Q: The ACS includes some new knowledge, risk mitigation, and skill elements that are not incorporated into our current part 147 program. The program is unable to procure the equipment necessary to adequately teach these elements in time to meet the Sept. 21 requirement. How are we expected to comply with the new rule if we can’t obtain the equipment in time to align our curriculum to the new mechanic airman certification standard?
 
A: First, since the vast majority of ACS elements are not new, we suggest you triple check that the element is in fact new and it’s not already addressed in the current part 147 curriculum requirements or in the practical test standard. If the element is incorporated in one of those documents, ask yourself how the program is addressing the element now? What equipment is the local DME using to test that element? So long as your curriculum addresses the element, the program is in compliance with the new rule.
 
For truly new elements (we estimate that around 9% of ACS elements are in fact new), part 147 will require that the school “align” curriculum with the standard, but the rule does not dictate how a program imparts the knowledge. The “how” is totally up to the school, including what equipment it decides to use. And just because the element is listed as a required skill in the certification standard, doesn’t mean you HAVE to tie it to a hands-on project. While that might certainly be the best way to impart the skill; for purposes of regulatory compliance, all the program needs to do is ensure the curriculum addresses it. Can it be addressed with a paper project?
 
For instance, the ACS requires schools to “troubleshoot an air-cycle air conditioning system.” While it would be great to have an air cycle machine or training aid to facilitate teaching of that skill, lead times are long and the school may not have the immediate funding to procure the equipment. The rule requires that the element be taught, but does not dictate how it is taught, that is up to the school. In the absence of the ideal equipment, schools must get creative.
 
Perhaps the program illustrates troubleshooting with an unserviceable component donated by an industry partner. It could use an online solution that allows the student to effectively troubleshoot in a virtual environment. It could provide the student with a maintenance manual and discrepancy scenarios for the student to research, troubleshoot, and describe possible repair solutions.
 
These potential approaches are not meant to suggest schools should not procure new equipment, but are a means of compliance in the short term, allowing the program to process and prioritize equipment purchases in the long term, as revised FAA guidance is published (i.e., 8083 handbook revisions) and student outcomes are assessed.
 
It's also important to consider that the FAA written, oral, and practical exams will not test any new ACS elements until next summer. Officials have told said DME minimum equipment lists will not change (at least in the short term). So, as long as the school ensures all ACS elements are addressed on Sept. 21, it has time to “perfect” training to ensure student outcomes meet expectations. In other words, the new rule requires that you teach it, but it won’t be tested by the FAA for another year.
 
In short, new equipment purchases are not mandated by the new part 147. Since the DME minimum equipment list isn’t expected to change, and the mechanic test won’t be revised until next summer, part 147 programs must get creative to ensure each element of the ACS is addressed with on hand or easily accessible resources. So long as the element is addressed, the school will comply with the new rule.

This issue was the topic of an ATEC Aug. 25, 2022 webinar. Check out the recorded version on the ATEC webinar channel.

​Q: We heard that the new part 147 also makes changes to early testing under 14 CFR 65.80. Is early testing going away?
 
A: Section 65.80 is not going away. The regulation will be revised to align with some of the new verbiage in part 147, but not in a way that will impact early testing. Here’s the explanation out of the preamble to the new rule:

Section 65.80 allows AMTS students to take the oral and practical tests prescribed by § 65.79 before meeting the applicable experience requirements of § 65.77, and before the student passes each section of the written test prescribed by § 65.75. The school must show an FAA inspector the student has made satisfactory progress at the school and is prepared to take the oral and practical tests. Additionally, § 65.75 states the student may take the tests prescribed by § 65.79 during the final subjects of the student's training in the approved curriculum. The reference to “approved curriculum” in § 65.80 refers to a certificated AMTS's approved curriculum, which was required under § 147.21 as it existed prior to this interim final rule.
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In accordance with Section 135 of the statute, AMTS curriculums under part 147 will no longer require FAA approval, as reflected in new § 147.17. As a result, the FAA is making a conforming amendment to § 65.80 by removing reference to an AMTS's “approved” curriculum. This amendment will allow AMTS students to continue testing under § 65.80.

Further, § 65.80 permits students to take the oral and practical test prescribed by § 65.79 during the final subjects of the student's training in the part 147 curriculum before the applicable experience requirements of § 65.77 are met and before the student passes each section of the written test required by § 65.75 when the AMTS shows the student's satisfactory progress to an FAA inspector. In the interest of regulatory standardization, the FAA is revising the language from “an FAA inspector” to “the Administrator.” Additionally, the FAA is removing gender references within the regulatory text.
 
Here is how the new 65.80 will read as of Sept. 21, 2022 (the effective date of the new part 147), in line with the edits as described in the preamble to the new direct rule:
 
§ 65.80 Certificated aviation maintenance technician school students.
Whenever an aviation maintenance technician school certificated under part 147 of this chapter shows to the Administrator that any of its students has made satisfactory progress at the school and is prepared to take the oral and practical tests prescribed by § 65.79, that student may take those tests during the final subjects of the student's training in the curriculum required under part 147, before the student meets the applicable experience requirements of § 65.77 and before the student passes each section of the written test prescribed by § 65.75.