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FAA Q and A
FAA-ATEC PART 147 CLARIFICATION
Frequently Asked Questions
1. Q: How should I include additional items in my curriculum that are above and beyond the subject areas included in PART 147?
A: In this case, you have two options. You can make it part of your curriculum or you have the option of making it a separate class. Subjects may be taught to a higher level than required by PART 147 Appendices, but if they are taught to a higher level, then the school shall include them as part of the approved curriculum.
2. Q: What is an exemption from PART 147? For which type of items can I request an exemption from PART147 and how does this process work?
A:An exemption is a request to the FAA to allow a school to deviate from existing regulations. (Note: Thereare no provisions for waivers.) A school can apply for an exemption for any items governed by FAR PART 147. The process is detailed in CFR 14, Part 11. In summary, the school must submit a request that provides a narrative on the following:
- Clearly defines and specifies the exemption requested.
Why the school is requesting the exemption.
Why it is in the public interest for this exemption to be granted.
- Why, if the exemption is granted, public safety will not be affected.
Also, refer to the FAA website:
http://aes.faa.gov/ which provides examples of past requests for
exemptions by schools, as well as the FAA response.
3. Q: Can a method of proof of student time attendance be standardized?
A: No, the regulation and the advisories make no provision for 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. Q: Are the actual student tests required to be kept for two years, or only the results of those tests (grades)?
A: According to 147-3 paragraph 26a, only the test grades must be kept for two years. By extension, completed lab project sheets do not need to be kept for two years. As with tests,only lab project grades must be retained for that period of time.The generic project sheet or test is a part of the curriculum and those are kept with the curriculum.
5. Q: Do we keep time and attendance records for students, individual projects, or for the block of time required for the subject area?
A: 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 lab, and the total numberof required projects for that subject area.
--Please note--
If a school, in their approved curriculum, specifies hours assigned to individual projects, then time and attendance must be kept on that basis.
6. Q: Do we use the guidelines from AC 121 or from AC 145-3 asthe basis for writing the PART 147 Operations Manual?
A: No. Guidelines can be found in Advisory Circular 147-3, asamended, the FARs as well as the recently released Job Task Analysis (JTA).
7. Q: Do the scope and details of the lesson plans have to be included in the Operations Manual?
A:The school's lesson plans are recommended for availability, but not required to be part of the approved operational manual. Lesson plans are not required to show compliance with the regulations, and they are not to be part of the approved operational manual.
Lesson plans should be available upon the request of the Principal Maintenance Inspector (PMI) and school officials.
8. Q1: What is the rationale for NOT allowing GENERAL
students to be administered the GENERAL computer
test upon completion of that course?
Q2: I have contacted several 147 schools/colleges
and have found that approximately 50% of those
querried give GENERAL computer tests upon
completion of the General course.
A: Part 65.77 specifies tests for ratings, not the
program the student is enrolled in. As a result, if a
student completes all the General portion hours and
completes the A, P 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, in order 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. Q: Training Aids During a recent inspection, FAA
commented that in order 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.
A: Training aids/devices that are required and on the current school equipment list should be in good
working order for the course/courses of instruction
they are identified and intended to support. Multiple
use or different utilization 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 at the same time control
surface travel is being checked. Such exceptions
should ensure that the objective of each project
is being met and, of course, safety is
not compromised.
10. Q: Complaints - During a recent inspection, a
comment was made that a complaint had been filed
and 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 and paya fee for
the report.
A: The FAA is not required by regulation to supply
any information contained in a complaint filed against
a 147school. 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. Q: Part 147.3(a) states "schools 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 can a student request to
go to both classes?
A: Not normally, but there are special exceptions. These would have to be approved by the PMI under special limited exceptions on a case-by-case basis.
It is the belief of the FAA-ATEC panel 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. Q: What authority does the FAA have pertaining
to the buildings that hold our classrooms and labs?
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 upon his opinion,
yet no measuring equipmentwas used to check the
actual lumens. 147.15 states "...must have such of
the following properly heated, lighted,and ventilated
as are appropriate to the rating he seeks..." Who is
to determine how many Lumens or BTU?s we use in
our buildings, if we meet the local building codes and
OSHA safety regulations are we not meeting
the standard?
A: What would a reasonable person expect to find in
a normal classroom and laboratory environment? It would
be apparent if there was 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 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 an} other safety
inspection documentation from local fire departments,
health agencies, and other regulatory agencies.
13. Q: FAA/ATEC needs to clarify the use of intimidation
and ultimatum with the use of AC's and handbooks to
enforce "rules." We find that inspectors tend to deviate
from the Rule, and try to make the AC's "regulatory",
rather than suggested or helpful in the process of working
with schools. This tends to give each individual 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 AC147-3 as the "standard that WILL be used" rather than the regulation being the standard and the AC being helpful in that process.
A: Advisory Circular 147-3, as amended, was developed to clarify FAR PART 147. It is to be used as a guideline. It is not regulatory.
14. Q: 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 ok 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 in civilian use; they are not made differently
(as would be afighter aircraft, for example), and should
be perfectly OK to use. In addition what difference does
it make regarding systems work, such as brake
replacement, etc., whether it is certificated or not. We
do recognize that, for example while a sheet metal repair
to industry standards would be acompletely different
issue, it should not make any differenceon systems
training as noted.
A: There is nothing in the rules that prohibits the use of military aircraft for training at a 147 AMTS, provided
the school has at least one complete aircraft of a type
eligiblefor FAA type certification.
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. Ex. - Research including
AD compliance, type certification, etc. This is particularly
true for aircraft without a civilian counterpart
-i.e. fighters.
15. Q: AC 147-3 was last issued in 1991, and it put great
emphasis on the Allen Study and how it is to be used by
schools to assist in the establishment of their curriculum.
Again, this is a suggestion rather than the Rule, and if a
curricula meets the FAA regulatory requirement, it (the
Allen Study) should not be used in lieu of the Rule to say
that the curricula does NOT meet the requirements. Is
there a more recent guideline, such as the ATA 104
Training Standard, in use that would be current in its
guidelines than the now quite old Allen Study?
A: Schools may use the more current JTA Study from Northwestern University to help develop or update their
curriculum. Schools should be sure, however, to meet the
requirements of PART 147 regulations as they use other "studies" for guidance. To access the Northwestern JTA
Study on the web: http://hfskyway.faa.gov
16. Q: Under Airframe Systems and Components, Cabin
Atmospheric Control Systems ? C34 and C35, has always
presented a challenge for us?Both seem to be same with
the exception of 33 mentioning air cycle machines. So,
under C33, we cover cabin atmospheric control systems
for both, large turbine engine aircraft with air cycle
machines as well as smaller recip engine aircraft that
are supercharged/turbocharged along with combustion
heaters, etc... We suggest C34 be deleted.
A: The redundancy has been previously identified. This is to be addressed by the FAA at the next revision.
17. Q: Is 1900 hours a minimum or maximum number of hours permitted under 147?
A: 1900 hours is the minimum. Schools may provide
additional hours at their discretion to meet institutional
program objectives or align with specific industry needs.
18. Q: The FAA has the responsibility to enforce the
content in the school?s PART 147 operations manual.
Can the following items be omitted from the manual
and kept on file at the school?
- List of instructors
Equipment list
Forms created and used by the school
- Other
A: The operations manual is the official document of
the school; it is not part of the approved curriculum.
The operations manual should reference the instructor
list and where it is kept at the school. The school
should be able to provide the PMI upon request a
current list of the instructional staff. It should discuss
the lesson plans and where they would be kept for
availability of the PMI on an inspection visit. The
equipment list should be discussed in the operational
manual and it should be kept current and available to
the PMI upon their request. The Student manuals
should not be included as part of the operational
manual. The methods of recording and tracking time
and attendance should be in the operations manual,
but the records themselves should be kept separate.
The operations manual should address the administering
of the curriculum and 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. Q: If a school and their PMI disagree on the
interpretation/enforcement of a particular 147
regulation, will the 147 clarification group of ATEC
and the FAA resolve it?
A: No. All attempts should be made to resolve a
disagreement at the local/regional level. The school
should contact the local PSDO office manager or, if
the dispute continues, contact the FAA in Washington
for a regulatory interpretation. Hopefully, some of the
other clarification answers in this document will be
helpful in resolving a school-PMI disagreement. This
current ATEC-FAA group may be brought together from
time to time to help clarify particular issues, but they
are an ad hoc advisory group. The FAA in Washington
will make all final determinations.
20. Q: A school overseas is modeled after 147. A
graduate of that overseas school applies for admission
to a 147 school. Can the 147 approved school award
credit towards a 147 approved program base on
evaluation of transcript and/or proficiency and/or
combination of the two methods?
A: Advisory Circular 147-3, as amended, as well as
FAR Part 65 clearly state that only schools in the
United States and Canada may transfer credits for
training. If a student outside of the United States
and Canada has aviation experience, then such
experience may be evaluated and 147 credit awarded
based on that aviation experience.
21. Q: Can the PMI be a member of the school's
Advisory Board be a nonmember but attend meetings?
A: 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.
22. Q: When an inspector came in, he inspected our
school as if we were a repair station returning everything
to service. All of our gauges are required to be calibrated.
The battery charger was required to be calibrated also
torque wrenches, measuring instruments, and measuring
tools. We are a school, not a repair station. All the
gauges located on hydraulic boards must be calibrated.
They don't even have 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 efficiency.
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 lend itself easily 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 such tools
other than a simple statement in the AC or Handbook
stating that a calibrated tool procedure is a
requirement when there is no mention in the rule
regarding this as such.
A: Some level of calibration is necessary-depending
upon 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. Not all
tools/gauges should be mandatorily calibrated.
23. Q: FAR Part 147.21, Paragraph B states: "The
curriculum must offer at least the following number of
hours of instruction for the rating shown" eg. General
400 hours, Airframe 750 hours and Powerplant
750 hours. Does the FAR directly state that a student
must "attend" 1900 hours of instruction from a school?
The FAA requires the schools to break down the 1900
hours even further into hours of instruction for each
{ubject taught. If a student misses a small amount of
training hours in a particular subject area but still
completes all of the projects and passes the subject
tests, should the school be able to award the student
hours of curriculum training rather than the hours
of attendance?
Another interpretation of the regulation is that the
curriculum needs to be designed around 1900 hours
of training. The student should not need to attend the
required hours for co}pletion of the subject area if
the student demonstrates knowledge through test and
competencies through practical projects.
A: This question is still under review by the joint
ATEC and the FAA working group.
24. Q: 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, 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
who took a financial hit to start the schedule in
January. After several discussions with the FAA,
the decision regarding the "50 minute" clock 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 determined by the FAA Regional
Office in Oklahoma.
A: The "50 minute hour" is based upon the
Carnegie rule of instruction that a 50 minute
instructional period maybe combined with a 10
minute passing time to equate to an hour of
instruction. The question here relates to two items,
first the interpretation of the 50-minute hour and
then the approval of schedule change. Historically
the 50-minute hour must be tied to the 10-minute
passing time. The school in the past has not been
able to bank the passing time and offer longer
breaks at a greater time interval. The school may
offer a 50-minute educational period with a
10-minute passing time and then take a second
10-minute passing time with the next 50 minutes
of instruction tied to the second passing time.
The second part of the question is based upon
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
FSDO has a responsibility to reply to the school's
request in a prompt manner. It is required that the
request and the approval be in written format for
the benefit of both parties to avoid confusion and
any misunderstandings.
25. Q: 147.21(b) states "instruction unit hour will
not be less than 50 minutes in length." Could we
teach for 150 minutes and then give the students
a 30 minute break and have it count for 3 hours?
Answer. Yes, but after the 30 minute break class
must continue, i.e. they could not leave for the day.
A: When FAR 147 was revised in 1992 the
50-minute hour was specifically defined in an attempt
to standardize hour requirements for curriculum
approval and management. Prior to this change many
schools could not give any breaks without adding
the break time outside of the approved number of
house. The 50-minute hour is in fact a 60-minute
hour which is used in most education and training
environments throughout the country. In addition
to standardization, the intent was to provide a better
learning environment for maintenance teachers and
students by allowing for breaks without penalty in
the laboratory and especially the classroom/lecture
portion of the A&P program. The 10 minutes allowed
for breaks during the day should not be used to
shorten the students day or individual classes but
rather to improve the learning process.
26. Q: A FSDO stated that one of our schools must
graduate students when they have completed the
Part 147 program, even though the student hasn't
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 FAR Part 147?
A: A school may require students to meet certain
requirements and/or obligations prior to issuing a
graduation certificate, diploma, or degree. These
may be in addition to completing the required
147 curriculum.
A common example is that most schools require
that all financial obligations of a student be met
prior to issuing transcripts of certificates, diplomas
or degrees.
The FAA believes this requirement is between the
school and the student. The student cannot test
without this proof of graduation, and nothing
requires the school to graduate a student who has
not met all school obligations.
27. Q: 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 1900 hours?
A: The answer is yes. This is very clear.
Referencing AC 147-3, chapter 2, pg. 12, G-3;
as well as 8300.10 Vol. II, chapter 187, pg. 2
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. |
