either case, the school must establish a policy on provision of common handtools. The school must provide a list of required handtools to the students. Any tools the school requires the student to furnish, must be listed specifically in the curriculum and that list must be provided to students.
13. MATERIAL REQUIREMENTS. The AMTS must provide a list of materials required for instruction. The school must have sufficient materials in stock and properly stored to provide for the approved student enrollment. To ensure adequate instruction, the amount and variety of stocks should directly reflect the requirements of the curriculum. For example, sufficient Par 9 Page 11
quantities of rivets, hydraulic fluid, gaskets, and sheet metal are needed to complete a course of study.
14. INSTRUCTOR REQUIREMENTS AND RESPONSIBILITIES.
a. Faculty Requirements. Individuals listed as instructors must be FAA-certificated with an FAA mechanic certificate having ratings appropriate to those subjects taught (other than certain general subjects such as mathematics, physics, and drawing). The suitability of noncertificated instructors to teach certain general courses is evaluated by the FAA on an individual basis. As an example, a school may propose to use a non-FAA-certificated, but experienced, engineering instructor to teach the mathematics and physics requirements of the general curriculum. Other employees, such as stock clerks or parts persons, are not required to be FAA-certificated.
b. Student/Teacher Ratios. Section 147.23 requires at least 1 certificated instructor for every 25 students in each laboratory or shop class. The AMTS may choose to provide a lower student-to-teacher ratio according to the needs of the class or subject. The AMTS must have procedures to maintain the required minimum instructor ratios when regular instructors are on leave.
15. FOREIGN SCHOOLS. Part 147 does not make any provisions for FAA certification or surveillance of aviation mechanic schools located outside the United States. Foreign AMTS applicants are not eligible for FAA certification.
16. SATELLITE SCHOOLS. An AMTS may not operate as a satellite facility. All AMTSs must be FAA-certificated as separate facilities.
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