Par 4-5 Page 33 (and 34)
d. Demonstration Deficiencies. When deficiencies in the demonstration arise, the FAA will provide a written list of the discrepancies to the applicant. Depending on the magnitude of the deficiencies, the FAA may schedule a meeting to discuss in detail the appropriate corrective actions that must be taken. At or immediately following the meeting, the applicant must provide the FAA with a list of all corrective actions taken. No AMTS will be FAA-certificated with outstanding discrepancies. All discrepancies must be corrected before certification may be granted. If the discrepancies cannot be resolved and/or the applicant does not demonstrate compliance with the regulations, the FAA will terminate the certification process and send the applicant a letter of rejection and a list of the discrepancies still outstanding.
e. Termination. If the FAA terminates the application, the applicant must correct the discrepancies and submit a new PASI to reinitiate the certification process.
4-6. CERTIFICATION PHASE.
a. Successful Application. When all the regulatory requirements have been met, the school will be issued an AMTS Air Agency certificate and appropriate OpSpecs. The original FAA Form 8000-4, Air Agency Certificate, signed by the district office manager will contain the name of the school and its ratings. At this time, the FAA will return the AMTS curriculum with each page of the LEP signifying FAA approval with a date and the PI’s stamp, initials, or signature.
b. Surveillance. A newly certificated school should expect that the FAA will inspect and observe the school frequently during the first 90 days of operation to determine compliance with the applicable regulations. The FAA may also identify needed changes in the methods or techniques of the school’s operation.
Appendix 1 APPENDIX 1. GLOSSARY OF TERMS This listing contains clarifications of some of the terms defined in 14 CFR part 147. When used within the context of part 147, these terms apply to Aviation Maintenance Technician School (AMTS) requirements.
1. Accreditation. Accreditation is the process used in U.S. education to ensure that schools, postsecondary institutions, and other education providers meet, and maintain, minimum standards of quality and integrity regarding academics, administration, and related services. This term refers exclusively to schools accredited within the United States.
2. Affiliated. A procedure allowing an AMTS Designated Mechanic Examiner (DME) to administer oral and practical tests to graduates/applicants, without an FAA signature in block V of FAA Form 8610-2, Airman Certificate and/or Rating Application only when a graduation certificate or certificate of completion is presented and the AMTS provides the DME with the certified list of graduates.
3. Asynchronous Learning. The method of teaching that takes place utilizing prerecorded developed training, preserved for the learner to participate in whenever the time is most convenient. Technology such as email, e-courses, online forums, and audio and video recordings make this possible. Asynchronous learning is considered more flexible than synchronous learning.
4. Aviation Safety Inspectors (ASI). FAA aviation safety maintenance inspectors are comprised of two principal inspector (PI) specialties, principal maintenance inspectors (PMI), and principal avionics inspectors (PAI).
a. PMI. The maintenance representative of the FSDO with principal responsibility for the certification and surveillance of a part 147 AMTS.
b. PAI. The avionics representative of the FSDO with principal responsibility for the certification and surveillance of a part 147 AMTS.
5. Aviation Technician Education Council (ATEC). The AMTS industry association.
6. Certificated Instructors. Those instructors who hold FAA mechanic certificates and the ratings appropriate for the AMTS subjects to be taught.
7. Certification. This term refers to AMTSs certificated as an Air Agency by the FAA.
8. Certification Project Manager (CPM). FAA personnel assigned as a team lead during an air carrier or air agency initial certification that provides guidance and written notification to the applicant during each phase of the certification project.
9. Check. To verify proper operation. A check is performed to verify proper operation without the item necessarily qualifying for return to service condition. At an AMTS, the item checked does not have to be the item overhauled.
Appendix 1
10. Common Hand Tools. Small, ordinary tools such as ratchets, sockets, and screwdrivers.
11. Distance Education or Distance Learning. A method of delivering education and instruction, often on an individual basis, to students who are not physically present with an instructor in a traditional setting such as a classroom. Distance learning enables participation access to learning when the source of information and the learners are separated physically by time or distance, or both.
12. Flight Standards District Office (FSDO). The FAA office with geographic oversight of a particular part 147 AMTS.
13. Focused Curriculum. Curriculum directed toward a particular area of the aviation industry.
An example is rotorcraft, Transport Category Agriculture, etc.
14. Instructional Aids. Equipment used to provide instruction. Examples 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.
15. Instruction Hour. The educational unit hour, as used by an AMTS, that consists of a time period of 50 to 60 minutes. This instructional time period conforms to the existing practices at many education institutions.
16. Inspect. An organized examination or formal evaluation by sight, sound, touch, smell or any combination thereof, completed with or without inspection enhancing tools or equipment.
17. Laboratory. Facilities for providing instruction in general principles that may require student demonstrations or participation. Determination of what laboratory equipment is required depends on the subject taught and the teaching level at which it is taught.
18. Letter of Compliance or Statement of Compliance (SOC). A compliance statement listing each applicable part 147 section and providing either a brief narrative or a specific reference within the document(s) describing the manner of compliance with the regulation.
19. Maintenance Training Review Board (MTRB). The MTRB is an advisory board to plan, coordinate, and advise the FAA regarding the certificated AMTS required curriculum specific to part 147 appendices A, B, C, and D.
20. Noncertificated Instructors (Specialized Instructors). Individuals who are not FAA certificated but whom the AMTS has found qualified to teach mathematics, physics, basic electricity, basic hydraulics, drawing, and similar subjects. The applicant is required to maintain a list of the names and qualifications of specialized instructors, and upon request, provide a copy of the list to the FAA.
21. Operations Manual. Document that the institution may use to show compliance with part 147.
Appendix 1
22. Operations Specifications (OpSpecs). OpSpecs are approved documents indicating authorizations, limitations, and certain procedures under which each kind of operation is to be conducted. OpSpecs are maintained in an Internet-accessible program known as Web-based Operations Safety System (WebOPSS).
23. Overhaul. To disassemble, inspect, repair as necessary, and check in accordance with FAA-acceptable instructions; that is, manufacturers’ maintenance manuals, FAA directives, and Service Bulletins (SB). For an AMTS, the overhaul requirement in a teaching scenario does not require the overhauled component to meet approval for return to service mechanical tolerances.
For example, a turbine engine that is not Airworthy or serviceable may be used for instructional purposes associated with component replacements or overhaul practices and techniques, but must not be used for engine run up demonstrations due to potential safety hazards and concerns.
24. Practical Project. A hands-on assignment that requires the use of manipulative skills taught at a teaching level of 2 or 3. A practical project generally does not include non-manipulative activities such as book reports. However, for certain required subjects such as maintenance publications, the use of FAA directives or manufacturers’ data constitutes a practical project.
25. Practical Test Standards (PTS). PTS are a guide for students, instructors, FAA, and examiners to know what is expected on a test.
26. Quality Standards. The performance level at which a student understands their responsibilities and can simulate returning an item to service. However, it is not necessary for the item itself to meet “return to service” standards.
27. Ratings. An AMTS may be certificated for the following ratings: airframe, powerplant, or combined Airframe and Powerplant (A&P). The general portion of the required curriculum is not a rating, but it is a required part of all the ratings.
28. Shop. Facilities for providing instruction on projects taught at teaching level 2 or 3. The shop environment should resemble a typical aviation repair facility.
29. Shop Equipment. Machinery, such as fabricating devices, sheet metal equipment, and battery chargers.
30. Simulated Approval For Return to Service. A measured standard of instructing students’ academic and manipulative skills in which to prepare them with the needed skills to maintain and properly return aircraft, parts, or components to service.
31. Special Tools. Highly specialized tools, such as tensionometers, micrometers, and torque wrenches.
32. Synchronous Learning. Learning that takes place when two or more people are communicating in real time, “live”. Sitting in a classroom, talking on the telephone, and chatting via instant messaging are examples of synchronous communication.
Appendix 1
33. Teaching Levels.
a. Level 1. Level 1 requires knowledge of general principles and instruction by lecture, demonstration, and discussion, but no practical application or development of manipulative skill.
Teaching aids or instructional equipment may include charts, books, diagrams, or other visual teaching aids. If an AMTS chooses to teach level 1 courses incorporating actual components, the components do not have to be operational.
b. Level 2. Level 2 requires knowledge of general principles, limited practical application, and development of sufficient manipulative skill to perform basic operations, as well as instruction by lecture, demonstration, discussion, and limited practical application. This teaching level requires some hands-on manipulative skills and their accompanying actual or simulated components/equipment; but still may be taught primarily in the classroom environment.
c. Level 3. Level 3 requires knowledge of general principles, performance of a high degree of practical application, development of sufficient manipulative skills to simulate return to service, and instruction by lecture, demonstration, and discussion. This teaching level requires hands-on manipulative skill, as well as sufficient and appropriate instructional aids to train the student to develop manipulative skills sufficient to simulate return to service. At this level, the teaching aids must be similar to, or the actual items of, equipment on which the student is expected to develop required skill levels. A level 3 subject cannot be taught solely by lecture in the classroom; the appropriate training aids and hands-on experience must be used.
34. Troubleshoot. To systematically analyze and identify malfunctions, and to identify the source of trouble in an airframe, powerplant, or aircraft component. For the purposes of AMTSs, the item of equipment or simulator training aids must be in operating condition. For example, a turbine powerplant must be operational for the student to troubleshoot.
Appendix 2
Page 1 APPENDIX 2. RELATED REFERENCES
1. RELATED PUBLICATIONS (current editions). Current Advisory Circulars (AC) are available online at http://www.airweb.faa.gov/rgl.
a. AC 20-37, Aircraft Propeller Maintenance.
b. AC 20-77, Use of Manufacturers’ Maintenance Manuals.
c. AC 20-107, Composite Aircraft Structure.
d. AC 43-4, Corrosion Control for Aircraft.
e. AC 43-9, Maintenance Records.
f. AC 43-16, Aviation Maintenance Alerts.
g. AC 43-204, Visual Inspection for Aircraft.
h. AC 43.9-1, Instructions for Completion of FAA Form 337.
i. AC 43.13-1, Acceptable Methods, Techniques and Practices — Aircraft Inspection and Repair.
j. AC 43.13-2, Acceptable Methods, Techniques, and Practices — Aircraft Alterations.
k. AC 65-30, Overview of the Aviation Maintenance Profession.
l. AC 65-31, Training, Qualification, and Certification of Nondestructive Inspection Personnel.
m. AC 91-82, Fatigue Management Programs for In-Service Issues.
n. AC 120-72, Maintenance Resource Management Training.
o. FAA Order 8900.1, Flight Standards Information Management System.
p. FAA Order 8900.2, General Aviation Airman Designee Handbook.
q. FAA-H-8083-30, Aviation Maintenance Technician Handbook—General, Chapter 14, Addendum/Human Factors.
r. FAA-H-8083-32, Aviation Maintenance Technician Handbook—Powerplant.
s. FAA-H-8083-9, Aviation Instructor’s Handbook.
t. FAA-H-8083-31, Aviation Maintenance Technician Handbook—Airframe.
u. FAA-H-8083-1, Aircraft Weight and Balance Handbook,
Appendix 2
v. Human Factors in Aviation Maintenance and Inspection, documents are maintained at the following website: http://www.faa.gov/about/initiatives/maintenance_hf/.
w. Job Task Analysis of the Aviation Maintenance Technician, Northwestern University, The Transportation Center. See: http://www.faa.gov/about/initiatives/maintenance_hf/.
x. The National Study of Aviation Mechanics Occupation (Allen Study). The Allen Study is available to the public through the National Technical Information Service (NTIS), Alexandria, VA 22312 or at http://www.ntis.gov.
y. Type Certificate Data Sheets (TCDS) available at http://av-info.faa.gov.
2. RELATED PARTS OF TITLE 14 OF THE CODE OF FEDERAL REGULATIONS (14 CFR).
a. Part 1, Definitions and Abbreviations.
b. Part 43, Maintenance, Preventative Maintenance, Rebuilding, and Alteration.
c. Part 65, Certification: Airmen Other Than Flight Crewmembers, Subpart D, Mechanics.
d. Part 91, General Operating and Flight Rules.
e. Part 145, Repair Stations.
f. Part 147, Aviation Maintenance Technician Schools.
g. Part 183, Representatives of the Administrator.
Appendix 3 APPENDIX 3. FREQUENTLY ASKED QUESTIONS (FAQ) REGARDING AMTS
CERTIFICATION AND OPERATION
1. Question: How should I include additional items in my curriculum that are above and beyond the subject areas included in part 147?
Answer: You have two options. You can make it part of your curriculum or you can make it a separate class. Subjects may be taught to a higher level in the curriculum than required by part 147 appendices, but if they are taught to a higher level, the school must include them as part of the approved curriculum.
2. Question: What is an exemption from part 147? For which type of items can I request an exemption from part 147 and how does this process work?
Answer: An exemption is a request to the FAA to allow a school to deviate from existing regulations.
NOTE: Currently there are no provisions for waivers.
A school can apply for an exemption for any items governed by part 147.
The process for requesting an exemption is detailed in 14 CFR part 11, General Rulemaking Procedures. The school must submit a request that:
• Clearly defines and specifies the exemption requested;
• Explains why the school is requesting the exemption;
• Explains why it is in the public interest for the exemption to be granted; and
• Explains how, if the exemption is granted, public safety would not be affected.
Also, refer to the FAA Web site, http://aes.faa.gov/, enter “147” into the “Regulation” field, and select “Search” to see examples of past regulatory clarification requests by schools, as well as the FAA responses.
3. Question: Does the rule establish a standardized method of proof of student time and attendance?
Answer: No, neither the regulation nor FAA policy established standardized procedures to record student time and attendance. Each school must develop and have approved by their Flight Standards District Office (FSDO) a method of taking time and attendance for each student.
4. Question: Are the actual student tests required to be kept for 2 years, or only the results of those tests (grades)?
Answer: Only the test grades must be kept for 2 years. By extension, completed laboratory project sheets do not need to be kept for 2 years. As with tests, only laboratory project grades must be retained for that period of time. The generic project sheet or test is a part of the curriculum, and kept with the curriculum.
Appendix 3
5. Question: Do we keep time and attendance records for students’ individual projects or for the block of time required for the subject area?
Answer: There is no need or requirement for time and attendance to be maintained on an individual project basis.
• Time and attendance can be documented on a “subject area” basis, recording only the students’ attendance in the subject area.
• A school’s curriculum should specify total hours for the subject area, the amount of time that is dedicated to classroom, the amount of time that is dedicated to laboratory, and the total number of required projects for that subject area.
NOTE: If a school, in its approved curriculum, specifies hours assigned to individual projects, then time and attendance must be kept on that basis.
6. Question: What guidelines should we use as the basis for writing a part 147 manual?
Answer: Guidelines can be found in the current edition of AC 147-3, 14 CFR part 147, and FAA Order 8900.1, Volume 2, Chapter 12, Certification of a Part 147 Aviation Maintenance Technician School. Refer to http://fsims.faa.gov/.
7. Question: Do the scope and details of the lesson plans have to be included in the AMTS curriculum?
Answer: AMTS curriculum lesson plans are not required to be part of the approved curriculum. Lesson plans should be available upon request by AMTS management and instructors and upon request by the FAA.
8. Question: What is the rationale for not allowing students enrolled in the general curriculum to be administered the general computer test upon completion of that course? I have contacted several part 147 schools/colleges and have found that approximately 50 percent of those queried give general computer tests upon completion of the general course.
Answer: Title 14 CFR part 65, § 65.77 specifies tests for ratings, not the program, in which the student is enrolled. As a result, if a student completes all the general portion hours and completes the airframe, powerplant, or A&P rating and the school issues a certificate of completion for a rating, then the student may take the general test. In other words, to take the general test, the student must have completed a rating plus all the general material and been issued a certificate of completion by the school for at least one rating.
9. Hypothetical Scenario: During a recent inspection, the FAA commented that to be in compliance, training aids must be available and in working order even if the subject is not being taught at the time. The same training aids are used in subjects requiring troubleshooting. If a subject being taught requires a teardown, the school should not be cited for non-compliance.
Appendix 3 Response: Training aids/devices that are required and on the current school equipment list should be in good working order for the course(s) of instruction they are identified and intended to support. Multiple use or different use of training equipment is acceptable as long as the unit is available for each project individually and is not being used for multiple projects at the same time. Some exceptions to this will exist, such as using a complete aircraft for propeller removal while simultaneously checking control surface travel. For such exceptions, the AMTS should ensure the objective of each project is being met and safety is not compromised.
10. Hypothetical Scenario: During a recent inspection, a comment was made that a complaint had been filed and the FAA was required to inspect the facilities. Regulations state that the school is to receive a copy of the complaint listing, the nature of the complaint, and all parties involved. The school had to request a copy of the complaint. We received a notice that we could request a copy from the Freedom of Information Act (FOIA) and pay a fee for the report.
Response: The FAA is not required by regulation to supply any information contained in a complaint filed against a part 147 school. In many cases, the FAA does discuss the nature and content of a complaint with school administrators, but the decision to do so is up to the FAA and is based on the nature and implications of the allegations contained in the document.
11. Question: Section 147.31(a) states a “school may not require any student to attend classes of instruction more than 8 hours in any day…” For schools that have both day and night shift classes, may a school permit a student to attend both classes when the student requests to do so?
Answer: Not normally, but there are exceptions. An exception must be approved by the school’s principal maintenance inspector (PMI) on a case-by-case basis. The FAA/ Aviation Technician Education Council (ATEC) panel believes that a blanket form of approval could compromise the integrity of the quality of instruction. This would allow for special exceptions that the school and student find themselves involved with such as sickness, illness, accidents, family problems, weather, or any other special circumstances.
12. Question: What authority does the FAA have pertaining to the buildings that hold our classrooms and laboratories? I once had an inspector who walked into my hangar and stated that I had to increase the lighting in the area for the students. This was based on his opinion;
no measuring equipment was used to check the actual lumens. Section 147.15 states that facilities must be “…properly heated, lighted, and ventilated…as are appropriate to the rating” sought. Who is he to determine how many lumens or British thermal units (BTU) we use in our buildings? If we meet the local building codes and Occupational Safety and Health Administration safety regulations, are we not meeting the standard?
Answer: What would a reasonable person expect to find in a normal classroom and laboratory environment? It would be apparent if there were a woeful lack of heat or light in the school, but at the same time, the PMI is not trained as a building inspector. What would be more critical to the school would be the school meeting the codes of the city and the state
Appendix 3 that it operates within. The school should be able to show the PMI that it has met the standards by displaying or showing, on request, building permits, building inspections, and any other safety inspection documentation from local fire departments, health agencies, and other regulatory agencies.
13. Question: The FAA/ATEC panel needs to clarify the use of intimidation and ultimatum with the use of ACs and handbooks to enforce “rules.” We find that inspectors tend to deviate from the rule and try to make ACs “regulatory,” rather than useful as suggestions or guidance in the process of working with schools. This tends to give each inspector the space needed to bring individual “causes” into the process and make them appear to have the force of law.
One example is the use of AC 147-3 as the standard that will be used rather than the regulation being the standard and the AC being helpful in that process.
Answer: The current edition of AC 147-3 was developed to further clarify part 147. It is to be used as a guidance. While AC 147-3 is not regulatory, it should be understood that ACs are developed to a standard that is found acceptable, and if the document does not meet the requirements set forth in an AC, then it could be considered not acceptable to the FAA?
14. Question: There needs to be some clarification regarding the use of military surplus aircraft in performing practical projects. While AC 147-3 states that the use of such aircraft is acceptable as long as the model is eligible for an FAA type-certificate, our inspector is telling us that no military surplus aircraft will be used. In our case, we have two twin bonanzas and one Sabreliner that we use as part of our program. Both are aircraft that are type certificated (TC) in civilian use; they are not made differently (as would be a fighter aircraft, for example), and should be acceptable to use. In addition, what difference does it make regarding systems work, such as brake replacement, whether it is certificated or not? We do recognize that, for example, while a sheet metal repair to industry standards would be a completely different issue, it should not make any difference on systems training as noted.
Answer: There is nothing in the rules that prohibits the use of military aircraft for training at a part 147 AMTS, provided the school has at least one complete aircraft of a type currently certificated by the FAA for private or commercial operation.
It is reasonable to assume that systems training in many areas such as brakes, landing gear, hydraulics, and many others, is no different on military than on civilian aircraft. Schools are cautioned that there are subjects where differences exist, such that military aircraft may not be adequate or applicable trainers, for example, documentation research including airworthiness directive compliance and type certification. This is particularly true for aircraft without a civilian counterpart, for example, fighters.
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 Airlines for America (A4A) 104 Training Standard, in use that would be more current in its guidelines than the now quite old Allen Study?