Par 2-7 Page 9 addressing the reporting interruptions that cause deviations in the order of instruction in the approved curriculum to the principal inspector (PI).
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 8, Maintenance of the General Curriculum).
NOTE: For distance learning information on requirements, see Appendix 11.
j. Testing and Grading. Testing must be included as part of the required curriculum hours and must be directly related to the subject matter covered (see sample 3 in Appendix 7).
(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) Students must pass all theoretical and practical portions of each subject listed in the curriculum based on the AMTS-approved grading standard. While theory and practical portions must be tested separately, the grades may be averaged before assessing passage. 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 appendices B, C, and D to part 147, as applicable. The curriculum should
Par 2-7 Page 10 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 appendices. If the teaching level for practical projects is to exceed those requirements, it must be specified as such in the curriculum.
(3) The curriculum should show an appropriate amount of time for an average student to complete each project. Although there is no set time by rule, it is good to establish time parameters for curriculum development and class scheduling. Data contained in the Allen Study provides useful information on project completion times. However, the Allen Study guidelines are only suggestions.
(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 appendices 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. Absence and Missed Material. Section 147.31(e) requires an approved system for recording student attendance. The system must show hours of absence allowed and how the missed material will be made available to the student. The system must ensure that all graduates will have completed all appropriate curriculum requirements (see § 147.31(c)).
(1) Instructors shall supervise and verify completion of practical project requirements;
other missed materials may be made available through:
(a) Communication of subjects and/or chapters covered in a course textbook;
(b) Availability of an instructor presentation;
(c) Availability of class materials; and
(d) Assignments directly attributable to the missed subject matter, such as:
• Supplementary reading assignments;
• Student completion of a written essay;
• Student completion of questions, answers, and references;
• A student oral presentation based on an outline; and/or
• Any other method acceptable to the Administrator.
(2) All makeup assignments, class assignments, and exams missed in a module must be completed before any written, oral, or practical test can be administered.
(3) Failure of a student to complete all makeup assignments and material within the school’s approved allotted time period may result in the student being required to repeat that subject.
Par 2-7 Page 11
m. Revisions to the Curriculum. Changes to an approved curriculum must be approved by the FAA before an AMTS can implement the revision. Changes in the curriculum may include changes in any of the following:
• Teaching level (Appendix A to part 147);
• Hours of instruction;
• Business hours during which instruction is conducted;
• Testing/grading criteria;
• Makeup procedures;
• Course content;
• Equipment or facilities affecting instruction in theoretical subjects or the accomplishment of practical projects;
• Order of instruction, such as changes in the logical sequence of instruction;
• Addition or deletion of a rating;
• Changes in the student-to-teacher ratio; or
• Distance learning.
NOTE: For distance learning information on requirements, see Appendix 11.
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, along with catalog reference 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 appendices A and B to part 147. (See Appendix 7.)
(2) Credit for Previous Instruction from Other Schools (Accredited Non-Aviation 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 § 147.31(c)(2)(iii).
Par 2-7 Page 12
(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 powerplant experience gained while working in the military or at an airline could be considered as previous experience.
(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) With discretion, an AMTS may credit a student with prior instruction received for certain non-aviation courses with content similar to the part 147 curriculum.
2-8. 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 §§ 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, state and federal 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 9, 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
Par 2-8 Page 13 treatment furnaces and metal working equipment must be safe and well ventilated. NDI (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 force-ventilated. Paint spray booths should meet state, local, federal 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, air supply connections, and vises to accommodate the number of students for which the training area has been approved. Facility layout should incorporate doors adequate to move aircraft in and out. This facility should constitute a learning environment appropriate 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.
2-9. 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. The technical data must be of a type appropriate for the AMTS ratings. At a minimum, the technical data should include the following:
• Title 14 of the Code of Federal Regulations (14 CFR) parts 1 through 199.
• Aircraft, engine, propeller, and Type Certificate Data Sheets (TCDS) and specifications.
• Airworthiness Directives (AD).
• Supplemental Type Certificates (STC).
• Maintenance manuals.
• ACs.
• Other instructional materials, such as textbooks on basic physics, math, hydraulics, and powerplants.
2-10. INSTRUCTIONAL AIDS AND AIRCRAFT.
a. Scope and Depth. The instructional aids required by § 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. FAA Type-Certification Aircraft. 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
Par 2-10 Page 14 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 as the aircraft is on the school premises at the time of instruction. Active aircraft used to comply with § 147.17(d) become part of the approved instructional equipment; therefore, the aircraft must be listed in the instructional aids inventory.
c. Instructional Aids to Student Ratio. 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 two 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 are too many in number to safely and competently conduct a certain project. As an example, instruction on a currently certificated aircraft used for the demonstration of gear retraction systems, eight students may be deemed as too many students involved in this training event.
2-11. SHOP EQUIPMENT REQUIREMENTS.
a. Equipment Quantity and Condition. 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. Equipment Placement. 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.
2-12. 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 § 147.19, 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.
2-13. STUDENT HAND TOOL REQUIREMENTS. The AMTS may either provide common hand tools or require students to furnish their own. In either case, the school must establish a policy on provision of common hand tools. The school must provide a list of required hand tools 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.
Par 2-14 Page 15 (and 16)
2-14. 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 quantities of rivets, hydraulic fluid, gaskets, and sheet metal are needed to complete a course of study.
2-15. INSTRUCTOR REQUIREMENTS AND RESPONSIBILITIES.
a. Instructor Requirements. Individuals listed as instructors must be FAA-certificated with an FAA mechanic certificate having ratings appropriate to those subjects taught in A&P subject areas as identified in Appendix C and D. The AMTS may provide specialized instructors that are not certificated mechanics to teach general subject areas such as mathematics, physics, basic electricity, basic hydraulics, drawing, and similar subjects. 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.
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.
2-16. 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.
2-17. SATELLITE SCHOOLS. An AMTS may not operate as a satellite facility. All AMTS must be FAA-certificated as separate facilities.
Par 3-1 Page 17 OPERATING RULES CHAPTER 3.
3-1. CHANGE OF LOCATION.
a. Notification. An AMTS may not make any change in the school’s location unless the FAA reviews and approves the changes in advance. The AMTS is required to notify the FAA in writing at least 30 days before the location change is to be executed. During the change in location, no disruption may be made to student instruction or normal classroom attendance.
Equipment, facilities, and instructors must be at least at the same level as the standards approved for the vacated facilities or revised and explained as part of the application process. Application for a change of location is made by completing FAA Form 8310-6, Aviation Maintenance Technician School Certificate and Ratings Application.
b. Amendment to or Transfer of Certificate. The AMTS must apply for a change to its certificate if changing the location of the AMTS. The air agency must notify the FAA in writing at least 30 days before the date of the change. The FAA may prescribe conditions the air agency must follow while moving to the new address/location. If the AMTS location is changed without approval, the air agency certificate will be revoked. (Refer to § 147.41.)
(1) Change of FAA District. When the location is a change to another FAA district office or region, the application for approval must go to the district office and receive coordination through each respective region that has current and/or future certificate responsibility. The originating district office will contact and coordinate directly with the receiving district office while maintaining close coordination with the affected Regional Office(s) (RO). The school remains the responsibility of the originating district office until approval of the change or transfer. Refer to Volume 2, Chapter 1, Section 2 for additional information.
(2) Sale or Transfer of Assets. The privileges of an AMTS Air Agency certificate are not transferable. If the holder of the Air Agency certificate sells or transfers its assets, the new owner must apply for an amended certificate in accordance with § 147.41. There are occasions when AMTS ownership changes without a corresponding change in location, facilities, or personnel.
(3) The Freedom of Information Act (FOIA). The inspector should recommend a new certificate number due to the FOIA and liability issues. ASIs should inform prospective owners that they may be held liable for the work performed under previous management if they keep the same certificate number. New owners must stipulate in writing that they clearly understand the potential of release of information under the FOIA before receiving permission to retain the old certificate number.
(4) Retaining or Re-issuing the Certificate Number. If the new owner elects to retain the original certificate number, the revised air agency certificate (FAA Form 8310-6) will show the original certification date in the “Date issued” field. If issuing a new certificate number, prepare a new air agency certificate using the effective date of the new certificate. The “Date issued” should always reflect the original certification date for the certificate number identified on the air agency certificate.
Par 3-1 Page 18
(5) Change in Ownership. A change in ownership may or may not affect the status of an AMTS. If the operational relationship that established an AMTS continues unchanged, a change to the certificate number may not be required. If that relationship no longer exists, the certificate number identifying the AMTS cannot be retained by the new owner.
(6) Regional General Counsel Office. ASIs should contact their regional general counsel office when faced with questions concerning whether limited liability corporations or changes in stockholder ownership constitute a transfer of AMTS assets.
3-2. TIME AND ATTENDANCE. An AMTS must specify in the approved curriculum the number of instructional hours the school intends to offer. An AMTS must ensure typical time loss items do not affect approved curriculum hours. Student attendance requirements are specified in § 147.31(a). Some typical time loss items are as follows:
• Instructors ill or on leave. In small schools, this could result in canceled classes or students sent to a study room;
• Teachers’ strikes;
• Weeks scheduled for private study and/or testing outside of the approved curriculum;
• Class outings, not related to aviation maintenance, that take time away from instructional hours;
• Student achievement days, sports days, and special event days;
• Teachers’ meetings and grading days;
• Student absences beyond those permitted in the FAA-approved curriculum;
• Classroom or laboratory and shop time spent on non-instructional activities such as school administrative work and pep rallies, cleaning, painting, repair and maintenance of instructional aids; and
• Any other activity that intrudes on instructional time.
3-3. ENROLLMENT. An AMTS applicant cannot have more students enrolled than the number stated on the certificate application. As enrollment increases or decreases, an AMTS may choose to change either the number of certificated or noncertificated instructors, or the subjects to be taught by each. However, when instructors are changed or if enrollment exceeds the FAA-approved figures, the school must notify the FAA in advance.
3-4. RECORDS, TRANSCRIPTS, AND GRADUATION CERTIFICATES. An AMTS must maintain and, upon request, make available to the FAA documents that show records on each student. (New AMTS applicants must also show the proposed method of meeting FAA records requirements.)
a. Records. Records must clearly show attendance, tests, quizzes, and practical projects grades received on subjects required. Student records should clearly distinguish between successful performance and unsuccessful performance. The record should show how credit was granted for previous experience and/or previous instruction. Progress records or charts do not need to show student grades for practical projects or laboratory work if those grades are available in another record at the school. However the progress record should show the practical projects and lab work completed and/or to be completed. Student attendance records should show the number of hours of absences. Section 147.33 requires schools to retain student records for
Par 3-4 Page 19 2 years. This does not refer to each student’s personal tests but to the grades received on tests given to the student for each subject. Examples of the forms used for these records should be in a document such as the curriculum.
b. Transcripts. Upon request, each certificated AMTS shall provide a transcript of the student’s grades to each student who is graduated from that school or who leaves it before being graduated. An official of the school shall authenticate the transcript. The transcript must state the curriculum in which the student was enrolled, whether the student satisfactorily completed that curriculum, and the final grades the student received.
c. Graduation Certificates or Certificates of Completion. An official of the AMTS must authenticate all student certificates issued. This should be accomplished by verifying the student has passed the specified courses or has received prior credit based on the AMTS approved curriculum requirements. The certificate cannot be issued unless all curriculum requirements have been completed for the certificate sought. All students meeting the AMTS graduation or completion requirements must be issued the appropriate certificate. Each school shall give a graduation certificate or certificate of completion to each student that it graduates.
The certificate must show the date of graduation or completion and the approved curriculum title. The certificates should contain the name of the AMTS, its certificate number, the approved course name, and date of graduation.
d. Student Graduation Lists. Schools with affiliations must provide a student graduation list to the assigned Flight Standards District Office (FSDO), Designated Mechanic Examiner (DME), and the Testing Center with the following content:
• Name and certificate number of the AMTS,
• Graduation date,
• Curriculum from which the applicant graduated (i.e., Airframe and/or powerplant),
• Name of the applicant, and
• Signature of the authorized school official.
3-5. MAINTENANCE OF FACILITIES. Under part 147, an AMTS is required to continuously maintain the same standards as those under which it was certificated originally.
This includes the maintenance of all facilities and equipment required for initial certification.
3-6. MAINTENANCE OF INSTRUCTOR REQUIREMENTS. After an AMTS is certificated or has added or dropped a rating, the AMTS must continue to provide an appropriate number of instructors with the ratings and certificates required by the FAA. The AMTS must continue to provide at least one FAA-approved instructor for each 25 students in each laboratory or shop class.
3-7. MAINTENANCE OF INSTRUCTIONAL AIDS. An AMTS must continue to maintain all instructional aids and equipment in good working order and in a condition for safe operation.
Examples of instructional aids include diagrams, visual aids, computers, interactive software, aircraft, and mock-ups of aircraft, engines, and components, as well as actual components, such as magnetos and fuel controls. An instructional aid is not required to meet return to service standards. Broken or deteriorated instructional aids must be repaired or replaced. The school
Par 3-7 Page 20 must continue to provide sufficient instructional aids so that there will not be more than eight students per instructional aid unit at any one time.
3-8. MAINTENANCE OF TECHNICAL DATA REFERENCE MATERIALS. An AMTS should provide a system that identifies the individual by position responsible for updating the technical data/reference materials. The procedure must clearly show the methods for maintaining and upgrading the data.
3-9. MAINTENANCE OF SHOP EQUIPMENT. Shop equipment should be maintained in good working order and be in a condition for safe operation. A system should be in place for routine preventive maintenance and component replacement on all shop equipment.
3-10. MAINTENANCE OF TOOLS AND SPECIAL TOOLS SUPPLY. The school must continue to provide all tools, as required. During school operation, tools may not be removed from the AMTS inventory without being replaced. A system should also be in place to maintain special tools in satisfactory working condition.
3-11. MAINTENANCE OF INSTRUCTIONAL MATERIALS. The AMTS must continue to provide required materials specified in the instructional materials list.
3-12. MAINTENANCE OF QUALITY OF INSTRUCTION. An AMTS must continue to provide instructions of the same quality as it demonstrated to the FAA, during and ongoing after certification. The instrument used by the FAA to measure AMTS instruction quality is a document titled “School Norms vs. National Passing Norms”. The national norm is a measure of the performance of AMTS graduates from each school who are taking the FAA A&P Mechanic Test measured against the performance of other applicants taking the FAA A&P Mechanic Test.
This information is available by review of the following reports:
• School Norms vs. National Passing Norms (8080-08); and
• Aviation Maintenance Test Applicant Listing.
a. Corrective Action. Corrective action may need to be initiated if the percentages fall below those specified in § 147.38(a).
b. Test Performance. While poor test performance alone may not indicate poor instruction, it may be an indication that some aspects of the school operation are inadequate or ineffective.
c. AMTS Norm. Use of the AMTS norm.
d. School Norms. When an individual school norm is significantly lower than the national norm, i.e., in excess of the requirements of § 147.38(a), an asterisk (*) will appear next to the 2 year school norm score on the 8080-08 report. The responsible region/district office may obtain more detailed performance information to assist in determining problem areas by requesting an Aviation Maintenance Test Applicant Listing from the Airman Testing Standards Branch, AFS-630. The 8080-08 report and the Aviation Maintenance Test Applicant Listing data may be shared freely with the school to which it refers.