Purpose
The Government Relations Committee acts as a resource and interface with the FAA. The committee will assist member schools in resolving issues with the FAA and will present issues to the FAA on behalf of the membership.
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Do you have an issue, question, suggestion or comment for this committee? If so, click the button below to access our contact form.
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Current Members
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Current Issues:
BRCC Receives Make-up Work Policy Clarification from FAA
7/18/12
See the documents below concerning make-up work for students. If you have further questions or discussion contact: Fred D. Dyen, Coordinator Aviation Maintenance Technology Program Blue Ridge Community College 43 Aviation Circle, Hangar 4 East Shenandoah Valley Regional Airport Weyers Cave, VA 24486 Phone: 540-453-2306 Cell: 314.753.1356 Fax: 540.453-2359 
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Quick Links
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FAQs
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: There are 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:
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 number of 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 as the basis for writing the PART 147 Operations Manual?
A: No. Guidelines can be found in Advisory Circular 147-3, as amended, 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 queried 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 pay a 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 equipment was 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 a fighter 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 a completely different issue, it should not make any difference on 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 eligible for 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?
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 require mandatory calibration.
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" e.g. 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 subject 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 completion 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.
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: There are 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 number of 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 as the basis for writing the PART 147 Operations Manual?
A: No. Guidelines can be found in Advisory Circular 147-3, as amended, 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 queried 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 pay a 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 equipment was 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 a fighter 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 a completely different issue, it should not make any difference on 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 eligible for 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
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 require mandatory calibration.
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" e.g. 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 subject 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 completion 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.
